ML20079F588

Twenty-fifth Set of Interrogatories to Nrc.Related Correspondence

ML20079F588
Person / Time
Site:	Clinch River
Issue date:	06/04/1982
From:	Finamore B, Weiss E HARMON & WEISS, National Resources Defense Council, Sierra Club
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20079F592	List: ML20079F588 ML20079F595 ML20079F601 ML20079F611 ML20079F634 ML20079F655
References
NUDOCS 8206080099
Download: ML20079F588 (40)

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RELATEd CORRFSPONDENCM l

June 4, 1982 1

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Marshall E. Miller, Chairman Gustave A. Linenberger, Jr.

Dr. Cadet H. Hand, Jr.

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In the Matter of )

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) Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY ) j PROJECT MANAGEMENT CORPORATION )

TENNESSEE VALLEY AUTHORITY )

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(Clinch River Breeder Reactor Plant) )

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NATURAL RESOURCES DEFENSE COUNCIL, INC.  ;

AND THE SIERRA CLUB TWENTY-FIFTH SET OF INTERROGATORIES TO STAFF Pursuant to 10 CFR S 2.740b, and in accordance with the Board's Prehearing Conference Order of February 11, 1982, Intervenors, Natural Resou'coe Defense Council, Inc. and the Sierra Club, request : _ t.e attached interrogatories be answered fully , in wi. tin s 2,ud under oath, by one or more officers or employees of Staf f wno has personal knowledge thereof or is the closest to having personal knowledge C)b thereof. If the interrogatories are ansaered by more than one /

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• person, whether or not he or she verified the answers, and whether or not he or she is an officer or employee of Staff, such person's name and title should be set forth together with an identification of which interregatories he or she is responsible'for. ,

Each answer to an interrogatory shall be preceded by a copy of the particular question to which the answer is responding.

Each question is instructed to be answered in six parts, as f ollo ws .

Answer to Question  :

(a) T = Jiide the direct answer to the question.

(b) 'dentify all documents and studies, and the particular parts thereof, relied upon by Staf f, now or in the past, which serve as the basis for the answer. In lieu thereof, at Staff's option, a copy of such document and study may be attached to the answer.

(c) Identify principal documents and studies, and tne particular parts thereof, specifically examined but not cited in (b). In lieu thereof, at Staf f 's option, a copy of each such document and study may be attached to the answer.

(d ). Identify by name, title and affiliation the primary Staf f employee (s) or consultant (s) who provided the answer to the question.

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o (e) Explain whether Staf f is presently engaged in or intend to engage in any further, ongoing research program which may af fect Staf f's answer. This answer need be provided only in cases where Staff intends to rely upon ongoing research not included in Section 1.5 of the PSAR at the LWA or construction permit hearing on the CRBR. Failure to provide such an answer means that Staff does not intend to rely upon the existence of any such research at the LWA or construction permit hearing on the CRBR.

(f) Identify the expert (s) if any, which Staff intends to have testify on the subject matter questioned, and state the qualifications of each such expert. This answer may be provided for each separate question or for a group of related questions. This answer need not be provided until Staf f has in fact identified the expert (s) in question or determined that no expert will testify, as long as such answer provides reasonable notice to Intervenors.

As used herein, " documents" include, but are not limited to papers, photographs, criteria, standards of review, recordings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, notes and minutes of meetings or of conversations or of phone calls, interoffice, intra-agency or

interagency memoranda or written communications of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical recording devices, notes, exh ibits, appraisals, work papers, reports, studies, opinions, surveys, evaluations, projections, hypotheses, formulas, designs, drawings, manuals, notebooks, worksheets, contracts, agreements, letter agreements, diaries, desk calendses, charts, schedules, appointment books, punchcards and computer printout sheets, computer data, telecopier transmissions, directives, proposals, and all draf ts, revisions, and differing versions (whether formal or informal) of any of the foregoing, and also all copies of any of the foregoing which dif fer in any way (including handwritten notations or other written or printed matter of any nature) from the original.

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INTERROGATORIES Contention 1

1. Please identify and provide all correspondence, including all reports and lists of questions submitted to Staf f by NRC l

consultants since July 15, 1976, related to reliability assesments which may be applicable to the CRBR or a reactor of the general size and type proposed, other than those related to the CRBR Reliability Program as described in the PSAR.

a. Identify each report described above which Staff may rely upon for purposes of the LWA-1 proceeding.

2. Please complete Staff's updated response to Interrogatories

1. I . ( 1- 4 ) , II . ( 1- 2) , III . (1-3 ) , V.(1-3), and VI(I) of ILntervenors' Fourteenth Set of Interrogatories to NRC Staff.

3. If Staff does not intend to update Interrogatories #I.(1-4) of Intervenors' Fourteenth Set of Interrogatories to Staff,

a. Will any of the existing data referred to by Staff in its original answer to Interrogatory #I. (1-4) of Intervenors' Fourteenth Set of Interrogatories (Staff Response, p. 2, line

13) be relied upon by Staff during the LWA-1 hearing? If so, identify such data, referring to documents to the fullest extent possible,

b. Identify the means of " extrapolating" such existing data referred to by Staf f in its original answer to Interrogatories #I. (1-4) (Staf f Response, p. 2, line 13) .

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c. Describe in. full detail the " review process" referred I

to by t.aff in p. 2, line 8, of its response to Interrogatories

1. I.(1-4) of the Fourteenth Set that will be used for purposes of the LWA-1 proceeding in assessing the Staff goal referred to in that response. Identify each specific document that Staf f may rely upon in this review process.

4. If Staf f does not intend to update Interrogatory II.2 of the Fourteenth Set,

a. How does Staff reconcile the estimated overall unreliability of shutdown systems for research and experimental reactors (10 -4 per reactor year) of WASH-1270 with the findings in the proposed ATWS rule (4 6 Fed. Reg. 57521 (Nov.

C 24, 1981))?

b. Quantify, if possible, the higher availability that can be achieved with two adequate and redundant shutdown systems, as compared to the 10-4 per reactor year estimate above.

c. Quantify, if possible, the higher availability that will be achieved with two adequate and redundant shutdown

-4 systems, as compared to the 10 per reactor year estimate above.

5. Identify all " components and systems exist [ing] in other areas of industrial technology" which provide guidance to Staf f as described in its original response to Interrogatory III of

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the Fourteenth Set (Staf f response, p. 5, lines 4-7, Dec. 6, 1976), and describe in detail the guidance provided by each such component and system. Identify all documents relied upon by Staff in answering the question.

6. Identify each document upon which Staf f intends to rely in determining the initiators of CDAs.

7. Identify which of the above documents, or other documents, Staf f relies upon to ensure that all CDA initiators have been identified for a reactor of the general size and type as the CRBR.

8. Provide updated answers to Interrogatories VII, VIII, and IX of Intervenors' Fourteenth Set of Interrogatories to Staff.

9. Explain in detail the reason for the changes in Staff's response to Requests for Admission 6-30 of September 16, 1976 (response of April 28, 1982, p. 7), and describe in detail Staff 's evaluation of " applicable portions of the Commission's regulations" referred to in such response. Indicate the extent to which such evaluation will be performed for purposes of the LWA-1 proceeding.

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10. In Staff's response to Requests for Admission 31-71 dated September 16, 1976 (and determined to be still applicable by Staf f as of April 28, 1982), Staff stated that:

For the specific accident paths of pressure vessel failure and anticipated transients without scram, we have, however, analyzed available operating data to derive probabilities which we consider to be reasonable estimates of the likelihood of occurrence of these events.

Identify and provide the analyses of available operating data, and probabilities derived from such analyses, referred to in this statement. Describe the extent to which such probabilities and analyses (or portions thereof) will be relied upon for purposes of the LWA-1 proceeding.

11. In Staff's response to Request for Admission 76, dated September 16, 1976 (and determined to be still applicable by Staff as of April 18, 1982), Staff stated that:

In order to achieve comparability with LWRs

... and in order to account for the unique aspects and differences of the CRBRP, vis-a-vis LWRs, the staf f admits that more limiting requirements than existing LWR

. criteria may need to be achieved.

Describe in detail each " existing LWR criteria" that may be insufficient, and each "more limiting requirement" for CRBR that may have to be achieved according to this statement.

12. In Staff's response to Interrogatory VIII of Intervenors' Fourteenth Set of Interrogatories (not yet updated) , Staff stated:

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. [P] robabilistic and reliability methods are I

used where appropriate as one of a number of techniques to aid our engineering judgment in the safety evaluation of reactors.

Identify and describe in detail each instance in which the Staff intends to use probabilistic and reliability methods in its review for purposes of the LWA-1 proceeding.

13. In Staff's response to Interrogatory 3 of Intervenors' Twentieth Set of Interrogatories to Staff, are the referenced criteria approved and finalized by Staff?

14. Identify in detail each of the " suggested modifications for evaluations in U.S. reactors" referred to by Staff in its response to Interrogatory 11 of the Twentieth Set.

15. Explain Staff's response to Interrogatory 19 of the Twentieth Set in light of the f act that the May 6, 1976, letter from Denise to Caffey was written prior to the Three Mile Island accident and the Commission's proposed rule on degraded cores (45 Fed. Reg. 65474 (Oct. 2, 1980)).

16. Identify the extent, if any, to which the performance of foreign reactors will be relied upon by the Staff to provide ascurance that

a. the CRBR can be built and operated to implement the Staff's design criteria;

b. CDAs should be excluded from the CRBR design basis.

17. Please answer Interrogatory 21 in light of the Staff's admission that the Appendix A General CRBR Design Criteria "do not specifically describe design criteria" (Response to-Interrogatory 4 of the Twentieth Set) and in light of the ACRS statement that the design criteria process "does not really address the safety issues; it addresses some artificial things and stops there." (Transcript of ACRS Meeting, March 30, 1982,

p. 53.)

18. Identify the " goals of the Applicants' out-of-pile testing program" referred to in Staff's response to Interrogatory 24 of the Twentieth Set. Identify and produce all documents in which such goals are discussed. Any reference to the PSAR should include specific references to the applicable section(s) and page number (s) .

19. Identify and provide all analyses t orming the basis of Staff's opinion (in response to Interrogatory 27 of the Twentieth Set) that the double-ended rupture of the primary cold leg piping is not a DBA for the CRBR despite the fact that it is a DBA in light water reactors.

20. What is the probability of a double-ended rupture of the primary cold leg piping in:

a. LWRs?

b. the CRBR?

c. a reactor of the general size and type as the CRBR?

Describe the basis for determining this probability and identify and provide all documents related to this determination.

21. Identify and describe Applicants' " development program" described in Staff's response to Interrogatory 24 of the Twentieth Set. Identify and produce all documents explaining or discussing this developmental program. Describe the extent to which Staff has examined the principal features of this development program and identify each Staf f employee or consultant participating in such review.

22. What is the accident that corresponds in terms of risk to the LWR double-ended rupture of the primary cold leg piping in

a. the CRBR?

b. a reactor of the general size and type as the CRBR?

How is it determined that these accidents provide comparable risks? Identify and provide all documents relating to your ans we r .

23. Explain in detail what is meant by Staff's statement (in response to Interrogatory 43 of the Twentieth Set) that:

It is also possible to have similar dedicated systems which take their intake and return at some point that would not suffer from the same disadvantages as the DHRs, if it is found necessary to devise a new approach.

In particular, describe the "similar dedicated systems" referred to in that statement. Does the CRBR contain such systems? If so, identify each such system.

24. Identify each abnormal occurrence in foreign or domestic breeders, identifying any departures by the system from its intended method of operation and explain the bases for Staff conclusions as to the relevance of that experience for its CRBR analysis.

25. During the ACRS Meeting of May 5, 1982, Mr. Cardis Allen stated that:

The Staff believes that the best way to proceed with its reassessment of the new CRBR design and its impact on CDA objectives is to use the most current analytical tools together with the best available data, to provide a new evaluation basing it all on best estimates of all parameters.

A best estimate calculation is a somewhat dif ferent approach than has been used in the past by us. [ACRS Transcript, May 5, 1982, pp. 431-32.]

a. Describe in detail (1) the "best estimate approach

("new approach") , (2) the approach used in the past ("old approach"), and (3) whether the old approach was utilized in the analyses performed in NUREG-0122.

b. What is the basis for selecting the new approach?

c. What is the basis for believing that the new approach is better than the old approach?

d. Will t,he new approach provide a greater or smaller margin of safety than the old approach? Provide the basis for your answer to this question.

e. How will uncertainties be treated under the new approach?

f. When did the Staff decide to adopt the new approach? -

g. How did the Staf f decide to adopt the new approach?

h. Identify all persons involved in selecting the new approach.

i. Would the "new approach" be utilized if the Bord decided that the CDA should be a DBA?

j. Why was the old approach initially adopted if the new approach is considered superior?

k. Was the old approach adopted in part because the CDA was considered a DBA at the time?

26. Identify each and every regulatory guide, regulation, or other regulatory standard or guidance that will be used by Staff to assure a very low probability of failure for the breeder reactor shutdown systems.

27. Describe each difference in the required timing of shatdown systems or other dif ferences in shutdown systems requirements between LWRs and LMFBRs. Identify and provide each and every document in the possession of Staf f whicn describes the shutdown system requirements f or LWRs or LMFBRs.

28. In light of the f act that Staf f 's updated answers to earlier discovery requests indicate that Staf f will rely primarily on the defense-in-depth approach in justifying its exclusion of CDAs from the design basis, please answer the following question:

I. Has Staff performed any assessments (since April 25, 1977) of the adequacy of Applicants'

a. proposed dual containment system;

b. proposed two independent reactor shutdown systems;

c. proposed two independent decay heat removal systems;

d. proposed means to detect subassembly f aults, cope with these faults, and protect against subassembly f ault propagation;

e. proposed means for insuring heat transport system integrity;

f. proposed means-for insuring heat transport system integrity, including systems for leak detection, provisions for pre-service and in-service monitoring, and long-term materials monitoring;

g. proposed means for protecting the containment system from the ef fects of sodium releases in the equipment cells.

II. If the answer to any of the above interrogatories is yes, (i) identify the person (s) who performed the review; (ii) provide the date(s) during and upon which such review was performed and/or completed;

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(iii) identify and produce all such assessments and any and all documents in the possession of Staf f relating thereto.

If these assessments are not in written form, describe their methodology, content, and conclusions.

29. Has Staff performed any qualitative or quantitative analyses (e.g., probabilistic risk assessments) since April 23, 1977, to assess whether the inclusion of

a. two separate, independent, redundant, and diverse shutdown systems;

b. two independent reactor shutdown systems;

c. two independent decay heat removal systems;

d. means to detect subassembly f aults, cope with these f aults, and protect against subassembly fault propagation;

e. means for insuring heat transport system integrity;

f. means for insuring heat transport system integrity, including systems for leak detection, provisions for pre-service and in-service monitoring, and long-term materials monitoring;

g. means for protecting the containment system from the effects of sodium releases in the equipment cells; will reduce the probability of a CDA sufficiently so that it may be excluded from the design basis, particularly in lignt of post-TMI concerns with regard to human error, systems interactions, and common mode f ailure? If the answer to any of

4 these interrogatories is yes, identify and provide such analyses and any and all documents related thereto. If these analyses are not in written form, describe their methodologies, content, and conclusions.

30. If the answer to any of the above interrogatories is no,

a. Explain in detail why Staf f has not performed such analyses;

b. Explain whether and when Staff intends to perform such analyses;

c. Identify the precise licensing stage, if any, for which Staff believes such analyses are necessary;

d. Explain the precise extent, if any, to which Staff intends to rely upon a review of Applicants' quantitative analyses of the CRBR shutdown systems' adequacy in determining whether the CDA should be excluded as a DBA.

31. Regarding Interrogatory 10' of Intervenors' Twentieth Set of Interrogatories to Staf f, explain whether and how Staf f independently verified that all favorable reports were accurate and all unf avorable reports were provided.

32. Regarding Interrogatory 16 of Intervenors' Twentieth Set to Staff, identify and provide all documents in the possession of Staff relating to the " reliable evidence of the performance of foreign reactors" referred to by Staf f in its response.

33. Regarding Interrogatory 23 of Intervenors' Twentieth Set to Staff, describe in detail every f actor, document, test result, study, or other information upon which Staf f relies for its conclusion that " feasible [ engineering) solutions in the four key areas are available." Identify and provide all documents in the possession of Staff relating to such factors, test results, studies, or other information.

34. Regarding Interrogatory 45 of Intervenors' Twentieth Set of Interrogatories to Staff, identify, and provide all documents in the possession of Staff related to each abnormal occurrence, identifying any departure by the system from its intended method of operation.

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Contention 2

35. In response to Interrogatory 49(c) of the Twentieth Set, Staff provided a " list of assumptions used by Staff in calculating the doses in Class 8 and 9 accidents."

a. Explain why many of the assumptions refer to " PARALLEL DESIGN ONLY."

b. Is this list a complete list of assumptions used by the Staff? If the answer is no, provide all the assumptions that are missing, in particular the assumptions used in calculating doses from Class 9 accidents.

36. Identify and provide any analyses of the W-2 test performed by Staff or consultants.

37. Identify and provide the " preliminary work" performed by Staff indicating a " potential problem for end of cycle core and for the forced mid-plane rupture" f or "10g per second ranges and on up" (see ACRS Transcript, May 5, 19 8 2, p . 416, statement of Mr. Bell) .

38. Does Staf f believe that TOP and LOF events for the BOC-1 and EOC-4 core configurations represent bounding evaluations in terms of the CRBR heterogeneous core energetics potential?

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39. For initiating phase assessments of TOP events at the BOC-1 and EOC-4 core configurations, what does Staf f believe are the largest values one should use to conservatively bound the energetic potential for these core configurations?

40. Describe in detail the analytical approach you are currently using to describe the meltout and large-scale pool phases of CDAs for the CRBR heterogeneous core and for a reactor of the general size and type as the CRBR.

41. With regard to the post-initiating phases (beginning of fuel motion) of the CRBRP heterogeneous core, provide the results of all calculations made to date by Staf f or consultants using the SIMMER-II code and identify and provide any and all analyses of these calculations.

42. What codes, if any, does Staff intend to use to simulate reactor-material boilup situations?

43. With regard to the initiating phase of TOP CDA energetics for the CRBR heterogeneous core, I

a. discuss the implications of the W-2 test;

b. pr ovide the results of all calculations made to date by l

l Staff or consultants of TOP CDAs, identifying in each case the reactivity insertion rate, location of pin failure, state of

f CRBR core (e .g . , BOC- 1) , and all other assumptions considered important with regard to CDA energetics for each of these calculations.

44. Provide a response to the last paragraph (including subparts a-c) of Interrogatory 83 of Intervenors' Twentieth Set to Staff.

45. Regarding Interrogatory 49(c) of Intervenors' Twentieth Set to Staff:

a. Identify and provide all input data, computer codes (if applicable) , formulas, notebooks, calculations, details of calculations, and other documents used by Staff to calculate the dosages appearing in FES Table 7.2 (e.g., the 279 man-rem estimated bone dose to population in a 50-mile radius for a Class 8.5 accident) .

b. In the above answer, display all the arithmetic used in the calculations, each computer code, input to computer codes, hand calculation, algebraic equation, and the value of each-parameter of the equation.

The purpose of this interrogatory is to find out if it is possible for an outsider to reproduce the FES results, and to determine whether the assumptions underlying the FES calculations are correct.

46. With respect to the following requests for information. we are concerned with four distinct validations relative to the models and computer codes:

i) Validation that the code's output is the correct numerical calculation that should result from a given set of input data and the model assumptions; ii) Validation of the models against actual experimental data; iii) Validation that the models can be extended to the CRBR; and iv) Validation that the input assumptions for the CRBR case are adequate with respect to the CDA analysis, i.e., are supported by experimental evidence. By " adequate" here and below, we mean that the calculations will not underestimate the CDA work potential (i.e., forces and resulting energetics of a CDA) or overestimate the containment capability of the reactor with respect to a CDA.

I. With respect to each of the following codes and each subroutine of each of the following codes:

(A) SAS-3D (B) SAS-4A (C) EPIC (if not included in SAS-3D or SAS-4A (D) SIMME R-II please provide the following information:

1) Is the Staff (including consultants to the Staff) utilizing the code (or subroutine) in its CDA analyses of the CRBR?

2) If not, why not?

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3) If not, identify the code or codes (subroutine or subroutines) that the Staff (including consultants) is utilizing in lieu of the rejected codes.

4) If the code (subroutine) is being utilized identify all codes (subroutines) that the Staff (including consultants) is utilizing to augment the analyses performed by the code (subroutine) in question.

With respect to each of the codes and each subroutine or each of the codes utilized by the Staff (including those identified above as (A) and (B) and those identified in 3) and

4) above) , please provide the following information:

5) Complete, current documentation (i.e., a writeup) of the codes and the subroutines.

6) Identify, by name and affiliation, the author, or authors, of each model, subroutine, or portion of each subroutine, which each contributed or worked on.

7) Identify by name and affiliation (including org anization, division, branch, title, e tc. ) each Staff member or consultant that has intimate working knowledge of the code and each subroutine, or parts thereof, including its validity.

Where more than one person is involved, delineate which portion of the code or subroutine with which each has an intimate work ing knowledge.

8) Describe fully the procedures by which the Staff has assured itself and continues to assure itself, that the various computer programs (codes) accurately reproduce the models (see validation i) above) .

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9) Indicate which models (including subroutines, or portions of subroutines) have not been validated as described in Validation 1) .

10) Indicate the models (including subroutines, or portions of subroutines) or assumptions that have not been validated as described in Validation i) .

11) For each model, portion of the model, or assumption that has been validated (against experimental (or other) data, see Validation ii) above), describe fully a) the procedure by which it was ,alidated, b) the results, including all uncertainties and limitations of the validation, and c) the source of the experimental or other data that was used in the validation.

12) Explain fully a) all instabilities in the numerical performance in the models, b) what causes them, c) how they are avoided, and c) the extent to which this introduces uncertainties in the calculations and limits the validity of the model.

13) To the extent that any answers to the above questions are based on referenced material not previously provided, please supply the references.

14) Explain whether NRC is presently engaged in or intends to engage in any further research or work which may af fect the answer. Identify such research or work.

15) Identify the expert (s) , if any, whom the Staff intends to have testify on the subject matter questioned.

State qualifications of each such expert.

II. With respect to the Interrogatories identified above where final information was not provided, please provide the following information:

i) What is Staff's present (preliminary) assessment in these areas?

ii) What ire the uncertainties that prevent l Staff f- making a final assessment in these areas?

iii) What is the precise information that Staff requires to resolve these uncertainties?

iv) What are the outstanding questions or requests for information to Staff in these areas?

l v) What were the outstanding questions or requests for information to Applicants in f these areas at the time of preparation of Staff's response to the Second and Third Sets of Interrogatories?

vi) With respect to (5) above, what information has been subsequently supplied by the Staff?

vii) In addition to the request for ir. formation from Applicants, is the NRC presently engaged in other research related to these areas? Does the NRC intend to engage in such research in the future?

4 Contentions 1, 2, and 3

47. With respect to each major unresolved safety issue indicated in Interrogatory 11 (Contentions 1, 2, and 3) of In tervenor s' Eighteenth Set of Interrogatories to Applicants, indicate the extent to which Staf f agrees or disagrees with Applicants' position (as indicated in Applicants' responses to Interrogatory 11, filed May 20, 1982) regarding whether such safety issue has been resolved. Explain the reason;s) for your position, and, for each issue Staff believes has not been resolved, explain in detail what work remains to be done in order to resolve that issue.

Contention 4

48. What specific actions have been taken to assure that DOE and NRC safeguards are " equally credible and comparably

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effective" (see Applicants' Response to 16th Set of Interrogatories, p. 13) ?

49. What is the " sufficient information" which Staff claims is available to enable it to make judgments with regard to the adequacy of safeguards throughout the fuel cycle (see Staf f's Updated Answers to 6th Set of interrogatories, p. 4)?

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50. State shat criteria, if any, Staff proposes to use to assess the " reasonableness" of safeguards on a " systems basis" (see Staf f 's Ans sers to 23rd Set of Interrogatories, p. 1-2).

51. Describe the specific steps that could be taken to upgrade physical security measures "within hours" (see Staf f 's Answers to 23rd Set of Interrogatories, p. 5) . What constraints are there on the ability of the Commission to take such steps?

52. What are the grounds for Staff's conclusion that details with respect to ground forces are " unnecessary" to make NEPA judgments (see Staff's Updated Answers to 13th Set of Interrogatories, p. 10)?

53. What criteria must be met for Staf f to conclude that there is a " reasonable assurance" that DOE will comply with safeguards regulations (see Staff's Answers to 22nd Set of Interrogatories, p. 12) ?

54. Does Staff agree that Applicants' combination of controls means that diversion attempts should be detected in time to interrupt them (see Applicants' Updated Response to 8th Set of Interrogatories, p. 36)? If so, why? If not, why not?

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55. In light of Intervenors' Updated Responses, dated April 30, 1982, to discovery by NRC Staff (particularly Interrogatories 8 and 9), state whether you agree or disagree with the following statements:

a. Small quantities of plutor.ium can be conve:ted into a nuclear bomb or plutonium dispersion device which, if used, could cause widespread death and destruction.

b. Plutonium in an easily useable form will be available in substantial quantities at the CRBR and its supporting fuel cycle facilities.

If you disagree with all or part of either statement, state the basis for such disagreement.

Contention 5

56. Explain in detail why the San Onofre plant was chosen for the LWR comparison study, as referenced in Staff's reponse to Interrogatory 8 of Intervenors' Ninth Set of Interrogatories to Staff. Explain in detail the purpose of performing an LNR comparison study, the factors that were compared, and each and every dif ference between LWRs and LMFBRs that was taken into account by Staf f during the LWR comparison study.

57. Describe in detail the methodology, assumptions, and data used, the results reached, and the reasons for Staff's conclusions in its preliminary evaluation and comparison of the

San Onof re nuclear plant DBA with the CRBR. Identify and provide any and all documents in the possession of Staf f relating to this LWA comparison study.

58. Has Staff performed any analysis of the Clinch river site, using currently available population and meteorological data, to determine whether the site would be considered suitable for a reactor of the general size and type as the CRBR if a CDA were considered a DBA? If the ansker is yes, identify and provide each such analysis and all documents related to such analysis, and describe in detail the results reached by such analysis. If the answer is no, explain why Staf f has not performed such an analysis, given that its review of CDA accident energetics is not yet complete.

59. Provide the information requested below for each of the following facilities:

A. Oak Ridge National Laboratory, B. Y-32 Plant, and C. K-25 Plant (Oak Ridge Gaseous Dif fusion Plant) .

( 1) Describe the national security function (s) , if any, perf ormed a t each f acility.

(2) If evacuation of such f acility were required, how many peole would be required to remain at each facility for (a) national security reasons?

(b) other reasons?

(3) Duri',1g an evacuation, how many people would be required to remain at each f acility for national security or other reasons if the whole body dose to such people were likely to reach:

(a) 1 rem, (b) 5 rems, (c) 25 rems, (d) 100 rems, (e) 240 rems, (f) 500 rems?

(4) Identify fully the national security impact, if any, of losing access to each facility:

(a) for one week, (b) for one month, (c) for three months, ,

(d) for six months, (e) for one year, ,

(f) inde finitely .

(5) Identify to what extent, if any, the Staf f judgment regardingtheadequacyoftheevacuationplansforIach \

f acility is based on the CRBR site suitability source term assumed by Staff in the May 6, 1976, letter from DeNise to Caffey.

(6) In assessing the adequacy of the evacuation plan for each f acility, what were Staf f 's assumptions regarding:

i _j

e i r

(a) the 2-hour doses at such facility?

(b) the 30-day doses at such facility?

(c) the basis for calculating the 2-hour doses at each facility?

(d) the basis for calculating the 30-day doses at each facility?

Contention 6

60. Identify each fuel cycle f acility (including fuel production, storage, preparation, fabrication, reprocessing, spent fuel storage, and waste disposal f acilities) that is likely to be used in the CRBR fuel cycle throughout its entire operating life.

61. Indicat whether Staff takes the position that the following regulations apply to each of the f acilities identified in r$sponse to Interrogatory 60 above:

a. 10 CPR S50.34 (c) ,

b. 10 CFR Part 20,

c. 10 CFR Part 60,

d. 10 CFR Part 70

e. 10 CPR Part 71 i

f. 10 CFR Part 73.

r

62. For each of the facilities and regulations identified in Questions 1 and 2 above, if Staf f's response is that a specific regulation on a particular subject does not apply to a facility, indicate which regulation (s) on that subject do apply to such facility and specify each and every difference in the regulations.

63. Identify each environmental impact associated with the operation of each of the following DOE reprocessing plants that (i) is likely to be used, or (ii) may be used to supply fuel for the CRBR or to reprocess CRBR fuel:

a. the Savannah River plant (H Canyon) ,

b. the Savannah River plant (F Canyon) ,

c. the Idaho National Engineering Laboratory,

d. The Hanford PUREX plant.

64. How will the following materials be disposed of?

a. CRBR soent fuel,

b. high-level waste from the reprocessing of CRBR fuel,

c. high-level waste from the reprocessing of LWR fuel to recover plutonium for the CRBR.

65. Does Staf f take the position that Applicants must meet the provisions of 10 CFR Part 71 with respect to the transportation of materials in the CRBR fuel cycle?

66. Will the disposal of wastes generated from the CRBR spent fuel, including high-level wastes from reprocessing

a. be subject to: 1

1. NRC jurisdiction?

ii. EPA jurisdiction?

b. be classified as defense waste? ,

c. be classified as commercial waste?

Contention 7

67. Explain in detail how the CRBR can meet its reliability goal given the apparent problems with its steam generators and the limitations of Applicants' testing program for such generators.

68. Has Staff performed any analyses of the following alternative sites during the LMFBR demonstration plant site selection process:

a. TVA Hartsville site?

b. TVA Yellow Creek sites?

c. Washington Public Power Supply System (WPPSS) Unit 4 site?

If the answer is yes, identify and provide all such analyses and all documents in the possession of Staf f relating to such analyses. Describe the conclusions reached by Staff

4 and explain in detail the basis for all such conclusions. If the answer is no, explain whether Staff intends to perform such analyses, and, if not, why not.

Contention 8

69. What are the environmental impacts of decommissioning CRBR?

l

70. What are the unavoidable adverse environmental ef fects associated with decommissioning CRBR?

71. Identify and provide all documents, analyses, memoranda, calculations, evaluations, assessments, etc. , related to the environmental impacts and/or unavoidable adverse environmental effects associated with decommissioning the CRBR.

72. Identify and provide all documents, analyses, evaluations, assessments, etc., upon which the Staff relies in assessing for purposes of NEPA review the environmental impacts and/or unavoidable adverse environmental effects associated with decommissioning CRBR.

73. Identify the Staff member (s) and consultants working on the NFPA review as it relates to decommissioning impacts.

Provide a description of his/her background and experience.

(

74. Have any analyses been undertaken of neutron activation products which Staff relies upon to determine

a. the potential isolation period of the CRBR following decommissioning?

b. the economic costs of decommissioning the CRBR?

c. the environmental costs of decommissioning the CRBR?

d. the societal costs of decommissioning the CRBR?

If the answer to any part of this interrogatory is yes, identify and produce such assessments and any and all documents in the possession of Staf f relating thereto.

75. If the ansker to any part of the above interrogatory is that Staf f does not rely on any analyses of neutron activation products, explain in detail why Staf f believes that reliance on such analyses is unnecessary.

Contention 11

76. This interrogatory addresses solely the calculation of whole body and org'an doses commencing with the assumed concentration of radioactivity in the air or on the ground.

Set forth explicitly Staff's method of calculation and all assumptions used with respect to the dose calculations for the site suitability scurce term and for conseguences of accidents as set forth in Chapter 7 of the FES.

77. Set forth the basis for the assumptions referred to in response to the above question (e.g., page and section citations to ICRP Reports and EPA Reports) . To what extent have any of these reports been updated (to Staf f's knowledge) ,

and to what extent are they being considered for updating?

Please confine your answer to specifics rather than generalities.

78. Explain the basis for Staff's change to its response to Request for Admission 3 (Contention 7 (renumbered as 11) ) ,

dated July 28, 1976, since the Request for Admission does not refer solely to normal operations.

79. Explain the basis for Staf f's denial of Request for Admission 11 (Contention 7 (renumbered as 11)) , dated July 28, 1976, particularly in light of the documents cited in Interrogatory 85 (a) of Intervenors' Thentieth Set of Interrogatories to Staff.

80. Explain the basis for the denial of Request for Admission 16 (Contention 7 (renumbered 11)) , dated July 28, 1976.

81. Identify what changes, if any, Staff would recommend or make in the NRC's Denial of Petition for Rulemaking (Docket No.

PRM-20-5) if Staff's understanding (interpretation) of the " hot particle" hypothesis as advanced by Tamplin and Cochran in

"NRDC Supplemental Submission to the EPA Public Hearing on Plutonium and Transuranium Elements, February 27, 1975" was that " critical tissue mass" did not refer to a particular susceptible type tissue in the lung, but rather referred to a mass of tissue of a critical size, or if the word " critical" were deleted altogether (see Interrogatory 85(c) of Intervenors' Twentieth Set of Interrogatories to Staf f for a more complete characterization of what is meant by " critical tissue" or " critical tissue mass").

82. Regarding Staf f's updated response to Interrogatory 74 of Intervenors' Twentieth Set of Interrogatories to Staff, would not use of the value of $8000 per man-rem be more appropriate for assessing the Class 9 accident cost in CRBR, in light of the f act that a court has awarded $25 million in a class-action settlement for the TMI-2 accident (a Class 9 accident according to the NRC), which had an offsite exposure of approximately 3000 man-rems by NRC estimates? If Staff disagrees with this statement, explain the basis for Staf f's belief that the $1000 per man-rem figure is more appropriate than an $8000 per man-rem figure, or even some intermediate value that would account for inflation between 1972 and 1982.

l

83. Respond to Interrogatory 85(b) of Intervenors' Twentieth Set of Interrogatories to Staff, now reworded to read "Does Staf f believe that the definition of " critical" is crucial to

\

the support of the Fed. Reg. Notice of Denial?

a. If so, in what manner?

b. If not, why not?

84. Respond to Interrogatory 85(c) of Intervenors' Twentieth Set of Interrogatories to Staff, where " critical tissue mass" is defined in pp. 4-6 of " Comments 17 NRDC on Nuclear Regulatory Commission' Denial of Petition for Rulemaking

[ Docket No. PRM-20-5] Re: Petition to Amend Radiation Protection Standards As They Apply to Hot Particles (June 2, 1976)."

85. Respond to Interrogatory 86(c) (i) of Intervenors' Twentieth Set of Interrogatories to Staff, where the referenced assumption is the minimum activity to constitute a hot particle is 0.2 pCi, and the tumor risk per hot particle is 1/2000, and the particle size distribution in the lung of case 7-138 is representative of the particle size distribution in the 24 Manhattan workers reported by Hemplemann, et al. [ LA-514 8-MS .

LASL. Jan. 1973].

e*

86. Respond to Interrogatory 89 of Intervenors' Twentieth Set of Interrogatories to Staf f, where the term "these lesions" refers to lesions in human lung, similar to those produced by Pu microspheres in hamster lungs. (See Richmond, e t a l. , Ref.

18, 41 Fed. Reg. 15375 (April 12, 1976).)

87. Describe in detail and provide all documents related to the " limited data available for LMFBRs indicat[ing] dose levels below those experienced at light-water plants of comparable size" referred to in Staff's response to Interrogatory 11 of Intervenors' Nineteenth Set of Interrogatories to Staf f (p. 12 of response).

88. Provide a response to Interrogatory 14 of Intervenors' Nineteenth Set of Interrogatories to Staff af ter substituting "FES p. 11-23, Section 11.5.32," for the FES reference now appearing in the interrogatory.

89. Provide a response to Interrogatory 13 of Intervenors' Nineteenth Set of Interrogatories to Staf f, where "NRDC analysis regarding the health effects of plutonium as set forth in NRDC filings with the Commission and in (original)

Contentions 7 and 8" and the "NRDC analysis" referred to in the second question of Interrogatory #13 refer to:

4'

( 1) the plutonium " hot particle" hypothesis advanced by Arthur R. Tamplin and Thomas B. Cochran, described in documents submitted to the Commission in NRDC Petition for Rulemaking, Docket No. PRM-20-5 (see Response to Interrogatory ll-18.c of NRC Staff First Round of Discovery to NRDC, et al. );

(2) the Karl Z. Morgan hypothesis described in " Suggested Reduction of Permissible Exposure to Plutoniem and Other Transuranium Elements," Journal of American Industrial Hygiene (August 1975);

(3) Inpervenors' contention that the approach utilized by Applicants and Staff in establishing 10 CFR S100.11 organ dose equivalent limits corresponding to a wole body dose of 25 rems l

l is inappropriate because it fails to consider important organs, e.g., the liver, and because it fails to consider new knowledge , e.g., recommendations of the ICRP in IReports 26 and 30 (see Response to Interrogatory 6 (Contention 11) of Applicants' Fourth Set of Interrogatories to Intervenors); and (4) Intervenors' analysis as set forth in Contention ll(a-c), as described further in Intervenors' Response to Applicants' Fourth Set of Interrogatories (Contention 11) , NRC Staff's First Round of Discovery to NRDC, et al. (Contention

11) and other discovery responses; and where " residual risk" refers to "the health and saf ety consequences to the public and plant employees which may occur if the CRBR merely complies with current NRC standards for radiation protection of the public health and safety."

i

_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ -_. 1

s'

90. Provide a response to the last sentence of Interrogatory 15 of Intervenors' Nineteenth Set of Interrogatories to Staff, regarding occupational exposure policy at West Valley.

91. Are the four systems described in Staff's response to Interrogatory 25 of Intervenors' Nineteenth Set of Interrogatories to Staff the only systems for which sufficient data was not available at the issuance of the FES to determine whether it is designed to conservative standards and engineering practices? If not, answer Interrogatory 25 for each other such system.

Respectfully submitted,

~

/.

p % e. . , ' . .;. . . , , , . . _

' Barbara A. Finamore S. Jacob Scherr 1725 I Street, N.W., #600 Washington, D.C. 20006 (202)223-8210 fe *

,.) ' ' ,

e Ellyn R. Weiss Harmon & Weiss

• 1725 I Street, N.W.

Washington, D.C. 20006 (202)833-9070 Dated: June /, 1982

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