ML20065M437

Affidavit of TB Cochran Re Environ Analyses for Fuel Cycle & Timing Objective.Prof Qualifications & Certificate of Svc Encl.Related Correspondence

ML20065M437
Person / Time
Site:	Clinch River
Issue date:	10/19/1982
From:	Cochran T National Resources Defense Council
To:
Shared Package
ML20065M427	List: ML20065M422 ML20065M437
References
NUDOCS 8210210240
Download: ML20065M437 (13)

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"T ~ ' " - > - a..'0?;D F = r U' lYc October 19, 1 2 GCT 19 pj g UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION - Sc W,K TATf ATOMIC SAFETY AND LICENSING BOARD l[cf0'002 Before Administrative Judges:

Marshall E. Miller, Chairman Gu'Jtave A. Linenberger, Jr. -

Dr. Cadet H. Hand, Jr.

In the Matter of )

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UNITED STATES DEPARTMENT OF ENERGY )

PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537 TENNESSEE VALLEY AUTHORITY )

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(Clinch River Breeder Reactor Plant) )

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AFFIDAVIT OF THOMAS B. COCHRAN

I, Thomas B. Cochran, being duly sworn, do hereby state as follows

1. I am a Senior Staff Scientist for Intervenor Natural

. Resources Defense Council, Inc.

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2.4 I am responsible for Intervenors', testimony on the environmental analyses for the fuel cycle and the " timing

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objective" associated with the Clinch River Breeder Reactor in the above-captioned proceeding.

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3. My statement of professional qualifications is attached.

4. The CRBR-epacific fuel cycle environmental impact analyses contained in the draft FLS Supplement and the ER are inadequate for the reasons stated in paragraphs 5 to 15 below.

5. There is no analysis of the environmental impacts of accidents associated with CRBR fuel-cycle operations in the DESS.

(October 12, 1982 Deposition of Homer Lowenberg at 28).

6. The analysis of the environmental impacts of the release of carbon-14 and iodine-129 from CRBR fuel reprocessing operations fails to include the impacts beyond the first 100 years, even though the hcalth impacts will persist for much longer periods due to their relatively long radioactive half-lives. (October 13, 1982, Dep. of Edward Branagan at 26-31).

7. The analysis of the environmental impacts of the release of krypton-85, iodine-120 and carbon-14 released from CRBR fuel reprocessing operations fails to consider the health impacts to people residing beyond the boundaries of the continental United States. (October 13, 1982 Dep. of Edward Branagan at 14).

8. The analysis of the environmental impacts of the release of

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gaseous effluents of plutonium from CRBR fuel reprocessing and fuel fabrication facilities fails to justify adequately the assumption that releases that are orders of magnitude less than the actual emissions experienced at operating plants (e.g. Rocky Flats and Savannah River Plant) are likely to be achieved.

(October 13, 1982 Dep of James Ayer at 53-54).

9. The Staff projects what DOE expects would be the likeDj environmental impacts of reprocessing CRBR fuel at a hypothetical Developmental Reprocessing Plant, and predicts -- without adequate supporting analysis -- that the impacts of possible alternative means of reprocessing (a private facility or modification of existing DOE facilities) would be enveloped by the impacts estimated for-DRP. (October 12, 1982 Dep. of Homer Lowenberg at 12-13).

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10. The plutenium isotopic concentrations assumed in.the fuel cycle analysis (e.g. those in Table D.7 at page D-13) are in l

j error and non-conservative as they do not consider concentrations associated with high burn-up LWR fuel and recycled mixed-oxide (MOX) fuel, which are likely fuel types to be used in CRBR.

(October 12, 1982 Dep, of Lowenberg at 8-11).

11. The analysis of the environmental. effects associated with i

proposed geologic disposal of high-level and transuranic l

radioactive wastes associated with the CRBR fuel cycle are not adequately analyzed with respect to the potential releases after mine closure. The Staff's assumption that these releases will be zero or negligible does not adequately take into account uncertainties in projecting the potential releases. (October 13, 1982 Dep. of Regis Boyle at 37-39).

12. The Staff does not explain fully the basis for its assumed releases from the federal repository (Draft FES Supplement Appendix D, Section D.2.2.4), but rather only states that releases from a repository "would be limited" to generic values specified in unpublished EPA standards. The Staff has provided no analysis to support its view that the proposed EPA standards can and will be met, and does not reconcile Staff's zero or negligible release assumption (after repository closure) with the larger releases permitted under unpublished EPA Standards. Id.

13. The Staff has used outdated dosimetric and metabolic models to estimate whole body and organ doses, including failure to calculate the dose commitment to members of the public beyond a 50-year exposure period. (October 13, 1982 Dep. of Edward Branagar. at 17-25).

14. The analysis of the impacts of terrorism, sabotage or theft against plutonium in the CRBR fuel cycle (Draft FES Supplement,

Section 7.3 and Appendix E) is inadequate for the following reasons, among others:

a) The draft FES Supplement incorrectly identifies the source of plutonium for the CRBR during its initial five years of operation, as the DOE stockpile of fuel-grade plutonium will be unavailable on account of demands of the nuclear weapons program. Hearings before the Senate Committee on Governmental Affairs, 97th Cong., 2d Sess. 47 (September 9, 1982) (Statement of Kenneth Davis, Deputy Secretary, DOE).

b) The Staff has failed to analyze the adequacy of the safeguards systems at existing DOE facilities that may be involved in the CRBR fuel cycle. (October 12, 1982,Dep. of R. Davis Hurt at 53).

c) The Staff has provided no analysis to support its I

conclusion that the Material Control and Accounting System, in conjunction with the physical security. system, would provide capability to detect and deter the illicit diversion of plutonium and would assure that no diversion will occur.

d) The Staf f has provided no basis for its conclusion that a prompt accounting system will actually work, that it will be put in place by DOE, or that it will meet the requirements-of an adequate material accounting system and provide timely detection, l

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15. In summary, Intervenors' concerns about the environmental i impact analyses of the CRBR fuel cycle are not remedied by the analyses which presently appear in the draft FES Supplement for

CRBR.

16. The design approach to LMFBR demonstration plant (CRBR) features which is presently being pursued might very well result 3 in less timely achievement or non-achievement of the plant's programmatic informatio~nal objectives than would .be the case using alternative approaches.

17. The GAO has expressed serious concern about Applicants' decision to install untested steam generators in CRBR. U.S.

General Accounting Office, R'evising the_ Clinch River Breeder Reactor Steam Generator Testing Program Can Reduce Risk, (GAO/EMD-82-75, May 25, 1982). ,

18. If the untested steam generators prove to be defective after installation at CRBR, the likelihood is very high that

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achievement of the informational objectives for CRBR will be delayed for a very substantial period of time--perhaps years --

or that the objectives will never be achieved.

19. NRC Staff has admitted that' alternative features might result in more expeditious achievement of the programmatic ,

objectives (October 13, 1982 Deposition of Paul Leech, at 12-13).

20. A more prudent approach of testing the questionable steam generators prior to making the decision to install them might very well lead to more timely achievement of the programmatic objectives for CRBR than the approach presently being pursued.

21. The choice of a more appropriate site than the CRBR site for the demonstration LMFBR plant could result in more timely achievement of the programmatic objectives for the demonstration plant. The Licensing Boarc might find the CRBR site unsuitable.

22. The Staff has admitted that, if the CRBR site were found "1

unsuitable, an alternative site might better meet the timing objective. (October 13, 1982 Deposition of Paul Leech, at 14).

23. Intervenors' concerns in Contentions 7(a)(1) - that it has not been established how the CRBR will achieve its objectives in a timely fashion - have not been eliminated by the change in the

" timing objective" from 1982 to "as expeditiously as possible."

Thomas B. Cochran Date: October 19, 1982 Sworn and subscribed before me

this /p" day of October, 1982.

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Notary Public

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My Commission expires: ;r~o /,f J/, /f F7 .

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October 1, 1981 RESUME Thomas B. Cochran, Ph.D.

Business Address:

Natural Resourcss Defense Ccuncil, Inc.

1725 I Street, NW, Suite 600 Washington, D.C. 20006 (202)223-8210

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,se Address:

4836 North 30th Street Arlington, VA 22207 (703)532-1044 EMPLOYMENT HISTORY April 1973-present: Natural Resources Defense Council, Inc.

Senior Staff Scientist, focusing on national energy R&D policy, principally nuclear energy issues, the breeder reactor, plutonium recycle, nuclear weapons proliferation, safeguards, and radiation exposure standards. Consultant to the U.S.

Department of Energy (DOE) on nuclear nonproliferation and nuclear R&D strategy; consultant to the Comptroller General on (a) U.S. and international controls over the peaceful uses of nuclear energy, (b) Advanced Nuclear Technologies, and (c) U.S.

Liquid Metal Fast Breeder Reactor Program; consultant to the Office of Technology Assessment-(OTA); Member of DOE's Energy Research Advisory Board, DOE's Nonproliferation Advisory Panel, OTA's Advisory Panel on Nuclear Proliferation and Safeguards, the Nuclear Task Group of OTA's Analyses of the ERDA Plan and Program, and OTA's Gas Curtailment Study Review Panel. Consultant to Governor of Lower Saxony, West Germany, to serve as an Inter-national Expert in the Review of the Gorleben Nuclear Fuel Cycle Center. Served as a member of ERDA's LMFBR Review Steering i Committee, the National Academy of Sciences' Panel on Strategy for Developing Nuclear Marchant Ships, the Task Force on Energy Conversion Research and Development of the Federal Power Survey, the United Nati'ons' Environment Programme's International Panel of Experts on Energy and the Environment, the National Council

of Churches' Energy Study Panel and the World Council of Churches i consultation on Ecumenical Concerns in Relation to Nuclear l Energy. Also served as a consultant to Resources for the Future l and numerous environmental organizations. Testified before l

Congress and federal agency hearings on numerous occasions, i including testimony before the Joint Committee on Atomic Energy, the House Committee on Interior and Insular Affairs, the Joint Economic Committee, the House Committee on Small Business, and the Nuclear Regulatory Commission's Advisory Committee on l

Reactor Safeguards.

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Thomas B. Cochran Page Two June 1971-April 1973: Resources for the Future, Inc.

Washington, D.C.

Senior Research Associate, Quality of the Environment Program.

Studying environmental effects of the U.S. civilian nuclear power industry, residuals management in the nuclear fuel cycle, liquid metal fast breeder reactor program, national energy policy, and radiation standards. Wrote a book, The Liquid Metal Fast Breeder Reactor: An Environmental and Economic Critique.

1969-1981: Litten Mellonics Division, Scientific Support Laboratory Fort Ord. California Modeling and Simulation Group Supervisor. Supervised the activities of'10 operation research analysts engaged in military research pertinent to the evaluation of proposed U.S. Army concepts and material by U.S. Army CDCEC.

1967-1969: U.S.. Naval Postgraduate School Monterey, California l Lt-USNR, Active Duty; Assistant Professor of Physics; Radiation Safety Committee; part-time research involving computer studies of synchrotron radiation production in beam transport systems at Stanfard Linear Accelerator, Stanford, California.

EDUCATION Summer 1969: University of Cdlorado, Boulder. Postdoctorate.

Summer Institute of Theoretical Physics.

1965-1967: Vanderbilt University, Nashville, TN. Doctorate.

Major; Physics. Minor: Mathematics. Research in high energy (bubble chamber) physics. NASA Fellowship. Guest Research Associate in Physics Department at Brookhaven National Laboratory, Upton, NY, studying synchrotron radiation shielding problems.

1962-1965: vanderbilt University. MS degree in Physics.

Research in radiation chemistry; AEC Health Physics Fellow; l

applied health physics training, Oak Ridge National Laboratory; vanderbilt University Campus Radiation Safety Officer.

1958-1962: Vanderbilt University. BE degree in Electrical Engineering, cum laude. NROTC.

l PROFESSIONAL AFFILIATIONS American Physical Society Health Physics Society Maerican Nuclear Society Sigma Xi l

I PERSONAL Age: 40. Birth date: 18 November 1940. Birth place: Wash. DC.

Wife: Carol J. Cochran. Two children.

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OE CERTIFICA'rE OF SERVICE GCT 19 P4;S2

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I hereby certify that copies of INTERVENORS ' ANSWER NRC STAFF'S MOTION FOR

SUMMARY

DISPOSITION OF INTERVENORS C5

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CONTENTIONS, MATERIAL FACTS AS TO WHICH THERE ARE GENUINE ISSUES TO BE HEARD , and AFFIDAVIT OF THOMAS B. COCHRAN, were served this 19th day of October 1982 by hand upon:

Marshall E. Miller, Esq.

Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission 4350 East West Highway, 4th floor Bethesda, MD 20814 Gustave A. Linenberger Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission 4350 East West Highway, 4th floor Bethesda, MD 20814 Daniel Swanson, Esq.

Stuart Treby, Esq.

Bradley W. Jones, Esq.

Office of Executive Legal Director U.S. Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georgetown Road Bethesda, MD 20814 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission 1717 H Street, NW, Room 1121 Washington, D.C. 20555 Atomic Safety & Licensing Board Panel

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U.S. Nuclear Regulatory Commission 1717 H Street, NW, Room 1121 Washington, D.C. 20555 Docketing & Service Section

[ Office of the Secretary

[ U.S. Nuclear Regulatory Commission 1717 H Street, NW, Room 1121 l Washington, D.C. 20555 (3 copies) l l

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Cartificate of Service - 2 R. Tenney Johnson, Esq.

Leon Silverstrom, Esq.

Warren E. Bergholz, Jr., Esq.

Michael D. Oldak, Esq.

L. Dow Davis, Esq.

Office of General Counsel U.S. Department of Energy 1000 Independence Ave., SW, Rm. 6A245 Washington, D.C. 20585 George L. Edgar, Esq.

Irvin N. Shapell, Esq.

Thomas A. Schmutz, Esq.

Gregg A. Day, Esq.

Frank K. Peterson, Esq.

Morgan, Lewis & Bockius 1800 M Street, NW, 7th Floor Washington, D.C. 20036 and by first class mail upon:

Dr. Cadet H. Hand, Jr., Director Bodega Marine Laboratory University of California P.O. Box 247 Bodega Bay, CA 94923 Herbert S. Sanger, Jr., Esq.

Lewis E. Wallace, Esq.

James F. Burger, Esq.

W. Walker LaRoche, Esq.

Edward J. Vigluicci, Esq.

Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue

Knoxville, TN 37902 William M. Leech, Jr., Esq.,

Attorney General l William B. Hubbard, Esq.,

l Chief Deputy Attorney General l Michael D. Pearigen, Esq.

! State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, TN 37219 l

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Cortificate of Service - 3 Lawson McGhee Public Library 500 West Church Street Knoxville, TN 37219 William E. Lantrip, Esq.

City Attorney Municipal Building P.O. Box 1 Oak Ridge, TN 37830 Oak Ridge Public Library Civic Center Oak Ridge, TN 37820 Joe H. Walker 401 Roane Street Harriman, TN 37748 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, TN 32219 J -

95rbara A. Finamore

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