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ENERGY, INC., JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
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9 tif. LATED. CORRESPONDN DOCKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION .g ,g q
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In the Matter of )
UNITED STATES DEPARTMENT OF ENERGY )
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537
TENNESSEE VALLEY AUTHORITY )
(Clinch River Breeder Reactor Plant) )
APPLICANTS' DIRECT TESTIMONY CONCERNING INTERVENORS' CONTENTIONS Sa) and 7c)
Dated: November 1, 1982 l
Q.l. Please state your name and af filiation.
A.l. My name is Lawrence J. Kripps. I am presently employed by Energy Incorporated in Seattle, Washington.
Q.2. Have you prepared a statement of your professional qualifications?
A.2. Yes. A copy is attached to this testimony.
Q.3. What subject matter does this testimony address?
A.3. The Intervenors, Natural Resources Defense Council, Inc.
CONTENTION 5 Neither Applicants nor Staff have established that the site selected for the CRBR provides adequate protection for public health and safety, the environment, national security, and national energy supplies; and an alternative site would be preferable for the following reasons:
I a) The site meteorology and population density are less favorable than most sites used for LWRs.
(1) The wind speed and inversion conditions at the Clinch River site are less
, f avorable than most sites used for light-water reactors.
(2) The population density of the CRBR site is less favorable than that of several alternative sites, i
(3) Alternative sites with more f avorable
. meteorology and population characteristics have not been adequately identified and analyzed by Applicants and Staff. The analysis of alternative sites in the ER and the Staff Site Suitability Report gave insufficient weight to the meteorological and population
! disadvantages of the Clinch River site and did not attempt to identify a site or sites with more favorable characteristics.
b) Since the gaseous diffusion plant, other proposed energy fuel cycle facilities, the Y-12 plant and the Oak Ridge National i Laboratory are in close proximity to the site an accident at the CRBR could result in the long term evacuation of those facilities. Long term evacuation of those facilities would result in unacceptable risks to the national sgcurity and the national energy supply.1 CONTENTION 7 Neither Applicants nor Staff have adequately
! analyzed the alternatives to the CRBR for the f911owing seasons:
! c) Alternative sites with more favorable environmental and safety features were not analyzed adequately and insuf ficient weight was given to environmental and safety values in site selection.
(1) Alternatives which were inadequately analyzed include Hanford Reservation, 1 Contention 5b) is addressed by the Applicants in separate testimony (Applicants' Direct Testimony Concerning Intervenors Contention 5b), dated November 1,1982) where it is demonstrated that the presence of. the CRBRP in the vicinity of the Oak Ridge Gaseous Diffusion Plant (ORGDP) , Y-12, and the Oak Ridge National Laboratory (ORNL) presents no unacceptable risks to the national security or the national energy supply. This conclusion confirms the assessment made during the course of the alternative siting analyses that the nearby presence of these facilities to the Clinch River site is not a significant factor affecting the selection of the site for the LMFBR Demonstration Plant.
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Idaho Reservation (INEL) , Nevada Test Site, the TVA Hartsville and Yellow Creek sites, co-location with an LMFBR fuel reprocessing plant (acg., the Development Reprocessing Plant) , an LMFBR fuel fabricating plant, and
. underground sites.
Q.4. In general terms, what analyses were perf ormed and what conclusions were drawn concerning selection of a site for the LMFBR Demonstration Plant?
A.4. The Applicants' alternative siting analyses for the LMFBR Demonstration Plant have considered alternative sites from within the TVA power service area and nationwide from land in the custody of DOE. In addition, potential sites on land in the custody of TVA outside of its power service area have been evaluated, and the siting concepts of co-location with an LMFBR reprocessing or fuel fabrication plant and Underground siting have been examined. All of these alternative siting analyses are contained in the CRBRP Environmental Report.2 As a result of the Applicants' alternative siting analyses, all of which have
. been recently re-examined and updated, the conclusion reached was that the Clinch River site is the preferred site for the LMFBR Demonstration Plant.
2 For ease of ref erence a bound copy of the pertinent CRBRP Environmental Report sections and appendixes containing the Applicants' alternative siting analyses are of fered as an Exhibit to this testimony.
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Q.5. What analyses were perf ormed and what conclusions were drawn by the Applicants concerning sites within the TVA power service area?
A.5. The original alternative siting analysis that selected the Clinch River site as the preferred location for the LMFBR Demonstration Plant is contained in Section 9.2 and Appendix A of the Applicants' Environmental Report. In this analysis the TVA power service area was considered as the region of interest. In 1982 the original alternative siting analysis was re-examined and updated. The updated analysis is contained in Environmental Report Appendix G
! and confirmed the findings of the original analysis that from among sites within the TVA power service area the Clinch River site is the pref erred site.
The original alternative siting analysis in Environmental Report Section 9.2 and Appendix A considered two distinct plant / site approaches:
- a. A hook-on nuclear island at an existing TVA team plant site, and
- b. An all-new plant at a site within the TVA power service area.
The evaluation covering potential hook-on and new sites ultimately led to a detailed analysis comparing two hook-on sites (i.e., John Sevier and Widows Creek) and a j new site on the Clinch River. The comparison of these l
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. l three candidate sites led to the conclusion that an all new plant at the . Clinch River site was the pref erred alternative.
The Applicants, in 1982, updated the original alternative siting analysis (see Environmental Report Appendix G) using the approach set forth in NRC's Proposed Rule on Alternative Sites (45 FR 24168-24178, April 9,1980) and considering available new information. The updated analysis first demonstrated that the TVA power service area was an appropriate " region of interest". Secondly, it concluded that the TVA sites considered in the original analysis constitute a sufficient number of candidate sites that meet the Proposed Rule's threshold criteria and represent the environmental diversity of the TVA power service area. Thirdly, the Applicants' concluded that the addition of applicable current information would not change the previous conclusions in Environmental Report l
Section 9.2 and Appendix A that the Clinch River site is I the pref erred location for the LMFBR Demonstration Plant.
The Applicants in 1982 also perf ormed as part of the l update to the original alternative siting analysis, a separate, additional analysis of eleven candidate sites which are representative of the best sites within the TVA power service area (see Environmental Report Appendix G, ,
Attachment 1). These eleven sites were the proposed Clinch River site and the ten alternative candidate sites of Spring Creek, Blythe Ferry, Caney Creek, Taylor Bend, Buck Hollow, Phipps Bend, Lee Valley, Murphy Hill, Hartsville, and Yellow Creek. Except for the Yellow Creek site, all of the alternative candidate sites had been considered as new sites in the original alternative siting analysis. The comparison of the Clinch River site to the ten alternative candidate sites was done in accordance with the first part of the Proposed Rule's two part sequential analytical test by giving primary consideration to hydrology, water quality, aquatic biological resources, terrestrial resources, water and land use, socioeconomics, and population. In addition, the Applicants' analysis included a comparison of the meteorological (atmospheric dispersion) characteristics of the candidate sites. From this comparison it was concluded that none of the ten alternative candidate sites were environmentally pref erable to the Clinch River site.
Although based on the conclusion that none of the ten alternative candidate sites were environmentally preferable to the Clinch River site there would be no requirement to proceed to the second part of the Proposed Rule's two part sequential analytical test, the Applicants nonetheless examined project economic, technology, and
l institutional factors that affect the selection of the LMFBR Demonstration Plant site. This examination concluded that there would be substantially increased Project costs at another TVA site and that the LMFBR program timing objective (i.e. , construction and operation of the LMFBR Demonstration Plant as expeditiously as possible) could not be met at any alternative TVA site.
Thus, the updated alternative siting analysis presented in Appendix G of the Environmental Report concluded that no environmentally preferred site and certainly no obviously superior site exists in the TVA power service area for the LMFBR Demonstration Plant.
Based on the original and updated alternative siting analyses contained in Environmental Report Section 9.2 and Appendix A and Appendix G, respectively, the Applicants concluded that the Clinch River site is the preferred site f or the LMFBR Demonstration Plant within the TVA power service area.
! Q.6. What analyses were perf ormed and what conclusions were drawn by the Applicants concerning alternative sites within DOE's custody?
A.6. The Applicants' alternative siting analyses examining sites within DOE's custody are presented in Section 2.1 of Appendix D and in Appendix E of the Environmental Report.
4 These analyses were updated in 1982 and the update is provided in Appendix F to the Environmental Report. The i
analyses in Environmental Report Appendixes D, E, and F
The analyses of DOE sites started with an inventory of U.S. Governr.ent owned land in the custody of DOE. A screening process eliminated from further consideration j all but three sites. Factors used to screen out the other DOE sites included, for exmnple, lack of available cooling water, high surrounding population density, and insufficient land. The Hanford Reservation, Savannah River Plant, and Idaho National Engineering Laboratory (INEL) were the three DOE sites resulting from this screening process found to be feasible for location of the LMFBR Demonstration Plant.
Based on an examination of the environmental and engineering characteristics of the Hanford, Savannah River, and INEL sites, it was found that these sites have
- somewhat more favorable atmospheric dispersion and site isolation (i.e. , minimum exclusion boundary distance, surrounding population density) characteristics than the w-- -,-r------+ +- , --- -vv-- -, e . .---+,-e,.----w--- m---- - - --,-$~---- - - - - - - - - - - - - - -
Clinch River site. The comparison of other siting parameters showed the Hanford, Savannah River, INEL, and Clinch River sites to be essentially equivalent. An
. examination of econanic and institutional factors determined that relocation of the LMFBR Demonstration Plant to the Hanford, Savannah River, or INEL site would substantially increase the Project costs and that at all three sites the LMFBR program objectives of extensive utility participation and timing (i.e., construction and operation of the LMFBR Demonstration Plant as expe-ditiously as possible) could Act be met. Based on these analyses it was concluded that none of the DOE sites were a satisf actory alternative to the Clinch River site and, therefore, the Clinch River site remained the preferred site for the LMFBR Demonstration Plant.
8 Q.7. Were any other sites considered beside those already discussed?
l A.7. The Applicants have also reviewed land owned by TVA outside its power service area for potential sites for the LMFBR Demonstration Plant. Only two potential sites were identified. Upon evaluation of the general characteristics of these sites, both sites were judged to be less desirable than the Clinch River site. (See I
Section 2.2 of Appendix D and Section 2.2 of Appendix F to
' the Environmental Report.)
Q.8. Were any other siting concepts considered by the Applicants in their site selection analyses?
fuel fabrication plant and underground siting (see Environmental Report Appendix D, Section 2.3). A comparison of the saf ety, environmental acceptability, safeguards, and economics of an LMFBR Demonstration Plant utilizing these concepts, and consideration of LMFBR programmatic obj ectives, showed that neither co-location nor underground siting would be a desirable alternative.
In the alternative siting analysis update provided in Section 2.3 of Appendix F to the Environmental Report, it was concluded that no new information had been developed since the 1976 analysis to change the previous conclusion that neither the concept of co-location or underground l siting offers tangible improvement in the safety, i i
environmental acceptability, safeguards, or economics of the proposed CRBRP.
Q.9. What factors were considered in the Applicants' l
alternative siting analyses?
A.9. The Applicants' alternative siting analyses included consideration of pertinent environmental, engineering, and economic f actors and LMFBR programmatic objectives. Among
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. the siting factors considered were meteorology (atmospheric dispersion) and population.
Q.10. How was meteorology considered as a siting f actor?
V A.10. The comparison of meteorology between alternative sites was .done using atSospheric dispersion as the pertinent siting characteristic. For alternative candidate sites within the TVA power service area the site comparison criteria for meteorological considerations related primarily to atmospheric diffusion conditions, including opportunity enr dilution before released effluents would be expects reach communities within ten miles of the site and local stagnation potential. In addition, the relative difficulty in determining and describing transport and diffusion patterns of effluent and the
- confidence levels in transport and diffusion estimates were compared (see Environment Report Appendix G, Attachment 1, Section B). For sites within the TVA power service area the evaluation was qualitative because of the varying type and maount of data available at each site.
The comparison of alternative DOE sites (i.e. , Hanf ord Reservation, Savannah River, and INEL) to the Clinch River
/ site was quantitative using conservative and annual I average X/Q values.
l Q.11. How was population considered as a siting factor?
L A.ll. The population and the populat sn density surrounding ,
candidate sites within the TVA power service area and the three DOE sites were compared in the alternative siting analyses. In addition to the comparison of population data between sites, population density data at each alternative site were compared to the NRC guidelines provided in Regulatory Guide 4.7 " General Site Suitability
. Criteria for Nuclear Power Stations.=3 The NRC population density guidelines were found to be met for the Clinch River site, for all alternative sites considered within dhe TVA power service area, and for the three DOE sites.
l Q.12. Based on the consideration of meteorological and population characteristics, what conclusions were drawn?
A.12. The comparison of meteorological (i.e., atmospheric dispersion) and population characteristics showed that some of the alternative candidate sites within the TVA I \
l 3 The NRC guidelines in Regulatory Guide 4.7 co'ncerning population considerations state:
If the population density, including weighted transient population, projected at the time of initial operation of a nuclear power station exceeds 500 persons per square mile averaged over any radial distance out to 30 miles (cumulative population at a distance divided by
! the area at that distance), or the projected population density over the lifetime of the facility exceeds 1,000 persons per square mile averaged over any radial l distance out to 30 miles, special attention should be given to the consideration of alternative sites with l lower population densities.
. power service area possessed certain advantages over the l Clinch River site and that all three potential DOE sites l
' had lower population densities and more favorable
! atmospheric dispersion characteristics compared to the Clinch River site. This would result in lower of f-site I doses associated with releases of radioactive material !
4 from the LKFBR Demonstration Plant at these alternative sites. The reduction in calculated doses at these alternative sites, however, does not represent a significant difference in terms of expected environmental impact. The Applicants' testimony concerning NRDC Contentions 1, 2, and 3 showed that the doses at the Clinch River site for the site suitability source term (SSST), which were greater than those associated with the design basis accidents, were well below the 10CFR Part 100 ,
dose guidelines. This testimony also showed that CRBRP I can be designed so that greater accident consequences are highly unlikely. In addition, under normal operation, the i Applicants' testimony concerning NRDC Concentions llb) and lic) shows that the health ef fects to the public f rom operation of CRBRP are small in relation to the background incidence of health ef fects in the population.
Consequ'ently, the real reduction in expected environmental impacts for an alternative site relative to the Clinch River site because of lower population density and/or more f avorable atmospheric dispersion characteristics is judged
. to be insignificant.
The effect of this conclusion was that while the atmospheric dispersion and population characteristics were more favorable at Hanford, Savannah River, and INEL compared to the Clinch River site and at several of the alternate candidate sites within the TVA power service area, these factors alone did not make these sites environmentally preferable to the Clinch River site. In fact, on consideration of all pertinent environmental siting f actors, none of the three potential DOE sites or the ten alternative candidate sites within the TVA power service area were found to be environmentally pref erable to the Clinch River site.
Q.13. What are your conclusions regarding Contentions Sa) and 7c)?
A.13. As discussed above, the Applicants have analyzed a range of alternative sites and siting concepts for the LMFBR Demonstration Plant that include the alternative sites and siting concepts specifically mentioned in Contention 7c) .
The Applicants' alternative siting analyses have considered the pertinent environmental, engineering,
economic factors and LMFBR programmatic objectives, including meteorology (atmospheric dispersion) and population. Based on these alternative siting analyses, the Clinch River site is the preferred location for the
LMFBR Demonstration Plant.
l STATEMENT OF QUALIFICATIONS Lawrence J. Kripps Energy Incorporated Seattle, Washington 98031 ,
i I received Bachelor of Science and Master of Science degrees in Nuclear Engineering from the University of Wisconsin, l Madison, in 1971 and 1972. During the summers of 1968 through 1971 while sttending the University of Wisconsin, I worked as an engineer at the Allen S. King Plant, Monticello Nuclear Plant, and Prairie Island Nuclear Plant, respectively, where my responsibilities included testing plant perf ormance and conducting pre-operational tests. While attending graduate school I was a teaching assistant for undergraduate and graduate courses in nuclear reactor analysis.
Upon graduating from the University of Wisconsin, I joined the Tennessee Valley Authority in 1972 as a nuclear engineer in the Power Research Staf f of the Office of Power.
From October 1972 to March 1973 I was temporarily assigned as a 1
test engineer at the Brown's Ferry Nuclear Power Plant where I prepared and conducted several pre-operational tests. After Brown's Ferry I worked in the LMFBR Branch of the Power Research Staff principally supporting the CRBRP Project. As a member of the LMFBR Branch I helped to prepare the CRBRP Environmental l
Report and Preliminary Safety Analysis Report (PSAR). I specifically assisted in the preparation of Environmental Report Section 9.2 concerning site selection.
In 1975 I was reassigned by TVA to the CRBRP Project Office as a licensing engineer in the Licensing Branch of the Public Safety Division. My responsibilities included overall responsibility for the CRBRP Environmental Report and Chapter 2.0 of the PSAR and for acquisition of all non-NRC permits required for CRBRP construction and operation. In this capacity, I conducted the supplemental alternative siting analysis of alternative DOE sites, TVA owned sites outside the TVA power service area, and the concepts of underground siting and co-location with an LMFBR fuel reprocessing or fuel fabrication plant. In 1977 I became Chief of the Licensing Branch with overall responsibility for CRBRP licensing activities.
From 1979 to the present I have been employed by Energy Incorporated (EI) as a Senior Analyst and Project Manager. At EI, under a contract with Westinghouse Electric Corporation, I have continued to support the CRDRP Project licensing effort by providing or assisting in providing updates to the previous CRBRP l
alternative siting analyses.
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TABLE OF CONTENTS FOR THE ENCLOSED CRBRP ENVIRONMENTAL REPORT SECTIONS AND APPENDIXES THAT CONTAIN THE APPLICANTS' ALTERNATIVE SITING ANALYSES Section 9.2 ALTERNATIVE SITES AND PLANT ARRANGEMENTS (The original alternative siting analysis considering the TVA power service areas as the region of interest)
Appendix A TENNESSEE VALLEY AUTHORITY RESPONSE TO ATOMIC ENERGY COMMISSION QUESTION 340.1 (9.2.4) ALTERNATIVE SITES (Additional information on new TVA sites provided in support of the original alternative siting analysis presented in Section 9.2)
Appendix D SUPPLEMENTAL ALTERNATIVE SITING ANALYSIS FOR THE LMFBR DEMONSTRATION PLANT (The Applicants alternative siting analysis l considering ERDA (DOE) sites (Section 2.1), TVA owned sites outside the TVA power service area (Section 2.2) , and the concepts of co-location and underground siting (Section 2.3))
Appendix E ADDITIONAL INFORMATION REGARDING CONSIDERATION OF
Appendix F SUPPLEMENTAL ALTERNATIVE SITING ANALYSIS UPDATE FOR WE LMFBR DEMONSTRATION PLANT (Update to Appendixes D and E which examined alternative sites from among DOE sites, TVA sites outside the TVA power service area, and the concepts of co-location and underground siting)
Appendix G UPDATE TO WE CRBRP ALTERNATIVE SITING ANALYSIS WIW IN W E TVA POWER SERVICE AREA (Update to the original alternative siting analysis presented in Section 9.2 and Appendix A considering the TVA power service area as the region of 1