Text

Third Set of Interrogatories Directed to Applicant Re Contentions I-X & XII-XXI.Certificate of Svc Encl.Related Correspondence
	ML19346A351
Person / Time
Site:	05000142
Issue date:	06/10/1981
From:	Pollock M; COMMITTEE TO BRIDGE THE GAP, POLLOCK, M.
To:	; CALIFORNIA, UNIV. OF, LOS ANGELES, CA
References
	NUDOCS 8106190204
	Download: ML19346A351 (54)
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NUCLEAR REGUIATORY COMMISSION m \ ,,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket No. 50-142

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THE REGENTS OF THE ) (Proposed Renewal of UNIVERSITY OF CALIFORNIA ) Facility License)

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(UCLA Research Reactor) ) "INTERVENOR'S INTERROGATORIES

) TO APPLICANT, THE REGENTS OF

) THE UNIVERSITY OF CALIFORNIA ~i SET THREE" TO: THE REGENTS OF THE UNIVERSITY OF CALIFORNIA AND THEIR ATTORNEYS OF RECORD, GLENN R. WOODS AFD CHRISTINE HELWICK.

Intervenor, COMMITTEE TO BRIDGE THE GAP, hereby requests that said Applicant answer the following interrogatories fully and separately under oath, pursuant to the stipulated discovery schedule in this action.

It is intended by this set of interrogatories to elicit information not merely within your own personal knowledge, but .

obtainable on your behalf, such as by your attorneys, employees, !

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investigators and . representatives. Wherever the term "you" is used, it refers to you or anyone acting on your behalf incl'uding your attorneys, investigators, representatives and employees.

Definition of Terms Used in Interrogatories In answering the following interrogatories, understand the following terms used in the interrogatories to mean as follows:

" Applicant" -

The Regents of the University of California.

" Application" -

Applicant's " Application for a Class 104 License for a Research Facility" submitted February 28, 1980.

"NRC" -

The United States Nuclear Regulatory Commission.

"Intervenor" -

The Committee to Bridge the Gap.

"the reactor" -

The UCLA research reactor, License No. R-71, docket 50-142.

" current Technical Specifications" -

The Technical Speci-fications of the UCLA reactor currently in force.

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" proposed Technical Specifications" -

The Technical Speci-fications of the UCLA reactor proposed in the Application.

" controls" -

"when used with respect to a nuclear reactor means apparatus and mechanisms the manipulation of which d:.rectly affect the reactivity or power level of the reactor"

" operator" -

Any individual who manipulates a control of a facility. An individual is deemed to manipulate a control if he directs another to manipulate a control (10 CFR 55.4(d)]. Inter-venor hereby for the purpose of these interrogatories specifies that if one individual directs another to manipulate a contrcl and that second individual does manipulate the controls, both individuals are deemed to manipulate the controls and thus both

~ are considered operators.

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" senior operator" - - Any individual designated by a facil-ity license under 10 CFR 50 (in this case,-the Applicant) to direct the licensed activities of licensed operators

[10 CFR 55.4(a)]. Intervenor hereby for the purpose of these interrogatories defines " direct the licensed activities of li- I censed operators" to not include directing the activities of unlicense,i operators except students in an engineering course, or operator license trainees as exempted under 10 CFR 55.9.

" Students in a nuclear engineering class" -

Students i i

formally enrolled, for credit and to be evaluated by an instructor, in a formal course in nuclear engineering offered by an accredit-ed institution of learning. For the purposes of these interroga-tories, students in a general science class, for example, a high school physics class, would not be considered students in a nuclear engineering class. Likewise, people who visit the facil-ity on a tour would not be considered " students in a nuclear engineering class" unless they were receiving academic credit ;

from an accredited institution of learning in a course in nuclear '

engineering and the tour was a formal part of that nuclear engine-ering course.

" Operator trainees" -

An individual in a formal training i

program to qualify as a licansed reactor, operator.

" commercial use" -

Use of the reactor, for which a fee is paid to the NEL or Applicant, by persons other than those official-ly associated with UCLA, other colleges and universities, or other non-profit organizations. In particular, use of the reactor by persons described as commercial users by the Applicant in .

Applicant's response of May 13, 1980, to an NRC information request of April 17, 1980.

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" Person" A natural person, a corporation, a partnership, an association, or any other similar type of entity.

" Document" -

Any printed, typewritten, or handwritten matter of whatever character, including, but not limited to, logs, minutes, computer printouts, contracts, data records, leases, diaries, letters, ledgers, amoranda, telegrams, state-ments of witnesses or persons having knowledge of relevant facts, catalogs, brochures, checks and check stnbs, invoices, vouchers, orders, any carbon or photographic copy of any such material, and any magnetic, mechanical, or electrical recording.

Intervenor has for purposes of clarity in these interroga-tories defined with specificity the terms it has used so that Applicant can know specifically what information is being sought.

None of the abova definitions should be considered definitions which Applicant, by answering the interrogatories that fellow, has in any fashion indicated agreement with. If Applicant dis-agrees with the definitions herein, Applicant should so state, 4

but should nevertheless answer the interrogatories according to the definitions above and thereafter give Applicant's definitions of these terms and answer the same questions'using Applicant's definitions.

GENERAL PROVISIONS The following general provisions apply to each interrogatory herein:

A. In answering these interrogatories, furnish all infor-mation available to A'pplicant, including information in posses-sion of your atterneys, investigators, agents, employees, and

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such other persons and not merely such information as is known

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personally to the individual or individuals primarily responsible for drafting the answers.

B. If Applicant cannot answer any of the following inter-rogatories in full, after exercising due diligence to secure the information to do so, so state, and answer to the extent possible specifying your f ability to answer the remainder, and stating whatever information or knowledge you may have concerning the unanswered portion.

C. With respect to each of your answers which identifies a document, you may attach a copy of such document to your answers to these interrogatories in lieu of describing such document and the contents thereof.

D. If an answer to these interrogatories includes a refer-ence to an oral communication, please state with respect thereto:

(1) The date and place of communication; (2) The identity of each person participating and/or present during each oral communication; (3) The substance of what was said by each person who participated in each discussion; (4) If a written record was made of the communication, please identify each document as hereinafter set forth; and (S) If any magnetic, mechanical, or electrical record-ing was made of the communication, identify the nature of same and the name of the person who has custody cf same.

C. If you are asked to identify a document please state with respect to each such document: _

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(1) The identity of the person who signed it or in whose name is was signed; (2) The identity of the person (s) who prepared the documents if different from the person (s) signing the document; (3) The identity of the person or persons te whom it was addressed; (4) state the nature and substance of the document; (5) State the date the document was executed if dif-ferent from the date it bears; and (6) If the~ document or copy of it is not in your control or custody, state the identity and most recent known address of the person or entity who has custody or control of it.

F. If you are asked to identify a person, please state with respect to each such person:

(1) Full name by which the person is known; (2) Last known home address:

(3) Last known business address; (4) Last known home telephone number; (5) Last known business telephone number; (6) Name and address of the person's employer; and (7) Relationship to plaintiff.

G. In answering interrogatories dealing with matters prior to 1975, furnish all infermation available to those persons who now employed by or otherwise associated with the University of California who might have knowledge of pre-1975 NEL matters, including but not limited to Tony Zane, Charles Ashbaugh III, Ja:k Hornor, and William Kastenberg. _

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H. In determing which employees of the Applicant may have information related to these interrogatories, include not only current employees of NEL (including but not limited to Neill Ostrander, Tony Zane, Charles Ashbaugh III, and Jack Hornor) and past and present NEL Directors Ivan Catton and William Kastenberg, but also all other persons known by your attorneys and principal NEL personnel to have knowledge relevant to the interrogatories asked, be they presently associated with University of California facilities at UCLA, Berkely, Davis, Riverside, Santa Barbara, Los Alamos, Livermore, or any other facility operated or managed

.by the Applicant, the Regents of the University of California.

I. Contentions are referred to herein by the Roman numeral by which they were identified in Attachments A, B, and C of the stipulation between parties of Cece=ber 1, 1980.

J. You are required to supplement your answers to these interrogatories in accordance with the provisions of 10 CFR 2.740(e).

K. Interrogatories are divided herein by the contention to which they primarily relate, although interrogatories will often relate to more than one contention.

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L. Throughout the questions that follow, Intervecor will refer to ' Applicant's responses to Intervenor's previous set of Interrogatories.

What follows is an example of the usthod Intervenor ut,es to refer to those previous responses:

In an interrogatory under Contentien III, Intervenor will ask, for example, "In Applicant's answer to Interrogatory 43..."

This is referring to Interrc6atory 43 as to Contention III in Intervonor's submission of April 20 (and Applicant's response of May 21).

Whenever Intervenor refers to Applicant's resperse to a particular Interrogatory, and uses the term Interrogator ,/followed by a nunbar.

Intervenor is referring to the previous set of interrogatories, of April 20, and to interrogatorien as to the contention in question in the current interrosatory.

M. In all questions where Intervenor requests the ];ggfdt for Applicant's answers, basis refers to facts, evidence, data, calculations, references and documents. The answer, "It is based en the scientific, professional and engineering judgment ofapplicant's staff" is not a sufficient answer to questions regarding basis.

.[ l Dated: June 10, 1981 FARK POLLoch at los Angeles, CA Attorney for Intervenor COMMIT 1TE TO 3 RIDGE ThT GAP

I-l IhTERROGATORIES AS TO CCf.TEhTION I

" Application Inadequate" i

1.ApplicantstatesinresponsetoInterrosatoriesI/9and10of the previous set of Interrogatories, dated April 20, that the Application was not done in draft form and that no specific individual was responsible for reviewing the accurscy and completeness of the Application.

In response to Inierrogatory I/4, Applicant states that the hi 6hest ranking univer.sity employee responsible for preparing the Application was N. Ostzunler, NEL Fanager.

a. What review was done of the Application, and by whom, prior to certification (on page 10 of the Application) by R.R. O'Neill, W.F. We6st, and J.W. Hobson "that 211 $nformation contained herein, including any supplemen+s attached hereto, is true and correct to the best of our knowledge and belief."

b. ILui Dean O'Neill read the entire Application prior to signing that certification?

c. Had Director Vegat read the entire Application prior to signing that certification?

d. Had Vice Chancellor Hobson read the entire Application prior to signing that certification?

e. On what hsis did each si6 n the certification if they had not read the entire Application?

2. In response to interro6atory No.14, Applicant states that the U. CF F.

HAZARDS ANALYSIS is applicable to UCINs facility because *The University of Florida operates a nearly identical Argonaut-type reactor." Dascribe in detail, and identify all documents related thereto, all effortu made

' by Applicant, besides those resulting in Table III/6-1(a)-(c), to determine similarities and differencec between the two reactors and potential effects on UCIMs Hasards Analysis or Safety Analysis Report.

3. Describe with specificity the efforts being ande ty Applicant, the name or names of the individual (s) responsible for those 6fforts, and the projected date of completion of the data collection and analysis mentioned in response to Interrogatory No. 17d-j, and the projected date of supplczentation of its response.

4. Sinen Applicant has stated precisely the number of hours of operation per yes.r for the reacter devoted to classroom instruction, why is it not possible for Applicant at this date to state what academic courses require the use of the reactor, as asked in Lterrogat ry No.17d?

5. A311 cant states in response to Interrogatory No. 18 that the -

number of graduate students currently de-ui4M upon the reactor is unknowns their hours of use is unknown and it is not known whether these students would be able to use other facilities. If this is true, on

[ what hsis did Applicant assert on page II/ 41 of the Application that l

"+ hare are no. sitita.ble er more economical aIternatives unich can accomplish

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I-2 both the educational ard research objectives of this facility"?

It would appear free the Interrogatory answer t!st Applicant does not know if there are alternatives for at least some of the functions of the facility. Explain the apparent centradiction.

5. Is the number of graduate students currently depending upon the reactor for all or part of their research less than...

a 100? l 5 507 '

e 25? -

d 207 l e 107 l t 87 '

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6. Has the university made any efforts to identify structural weaknesses in the reactor, aside from the C.B. Smith vibration testing study?

If so, describe in specificity all such efforts.

7. Show precisely how $3 54 represents an upper limit on the conversion from delta k/k to dollar value.

8. Does the response to Interrogatcry 20b nosn that $3 54 is the upper linit in dollar value when converting from 2 3% delta k/k, given various possible figures for 3etas er does it mean the opposite. that 2.3% delta k/k is the upper limit in 5 delta k/k when converting from $3.54, given varicus poss nle figures for Beta?

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9. Does Applicant conteni er assert that $3 54 con :,n no way represent a large amount of excess reactivity than 2 3% delta k/k?

a. Please provide calculations and references upon which that answer is based.

10. What is the upper and lower limit of Beta Applicant considers possible for this reactor?

11. What is the upper and lower limit of 3 eta effective App 1" cant considers possible for this reactor?

12. Plosse provide all calculations, measurements, and references upcm which answers to 10 and 11 above are based,

13. Applicant states in respense to Interrogatory 21.f that Applicant's {

operating experience is the basis for the belief that fourteen months l is an adequate calibra+1on interval for certain instruments. '

i l a. Is it not true that NEL has been cited by the Commission fr l failure to calibrate at the required intervals?

b. Is it not true that failure to adequately calibrate the gassous effluent ronitor led to an underestimation of gaseous effluents by at least an order of magnitude?

c. Please pr3vida the hsis for the answers to 13 a and b above.

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14. Precisely where in the proposed technical specifications is the requirement for the heat hiance instrument calibration to bdfound? Give both page, chapter and section number.

15. The current technical specifications refer both to calibration of neutron channels and to calibration of said channels a6minst an independent measure of core pouer. Do the pwy-M Technical Specifications state specifically that a specific kind of neutron channel calibration-the heat balance, or measure a6ainst independent measure of core power--

must be done, or merely that some form of calibration must be done?

Explain the k ais for your answer.

16. Does the heat kluce calibration involve calibration of power level instrumentation? If yes, precisely which instrusentation?

17. Were the heat balanca calibration off by several orders of magnitude, what would be the maxinun possible effect on reactor safety? Se specific.

18. What studies or analysus has Applicant conducted to determine the potential effect of improperly-done heat talance calibrations?

19. In what documents, and in..what specific locations at NEL, are the ALARA written requirements kept at the facility?

20. Besides the current technical specifications, and such copies of 10 CPR that any be at hE. are written reminders of the AIARA requirement and principle posted at-NEL or otherwise mde available?

21. How many copies of 10 CFR exist at LE, where are they kept, and la there any requirement at NEL that all staff, employees, reacter operators and trainees read the relevant sections, applicable to LE?

22. Are NEL staff, employees, reactor operators and trainees ever given a written examination regarding their knowledge of the 10 CFR regule'.%;;ns applicable to NEL?

a. Please give the dates of all such --==4 rations.

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b. Please indicate the test secres from such - =4n=tions.

23. Why does Applicant state in answer to Interrogatory No. 24d that the question is not applicable?

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24. Are the requirements for

a. exhaust stack hei6 ht

b. fic: rate out of the exhaust stack (as opposed to cavability of exhaustfans) included in the current technical specifications?

1 I-4 25, If no data were zwiewed, nor hydrolic studies pedorsed, in preparation of the Application to ascertain the ar'. curacy of the statement in the application about no deep wells in the vicinity of the campus, on what specific basis did Applicant include the assert!on 1 in its Application?

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26. Precisely what information, data, studies, or facts did Applicant base its " scientific, engineering and technical judgment" as desedbed in answer to Interrogatory 26.e.

27. Re Interrogatory answers 26.d

a. If the " guidelines in 10 CFR Part 100 do not appl and are not ,

apprvydateforcomparison"whydidApplicantatpageII,y-1ofApplication 3

use then for comparison? i

b. What specific thyroid dose at NEL boundary for 2 hourc and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months does Applicant assert should be used for judging site suitability of this reacto2;?

c. Does Applicant assert that the consequential dose estimates in case of major accident, used in determining site suitability, should be greater for its facility than the 10CFR100 guidslines given for power reactors?

d. Precisely how extensive an environmental impact is considered by the university to be negligible? .

a. Is Applicant asserting in this answer that it considers the

" largest core damage and fission products release" possible to be a destructive earthquake or a hypothetical core melt? Which of these is meant to be the ans,ser?

f. Precisely what whole body dose and thyrcid dose at 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months does Applicant consider to be consequential to the two scenarios mentioned in e above?

g. What specific fraction of 10 CFR 100 guidelines does Applicant assert are consequential to "the largest core damage and fission product release considered possible"?

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28. If no _al.tarnatives have been analyzed or considered in any way l as a basis for the Statement quoted in Contention I (3) (f), as Ayglicant indicates in answer to Interrogatory 27, how does Applicant assert that the statenent is neither untruthful nor misla=Mnf?

?.9. Does not the dollar amount of excess reactivity that will cause a j specific type of fuel to melt depend upon fuel spacing, type of moderation, reactar structure, amount and shape of fuel loading, and other facters f that vary from reacter to reactor? If r.:swered in the negative, provide detailed basis for yetT answer. _

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30. Applicant stm.es, in answer to Interrogatory No. 28b, that Applicant has undertaken no study to assess the correlation, if any, between SPE E ,

3CRAX, and Argonaut reactor experience.

a) besides the analysis contained in Appendix A of Part III ef the Application, has Applicant conducted any other analysis to ascertain the applicability of the SPEE and/or BCRAX tes.s to the UCIA reactor.

b) If so, please specify that analysis, its results, and any documents that exist documenting it.

c) If no such analysis has taken place, and no stud done, on what hsis is the assertion quoted in Contention I(3)y(g) made?

Do not merely indicate technical, scientific or prcfessional judgnent of Applicant's staff, but the IA2 f.tupon which that judgment is based.

31. Given the statement with the improved syntax cited in answer to Interrogatory 28, precisely what facts, analysis, and evidence does Applicant possess to support the assertion that SPERT and 3CRAI tests indicated that inadvertent reactivity insertions of $3 54 will not cause ER fuel elements to rupture?

a. Cite the specific reports of the SPERT and 30RAI tests, with name of study, author, publication, and date that support that stat s ent, rnd indicate which pages of those rvports contain the facts, anclysis and evidence upon which that statement is hsed.

h. At what temperature will MTR fuel begin to rumure (as opposed to melt)?

c. On what specific facts, analysis, and evidmico does Applicant rely in answering b above, and on which it relies to indicate $3 54 reactivity insertions cannot bring temperatures in Argonaut reactors' fuel to that level?

32. Given the answer to 2Sh, that the question seeks information Applicant cannot provide without conducting extenrAve scientific and engineering studies ani evaluations which Applicanc cannot do given personnel, time and resource constraints, on what basis does Applicant assert that the BORAX &nd SPERT data and inferences drawn from said data have validity far the UCLA rs wtoe?

33 Does Applicant possess an$ information, data, evidence, stuiles, 4

facts,-or documents besides the 1960 Hazardr Analysis which supports e

thestatementinContentionI(3)(g)? If so, please detail with pecificity all such irformation, data, evidence, studies, facts, or documents.

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l II-I INWRJt0GATORIES AS TO CGiTENTION II

" Wrong Class License"

1. How were tra figures regarding the allocation of hE expenses and i supplies to the Reactor operation listed on Page I/2-1 of the Application arrived at?

2. Please identify all documents used in the process of annual budget requests fcr NEL and all documents used in the process of deter =*M g what budget should be allocated to NZL.

3. For the last five years, please indicates (a) the initial budget aygugiate request for NEL i (b) the final budget appropriation

4. In response to Interrogatory II/10, Appliesnt states that

'The Dean in consultation with his faculty reviews all programs within SEAS i on the tasis of the general contribution the program nakes to the academic I mission cf the SEAS." *

a. Identify all documents regarding reviews of NEL referred to above.

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5. The response referred to in 4 above continues: "An in-depth review generally occurs only when theDean or the faculty make a specific proposal to add er delete a program."

a. Please identify all in-depth reviews, by date, that have taken place regarding NEL. i

b. Please idestify all documents regarding said reviews.

6. Please describe specifically and in detail what sample preparation by students, as mantioned in answer to interrogatory 18a, entails,

a. Dom it include ever crushing of ore samples into powder or dust?

b. Does it include svar placement of sample into the rabbit?

c. What else does it include?

d. Do students receive academic credit for sample preparation?

e. Are students on.1 ated (i.e. graded) for their sample preparation efforts?

f. Is sample projaration part of any regularly scheduled, accredited 1 nondomic course? If so, specificy which courses.

7. Please describe specifies 11y and in detail what data analysis by students, as mentioned in answer to interro6atory 18a, entails.

a. De students receive academic credit for this data analysis?

b. Aru stadents evaluated (i.e. graded) for their data analysis efforts?

c. Is this data analysis part of regularly scheduled, accredited :

academic courses? If so, specificy which courses. , ,

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8. llegarding responsa to Interrogatory No 31aa

a. What is the diffe.rsnce , in terns of the educational values out-lined in anmnr to 31a, between being a student working at IEL on its "entrrenal" activities (for users such as Dr. E='C ) and being a new encloyee at a ec=ercial reactor in support of its connercial activities,

b. Does the. Applicant equally assert that working at a hamburger stand on campus, in the campus secounting department, or at the campus police department is educational in the sense in which Applict.nt uses the concept " educational in 31a?

c. Would being a new employee at a nuclear power plant be

" educational" in the sense used in response to 31a?

d. If the answer to e above is yes, what makes that commercial plant not " educational" in terms of 10 CFR sections outlining clasa 103 and 104 licenses? ,

e. If the answer to e above is no, why not?

9. Does not tha University of california cartify some for=s of educational experience as educational by certifying those experiences as worthy of academic cr p it?

10. Can educational experiences obtained by a student be used try that student in ob+=4ning a degree from the University of California if those experiences have not received a grant of academic credit by the University?

11. Do appropriations free the State Tea 1=ture to the UC Regents fund any commercial enterprises in which students are employed but for which they do not receive academic credit? If so, please specify those enterprices.

12. Who is responsible for the collection of and analysis of data mentioned in response to Interrogatory 35: when will that process be completed: and when will Applicant supplement its response?

13. Why could 135AL, 3L, and F no longer be offered if the reactor were not relicensed?

a How many students take each course per year?

b How rany units do students receive for each course?

c Are these courses quarter-long courses, or do students only take each course for a portion of the quarter? If a portion, precisely what portion?

d) If the reactor were converted to a simulator, which of the courses could no longer be offered?

e) What records exist detailing answers to 13 a through d? ,

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14. Precisely why can no facility at another campus or at another location adequately ougyw.i. the nuclear engineering program at UCIA?

a. What data, evidence, studies, or other facts does Applicant have to support its response to Interrogatory Wo. 37?

b. Since chsaroom instruction involving reactor operation only consumed 31 hours3.587963e-4 days 0.00861 hours 5.125661e-5 weeks 1.17955e-5 months of reactor operation in 1979, 46 houre in 1980, and only 10 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months in the first four months of 1981 precisely what is it that askes utilisation of another reactor for the 10-15 hours per quarter of classroom instruction currently needed impossible?

c. What efforts has Applicant ande to determine the suita.bility or adequacy of using another reactor for the classroom instruction now utilizing the UCLA reactor?

d. What documents exist regarding efforts identified in c?

15. Have Manaes from other conegas and universities utilized UCIA's reactor for instructional purposes?

a. Which colleges and universities have so done?

b. Why is it possible for other universities and colleges to utilize UCIA's reacter for instructional purposes but not possible for UCIA to utilize reacters at other colleges or universities for said purposes? (If due to the nature of the UCLA progran, detail with specificity so.id nature that makes use of other facilities impossible.or impzsetical.)

16. Please indicate when the compilation and analysis of data identified in response to Interrcgatory No. 39 is expected to be completed, by whom it is being done, and when the answer is expected to be supplemented.

17. As used in response to Interro6atory No. 41, precisely what does Applicant mean by the term "other extramural users?" Do not answer in the negative (i.e., all users who are not...)

18. Please list by name and institution all "other extramural users" for 29f;C and 1981 to date.

19. Please list reactor part-hours for 1980 and 1981 to date for an extramural users identified in response to 18 above.

20. In answering Interrogatory 44 affirmatively, is Applicant asimitting that there are commercial uses to which the reactor is put?

21. Does /pplicant admit that the reactor is put to som1 commercial uses?

22. For each year 1979 through the present, please indicate in dollars -

or percents the cent of owning and opera'dng the reactor devoted tos (a) classroom instruction, (b) NEL experiments, (c) Fainteance, (d) UCLA users, (e) other coH eges and unimersities, (f) denonstrations, (g) commercial.

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23. By what means or method does Applicant determine the cost of owning and operating the reactor devoted to the categories in 22a-g?

Be specific, show all calculations, and identify all documents in which facts, definitions, or other informati:m is recorded relative to said methods or means.

24. If Applicant is unable to determine the cost of owning and operating the reactor devoted to the categories in 22a-g, on what basis can and does Applicant assert that more than 50% of the cost of owning and operating the reactor is devoted to education and research as opposed to sale of services, energy, or products?

Be specific, and identify all documents which support Applicant's answer.

25. Do the fees recharged to commercial users fully defray the cost of operating the reactor for commercial users, including their share of the costs incurred by Applicant in owning and main + mining the reactor?

26. Why is the cost of operating the reactor for one hour at full power unknown to Applicant?

27. What factors would influence differences in cost per porthour when reactor is run for commercial users and when run for classroon instruction?

28. Does Applicant have a cost figure for an hour of reactor operation?

a) If so, what is it and how is it obtained (showing the calculations)?

b) If not, why not?

29. Please identify all docu:nonts in which SEAS Academic Senate, Chancellor, UC President, or UC Regents have authorized and/,or sandated NEL to provide the non-academically-accredited activities that Applicant claims are part of the educational function of NEL. Identify by page number the sections of each document that so andates NEL.

tory l'o. 56 indicates that Applicant uses the term

30. Answerontopage "research" Interrogn/1-5 III of its Appliution as "any use of the reactor that ,

j is not better described as being related to ' classroom instruction' or ' maintenance. '"

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a. Is this the standard use of the term "research" at the university?

b. Did the three pert-hours in question constitute research in the s+mMud use of the term at UCIA?

c. Does UCLA have a system for approving the scholarly nature of research conducted by its researchers?

d. If so, please detail that system or systems in specificity.

e. Is gem irradiation for commercial gem dealers consider.si "research" as the term is used in the Application table in question?

f. If so, on what basis-bisides it not being instruction or maintenance--

is it viewed as research?

g. Is era assaying for Uranium West considerud research as the term is used in the Application table in question?

h. If so, on what basis-besides it not being maintenance er instructien- -

is it viewed as research?

II-5

31. In what way or ways does gem coloration for profit-makirg jewelry companies constitute scholarly p esuits or advancement of scientific knowledge? 3e precise.

32. In what way does are assaying for a profit-making uranium company constitute scholarly pursuits or advancement of knowledge?

33. Please identify any articles that have been published in the scientific and technical literature as a result M the gem-colcration and ore assaying activities of NEL listed in the Application page III/1-5 as "research."

34. Please identify all university committees that have approved the )

cro-assaying and gem-coloration activities as "research" worthy of ;

being undertaken by the university. 1

35. Does Mr. Ashimugh directly receive any financial compensation due to the irradiation of gens in the reactor, aside from indirect compensation as re-charges by the university? If so, please detail ~

all such compensation and from whom it is paid?

36. Which particular gemelogists do the diamonds belong that are identified in answer to Interrogatory 57b?

37. By "gemelogist" does Applicant mean an individual or privs.te company who enga6es in concerce in gens, jewelry, and precious stones?

38. If not, precisely how does Applicant use the torn?

39. Is Applicant's response to Interrogatory 59, in which it states that 4

there are appr

mtely 55 students in the nuclear engineering program, refezzing to students in the thermal, chemical, and nuclear engineering program?

l l go, If answer to 39 above is affirmative, how any of the 55 students are involved in the nuclear part of the tia.,; part program?

41. If the answer to 39 above is negative, was Applicant asserting that there are approximtely 55 students in the nuclear part of the theral, chemical, and nuclear engineering program?

l 42. If the answer to 41 above is affirative, how mny of those students each year use +he reactor as p rt of their accredited studies?

43. The Daily 3 ruin of May 22, 1981, quotes UCLA nuclear engineerir4 Professor William Fastenberg as saying that there has been a significant drop in the number of applicants applying to the, engineering school's graduate department of nuclear enginnering. Is that statement correct?

a. If there has been any drop at all, please indicate the number of applicants applying for all years for which figures are available.

44. How mny theses were completed in the last three years which necessitated use of the reactor? - ,

45. Precisely what is the difference between the term " extramural users" as used in response to Interrogatory 41 and the term " commercial"?

I

. . -j III-l Interrogatories As To Contention III

" Inadequate Managerial and Administrative Controls"

1. Has Tony Zane, Jack Hornor, Nein Ostrander, Charles Ashtaugh, Maurice Thelia, or Viniam Toman ever operated the NEL reactor after the expiration of their operator or senior operator license ,

without having filed a timely application for renewal? If so, l please specify the individual (s) involved and the time period in which such operation occurred.

2. Applicant states in answer to Interrogatory No. 33 as to Contention III, regarding Intervanor's second set of Interrogatori-es, that J.W. Forner from approxi mtely 1975-79 was appointed to perform the " audit function" and that thereafter that function was "taken over by the UCLA Office of Internal Audits." However. letter of March 18, 1981, from Neill Ostrander to Robert Tsdesco, Divisiodpf Licensing, USNRC, indicates that NEL as of Narch 1981 was "pursuihg an investigation of using the UCIA Internal Audit Office to parform a compliance-type audit of our !

operational records and procedures. This investigation was recommended by '

the RUC on June 17, 1980 but postponed to coincide with the annual review following the close of the calendar year."

a. Explain the apparent contradiction between the Interrogatory answer and the Ostrander letter.

b. Was the UCLA Office of Internal Audits appointed to perform the

" audit function" in 1980?

c. Did it perform such an audit in 1980?

d. As of Narch 1981 did the UCIA Office of Internal Audits have the responsibility of conducting such an audit for NEL?

e. Has the UCIA Office of Internal Audits conducted such an audit of NEL in 1981?

3. Besides audit results reported in the minutes of the Radiation Use Committee, what records exist regarding audits of NEL?

4. Please specifically identify any and all reports, by date of said report, ode to the FRC or its predecessor agency described in 6.5.2.1 of the proposed Technical Specifications from 1960 through the present.

5. Please specificany identify any and an reports made to the NRC or its predecessor agency described in 6.5 2.2 of the proposed Technical Specifications from 1960 througn the present, by date of each such report.

6. Why was Applicant able to answer Interrogatory 54 regarding the visit by Culver City High School but unable to ansunr the same questicns regarding the other tours of NEL described 55-60, other than referring Intervenor to operating lors and visitor logs? _

7. Why has the question of the reactor's controls by unlicensed operators tever, to applicant's knowledge, been reviewed by any of NEL's supervisorial committees?

8. When and by whom was the procedure or policy outlined in response to

, -.- - , , ,,c-,.,, w e m m e ,

4 III-2 Interrogatory 65d promulgated and approved?

a. Did the NRC or the AEC approve said policy?

b. If so, when was approval solicited, when granted, and what documents exist regarding said approval?

c. If not, why was NRC or AEC approval not solicited and/or granted?

9. Mas Applicant subsequent to 1966 received written permission from the Commission regarding operation of the reactor controls by unlicenrod operators?

a. If so, please identify all documents which record that permission.

b. Has NEL solicited such approval since 1966?

c. If yes, on what occasions, what was the result, and what documents exist regarding that solicitation of approval?

10. Answer to Interrogatory 67b states: "The Comnission's respense has been interpreted by applicant as not prohibiting the practice" (referdng to permitting manipulation of the reactor controls by an smlicensed cperator under the supervision of a licensed operator).

a. Which specific response by the Commission is Applicant referring to in the statement quoted above-please give date of said response and name of Commission official responsible for said response.

b. In detail, give Applicant's interpretation of said response and why it does not prohibit tSe practice.

11. Does Applicant have any document from the Commission supportin6 Applicant's contention in response to Interrogatory 68?

a. If so, please detail any and all such docunents,

b. If not, on what specific h sis (not merely technical, scientific and professional opinion of your staff) does Applicant kse said contention?

12. Please answer the questiens in Interrogatory 54 of the April 20 Interrogatories by Intervenor (as to % ntention III), parts a-p, for the tour groups prerwnt for (a) run 2101, (b) run 2115, (c) 2138, (d) 2213, (e) 2220, (f) 2228, (g)227 and (n)5. (h) 2281, Pierce (i) demo Collage 2309,of(j)7-1-79, 2311,and (k) 241, (1) 2459, (o) demo for "75(n) 2463, Junior High School children" on 12-12-73.

13. For each answer (a)through (o) above, please answer the follouing ques ions.

a. 'Jas the scran trie reint reached?

I

b. Did any " unusual in'cident", accider t or other abnomal occurrance occur as a result of the unlicensed operatcos) running the reactor?

c. If answer to (b) is affimative, please detail precisely uhat event occurred, how it occurred, and how it was rectified.

~

14. In answer to 54n, no specific Connission approval for the operation of the reactor by visitors was given. Did the Connission ever give suecific approval for any visitors to 5:n the reactor?

a. If yes, under ifnat conditions was pemission granted?

b. If no, do any p cedures exist which screen potential unlicensed operatrs or give pe=ission for their operation of the reactor?

?. .

' c. If answar to (b) is affin:ativa, pler.sa detail which body is rasponsible and under what conditions is pen:ission granted.

INTERROGATORIES AS TO CCNTENT1Ca' IV

" Violation of Regulations and Technical Specifications"

1. Please identify all Commission inspection reports and Notices of Violation or Noncompliance, 1958 threugh 1967. both for the construction license, operating license, and SNM license, ty date of issuance of the report or Notice, its code number, and the type of inspection conducted.

2. Why is it unknown to Applicant how long prior to the notice of non-ce plianos the acceleration nozzle was also not on top of the exhaust stack?

3. Does any of Applicant's staffperson;have personal knowledge to answer Interrogatory 22? If so, who, ani what is *Jiat personal knowlsdge?

4. Have any employees of Applicant ever received reportable radiation doses tha+ were reported to the Cosmission? If so, please describe each such incu ent, including date.

l i l

i m_..__ s

V-1 l

l INTERROGATORIES AS TO C0!CDirION V

1. In response to Interrogatory 8d, Applicant states "in general the effects are observed to be no61161ble." Please state whether there have ever been times when the general observation of negligible effects has not been the case. If so, please specificy the instances in which effects were not no611gible and the degree of said effects.

2. Is it_ physically possible for a sample worth a.12.3%hk/k to physically fit ins $de a pneumatic tubo " rabbit"?

b. ! 2.1% hk/k to physically fit inside a pneumatie tube " rabbit"? l

3. Is it ph/sically possible for a sample worth a.!2.1%hk/ktophysicallyfitinsideanirradiationport? l b, t 2.35 Ek/k to physically fit inside an irradiation port?

4. Is it physically possible for a sample worth + 2 3% hk/k to be inserted l into the reactor, separate from the issue of whsi.her such a sample could !

fit into a pneuantic tube sample container or an irradie. tion port?

a. answer the same question for a sample worth ! 2.1%

5. Precisely what was " vaguely described" about Interrogatory No. 18's l "hoothetical reactivity insertions"? )

a. Why does wha,tever va6ueness is identified in respense to 5 abeve i make impossible an answer from Applicant? l

6. If the answer to 2 above is no (for either a or b), please detail l specifically why it is not physically possible, and provide all l calculations and describe all documents that support that answer.

7. If the answer to 3 above is no (for either a ar' b ). please detail specifically why it is not physically possible, and provide all calculations and describe all documents that support that answer.

8. If the answer to 4 above is no (for either 4 or 4a), please detail specifically why it is not physically possible, and provide all calculations anf describe all documents that support that answer.

9. Can a sample worth - 2.3Qk/k be withdrawn from the reactor without the control blades being inserted first if the sample is a} inserted through the pnetunatie, tube b) is inserted in an irradiatio.i port?

10. If the answer to 9a or b above is negative, explain precisely what mechanisms make such withdrawal impossible. If there are no mechanisms, so state. If there are procedures, rules, or other humsn controls, please describe them specifically. _

c --

. i V-2

11. What is the largest worth sample (t), with 2.3% considered larger than 2.15 if both are negative worth samples or positive worth samples, that can be inserted in the reactor without intervention of physical prevention mechanisms?

a. On what facts, documents, calculations, data is the above answer lased?

12. In Applicant's Response to Interrogatory No. 26b, does Applicant mean that sample wcrth is estimated-not calculated nor measured?

a. If yes, precisely hew is it estimated? !

l

13. On which forms is general estimate of expected sa ple worth currently included?

l

14. Are there any interlocks, inhibits or scram systems that would prevent ,

the insertion of a sample worth ! 2.3% d k/k? i

a. Are there any other physical mechanisms that muld so prevent.

15. How is the tenperature coefficient of reactivity measured? Be precise.

16. What is the overall temperature coefficient of reactivity (not merely l the water coefficient)? If the coefficient varies at different temperature i ranges, or with length of operation cf reactor, please give different I coefficients for those temperature ranges and operating periods.

State how and when those coefficients were arrived at.

17. How does NHL measure and/or calculate the void coefficient of reactivity?

Be precise.

18. What variation in measured and/or calculated void coefficients has NEL l found for its reactor? Please give the low and how figures.

19. Does Applicant assume that the measured value for tne void coefficient included in the Application in Table III 6-2 is more accurate than the figuro employed in Application, page III -l?

a. If not, why not?

b. If yes, does Applicant thus assume that the calculations included I in Attachment A ofSectiot. III of the Application are incorrect in so far i

j as those calculation relied on a less accurate value for the void coefficient than now appeaza correct?

c. If no to b above, explain your ars'eer.

d. If yes to b above, does the use of the more correct void coefficient have the effect of lowering the level cf excess reactivity insertion necessary to cause melting of the cladding, if Attachment A is relied on and no other factors change?

e. Are thers any compensating changes that likewise modify Attachment A of Section III?

f. If so,specify these and indicate, ty calculation and reference. - 4 how they alter the conclusions of Attachment A?

g. Are there any other changes that would reduce the estimated level of excess reactivity insertion necamanry to cause melting of ths fuel c32dding?

h. If so, specify these changes and indicate, by calculation and reference, how they alter the conclusions of Attachment A.

V-3 ..

20. Why has Applicant not undertaken the analysis required to revise the 1960 Hazards Analysis section included in Application as Attachment A of Section III utilizing the measured void coefficient instead of the 20-year-old estimted value?

21. Applicant states in response to Interrogatory No. 41 2at, despite current use of values of beta and 1 other than those used in the Hazards Analysis, the graphs of excess reactivity versus period "probably characterize i the general reactivity-period relationship for Argonaut-tyte reactors."

a. Does UCIA have any graphs, charts, or other data that provides the specific reactivity-period relationship for the EEL reactor?

b. If not, why not?

c. If so, please describe thess graphs, charts or other data with specificity, and indicate how they differ in specificity to the reactivity-period relationship shown in the Hazards Analysis graphs.

d. What is the precise excess reactivity insertion, given the best i estirate, calculation or measurement available to Applicant, ccrresponding to a 9 nillisecond period?

e. If Applicant has no answer for question 21d above, why not?

22. Who at Applicant's staff is analyzing the " uncertainty question" identified in response to Interrogatory 41f?

a. How is that analysis being done?

b. When is said analysis expected to be completed?

c. Will Applicant supplement its answer at that tine?

23. Why does Applicant use a value for beta equal to 0.0065?

a. What analysis has Applicant done regarding that choice?

b. Please provide that analysis, and supporting calculations and

' .*en tify supporting refereness.

24. Does the use of the " conservative" value of teta (effective), without altering the Hazards Analysis calculations indicating 2.3%d k/k linit on reactivity, make that 2.Y limit less " conservative"?

a. If not, why not?

b. If a higher Beta were used in the Hazards Analysis than is now considered " conservative," to be conservative, should not the 2.3%

limit be lowered? ^

c. If answer to b above is negative, please explain your answer.

25. Applicant states that Professor Cattan is not on long-term absence and regularly ccmes into the NEL office and, one asacaos, can otherwise be reached. What did Professor Catton mean by the ctatement cited in Intatrrogatory 44 Please have him answer 44 and h4a, not merely report what Applicant's staff believes Professor Catten meant.

~

26. Why does Applicant not know how nuch Wigner energy its graphite has stored and the maximum it could store in the next 20 years, as asked in Interro6atory 45?

a. If Applicant does not know the answer to Interrogatory 43, and indicates it doesn't have the time, personnel, nor resources to find out,

V-4 how does Applicant intend to demonstrate that Wigner energy cannot be a problem at its facility?

b. Why hasn't Applicant made such calculations and analyses?

27. Applicant states that a positive temperature coefficient for graphite is " hypothetical." (Interrogatory 46. )

a. Does Applicant mean there is no positive temperature for graphite?

b. If so, please detail all evidence, data, facts, calculations, and references you can produce to so demonstrate,

c. If not, what does Applicant mean by the torn " hypothetical" in this Interregatory answer?

28. Does Applicant possess any evidence, facts, data, calculations ce references which would indicate there is a positive temperature coefficient for graphite?

a. If so, please detail.

29. Please describe in detail the occurrences which led to the AEC inspector informing NEL of the apparent positive temperature coefficient for graphite supposedly noted by the University of Washington.

30. Did it turn out that such a coefficient indeed existed at the University of Washington?

a. If not, what caused the initial rescrt and what evidence centradicted it.

31. Did UCIA follow up on its statenent to the AEC inspector at the time of the discussion of the graphite coe:lficient to test the coefficient for its reactor?

a. If not, why not?

b. If so, how did UCLA test for that coefficient, when did those tests take place, and what were their results?

32. Has UCLA at any other time conducted tests or other analyses to determine the reactivity coefficient for graphite?

a. If not, why not?

b. If yes, what specific tests or analyses were conducted, when were they done,~ vhat were their results, and what, documents exist relative thereto?

33. Does the graphite in use at the UCLA reactor have at any temperature above room temperature a positive coefficient?

a. If so, at what temperature ranges is taere a p%1tive coefficient?

34. Why doesn't Applicant know t.m answer to Interrogatory 47e. .

l

35. How can Applicant rely on Scrax results in its proposed Technical Specifications and its Safety Analysis and not be able to answer Interrogatory 48a?

36. Precise'.y what does Applicant me: n by " interpolated" rather than

" extrapolated" in answer to Interrogatory 48b? ,

1 i

l V-5

37. Answer Interrogatary 48 a through c, inserting the term " interpolated" for " extrapolated".

38. Why has Applicant not reviewed data r: ore current it.at the Sorax data

$ a determing the safety of its facility regarding excess reactivity?

39. On uhat basis dcas Applicant state that it cannot answer, without conducting extensive scientific and engineering studies and evaluations, Interrogater/

50. which merely as:4 what Applicant means by portions of its Safety Analysis?

40. What level of excess reactivity and whr.t corresponding period does Applicant currently centend reprecants a sufficiently conservative levol to warrant relicensing of the Isactivity, sufficient to adequately protect public health and safety?

a. What is the haain for that answer?

b. Besides the Application, what documents support that answer?

i l

l I

l

VI-1 IFTERROGATORIES AS TO CONTENTION VI

1. Were TLD's placed in Culver City ever used as a control in the TID program?

a. If no, and if one was placed in Culver City, why was it so placed?

b. If yes, where specifically was it placed, inclurH ng the name of the owner of the place, and why was it so placed?

2. Were TLD's placei in the Iab Nanager's office as part of the TID program or during the period of the TLD program?

a. If yes, why was it or were they placei there?

b. Was a TLD placed in the Iab Manager's office considered a control?

3. Provide all results of TIDs placed in Culver City or Isb &na6ers office.

4. Precisely how irt Applicantly attempting to determine whether or~ not the TLD's were pi: king up radiation from concrete or granite?

a. When did mis analysis h 1n?6

. b. What have been the results to date?

c. When will the analysis be completed?

d. Who is specifically responsible, by name of staffperson(s), for such effort?

e. What data are currently available?

f. Using precisely which measurement devices is this effort being done?

5. Precisely why cannot the TLD results be "used as an accurate measurement of the dose due to Argon 41 stack emissions."

6. If the TID results cannot be so used, how does Applicant intend to show that it is in compliance with AIARA and 10 CPR 20.106(b)(1) -d (2)'

Be precise.

7. If the statement quoted in Interrogatory 13 is believed to be trv a by Applicant, as indicated in the answer thereto, how does Applicans reconcile that lack of confidence in the TLD data with tha statement in response to Interrogatory 11 that Applicant "has no reason to doubt the validity or accuracy of the TLD pro 6 ram measurements"?

8. Re Interro6atcry answer 18a, when is the general answer not accuratc?

j 9. Precisely, how is background deter:nined in the film badge pro 6 ram?

10. Where are the control film hdges kept-indicate.Wmng, room number, vertal identification of each room (i.e. health physicist's office),

aml location within said room (i.e. cabinet, desk drawer)?

l

11. 'ihat is the range of radiation assumed for tackground in the film badge pro 6 ram (both area pro 6 ram and other pro 6xam).

12. In Inspection report 80-03, p2, it is reporte'. that Applicant's staff -

have undertaken a study to make independent measurements of the Argon 41 emissions. Those readings have been compared with the nessurements of the stack gas moniter, indicating a discrepancy between the two methods of asasurement.

a. Indicate whether this is true.

VI-2

b. What is the highest Argon reading obtained at 100 kWth by either

.u_ method?

c. ht is the average Argon reading obtain at 100 kwth by the aethod independent of the 6as stack monitor?

d. ht is the correction factor (the actually number) being used to correct the gas monitor remdhgs?

o. What were the results of the ev=mination of the methods of the study and the additional samples and coraection of identified souces of sampling or measurement errer?

f. What is App'dcant's c2rrent best estiante--i.e. most conservative-of Argon concent;ation at the point of etiasion and inside the stack (use micro-curies of Argon 41 per milliliter of air, or some comparable unit involving both curies of Argon 41 and liters of air).

g. What documents crist relative to answers 12a-f above?

21. By name, who is responsible for the collection and analysis of data identified in response to Interrogatory No. 21 when will that process be completed and when will that answer be supplenented?

a. How is the collection and analysis of data being done?

b. What data is being collected and analyzed?

22. To the knowledge of Jack Harnor, John Evrasts, Walter Wegst, or Harold V. Brown, has fi]mthat was beyond its expiration date ever been pzovided to NEL for use in film hdges?

a. If so, indicate who has knowledge of such instances.

b. If so, iniicate each occasion cnwhich this has occurred?

c. Has such film ever hen used by hE ?

d. And how was the fact of the film's expiration discovered?

e. Were any actions taken thereto, if such instance occurred?

23. Who at the UCIA Radiation Sefety Office does the film badge analysis?

24. What is the reliability in terms of film hdge measurenant as opposed to recovery?

25. h t is the probability of error for film udge => w nen?

26. How often does the filn hdge technician correctly determine the. exposure of the film badge with exposure unknown to technician, and hew often does s/he fail to correctly so determine?

27. With a Beta calibration curys for film badgas covering eXPocures from 35 to 22000 mr i a. what is the accuracy at the bottom of the calihation curve (i.e. 35) with such a vast calibration rarge?

b. what is the acetracy at Beta raadings below 35 mr (e.g. 5,W,20 m.)?

VI-3

28. How was the mistaken . calculation identified in response to Interrogatory 27 arrived at?

a. Why did the calibration factor c. go between 1978 and 1979?

b. How can a calibration factor be correct for one year and not the next, in this particular case,

c. Were emissions far part of 1979 incorrectly estimated until the changed calibration factor was discovered?

d. What caused the discovery of the changed calibration factor?

e. Was calibration error involved?

29. Has NEL ever purchased, built or utilized any device te monitor directly for Argon-41, other than stack monitors and not referring to devices that measure gross radiation as opposed to specific radioactive isotopes?

a. If so, please describe each such device ard the manner, time and places in which it has been used by NEL?

b. Has NEL over monitored directly iar Argon-41 radioactive isotopad within the MLth Sciences M14ty?

c. If so, with what device, what was its threshhold, sensitit;.1,y and accuracy, and what were the results?

d. If not, d2y not?

30. What made the size of the tanks being considered at the time, as per response to Interrogatory 30, " impractical."

31. What is the threshhold, sensitivity and accuracy of the Model PNR-4 counter?

32. Is the REM counter always present in the void ares / equipment room when the reactor is running? If not, how often is it so placed?

33. Is the occupancy analysis in the letter and attachments Wegst to Curtis, December 3, 1980, indicative of greater than 10% occupancy on the roof?

a) What precise occupancy factor does Applicant state is the maximum occupancy factor possible for the Soelter Hall / Math Sciences roof?

34. How many total " random olnervations" of roof occupancy, to+=11* T how much total time on the roof, over what period of time, have been made?

a. de'.ng what peruentage of those observations were individuals not seen on the roof ares?

b. how many total people were observed on the roof during those observations?

35. Does Applicant consider the shielding effect for gamma radiation of the Math Science Building walls, ceilings and floors 100%?

a. If yes, on what factual basis?

b. If no, what shielding effect is believed to be accurate?

Y

- . - - . , _ . , , , _ ~ , . , . _ .

VI-4

36. On what basis does Applicant assert that " occupancy factors are not additive"?

37. If 30% of the work day people occupy the meteorological station and 10% of the work day people occupy the area adjacent to the meteorological station, on what basis does Applicant assert that the occupancy factor was1d be not more than 305?

38. Why would decay tanks cost $20,000 in 1980 dollars accezding to Interrogatory No. 44, when Kastenberg's estinate to Galler just a few years earlier was in the range of $1000?

39. Explain the apparent contradiction in answer to Interrogatory No. 44 and Applicant's answer to NRC Staff Q.estion of April 17, 1980, on same subject indicating cost of between $5000 and $100007 acquired, and how nuch remains 40.

to beHow muchfor acquired equipment a functionhas been delay currently / holdup tank system?

/ decay

41. Applicent states in answer to Interrogatory No. 45 that increasing the stack height by eighteer leet would yield no calculable benefiti i

How does Applicant reconcil. that answer with study conducted for hT.L by Applied Nucleonics, dated February 1975, indicated calculable reductAons in emission concentrations and/or population doses? (Furthermore, the Applied Nucleonics study based its A:Jgon concentration emission figure on an estimte that van considerably smaller than what is now the etc rent esti:mte of Argon concentration).

42. How would the assumption utilin.d by Applicant on August 22, 1980, regarding NRC questions as to exhaust plume centerline being closer to !SA air intake than assumed in the Rubin thesis affect Rubin's conclusion of 125 MPC inside Math Sciences? What would be the revised figure given the new assumption?

43. Why is it not Imoun what radioactive element comprises the largest source strength next after Argon-41 at the exhaust stack?

44. On what basis does Applicant assume that the source strengths and dose rates of all nuclides besides Argon-41 emitted from the stack are "n*gliGible"?

a. What precisely does Applicant mean by the term "narlirible?"

45. When Applicant says in the 1960's the l= kine Cobalt-60 source was "probably" stored in the reactor high lay, where else could it have been stcred?

46. Frecisely what is menat by " reactor high bay?" Does it mean the rector room?

47. Precisely whstre in the reactor high bay was the 1960 and 1975 laakinc Cobalt-60 source stored?

h8. Was there spent fuel in thespont fuel storage hole at any point during the time. the Gotalt-60 source fron the early 60's was stored there? -

a. If so, was that fuel ever shipped out of NEL, and if so, when?

E VI-5

49. The 17/5 incident of storage of a leaking Cobalt 60 source--

was the lead pig stored at any time in a spent fuel storage hole?

a. If not, precisely where was it stored?

b. If so, has spent fuel ever been stored in that hole, either at the time of the Colmit-60 storage or thereafter?

c. If yes to b above, has that fuel ever been shipped out, e come into contact with fuel that has been shipped out; if so, when was that ship ment?

50. Indicate all locations within the reactor high bay where the source Cobalt 60 was ever situated. ,

51. Were any materials (e.g. wipe materials, clean-up materials, etc.)

ever contaminated by the leaking Cobalt-60 scurces?

a. If so, where were these con +mmimted materials placad?

b. Specifically, indicate the cicaest proximity any of these contaminated materials my have had to spent fuel, spent fuel storage holes, or equipment used in moving spent fuel to 1= Ming location for shipment, er equipment used in said Imdinf.

52. Indicate the closest proximity any Colalt-60 source or Cotait-60 from any source may have come to spent fuel, spent fuel stcago holes, equitment used to move spent fuel to loading location, or equipment used in said 1= din 6, be it loading of reactor, unloading of reactor, loadig of shipment vehicle, leading or unloading of spent fuel storage hole. l for Cotalt-60 53.HasApplicaatsinceJune1980 monitored /anysiteswhereinCotalt-60 leaking source e contacinated m terials that may have come into contact with Cobalt-60 my have been situated at Applicant's facility?

a. If yes, identify with particularity each site monitored ar.d the date of such monitoring and the results.

b. If no, why not?

54. Are there any sites at Applicant's facility wherein Cobalt-60 leaking i source or contaminated storials that may have come into contact with Cotalt-60 may have been situated have not been monitored for Colait i 60? j

a. If yes, identify with particularity each such site and why it was not monitored.

55. Please identify any effluent of the reactor that may centain cobalt-60 and how that Colmit-60 is there.

56. Please identify ar.y other Colmit-60 contamination that has occurred at the $cility and that may have occurred, by date, description of enurce of Cobalt-60, what was contaminated, and proximity of any materials that may have been so contaminated to_any thing or individuc1 who may have come in contact with the June 1980 spent fuel shipment or vehicle or related equipment. l 5(7. Have the measured forspent fuel storage that specific holes Ifbeen isotope)? so, when, monitored and directly what werefor Coba]t-60 the resulta?

VI-6

58. Is it possible that Cotait-60 froa IEL, or Cokit-60 produced by or stored at NKL at any tine, any have contributed to the contamination of the shipping vehicle and shipping catainer in June 1980?

a. If not, specifically why not--not merely opinion, but the facts and all the facts that support that opinion?

b. If yes, what means of estc_ ination and what source of . con += m4 = tion are considered possible in t+:nt situation?

59. Has the lead pig in which the Cobalt-60 sources wera stored been shipped out e do they or it remain at NEL?

a. If shippped out, when?

b. If remmiMng, was it or were they monitored for Cobalt-6G in the last 12 months-if so, what were the results: if not, why not?

60. Why did not lEL inform the Department of Transportation dur4* the investigation of the Cotalt-60 con +mmintion incident that it had at one time stored laalrime Cobalt-60 sources in the reactor high bay?

61. b y did not NEL inform DGI that NEL has Cobalt-60 in its affluant?

62. Please a by otation and precise section number "the applicable definiti m or AIA found in 10 Code of Federsl Isgulatims Part 20.

63. What standards does Applicant's staff use in judging ALARA compliance?

3e specific.

64. Please show in detail the calculations Applicant usei to get estimate of 174 cr in answer to Interrogatory 64 Intervenor gets figure of 200.7 (see Intervenor's answer to Staff Question h4)--please explain discrepancy.

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VII-1 Ilf!ERROGATORIES AS TO CONTENTION VII

1. With re6mrds answer to Interro6atory No. 3, please provide a definition fcr those terms you say are used a in the common english sense b in a general nuclear en61neer 4* sense e in a special sense

2. Frecisely where in the reactor control room are the procedures identified in response to Interrogatory 9 kept-where at the console and in what fo:m?

3. Have any abnormal occurrences or reportable incidents, as the term (s) are used in the propossi Technical Specifications, occurred at NEL '

in the last 13 months?

a. If yes, describe each such event, the date of occurrence, ,

and what documents exist regarding it. '

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VIII-1 INTERRCGATORIES AS TO C0hTENTION VIII

1. Give by calcuhtion and reference the huis for assumption identified in answer to Interrogaterf 3.

2. What efforts has Applicant made to assess the validity of the estimates in Appendix 3,Section III, ofthe Application? Be specific,

s. If no efforts have been made, on what basis did Applicant include it in the Application?

3. Why does Applicant's staff assume, in answer to Interrogatory No. 5, that steady-state operation at 10 kw "for a very long period time",

whnn Application refers to "equilibeium concentrations of the relatively short-lived fission products?"

4, If Applicant's statement on Page III/8-1 of Application "follows strictly only if the reactor cperates stanAily at 5 kx" (ansvar, Interrosatory 7), and since the NEL reactor does not operate steadily at 5 kw, on what basis does Applicant make the cited statemant in the Application?

a. Does Applicant now admit that the cited statement from the Application (last two paragraphs, page III/8-1) is not fitlly accunte?

5. On what hais, including all facts and calculations, does Applicant base its assertion thrt "the basis of the earlier calculations are not exceeded in the present application"?

6. Precisely what is the Applicant's method of annual averaging mentioned in response to Interrogatcry 8, and wkr would it preclude conditicas h and j?

7. Precisely what is vague and anbiguous about the Interrogatory 3?

8. Which specific provisions of Applicant's current Technical Specifications, proposed Technical Specifications, or license prohibit operation of the reactor under any of the conditions a-j in Interrogatory 8, and which of those ecmditions are prohibited?

9. Why, "as a practical m tter," Applicant could not operate under conditions c.d.e f.g. ani i of Interrogatory 87 3e specific as to each conditicn.

10. Intervenor cannot find a Technical Specification V.5.3 as identified in response to Interrogatory 9. Please identify correct Specification. Same for correct 10 CFR section.

11. Explain precisely which conditions the cerrect Technical Spec *fication prchibits do the seme for 10 CFR 20-correct section.

12. Explain precisely and in detai] why that Techn9 =1 Spemification and that 10 CFR 20 section p:chibit each condition prohibited.

13. What is the beginning ani and date of the year used by Applicant for

its method of av W ng?

14. Precisely on what facts, studies, references, calculations, and data did 1960 hazards ane.lyst base his assertion that 10% volatile release and sero non-volatile release was reasonable?

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15. Is the authe of the 1960 Hazards Analysis still alive?

a. If still alive, or if Applicant doesn't know, please provide last known work and home address and phone number.

16. Precisely what in the 1960 Hazards Analysis shows that the 105 volatile sero non-volatile release premise is reasonable, aside from the question cited at Interrogatory 13 of the previous set of 1 Interrogateies? !

17. Does Applicant have any other evidence to support the premise of 10% volatile release and zero non-volatile besides the Hazards Analysis itself?

a. If yes, please detail all said evidence.

18. How can Applicant make the assertion quoted in Interrogatory 13 if it is, as stated in response to Interro6atory 13, " unaware cf specific facts demonstrating the reasonableness of the assumption?"

19. Did us Berax self-destruct experiment result in the biological shields being- blown off and a spray of water- steam-radioactivity released?

20. How can Applicant, andhow does Applicant intend to, prove or demonstrate that the results from a severe accident at the facility would not pose an unacceptable hazard to the public if it doas not have any estimate of the maxinum radioactive core inventory for the reactor and inventories for various species?

21. Absent any prior running, ard 100 kwth power level, answer Interrogatory 23b.

22. If Applicmt has neither the time, nor the personnel, nor the resources to estimte *== I-131 inventory, how can it and how does it intend to denonstre.te that an accident involving release of I-131 will not pose an unacceptable hazard to the surrounding population?

23. On what specific factual and scientific basis-not merely opinion-did Applicant determine that the 1960 Hazards Analsysis sections on conseequential doses in case of accident could be xeroxed and included in the Application despite the considerable construction since then enveloping the reactor structure, which Appl $emnt states in response to Interrogatory 33, that it has no octimates whatsoever for the effect of such construction on the criginal estim tes?

24. How does Applicant intend to disprove Contention VIII when it states in answers to Interrogatories as to that Contention that it dcean't know the fission product inventory maximum for the reactor, has*'t tested the

leak rate, has not estimated effects of new construction, and claims it doesn't have the resources to determine the likely doses to people within Boeltar Hall?

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25. Has Applicant undertaken any analysis of the effect of Boelter Hall-Fath Sciences ventilation systems on consequential doses in case of accident at the reactor? .

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a. If so, specify those analyses, their results, who undertook them (by name), and all documents : elated thereto.

26. Does the Appendix 3 of Section III of the Application consider ground and surface deposition of radionuclides released from the reactor in an accident?

a. If so, identiry by page the sections.

b. If not, why is that pathway cf public exposure not considered in the analysis?

27. What precisely is not applimble in Interro6atories 39 a, b, and c7 T.

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IX-1 INTERROGATORIES AS TO CONTE!TIOh* IX__

1. Precisely what does Applicant refer to when it talks of a "1975 interim adjustment" in answer to Interrogatory 6?

2. Who.at NEL, or formerly at NEL, was consulted in answering Interrogatory 9?

a. Which individuals who were at the facility prior to 1974 and are still usociated with the University were not consulted in answering i this Interrogatory? I

3. ht "other places" are referred to by the answer to Interrogatory !

12?

4. Why does X Applicant deea .. that none of the methods identified in response to Interro6atory 13 are neccessary?

5. Name the specific individuals consulted in answering Interrogatory 22. l l

6. If the heat klance takes six to eight hours, why did Applicant undertake heat klances of four hours or less, as evidenced in operating )

logs? )

7. h t independent observations:would indicate the error identified in response to Interrogatory 25d? And what minor consequances wouM result, specifically? ,

I S. Specifically, what was the nature of the problems encountered in l doing the heat klances, as answered in response to Interro6atory 25d? l

9. Which NEL staff were asked for information regarding Interrogatory 26? Were all NEL staff present at the facility at the time asked?

Was Jack Hornor asked?

10. What efforts did Applicant specifically make to answer Interrogatory 28?

11. For long reactor runs prior to seven years ago, what problems have there been?

12. Precisely what concern was expressed over control rods sticking for long runs of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or sore?

a. Had the rods stuck in such runs? ]

b. What evidence existed that they night? ,

c. Indicate each instance referred to in a above. 1

d. What was believed to be the cause of potential control red sticking in long runs? .

13. Which NEL staff present at the facility in 1968 were asked for information reBarding Interro6atory 31 and which were not? Same for 32 and 33.

I 14 What was the nature of the 1968 problems identified in response to l

.Interrogatires 31-33, specifically?

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IX-2 15, who was asked for information regarding Interrogatory 347 Specify the individual staff persons.

16. If NEL personnel have not, to Applicant's knowledge, ever manually freed the control blades after sticking, how does Applicant know that a stuck control blade can be torqued down with a pipe wrench?

(NEL answer to NRC Staff Question 13 of July 31,1980).

17. Have NEL personnel manually freed control blades at any time in response to sticking or slowed withdrawal or insertion time?

a. If yes, specify each instance, and its cause.

18. Of the approxisately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of maintenance and calibration requiring reactor operation MMm=11y necessary to meet the requirements for all instruments in a twelve-month period, state the rough break-down of hours spent for types of maintenance or calibration and specific instrument required to be calibrated or maintained.

19. State specifically what efforts Applicant has mde on which it tases its statement that "there is no recognized 'Wigner" program far low power research reactors."

a. Did Applicant mean " problem" rather than Dogram"?

b. If so, answer the question as to "problen"?

20. Cite the literature specifically searched and the other efforts

mde to deterrine whether there is a potential Vigner problem at the UCLA reactor.

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X-1 WRROGATORUS AS TO CONTDITIW X

1. Besides the fact that the NEL facility is a research reactor and operates at below 2 W, what other facts, studies, data, evidence, or documents indicate that the conclusions reached in the AEC memo are completely applicable to the UCIA facility?

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III-l INTERROGATORIIS AS TO CCNTENTION XII

1. Explain gecificany and_ detail, and cito references by title End page number, to show what and why "It ia totally inopposite to the basic physics of applicant's type reactor"? (as Applicant answered Interro6atory 3).

2. Why does Applicant not know any of the requested information about leak rate asked in Interrogatories 5-7?

3. What efforts has Applicant nade to obtain the requested information in Interro6atories 5-??

4. Identify the location of all fire doors in NEL, their construction, whether they slide into place or suivel on hinges, and the mechanism for closing and opening them.

5. How would cadmium sheets be used'if the reactor could not be shut down by dunp valve or control blades? Be specific.

6. Who on Applicant's staff is responsible for the current study on the possibility of ins +=11hg HEPA filters, what factors are being considered, and when win the study be completed?

7. Why haven't HEPA filters been instaned before?

8. Why are holdup / decay / delay tanks for gaseous emissions

" totally incpposite to the tasic physics of applicant's tme reactor."?

a. Specifically which laws of physics are referred t;..

b. If it is inopposite, why are holdup / decay / delay tanks being considered for installation?

9. If it is unknown when the hekup et:rstrol blade r.otor was last tested, how does Applicant know it still functions?

10. Why hasn't the r.otor been tested within thememory of Applicant's staff?

11. Precisely where at NEL is the backup motor kept?

.2. Are the walls of reactor building or its roof borated, contain paraffin, e.r otherwise specially treated in any fashion to reduce radiation penetration?

a. If so, precisely with what material and how much of it?

+ b. If not, why nots what analyses have been done to indicate, since the addition of new construction around the reactor housing, that no suen additional shielding is necessary?

13. Re6mrding answer to Interrogatory 23: protection of which persons and precisely from what source of radiation?

a. What makes that source of radiation radioactive?

b. If protection is needed in the machine room, what evidence does Applicant have that radiation hazard is non-existent or acceptably small for people in th's engineering cafeteria or snack kr next to the equipment room and to people walking by the equipment room and to people in rooms above the equipment room?

14. Is the radiation from which people are to be protected in the equipment room coming from a source in the equipment room?

a. If so, what is that source?

XII-2

15. Is the radiation from which people are to be protected in the equipment room coming from radiation streaming from the reactor core itself?

a. If yes, is the radiation gamma, neutron, or both?

b. If yes, what is the maximum dose rate when the reactor is running at 100 kw g?

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16. Why is the third floor lunch area above Tokamak fenced and locked?

17. What does Applicant mean by its answer to Interro6atory 24, "No, with respect to normal operations"? Are there s koraal operations that do necessitate the third floor lunch area being fenced and locked?

If so. precisely what operations and what kind and intensity of radiation are involved?

18. What evidence does Applicant have that the walkway is infrequently occupied?

19. Why was the wall separating the reacte? stack area from the unrestricted area on the top of Boelter H 11 designed and built no more than four feet high, with no krt.w'. wire atop it?

20. Jn what tasis has Applicant determined that items identified in Interrogatory 29a-c are "notneeded."

21. Which part of the Application besides the Technical Specifications l contains the information requested in Interro6atory 30? Identify by l page number.

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22. Are there any interlocks, inhibits, or scram systems currently in use at the NEL reactor not identified in the Technical Specifications or Application pages cited in response to the previous question?

a. If so, identify them with specificity, including their purpose.

23. If there is a hazard to being in the 3rd floor equipment room necessitating that it be locked and interlocked, why is there no hasard in entry into the reactor room?

24. How can the interlock system on the 3rd floor equipment room be overriden' l

25. Applicant states in answer to Interrogatory 32e that the reactor has been run while someone is in the 3rd floor equipment room.

Applicant further states "it is done for the purpose of health physics monitoring." Has any individual aside from health physics personnel over been in the 3rd floor equipment area while the reactor was running? If so,

a. Please indicate each instance where such occurence occurred, by general date, cause of instance, reason individual was in said area.

b. Give name af individual,

c. Identify all documents relative to said occurrences.

26. If no such instances have occurred, explain the numerous instances in operating lo6s (e.g, page 9't 1979-80 log, #1) where key to 3rd floor ~

equipment room was found missing, and NEL personnel had to go up to area and visually inspect it to see if anyone was in it and chain it shut.

27. Explain the sign-out procedure for the 3rd floor equipment key and how it is designed to prevent operation of reactor with personnel in said room.

III-3

28. What was the cause of the tie bolt failure problem en the reactor fuel?

29.10ao made the fuel the first time?

30. IE5XII Is thas fuel still in the reacter?

a. If not, why not?

b. lias any of it been removed?

c. If affirmtive to b above, why was it removed?

31. What caused the physical dange to the one or two bundles outside the core?

a. what documents record that dange incident?

b. was M* Ming damaged?

c. were fission products released?

d. if affirmative to e, how much fission products were released?

32, 3esides the tie bolt failures and the damage to one or two bundles outside the core mentioned in response to Interrogatory 39b, have there ever been other instances in which fuel plates were damaged?

a. If so, please identify each and every such instance.

b. If so, identify all documents that would contain information about said instances.

33. Why did Applicant cut away some graphite near control blade shrounding after a control blade sticking incident in the hte sixties?

34. Could steam and/or water absorbed by graphite be rapidly driven from the graphite, causing a rapid reactivity insertion?

35. By how much did reactivity drop during the incident mentioned in response to Interrogatcry 43?

36. What caused the leaking gasket in the primary coolant loop to leak?

37. Precisely what effect does radiation heating of the control blades have?

a. how did Applicant surmise that to be the cause of the problem identified in response to Interrogatory 45?

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38. Cite volume and page nunber of operating logs and inspection reports that identify the heat balance problems cited in response to Interrogatory 45 a.

39. What efforts has Applicant made to determine whether research rea.cters have experienced problems with graphite?

40. In response to Interrogatory 56, Applicant claims that the su%%c-e are

" vague, ambiguous and uncertain." In each case, specify the vagueness, ambiguity and uncertainty involved that makes answer impossible.

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41. What is the ignition temperature for the uranium used in Applicant's I fuel? !

i 142. Vnat is the ignition temperature for the graphite used in Applicant's I reactor?

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XIII-l DrrERROGATORIES AS TO CCNTEFFION XIII

1. Why does Appliant contend that it is essential to have 4700 gne uni h ted fuel when the core can only contain under present loading 3556 grame?

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2. What probleme did Applicant have in its first eight years of operating the reactor that make it mandatory that the facility have more fuel on site than it had during those first eight years?

3. Why is it unknown as to whether the reactor could function should the enrichment level of its fuel be reduced to 20%

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l XIV-1 INTERROGATORIES AS TO COffrENTIGI IIV

1. Was the UCLA reactor, Argonaut-type, built or designed by AFF?

2. Was the U of F reactor built or designed by ANF?

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7. Was the U cf W reactor built or designed by ANF7

4. Why does Applicant not know whether other annufacturers of other-Argonaut reactors built any such reactors?

5. For each of the 5 reasons given in response to Interrogatory n % l first sentence of answer--please detail what Applicant manna by the phrase and indicate how much excess reactivity each reason necessitates.

6. Do the same for the second sentence of the answer to Interrogatory 11.

7. Applicant states in response to Interrogatory 20 that it "has never identified a positive temperature coefficient of grapaite."

a. Has it found a negative temperature coefficient?

b. If so, what is that coefficient (or coefficients if the number changes over temperature range)?

c. Has Applicant any evidence, facts, data, documents, studies, er '

analyses that indicate that there is no positive temperature for the graphite in its reactor? ,

d. If the answer to e above is affirmative, provide all such information l and identify all such documents.

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8. If Applicant has always had a spare control blade notor, where did the 1 inspection report citing the lack of sr.mo obtain the information that Applicant did not?

9. Has the NRC ever advised Applicant cf problems of safety significance c, ing at other research reactors?

a. If so,1".dieste each such problem of which Applicant has been informed

b. Identify all documents in which NRC so informed Applicant.

10. Does NRC have a routine method of informing Applicant of problems at other research or other Argonaut reactors?

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XV-1 INTER!!OGATORIES AS TO CChTENTION IV

1. Were the architects of the Math Science Addition, and/or the Campus Architects, informed of the existence of the reactor exhaust stack on top of Boelter Hall at the time of the design and construction of the Math Science Addition?

2. Was the location of the exhaust stack +miran into account by those architects in placing the MSA air inlet where it less placed on the NSA roof?

a. If not, why not?

b. If so, why did they place it where they did?

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XVI-l l INTERROGATCRIES AS TO CONTENTION IVI

1. Regarding Applicant's response to Interrogatory 3, is the )

" log N and period amplifier" one device, or more than one device' '

Or is there some typographical error here if so, please correct. l

2. In response to Interro6atory 5, Applicant states that funds sufficient ,

to replace the log N period amplifier were obtained. Was the safety '

amplifer replaced? Were funds sufficient to replace it obtained?

3. Does the answer to Interrogatory 10 mean that Applicant has no drawings and tech manuals, or that there are no major pieces of console or reactor equipment for which Applicant does not have original drawings and tech manuals?

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IVII-1 INTERROCATORIES AS TO CCt:TENTION XVII

1. What is the mart = a core acceleration possible from the Greatest magnitude seisaic event possible at the reactor site

a. in the N-S direction

b. in the E-W direction

c. in the vertical directions.

2$ On what basis does Applicant believe that earthquake experience related to Code-complying structures during the Imperial Valley quake would not be relev.:nt to Applicant's repetition of its 1960 assertion quoted in Interro6atory 8?

3. By answer to Interro6atory 10 is Applicant claiming that the power oscillation noticed in the vibration tests of the reactor core and experimentally examined by Rudman thereafter were not related in the vibration test to fuel plate oscilation?

a. If yes, please explain answer.

b. If no, please explain answer.

4. In answer to Interrogatory 10, is Applicant referring to volume of fuel, volume of coolant, or some other volume (if the last, please identify)?

5. Rudman fcund oscillations simply by vibrating fuel bundles. How does vibration of fuel bundle indicate necessity of physical expansion of core and addition of water?

6. t . . can Applicant answer Interrogatory 10a, but say it hasn't the tine, pe,sonnel nor resources to answer lod, a similar and related question?

7. Why was Applicant unaware of the degree of proximity to the Inglewood fault?

8. Does the domineralizer and related system contain radioactive material at any point?

a. If ,o, what is its source or cause?

b. If so, what is the dose rate (:mxima) at the surface of the deaineralizer?

9. Applicant states that the ten-tm crane puts O stress on the roof--

please explain.

10. Given that the Applicant has stated that it does not know the strength of structural nyyw.t.a. and reactor roof, nor the minimum force necessary to shear off the supporting columns, nar the ma6nitude of the largest quake possible in the area nor even for sure the nearest capable fault, how does Applicant intend to defend a6minst the contention that its facility is seismically vulnerable?

11. Does Applicant admit that an earthquake could dama6e a significant portion of the care?

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12. What is the Richter scale mm6nitude of the largest possible earthquake alons the Inglewood fault?

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13. What would be the accompanying ground motion and core acceleration? [

14. What makes the items referred to in Interrogatory 32 " relevant factors?" ;

What is their relevance to nuclear reactor sitin6?

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15. Regarding response to Interrogatory 36: If the attribution to the earthquake of the water leak was determined to be erroneous or at least t not clearly related, why does the Annual (Specialized Activity) Report for 1976 and for 1977 continue to refer to the probless as related' I

16. Was the water leak identified in response to Interro6atory 36 leak l of primary coolant? l

a. If so, where did the water leak to? !

b. Could such a leak lead to variations in coolant level in the fuel boxes?

c. Ifnot, why not? i

17. Does Applicant now contend that the water leak referred to in -

Interro6atory 36 had nothing whatsoever to do with the 1971 earthquake?

18. When Applicant savs !,he leak was "at least not clearly related to the earthquake", in what way may it have been related to the earthquake?

19, could an earthquake lead to release of primary coolant into the .

environment?

20. CouLi an earthquake lead to rapid variations in coolant level?

21. Precisely in what volume and on what pa6es of the operating logs is the answer to Interrogatory 39 found? ;

22. Why does Applicant not know what the M 4 = = Design Earthquake is for which the react was w9ein=177 built to withstand? ,

23. What is the Safe Shutdown Earthquake for this reactor?

24. Precisely on which pa6es and whidt sections of does tSe information specified in 10 CPR 50.34(b)(pages

1) appear?in the Application

25. Applicant states in response to Interrogatory 48 that the information specified in IO CFR 50.34(b)(1) is not required. Does Applicant adr.it, aside from the issue of whether such information is required, that the information to which that code section refers is absent from the Application?

a. If not, precisely on what pages ani which sections of pages in the Application does the information specified in 10 CFR 50.34(b)(1) appear?

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e XVIII-l hrsniOCATCRIES AS TO CCNTENTICN XVIII -

1. In what precise documents does Applicant's policy of confidentiality of aendemic reviews of programs such as NEL appear? Identify by pa6e number the section of said documents applicable?

2. Are no academic reviews of pro 6:ams such as NEL ever available to the public or =ade public?

a. if they are ever available to the public or made public, what c=1terion is used in determining which are confidential and xhich not?

b. in what documents are these criteria found?

3. Are academic reviews of programs such as NEL subject to the California equivalent of the Freedom of Information Act?

a. If Applicant received a request for such :sviews under the CmHfornia state equivalent of the Freedom of Infccmation Act, wculd such reviews be provided?

b. If not, on what tasis would they be denied?

c. Where is that tasis codified, or in stat documents is the policy written down.

4. The M M of April 14, 1981, centains an article reperting cn the results of an academic rsvinw of another progran within the School of Engineering and Applied Sciences. Tt.e article states: " School of Engined.g Dean Russell O'Neill believes that the quality of the en61ned.g systems department-ene cf seven depart:nents in the school of engineering-is too low to continue as an independent department." The article further indicated O'Neill's conclusion that the engineering systems department does not have an adequate academic plan and should be elininated.

a. How does Applicant argue that academic review irfcrmation about the Nuclear Engineering Iaboratory pro 6 ram of SEAS is confidential tut

=4M1"* information about the =a=4 **" systems department of SEAS is not?

XIC-1 UTERROGATCRIES AS TO CONTE:ITION XIC i

1. '.lhere.is the definition Applicant refers to in response to Interrogatory 4a in terms of specific chapter, part, and section of CFR7 '

2. The reactor was initially designed to withstand .iacaing of all control rods-was that the worst accident the reactor was designed to withstand? (res answer to Interrogator /15).

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. c U-1 INMRROGATORIES AS TO CONTENTION U

l. Regazding answ w to Interrogatory 41, have tours of over 50 people ever been given of NEL with only 1 or 2 NEL staffpeople along as guides?

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2. Re6ardin6 answer to Interrogator / 43, what criteria are used to determine whether the individual tour members sign in or merely the tour leader?

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XXI-1 INTERROGATORIES AS TO CCNTSNTION XXI

1. When does Applica.t: expert its new emergency plan to be completed?

2. If there is no specific prc6 ram, as stated in response to Interrogatory 9, how does Applicant know that the equipment needed for emergency response is available and accurate at a u times when it could possibly be needed?

3. Is there an over-all emergency plan for the campus? What is it caned?

4. Who is the dele 6 ate of the Administrative Vice Chancenor authorized to approve evact.stion of 3oelter Fall?

a. What Mining has that individual undergene regarding the parameters to be considered in makin6 that judgment?

b. Who is that person's delegate 1" both the Vice Chancellor and his/herdelegateareabsent?

e. answer a above for the individual identified in response 'A b above.

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5. Who is responsible for the conection and analysis of data identified in response to Interrogatory 29, when will that analysis be finished, and when will that answer be supplemented?

a. What data is bein6 collected and analyzed?

6. Answer question 5 above for the Applicant's response to Interrogatcry 36, and 41, and 42.

Dated: June 10, 1981 M Pon ock -

/AttorneyforIntervanor

/ COMMITTSE TO 3 RIDGE THE CAP i

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l

GIITED STATES OF AMIRICA

,. NUCLEAR REULATORY CO:21ISSION 3EMP3 THE ATOMIC SAFErf A:iD LICEISUG 30AJP

-In the Matter of )

) Docket io. 50-142 THE REE!TS OF THE U:;IVERSITY )

0F CALI3t)RNIA ) (Proposed Renewal of Facility

) License)

(UCLA Research Reactor) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of "ETERVEiOR'S ETERROGATORIES TO APPLICAUT, THE REGE;TS OF THE CII7ERSITY OF CALIFORNIA-SET TEPIE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first cla.ss, this 10th day of June, ic81.

Elizabeth S. Bowers, Esq. , Chaiman Counsel for URC Staff Administrative Judge U.S. Nuclear Regulatorf Comission Atomic Safety and Licensing Board 'lashington, D.C. 20555 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Docketing and Service Section Office of the Secretarf Dr. Emmeth A. Luebke U.S. Nuclear Regulator / Co=ission Administrative Judge Washington, D.C. 20555 Atomic Safoty and Licensing Soard U.S. Nuclear Regulatorf Comission Rodger Holt, Esq.

Washington, D.C. 20555 Office of City Attorney 200 North Main Street Dr. Oscar H. Paris City Hall East, Room 1700 Administrative Judge Los Angeles, CA 90012 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Washington, D.C. 20555 .

William H. Comier, Esq.

Office of i dministrative Vice Chancellor University of California 405 Hilgard Ave.

Los Angeles, CA 90024 Christine Helwick, Esq.

Glenn R. Woods, Esq.

Office of General Counsel 2200 University Avenue 590 University Hall Berkeley, CA 94720 ,/

Mark Pollock Counsel for Intervenor

' COMMITTEE TO 3 RIDGE IHE GAP

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ML19346A351

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