ML19352A880
| ML19352A880 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 05/20/1981 |
| From: | Pollock M COMMITTEE TO BRIDGE THE GAP, POLLOCK, M. |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8106020273 | |
| Download: ML19352A880 (40) | |
Text
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L"JI"ED STATES CF AlIRICA 11'CISAR RENTORY COMI2SSIC::
2SF0FS TF2 ATG2C SAFEY A':D LICE"SII G 30ARD
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In the Fatter of Docket No. 50-142 (ProposedRenewalofFacility
'IA License Number R-71)
(UCIA Research Reactor)
A1:SWERS T TF2 CCF3ETIIE TO 3REGE Tl!E GAP TO STAFF'S FIRST SET & II.""ERROGATORIES e g Dated: Fay 20, 1981 4 .
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On April 20. 1981, the !!RC STAFF submitted to !ntervenor.
"HE CC!G r TEE '.T 3 RIDGE THE CAP, one hundred ard four (104) interry,a tories with subparts. S.ese interrogatories are answered in the responses that follow, as per the discovery schedule stipulated to by the parties and ordered by the 3 card.
Discovery is proceeding on all catters touched en in the Staff's interrogatories. The responses to the Staff's interrogatories that folicw represent Intervenor's infor=ation relevant to those interrogatories as known at the start of the formal discovery period. '"he following answers are provided without prejudice to Intervencr's ability to introduce subsequently discovered caterial at a later date at hearing or any related proceeding.
Although Intervenor views a, number of the 3taff's interrogatories as harrassin6 and unduly burdensome, no fornal protective order has been requested and no question objected to. Staff is put on notice, however, that should future interregatories follow the same pattern, relief from the 3oard will be sought. Intervenor particularly refers to numerous interroratories wherein Staff has requested detailed calculations, scientific analyses, and computer models for catters which should properly be addressed to Applicant.
Intervenor notes that it received over one hundred interrogatories from Staff whereas Applicant apparently received none. Intervenor reninds Staff that it is Applicant that is up for relicensing, not Intervenor, and that the burden of proof in such a licensing proceedirt is with the Applicant. Furthermore, it is the Applicant that is the party most likely to have the information Staff has requested (for example, the fission product inventory by species for this particular facility, computer models of the effect of the new UCLA buildings on consequential doses in case of accident, and the annual cost to UCLA of owning ard operatirg the reactor). ,
Intervenor does not wish to burden the 3oard with numerous requests for protective orders. 3ut Staff should be on notice that if Intervenor perceives this harrassment to continue, it will have no alternative but .
to seek remedy from the 3oard. .
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1 (a) No arrangements have yet been made by Intervenor regarding expert witnesses.
I (b) See answer to (a) above.
(c)Seeanswerto(r.)above.
(d) Fark Pollock and Daniel Hirsch prepared and/or substantially contrib-uted to the preparation of each of the responses below.
Contention I i- Q2estion 1 Intervenor believes that the UCLA application is misleading by its reference to the 1968 report on experimental vibration because the application merely mentions the fact of the performance of the test, not the results of said test.
The test reference in question occurs on page II/3-1 of Application, in a section of the Environmental Impact Appraisal entitled " Environmental Effects of Accidents". "'he topic sentence of the paragraph in question states: " Accidents ranging from failure of experiments to the.lar6est core damage and fission product release considered possible result in doses of only a sm11 fraction of 10 CFR Part 100 guidelines and are considered negligible with respect to the environment". In defense of that assertion, Applicant cites the vibration test.
W e results of that vibration test in no way support the assertion.
Applicant's statement implies that the largest core dam ge and fission product release considered possible is actually quite small, in part because no seismic damage of any significance is considered possible, as evidenced by the shake test cited immediately after the initial assertion.
However, the results of that test indicate that the reactor internals so shifted that control blade operation was apparently impaired and eventur.11y made impossit 4 "he implication of the reference in question is that the react e " passed the test", lending support to the assertion of minimi core damse being possible. The results indicate that significant da ngo did occur.
In addition, the article an serts that the problem was addressed by significant alterations of the reactor core after the damage was discovered. This infor a tion is important to have been included -
because it indicates that the reactor that was the subject of the l - -- _ _.
P00R BRIGINAl.
vibration test in question is not the same reactor up for relicensing, but one significantly modified. The relevance of the reference to the test in support of the preceding statement about safety is further called into question by the fact that the reactor was significantly modified after the test and has apparently not been tested in the condition in which it now is, awaiting relicensing action.
These, w all facts important for the Board to hare in making a judgment on the environmental effects of accidents and other safety questions and should not have been omitted. The reference to the test without mention of the results of the test is misleading in that it creates the impression that the performance of the test lends support to the assertion of safety.
.QLlutica .1 See answer to Question 1 above, incorporated-herein by reference.
i Question 1 .
Intervenor relies on interpretations of the following 10 CFR code sections: 50 34(b), 50 36, 50.40, 50.41 or 53.42 (depending upon Ecard decision regarding which class of license is the appwglats one in this case), 50 57, 50 59 & 50 Appendix D.
,uestion Q 4 Intervenor does not assert that applications for license renewals are required to contain only " original" information. Intervenor's contention is that certain paterial in the Applica t. ion which should have been original is not. See Intervenor's answer to Applicant's Interrogatory ro. 2, incorporated herein by refers tee.
Question 5 3y " original" Intervenor means that the material submitted about a particular reactor up for relicensing must be information about that particular reactor, as it is at the time application is made, not as it once was twenty years previous nor as some other reactor might be.
. P00R ORIGINAL
Questior 6 Intervenor assumes that by this question Staff requedts information as to the parts of the 1960 Eazards Analysis that were ccpied vertatim in the 1980 Application. Currently viewed as inaccurate are parts:
hydrology section, page 13 (a) there are wells in vicinity, (b) well map in Supplement reactor site section, page 1 (a) building has bee oded to, (b) I&E Report 75-01 Seisan1rwv section, pares 1 and 9: (a) 1971 earthquake modified much of the previously-held picture of 5. Cal. seismology: Uniform 3uilding Code has cinanged certainly doesn't represent "the accumulated wisdsm of the engineering profession in this field": buildings built to that Code have suffered earthquake damages structural rearrangements could increase reactivity (b) Science, February 1,1980: NEL shake tests Meteorology section, page 9,101 (a) inaccurate representation of current snog and inversion situation, inaccurate discussion of prevailing wind conditions, (b) Applicant's answer to Staff regarding questions on prevailing wind conditions.
Training Reactor Description, intro, page 19 (a)powerhaschanged, there are credible ways for the fission products, no longer below promi:t critical (b) see evidence regarding reactivity, maximum credible accidents charts, page 23, 24, 25: (a) con't show pneumatic tube, any other modifications since 1960s (b) license amencsont on pneumatic tube reactor core, page 27: (a) degree of confidence regarding similar fuel, 3orax extrapolation deflector, (b) see sections on reactivity ~ ,
typical fuel cluster, page 29 a)new tie bolts, b) CO Report 68-2 l reactivity) analysis, page and (b supporting 3-1 basis in to 73 (a) see reactivity contention Supplement consequential dose analysis, ytges C-1 to 73 (a)ContentionVIII,and (b) supporting basis in St pplement Question 7 The environmental information Intervenor currently believes to be omitted i
! from the application history of radiation exposure incidents, spills, leaks, mis-calibrations:
(a) should be included so Soard can guage potential environmental i= pact of a licent.ing decisions (b) UA l
i that tours are taken through the reactor rooms (a) because Applicant claims in II/S-1 that entry requires health physics qualification and dosimetry: (b) Application T . .-, _.. - - ..--- .. - .-. -_ - - .
l thatbackgroundisnot(.04*.03 mrem / hour): (a)truthfulnessis essential in such an a for board to knows (b)pplication, insensitivity of devices is importantsi=ple mu figuro full set of film hdge data, including threshholds, sensitivity, and location of controls: gamma devices in stack, neutron figurest (a) essential to a full appraisal of environmental impact, (b) I:A explanation of discrepancy between 1979 figure in application and in annual report regarding Argon releases (a) accuracy importants (b)ApplicationII.2-5,1979 Annual Report full-scale analysis of maximum potential accidents and their environmetal effect',s keyed for this particular reactors (a) impossible otherwise to accurately assess environmental effects of accidents: (b) Application II/3-1
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full-scale analysis of unavoidable effects of facility operations (a)impossibleotherwisetoaccuratelyassessenvironmentaleffects:
(b) Application II/4-1 full-scale analysis of alternatives to operation of the facility; (a) impossible otherwise to accurately assess.that matters (b) Application 5-1 full-scale analysis of long-term effects of facility operations (a) cursory conclusion without supporting data makes Board and staff assessment of impact on the environment impossible, (b) Application II/6-1 full-scale analysis of costs and benefits of facility and alternatives all such facilities tells nothing (a)conclusorystatementsregarding/7-1 to help judge this facility (b)II Actual measurements, competently done, well-controlled, with adequate sensitivity, of the h; ion releases. Actual measurements of Argon on roof, in Fath Sciences not just estimates of Argon concentrations.
Data based on current reactor usage and maximum licensed usage.
(b)II/A-1to63 (a) because without actual measurements under current and licensed limit conditions, Soard cannot assess with reasonable assurance that emissions will be as los as reasonably achievable and that insult to environment will be minimal.
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@estion 8 Intervenor contenda that the statement on page 5 of the~ Application regarding the purpose to which the facility will be put is inaccurate because it, states that the purpose will be for "the education of senior undergraduate and graduate students in nuclear engineering and related sciences. In addition to form 1 courses and demonst. rations, the reactor will be used to support research at the M.S. and Ph.D. level." The actual primary function of the reactor is commercial, and the use to which it is put for education of students in nuclear engineering is mki==1 Research at the M.S. and Ph.D. level is also minimal. The evidence for this is the ray 13, 1980 answers by UCLA to Staff questions of April 17, regarding usage of the reactor. The table provided indicates the last year for which data is provided that only 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> went to hTL experiments, only 31 for engineering classes, and 60f,of reactor usage was commercial.
Additional evidence is the financial lodgers, billings and operating logs for '2L. Staff is referred also to pages 1 through 3 of Intervenor's Supplemental Cententions cf August 25, 1980, daaling with contention II,
" Wrong Class License", which is included herein by reference. Staff is
.. additionally referred to Applicant's " Answers" and "Further Answers" to Intervenor's First Set of Interrogatories as to Contention II, and to Applicant's Answers II.1-61 and I.17-18 of Interrogatories of April 20, 1981.
testion 9,
- Intervenor; believes that the UCLA research reactor has been used for extremely minimal student education and rssearch.
@estion 10 Applicant states (Application, page 7): "No structural weaknsases (earthquake vulneability) have ever been identified." Intervenor alleges that this statement is inaccurate because: 1) the vibration test did identify structural weaknesses associated with earthquake vulnerability (e.g. the shifting of lead shielding between the graphite and biological shield, leadin6 to binding of the control blade shaft),
2)1976 Annual (SpecializedActivity)Reportindicates"TheFebruary1971 earthquake gave rise to minor problems that worsened with tim, and ultimately required a major raintenance effort in 1972", and 3) Richard ,
Lee Rudman's 1968 study " Simulation of Earthquake-Induced Vibrations in l
- a UCLA Reactor Puel 3undle" detected (as did the structural vibration l tests) power oscillations related to simulated seismic vibrations. '
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@estion 11 Yes.
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@estior E i Yes. i (a) Intervonor has not to this date (although future discovery may change this) asserted any specific actual harm to public health and safety occurred at the UCLA reactor during the February 1971 earthquake.
Intervenor has, however, contended that stuctural weaknesses and earth-quake vulnerability were identified that thus make Applicant's statement to the contray on page 7 of the Application incorrect and that the Board should have been provided the correct information.
(b) See 12 (a) above.
l 4estion H (i)Dependingonwhatistho' correct fortheUCLAreactor(atpresent and throughout its proposed license period), $3 54 may be in excess of
- 2. 5 k/k, the current licensed limit. Since excess reactivity is closely tied to exponential period, and since period is closely tied to capacity of a reactor to have a damaging power excursion, including fuel melting, and since such an excursion and fuel molting might result ,
in significant release of fission products, posing a substantial threat '
to the public, any possible increase in the licensed limit on excess reactivity is potentially of great safety significance.
(ii) Instrument calibration is central to the safe operation of a nuclear facility. If instruments are giving falso readings, the functions of safety features become unreliable, operator response can be very much impaired, and safety of the facility and surroundings can be threatened. An increase in the calibration interval increases the likelihood of instrument error because the instrument has gone out of calibration in the interval since the last calibration. Applicant has been cited in the past for failure to calibrate at the required intervalg one such failure resulted in an underestimation by several
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ceders of magnitude of radioactive emiss1ons. Proposal to relax cali-bration efforts can thus lead to serious safety problems.
(iii) Heat bLlance instrument calibrations are essential to assuring that neutron channel instrumentation and power level instrumentation reflect accurately what is going on in the core. If not calibrated,
- fal'es readings can ensue. Scram systems and other safety systems ti d to neutron channel and power level instrumentation can fail to activate because they are receiving false readings of core conditions if those instruments are out of calibration.
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(iv) Failure to keep radioactivity released to the environment at levels as low as reasonably achievable clearly can be of safety significance, because radioactivity is potentially severely hasardous to exposed persons.
Because of NEL's histo 27 of violating radiation standards, any proposal to reamve ALARA requirements from Technical Specifications and possible reduction of the probability of NEL personnel and students to be informed of the ALARA requirement, can only be seen as a move in the wrong direction from a safety standpoint. The ALARA requirement should be posted visibly throughout the NEL facility it should not be removed from the only 1
- location currently written down, the Technical Specifications ( aside from the paragraph in the few conios of Title 10 CFR that may be at the facility l and rarely if ever looked at).
- Keeping emissions and exposures as low as reasonably achievable is centra 5 to reactor safety. This facility has evidenced that it needs to be reminded of that responsibility repeatedly. Reducing the presence of that responsibility is a step in the wrong directica from a safety standpoint.
(v) The avhanet stack is too short as it is. Removing the requirement of stack height makes it possible for the stack to remain as is, or to become even shorter. The safety significance of stack height is that-the +
reactor stack is located on a roof readi'y accessible to the public . .
(meterological station, planetarium, seminar roof, observatories, 7 unlocked
- entrances) who might be exposed to the plume. Keeping the plume as far ,
as possible from h public is necessary from a safety standpoint to reJuce :
radiation exposures. The higher the stack the lower the chances of someone i' being enveloped in the plume. Furthermore, given the placement of the downwind airvent for the Math Bu4lding, further reduction of the stack's ,
height could significantly increase the amount of Ayyudi and other ,
radioactive emissions entering the air vent and thus exposing the people :
in Math Sciences. The stack height requirement should be increased, not removed. Finally, the area right around the exhaust stack is sed to be restricted beause exposures close to h stack are poten far ;
, higher than farther away. Without the access restriction in the Technical i l' Specifications, significantly larger radiation exposures are possible, clearly undesirable from a safety standpoint. Intervonor believes it would be preferable from a safetystandpoint for the entire roof to be effectively restrictedt clearly removel of the one restriction (the area right around the stack) agreed to by NEL is the wrong direction. j i
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Question 14 Vells in the vicinity of the reactor can be significant fron a safety standpoint because in case of accident er other release of radioactivity; ground water can be polluted. If water for public use draws from the ground water near the reactor, or if that ground water can readily nigrate to those wells, a substantial pathway for public radioactivity exposure exists. In addition, should Applicant be unaware of all the wells in the vicinity, and should Applicant's emergency plans not take those wells into account and provide a means for identifying each such well and rapidly stopping its use er at least monitoring it routinely, considerable public harm can ensue in the event of an accident at the facility. .
Question 15 Yes Some effluents from the UCLA reactor are normally dumped down the drain into the LA City Sewer System. Should part of that sewer line be broken, radioactively contaminated material could escapa into the grounG, migrate ,
into water and then to nearby wells. -
In case of a major accident involving ground deposition of radioactive materials, perhaps rained out, tne material deposited on the ground could migrate downward over time and contaminate ground water.
All of these possibilities have poteatial safety significe.r.ce and should have been analyzed by Applicant. At least .the Board should have been provided the correct information about wells rather than a denial there were ary.
Question 16 The figures given ty Applicant in the Application itself (page III/3-6) l show estimated thyroid doses considerably in excess of 10 CFR 100 guide-lines, even utlizing assumptions that severely underestimate the actual dose.
(a) Staff is referred to Contention VIII and the discussion of its tasis in Intervenor's Supplemental Contentions of August 25, 1980, included herein by reference.
Question 17 The facility was used for engineering classes en3y 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> in 1979:
only 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of yEL research was conducted. It would be far more suitable and economical for the few hours spent annually in research and education to be done at another reactor. There are 11 other research reactors in California alone. Applicant itself operates at least three other research ;
reactors. When business is declining and research and education funds l are tight, as is the case, it makes sense to combine use. Activation !
analysis samples can as readibly be sent elsewhere as sent to UCIA. UCLA l students utilizing the UCLA reactor for their education could continue i
to take classes reactor atIrvine
( say UC UCLA,) forcontinue to class those few do werk hours at UEL, but goreactor requiring to another
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operation. Tnis is a standard procedure for other resources systemwide (for example, shuttle buses take students from some campuses to other campuses to use specialized litraries or language facilities or classes not available at their campus). 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> per year is about 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per quarters essentially 1-2 all-day field trips per quarter. Far more suitable and economical.
Anotheralternativeistosimplyremovethefuelfromthofacilityand make the reactor into a simulator. Airplane pilots don't start out flying a planes they use a simulator. The nuclear industry itself is beginning to rely much more heavily on simulator training. Students would continue to be able to learn how to operate a reactor, but the riska to the public would be removed because no error made by those students would result in .
anything more than a simulated hazard, rather than a real one.
a) evidence regarding other research reactors in California can be found in liRC Facilities License Application Record (FIAR)06-30-77 Question 18 UCIA's Application itself (Part III, Appendix A) shows that 3orax and Sport data requires considerable alteration to prodt.ce an estimate of the safe level of reactivity insertions (noto error in text) for other reactors.
Thus there is no one figure for plate type fuel elements in terms of $
apeuats: the figure varies reactor to reactor. In addition, Borax testa never tested fuel e $3 54- only abwe and below that level. Above that level, the reactor exploded.'
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Ih Question 19 The basis for this assertion is found in ths Supplement, Part II, and the answer to Question 21, below, both of which are incorporated herein by reference.
"he operating logs and financial ledgers anc billings provided to date to Intervenor by Applicant confirm the heavy commercial use of the facility, and that commercial use has been increasing year-by-year for the last few years.
"he infarmtion requested here by Staff .as to use of reactor for various purposes is information Intervenor has attempted to get from Applicant for six months. Despite Intervenor s First Set of Interrogatories as to Contention II, which asked precisely for the information Staff now requests of Intervenor, and despite three Motions to Compel and two 3oed Orders, full answers to those interrogatoriu still have not been provided by Applicant to Intervonor. Intervenor suggests that Staff, should it require more inforation than has to date been provided Intervenor by Applicant on this matter, attempt to obtain the information from Applicant, in whose possession said information remains.
(a) Intervenor still lacks Applicant's definitions for such terms as sale of services and camercial activity, so it is difficult for Intervenor at this time to phperly divide the commercial activity into the categories you have here requested. For the purposes of this interrogatory, however. Intervenor will respond by calmg diamond coloring and are assaying through activation analysis sales of services other than services i for research and. development or education and training, rather than referring to them as sales or commercial distribution of mterials, products or energy, and thus listing those services under (c) below.
The commercial activity of which Intervener is currently aware thus falls into category (c) below.
(b) See (a) above.
(c) Intervenor has not been provided ledgers or billings for 1976, so no listin6 can be made at this time for 1976. Intervenor has not been provided financial billing statements for 1977, and thus likewise cannot make listing as requested for that year. Intervonor has been provided ledgers and billings from mid-1978 through mid-1980, so that inforation is listed belous mid-1978 - end-1978 Emil Kalil i Uranium West
, 1979 Emil Kalil Gems ahd Minerals of Sarosi 1980 - mid-1980 Emil Kalil Kalil and Uranius West utilize neutron activation services of the reactor for assaying uranium ore samples in a commercial venture. Gems and Minerals uses the neutron activation services of the reactor for ecloring commercial jewelry.
(d) That evidence is sought in Intervenor's April 20, 1981, Interrogatories to Applicant, II.1-61, and in the First Set of Interrogatories, still awaiting full answer. Until Intervenor knows whether academic credit is received for work for Kalil. and whether the student pays 'or Kalil pays, and related questions are answered. Intervenor cannot make a determination on this question, j]
Contention II hostion 20 a) The financial figures and data Intervenor uses for annual costs to UCIA of owning the research reactor at present time are zero, as the Applicant i states that construction of the reactor facility was done through a grant from USAEC, with funds expended on construction and reactor equipment. ,
b)ThefinancialfiguresanddataIntervenorusesatthistimeforannual costs to UCIA of operating the research reactor is $167,000, c)Thesourceofitem(a)isAp The source of item (b) is Application, page I/2-1. plication, page III/1-1.
d) Intervenor at this time allocates owning and operating costs among the various activities of the reactor on the basis of reactor usage for each function in terms of hours or port-houzz of usage. -
i Westion 21 Applicant's revised Table III/1-3, provided to NRC staff on Fay 13, 1980, indicstes Reactar Usage in hours per years for 1979, the last year reported, 26l4 hours were listed as commercial, 31 as e g4 e m g classes, 1 as 13L l experiments, with mintenance, UCLA Users, Colleges and Universities, and Demonstrations taking up the rest. The total part-hours were 446 the actual run time 372. The commercial use alone represents 59.195 of port-hours. Since a review of the relevant billings and operating loss indicates that virtually all of the commercial use was for Emil Kalil's firm, and that Kalil's runs were exclusively or virtually exclusively utilizing one port (the pneumatic tube port), actual run time for commercial use is nearly the same as the total port-hours, thus making the commercial percentage of actual run time even higher than the 59.1% figure for port-hours.
l Westion 22 !
t Intervenor stated on page 1 of Part II of its Supplemental Contentions !
that 52 5; of the :3L income in 1979 came from " reactor earnings" . !
and "other income." This is a computational error, which Intervenor hereby acknowledges. !
( Contention III !
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Question 23
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Intervanor does not believe that the UCLA Application should provide !
information required by 10 CFR 50, Appendix 3 concerning power reactors and reprocessing plants. Contention III makes no mention of said Appendix.
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I p estion 24 Intervenor at this time has no evidence on way or the other indicating
- either conpliance with or frilure to comply with requirement of obtaining
' Reactor Use Committee, Director, or Commission approval for changes in reactor systems, non-standard experiments or facility changes. Inturvenor to date has not been provide 1 access to Applicant's Reactor Use Committee minutes nor other records where such approval would be noted: Intervenor directs Staff to Applicant, which is in possession of the information requested in this question.
Westion 25
- 1. The present management responsible for the reactor is essentially the same individuals as past management. Fr. Zane, Professor Kastenberg, and FT. Eorner have been associated with the facility for close to twenty years each. Fr. Ashkugh has been with the facility for roughly to years.
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Fr. Ostrander and Dr. Catton have been with the facility at least five years each.
- 2. Emissions have increased, rather than deczamed, over the last few years decay tanks remain uninstalled: the reactor exhaust stack remains too short, there is no accelerator nossle on top, and exhaust fans remain too weak to exhaust emissions at the required rate with the nossle on, the reactor' roof remains unrestricted in terms of physical restrictions:
the June 1980 fuel shipment clearly evidences failure of management organization to follow adequate safety procedures inspection report 80-02 indicates numerous log-keeping errors, failure of supervision, failure to report reportable incidents, failure to have necessary safety procedures (i.e. cracked rabb.'t).
- 3. Intervenor is not in possession of any evidence to indicate that the present situation is qualita.tively different from the management problems
' evidenced earlier in the facility's operating history.
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Question 26 Interrenor does not contend that NE[ personnel allowed "unauthorised" persons to operate the UCLA reactor, but that they permitted unlicensed l visitors operate the reactor. Instances whereupon these incidents occured as !
referenced in operating logs are as follows: (a&b)
Date-4-1-76, Run No.2101, a Demostration for Harvey Mudd Conego, "2030 hr.-
students operating at various powers". Page 76-96 of operating logs.
l Power level was variable, so it would appear that students manipu-lated montrols which would affect reactivity and power.
Date-5-28-76,Run No. 2115, a Demonstration Run for Culver High,"1402- student operatiens of reactor", power level was variable, so it would appear that students manipulated controls which would affect reactivity and power. Page 76-197 of operating logs.
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1 Date-9-11-76, RuheNo.2138, Demonstration run for ANS, students will operate reactor, "1550-student operation will continue,1628-Auto 100kw-student operation ceases." Reactor power was up to 100 kw, a it would appear that students manipulated controls which would affect reactivity and power. Page 76-338
- of the operating logs.
Date-5-21-77, Run No.2213, Class experiment for Mt. San Antonio College, "1032-student operation". Power level variable, so it would appear ht students manipulated controls which would affect reactivity and power. Page 77-180 of the operating logs.
Date-5-31-77, Run No. 2220, Demonstration for Pierce College and Sample irradiation for Marian Furst,"0911-student operation",at "097.8-Manual scrams" Power level was variable, so it would appear
! that students manipulated controls which would affect reactivity and power. Page 77-207 of h operating logs.
Date-6-10-77, Run No.2228, fl0TC run and demonstration run for class from Southern California 3dison,"1344-student operations began".
Power level was up to 100kw, so it would appear that students manipulated controls which would affect reactivity and pcwer.
Page 77-244 of the operating logs.
Date-12-7-77 Run No. 2275 Demonstration and student operations run for Cal. State Northridge, "1806-student operations begin,1040-
< Ashbaugh relives students". Power level variable to 100kw, so it would appear that students manipulated controls which would-affect reactivity and power. Page 77-334 of the operating logs.
- Date-1-7-78, Run No.2281, Reactor Demonstration and Au Activatihn, user-Mt. SAC, "1128-student operator takes over". Power leval-100kw , so we are '
not sure which instruments students manipulated. Page 78-8 of the operating logs.
- Date-4-21-78, Run No. 2309, Reactor Demonstration for Taft High Physics Students, l "1505-Taft H. students take over". Power level variable, so it !
would appear that students manipulated controls which unuld affect reactivity and power. Page 78-127 of the operating logs.
Date 4-28-78, Run. No.2311, Reactor Demonstration for Culver High Physics and check out for 135F, "1440 student operations". Power level was variable, so it would appear that students manipulated controls which would effect reactivity and power. Page 78-135 of h operating logs. .
1 Data.3-16-79, Run No. 2441, Class demonstration for Ca1=ha=== High School, "11:10 studmt operation". Power level 10kw, so we are not sure which instruments students manipulated. Page 147-79 of h operating logs.
Date-5-7-79, Run No. 2459, Demonstration for CSULA, "1545-students operating".
Power level variable, so it would appear that students manipdated controls which would effect reactivity and power. Page 237-79 of operating logs.
Date-5-18-79, Run No.2463, Demonstration for Culver High,"1453-student operation l coimiences". Power level was variable, so it would appear ht students manipulated controls which would effect reactivity and power. Page 258-79 of the operating logs.
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Date-7-1-79, Reactor Demonstraibn for Pierce College, " 1545- student operation begins". Power level was variable to 100 kw, so it would appear that students manipulated controls which would affect reactivity and p wer. Refer to operating legs.
l Contention IV l Westion 27 n) 10 CFR 50.40 andates that the Commission not grant a license unless the operating procedures, the facility and equipment, the use of the facility, and other technical specifications, or the proposals cellsetively provide reasonable assurance that the applicant will ,
comply with the ro6ulations in 10 CFR 50 and 20, Ag that the health and safety of the public will not be endangered. Contenti m IV, in part, goes directly to the question of whether reasonable assurance :
can be given that regulations will be obeyed in the future, since there is such a persistent history of violation of regulations in the past.
It my well be true that lax managerial and admin $s trative controls have contributed to some or all of these violations, and that some or all of these violatims my be evidence of lax controls, but the two are different issues. Some lax controls do not zesult in violation of regulations but nonetheless may provide evidence that reasonab%
assurance of future protection of public health and safety can be made.
Soms regulation violations are due to lack of money for equipment improvement or some other factor unrelated to managerial control.
In addition, some IE reports criticize applicant's unagerial controls while not formily citing it for violation of regulations.
b) The evidence for this contention comes from the IE reports, all of which are in Staff's possession, and from the Department of Transportation study of the !~4L incidant of June, 1980, and from the documents on continued emissions referenced in the Supplement, part VI. The same documents my be useful evidence regarding several different atters before the Board, and since the issues are so interrelated, this is likely to be the case. Were the unagsrial and administrative controls not so lax, the number of violations ~ woula likely be lowers were there fewer violations, and better management, and better instrument calibration, it is likely emissions would be lowert were the management better, the risks . rom excess reactivity insertion would be lowers were the applicant more financially capable, better unagement organization ard more staff could be hired, safety instruments could be better mintained, and nonexistent safety features could be added where needed. Each contention does relate to each others because, as 10 CFR 50.40 makes clear, it is a collective finding that must be made by the 3 card.
In response to the question as to which IE reports Intervenor currently believes support its contention on violations of regulations that have not previously been mentioned in support of its contentien on anagerial controls:
IE Inspection Report 50-ib2/69-01 50-142/73-01 50-142/74-01 l 50-142/75-01 50-142 77-01 50-142 80-02
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CCNTE!"rIC!! V Question 28 a)~ ~Intervenor has contended that the excess reactivity licensed limit is large enought that, when inadvertently inserted under certain conditions, it gg g , create a power excursion sufficient to raise the temperature of the fuel and/or the Add %g to the melting Point of either. Those calculations are included in the Supplement, part V, which is included herein by reference. The calculations at this point are haed on Applicant's calculations in Application, Part III, Appendix A.
For clarification, the calculation will be summeized here in addition ,
to being containcd in the Supplement.
Applicant's analysis in Application was able to estimate from 3crax
, data that 41 l#-sec of energy release would have been sufficient at the 3crax
- . to raise the aximum temperature of the fuel plate from the temperature of boiling water to the melting point of aluminum, a temperature change of approximately 10000F, through the formula UF hW sec
" *~****
Using a table included in the orginal Hazards Analysis and taken from one of the early 3erax articles, references in the Application, Applicant states that a re e.iprocal period of 150 see- "would give an energy release I 'of 41 !W-see in addition to the energy necessary to raise the fuel plate temperature to the saturation temperature of water." That period corresponds to 6.7 milliseconds: Applicant interprets the calculation to mean 6.7 milliseconds was the estimated safe limit for the Sorax reactor, while Intervenor interprets the same calculation to mean that 6.7 milliseconds was the estimated danger point for the Borax. A dekte over whether the glass is half full or half empty.
Applicantthenproceedstotransposethe3craxsafety/dangerpointto the UCIA situation. Correcting for differences in plate spacing, void coefficients, and figure of merit regarding heat flux, and without including errorbarsforeachtransformation,Applicantconcludes(pageIII/A-5) that the corresponding exponential period for the UCIA reactor is 9.1 milliseconds, corresponding to excess reactivity of 2. 5 keff. These caluclations are shown on page 5 of Intervenor's supplement part v.
SincethevoidcoefficientreportedbyApplicant(ApplicationIII/6-5) currently at the reactor has changed from the one used in the calenlations included in Applicant's analysis, the substitution of the void coefficient Applicantassertsispresentlycorrectchangesthesafe/dangerpointto 10 milliseconds and 2.15 excess reactivity. The other factors mentioned in the contention (e.g. lack of error bars, questions about correct 3 eta, effects of positive temperature coefficient for graphite) all indicate a degree of uncertainty about eith. the 2.15 or 2 5 figures sufficient to warrant a substantially lower li unsed limit, to he on the safe side.
b) There are numerous possible scenarios by which excess reactivity could be inserted into the UCLA reactor sufficient to potentially cause a power excursion. '"he pneunatic tube could insert a sufficiently large positive worth sampler or a large no6ative worth sample could be inserted and the control blades not reinserted before ejection cf the sample. Or an earthquake could force a e _:ple ta move out of the core area, removing neutron absorption and increasing reactivity.
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Question 29 )
l The was' 1960 6 5 deltaHazards k /k, which would be less than that necessary for-Analysis indicate
" prompt criticality". Prompt critical is, of course, simply above 3 eta.
The figures for Beta for this reactor Intervenor has seen to date vary from . M to .7 W. Thus keeping excess reactivity below .65, as the original haruds analysis recommended and as the Commission W.tially mandated, seems to Intervenor prudent. In addition, Saul Levine, Chief, Test and Power Reactor Safety 3 ranch, Division of Reactor Licensing, AEC, by letter to H.V. 3rown of UCLA, February 18, 1966, stated, "It is ;
noted that experiment worths are now limited to 0.69 4/k, and that only about 0.18% dk/k is needed to achieve the authorised and mum power level of 100 Kw." UCLA's response was that they needed more excess reactivity because of pile oscillation experiments then in use and 16-hour /dayoperationbecauseofextensivereactordemand,neitherof which is currently the situation at the facility, so far as Intervenor knows.
Question 50 (c), (b) and(c) Intervenor has no information regarding changes in the level of excess l reactivity since February 1976. -
(d)
Reference:
Page 27 of UCLA 1960 Hazards Analysis. Intervenor does not know on what calculations UCLA made the assertion, suggests Staff contact Applicant for answer to this question.
(e) Tha calculations and references are included on pages 2 and 3 of l Supplement, Part XI, which are included herein by reference.
(f) (1) Intervenor has made no contention that the power level increase has had an effect on the amount of excess reactivity available, and has no infora tion about any such effect.
(ii) the margin of safety is diminished by the increase in fission product inventory at 10 kw. Intervenor has no calculations or references at present to indicate precisely by how much the margin of safety is
, so diminished.
i (iii) Intervenor has no calculations or references at present rsgarding effect of power level increase to increase of fuel temperature i
'(iv)Intervenorlikewisehasnocalculationsorreferencesat present regarding effect of power level increase to cladding melting l
(v) Fission product inventory generally is proportional to powert l ne calculations available nor references regarding exact amounts of species (va-c) Ins,ervenar at this time has no calculations or references
- eegarding these questions.
Intervenor directs Staff to Applicant if Staff wishes answers for these questions. Applicant,, far more'likely than Intervenor, will know the i effect of its power increase on its fission product inventory, fuel temperature, etc. NRC' Staff is further directed to Applicant's answers to Intervenor's interrogatories VIII/1-52 if it wishes the information requested. ,
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Westion 31-As the UCU 1960 Hazards Analysis section on reactivity accidents is j simply xeroxed into the 1980 Application, this question has been answered !
in the response to testion 28, which is incorporated herein by reference. l bestion 32 (D), (b), + (c) Intervenor has no information re6arding this question of void coefficient change since 1976. URC Staff is directed to Applicant fcr an answer.
kestion 33 Intervenorhasnotcontendedthatthechan6efrom%deltak/kto dollars and cents hg, chanaed the excess reactivity calculations, but rather m h changed those calculations. The conversion from y*ds.nq to dollars and cents is ande by use of $. Since four figures fer p occur throughout the Application and the Hazards Analysis, depending on which is the correct fi ure, 6 the conversion may or may not have altered the excess reactivity limitation..
l If h is.74%, as indicated on page D-12 of the Hazards Analysis, then $3 54 (the newly proposed limit) actually equals 2.3% delta k/k. ,
$3 54 x .74% = 2.6196%deltak/k ,
@estion 34
, (a), (b) & (c) Intervenor has no opinion at present time as to what error bars (numerically) should have been utilized in using the Sorax data for the UCLA calculations.
E tervenor contends that the burden to do u, curate and reasonable and complete eniculatims as to safety limits falls to the Applicant and that the Applicant has not met that burden. Intervenor has merely contended error bars should have been included in the calculations and that those error bars, given the nature of the Borax Gata, should have been significant. l Intervenor contends that reasonable error bars can only reduce the
~
figure arrived at for a safe excess reactivity licensed limit, but has no information to determine by precisely what nar61n. 3 i
bestion 35 Intervenor's contention is that Applicant should have included a survey I of new data on reactivity questions since the Sorax tests utilized in !
its Application and Hazards Analysis. *he burden to do that analysis, l should the contention be approved, is on the Applicant, not the Intervenor. [
In the Supplement, Part V, pa6es 9 and 10, incorporated herein by reference, >
identifies a number of reactors whose experience provides important data j for possible consideration in reviewin6 the accuracy of UCIA's 20yearold analysis. As an Appendix to that part of the Supplement, a chart !
from Thompson and 3eckerley, Technology of Reactor Safety, is reproduced regarding some of the newer data that should have been considered. The ,
analysis Intervenor contends Applicant should do)would include, but not {
be limited to the reactor experience identified above. ;
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Question 36 i
These assumptions are detailed in pages 10 to 13 of Part V of the Supplement, which are included herein by reference.
Question 37 This contention is not based at this time on calculations or referencess it simply states that the pneumtic " rabbit" system, given the excess reactivity limit in the proposed license, provides 2 means of rapid insertion of excess reactivity capable of causing a severe power excursion. The calculations and references regarding the excess reactivity limit are included in answer tguestion 28, included herein by reference.
Question 38 (a) Reference regarding removal of beam tube, and related calculations, j are found in Hazard Analysis page 3-6.
(b) Removal of the binam tube. increases reactivity above the previously measured level. Reactor core has x % excess reactivity installedt thereafter beam tube is removedt neutron absorption is lessened; reactivity increases.
Thus if the core has precisely the Technical Specifications limit installed with the beam 1.ube in ple.ce, removal of the beam tube increases excess reactivit:r over the Technical Specifications limitations.
Question 39
'(a) Page 15 and 16 of Part V of the Supplement are hereby incorporated by reference by way of answer.
(b) Intervenor's contention is that, even were safe excess reactirity limits imposed by the license, it is impossible to prevent possible excursions at this facility, given its history of violation of its license, technical specifications, and Commission regulations, because Applicant may once again violate excess reactivity limits, this time disastrously. Applicant cannot give reasonable assurances that ,
it will obey whatever limits there are in its licenser thus reasonable assurance of protection of public health and safety cannot be given.
Question 40 (a)through(d) no informatimt available.
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@estion 41 If Applicant's effluent monitor is now correct (and independent samples referred to in I&E Report 80-03 indicate that possibility that the readings remin low), Applicant's radioactivity releases have increased significantly since the time in the mid-70s when the Commission determined (prior to Anandment 10) that UCLA was in excess of 10 CFR 20 Appendix 3 limits. SeeApplicationII/2-5,andAnnualReport1979,page9,and UCIA's Ashbaugh letter to NRC's David Jaffee, April 23, 1975 Corrected (by Ashbaugh) figures for emissions '73 and '74:
52.9 Ci released instead of .248 reported 1973 56.2 Ci released instead of 2.39 reported 1979 figures: 82.9C1(1979AnnualReport)
The concentration at the reactor stack is, whenever the reactor is running at full power, over the 10 CFR 20 Appendix 3 limits for concentration by several arders of magnituder even when averaged over a year's time, the concentration remins' over that limit, approximately 1 x 10-5 been maastired) P Ci/ml compared to 4(concentratgon x 10 p Ci/mi indicates of Argor/at thatonly the place where it has concentration is 250 times FTC. The provisions of the Amendment 10 permit reduction by 18.85 for operating time which still puts the facility at roughly 47 times FTC. The dispersion factor approved in Amendment ten of .115 still puts the facility over FTC by a factor of 5.4 The occupancy factor for the roof was esti mted to be 10fr a figure which Intervenor disputes-but as required by the Amendment, Applicant has reported changes in trutt factor. For example, on October 23, 1979, by letter from Neill Ostrander to Director, Division of Operating l Reactors, inforring the Commission of new information about use of the meteorological station on the roof which alone, without any other occupancy of the roof, brings the occupancy factor to 33 3fe at least.
'elith this new, more correct occupancy factor, exposure on the roof is 1.8 times FTC.
@estion 42 Reactor stack too short, no decay tanks in place, no accelerator nozzle l on stack, roof not restricted, reactor run too long at too hi6h power, no containment structure.
r Question 43.
No TLDs in place. Effluent monitor does not mtch readings from independent
- samples (former too low): see I&E Report 80-03 Eo Argon concentration l readings are taken anywhere except stack, thus there is no information available to demonstrate safety on nearby roof or inside Fath Science ,
kWi ng.
Question 44 exp,osures (a) Lower emissiong/could reasonably be achieved: move the math sciences' air vent, raise the stack height, increase the flow rate, put the accelerstar nozzle on. put in decay tanks; thus emissions are not as low as could be reasonably achieved. In addition, Applicant's own extrapolation of its TID data indicate (8-27-80 response to Staff question 2) that if scaled up to 1979 operating level, estimtei beta and gamma dose is about 97 mr/ year, averaging the TLDs. If the highest TLD is taken,forthehighestdoseinunrestrictedarea,(pageV/3-10 indicating the highest level being 50 mRom per year), scaled-to-1979 becomes j ,
ILD x97mr/yr=134.7mr/ year ,
If the scaled-to-1979 figures are scaled to aximum permitted levels under the license 05 x 365 days / year x 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day.x 100 kwth 43800 kwhours 294 hours0.0034 days <br />0.0817 hours <br />4.861111e-4 weeks <br />1.11867e-4 months <br /> x 100 kwth 29400 kwhours licensed limit , 7,49 1979 output
'"hus 134.7mr. x 1.49 = 200.7mr/yrinunrestrictedareas. l That is any times tackground... clearly not ALARA, which is supposed to ;
be generally considered as some sm11 fraction of background. l (b) 20.106(b)(1) requires that applicant mke a reasonable effort to l ninimize the radioactivity contained in effluents to unrestricted areas ;
Answer to Question 42, incorporated herein by reference, indicates that those reasonable efforts have not been mde. ,
20.106(b)(2) requires that applicants demonstrate that it is not likely that radioactive material discharged in the effluent would result in exposures to concentrations in excess of Appendix 3, Table II limits Intervenor contends (see answer to question 43 above, incorporated herein ,
by reference) that no such demonstration can be made by Applicant due !
to its inadequate monitoring. Averaging of emissions over a year - I in no way is a reasonable effort to minimize radioactivity nor of making l l adequate demonstration that excessive exposure in unlikely. l l
(c) In applying for license renewal, Applicant is requesting higher limits I for emissions than is contained in 10 CFR 20.106(b), as is evidenced by the calculations and references in answer to Question 41, included herein by reference. _
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Question 45 l
(a) Intervenor means by the ward " practicable" what is now meant by l the term " reasonable". Intervenor understands the current AIARA principle and requirement formerly was known as AIAP--As low As Practicable.
The term " practicable" is not Intervenor's but is quoted fron Applicant's current Technical Specifications.
(b) Since ALAP and AIARA are used here interchan6eably, answers to questions 41 and 44 are included herein by reference.
4 o COM1iFTION VII Question 46 (a) Intervenor's contention does not allege that unscheduled (reactor) shutdowns endanger public health and safety. Intervenor's contention is that the reactor's history of persistent pattern of numerous unscheduled shutdowns, abnormal occurrences, and accidents are so
! pervasive that they evince a pattern of unreliability which makes it l
impossible for Appliant to reasonably assure that the reactor will,
- if relicensed be operated in a manner which does not endanger the public health and safety. It is the pattern of urmeliability, evidenend by the high level of such occurrences, that is at issue in tMs contention, not the individual occurrence.
(b) see (a) above.
Question 47 (a) Intervenor is not in posass' ion of the Energy Reorganization Act of 1974 and thus cannot answer the question. If Staff can quote the definition in question from that Act, Intervenor can respond.
(b) An abnormal occurrence is a non-standard incident at the facility.
(c) Abnormal occurrences and unusual events which we are currently aware are !
identified and described ins
-Annual Report-UCLA Huclear Reactor Jan.1.1975 through Dec.31,75,pages 4-6
-Annual Report-UCLA Nuclear Reactor,Jan.1,1978 through De.31,1978,page.3. !
-Annual Report-UCLA Nuclear Reactor,Jan.1,1979 through Dec.31,1979,page 3. >
-Inspection Report-Co Report - No. 50-142/68-2, page 2. l
-Inspection Report-RO Report No. 050-0142/73-01,page1.
-Inspection Report-RO Report No. 50-142/74-01,page1. ;
-Inspection Report-IE Report No. 50-142/75-04,..page i and 6. .
-Inspection Report-IE Report No. 50-142/76-02,page1. j (d) Intervenor has made no contention to date one way or the other as to whether or not harm occurred from these past abnormal occurrences. Intervenor's l contention is that the high number of these occurrences evidence a pattern '
of operational unreliability which make it impossible for Applicant to assure that health and safety will be protected if license is granted.
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Question ,4_@,
(a) By " accident" Intervenor means an untoward incident such as a radiation spill, pipe break, coolant leak.
(b) These accidents are identified in the Supplement, Part VII, which is included herein by reference. In-addition, the shipment incident involving contamiration, and the cracked rabbit incident reported in I&E Repart 80-02.
(c)Theconsequencesinvolvedamagetocontrolpanel.(domineralizer leak), potential radiation exposure to the public '(leaking start-up sotr ces shipment incident, shield tank and coolant leaks, cracked rabbits .
CC'TEITIOfi E a ,. . % 49 (a) Because 1800 rem is a very high dose. The whole body dose received from the avera6e chest X-ray is about .029 mrom by comparison, and even X-ray
, doses that low are such as to have ph,rsicians carefully assess the risks of the exposure weighed against the medical need for the diagnosis.
(b)Yes.
(c) Intervenor at this time interprets 10 CFR 100 sections dealing with doses as based on the worst possible meteorological. conditions at the particular site. Los Angeles is known for its inversiansP that ir a big pert of the cause of Los Angeles' smog problem.
(d) The precise reasons why the UCLA severe inversion calculation is not a vraid upper limit are given in the Contention, parts la through e, incorporated herein by reference, and the the Supplement, Part VIII, likewise incorporated.
Question *0 (a) Far more than 10% of the volatile fission products may potentially be released in the maximum accident. Far greater figures than 10% of volatile fission products are assumed to be released through damaged er melted cladding when sir m v analyses are done for other facilities.
(b) For example, WASH-740 based its calculations on 1005 volatile release The Summary Report on the Hazards of the Argonaut Reactor by Lennox and Kolber (A"L-5647) regarding the original Argonaut assumed 50% release.
(c) Intervenor at this time has no conclusion as torthe fission product relsase it deems valid.
_ Question el (a) 3ecause to do so the SAR assumed "that the incident is not violent enough to blow off the top and side biological shields so as to cause an intense spray of water-steam-radioactivity mixture in M the building air,'
(b) The assumption identified in'(a) above is , invalid hr a simple review of the 3orax experience (see references cited in Applications plus Thompson and 3eckerley; and the film of the 3orax self-destruct).
A reactivity accident certainly can be violent enough to blow off the biological shields and cause an intense spray of water steam-
. In addition, the sources cited in answer to radioactivity
%estion 60 (b)allassumesignificantreleaseofnon-volatiles.
4estion R (a) Intervenor has not contended the statement attributed to it in the question.
(b) and (c) Intervenor cannot answer for the reasons stated in (a) above; the statement cited in the question is not the assumption Intervenor believes to be invalid.
@estion 53 (a) 3ecause it is now in a 7-story % ing.
(b) 3ecause maximum exposures may be inside the bn W ing.
Question 4 ,
(a) *his question is answered in the Supplement, Part VIII, page 5-6,'
included herein by reference. In addition, assumption assumes reactor room u:ulamaged, whereas that may not be the case.
(b) 1960 Hazards Analysis indicating efforts assumed to be taken to minimize potential leakage versus physical evidence made upon inspection indicating significant leakage under doors, etc.
(c) Intervenor has no fornal opinion at this time as to what leak rate would be valid. Intervenor's contention is that Applicant's SAR assumptions are invalids it is not Intervenor's burden to write an adequate Application for the Applicant, but merely to call to the attention of the 3 card the areas where the Application before them is invalid.
(d) We do not challenge the assumption of a 30 mile an hour winds we challenge the assumption of a 205 M ak rate at 30 mph wind, with a proportionately ascumptio:
lower leak rate at lower wind speeds. We do not necessarily support the 30 mpD/either (e) As we do not challenge an assumption about wind vehcity of 30 mph, there can be no answer here. see (d) above.
(f) Should part of the reactor room be destroyed, C .an products would not " leak out" at all, but just be released leak rate into the parts of Soelter Hall now next to the reactor when none was there when Fazards Analysis was built would not necessarily be tied whatsoever to Wind velocity outside the kilding.
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@estion 35
'(a) 3ecause the assumptions are critical to an accurate analysis because Applicant's previous assumptions (e.g. re6arding Argon emissions) turned out to be vast underestimations when actually neasured; beca L a the l
, central principle of science is that a hypothesis has little weight until its *ralidity is conclusively demonstrated through carefully controlled experimentation.
(b) Intervenor is precisely asserting that common scientific principles
_mL5t to be used be used is theinone thedescribed SAR calculations,)and in (a above. the principal scientific principle ,
(c) Intervenor's contention is that the burden to do a current review of nuclear safety literature is the Applicant's. The burden of proof that the twenty-year-old refereneus Applicant employed in 1960 are still valid with what is known today is upon the Applicant. As basis for its contention that there is new dose data t.vailable different from that used by Applicant in 1960, Intervenor cites Reg Guide 1.109, which also provides j some dispersion data. It is Applicant's burden, should the contention +
be approved by the Board, to do such an analysis, not Intervenor's.
I Questienff .
(a) Inspection Reports 80-02 and 80-03 (b) Inspection Reports 80-02 and 80-03 .
l (c)InspectionReport80-03 (d)InspectionReport80-03. l (e) Failure to calibrate instrurents properly pose a threat to health and safety as described in answer to Question 13 11 and 111, incorporated j herein by reference. The calibration errors regarding emissions pose ,
a grave threat to public health and safety because of the potential for ,
dangerous doses of radiation being received by the public. ,
(f)COReport68-1 I&E Report 80-02 I Question 17 '
(a) " Adequate time" is the amount of time sufficient to thoroughly and responsibly, within a significant margin of safety, maintain and calibrate equipment l and instruments.
l (b) We intend no specific form of mintenance in this contention but '
( rather all forms of maintenance necessary for safety to be adequately assured l and reliability insured.
P r
(c) We refer to all components of the facility which require maintenance.
(d) Contention IX.6, about whi::h this quection is asked, does not go to the question of whether individual *.nstruments have been adequately 1 calibrated, but to whether Applicant has devoted adequate time to calibration of its instruments.
(d) The basis for this contention is found in the Applicaticrfs listing of overall maintenance tima requiring operation of reactor. Intervenor's contention is that the amount of time reported by Applicant is insufficient to adequately maintdn the facility. Specific components and safety systems can only be determined when access is granted to the maintelance logs tFat haven't beer. lost by Applicant, access to which Intervenor has not at this time been granted.
CO:TENTION I Question 18, (a) This' question is answered in response to Question 17, answer to which is incorporated herein by reference.
(b) 3 of the other reactors in the state mentioned as alternatives already existing are operated by the Applicant and available for use in education and research by any UC student.
(c) Intervenor has at this time no specific cost figures. .
_ Question W (a) DBA as used in this contention is defined as the maximum accident '
that could occur at the facility, should the worst event or series of events credible occur.
(b) This Question is answered in Intervenor's response to Applicant's Interrogatory No. 42a, which is included hersin t/ refcrence.
(c) The likelihood of a design basis accident is insed on a collective showing of all the evidence referenced in support of all the other contentions. The evidence of violation of regulations, inadequate monitoring and calibration and maintenance, lax managerial controls, history of operational unreliability, all provide a collective showing of unacceptable likelihood of accident.
(d) Intervenar at this time has no calculations regarding 1-v, aside from those calculations Applicant has provided in Application, which, although based on numerous assumptions that make the estimates too low, i still show dose estimates that are what Intervenor calls dangerous.
(a) see (d) above.
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@estion 62 ,
(a) " inherent safety features" are instrinsic safety features, those that are inherent in the physical nature of the reactor concept being censidered.
"Engineerd safety features" are systems that are added to the basic reactor concept. The features intended and their explanation are included in Contention III 1 9 and Supplement, Part XI, both of which are included herein by reference.
(b) Intervenor at this tiae has no opinion of the configuration of the containment structure that should be built by UCIA.
(c)10CFR50.40 (d) Intervenor at this time has no such calculations.
@estion 61 (a) Studens operation of the reactor; students involved in raintenance and calibration; students involved in activation analysis, pneumtic tube operation, tours; ready access by its training nature of large nunbers of people capable of sabotage.
l Annn=1 Reports and Inspection Reports from (b)6 (1) Supplement, 197 through 1981. Part III, and (b) (ii) See answer to question 47c in Interrenor.'s answers to NRC staff's interrogatories.
(b) (iii) Refer to Annual Report-UCLA Huclear Reactor:
Jan.1, 1972 through Dec.31, 1972, page. 1-2 Jan.1, 1971 through Dec, 31,1971, pages 1-2 Jan.1,1973 through Dec. 31,1973, page 1 Jan.1, 1974 through Dec. 31,1974, page2
- Jan.1, 1975 through Dec. 31, 1975 pages 3-4 1 Jan.1, 1976 through Dec. 31, 1976,pages 2 h Jan.1, 1977 through Dec. 31, 1977,pages 2-3 Jan. 1,1978 through Dec. 31, 1978,page 2 Jan.1, 1979 through Dec. 31, 1979,page 2
. Applicants The above references describe all infomat9n regarding^ unscheduled shutdowns currently in Intervenor's possession.
l (1. ',1v) See answer to question 48b in Intervenor's answers to NRC staff's l int- :ngatories. htervenor has made no contention to date and has no infor-mac ,n at this time, as to the consequences of these accidents, ortway or another, to University personnel, students, and the _public.
9
Question g 3y "significant damage" Intervenor means damage sufficient to require a mjor mintenance effort thereafter. Intervenor has made no contention one way or the other regarding whether a threat to public health and safety did or did not result at the time; Intervenor's contention goes to possible future threat to public health and safety from earthquake vulnerability in case of major earthquake should the license be renewed.
_ Question 63 A far smaller volume or mas of fuel is necessary at high enrichment to cause a criticality accident. One cupful of U-235 at UcIA's enrichment is sufficient, under the right circumstances.
Question 6'l Same definit, ion as in 59(a) above, incorporated herein by reference.
(a) Intervenor has no opinion at this time as to the specific anner in which fission products would be released as a result of the DBA.
No D3A has yet been determined for this reactort one of Intervenor's contentions is that Applicant should determine such a D3A after serious analysis and then adequately esti m te fission product sleases.
(b) see (a) above. All Intervenor can base its judgeant on at present is Application, the estimates in which Intervenor be9. eves are far too low, and yet nonetheless would endanger the public.h alth and safety.
Contention XII Question 65 (a) The evidence is the consequential dose estimtes of Applicant without containment; any reduction of those doses would be a significant protection to the public, i
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l (b) Intervenor has at this time no such calculations.
@estion 66 (a) has been too extensively shielded and moved too far from its proper locatial to perform its job correctlyt this because it kept scramming reactor too often. Rather than reduce its sensitivity the zadiation problem should be taken care of.
l (b) Bather than reduce the sensitivity of the monitor the radiation l 1evels should be reduced; the shielding should be removed and the monitor returned to its original location.
(c) CO Report 69-1.
Question 67 I. These questions are answered in Intervenor's response to Applicant's Interrogatory 43.c, incorporated herein by reference. The addition Intervenor believes should be made is the addition of systems a-f.
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i II. Uo calculations or material of an evidentiary $1ature is available '
at this time.
l _ Question M (a)"%equateshielding"meansbarriersbetweenradiationsourcesand the public capable of keeping public exposures as low as reasonab]y achievable.
-(b) " access restrictions" are physical tarriers to people antering certain areas (c) physical locations wherein a member of the public may be situated and might be exposed merely through presence at that location to radiation or radioactivity from the reactor; such locations are Fath Science-3oelter Hall roofs, inside of Fath Science Buildings inside of 3oelter Hall: 3oelter courtyard and walkway.
(d) Intervenor. at this time has no firm opinion of precise radiation exposures in the above areas, because the only measurements taken to date of which Intervenor is aware are measurements taken by Applicant, which are badly flawed, contradictory, have large margins of error, and otherwise inadequate (see Contention VI). Answer to Question 41 and 44 above, provide some extrapolation of data currently available, and are incorporated herein by reference. In addition, the Rubin thesis, indicated Argon concentrations inside Fath Sciences of roughly 60%
of those on roof utilizing the dispersion factor and operating time limit approved in Amendment 10 and the concentration at the stack, the only known concentration (if the monitor is s'ccurate), gives Argon concentrations inside Math Sciences in the area of 3 24 times EPC. Accurate figures for public exposures can only be given when adequate monitoring has been done, which Intervenor contends has not been done to date and is a burden the Applicant must meet before relicensing is granted. Ihe few film badges placed have such high threshholds and, Intervenor believes, such poor controls, that doses of biolo61 cal significance could be being imparted.
(e) Applicant's "1D and film badge datar Rubin thesis.
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(a)Ihe reactor should have an interlock system which prevents operation of the reactor when someone is in the 3rd floor void area and when the high level radiation monitor is not connected to the scram system, and both systems should be adequate to effectively prevent operation under those conditions.
(b) When NEL personnel have noticed keys to 3rd floor void area missing,'
they have had to chain the door shut after visual inspection of the area. NEL personnel have run the reactor with the radiation monitor by-passed.
(c) The system should make reactor operation impossible (prevention of start-up and immediate scram if running) whenever someone is in 3rd floor void area or potentially in area and whenever that door is unlocked likewise for ccruiitions in which the high level monitor has been bypassed or over-shielded. ,
(d) CO Report 69-13 operating logs notations regarding 3rd floor key missing and need to visually check it and chain it.
Westion 70
- The diagrams of the reactor provided in the Applications viaual inspection.
3 NA 4estion 71 (a) No information available at this time regarding operating experience of 100 kw graphite moderated research reactors as to graphite changes.
1 (b) see (a) above.
@estion 72 (a) page 8-9 of Supp]snent, Part XI, incorporated herein by reference.
(b) Intervenor has made no contention, one way or the other, about past control blade problems having caused damage to public health or safety; i Intervenor's contention is that the control blade problems evidence an unreliability of a key safety feature making it impossible for Applicant to adequately assure that operation during the next twenty years, if relicensed, can be done without undue threat to public health and safety.
Contention XIII
@estion 73 Intervenor believes the SUM license request is for an excessive quantity and enrichment of S111 because the amount requested is fcr more than a fresh core and a present core & because only a present core is needed for operation.
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Intervenor does not agree with implication of Staff's question that the S5K request is for one irradiated core and one fresh core. Nonetheless, it believes that the request for 4700 grams irradiated and 4700 grams fresh is dangerous because it increases the availability for diversion of bomb-grade uranium, particularly through its placement at a facility with inadequate security, and because it increases the risk to the public, and the consequences from that risk, of damage due to radiological sabotage or somte other event causing release of the fission products in the irradiated fuel. The risk to the public from diversion of the SNM is that some group (sukational or national) could thus acquire part or all of what it needed for an atomic bombi the consequences of that are dire.
Question 73 (a) The original Argonaut reactor and the University of Florida Argonaut both have run with lower enrichment fuel (b) Eazards Analyses for both reactors 1
CCETrTICK XIV j Question 76 (a) Intervenor's contention is not about specific problems common to Argonaut reactors. Intervenor's contention is that an analysis of problems at other similar research reactors as the UCLA reactor should be included in the Application in order for the Board to adequately judge the safety of this reactor. As basis for the contention,
- Intervenor identified three problems to show that such an analysis i would be useful. Those problems are identified in the Supplement, Part
-IIII, incorporated herein by reference.
(b)theevidenceisidentifiedintheSupplementpartreferencedabove.
(c)positivetemperaturecoefficientforgraphitethrowsoff excess reactivity calculations if not included in those calculations, makin6 power excursion potentially more likely; lack af replacement '
control blade moters my make the reactor uncontrollable in event of l failure of the existing motors; coolant system tied in with potable l system creates public exposure potentials and reactivity and coolant problems if water level drops because of water pressure changes. s (d) see (b) above.
Question 77 Intervenor's contention is that a review of these problems by Applicant is necessary. It is not Intervenor's burden to perform that analysis for Applicant. Inspection Reports 68-1 and April 1975 indicate at least 2 of the above-identified problems exist or existed also at UCLA.
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Contention X,V -
Westion 78 l
(a) through (e) Intervenor has mde no such calculations at this time of an independent nature. Applicant's own estimates of radiation dose (ApplicationIII/A)indicatetoIntervenorthatconsequenceswouldbe significant. Intervenor contends it is Applicant's burden to produce adequate and accurate accident consequence estimates.
Question 70 Those buildings increase the likelihood of exposure and increase the mgnitude of the number of people so exposed. There are many more people immediately around the reactor than before, and the new construction m ksa possible exposures to the public inside the building rather than nerely outside it a reality, reducing dispersion, increasing concentration of radioactivity, and thus significantly increasing dose. Precise figures estinting the sffects of these changed conditions are Applicant's burden to produce.
Sggg, tion 80 Reactor building was initially a separate building. Kow it is part of an entire building complex built around and on top of it.
These air systersinterface by necessity because they are ri6ht next to each other. The actual architectural plans are available from Applicant, which has not yet yet made them available to. Intervenorg Staff is directed to Applicant for those detailed plans.
Question 81 The esfety significance is described in response to Question 79, included herein by reference. Intervenor has calculated no doses at present and directs Staff to Applicant for such calculations.
CormTIC:' XVI Question f,1 .
(a) This is answered in Intervencr's response to Applicant's Interrogatory 50.a. which is incorporated herein by reference.
(b) See (a) above.
Westion 83 If it is difficult to repair or replace M s because of their age and because the manufacturer is no longer in the business, reliability of iristrumentation can severely suffer, improper "make-shif t" repairs or use of parts not quite appropriate can occur, and there is increased risk of safety systems failing ard accidents occurring.
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Parts are difficult to acquire, R & D into safety improvements for that kind of reactor have stopped, support services normlly provided by
' mnufacturers to operators of functioning plants are not available, no one entity is keeping track of safety-related atters of Argonaut type reactors, and there is no one place where continuity of knowledge about Argonauts is maintained. -
Contention XVII
@estion 35,
' Intervenor has no belief rosarding this matter at this time as to specific Richter scale or accelerogram shape for the SSE at this site, but believes it to be well beyond what this facility can withstand.
Questionfl (a) This depends very much on the accelerogram for the quake and the -
particular response of the M m gnand/or reacter. The worst consequences af an earth-quake induced reactor accident at this facility are the release of significant quantities of fission products, and exposure of significant numbers of people to radiation.
(b) Intervenor relies at this tir.e on an interpretation of Applicaat's radiation dose estimates in time of accident, included in Application.
Intervenor has made no specific calculations and has no computer.
If Staff wishes an adequate earthquake analysis to be done, including computer modeling, Intervenor suggests Staff ask Applicant to produce such an analsysis. It is Applicant's reactors it is Applicant that is requesting a licenses it is Applicant which has the burden of proof that an earthquake will not result in severe reactor damage or produce a threat to public health and safety if damaged. Intervenor contends Applicant should have done such an analysis and has not done so. Whatlimitedinformationithasprovided(Application,III/A) shows consequences Intervenor views as unacceptable. Intervenor's review of that analysis by Applicant is that its estimates are, furthermore, way too low. Applicant should do an adequate analysis. It is not Intervenor's burden to write an adequate application for Applicant.
Question 87
. (a) Applicant has described the damage as requiri g a major maintenance
, effort to repair. Intervenor views this as significant dange. Intervenor has requested in its Interrogatories to Applicant aetails of that damage, but is not yet in possession of a response. Staff is directed to Applicant for that information, as it is in Applicant's possession at present.
(b) Intervenor has made no contention as to actual consequences of the 1971 l damage to public safety Intervenor's contention is that the damage evidences seismic vulnerability that could pose a threat in a maximum earthquake shuuld the facility be relicensed.
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l We know of no studies, literature, or reports that UCLA has produced t to comply with 10 CFR 50.34(b)(1). 'Ihat is precisely our contention--
! that the information' required to be provided by UCLA by 10 CFR-50 34(b)(1) I has not been. We have not contended that UCLA has produced studies and reports that it has not included in the Application; we have contended that they have not done' the studies and reports that would provide the required information.
00rrE'!TIO!; XVIII Question 89, Part XVII, pa6e 1-4, of the Supplement is included herein by reference by way of answer.
Co m ENTIO2 XIX Question 00 (a) We have mde no sasumption at any time to date regraling specific explosive and amount to be considered in the hazard scenario.
identified in Contention XIX. , Our contention is that such hazard scenarios as sabotage, including the use of explosives, should be analyzed by Applicant in determining a maximum credible accident or design basis accident for this reactor. Intervenor has madd no such analysis at this timer Intervenor's contention is precisely that it is the Applicant's burden to do such an analysis.
(b) See (a) above.
@estion S},
Vere a saboteur to throw explosives or place explosives on or near the reactor, the saboteur could readily escape unharmed, depending on the time deley of the explosion and other factors. It would be quite possible. in Intervenor's view, for a saboteur to use explosives to destroy the reactor and for the saboteur to be in a safe location when that destruction occurred. A saboteur could also conceivably be hurt in such an act; a suicidal act that kills any others is no less a tragedy.
Question 92 Intervenor has mde no such calculation and suggests Staff ask Applicant to mke such a calculation, as it is their burden. An explosion could kill and wound a relatively small number of people; an explosion at a reactor would potentially add to that a great any additional deaths and injuries and latent health effects. !
@estion ,J o ..
1 "his inforation is not at pres'ent in evidentiary form. Intervenor's t investigators have spoken to local FAA officials and local airport officials by phone, who inform Intervenor's investigators that airliners, private planes. and helicopters fly over or near 3oelter Hall. Helicopters and l ivate plans do not have standard routes but rather are permitted to I . y in certain air spaces, which includes that space near and over UCIA.
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Airliners coming in to land at Los Angeles International Airport, our investigators were informed, routinely fly within a few miles of UCI.A as they pass over Santa Monica on approach; in addition, when airport some of is backed which circles at ni6pass up may ht, planes are putAdditional over UCLA. on circlesinformation for holding, ' tid sno.
be obtained by requesting Applicant to present proof that planes never fly ,over or anywhere near the campus. The presence of commercial, private, and helicopters in the airspace over or near the campus has been confirmed by visual sighting by C3G volunteers.
Questign n (a) Depends precisely where the aircraft hits the bi41 ding, what direction, speed, etc. it is traveling, and the b" 9"5's response. The maximum accident possible from this hazard scenario, in Intervenor's prelimirary view, would be major release of fission products.
(b)Sameasabove. The effects from fission product release may well be the same from a small plane crash as a big one, or even from a helicopter crash, depending upon point of impact. Result for both (a) and (b) depends upon where crash occurs-crash could be directly into reactor
- room leaving 3oelter intact and fission products escaping throughout it.
Or it could bring 3oelter Hall down, killing some, and trapping and wounding many others, forcing them to be exposed for far longer periods of time to the fission products released because they are immobilized by)therubble.
(c Plane crash or helicopter crash into any other bi ing on campus could only cause death and injuries related to the crash (perhaps in Chemistry or other labs some release of toxies); crash into 3oelter would be those effects ragnified by the addition of major radiation release.
(d) Intervenor has made at this time no mathematical calculations. Intervenor's contention is precisely that Applicant should do such an aralysis.
_ Question 0,,j, (a) scenarios in which not merely one thing goes wrong, but, several which are interdependent.
(b) Intervenor has made no estimate of the consequences of such a series of events. nor determined what is the worst possible such series of events.
Intervenor's contention is precisely that A iplicant I should perform such
, an analysis.
! (c) The statistical probability of each multiple failure mode is dependent upon the particular failure mode in question. Again, it is Intervenor's contention that Applicant should do an analysis that determines which multiple failure mode that could possibly occur would result in the maximum accident. Site characteristics and safety features cannot be fully assessed absent such an analysis.
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Question 9f(
(a) '4e have made no contention as to which operator error or errors would lead to a 23A. Intervenor has, however, contended in this Contention that Applicant should make such an analysis.
(b) See (a) above (c) See (a) above Contention XXI Question 92 One cannot know in minutes precisely the time delay unless ten accidents occurred over the years and data was available to show the delay was inconsequential ce consequential. In absence of such evidence, the prohibition, Intervenor contends, is an unnecessary delay.
Supstion Sj, la) What if you can't locate the Vice Chancellor?
(b) The person on the scene should have the authority to order the evacuations or there should be clear alternative lines of authority in l case.Vice Chancellor can't be reached; and there should be clear I
guidelines established and procedures routinely worked over by which the person with authority to order evacuation would judge whether to so
, order (c) To reduce public radiation exposures in case of accident.
t Questien $
(a)(b)and(c) See answers to Question 98 above, incorporated herein by reference.
%estion M
! Alternative personnel to carry out that role should be -established, with -
l chain of responsibility readily understood and people readily on call.
l _ Question 101 l Intervenor's organization has been at the campus, as have many of its members, for a decade, and are aware of not a single evacuation drill, training pro 6 ram, er other program for evacuating the entire campus. .
In addition, no such provision is made in Applicant's emergency plan f submitted with Application. ;
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Westion 102
($) Intervenor has not contended that the UCLA medical center should be shutdown in case of a major accident, but that it is possible that a particular form of major accident would make such shutting down prudent, desirable, or necessary. 'The medical center is only a short distance from the reactor.
(b) An accident which releases significant quantities cf fission products and in which the wind direction is not away from the medical center (although even with the wind being away from the center, emergency officials might prudently and properly choose such an evacuation because of fear of the wind shifting).
(c) Intervenor has not contended that the UCLA medical center would be adversely affected; merely that it could be. Intervenor suggests Staff ask Applicant for Flculations showing the medical center could not be adversely affected in an accident. Intervenor has no such calculations at this time beyond the ones in Application; it is Applicant's burden, Intervenor contends, to take the hospital into consideration and prove that there is no possible way the medical center could be adversely affected.
Question E The Emergency plan does not make clear precisely which pieces of radiation and emergency equipment and what quantities of each piece of equipment are available at each equipment location; without knowing that, how can emergency officials or officers obtain the necessary equipment with which to respond rapidly?
Question 104 (a) Intervenor is aware of no evacuation drill for 3oelter and Fath Sciences ever being conducted (Emergency Plan, 5 2).
(b) See (a) above.
Respectfully' submitted, m
f .h Eark'Pollock Attorney for Intervenor CO EITTEE TO 3 RIDGE THE GAP 1
Dated at Los Angelcs, California this 20th day of May, 1981 l
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VERIFICATION I, DANIEL 0. HIRSCH, say:
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- 1. I am the President of the CCHMITTEE TO BRIDGE ME GAP, , ,
'Intervunor in this action, and I have been authorized.to sign this.
verification on.its behalf. .-
2 All of the information provided in the attached ANSWERS OF THE CGetITTEE TO BRIDGE THE GAP TO STAFF'S FIRST SEE OF INTEPJt0GATORIES represents the information currently possessed by the Intervenor relevant ..
to those Interrogatories. _
- 3. I have read all said ANSWERS and do believe them to be true and. correct. -
Signed on May 20, 1981, at Los Angeles, California.
I hereby affirm that the foregoing is true and correct.
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Daniel 0. Hirsch 6
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'I L3ITI:D STATES OF MIERICA NUCLEAR REULATORY CD:HIISSION 3EMRE THE ATCHIC SaFhTl AND LICCSDG 30A_RD In the Matter of ) l
) Docket No. 50-142 THE RE3:iTS OF THE UNIVERSITY )
0F CALIMENIA ) (Proposed Renewal of Facility
) License) -
(UCLA Research Reactor) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of "AFSWERS OF COMMITTEE TO 3 RIDGE Tr2 CAP TO NRC STAFF'S FIRST SET OF IITTERRCGATORIliS" in the above-captioned pwcseding have been served on the following by deposit in the United States mail, first class, this 20th day of May, 1981.
Elizabeth S. Bowers, Esq., Chairman Counsel.for URC Staff Administrative Judge . U.S. Nuclear Regulatory Commission -
Atomic Safety and Licensing Boad - .lashington, D.C. 20555 '
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section
. Office of the Secretary ,
Dr. Emmoth A. Luebke U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 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 Boad U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Uilliam H. Cormier, Esq.
Office of Administrative 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 .9 I Hark Pollo~ck l Counsel for Intervenor ;
l Cod 1ITTtE TO ditIDGE THE GAP
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