ML20003G619
| ML20003G619 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 04/20/1981 |
| From: | Helwick C, Reidhaar D, Woods G CALIFORNIA, UNIV. OF, LOS ANGELES, CA |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8104300269 | |
| Download: ML20003G619 (8) | |
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i 1 j-RErJC CORRES?0NDM
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UNITi.D STATES OF AMERICA
.,j NUCLEAR REGULATORY COMMISSION 4;
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
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10 In the Matter of p
Docket No. 50-142 tb
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11.THE REGENTS OF THE UNIVERSITY (Proposed Renewal of
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Facility License 12
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Number R-71)
!(UCI.A Research Reactor)
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April 20, 1981 13 14 i
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16 APPLICANT'S FIRST SET OF INTERROGATORIES TO NUCLEAR REGULATORY COMMISSION STAFF j
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18 19 PROPOUNDING PARTY:
THE REGENTS OF THE UNIVERSITY OF CALIFORNIA j
RESPONDING PARTY:
NUCLEAR R5GULATORY COMMISSION STAFF 21 SET NUMBER:
ONE 22 23 I
- lgto, DONALD L. REIDHAAR l
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CLENN R. WOODS go$
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CHRISTINE HELWICK i
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Applicant, The Regents of the University of California requests t
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2 !the Nuclear Regulatory Commission Staff (NRC Staff) to answer the following l
3 jinterrogatories under oath within thirty days in accordance with 10 Code 4lof Federal Regulations Section 2.740 and the schedule contained in the order i
5 !issuedMarch 20, 1981 by the Atomic Safety and Licensing Board in the i
6 linstantaction.
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8 In answering these interrogatories, please furnish all information 9
as is known or available to you regardless of whether this information is
] possessed directly by you, or by agents, employees, representatives, 10 l
finvestigators, consultants,oryourattorneys.
11 12.'
N 13 h If any of these interrogatories cannot be answered in full, 14ll answer to the extent possible, specifying the reasons for your inability 151:to answer the remainder, and stating whatever information, knowledge, b
16 '! opinion, or belief -you do have concerning the unanswered portion.
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18 As used herein from time to time, "NEL" refers to the Nuclear 19 Energy Laboratories; " Contention I," " Contention II," etc., refers to 20 specific contentions (and, where indicated, their subparts) contained in 21 the proposed Stipulation of November 28, 1980, as amended by the order 22 issued March 20, 1981 by the Atomic Safety and Licensing Board in this 23 laction, which amendment effectively integrates the three attachments to the 24 l Stipulation but with the same numbering sequence as appears in the Stipulation, 25 and" staff" refers to the Nuclear Regulatory Commission staff.
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h IIINTERROGATORY NO. 1 (Contention I):
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2' At the time applicant was preparing to renew its facility license 3
did you provide applicant with written instructions relating to the 4 'information to be submitted as part of applicant's research reactor license 5
renewal application?
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7 lolINTERROCATORY NO. 2 (Contention I):
ti 81 Has applicant responded to all supplemental questions you have 9 asked of applicant relating to applicant's license renewal application?
l 10 11 INTERROGATORY NO. 3 (Contention I):
12 Was the staff misled by the reference in.the application to the 13 iC. B. Smith article on experimental vibration of the reactor? If yes, 3
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14 lplease explain.
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lINTERROGATORYNO.4(ContentionI):
16 17 Does the staff contend that the application contains any materially
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18 ! alse statements? If yes, please explain.
f 19 l fINTERROGATORYNO.5(ContentionII):
20 21 Are any research reactor training facilities which are operated 22 by educational institutions licensed as " class 103" facilities? If yes, 23,please identify the facilities.
24 25,INTFL OGATORY NO. 6 (Contention III):
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26 l Based upon the operating experience of the applicant during the 27 immediately preceding five-year period beginning January 1,1976, does the j
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1 : staff contend that applicant's managerial and administrative controls l
i 2 ihave not been adequate in prctecting the public health and safety? If yes, 3
please explain.
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5 INTERROGATORY NO. 7 (Contention IV):
6 Based upon the operating experience of the applicant during the i
I 7 jimmediately precedi'ng five-year period beginning January 1, 1976, does 8 f the staff contend that applicant has exhibited a consistent pattern of 4
9 jregulatorynon-compliance? If yes, please explain.
10 11. INTERROGATORY NO. 8 (Contention V):
12 Based upon the operating experie ce of the applicant since the 13 establishment of applicant's current reactor excess reactivity limits 14 (" Change No. 1" to the technical specifications, dated September 20, 1966),
15 jdoes the staff contend t. hat the amount of excess reactivity permitted by 18 the technical specifications could bring about melting of the fuel cladding 17 and thereby endanger the public health and safety? If yes, please explain.
18 19 _ INTERROGATORY NO. 9 (Contention VII):
20 Based upon the number of unscheduled shutdowns and abnormal 21 joccurrencesatapplicant'sfacility'duringtheimmediatelyprecedingfive-22 ! year period beginning January 1,1976, does the staff contend that the 23 reactor is unreliable and, thereby, a danger to the public health and l safety? If yes, please explain.
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i 1 INTERROGATORY NO. 10 (Contention XII):
2' Are the safety features of applicant's Argonant-type teactor, l
3 las described in the application, generally the same as those found on 4 jother Argonant-type reactors? If no, please explain.
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5 6 jiINTERROGATORY NO.11 (Contention XIV):
7 ;'j Are you aware of any problems of safety significance common 8 to Argonant-type reactor facilities? If yes) please explain.
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10l: INTERROGATORY NO. 12 (Contention XVIII):
1 11 i
Is the infctmation provided by the applicant in the application 12 sufficient to demonstrate to you that the applicant possesses the funds 13 rnecessary to cover estimated operating costs or that the applicant has 14 reasonable assurance of obtaining the necessary funds, or a combination 15.of the two? If no, please explain.
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,t 17 lINTERROGATORY NO.13 (Contention XIX):
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18 Is sabotage an accident scenario that a research~ reactor operating
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19 license applicant is generally required to consider as part of that 20 applicant's safety analysis? If yes, please explain.
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INTERROGATORY NO. 14 (Contention XIX):
2' Absent a demonstration that the approach flight paths of large 3licommercial airliners are in close proximity to applicant's facility, are I:
4 ':research reactor operating license applicants generally required to consider 5 airplane crash scenarios as part of applicant's safety analysis? If yes, 6
please explain.
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9l Dated: April 20, 1981 l
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12 DONALD L. REIDHAAR I
GLENN R. WOODS 13 CHRISTINE HELWICK 14 15 By i
GLENN WOODS' 16 l l
Attorney for Applicant I
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(DECLARATION OF SERVICE BY MAIL (CODE CIV. PROC. SS1013a & 2015.5) 2 I,
the undersigned, say:
I am a citizen of the United States, 3
over 18 years of age, employed in Los Angeles County, California, in 4
which county the within-mentioned mailing occurred, and not a party 5
to the subject cause.
My business address is 2214 Murphy Hall, 6
405 Hilgard Avenue, Los Angeles, California 90024.
I served 7
the attached:
APPLICANT'S FIRST SET OF INTERROGATORIES TO g
NUCLEAR REGULATORY COMMISSION STAFF 9
10 11 by placing a copy thereof in a separate envelope for each addressee 12 named hereafter, addressed to each such addressee respectively 13 as follows:
14 SEE ATTACHED 15 16 17 18l Each enevlope was then sealed amd with the postage thereon 19 fully prepaid deposited in the United States mail by me at 20 Los Angeles, California, on April 20. 1981 21_
There,is delivery service by U.S. mail at each place so l
addressed or regular communication by U.S. mail between the place 22 23 f mailing and each place so addressed.
24 I declare under penalty of perjury that the foregoing is true 25 and correct.
26 Exc
- -d on April 20, 1981 at Los Angeles, California.
DARLENE OTTEN
)
Elizabeth Bowers, Esq.
l U.S. Nuclear Regulatory Commission 2
Atomic Safety & Licensing Board Washington, DC 20555 3
Dr. Emmeth A.
Luebke 4
U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Board 5
Washington, DC 20555 6
Dr. Oscar H. Paris I
l U.S. Nuclear Regulatory Commission 7
l Atomic Safety & Licensing Board j Washington, DC 20555 8
!! Counsel for NRC Staff I Office of Executive Legal Director 9
U.S. Nuclear Reg *Jlatory Commission l Maryland National Bank Building
!0 7735 Old Georgetown Road Bethesda, Maryland 20015 33 Daniel Hirsch 12 Committee to Bridge the Gap 13 l 1637 Butler Avenue. #230 i Los Angeles, CA 90025 14 Mr. Mark Pollock 15 Mr. John Bay 1633 Franklin Street Santa Monica, CA 90404 16 Chief, Docketing and Service Section 37 Office of the Secretary U.S. Nuclear Regulatory Commission gg Washington, DC 20555 19 20 21 22 23 l
24 25 P00R ORSKl
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