ML20009H055

Interrogatories & Request for Production of Documents Directed to NRC Re Proposed Renewal of Ol.Declaration of Svc Encl.Related Correspondence

ML20009H055
Person / Time
Site:	05000142
Issue date:	07/30/1981
From:	Pollock M COMMITTEE TO BRIDGE THE GAP, POLLOCK, M.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8108050399
Download: ML20009H055 (62)

Text

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A3 70 dE3, EIA, i:UFIG/C3-2079, and TUF20/03-219?."

TO: "RC 5TAFF A"D IT3 ATTCP:TY CF 3ECORD, CCILE WCCDHCAD.

Intervencr. CC:C'I""EE TO 33IDGE HE CAP, hereb/ requests that said Staff arsuer the follouirg interrogatories fully and separately ':rder cath, pursuant to the 3oard Order of July 1, 1001.- Furthernere, also pursuant to that 3 card Order, Intervenor requests production of certain decunents detailed herein.

It is intended bf this set of interrogatories to elicit informatice not nerelv within your own personal knowledge, but obtainable en your 3' S

behalf, such as b/ your attorneys, enployees, investigators, and representatives. In particular, certain irterro6atories are directed ff to certain of your consultant identified as responsible for the contents of certain studies to uhich these interrogatories go. All such interrogatories are to be answered fully and under oath; where complete information is not in the possession of the party responsible fo~ answering, they shotild so

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. state a-r1 provide what irforration is available. ataff :_nd its ccnaultants

.,.re renirded of the dut" to supplanent responses as rcr 10 ':73 2.740e.

"o new studies are requested by these interrocatories. If 3 pff has no irfornation in its possession or readily acquired, it should so state ari' provide what inforraticr it does pcssess. If an; cartial informtion is available, that inferratice. shculd be provided. If inferratien is available ir a forn different than requested by Intervencr, uho cannot how the fern of inforration er catecories in which it is crcanized in uhich "cu possess the inforration, please provide the infornation in what forr. and catet; cries you do possess.

As per the 3 card's Order, responses are due to be served thirty da,;s af ter service of this disccvery request.

,.1 2especyfully subnitted,

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t I"TEFROCATCRIE3 AS TO THE SA T Y E'. CAPIC" 'EFCr 1 5'i3 v. 1-2

1. 323 states: " Our technical safety review w. .1 resput !to icwirr a renewal operatirg license to UCLA has been tased on the infornation cortaired in the renewal applicatic and supportinF appendices plus resp *cses to. requests for additional .rfornation." 3E3 further indicates ~

all of said 'infornation is available for review at the FDR and the LFDR.

a. Besides security infornation, ard tesides Applicant's responses to Staff's April 17, 1980 request for infernation as to 15 items and Staff's July 31, 1980 request for information as to 14 '

uestions, what urittan requests for information have been made by topic and date) and what written responses have _ teen received ty date of response)?

b. 3esides the items indicated in the quoted passage above and in response to la above, and besides the itens identified on SER p.1-3 (annulal repcrts, reports by Inspection and Enforcement, and the Los Alames-and Battelle studies), what specific documents and records were reviewed by Staff in preparation of the SIR? Please identify said docunents and records by author, title, and date.

2. SEE states: "This SER will serve as the basis for renewal of the licerse for operation of the UCLA facility at power levels up to and i ircluding 100 kw." Precisely. what is meant by the phrase, "This SER' will serve as the basis for..."? .

3. SER states: The facility was reviewed against the Federal Regulations, applicable Regulatory Guides, and appropriate accepted industry standards." .

a. Which particular Regulatory Guides (by number, title, and date) was this facility reviewed a6Tinst?

b. Against which " appropriate accepted induecry standards" was this-facility reviewed against? -Waere said standards tre in documents, please -

identify with specificity said documents.

4. As Staff has ar6ued in the past (Decenter 1,1980, "NRC 3?AFF FC3ITICE C" U" STIPULATED CC"TE rIO:*S").that dose values in 10 CFR 100 do not apply to research reactors such as the UCLA facility, and as 3oard upheld this position in its Parch 20, 1981 Order, on what basis does Staff now conpare " calculated dose values with related standards in 10 CFR Fart 100, the standards fer accident considerations for power reactors"?

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5. Precisely what shielding (by composition, thickness, density, and location) was added to the reactor

a. when the power increased from 10 watts to 10 kw

b. uhen the power increased from 10 kw to 100 loa

c. when new construction was added on the sides of the reactor facility

' d. when new construction was added on top of tF reactor facility.

Please provide all drawirEs that indicate said shielding.

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6. The SER refers to twenty years of operation "en a utilisation level of 9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per week." Intervenor understards the 8.5 heur linitation to te part of A-endnent 10, adopted in the nid-1970s, and has seen. indications in operating lors and inspectior reports of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> / day operation for extensive perieds during the 1960s. Plea:e clarify SER statenent.

7. The SER refers to other Argoraut reactors which have cpera ted

"#cr nore than twenty years on a utilisation level cf ?.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per week."

Frecisely where do s the P.c hour figure cone fron, uh!ch Argenaut reactors does it refer to, and does Staff intend by that quoted statenent that operation limited tc an avera6e of 8.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per week has occurred during the twenty year operating history of these reactors?

iER 2 1-4 P. 3E2 ntates that accident doses outside the reacter rocn "will probably not exceed 10 Cy? Part 20 deses." Which specific 10 CF3 20 deses:

for the public, fer occupational enposures er sone other standard?

9. SER statenent that accident doses "will nost certainly be only a small prtion of doses set out in 10 CF' Part 100 for offsite dose guidelines for power reactors." Applicant's Application indicates doses considerably in excess of said guidelires. Ey ce_leulation and reference, specifically descrite the errors Staff believes exist in Applicant's Appendix S cf

' Fert III of the Application that invalidate Applicant's estinates and trun validate Staff's far lower dose esticates.

10. 323 states that Staff has determined t' er .:.pplicant's nanagenent organization, conduct of educational and research activities, and security neasures "to be adequate to assure safe operation of *he facility." a)

Precisely what does Staff mean by " adequate" in this centext?, b) Joes 3taff consider these factors to te tetter than adequate?, c) Does Staff consider these factors to be excellentS, d) Conpared to other research reacters, would Applicant be considered to be in upper third, niddle third, or louer third of said reactors with regards the adequacy of said factors?

11. Precincly how dces Staff defire "as leu as reasonably achievable" as used in the content of this page, and uhat is the source cf that definition?

12. Rt what standards did Staff judge Applicant's conpliance with A1A2A?

13. Cn what precise bases did Staff conclude that releases of radioactive naterials from the facility and public exposuren fron said releases cannot reascnably te lowered?

lb Where in the SER is the analysis showing ALARA teing net?

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If, Eas 3taff corcluded that Applicant Pas adcquately denonstrated that it will allocate the necessary furds to cover operating costs without conpronisirg safety? If so, en precisely what tasis has this deternination been nade?

16. *ihen dces 3taff anticipate publishinC its supplenental 32P regardirg the outstanding iten, energency planning?

3ER s. 1C

17. SER states that "The UCLA research reactor is an Argonaut-UTR reactor using about 4 kg of U-235 fuel enriched to apprximately 935 in a graphite-reflected, water moderated core."

a. Intervenor's understanding is that the Argonaut reactor at UCiA uses less than 4 kg of U-235 in its core loading. Is the core loading of the UCLA reactor nore or less than 4 kg of U-235?

b. Do other Argonaut reactors have core loadings snaller than that at UCLA? If so, please identify the Argonaut and the size of its core leading in terns of kgs of U-235

c. Application at Page III/-6-4 indicates the noderation for the UCLA reactor is "H2 O and graphite." Does Staff assert that the UCLA Argonaut reacter does not obtain moderation from its graphite?

Please explain the SER quoted statement in this regard.

19. 3ER states the fuel in the UCLA reactor is contained in FCR-type plates. Describe the similarities and differences between the UCLA fuel and the FOR fuel.

19. Eave leaks ever developed in UCLA's " watertight aluninum" fuel boxes?

Eave leaks ever developed in said boxes at other Argonaut reactors?

If answer to either question is affirnative, plea,se provide date, cause of incident. extent of leakage, and, if at a reactor other than UCLA, which reactor.

20. r e- old is the graphite used in the UCIA reactor?

ai has any of the graphite used in the UCLA reactor ever been used in Krather reactor? If so, please indicate which reactor, its neutron flux (fast and thermal), and the number of F% days during which the reactor ran uhile that graphite was in the reactor. In addition, p3..ase indicate the anount of said graphite that was previously irradiated, if such was the case.

b) Does Staff accept the EUREC/CR-2079 WL-3691 estinate cf how nuch

'a*1gner energy the UCLA reactor could have absorbed to date? If not, please indicate, ty ralculation and reference, the figure Staff believes to be ccrrect.

c) 3y the year 2000, uhat changes in characteristics, through irradiation, contanination, or aging, could cccur in the UCLA reactor graphite, ard what possible effect en reactor operations could those changed characteristics hase?

-4 d) Does currently UCLA 4" the reactor) have sp?re If so,graphite bars precisely (bars where andother howthan those are they stored, and in Staff's view, is the rraphite thus stored adequately protected from the elenents or other danage? ,

e) Please describe with specificity the analysis dore and data acquired by Staff in assessing the current ard potential condition of UCLA's graphite for its reacter, both in core and in storage.

21. SER refers to cadmiua plates used as centrol rods for the UCLA reactor, a) Are the control blades (rods) pure cadmium, cr are they alleyed with or jacketed by sone other substance? (Intervenor here does not refer to the nagnesium shrouds).

b) If the blades contain substance (s) other than cadniun, please identify the substance (s), whether alloyed with or jacketed around or in sone other configuration, the amount, thickness, chemical form, and otner relevant specifications for the non-cadmium part of the control blade, c) What is the melting point and boiling point of cadmiun?

d ) Does cadnium burn in air or underco chemical reactions with air, water, steam, nagnesiun, graphite or aluminun? If so, at #1at temperatures and under what conditions?

e) If cadmium burns or vaporizes, are any toxic or carcinogenic products released? If so, unat are the health effects associated with such release, f) Why is cadnium rarely if ever used in control rods for reactors operating at considerably higher tenperatures than the UCLA reactor?

f) Please specify the analysis that has been done by Staff as to the effects of a fire, earthquake, reactivity insertien, or other incident uhich causes the reactor tenperature to rise to tenperatures causirg control blades to nelt.

22. Can the control blades be withdrawn from the reactor core region .

through any other means than operation of controls at the control panel?

Specifically, can the control blades be nanually nanipulated uithin the reactor roon? If so, please describe in detail how such nanipulation could te done and indicate whether Applicant has in the past ever done so, giving details and date.

23. 3ER indicates that the control blade drives are " located outside the ranctor shield for accessibility." So these drives have nissile shields protecting them? If so, please describe the missile shield and their capacity (i.e. what size and velocity of missile can they withstand, or what inptet forco) snd the calculations and references by which that arsucr is nade, s

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"ote: in the 24-31, centrol blades refer to the entire control device.

24. Inotevent no-alvofthe p nquar.e.platg*

ear.adnis wea. failure nodes exist for the control blades?

Please detail analysis of said modes.

25. Yhat g force would be required to force control b:-des to " jerk out" cf the core region?

26. 'lhat g force would be required to force control blades tc break off and fall out of core region?

27. What g force would te required to cause binding of control blades, preventing blades from being inserted into core re6 1on?

29. " hat failure testing has been done of this type of control blade?

Cit 3 the studies by title, date, and publication information. What were the results of said studies?

29. How rany scrans em the blades withstand (gravity drop scrans) prior to failure?

3C. Ecw many years of operation can the blades undergo prior to failure?

31..Flease provide by calculation and reference the bases for answers 24-3C and descrite the ana]ysis Staff has undertaken of the ratters raised in said questions.

32. SIR states that the "four control rods and protected by cagnesiun shrouds."

a. Please descrite precisely the chenical form of navnesium the thickness and other dimensions of the shrouds, what kif any) other substances conpose the shroud and how,

b. Please describe precisely the control blade stop (the device,

-barrier, or other nechanism or thing which stops the control blade i after it has completed falling into the core region and prevents the blade fron falling out of the core. )

c. Please describe any redundant control blade stop (i.e. any nechanism, device, or barrier which would prevent the blade from falling out of the core if the first barrier fails. )

i d. Picase describe all failure testirs of the tmchanisns, devices, i

er barriers identified in 32b and c above and the results of said testing.

e. Eave the control blade stops at the UCIA facility or any other

' research reactor using similar control blade systens failed? If so, please identify each such instance by date, reactor, cause, and identify I all documents related to said instances.

f. Can warping or other nalfornation of control blade shrouds prevent or slow doun control blade insertion? If so, please descrite how such an occurrence could exist,

g. Have such instances occurred at UC1A or other facilities with sinilar shrouds? If so, please specify each instance, date, and cause.

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h. What is the nelting, vaperization, and ignition tenperature of the nagnesium used in the control blade shrouds? Under what conditions will the ragnesium ignite? What is the caloric release per cran of ragnesiun burned? What analysis has Staff perferned regarding nelting, vaprori::ation. er igaition of the ragnesium with regards an accident at this reactor or any similar reactor?

33. Please describe all centrol blade talfunctions at the UCLA reactor irdividually, by date, describing incident, and outlining cause.

34 On what specific factual basis does Staff deter-ine the control-blade systen to be reliable through the proposed license period?

35 What control blade ralfunctions is Staff aware of at other Argonaut reactors? Please describe all such instances individually by date, reactor, description of incident, and cause.

< 36. '.lhat efforts has Staff nade to asc'ertain what control blade problems have been experienced by other Argonaut reactors?

37. Is a bicycle-type chain used in the centrol rod drive system?

If so, has it ever failed? Give details if known.

3 . Eas the control blade logic systen at UCLA ever failed? If so, please descrite each such incident, i

39. SER states *The graphite prism is surrounded tv a biological shield of both conventional and heavy (nagnetite) aggregate concretes."

3ER states further the shield was designed in the late 1950's,

a. Reactor cas designed in the late 1950's to operate at 10 ku

, in a building with no members of the public on flocrs above. Both conditions have since changed. Please detail with specificity all alterations to biolo6 ical shield (and other shielding) sinco reactor was cririnally designed. In particular, please cescribe '_7 drawin6 and description placement of all paraffin and lead,

b. What is the density of the nagnetite and the conventional i cencretes?

att is the ninimal thickness of the concrete shield?

d. *ihat level (in curies and in mrem /hr. dose contact) of activation products has the shield acquired to date,suhat level could be expected by end of license period (year 2000) if operating licensed limit were net for the next 20 years?

e. Applicant asserts naximum dose fron streaning radiation cutside biological. shield is 200 mr/hr. Does Staff have any independent information by which to measure that assertion? If so, please provide said information.

40. 3ER states, "This shield was designed in the late 1950's with an adequate factor of safety against seismic forces for a Zone 3 earthquake area."

a. Precisely uhat is the numerical size of the " adequate factor of safety"?

b. Against what criteria does Staff determine the shield to have "an adequate factor of safety."? Please specify the particular code sections, industry standards, or other standards.

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c. Precisely how n.uch acceleration in the vertical &horiscntal E-U, 7-s) d,irections was the biological shield designed to withstand?

d. What is the largest capable fault near the reactor s.ite?

e. How close is the nearest apprcach of said fault. to the reactor site?

f. What is the accelero6ran--that is, the shape of the curve of acceleration--for that fault at the reactor site in the worst case scenario?

g. What is the naxinun ground acceleration possible and naxinun pessible magnitude in Fichter Scale for that fault?

h. Shw by calculation and reference how the naxinun credible earthquake at the largest capable fault near the reactor site could be withstood by the reactor's biological shield.

1. Have earthquake design standards for reactor conpenents such as biological shields changes since the late 1950s? If so, please detail how they havS changed as such changes would relate to current standards for building a biological shield for a research reactor at the UCLA site.

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j. Dces the reactor have a seisnic scran device other than the I embedded switches in the nonolithic shield? If so, please detail the TAture of said device.

SER n. 1-6

41. Please bescribe all notification received by the Connissien fren UC1A at thc Line of the additional construction next :c and en top of the reactor building in 1968. (Give title and date of all docunents related thereto)

42. Please describe all analyses done by the Connission prior to 1974 of the effects of the new construction done in 1868 in terns of radiation protection to the public and seismic risk to the reactor. CiYe title and date of all docunents related to said analyses.

43. Descrite in detail all shielding additiens nade related to the new potential areas for public radiation exposure.

44. Was the Connission notified in advance of said construction, and did it grnnt approval for the 1968 building additions?

h5. Did the Connission analyze, prior to 1974, the effects to public health of having the Fhth Science building ccnstructed .next to the reactor building and the placenent of the exhaust stack uhere it now is in relation to the IS air inlet? If so, please provide said analysis if not, please explain why rot.

3E3 n. 10 .

h<. Is air from the reacter roon exhausted from said roon cnly when reactor is operating, or is it exhausted at other tines as wel?

a. If exhausted only when re.,ctor is cperating, what prevents Argon-41 buildup in t':e reactor reon?

b. If exhaust only when reactor is operating, does this nean recative pressure is maintained in reactor roon only during operation?

c. If exhausted air is released fron reactor rocn at times other than operation, please descrite under what conditions air is exhaustri and when not. During the day is the exhaust systen in operation?

Is it turned off at night?

47. Please detail precisely how Ar5cn-41 produced in the reactor core is produced to begin with,

a. : iou nuch air is present in the core, at any cne time, and uhere, fren which the Argon-41 is activated?

b. How is the air with the Arcon-41 renoved from the core and released through the exhaust stack? And at what rate (cfn/ninute of air containing Argen-41) is air renoved from the core?

c. Precisely where in the core are there air pockets in which the Argon-41 is produced'

d. Is there a separate Argon-41 or air renoval systen fron the cora, separate from the exhaust fans which keep the reactor roon at regative pressure? If so, please irdicate where the core air systen is located, hov it operates, and whether it operates only when the reactor is operating or also when the reactor has teen shutdown?

49 Is the 3rd. floor crea described on 353 p.1-9 fenced by a fence that cannot be climbed over?

49. Is there a docr darough whica entry can be made into that area?

i 50. Is Staff aware of any tines uhen that door has been lef t open or l

unlocked? If so, please indicate each such time and the circunstances.

I fl. Precisely what is the aircorditioning systen in the 3rd floor area used for? Does it provide cool air to reactor complex? Eoes air fron re.-eter complex other than reactor roon exhaust through that airconditioning systen?

52. What is the function of the water denineralizing equipment used by the reactor facility thatis based on the 3rd floor?

a. Eoes radicactivity buildup during reactor operation in that denineralizer?

b. What are the highest direct radiation readings found at contact with the denineralizer?

c, Should the denineralizer malfunction and reactor o ation continue, would reactor cooling water (either secopdary or primary)per generate or

' contair nore radicactivity than it does norna11y? What uould be the i

naximun radioactive content (in nicrocuries per n1) i' such an occurrence l

uere to happen?

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53. 1.*ere the denineralizer to malfunction or be intentionally danaged, is it possible for efflu2 nt containing radicactivity in excess of 10 CFR 20 public exposure licits to 'ce released into urrestricted areas (for exanple, via ficodin6 of public ualkuays, engineering snack bar)? Please explain the basis for answer, c4. Is the denineralizer for secondary or primary coolant?

55. Is there another denineralizer for the other coolant loop? Where is this denineralizer located?

e6. "here is the secondary effluent radioactivity monitor located precisely (3rd floor,1st floor process pit, orwhere?)

57. Is the secondary coolant a closed or open loop? Does it recirculate or is it once-through, dunped after use in the seuer?

58. If the denineralizer were to nalfunction or be intentionally danaged and the secondary effluent nonitor likewise nalfunction er be dana 6ed by intent, what would prevent release of radioactively contaninated water off-site? j

59. Is the denineralizer used to renove minerals from the coolant water so that those inpurities aren't activated and don't become radioactive?

If not, please describe precisely the use.

60. Has the denineralizer ever nalfunctioned?

61 Eas effluent fron the denineralizer ever travelled beyond the confines of tha 3rd floor equipnent roon? If yes, please give details and dates.

62. Has nalfunction of eculpnent related to the denineralizer ever danaged other reacter equipment? If yes, please give specific details.

63.. Iten 1-5 of SE3, "conparison with Similar Facilities" consists nerely of three sentences. Besides the Los Alanos and 3attelle studies, what review of other Argonaut reactors has Staff perforced in relation to this proceeding? 2e specific,

a. Mas Staff reviewed IER's and abnormal .. :urrence reports for other Argonauts in Iceparation for producing this SER?

b. Eas Staff reviewed Annual Reports for other Argenauts in preparation for producing this SER?

c. Eas Staff reviewed inspection reports for other Argonauts in preparation for this SE3?

d. If the answers to a,b, or c are affirmative, please estinate what percent of the existing docunents were so reviewed.

64. 30 changes in water pressure in UCLA's secondary coolant systen affect any reactor paraneters such as coolant tenperature, safety of having prinary systen at lower pressure, or any other reactor paraceter? If so, please identify all such effects.

45. Please identify total annual usage of the UCLA reactor fron 1960 to -

1972.

SEE n. 1-10 i

' 66. Precisely what does Staff nean by the tern " confinement buildirg" cr "confinenent roon" as used at this pare?

67. What is the difference tetween " confinement" and "ccciainment" as the latter tern is usually used regarding reactors?

69. What is the leak rate fron UCIA's "confinenent building" for air? What is the source for this ' answer--calculation, estimate, test data? Please provide said calculations, estinates, or test data.

69. Precisely what is neart by " concrete glass curtain wall" re6arding the University o# Uashington?

70. The chart lists forns of "containnent." Ices Staff cortend that the reactor at UCLA has a "containnent" around it capable of containirg fission products released in case of accident? Frecisely on what does Staff base its cnswer?

71. '3ER chart indicates Iowa State and Virginia Polytechnic reactors operate on 90' rather than 031 fuel. Please explain why.

72. The chart irdicates Iowa and Virginia reactors use only 144 fuel elenents whereas UC1A uses 264 Please explain the difference.

a. "cw can Iowa and Virginia function with a core leadinc 555 that.

of UCLA?

b. What preventa UCLA fron functioning as do the other two Argonauts with a leading of only 144 elenents?

e. In what configuration is the fuel loading at Virginia and Icwa?

73. Please identify the reactor vendor or manufacturer for each of ths five listed Argonauts.

74. Please identify the excess reactivity linits for each.

1

75. Please identify the fuel spacirg and thickness of cladding for each, as well as the delayed reutron fraction and pronpt neutron lifetime.

i l 76. What prevents UCLA from operating at the power level of the 1.ictor at Iowa State; i.e. why is a 10 kw power level linit satisfactory for Iowa but would not te for UCLA?

77. Please describe shielding differences between -the five reactors.

j 7P. Are 1ER's routinely transnitted between the five reactors or fron staff? If not, why not?

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79. What is the Arcon-kl concentration at the point of emission for each of the ft;e reactors?

CO. Which',~if any, of the other four reactors has an exhaust stack near unrestricted areas of canpus buildings or near air inlets for such buildincs? If any do, please identify all documents referring to such instances of which 3taff is aware.

1. Nt is the licensed linit as to ancunt of 37K at each of the five facil* r.ies?

2. Uhat is the data of first criticality for each of the five (year of starting would be sufficient answer)?

C3. Which other Argonauts have applied for reltaensing?

4 ch. Cf those which have not so applier , uhat are the reasons for not 1

yetapplyi{.g?

Cf. Has 3taff approved the relicensing cf any Argonaut within the last tuo years? If so, which and when.

66. Eces 3taff anticipate renewal of license of any Argonaut prior to rulirg ty the licensing 3 card in the UCIA reactor proceeding? If so, for uhich Argonauts?

C7. Are there other research reacters awaiting relicensing besides

'Arcerauts? If so, please estinate how many now face relicensirg or will within the next three years.

F8. Is 3taff aware cf any other contested research reacter relicensing L proceedings--either for other Ar6cnaut reactors or other types? If so, please identify said reactor (s).

99. Which o' the five Ar6cnaut reactors listed have ever utilised fuel of louer enrichnent than 9047 j a. For each reactor so identified, pleaso ind icate period - Curirg

! uhich such fuel was used, its enrichnent lev. 2, and why it no loncer uses said enrichnent.

b. Please identify all documents of which Staff is aware relative to use by other Argonaut reacters of lower errichment fuel than 905.

c. Is 3teff aera

• any reactor in the U.S. or abroad which utilizes flat plate-type fuel, aluminum clad ard uranium-aluminun neat, of less than 901 enrichnent at present? If so, please identify each such reactor and the enrichment of its fuel,

d. Does Staff assert that the ; are no reacters in operation currently utilizing fuel as identified in c above? If so, please provide the basis for said assertion.

2 s

,,w3-- w r-. em,w-- , - e,-.,m,..m,=--+-..r-. e ., v.+----- --------+--.--.*x.-v,r.,* -,re- - , - . . - .-w m- - e ,-.---%-.-.,.w-e, w =----,v- -r - -

e. ?ere the 3 card to place as a condition on the UCLA license that it use a louer enrichtent fuel than it presently does, is it Staff's .

position that the UCLA reacter uould te unable to function? If so, please explain and provide all facts 3taff could produce to suppcrt such an assertion.

3EP n.~ 1-11

90. 71 ease update Table 1-6-1 for 19 0 and add 1960 to 1972.

3ER n. 2-1

91. Coes Staff assert that the area north of the UCLA campus is urdeveloped?

SE? n. 2-2

92. Do the data recorded on this page represent residential population cr does it include the canpus non-residential population and the

,.eople rornally in Westwood Village shops, restaurants, novie theaters, L7d offico buildi.nFs?

a. If terely residential pcpulation, what are the figures if non-residential populations are added in?

93. Has the population around the reactor site (within 2.5, 5.0, 7 5, and 10.0 miles respectively) increased since 1960? If so, by what factor (s)?

323 n. 2-3

94. SER states, "In addition, there are several other connercial airports approximately 45 miles from the campus." Please icontify all such airports, ard their distance fron campus.

9% Please provide all facts Staff can produce to support the statement, "There are no scheduled eirlire routes over the campus." Please indicate the source (s) of all suen facts, and identify with specificity all documents which relate, thereto.

96. What is the nearest scheduled airline route in relationship to UCI'-

and how close (in distance) is that nearest approach? At uhat altitudes do planes flyin6 along said route fly, what is the largest type of plane that flies along said route (s), and hcu much fuel uculd said planes have at the time of nearest apprcach to the UCIA canpus? Hou many planes annually fly along said route?

97. Does 3taff asseri. that commercial p3 anes never fly over the UCLA campus?

If so, please provide all facts.and identify all documents that suppert said facts, that form the basis for that assertion.

98. If Staff does not so assert, please indicate hcu many commercial planes do fly over campus annually.

4

i i

r

. c?. Do contercial airliners fly over or near campus when put on circling patterr.sauaiting lardirg at nearkt airpcrts? Flease provide all facts and indicate their source that support your answer.

100. Please indicate all airports for private rlanes ard so-called

" light aircraft" within 15 miles of UCLA.

101. Do private planes and other " light aircraft" fly ever UCLA?

Flease provide source unl identify documents for all facts you can prcduce to suppert your answer.

I 102. What is the largest private plane or " light aircraf t" that is permitted to fly over UCLA?

103. Do helicopters ever fly over UCLA? What is +he largest helicopter that is pernitted to fly over UCu?

104. Do helicopters routinely land and take-off fren UCLA campus itself?

Frovide all facts you can produce to support your answer.

105 Env -- neercial airliners per year

~

actly cytr the UCLA campus 2 thin one mile of the campus e, fly within tuo miles of the campus d)flywithinthreenilesofthecampus

e) fly withiv five miles of the canpus f) fly witnin seven niles of the campus r

h{s ny withinten fly within nine nilesofofthe m',les the canpus campus 106. Please answer questions a through h for all airplanes and jets that are not concercial airliners.

107. Please answer questions a through e for all helicopters.

10P. If Staff has infornation relative to plane and helicopter travel over ind near UCLA that does not f;t the categories ir interrogatcries c6-107, please provide the information that Staff does have relative thereto.

109. How dces airplane density in the Los Angeles 2asin compare with other areas nationally in which reactors are placed--i.e. is the la 2asin l the third nest ercuded airspace in the country, the 9th nost crowded, the 100th, for any cenparable-sized airspace?

110. How rany helicopter crashes occurred in Southern California ir the twenty years the reactor at UCLA has operated? (If Staff does not have figures for tuenty years but does for other time periods, please provide these. )

111. How many plane and jet crashes, other than those involvin6 connercial airliners, occurred in Southern California in the tuenty years the UCLA reactor has operated.or any alternative period of time for which Staff has figures?

112. Please answer question 111 for connercial airliners.

113. Please indicate the source of answers 110-112 and all documents relative thereto.

,4-114. What are the cl.ances (i.e. statistical prabability) 'aring the next tuerty years of a

a. cornercial airliner crashing on the UCLA campus b, plane or jet other than concercial airliner crashing en the UCLA campus

c. helicopter crashirr on the UCLA campus

d. comnercial airlirer crashirr into 3celter Eall

e. plane or jet other than contercial airliner crashing into icelter Eall

f. helicopter crashing into 3oelter Hall

g. cornercial airliner crash damaging reactor (either directly or through damage to building causing fire or building collapse)

() h. r above for plane or jet other than comnercial airliner

1. g above for heliccpter 115. Please provide all calculations, references, and facts upon which those ar suers are based and identify all docunents relative thereto, 116. Could the colunrs of Boelter Eall which support floors five through eight above the reactor collapse upon i= pact fren a helicopter er non-connercial airliner plane or jet crashing into these columns? Flease provide all facts upon which the answer is based.

117. Ecw nany columns would have to collapse or be damaged before the floors uhich they hold up would collapse?

11P. Here those floors d5 and above to cone crashing down en the reactor roon ceiling, would the ceiling sustain the impact?

110 If the ceiling did not sustain the inpact, what would be the maximun possible.

danage to the reacter?

120. Uhat is the strength of the reactor roon ceiling ard the supporting colunns *n the third floor void area?

1?l. Please provide all facts, calculations, and references upcn which answers 116-120 are taned.

122. In case of changed weather conditiers or other factors, are there concercial airline patterns (as opposed to routes) which cet within five niles of UCLA? If so, please identify such patterns and the closest approach for each to UCLA.

123 SER states"There is no heavy air or railroad traffic. . . "3y this does 3taff nean air traffic is not heavy near the campus, or rather does Staff mean that heavy airplanes (i.e. big commercial airliners) do not re6ularly fly near the carpus?

124 Frecisely hcu close, in terns of =iles, does 3taff consider "close enough to the campus to :onstitute a threat to safe operation of the reactor?" Frecisely where dces that standard of closeness come from, and what is the nunerical guideline so assigned? Does Staff have formal guides for deterniring adequate distance fren overflights and concentration of said flights considered Icu enough to be adequately safe; if so, please identify such guides.

J

125. SER states: Wirds blow from the ocean (usu, sw) about two-thirds to E..reo quarters of the daylight hours, as shown in Ficure 2-3-1. For tha renaining. tice vinds are fron inland directions." What is the frequency, severity, and duration of severe inversions?

SE3 n. 2<

s T 126. The atmospheric dilution figures provided are over what distance?

127. Precisely what neasurenerts were done in connection with smoke release

< experiments by which a nunerical atmospheric dilution was determined?

- 129. Precisely what neasurerents were done in connection with balloon releases by which a numerical atmospheric dilution factor was determined?

129. "one of the tests mentioned by Staff produced dilution factors outside the range of 4-6 x 10-3? If any results were outside that range, please indicate what those results were.

130. SER states: "The water table is estinated to lie 200 feet below the surface of the campus and its vicinity."

a. Estinated by when?

b. Estinated how?

c. Ertinated when?

d. I nat did Staff do to check the estinate.

131. 3E3 states: "The reactor core lies about 10 feet above Westwood loulevard which is the main drainage course and therefore the area nest likely to te flooded from runoff from the watershed area :: orth of the campus."

a, 'fhe reactor roon floor lies hcw many feet above or below the loading zone to the west of the reactor rocn?

b, The botto, portion of the reactor core lies how. nany feet above the reactor roon floor?

l c. Ooes land rise to the Torth and West of the reactor roons i.e. ,

is the reactor roon built on a low portion of a hill rising to its rorth and uest?

i l

i

d. Did Staff corsider ruroff # rom those parts of campus that are on higher grourd than the reactor (e.g. area arourd i: core ard Knudser Halls)?

If so, please provide all such analysis.

l 132. 3ER states: "From the information provided in the application and a site visit, the staff concludes that there is no risk of floodirg of the reactor from precipitation, runoff or risirg ground water."

a. Old technical staff nake only ore site visit (aside from security natters) prior to preparing this 3E3?

b. If nere than one site visit, please irdicate how many, and the dates of said visits.

,c. Please irdicate the total number of hours spent en site by the technical staff responsible for this SER.

d. Is not the reactor roon lower than surrounding areas innediately arourd the reactor room in order to make sure that water flow would not be from the roon to the cutside?

e. 3E3 ntkes to statement alout risk of flooding f rom causes other

_ _ ~ .__ - __ ____ . _ .

- - . .. . . ~ .

i tha- "creci31tation. rur.off or risine grourd water." Fleaso provi?e all arilyses that have been nade of risk of flooding of the reactor i fren causes other thar these. I-tarvenor ir this question refers to the risk of floodirt the reacter, rot the risk from floodirc it.

}

i 133. The paragraph about "Evdrology" does rot address the question of co-tamiration of ground water. Please provide all aralysis dore by 3taff rerardirr that natter.

i 134. The paracraph about " Hydrology" does not address the question of whether s ' 3xist in the vicinity or not. Please prcvide all information 3taff car procuce as to the exjotence of wells on canpus or in the

! vicinity,

t. -

t

[ 3E2 2 4 2

! 'S c 337 states: "Thouch it is recognized that the UCLA canpus nay to path of a active seismic f ault, it is difficult to deternire ard verify the derree o# activity of such faults and the potential damage that can occur to the reactor or reactor buildirg." i

! a. Which particular active seismic facit nay UCLA be ir the path of?

b. When was it nost re;ently active, what was the size of the associated seisnic event (in Richter ;cale and in grourd acceleration maximun),

what damage occurred fror said activity?

c. Please provide .he information asked ir 135b above for seismic activity prior to the most recent seismic event alorg that fault.

. d. Precisely why is it difficult to determire and verify the degree of' activity of such faulisi Farticularb address why such deterniration l

is di'ficult in this case but has been accompi sned in. other reactor proceedings.

e. Precisely why is it difficult to determine the potential damage that car occur to the reactor or reactor building from such faults?

Again, particularly address why. such determination has been possible in i other reactor proceedirgs.

f. Please provide all aralyses perforned by 3taff in an attempt to "deternine ard verify the degree of activity of such faults and the potential danare that can occur to the reactor or reactor buildirg" and irdicate l

ubat difficulties were encountered ir perfornirg such aralyses.

! g. Please shou kr calculation ard reference the shape of the acceleregram l

of the 33E at this site, the naximun grourd notion (ir each direction) l associated with it, ard the response spectra of the reactor and the reactor

j. building in such a 33E.

j h. Please provide all reunark-type analyses perfer:ed for this site.

i. 'ihat is the maximum acceleration the reactor core is capable of sustaining without damage in the east-west. north-south, and vertical directions?

l j. 'ihat is the specific potential event at the prircipal capable -

j fault uhich limits reactor design at the UCLA site?

k. What is the strain erergy release on that fault which is the liciti g condition for reactor design at the UCLA site?

1. What is the acceleregran that would te associated with the event

, identified in 135j above?

m. 'ihat datage related to the 1971 earthquake was Applicant referrirg I to ir its 1976 and 1977 Anrual (Specialized Activity)'3eports?

r. " hat other seisnica'ly-related damage is Staff aware of for'the i reactor?'

i

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

136. JE3 states: "In oorder to circunvent these facters, the staff ottaired 4 laboratory analyses of the inpacts of earthquake induced ccre dis ; tion er Argonaut-type reactors. "

a. Cid Staff specifically recuest dose estirates and/or fission product release estimates ir case of earthauake-irduced fracturing of the fuel?

b. Precisely where in each stut v can such estimates be fourA?

c. Los Alanos study deals with :ne earthquake effect--reduction cf 9 coolirg to plates follouirg scram; 3attelle study considers briefly changes in core geometry, with arother consideratien aof flooiirg, and i

elsewhere a consideratior of reactivity accidents, fire, and chemical reactions, each considered serarately. Please provide all analyses of fission product release are dose estimates concequential to an accident initiated by earthquake but 4hich resulted in an occurrence which combined two er nere of the effects the lateratory studies analyzed sirgly. For exanple, reductier in coolics follouirg a tecperature rise caused by earthquake-induced reactivity insertion. Please provide all analyses performed by er for itaff cf such connon-node events; i.e. the possible per=utations  !

cf. two or more everts caused by same initiating event (earthquake).

329 n. 3-1 ,

137. Please provide all facts ycu can produce that support the statement that the reacter is "in auell drained locatict."

,i 13 . a ' Aster's thesis prepared by Richard Lee Rud=ar entitled "3imulation of Earthquake-Induced Vibrations in a UCIA Feactor Fuel 3urdle" dated 196C refers to tre Cctober 1966 vibration tests of producing accelerations of a naximum of .01 g rather than the .lg reported in the JER. Please irdicate which is the correct figure and show all facts you can produce to support that answer.

130 Please show, by calculation and reference (including page d and

~

paragraph) the extrapolation that produces accelerations of .5g.

I 140. *n' hat analysis has Staff performed to verify the Applicant's conclusions l

fron the "out-of-core fuel element vibration tests"? In particular, i.

what analysis has Staff undertaken as to the effects of pcuer escillations i in conjunction uith other seismically induced reactor effects? Please show said analyses.

141. Oces 3taff consider the Uniform Euilding code in effect at the l --

time of the reactor's construction to include design considerations or seisnic forces adeauate for construction of a reactor in the Los Ang 'es I region today? Elease show all "RC guides or other documents that indicate adequate seismic design for reactor construction in seisnically-active re61ons can be met by following the guidelines of the 1959 Uniforn 3uildire

. Code. I 142. SIR states: "According to the infornation in the application, reither the reactor facility or other campus structures sufferrd any structural damage due to the severe earthquakes in 1952 and 1971."

a. Descrite all efforts made by Staff to ascertain the accuracy of the information from the Application cited above and provide all independent I

information obtain t/-Staff.

t I  :

?

b. That was the ground notion associated with the 1952 and 1971 ,

earthquakes at the reactor site?

c. Uhere were the epicentera of said earthouakes and 31chtec scale nagritud e? -

d. What fraction ef the maximum ground notion acce ' ration ossible at the reactor site, given the varicus faults rearby, were repren.nted by the zrcund notion associated.at the reactor site in the 1952 and 1971 earthc uakes.

$ERn. 1-2 142. Precisely where (by pace number and paragraph) in each of the tuo

laboratory studies perforned for the Connission is there an evaluation of the potential danage to the UCLA core 'ron a hypothetical earthquake that causes the reactor structure to e ,11anse orto the core?

143. Provide all analyses of the effects if the building structure above the reactor room fell onto the reactor and crushed the core.

i 144. 'Jera .ny buildings built according to pre-1)60 Uniforn 3uildirg Codes damaged during the 1971 earthquake? Please indicate how many such buildings and the source of the facts which the answer is based upon.

145. Precisely, by page number and paragraph, for both laboratory studies.

where is the analyses that indicates " fission product concentrations and i deses significantly less than 10 CF3 Part 100 guidelires for pcwer reactors and probably within 10 CFR Part 20 li-its."?

146. Precisely which 10 CPR 20 linits--occupaticnal exposure limits, or for the general public?

147. 3E3 atates the studies were based on " equilibrium inventory of fissi on products. " Flease indicate, for 100 ka operation, the invertory naxinally possible under those assunptions:

a. total fission product inventory

b. inventory total for the principal cesiuns and strontiuns (by each isotope)

c. total noble gas inventogt_

d. total volatile inventory

e. total nonvalatile inventory

f. total alkaline earths

g. total noble netals

h. total rare earths

1. total refractory exides J. individually, for each of the principal isotcpes of Xe, Kr, 3r, Pu, Te, Ea, Ce

k. for I-131,132,133, l'. 4,135 SEP n. 1-3 148. Please indicate the analysis undertaken by Staff to determine the adequacy of the control rod systen as a whole and its respective parts, 149. Please irdicate all control rod systen problems or problens of the control rod systen parts of which Staff is aware, by date of event, nature, and cause. Furthernere, please indicate whether Staff considers these problems to evide.ce control blade systen unreliability: if not, please provide all facts you can produce to indicate systen is not unreliable.

323 n. 4-1 1c0. Please provide all facts Staff can produce to indicate that the UCLA reacter is indeed a "r: search reactor." .

Icl. Please indicate whether the najority of neutron activation analysis

. perferned by the UCIA reactor is connercial, i.e. done for connercial firns.

152. Please provido all facts 3taff can produce to shcw that the neutron activation analysis perforced at the UCIA reactor is either i research cr education.

32P r, h-3 173 Please show by ptge nunter, paragraph, and reference hou the basic Argeraut reacter design was based en 3PER2/3CRAX destructive testing when the SPERT destructive tests did not occur until the earP. sixties.

154. 'Jhich of the five Argenaut reactors in the U.3. is not currently being reviewed for license renewal, and for what reasen?

155. Please identify with specificity, and where possible, by page nuuber and reference, the " latest nathenatical nodels" referred to in the 322 sentence beginning "Since four of the five cxisting. . ."

! If6. The 3attelle study a k/k at roon tenperature (ppears to Intervenor to assume that 2.3% deltath when the water 1: coola2r than nornal and thus, to be conservative, assuned that Argonaut reacters limited to 2.35 delta k/k could actually achieve 2.6d insertion under certain temperature conditions. Under j

current licensed limit, can UCLA reactor hava 2.65 available under lou tenperature conditions? Flease explain.

157. 3atte11e study on page 21 indicates "3ased on the estinated peak tenperature produced in- the 3F227 I destructive test, the fuel hot spot would be approxinately 590cc..." Yet 3ER asserts the study showed maxinun tenperatures "of approximately 4630C." Flease explain the discrepancy, i 1f 8. Please indicate by page nunter and paragraph where in reports cf the 3CRAX tests it is indicated that there was "no fuel or cladding nelting fren an instantaneous reactivity insertion of $3 90." Flease indicate said 3CRAX reports by date, author and title.

, 159. Please indicate the largest dollar and cent reactivity insertion

! during the 3CRAX tests that did not cause fuel or cladding nelting; give reference and page number.

160. Please indicate by precise section number what part of the Technical

• Specifications linits positive reactivity to a maximun $.29. Indicate also whether that is limit for single irradiation port or for conbined ucrth of experinents if the forter, please give the contined worth limit.

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

,_,,m._...- _ _ . _ - . , _ . _ _ _ . - , ,,.m . . . - _ , , ,. . , _ , . _ . , . . . . . . , _ _ _ , _ , _ ,

ST3 n. 4 h 161. Is the negative reactivity linit cited by the SER (-30.92) for single ports or contined worth of experinents? If the former, please give the cochired worth limit.

162. If the " excess reactivity in the reactor will not pose a threat to 4

the rublic," uhy is Staff proposing to lower .the excess reactivity linit?

i 163. Please shcu, Mr calculation and reference, all facts Staff can show as to the 1cuest level of excess reactivity sufficient for- this reactor.

r 164. Are flannable naterials permitted to 'ce irradiated in the reactor, according to the Technical Specifications?

165. What analysis has been performed by 3taff as to the propriety of permitting or not permitting the irradiation of potentially flannable substances? Please provide all said analyses.

166. SER states: "the proposed Te chnical 3pecifications limit the total excess reactivity to $3 00." Intervenor sees no requirenent as to the tenperature at which that reactivity limit is to be deternined,

a. Is that $3 00 at roon temperature?

b. If at some other. tenperature, what temperature?

c. If at room tenperature, is it not possible that at a louer temperature i

the actual excess reactivity could be 33 54 or so?

' d. If the answer to e above is negative, please provide, .by calculation and reference, all factsyou can produce to support your answer.

167. Intervenor_ has before it proposed Technical Specifications by Applicant, contained in Application for license' renewal, and proposed Technical 3pecifications by 3taff, contained in the SER. Please explain the relationship of the two documents one to the other and in the licensing proceedings.

I 168. The linitationof $3.00 proposed represents a linit on installed reactivity or total that can ever be in the core at any one tine?

a. If the former, could not more than $3.00 be in care through insertion of a positive worth sanple?

I i 169. Specifically uhat reports of the 2CRAX/3?ERT Tests were reviewed by Staff in making the conclusions stated at 4-4.17 Flease give title,

, author, and date.

l 3E3 v. h-S i

l i 170. How rapidly is the core water completely drained?

171. What nalfunctions of the core water dung valve is 3taff aware of?

l Flease identify each incident by date, nature and cause of incident.

172. Please provide all analyses performed by 3taff of failure nodes for i

the dump valve and possible consecuences thereto.

i f Jgy. Please provide all analyses performed by Staff of failure nodes the control blade systen and possible consequences thereto.

f L

9 323 n. c-1 17h. Please descrite all tests that have been done, f year. to deternine that the dunp valve and the rupture disk cperate properly.

175. Do the fuel toxes have deflector plates, as described in the 1960 Earards Analysis, to prevent water fron fallirg back into the fuel boxes '

If not, why not?

176. Explain whf Jtaff concludes these systens are adequate to assure safe operation given the partial opcning of the dunp valve due to pressure loss and the potential for reactivity accidents caused ti sudden closing of the valve after such a partial openirg.

177. Descrite the adequacy and sensitivity and operating history of the radiation tank which nonitors the retention tank and indicate why staff feelu that detectcr is adequate for preventing inadvertent releaae ,

of radicactive naterial to the sanitary sewer.

3E' n. 4-1 179 Precisely what does Staff nean by "confinenent," in what "EC docunents (ard page) is "confinenert" defined, and what standards exist to neasure adequacy of such confinenent for reactor effluents?

179. Is shutdour of ventilation fans. closinc of danpers, and scranning of reactor all autenatic when high radiationis detected er pcuer lost, or do any of these actions require human action? If hunan action required, please identify specifically.

l?0. The ventilation systen is shutdcun by shuttinC cff what nechanists?

I'1. Eith bay ventilaticn intake fans take in air fren what air source 7 iP2. Is there a fan or air renoval systen in the reacter structure (core and biological shielding) to remove Argen-contaninated air fron inside the biolcgical shield to be vented through the exhaust stack? If so, where is that fan er systea located and what is its capacity?

1P3. Is nerative pressure naintaired in the reactor reon at all tires?

If not, when is it rot so naintained?

194. Uhat is the efficiency of the danpers; i.e. what leak rate is there?

I c. 'Jhat failures cf the ventilation systen is Staff aware of?

1F6. In event of high radiation bein6 detected and shutdown of ventilation fans in reactor roon and closing of danpers, uhat is the leak rate of contanirated air out of the reactor rocn, and what pathways does it take?

Frovide all data, facts, and references upcn which this answer is based.

17. Precisely where is the radiation nor:itor located which initiates the autonatic actions cutlined at the bctton of dEP. p. 6-1? 'Ihat is its trip point; how of ten calibrated; how of ten is the entire systen checked or tested?

1C . Is the scran and reactor room fan shutdown nochanism set to initiate action when airflow fron the exhaust stack goes below 14,000C7l:?

If so, at what C7h level is it set to initiate such action?

109. Precisely where are the dampers located--precisely where in exhaust systen?

190. From the 8th floor of the ventilation duct carryirc reactor exhaust air to the exhaust stack, dcun to the reactor room, please indicate any ard all obstructions (gratings, etc. ) within the duct, including their location and composition.

101. What is the leak rate fron reactor roon exhaust air betueen the point it leaves the reactor roon and the time it is exhausted out of the exhaust stack (i.e. of x curies of Argen-41 produced in reactor room, what percent of x does not get exhausted from the top of the 8th ficor)?

a. precisely where do those leaks occur?

b. what is the ganna dose to the public from the effluent as it passec through the ventilation duct on its way to the eight floor stack? c

c. please provide all data, calculations, readings, and references upon which answers to the above questions are based.

SEP r. 6-2 192. Precisely descrite the airflow (where it cones fron, where it goes to, and the quantity of air present at any one time) involved in air convection

• coolirg of the fuel elements after the dump valve has drained the water into the dump tank.

193. When air pressure is recoved from the dump val's, does some air flow continue from the source of that air pressure after the core has been drained?

194. What is the source of air pressure for the dump valve, and what is the capacity of the.t source (total volume of air contained, at what pressure)?

Is it indeed air?

195. Precisely where is the dump valve located, and prec'.sely where is the air pressure source?

196. What is the maxinum fuel neat temperature during operation; provide all facts, data, and references upon which answer is based.

197. Is the core water always dumped during a scran? If not, under which corditions is it dumped and which not?

-196. At the end of the' day, is the core water always drained from the cere?

Please explain.

-2.

Ic9. What is the procedure to be followed in case of fire--scran through '

insertion of control blades and dunpirg of water, or is water to be left in :he core to protect the fuel fron the, fire? Please previde the _

detailed procedure in such a case, and all docunents identifyin6 such precedures.

200. What is the procedure to be followed in case of fire while the reactor is abutdcun (control ' lades inserted)--is water to be added to core for fire protection? Please provide all procedures.

201. Did the UCLA reactor have an energency core cooling systen when it ran at 5C0 ku? If not, why didn't the Connission require such a system at that tine, 6 ven 1 the conclusiens of the los Alanos study that loss of air convection at SCO kw can result in fuel neltin6 after shutdown?

202, 3ER states: "Part of the safety of its operaticn depends on rapdily enptyirg the water (coderator) in the core if the reactor scrans shutting down the reactor. " Precisely what precedures are to be followed in caae of. fire in fighting that fire and what fire-fightir6 agent (e.g. water?)

is to be used, and how? Please provide all procedures for dealing with fires, and indicate all analyses by Staff as to how fire should be handled at the UCLA or other Argonaut reactor.

203, 3E3 states. *There is no need for an energency core cooling systen for this reactor sirco fuel te:peratures during operation get up to only 1200-160 '..." Since terperatures during operation are not terperatures during an energency, does 3taff contend that energency core tenperatures cannot exceed 1600F?

204. Please provide all analyses by Staff indicating that core tenperatures in an energency could not reach levels necessitating enercency ecoling for any conbination of possible 1ccident (i.e. power excursion followed by loss of convection cooling by air).

SER n. 7-1 205. SE3 refers to 2 safety channels as well as 1 linear power channel and 1 log 5 and period channel. Elsewhere on sane page 323 refers to the power level instruments as safety channels. Are there 4 different charnels, or is the linear device and the Icg device the two safety channels referred to? Please expalin.

206. The 4 rod position channels--is that one channel per rod, or is there redundancy?

207. Is there one primary coolant fleu channel and one secondary coolant flou channel, or are there two of each?

208. Is only cne core level indicator necessary for operation?

209. Please descrite all inhibits or interlecks.or scram features that would prohibit-insertion of a -2 31 delta k/k worth sanple in the reactor while the control blades are inserted, slow withdrauc1 of said blades to bring reactor up to power, and then renoval of said sanple without first re-inserting the control blades.

- , 210. *lhat analysis has 3taff dene, and what facts acquired, as to the operasing . history, naintenance, and nalfuretion record of the channels,

- safety furetions, and inhibit, interlock and scran systens? Flease indicate each malfunction as to nature and cause of which Staff is auare.

! 211. Tlease indicate which of the inhibits, interlocks and scran

]

systens can be by-passed, and how. ,

212. Please indicate whether any of said inhibits, interlocks. or scrats svatens have been by-passed.

213. Please indicate whether Applicant has. ever irappropriately by-passed 1

said systers ard, if so, when, which systen, and what was the result.

3ER p. 74 214. !f an inhibit condition arises, can it be cleared, permittind f

operation to continue, without resolving problem that caused the inhibits e.g. , is there an irhibit override nechanism that pernits the inhibit to be cleared without actually resolving the cause of the inhibit?

Ze specific as to all such override nechanisms or situations where such override can cccur.

215. When was the control rod-drive-dswn response added to the inhibit?

21c. iculd the inhibit at period less- than o see and scran Lat less than 3 seconds be able to operate fast enough to prevent a power excursion if the excess reactivity were inserted rapi,3y and were sufficient to cause a period

, in- the nillisecond range? Please provide all calculations and facts to i support your answer, j.

SER u. 7-5 1

217. What investigation has Staff undertaken to assure that the types of instrumentation at the UCLA facility are capable currently and during the next twenty years of performing their functions reliably? Flease indicate-l all' facts acquired through said investigation as to the reliability of I. . said instrunentatien.

l l Sc? v. A-1 l

!- 219. Does the reactor facility have no ensite energency power systen whatsoever,

! even for key or limited uses? If it does' have sone limited backup power systens,

, please indicate the nature of said systens and for what instrunentation.

(

! 219. In case of an energency situation involving less of power and- need l

to enter reactor room, what li hting 6 would be available?

220. "ow nuch air (in volune) is contained in the core 'and in the reactor structure inside the biological shield at any one . tine, and what is the flow rate (via natural air convection) of that air?

SER p. c.1 221. Are the fuel plates stored in one or two cabinets?

}

223. What are the dimensicrs (internal) of the cabinet (s)?

224. New nary drawers are there per cabinet?

22<. '4 hat is the nake and nedel of the criticality alarn, precisely ubere is it placed, hcw often is it calitrated and tested, has it ever failed such tests, ard what is its " trip point?"

226. What is the criticality alarn's power source in case of the nernal power systen to the reactor facility failing?

227. What is the spacing between plates in the cabinet drawers?

228. Were the cabinet (s) to be filled with water, what is the probability of a criticality incident occuring? please provide all calculations.

229. Is there a sprinkler systen above the cabinet or nearby?

230. Are there tarks of water, or heavy water nearby? If se, what volute

of water or heavy water to thet contain.

231. Uould flooding the filirg cabinet with heavy water produce a chance of accidental criticality? What probability?

1 232. Has flooding (from piping, water tanks, or other causes) ever occurred in the area where the fuel is kept? Please describe each such incident.

233. Is the cadmiun linirg of each drawer's botton renovable?

233. 'that rating of fire resistance is there for the cabinet?

234. Uhat is the neltirg tenperature of the material of which the cabinet is nade? -

235. Vere a fire to take place around the file cabinet, reaching the nelting point of cadmium, could the cadnium in nolten forn ucrk its way (or dripj out of the drawers to the botton of the cabiret?

a. if so, what is the probability of criticality were firefighters then to flood the area with water?

i 236. What is the thickness of the shielding on top of the storace holes and storage pit for irradiated fuel? Uhat is the shielding ade of?

237. What is the dose rate at the surface of a fuel plate (naxinun) while in the reacter core?

239. Uhat is the naximum dose rate at the surface of a fuel plate af ter renoval from the core?

239. 'Jhat is the maximun dese rate on top of the irradiated fuel hole wi th an irradiated elenent stored inside at its " hottest" possible level?

Please provide all data, and calculations upon which answers 237-239 are based.

. . _ _ . __ _ . _ . ~ _ _ .

4 240. What is the nininan dose rate at 3 feet urshielded from irradiated fuel that has been stored at the facility (i.e. of irradiated fuel stored at "CLA during the license period, what is the mininun dose rate for that fuel at any poirt during that period)?

241. What is the 1cuest dose rate at 3 feet, under ':RC regulations and *

"UCLA's proposed Technical 3pecifications, of irradiated fuel that car be pernitted to be stored on site? (i.e. UCLA is not pernitted to have on site irradiated fuel of less than x dose rate at 3 feet unshielded).

Please indicate which regulation or specification makes such a requirenent.

242, 7 hat is cenpressed air used for at the facility?

243 Is the back-up conpressor autonatically turred on when compressed air pressure from the general supply drops, or does this require nanual intervention? If not autenatic, please indicate how personnel knou of l

l drop in pressure, at .uhat level of drop they are nade aware, and uhat i

must be done to switch to the back-up conpressor.

c44. Please complete the last sentence on this page from the phrase "the o'Jher inhabited" to the beginning of next page "is a safety feature".

(pages 9-1 to 9-2).

353 v. 0-2 24". 3E3 refers to " periodic inspections" to insure there is little flannable raterial available for a fire.

a. '1ho perferns these inspections _

b. Ecu of ter. have they been perforned, at what interval.

c. If referrinc to fire inspections, please -idertify all irspection i reports of which Staff is awarq.

4 246. How nany fire extinguishers are there in the .:EL facility, at j uhat locations, and of- what type? .

l 247. Please identify the Fire C11efs who have been nade familiar with s-,

n 1

24P. In the event of fire on weekends or at night when no health physicist

' is present, uhat are the instructions to fire fighters as to whether to proceed irto reactor roon to fight a fire? What are the fire departnents policies regardirg fightirg a reactor fire? Yhat written precedures 2 exist for fi htirg 6 a' fire at* the UCLA reactor?

240 Is uater to be used to fight a fire which involves the UClA reactor?-

i 250. " hat instruction has the Fire Eept. received regardirr possibic

! reactivity insertion kf, flooding the reactor?'

l 2(1. h* hat " lessons learned" from the '.lindscale fire have been applied to preparations for fighting a fire at UClA? Where car those " lessons learned" be found in docunentary forn?

2c2. Did TT.0 3taff contact local fire chiefs and watch connanders to deternine adequacy of their fire response? If so, please indicate u

p[.ich one nsgggif}ic er andindividuals uere sothrough the facts obtained contacted said(by nane, address and contact.

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

- , 2f3. What instructions do the fire departments have, and uhat is their policy. regarding uhat radiation level is ecrsidered too high.for then to send their fire-fighters into an area involved with flate?

2ch. 5* hat radiation detection equipment do the fire departnents have and_would tring in case of reactor fire?

255. 7ere the nearby fire departtents to receive a report of a fire enrulfirs much of 3oelter Hall, do they have a fornal policy of goinc first to the reactor?

2c6. 'that are the probabilities of a netal-water reacticn should water be used in fighting a reacter fire that had produced nelt3"- of the fuel cladding and fuel itself?

257. How nary hcurs of bur-ing wculd be required, startiny from a buildinc fire, to reach fuel nelting, tamperatures? Frovide all calculati.'ns, data and references.

25C. Oces the UCLA reacter roon have a fire-fighting sprinkler systen?

If sc. what arount of water would be sprayed en the reactor per minute were those sprinklers turned on?

'2f9. Oces UCLA have an overhead deluge er fcan systen for its reacter?

If :res, please give the specifications. ,

260. 3atte11e study, p. 43, indicates a graphite fire would- prcduce heat but little' stoke. The Staff proposal for installation of smoke detectors in the reactor roon does not indicate the level of snoke necessary for activation of the systen--please provide said infernation and indicate whether a graphite' fire, with air exhausted through ventilation systen, could burr for any extended time uithcut producing enough smoke to set off alarn. If so, how long?

261.71 ease indicate all snall fires or explosions of which Staff is aware that have occurred (a) in the Nuclear 2nergy lab, and (b) in 3celter hall sirce the reaotor was built. Please indicate also what efforts Staff has nade to determine frequency cf such fires or explosiors.

323 p. 10-1

?$2. Does Staff consi.'er the TEL's neutron activation analysis activities for Dr. Kalil's uraniu.a ore assaying conpany part of the (JCIA reactor's -

" experimental progran"? If so, please indicate precisely what is experinental about said activity.

263. '4 hat is the pneunatic tube made of (composition) in the reactor core regior?

l 264. Ecw rapidly (in nsec) does the pneunatic tube insert ar.d withdraw sanples fron the core region?

265. '.' hat is the naximum reactivity worth of a sanple that can to pneunatically e inserted that is th rsically capable of being inserted in the reactor?

. 3:' . '1-1 266. Is the threshhold of sensitivity of the :'EL nonitoring capability sufficient to deternine the 10 I'3 20 discharge levels are net before discharre to the seuer? Please irdicate the nunerical sensitivity of said s" sten (s).

267. Ecu nuen air (in volune) leaks into the core regicn per heur7 SER m. 12-2 -

26?. 3Z3 states that the naxinun alleuable discharge of Ar-41 from the reactor stack is 1.65 x 10-5 u C1/cc. "If that value is exceeded, the alarn rings at 1.3 x 10-f y C1/cc and the operator shuts down the reactor or the vertilation systen." Please explain what is neant by say'.ng if 1.65 is exceeded, the alarn rings at 1.8?

260 Meu cf ten is the alarn tested?

270. Where precisely in the exhaust stack cr elsewhere is the nonitor placed?

271. 'Jhat is the maxinum concentration of 1.igen-41 determined in tne last five rears to be enitted from the exhaust stack?

272 ilat is the current, nost conservative estinate of Argon-41 concentration at the point of emission?

273. Oces this estinats include correction (upward) for the 37' discrepancy deternined. by UCLA te:seen Frab camples and stack ioniter?

o 274. Eces this estinate include correction (upward) for the drop over tine roted by UCIA in its Argon concentration readings?

275. If answer to either 273 or 274 above is negative, please explain.

276. What is the error bar that should be given to the figure provided in arsuer to 272, and en what basis (including all calculations and data) is that judgnent made?

277. Eas the alarn settine been a2tered sf :e the discovery cf either discrepancy (described in 273 and 274)? If so, what is the current alarn point?

SE3 n, 11-3 278. How cften are the alarns described at this page tested? Is there an indicator light or other device to alert centrol roon operator that the alarn er the radiation nonitor or the connection tetueen then is not working?

279. Does the Exhaust Duct Fcnitor autenatically shut down ventilation fan, close autonatic danper and scran reactor; or does it nerely anrunciate at the contr-1 panel indicating to anyone there to shut down the fan, which initiates the other actions?

4

2CO. Is it correct that Anendnent 10 to the license provided for a reduction factor for Argon-41 concentratio" of 460, composed of a power use .cetor (10.S'), occupancy factor (10 ~) and dilutien factor ( 115)? If not ccrrect, please specify specifically what aspects of that statement are not correct.

291. Amendnent 10 to the license also randated that the licensee repart to. the connission any change that would- cffect thPt reduction factor--

is that not correct? If not correct, please specify what did occur.

292. UCIA has since reported to the Connission an increase in occupancy factor--is that true? If so, please indicate what increase there has teen repcrted. If not, pleaso indicate what is urcrg with the statement.

353 n. 11-4 s 2C3. In what directions do the norning winds blow? ,

2 h. When 3E? states that thu ventilatien intake on the Ihth Science building is "about the san? elevation" from the discharce of the exhaust stack,

precisely how nuch higher or lower is it?

2ec. Staff states that "UCLA aas required to inplenent a two year environnental survey progran as part of the requirenents of Anendnent

1. 10 to corroborate the estinated doses." Since the 3ER later sa.w that the values obtained,are incorrect, is not UCLA then not in conpliance with A endnent 10 for failing to have corroborated the estinated doses?

If not please explain with specificity why not.

] 2 6. Please indicate why the Pauley Pavilien TLD (on campus, out cf nrevailiny wind nattern) consistently showed a lower dese rate than either the contr'o1 TLD placed in Sunnyvale (400 miles north of canpus) and in Culver City (roughly five niles south cf campus) and yet uas not used as the control. Hou would use of that control numerically alter the readings?

2??. Why is the failure to shield the TLDs not an indication of inadequate

! radiation monitoring practices?

2?e. What hard dato, actual readings, does Staff posuess to indicate to it that the values from the TLEs are "nuch greater than actual exposure fre n the Ar-41"' 'That neasurements has 3ta#f undertaken to deternine the contribution from brick and concrete parts of the 3celter structure?

21 ease provide all facts, readings, and other data that Staff ein produce to support its clain that UCLA's TLD readings are " incorrect" and probably much. greater than the actual exposure fron the Argon-41?

289. Please show by calculation and reference how a TLD readinc h4 nr/yr durirg the T study, when " adjusted for maxinun permitted operating schedules, would becone 90 nr/yr. ,

290. What is the beta dose at the stack?

s i

-*-W y p ep- , --e - --ww---- p- wy .--p- -+t 9-

-- v -.--~_.--y p-w- , .y - , , , , . , -cw%q e yc ,-3

--w9

.- - .. _ ~

t TD ,, 11-5 e

291. Cn what tasis dces 3ta'f estinate peak concentrations of 1.65 x loL?

292. Tees 3taff have any infornation indicating peak concentrations higher?

I? so, please provide said informtion.

293. 3'.'3 irdicates F1 cperating factor stipulated in the Technical Jpecifications.

Arerdnent 10 d&rined the operating factor to be 1".P '. Please indicate wh:r the use of the 5T figure is not a violation of Amendrent 10 conditions.

29h. At uhat distance ard uhat point is netecrological dilution facter

' estirated to be h.67 x-10N ? Is this average " actor over a year of I

different vec.bber patters?

295. Aside from the Rubin thesis,3 on what basis did Staff deternine the runerical value of 4.67 x 10- it is now using? J1 ease provide all data and measurenents taken.

! 296. Frecisely uhere in 10 CFR 20 does Staff get the 15f dese c rrection factor (10 CF3 20, with unspecified section, is given as reference)?

217 On uhat basis does Staff assert that dose correction factors valid in ic?4 for the chimney of the Harwell Iile (3EFC) are valid for the "CI.A roof conditions, neteorology, and exhaust stack systen? Please provide all facts, by m1culation and reference, that indicate that is a valid assumption.

29N. Is either the dilution facter or the dose correction factor based en data from facilities where exhausted a*.r was hotter than anbient i when exhausted? If yes, please indicate specifically uhich factor was so l Insed and how staff corrected for the difference.

299. How did Staff correct for the fact that the roof top concentration nay be icwer than concentration sone distance on tcp of roof, which could also be 6 ving 1 a gamm dose?

l 300. L' hat actual radiation measurenents does 3taff possess or is 5taff l aware o' that indicate exposure due to Ar-41 at the ventilation-intake is lessthan.2nr/yr? Flease provide.all actual measurenents of radiation that so indicate.

3ER p. 11-7 L 301. Please indicate precisely how the meteorological dilution factor l was arrived at b:t Staff, 1

i 302. Aside fron the Rubin study, please indicate how smoke release studies l

provided nunerical verification of the dilution factor.

i l

I I

l

. \

303. , Staff irdicates calculations by the UC1A netecrology department verify the dilution factor. "The only contribution by the neteorology departnent !ntervenor can fird in the referenced iten is an essay

"~'he Ton-3uoyant 3ent-Cver ?_une" in which no calculatic s of corcentration at 'the point in question can be found by Intervenor. Please indicate

b. r page and paragraph where in that work such calculations can be fcund.

304. Yas it 3taff's inpression that the text _ of UC1A's answer to Questler.

P was by Eeteorology Professor Vurtele in 353 Ref. 6?

30?. That analysis did Staff undertake of the nodels proposed by Frofessor Wurtele, particularly the statenent on pare 3, '*Thus, in tnis exarple this simple theory says that either (1) the air intake is within the plune, in which case it is receiving a high concentration, er (2) it is outside the plune and receives a concentration of sero."?

SE3 c. 12-1 306. Please show by calculation and reference hou .04 t .03 nren/ hour represents background radiation in los Angeles.

307. Is the assertion that levels of direction radiation in this uncontrolled area are not detectable above background by calibr.',ed meters during full power reactor operation based on ceasurements by Staff or on Applicant's neasurenents alone? If neasurements have been undertaken by Staff, pleaso provide the readings and the records thereto.

309. Did Staff review the avnual rad *ation surveys prior to taking this assertion or nerely accepted the statenent by Applicant?

3C9. If Staff reviewed Applicant's data, did Staff note any readings above this " background" level in uncontrolled areas? If so, please identi#y said readirgs.

310. What is the rE!. nun dose (beta, gatra, and neutron individually) to persons employed in the Engineerirg 3uildirg snack bar on the third floor of 3celter Ea11'above the reactor?

311. What is the raximm person-ren integrated figure for neutron, ganna, and beta exposure in that snack tar since it was built?

312. Provide all calculations, data, aEd references upon which ansuer 310 ard 311 were based.

313. Uhat is the taximun readirg (" hot spot") on the fifth floor above the reactor.

314. What is the naxinun person-ren exposure to the'public fron walking on walkways on 3rd f1ccr surrounding the 3rd floor equiptent roon provide all calculations, data, and references.

315. What facts, including all calculations, data, readings, and references, can Staff provide to denonstrate the adequacy of tne reactor and reactor roon shieldirg in protecting the public fron direct and induced radiation around ard above the reactor?

)

316. Does UCla have EPA filters in the rabbit roor.?

317. Does UCIA have HEFA filters anywhere in its facility? ,

319. If ro O?A filters are at the facility, what facts can Jtaff produce to denorstrate thev are no't needed to comply either uith radiatior protectio" standardfs o* -with ARRA?

319. " hat is the age of the hand-ard-foot counters enployed by UCM at the reactor facility' Oo they enple- vacuun tutas or nore advanced technology?

320. Do visitors routinely wear filn tadces when touring the facility?

If not, are their nanes and ad:iresses routirely recorded to contact then in case significant exposure was later deternired to have occurred?

c *v. 12-?

321. Is 3taff aware of ircidents in which contanination was not detected

- T Applicant? If so, please identify each such inc' dent bj- tine pericd, nature of incident, and cauce.

322. Please provide all data Staff pcssesses indicating that Ccialt-60 cer'aniration is no s present in the TIl high by.

323. Please provide all facts Staf possesse: indicating that Cobalt-60 cortaninaticn has cccurred in the EL high ta . Identify the particular and specific parts of the high bay where the contaninatior took place l l' such contanination has occurred.

[

iE? n. 12-3 324. Please update the chart for 1990 and provide all data dtaff possesses to fill in the period fren 1960 to 1974 32c. Cn what Msis is the visitor dose nade when visitors are rarely tadced? What is the visitor person-ren?

! 326. Please indicate all cases of over-exposure of workers at the UC A reactor during the period 1960- present.

[

327. Intervenor finds to discussion of film tadge prceran at UCLA.

j a. 7 hat is Staff's assessnent of UCIA's practice of nonitorirg its own film badges?

b. 7 hat is the mininun detectibility above background for ganza, .

soft ganna, beta, and neutron filn tadges? Please explain discrepancy between como of Farch 4,19 0, Jack Horner to Walter *.*ecst, stating I hard ganra (greater than 150 kev) mininun as 20 n3, and statenents by UCIA in answer to Staff questions that mininun was 10 nR?

c. What accuracy does Sta#f believe the film badge rendirgs have?

d. What total dose (teta, ganna, neutron, and X-ray) coulri an individual be receivirg and still have the tadges read sero because of their threchholds ,

(for the ncnthly badges)?

! e. Uhat percent of' actual dose fades in a three-north hadge?

f. Where are UCIA's control filn badges kept?

g. " hat has Staff dene to deternine whether the control badres may be pigking up radi tier other than " natural background" and thus skewing the other readings? Please te specific of efforts to nake such a det'ernination.

2.

3E'. 32 irdicates UCLA has aubnitted a draf t enersency plan for revieu tr ite ff.

1) Oces 3taff refer here to the ercrgercy plan certaired in the application?

t? If rc+. ple: ce provide a copy of tne draf t referred to, and all writter cc 7"ricatien there+c. It is Intervenor's understandirg that all such connurication between Staff and .tpplicant is to te served en Irterveror as well.

3EF 9, 11 h 320 Did any of the violations of rules, guidelines, or techrical specificatiens have potential safety significance? I' so, please identify these that di??

3 ?' ,, lh h 330 Please shcw, by refererce and page, all facts to support the statenert that for the netal-water reaction between aluninun and water to cccur requires that the cladding te in the form cf aluninun filings.

331. Please show, by pace and paragrapn, where in the Latte11e study it indicates that the alumininun nust te in the forn cf filirgs to explosively react with water.

332. If the assertioris correct that aluminum filirgs are recessary for explosive retal-water reaction, please explain the existence c' alu;inun-water reaction at 3?:3? and SL-1.

SER ,, 14 <

333. Please shew, by pace ard pararraph precisely where in the latte11e rerort it is irdicated that a chain of :ee events (failure ci experinertal apparatus, building fire, ard the exposure of graphite ticeks to free fleu of air) is recessary for a graphite fire?

o 334.

that it3E3 states poses that ;2 virSmil" it ccrsiders risk Lt the"this scenario UCI.A to (enphasis reactor." te such a rencte added "h.ssibility 3y "vir.ually.no risk" and by reference to a particular scerario, does Staff interd to say that a' a craphite fire at the UCLA reactor cannot te creditly initiated?

b a graphite fire, were it to ?ccur, carrot credibly cause fuel damage?

c Flease show all facts which 3taff could produce, by calculation and reference, to support answers to a and b above.

335. lattelle, p. 26, concludes about nochanical rearrangementef the core and floodirg *0etailed analysis of this accident and its censequences are teycrd the scope of this study."  ?. 25 refers to a "potentially credible" scerario with a secondary external water source causing a nuclear excursion.

Please show, by page and paragraph, precisely on what Staff tases its assertion that the Cattelle aralysis " indicated that the nost severe consequences from these events would be nechanical danage to the core."

i .

3:E m. 14-6 336. Does Iattelle study assune "1C0 irstantaneous release of roble and iodire gases" as JE3 states or rather 107T withir the recoil distance er 2.7 .

337. Precisely what is the dose that ar. ir.dividual would receive at the reacter roon outside wall or in the 3rd floor snack bar over an eight hour period fren direct radiation from exposed fuel given the hatte11e assunptions

'Yout prior history? Please show all calculations and references.

1 i 3E3 n. 1h 9 330 Precisely where in the 3ER (pare 4 and paragraph) dces it show that the

acciderts centioned "would not pose a threat to the health and safety of the ucrkers..."'

i 330, 2attelle study states (p. 26) that the "consequerces from a core-crushirg accident uculd be some cultiple of the corsaquences of the fuel-hardling accident." Yet Staff censiders tha maxinun deses to' the public from any credible accident to te less than what 2attelle considers.for the fuel handling accident. Furthernere, Staff clains its aralysis is based en "extrenely conservative assunptions." Please explain the apparent discrepancy between the Battelle study and the Staff's conclusions in the SER based on said study.

3h0. 3E3 clains that a fire in the reactor reor "would not pose a threat to the health and safety of the workers or the public." Earlier in the .

I SER. Staff clained nerely that a craphite fire could not credibly occur.

Does 3taff clain that such a fire. should it cccur, would not pose a threat 1

to health and safety? If so, please provide all facts and references upon which such a statenent is supported.

i l

341. 3taff also clains that "a severe fuel handling accident irside the reactor roon would not pose a threat to hes3 th and safety." Eas j, 3taff analyzed such an accident occuring outside the reacter roon; if j

so, what are the results of that aralysis?

3ER u. 1h-2 342. On what basis dces 3taff conclude danage to fuel plates uculd cccur as guillotine-type breaks? Yould not gr:ater surface be exposed by non-guillotine-type breaks, and are not guillotice-type breaks far less likely to occur than fractures, splintering, and rough edges?

Fresent all facts and references upon which your answer is based.

SER n. 1h-10 i 343. 2atte11e study assunes the result of dropping a shield block on the core would result in exposures " sone cultiple" of its dose esticates for a #uel handlirg accident. Staff assunes the worst credible earthquake, involving collapse of the superstructure onto the core, would result in doses less than the doses Iattelle postulates for dropping cre of 24 fuel elenen'a on the floor in a fuel-handlire accident. 21 ease explain wht-Staff rejected the results of the .sattelle study and provide all fact's j

upenuhich that conclusion was based.

I

. 3hh. "Thus," says the SE2, "the iodire releases for the severe earthquake danared core are uithin 10 CF2 Fart 20 limits.** The previcus sentence refers to linits for ucrkers. Is 3taff censidering visitors, students, ard faculty at L* CIA radiation ucrkers for determinirc which 10 CF2 20 linits to apply?

3h5. Please explain whr 3taff uses 10 C73 Fart 100 for corparison purycsos.

3E? n. 17-1 346. Please provide all facts and references to support the statenent that "the operators of the UCLA reactor perforn regular preventive naintenance in order to discover potential failures or to preclude the failure of conponents. At appropriate tir.es, conponents with degraded perfor ance are replaced before failure occurs."

347. Please provide all facts and references that indicate Applicant has failed to do appropriate maintenance at the required tine.

3hP. Please indicate, for the fuel currently in the reactor core, and for operation for the next twenty years at the licensed limit cf operation. at what point naxinun fuel plate burn-up would occur; i.c. when, under those conditions, would fuel have to be replaced?

If naxinun turn-up would not have occurred by that tine, please indicate what percent of taxinun would have occurred by year 2000.

349. 'lhat would be the maxinun case at 3 feet urshielded fron fuel at naxinun turn-up a) innediately af ter shutdown, and t) 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> af ter shutdown?

Gereral Yatters 3f0. Flease identify the USC Staffperson(s) who principally answered these interrogatcries or contributed to their ansucring. If specific interrogatories were primarily the work of one person and others the werk of others. please idertify which interrogatories were identf fled by when.

351. If not elsouhere identified herein, please provide the qualificaticrs of the individual (s) who answered said interrogatories.

352. Please indicate the 3taffpersen(s) who did the principal technical

work on the JER and if not elsewhere provitxd, please provide a detailed descriptien of technical qualifications, previous enploynent, educational background, and other relevant data by which to evaluate technical expertise.

353. If not identified in response to 352, please provide the infernation requested therein for Dr. Hal 3ernard. Fast enploynent unrc ated to tec?nical qualifications but which nay be related to potential past associations with licensees in questien should be included if relevant.

354. Please identify by rane, address, and title, any expert uitnesses when 7EC Staff interds to call at hearing, the subjects to which they will address thenselves, the references and calculations they will use cther than these contained in the 4 June reports, their qualifications

-y. .

as experts and any infor= tion such as past c::ployr.cnt or current associatiers other than regulatcry functicca.

355. Frior to thc 3 3 beiri released, the follouirs stater.ent was recorded in ninutes of the Canpus 3adiation Jafety Cornittee at UCJ (Cecenter 15, 1990):

here will be a pu':lic 2eactor lice:sse renewal and 3 ridge the Saq.

hearing (precedent for a teaching reactor on the nuclear reactor.

Jtate 2 card (sic) will tell parties uhat points will be heard at a hearing sometine in the sprinc. At that point T30 uill shi#t fron neutral to support of UCL\. .3 ridge the Cap has 23 iter.s of issue, sone of which will help us to do better.

Please indicate the nature of any conr.unications between :?.C 5'iff a-d staff of the licensee that nay have resulted in licensee's belief that at a certain specified tine ""RC uill shift fren neutral to support of UC*d." Please indicate the da'.e of all such conversations cr connunications ard who the ir-ividuals were who acre involved in said corrunications.

. . . - - .. __ - _ - _ = ~ _ - . . __. --. _ _ _ - . . . --

i IS?CGA?C3'2.1 AS TO Z"/IEC:::0:".'AI. i

I

.?AC' AFF2AT3A'.

i 4

. 1. The ~A variously describes the UCIA reactor as water nederated l (p.1) and as graphite moderated (p.2). Hease clarify. 1

2. 2IA indicates: "The roof of Icelter Hall houses the 14,CCC CT;.

3

.eactor stack and reacter roon exhaust fan, and is a restricted area."

a. precisely what is neant by "a restricted area."

{_ b. p-ecisely what physical neans restrict the area fren public access?

c are there other ventilation intake ard exhaust fans fer tHe 4

reactor roemi if so where are they located exactly?

e l 3. Ela states that C-14 exists in very minute qu?ntitics. Please show tr calculation and reference, and by producing available dr.ta as well, uhat' quantities.of C-14 are produced: I j

a) per year

9 per hour of operation at 100 kw

! ch to date by the facility d) total produced by year 2000 given past operating history and assuming future operation and licensed limit.

1 4. Please show total environmental impact of that aucunt of C-14, given its life-time. How nany person-ren of exposure will that C-14 5 produce before it has decayed away? Show all calculatiens and "eferences.

1-

c. Are there any direct radiation readings en the Eath-3cience building i which, if valid, would contradict Sta'f's calculation of 1.4 cr dese?

l If so, by what factor is there a discrepancy?

l 1

! 6. Applic'. tion and annual radiation surveys indicate canna doses in reactor roon up to 200 re/ hour. Please explain quoted average film bidge reading of 175 nr/yr ard 1200*nr/yr naxinun.

l

! 7. " hat is the neutron dose to people in unexposed areas" Flease present all data and calculations and references to support your amer.

I 0 "as UC1A experienced any contanination problema regarding hich and

. low level wastes that nay have resulted in public radiation exposures?

i If so. please identify each irstance, t

O. Is the low level liquid effluent radiation nonitor capable of detecting b concentrations at less than 10 CFR 20, Appendix 3 linits? Frecisely what is its threshhold and what problens has it encountered that may shed light on its reliability.

10. 3E3 states regarding the los Alanos ard latte11e studies:

"In all cases the aralyses nade on a " worst case" basis, di:1 not result ir releases outside the reactor roon of nore than fractions of the Suidelines l i in 10 CF3 Part 100 for offaite doses, and ...would protably not exceed 10 CTR Part 20 limits." Intervenor can find only one dose esticate related to one accident scenario in either study. Please, by pace nunber and paragraph indicate where the two studies. deternined that the scenarios

! you cite would result in doses probably not in excess of 10 CFR 20.

l

?

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_2-

11. 2recisely uPat in the naxinun credible accident, in Staff's deterniration, at 'he UCIA reactor 7

12. At page e of IIA. Staff refers to cducational ard research objectives and activities perforned by the PCIA reactor. Oces Jtaff corsider reutrcr activatier services for connercial users pa - ^#

+'cce furetions?

If sc. please specify in detail, and produce all facts you can provide to suppert you answer, precisely wh" such activity is research or educatier and rot connercial activity.

13. 2rovide all evidence y.ou car produce to show that the nuclear engineerirr/

physics progran at UCLA uculd be elinitated if the reactor were shutdown and ita functions not transferred elseuhere.

14. Please provide results of all analyses 5taff undertook to deternine feasibility of rot shuttin,- doun the facility but instead converting it irto a sinulater, with no fuel en site but the reactor otherwise presert and perfernirr its teaching functions.

15. UCIA indicated in answer to questions by 2taff that in 1979 only 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> of reactor operatict were devoted to instruction, with sinilar figures for other years. Precisely what is it that nahes "cennuting" necessary if only 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per quarter of reacter use wert to classroon instruction?

15. So any ruelear ergineerire prograns at other colleges travel to UCIA?

Uhat would prevent " field trips" to UC Irvine 'cy the snail instructional activity neu taking place on site?

17. Precisely how nany nuclear enrineering students Ucrrently (during ary quarter of last year) rely en the r eactor for their credit-receiving studies er research? (Ue are not referring to total enr 11nent in the chenical, thernal and nuclear engineering progran, nor to students whose class nay visit the reactor for a denonstration). 21 ease provide 11 facts, data, ard references upon which this ansuer is based.

19. Staff refers (p. 6) to " activation of naterials as part of the UCLA curricula." Precisely hos does activation of secs for a connercial jeweler and activation of nining sanples for a contercial assayinc conpany represent part of the "UCLA curricula?"

19. Staff refers er page 6 to "teneficial uses of the reactor" ano g then "contributiens to scientific krouledge." Flease indicate all cortributions to scientific knowledge by the reactor since 1970 of which Staff is aware and which forns the basis for said statenent.

20. Please indicate all scholarly papers published since 1975 tased on research in reactor physics dono Sy the UCLA nuclear engineering departnent reouiring use of the UCLA reactor.

21. As JFL and other non-UCIA users send their sanples to UCLA for activation analysis, what would prevent UCLA users fron sending their sanples to UC Irvine should the UCLA facility cease to exist?

3 2%. Staff states that "!nasnuch as the reacter has teen censtructed ard ir cperation airce 1060 there are virtuall:' no additional capital resources required. " ' Please indicate how nuch norey is expended ir rnintaini*g. cporating, an! upkeep of the reactor per year and how .much would reed to be experded over the rext twenty years if relicensed.

Then please indicate what the reactor cor.struction cost.

23, 21 case irdicate all analysis included in your 3IA as to the environnental inpacts should the tonb-crade uraniun te diver $2d and fall into violent han?s.

2h. Please indicate the environnental inpacts should radiological cabotage take place at this facility.

2c. Please indicate the adequacy of the protection neasures against radiological sabotage.

26. Mou large an area of canpus uculd te centaninated were 57 cf the core fission products to : scape? Please sncu all calculations and refererces.

27. "het ?culd be the effe'et en ground water should $CF of the soluble fissier products centaninate water that reaches the water table?

29. Flease specify. in detail, all alternatives considered b" 3taff to the ecntinued operation of the 'JCLA reactor with fuel on site, all analyses corducted of those alternatives, ard all data acquired thereto.

E9. Preci,ely how did 3taff go about deternining what the alternatives to this reactor are?

30. As' this reac tor is only operated less than 13.R' of the week, and as the licensee has several other, neuer reacters, nore state-of-the art, precisely uhr is it not nere cost-effective to consolidate users and have students who wish to najor in nuclear engineering (the few who do so najcr at 'JCIA) go to a canpus with a neuer facility" "ould not fewer resources te expended? '. culd r.ct risks be reduced?

? ease provide all facts and references you canproduce to support rour answers.

M- ' w e

j I'TERRCONT317 TO 3.C. PAULEY, R.L. MTERE' , A'?D e . A. RC2XI': A3 TC "ANALTSIS CF CRECEIT ACCIDE""3 "O3 A3CCTAUT REAC"'CR3"

] UZIC/C3-2070 FTL-3401 TC 3. C. ? KIST, R.1. M'.C*, A"3 M. A. FC2KI's

1. Your report states that the UTR design was ranufactured by Anerican 4diator and 3tardard 3aritary Corporation and that "all five contenperary i Argonauts in the Unitel States. . .are the UTR nod el." It is our understanding that the UC1A Arronaut reactor was nanufactured by AFF. Flease clarify.

2 feu state that the origiral Argonaut reactor had 2C'. fuel, relatively large negative void and tenperature coefficients, and was only capable of continucus operation at 1 ku because sustained operation above about 1 ku would result in shutdown because of the negative temperature coefficient.

Are these " fail-safe physics paraneters" fourd in greater or lesser neasure at the current UCIA Argonaut' reactor?

3. ?ou state (p.1-3) that past Argonaut safety analyses have been based

• • alnest exclusively en linited experimental data. Hence the scope of these analyscs is quite narrow. To expand ard update these original studies, particularly in the light of nore than twenty years of operating experience and additional research, the Uuclear Regulatory Conmission requested 2atte11e, Eacific "orthuest Laboratory, to take a generic credible accident j analysis of Argonaut-UTR reactors." 2esides the S?ER? destruct test

and ectinates of percent operating tine at existing Argonaut reactors,

! specifically what aspects of the "nore than twenty years of operating experience and additional research" were considered in naking your an? lysis?

i

4. Are there any annular core Argonaut reactors in the United 3tates? ,

If so, please specify which.

I f. Tour study refers to the Argonaut's negative tenperature coefficient.

As the Argonaut is both water and graphite-noderated, as well as graphite- '

reflected, the coefficient for both Secones inportant.- What are the i various tenperature coefficierts at different Arronaut reactors for a) water and b) graphite? Please provide references.

I i

6. Does fraphite, as used in the Argonaut reactor, have a positive tenperature coefficient? Please provide all facts cnd references to support your answer.

7. If so, did you consider that positive coefficient in your analysis;

if so, hou?

P. If it does have a positive coefficient and you did not consider that fact ir your analysis, please irdicate how the analysis would be altered if that fact were considered.

- 9. Zou list a nunber of previous analyses related to excess reactivity insertions. Sone of these analyses appear to contradict the conclusions nade in your analysis. Please indicate, speci 'ically and by reference, what is in error ir each.of these analyses the: leads you to conclude your analysis is correct and theirs is not. In particular, the assunption

< you nake that a 2,6" delta k/k insertion will produce a period of 7 2 tsec.

12 EJs energy release, and naxinun fuel tenperatures of 590 C. 71 ease show study, the) c 1961 flaws ATLyou study, believe a)xist d G"EC in the study, a))ANL e URR study, study, f JA305b))the study, 1959 ATL'

= . . . -- - . - - - . . = .. .-

(

ard g) the UCLi 1960 "azards Analysis, which differs d!ichtly from the 072C report. You need only address why you arrive at different figures for period. erercy release, and naximun fuel tenperatures, but should indicate why your estimates are believed to be the correct and nest sufficiently conservative in contrast to these conpeting analyses.

i

10. You state on page 6 that the GrEC naterial postulated a 10000F

' rise in fuel temperature. It is our urderstanding that what was postulated ,

was an energy release capable of a 1000 tenperature rise above the i

4 saturation tenperature of the water. Please clarify.

l

11. It is our understsnding that the C:TEC naterial deternined that nelting uould occur uith an energy release capable of a 1000*F tenperature rise in addition to the energy recessary to bring the water to saturation, that this was correlated to a energy release of 32 iMs, uhich was deternired through certain relationships between 3crax and different Argonaut reactors, to bearesulted fron a 2.4' insertion (2 3: ' in the UCLA case).

You state that the GTEC naterial stated "that the reactor uculd tolerate -

this anount, ranidly inserted, uithout the fuel or cladding nelting."

(. (erphasisadded). Please explain the apparent contradiction.

i f 12. At page 8 you state: "An a priori calculation of the expected tenperature rise fron the largest possible pulse needs to be perforned and the results l

conpared with the data from the 3FER7 and 3CRAX experinents rather than ,

relyingselely on empirical extrapolations ard interpolations of the sane da ta. " Your analysis, however, appears to te an extrapolation and interpolation i of the SPERT destruct data uitnout conparison with 303AX data or other I data. Please explain.

l

13. Why was " deliberate destruction or similar events -- i.e. sabotage - "

rot considered ir your study?

14. You nahe clear that shock wave phenomenen should be investigated in I

j a future study. '#7 that do you ne.n your study does not conclusively i

determine what is the naximun credible accident for Arconaut-type reactors .

tecause shock wave phenonenen nay produce greater danage than that postulated in the accidants you did investigate? Pleass explain your answer in detail.

Ic. What prevents 20' fuel fron being used in contemporary Argeraut reactors?

l

'lhst nodifications would be necessary to pernit use orce again of 20 ' fuel?

t

16. Is the cadniun sheet used in control blades for current Argonaut reactors (UCLA inparticular) cladded with any other natorial, alloyed with other material, or is it simply a cadmium blade? Flease give details and source of information.

l

17. Is the void coeffictent for the UCLA Argonaut reactor smaller or larger than the void coefficient for the 3FERT?

1D. When-yourefer(p.c)tolargenerativetenperaturecoefficients, f do you refer to the tenperature coefficient of water?

l

19. Fou does the overall tenperature coefficient of the. core change durirr lorg-tern operatien durirc which the graphite warns up?

20. '<That is the tenperature coefficient in the higher.tenperature rarges that could te expected -in a power excursion?

i

. - _ __ . - . .= . .

/ '

_3

21. You stato (p. c) that the 1cnc pronpt rentrer lifetino is largely a furetier of the graphite re'lection. *That other factors affect it?

4 j 22. Oces the pronpt neut'. lifetine charge with tenperature? ' hat .

specific charges take place ?? the range 3Co C - 7CCoC; provide all facts er which you base your answer, including references.

23. Does prorgt nr ,

. lifetine charre during an excess reactivity tesertion of 2.6 ' ir an Argonaut reactor and if so, how does it chan6e; provide all facts and references upon uhich you base your answer.

J

24. Is pronpt reutron lifetine for Argonaut reactors calculated or neasured; please indicate how the calculation or neasurenent is done, and what error bars should be giver to the reported figures for pronpt neutrer

! lifetine.

L l 2f. ?.11 states that the earlier analyses identified naxinun levels of reactivity and "inplicity" those levels that would not cause severe disruption of the core. Please present all facts and references which denonstrate that severe core disruption carrot occur at an Arcoraut reactor without

] neltir.z cf the cladding.

7

26. You state (p.11-12) that the maxinun power and total energy release are a function df the period. Are Shey rot also a functier of the total nunter of e-folding tines prior to shutdown, and thus dependert upon the speed of particular shutdown nechanisns in particular reacters? Please explain your answer and produce all facts that suppcrt it.

27. You state (p.12) that the required review systen for experinents at research reactors uculd nreclude a severe inadvertent chenical explosicn. Please state explicitly what review you have conducted of the adecuacr of said review systens at the UCIA reactor and the results of said aralysis, and all facts upon which it is based.

9

28. Please. by reference and facts, show all supporting information you can produce that aluminun "has to be nolted or finely divided before the exothernic reaction occurs." (p.13) i i

j ?o. You state crpaFe 13 that "the water used to extinguish a fire could lead to stean or other explosive reactiers, includirc the Al-E C 2 reaction. .

Evce coolingof the fire, if sufficiently rapid, nicht lead to contraction and ficxing Of netallic conzonents that night rupture the claddirc and-lead i

to fission product release." We see no analysis of hazards from craphite-fire-fightirg included in the section en such fires; indeed, there appears i

to be an assertion that dancers from such fires are linited by the fact that fire departnents may arrive in time to put out the fire.

Please indicate in detail what hazards -ay exist in the fiChting of a graphite fire at a reactor, what training and precedures nornal firedepartnents rear Argonaut reactors (particularly the UCIA case) have in fighting such fires, what the correct fire fighting technique would be and what incorrect t techniques are possible. Floase also discuss the potential for acciden'.a1

' criticality or reactivity insertion by water-flooding during fire-fighting.

, ~ . - . . - , - e,.e _ ..- . , . . . . _. v v . . , . -_ , ,,, .,..._._.._,n,.

30. At page 16 you refer to positive reactivity irsertions. You assune 100 : cf ratural uraniun; what uculd te the effect of adding 100 g of 93:' enriched urariun in terns Of reactivity additien? 21 ease provide calculatiers ard references where applicable.

31. Are you aware of any pcsitive reactivity effect by partially drainirc the core? If so, please specify,

32. Trecisely why is the "substitutionof heavy water" rot credib137 31ve all facts and references to support your assertion.

33. fou say that "although possitle" partial er cenplete replacenent of the noderator with a superior nederator is "not a credible or feasible accident scenario." ?recisely what do you nean by the difference between sonethirg being possib'e but not feasible er credible? Ard show all data, calculations and references that denonstrate it is not feasible er credible.

34. Are there any other versions of the inheur equation that produce different results in terns of pericd fcr a 2.6 ' delta k/k insertion?

If se, please describe and give the equations and the resulting period.

3<. Your relationship of recip.;ocal period to total energy release is far less conservative than that assuned in several other hazards aralysis. Please provide all facts and references that show your figure to be sufficiently conservative and the figure of choice.

36. If the 202AX data were used instead of the GM data, what total energ" release uoald te associated with a 138 s~l period?

37. If data fren the SI.-l excursior were used instead of the 3?Er de .,

what total energy release uculd to associated with a 139 s-1 period' 3C. Precisely why is the SPEE data to te preferred over 202AX and 31.-1 data; or is it preferred in your analysis?

39. Please show precisely, b:rgiculation and reference, how 12 Ws is assuned to produce 4 x 10~ fissions.

40. ? lease show all facts, by calculation and reference, that suppert your claim that "this calculation raxinun energy release...is not large enouch to produce cere disruption leading to cladding failure."

0

41. On uhat hsis do ;;cu assume (p.12) initial fuel tenp- sture of c0 C.

42. Please explain the large difference (1cu) betueen yi .lculations on page 18 for tenperature rise, based on nodels, a*d irate en pace 19 taced on the 3FEr enpirical data.

43. Ilease explain hcu you deternine 506 C to be 7d be ou the nelting 0 point of the fuel neat, when elsewhere you say neltin6 cccurs at 640 C?

44 UP.C Staff in its calculations assunes an initial fuel temperature of 7 c C. Given the nelting point of the uraniun-alaninun eutectic used in 6

the UC!A reactor, how nuch below the neltirg goint uculd your estinate Msed on 57Er's hot spot be, assuning the 75 C starting tenperature?

4

-5 he. '! hat errer tars should be given in transferring fren the SPEI hot spot to a possible UCLA hot spot? !1 ease provide all calculations and references to support your answer.

46. At what tenperature telcu the nelting point of the neat does the cladding becone ductile and claddin6 failure due to internal pressure terin to occur with this kind of fuel? Please previde all facts and references to support your answer.

47. At what te:perature does volunetric expansien tegin to occur in this particular fuel?

l9 At what level of energy release and period and excess reactivity insertion were claddin6 failures noted at Sorax arx' 0FEr?

4o. At what tenperature can claddirg failures te conservatively expected at UC1A? Please shcu all calculatiors ard references.

0

50. Cn pa7e 19 you refer to the supposed 74 C nargin "telow the celting i point of the fuel neat" as "certainly adequate" as a "nargin of safety. "

In decrees C, what is the nininal nargin of safety given conservative assumptions? Flease provide all facts ycu can to suppcrt your ansuer.

51. If your estinate of 12 :C.'s were not correct, and the C"EC estinate of core than 32 Els were indeed the correct value, what would te the i actual tenporature rise for the hottest part of the fuel? Flease cive all calculations and references, j 52. If your istinate of less than 590 C naximun temperature from 12 ;Ns

! release wzre not the correct ve.lue, and the JA30r estinate of 6-12 !!!s for neltin6 were correct, what would be the taxinun fuel tenperature given the UCIA fuel configuration with a 12 I5s excursion? Please show all calculations ard references. .

j <3. Cn page 21 you state that " core disruption, if any, would be minital."

Flease show all facts that you can produce to deconstrate that that statenent l

is correct for the UCLA reactor confiduration.

f4. Does the UCLA reactor have deflector plates designed to prevert i

repeated criticality from water fallirg back lato core! 21 ease detail arsuer, c5. !! hat is the effect of repeated criticality on your anal" sis of reactivity accidents? Please te specific and provide supporqing data if available.

56. Precisely where in the UCIA 1c90 document referenced at page 22 have i "the effects of catastrophic seismic phenonena" teen " addressed in detail"'

Cive pages runters and document title.

57. State precisely why "no significant effect would result from flooding unless structural rearrangenent of the core also cccurred or the control blades were sonehow prevented from toing inserted into the core."

i

(

I l

t I

k

l cA. 1*ere tie bolts to fail in fuel elenents during nechanical rearrsncecent precisely uhat uculd nakn increased fuel plate spacing ron-credible 7 f9. Ilease show all facts you can produce to show that bcuirc of the fuel plates carrot credibly increase plate spacing.

60. You siate on p. 24 that the decrease in reactivity from floedirg the interstitial graphite spaces "would be nore ".han cffset Mr the ircreas fron the otrer ficoded voids " later you assune Cat the floodirs cf the experinental iteilities facilities uould just offset the negative effect, givinc a 2' plus reactivity. Please show all data that irdicates ar equal conpensation leading to 2M plus reactivity.

61. icu state nini al critical mss is 1.9 kg--is that given slats together. ircreased fuel channel spacing, or both? If not both, what is 1 the critical nass if fuel channel spacirs is optinal and slabs are optinally tecether? Please show calculations.

62. You indicate (p. 2f-6) that "an appreciable fraction of the fuel plates could te danaged and that fission oroduct activity would get into the water. ^etailed analysis of this accident ard its consequences are beyond the secpe of this study. " Zy this do reu nea'n that the fission product j release and public exposure could ;2t be greater than that postulated fo r

the fuel handlirg ircident, could be greater, or that you can nake no determination given the scope of year study. Ze specific and back up ycur answer with all facts you can produce.

63. Table 2 appears to indicate that 13.7' reactivity is the naxinun possible with flooding and rearrangement; you state that it is not credible that perfect rearrangenent and complete ard instantaneous reactivity insertion isn' t credible. 3ut since around 3.C delta k/k scens erough to produce fuel nelting, less than 1/4 o# the mximun available, perfection doesn't seen necessary to create a serious excursion.

Ilease explain why an imperfect excursion is not credible. Provide all facts available to support your answer.

i

64. Given a graphite fire in which graphite in core regicn burns, causing

l. fuel slabs to slunp touards each other and requirirs firefichters to flood core with Uster to prevent fuel nelting, what is the potertial reactivity available? If you believe this scenario to be non-credible,

! produce all facts to support your assertion.

65. You state (p. 25) "Cnly if there were a secondary external water source for the core could this accident te considered potentially credible."

Given firefighting, or earthquake that causes ruptured piping above reactor or other floodingof reactor fren secondary external water source, does rot this statement nean that you consider this accident to be "petentially credible. " Please explain in detail your answer. providing all supporting facts available.

66. P. 26 you aralyze core-crushing accident based on dropping a shield block en core. 'Jhat would be the effects of several stories of building ,

above reactor crashing through reactor ceilirg onto reactor in earthquake or plane crash irduced accident? Please be specific--would that increase censequences over the scenario you analyzed, and by how nuch?

67. You state that the consequences of a cere-crushing accident would be "sene multiple of Jus consequences of the fuel-handling accident."

On uhat basis do you then say in your abstract that "the only credible

accident involving offiste deses was deternined to be a fuel-handling sacident which, giver highly conservative assunptions. culd produce a dhole-tody dose equivalent of 2 ren from noble gas innersion and a

.fetino dose equivalent connitnent to the thyroid of 43 ren from radioiodi" es. " 71 ease give all facts that can tack up your explanation of the aprarent centradiction.

6 . Giver the hirher figures reported on p 27 for various scenarios (s.r. 5.61 for flooding the core air spaces with the blades out),

precisely wh* do you conclude--at least as sunnarized in the abstract--

that such an accident (cr partial accident) is not credible?

60 Do you admit that your aralysis of explosive chemical reactions is dependent upon the precise that cladding nelting cannot occur in the ArForaut?

70. Were aluminun nelting to occur, can you accurately predict that Aluminun-water reaction could not occur? Please explain youranswer.

71. We notice ro analysis of stean explosion. Is this the " shock wave" phenore-on nentioned earlier in the study as needing study elsewhere?

Ficase explain.

72. Could a stean explosion caused during a reactivity irsertion at the Argonaut reactor disperse hot aluminun with enough energy to cause netal-water reaction, even if the nelting tenperature of the aluminun was not reached? Please provide all calculations and references that indicate enough is known to predict that accurately.

73. Your analysis (p. 30) of the argon dilution air flow appears to irdicate that that nochanism provides enough ate flow to begin- a graphite fire were an ignition source available. Is that correct? if not, please explain.

74. Uere a graphite fire to start in a una11 part of the fraphite where air er oxygen was available, is it rot' pessible for the fire, as it progressed, to expose more and nere graphite to air, feeding the fire? Flease explain.

75. You say "if the reactor was otherwise rormally sealed, the graphite temperature would not renain elevated." Flease explain precisely what you n.ean by "otherwice norna11y sealed".

76. Is exhaust fan run only when the reactor is run, er is it run other tines (at the L'CLA reactor in particular).

77. Precisely where in rightingale (or other source) do you find the figure 3 cal /g at 50 C cited on page 37 of your report?

79. Precisely why is it considered non-credible (p. 40) for a large excursion to occur coincident with a large enough spill of organic liquid irside the reacter? Are there no connon-node failures that can occur that would cause both everts? Please provide all . facts you can to support

?our arsuer.

4 t

d 7

q 79. You 3%te that "the varicus events exanined ce far that could centribute to or initiate. a graphite fire are all of low probability. Ecuever,

' iraufficient data is available for quantifying 0;c probabilities."

Zr (a)this do you nean to say a F)raphite fire which ?anages the fuelis certainly rot cred is certainl~

r credible, or (d) credibic, nay not be(bcredible. Please explain your answer ard give all facts fcu can to back it up.

, 00. You or pares.4143 exanine tuo conncn-node scenarios in your.

l discussion of a design basis accident. It is unclear whether.ycu deternine these to te design basis accidents er rot, and u' r at their corseguences would be should they occur. 71 ease clarif/ .-

21. ?. 42 you say that the class would not sof ten and failure would te linited to nochanical causes. That is with an assunption of heatinc.

i one hour of irradiation. Could the glass sof ter if irradiation uere l

loncer than one heur? Ecw long would be required for sof tening?

' 21 ease show calculatiens and references where applienble.

t

92. You say that if the accident occurred while attended, "innediate respy::e by the errerimenters uculd limit the consequenecc."

a. what would te the appropriate response?

' b. what precedures exist at UCLA~ delineating said response?

c. are student experinenters nade faniliar with said. procedures, if the exist?

d. were water to be used to respcnd, what reactivity ecnsequences -

, could ensue'

! e. what would te the effect if response were ot innediate?

l

f. by limited consequences if response were innediate, what consequences j do you nean?

l F. if consequences were not linited by innediate response, what I naxinun consequences could ensue--be specific.

t

( C3. Your surrary at page 43 does not nake clear whether you think the ;raphite fire leading to release of fission products is conpletely nor-credible or uhether there are a number of scenarios uith " sone pctential" fcr such events. Please clarify.

Ph. You say, unless the uhole building were extensively involved, 'it again appears unlikely that enough time would elapse without detectior

- of the fire to pernit ignition of the graphite and . subsequent. fuel nelting.'

a. Are you sayirg that to prevent fuel nelting the building fire nust te detected (e.nd successfully kept fron igniting the graphite)?

Please explain.

b. If the reactor itself caught fire, how should the fire be fought?

c. 'ihat training do fire departnents near reactors hav- for taking such determinatien, and uhat radiation detection equipnent and procedures?

d. What is the potential for the fire burning a consid erable ' tine because of indecision whether to enter the reactor rocu because of radiation (fire at ni6ht or on weekend when health physicist can't be located) or how to fight it?

e. Uhat experience exists from other reacter fires as to hou long they, burn before being controlled? Ilease specify.

f. Eov long would an Argonaut reactor have to be . involved in flanes i for the fu el to be danaged?

g. Could 'a fire from a ruptured gas line in the reactor vicinity, perhaps due to earthquake, ignite the graphite?

-9

24. Tnat is the certainty that a graphite fire would be detected by a sr.oke alarn?

9e. Cn page h3 you sar "the aluninun fuel boxes ard fuel could be at risk for neltin,q."

a. Uhat would te the specific radiological consequences of such an event!

b. Jre you saying such an event could er could_ net cccur? 71 case explain and give all supporting data for your answer.

c6. Herarding p. hh and your assunption of a "scrst case" situation regarding fuel

'r ardling, " involving tuo mutually independent events"--hou nany nutually independent events led to the T E in'.. dent?

W. Please give the conplete fission product inventory assuned, not just iodines, kryptons ard xenons, for the prirary isotopes. In particular, rive for the whole core (not just one elenent) a raxinun total core invertory, ard the naxinun inventory in the whole core of

a. the rajor cesiuns

b. the rajor strontiuns

c. I-131 through 135

d. Xe 133n,133,135n,135

e. Er 85m. 85, 87, 29

f. bronine, 33, Te, Se, 3b, 3a, Ru, 2d, ho, Tc. Y, la, Ce, Fr, Ed. ?n, 3n,Zu. Up,?u,

c. ard the tctal core inventorf 71 ease specify precisely the operating conditions assumed to bring about this axinun inventerf. If you do not have figures for the categories requested, please provide all infernation you do have available as to raxinun core inventory, and provide refererces.

88. Tou state that fission product release is strongly tenperature-depende-t in uraniun-alucinun plate fuels.

71 ease provide all data available, and all references known to you, as to fission product release tactions for different isotopes at temperatures from ambient to above nelting.

E9. Is the UCIA, LT3-t;pe fuel aluninun natrix with EM4 dispersed therein, or is thq neat an aluminum-uranium eutectic? ? lease specific, and descrite the particular characteristics as to nelting and fission product release properties as to the UCIA fuel.

90. Please state with specificity why you think your 2. 7 gaseous release estirate for a single fuel elenent in a fuel handling accident is a reasonable estinate (why it is neither too conservative nor too non-conservative.)

91. x/Q was determined for what distance for an observer downwind?

92. 7nat would be the deses to pecple inside the building which houses the reactor? 2Prtse show all calculations and data and references.

93. Uhat would a fuel elenent with that operatien history be giving off in. terns of direct radiation (at one foot, three feet, and the other side (outdoors) of the reactor roon walls (or ceilin6 for classrocns, etc. above)?

? lease provide all data, calculations, and references.

_4c_

94. *1hy wasn't 51-1 data included in your analysis?

Of, At what tenperature does uraniun oxidation beccne exothernic?

06. At what tenperature will netalic trariun ignite?

07. Why didn' t your analysis consider uranium fire?

0'. 'That reac,tivit-f insertion cauced the destruction of a sw

.. . e a a L. .

b c( the

, the 31-13C2AX

99. '<?hy in your reactivity analysis did you not, as G: C did, conpensate for differences between STCET and 2C2AX suen as different void coefficients, ratio of heat flux to tenperature differerce, an? so On?

100. 'Jhat effect does the fact that the Argonaut is craphite and water nederated and 3??RT and 20?AX were merely water tederated have en extrapolations and interpolations of the destruct experiences?

101. '.-lhat error bars should te put on the SFIRT data itself?

102. Yhat error bars should te put on your extrap01ations and interpolations of the 3FERT data; i.e. when you say fuel tenperatures could reach "9CC C, plus er ninus what temperature rance to produce a 955 confidence level? Flease show all calculations, facts scd references upon which you base vcur answer.

.. - _ - _ _ = _ - . _ . .. . - ._ _ _ _ . ._, _ _ . _ - -

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The 'follouirg interrecatories are to te answered by 3.C. hauley alene

~

1 j

a(1). Ficase provide a current c.v. er resune and indicate in addition any other techrical qualificatiers upon uhich you base your erpertise as to the natters addressed in the report ir question.

A(2). Are you row, or have ycu teen within the last five years, an enple,*ee of ary of the five current licensees of Argoraut reactors?

If sc. please indicate uhich licensee, which pericd of enploynent, and what "our role nas at that licensee. By licensee we rean rot nerely on staff cf a particular reactor facility, but being a faculty nenter, researcher, consultant er other enployee of the Uriversity er University arsten (e.g. 2ccents of the University of California) which held the licensa for the facility..

1 A(3)Doyouneu,c: have you uithin the last five years, received a paycheck fron any of the five current Argonaut reactcr licensecs?

If so. please explain.

A(h) Do you have perscral acquaintance with any of the current er past staff of the. reactor facilities at any of the five Argonaut facilities?

If so. please identify each such individual and descrito the rature cf the acquaintance.

A(5) Uhat personal knowledge do you have regarding Arcenaut reactors?

Please be specific.

A(6) Kave you ever bsen enployed at an Arconaut reactor? If so, please give details.

A(7) Have you ever operated an Argonaut reactor? If so, please give date arc detaile and identify the specific reacter(s).

A( ) Eo you endorss the full centent of the report you co-authored?

If not, please idertify each specific portion, espect or sentence which .

you do not fully erderse. and explain uhy.

A(0) Do ycu have reservations about'any aspect of the report? If so, please identify each specific portion, aspect, or sentence about which "ou have reservations, and explain the reservations.

A(10) Io you take the abstract and sunnary of the report at its beginning to accurately reflect the content of the report?

A(11) Do you have any reservation about the abstract and sunnary completely ,

accurately reflectin6 the content efthe report? If yes, please identify '

each aspect of the abstract or sunnary with which you take sone issue and indicate what you feel would be a nere accurate way of sunnarizing cr abstracting the report.

.- . -. .- - . . _ _ - - _. - .- . . - n.. ..

A(12) "e note 14t lart;uace throu.7h out the report could readily be '

irtorpreted as sayirc that certain accident scenarios (other than the feel handling incident) are potentially credible. Is it your view that accident scenarios other than the fuel handling accident are l credible? If yes. please specify which. If no, please explain uhy.

A(13) If A(12) ateve was affirmatively answered, please indicate uhether

. ary cf the accidents potentially credible could result in doses in excess of those pentulated fer the fuel handlirs accident.

I A(14) 'a'e note also that throurhcut the report there are indications of destruct events which were consciously not censidered or which nore j study was reconnended or which your tean stated firn analysis was outside i of the scope of the present study. Do you telieve that your tean

aralyzed all credible destruct nodes for Argonaut facilities?

! - A(15) Are there sone destruct or accident nodes that you think denard

! greater attention than you have been able to give then to accurately '

1 assess their credibility and/or consequences?

l Part 3 These interrogatories are to be answered by R.L. Kathren Flease answer questions A(1) throuch (15) above, nuntering your answers 3(1) through 3 (15).

i i

Part C These interrcCatories are to be ansuered by E.A. Rotkin Please answer questions A(1) through (15) ateve, nuntering your answers l (C)(1) through C(15).

Flease in addition answer the followirg questions:

C(16) "e note that the report indicates you are an enployee of the University

)

of Washington, a licensee of an Argonaut reactor. We also note that you

are enployed by the Department of Euclear Engineering at the University

}

of 'Jashingten. Is the U of V Argonaut part of the Departnent of Huelear Engineerin6?

i C(17) Do you teach any courses which utilize the U of W Argonaut?

If so. please specify which classes, what use the reactor is put -to, and-how nany hours per year roughly of reactor time you so ass.

1 C(19.) Have you ir the past taught any classes that use the reactor? ' Please give detailc.

! C(19) Do you now. ' or have you in the past. used the U of 7 reactor for any .

i research, neutron activation. or other non-teaching activity? If so, please detail uith specificity the uses to which you have put the reactor, the research you have conducted with it, ard roughly the hours of reacter use so involved.

1

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_13_

C(20) Co reu persona 11:r know any of the staff <' a' of 'l Argonaut?

If so, please detail all such acquaintances.

C(21') 7o you have colleagues at the University of ?ashington who use the reactor for teaching or researca or other activities? If pessible, please identify colleagues who are principal users and the use put.

C(22),So you now. or have you in the past, sat'.cn ary supervisorial cennittee for the U cf 'l reacter (reacter hasards connittee, etc. )?

If so. please detail said involvement.

C(23) Are you personally acquainted witn any nonbers of said superviscrial connitteest if so, in uhat capacity?

C(24) ere the *.'riversity of '. ashington reacter shut down, would any of your research or teaching activities have to be nodified or curtailed?

If so, please specify what activities would have to te altered and how.

If rot, please specify precisely why no alteration would be needed.

C(25) Is the University of ' ashington reactor currently up for relicensing or will it be in the :. ext three years?

C(26) Is the '3C at this time reviewing any application fron the University cf Washingten re. carding its reactor facility? If so, please specif .

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1. 7 cur Fetruary 5,1991, report ('i-4-3692, in titled *5unnary of Conputerdiciel ard 3 elected Results Fron Argonaut Design lasis Accident Ivaluation." (enphasis added)

s. Please indicate precisely which results uere selected for inclusion in your repcrt ard which were selected to rot be included.

h. Did you at nry tine durirg your study, using different nodels er di'ferert assunptiers, cone up with peak tenperatures, for.a 1.00 kw Argeraut under any hypothetical corditior corsidered, creater thar the 6310 Z ser.perature reported in Thble I o' your report?

c. If the answer to t is af'irnative, please irdicate with specificity all runerical estinates hirher thar 631 K,0the assuned corditiers and nodel facters that produced that estimate, ard why the estimate was rejected.

2. "ho deternined the particular accident scerario you considered (less c' water while at 100 kw, caused by earthquake potentially causin compaction of the fuel elenerts, successful irsertier of centrol arts) g to te a Desige 2 asis Accident for the Argonaut reactor? Ecw was that deterniration made?

3. You state ir the first sentence of your report: "The hy;cthetical Desier 2 asis Accident (D2A) for the Argonaut reactor is assuned to te a cocplete loss of water coolant /noderater while operating at full pcuer (100 kw)."

a. Precisely defire Cesign 2 asis Accident as used here.

5. Ilease irdicate, ty reference and page, the source for said definition,

c. "o you nean by the above-quoted statenent that the accident sce*ario co-sidered in your report is the Design 2 asis Accident for Argorant reactors, or rather that it is a 32A, with others possible, and is cerelt Qa,D3A analyced in your study?

d. Did you ir ycur study make ary aralysis of, and ary consequent deterniratio" o#, whether any credible accident at Argenaut-type reactors could have greater public health and safety corsequerces than the D2A you analyced?

e. If the answer to d above is affirnative, please provide said aralysis.

4. Precisely why was this particular 22A chosen for analysis?

c. *4hy, o' all the possible earthcuake-induced transients and accidents possible at the Argonaut reactor, was a L2A chosen that represerts the rorral cordition cf the reactor after shutdown with cnly two exceptiers--

reductice in coolant chanrel width ard cutting off of natural air convection?

6. Which specific earthquake-irduced possible transients and D3As did -

yc.t corsider lefore choosirg this particular 03A for analysis. Please be specific as to the differert scerarios corsidered and why they were rot chosen for aralysis.

U

7. *.!hy, ir the 2;A "ou assuned. did you assune successful operation of the cortrol blades ir the earthauake situation? .

a. C- uhat basis did "ou assune the centrol 11ades would ucrk?

h. Uhat uculd have been the effect or your peak tenperature estinates had the control blades teer assuned to te stuck out-cf-core?

c. Please provide all facts, by calculatior ard refererce, on which you tase vour arsuer to 7b above.

'. Yhnt specific connon-nade failures arisirg from the earthquake did you co-sider in your analysis teyord the charFe ir coolart channel width ard loss of air fleu?

a. 'fhat was their effect on naxinun fuel temperatures? .

b. If ro common mode failure elenents were considered other than charrel width ard air f1cu loss, uhat facts can you produce to irdicate that "o other failures uculd accompary a major earthcuake at ar nrgoraut resctor like UCLA's?

c. You say ir vcur studw (p. 2): 'The core night also te crushed in the vertical directio vv fallirg lead tricks, access plugs, fuel tox shieldirg -

p19:s. or the nassive renovatie concrete shield blocks. These corpererts are interlocked ard supported tv the reirf orced corerete shield. Ever though the corerete in the shield nay crack and spall, it is difficult to imagire that large displacene-ts could occur snat uould allow these irterlocked conpo-e-tn to fall."

a. Old you consider ir " cur aralysis the core crushirr effects of ar earthquake which causes several stories of building above a reactor to fall onto the reactor structure itself?

b. If so, please provide detailed results of such analysis.

10. '.*cu sav $n your study (p. 2): "Arv crushir that takes place will terd to 'souceze the air out' from tetween the fuel plates so that heat c wductica to .the surr: undine g 9phite will te inproved relative to the un ~ushed state. "

a. Please state precisely why you telieve "any crushirc that

akes place" will increase conductier. *

b. Please state precisely why squeecirg the air out from betweer the fuel plates util inprove heat corduction to the surroundirg craphite.

c. Please pro 6uce all facts, by calculation and refererce, ircludirg

[ all erpirical eviderce, that supports your claim.

11. On pace 3 you state: "The calculations reported hereir include cases with the core crushed laterally so that the coolant gap between adjacert t

fuel plates is reduced to 50 per cent and 25 per cent of its ronical value."

a. Frecisely why are calculations rot reported ir the study of cenplete closirc of the coolant rap?

t. Would not the tenperature in the certer-nost plates te hifher if all the plates were ir direct contact? If so, please indicate hcu nuch higher tenperature, by calculation and reference; if not, please irdicate, with all facts and ret ererces you can produce to support your answer, uhy not.

c. Uere calculations nade but not reported in the study of coolant rap reduction to other than fCf and 2f5 of coniral? If so, please indicate the coolant rap corsidered and the calculations and their results.

12. Please descrite how the air between fuel plates in coolant channels was included in your honogenized nedel.

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

o I. f, 13. 'That fi;rure, for ther al conductivity of graphite did you use, and fron what actreet j 14. In deterninirt ther al conductivity of grapnite, did you take into i accourt charges in that cerductivity due to radiation danage in graphite?

l If so, precisel" heu was that factor taken into account?

! 1". In deterrinirg ther .a1 cerductivity of craphite, were charges in that ecMuctivit" at differert tenperatures assuned if so, precisely how ard -

with what result?

16. "ou state (p.3): '5 e fuel plates and coolant charrels are r.ot ,

redeled irdividually in the code because of linitations on computer tine ard nenor". Instead, the core is 'honegenized' bycontiring the fuel, l

structure, and coolant chanrels, accordirg to their respective volune .

fractions, into tuo conpos5 te raterials."

a. Aside fr:n the question of tuo versus three dinensicrality, which you addressed ir the study, how would your results have been altered, had you rot been limited en conputer time ard nencry and could individually i nedel plates ard channels?

17. On page 8 you state an equilitriun inventor.; cf fissior products uas assuned. Please give total curies of said inventorf, ard curie

, total of the ajer isotopes. .

1?. Please irdicate the total erergy output in terns of heat assuned 4

fron decay hen.t right af ter shutdown.

i 10 What percent of operatir4 power is assuned for decay heat at shutdown--

1 Five scurce D7 reference for said assunpticr. .

20. 3heu bf calculation .ard reference hou you deternined that the " fuel plate could te a raxinun of 12 K hotter than calculated t/ the nodal." (p.9).

21. " hat tenperature diffeerence with the nodel uculd there be for the fuel neat of the centernest fuel plate? Please shcu by calculation ard ,

refererce. ,

22; 3y calculation and reference, please shew precisely or what tasis

! you assune the reactor to te at a uniforn temperature of 311 K at 100-ku.

23. Was the assumption referred to in 22 above ksed on cperation of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> er so--ptecisely hou 1crg was reactor assuned to have teen operating, or dces that rake a differerce in your assumption of 311 K startirs tenperature?

l  ? lease explair.

24. I! hat was.the fuel reat tenperature assuned to.bu at the start c' your assuned D3A. and on what tasis?

2'. h'ou was the lead radiation shielding ucrked into -your ned el?

26. Does your honogenized nodel assume unifo-n graphite temperature.

i thro ghout core, uniforn fuel tenperature, and so on? If so, on what hsis is that assumption nade?

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27. Please explain footnotes a and b ir Table !--explair the relationship betweer coolant gap i noniral ard void fraction beinc 757 of noninal.

29. That error 'ars shculd be civen to your calculated peak tenperatures?

20 Please irdicate why tenperature is lower with snaller ceclant channel.

Give all empirical data and sources you can to support your arcunent.

30. Provide all facts, enpirical data, and sources you can to support clain 2

at paFe 11 that crushine the core causes "a decrease in tenperature uhen air l I flow is rot presert (tecause corductior heat transfer is inproved)."

}

31. Is the assumptier nertio-ed in 30 above based on an assunptienthat l

core crushirg sufficient to reduce coolart channels would also brirr graphitecloser into contact with the fuel boxes and fuel?

a. If so, please produce all evidence you can to show that vibratory esci11ations consequent to earthquakes could not produce an "accordian-type" effect in which ore part of the initial oscilation causes corpacticn of the fuel, but that the graphite cones to rest at sone distance fron the fuel, reducirg corduction.

1

32. Is the statenent that in the typical isothern shown in Figure 2, the graphite temperature'dces not exceed 340 K true merely for that isotherns with other isotherns are isolated portions of graphite at higher terperatures 1 than 3h0 IC

33. P.14 states : "It is reasonable to conclude that fuel nelting is precluded for the 100-kw reactor under the D3A scenario."

Does your study preclude fuel meltirg for all credible accident scenarios in 100 kw Argonaut reactors, or merely for the particular 4

D2A you aralyzed?

34. You state at the end of your sunnary, "It is quite possible that-refirenent of sone of the corservative assumptions, such as a three-

[

dinersioral rather than two-dimensicnal model and including the latert

! heat of fusion, would show that .teltirg would not occur at 500 kw."

a. Are there any non-conservative assumptiors whose refinenent would show increased melting at 500 kw? If so, please identify then,

b. Are there any non-conservative assumptions about your 100 kw

- analysis that would show, upon refinenert, increased naxinun fuel tenperatures? If so, please identify then and uhat their likely effect would be if refined, and the basis for that assessnent.

35 You stato in your February 11, 1981 letter to :.111ard Wohl that, "As you know, the release of ? fission products from the aluminun-uranium alloy plates can occur only after .the fuel has celted."

a. Please provide all facts and references you can produce that support this assertion.

36. Why does your analysis assume intact fuel plates af ter the 'caximun core crushing possible in a raxinun earthquake? What would be the effect (in terns of thernodynamics and in terns of fission product release) if there uere significant fuel danage?

. 37. Did vou consi?er in your nadel U1gner erergy teing released by the graphite as it was heated by the fuel's decay heat?

a. I' so, please give all calculations and refererces that indicate the effect on conduction from the fuel by changes in the graphite's heat sink capabilities and conduction to the fuel by the heat given cff by the ' diener energy.

b. If not, please give all calculations and references that uculd indicate the effect on conduction fron the fuel by chances in the Graphite's

' eat sink capabilities and . :enr'ucien to to the fuel by the heat given off r

tr the Vigner enerry.

c. In either case, give a numerical value for peak tenperature of the hottest part of the hottest fuel plate given a 'ligner enerFy release.

To te conservative, consider the Wigner release assuning the maxinun operating history pernitted under the proposed UCLA license (19.7 .Ud to date, plus 36.4 Efd thrcuch the year 2000 if license is rerewed with current operating limit). If you do not have infernation given these assunptions. please provide what infornation you do have available and (

specify what assumptions were used. Please detail your answer by calculation and reference.

39. Given the hottest fuel plate temperatures you estinate for 1C0 ku, could:

a. the cadmium control blades nelt?

b. the uranium netal--assuming splintering of the fuel--undergo exothernic cxidation?

c. a flan able irradiatier sanple or sanple container in core at time for sarple irradiation ignite?

d. the graphite undergo Uigner release?

Flease provide, by calculatien and reference, all facts you can produce to substantiate your answer to a through d atove.

39. Is the uranium fuel for the UCLA reactor an alloy, natrix, or sone other contiration of Uraniun-Aluninun; Please provide what infornation you have as to the fuel nature and its capacity at various tenperatures for fission product release.

i 40. Vere the 'IA you considered to occur in ccnjunction with an earthquake-induced building fire, what would be the naxinun fuel temperatures at 100 ku histo:tr and would neltine occuri Flease, by calculation and reference, show all facts upon which answer is based.

41. Were the 03A you considered to occur in conjunction u$ th an earthquake-

, induced graphite fire of the reactor itself, what would be the maxinun fuel tenperatures (for a 100 ku reactor) and would nelting eccur? Ilease, by calculation ard refererce. show all facts upon which your answer is based.

42, Vere an earthquake-induced reactivity insertion to occur fclloucc: Sc the 32A you analyzed, could nelting occur? What would be the pininun l reactivity insertion necessary in such a scenario to cause neltirg in l

conjuretion with the D3A you analyzed. Please, by calculation and reference, show all facts upon which your answer is based.

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7-

43. Are 7ou reu, or have you Seen uithin the last five jears, an enplc.f ee of the ?.egents of the 'Jniversit cf C-liferia? Ilsase explain, hh. Do you now, c- have ; ou in the past five ;rcarc, received a parchack fren the Eecents of the University of Califerf ia'? Ilease explain.

h5. Do you have personal acquaintance with any cf 'he currer.t or past staff of the UCIA "uclear D ercy InScrator r? If so, please identif-l sach such individual and lescrite 'he nature cf the acquaintance.

h6. ' M t personal kreuledce do you have regardinc ergenaut reacters?

h?. Have you ever been enployed at an Argonaut reacter? If so, please

-ive details, h* Fave you e!.:c cperated ar Argonaut reactor? If so, please give details.

49. Fave feu ever visited an Arcenaut reactor? If so, please give data and 'etails and identify the specific reactor.

50. Please provide a current c.v. cr reuune and any additional

'nfernation as to your particular technical qualifications to .ake the assessnents rou have in jour report.

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Intervenor hereby requests the folleving docunents te produced.

^ hose docunents can be produced by havirs copies sent to Intervenor; or the" can be nade available for inspection and copyirs at the 1F:2.

~hese requests are nado pursuant to the Freedon of Infernation Act as uell as the discovery procedures established in this proceeding.

!r tervencr reque.sta ualvirr of any copyinc and search fees, as per the Freedon of Infornation Act, as the use to uhich the docunents uill te put is provision of infernation to the Atenic Safety and. Licensing Joard in a n"tter of reactor safety. Provision of e full evidentiary record for the loard . obviously in the public interest.

T urthernere, Intervencr notes that 'TC 3taff has not charged the other party ir this proceeding for docunents provided.

The following docunents are hereby requested for production:

all licensee event reports for the University of Unshington and the "niversity of Florida Argonaut reactors for the period 1970 to the present.

all abnornal occurrence reports fron " of F and i _f V Argonaut reacters 1970 to present not ircluded in iten above.

arnual reports for the last.three years fron both reactors initial hasard analysis fron "niversity of *4ashington a

drauings provided U2C Staff by " CIA in response to TRC Question dl, l h-17-80.

reactor core drawings provided by NRC Staff to C.E. Cort for his study.

l 6

i ACC letter, Frice to Zoelter, regarding Argon 41, Septenber 9,1960 l p. 2. inspection report 1963 .

r application for relicensing, University of *.?ashington and University of Florida r

I inspection reports.1975 to present, University of Uashington ard "niversity of I Florida reactors

probabilistic risk assessnents for research reactors perforned by i EC i

compilations of statistical data regardirg operating perfornance (# of u . intentional scrans, abnormal occurrences, violations) conparirs j

1. research reactor perfornance.

currert statenent of "3C policy regarding consideration of Class 9 accidents in 3 2s. CIAs. and licensing hearings.

! Reg. Cuide 1.60 dccunents detailing results of or status of revieu of total-safednards requirenents at research reactors rentioned in 12 TRC 528, CLI-20-37, t

i, gy g y -e g -M t d ag y 93g-'+e-yp,-grgy r -e g,

O UNITED STATE CF AMERICA NUCLEAR REGUIATORY COIOiISSION 3EFCRE "'HE ATOMIC SAFETY AND LICE:!SIG 3 CAR _D In the Matter f I Docket No. 50-142 THE RECE*"3 CF THE UNIVERSC

& CALIFCPl!IA (Proposed Renewal of Facility License)

(UCLA Research Reactor) )

DECLARATICN CF SERVICE scover; 3equests as to

! hereb" SE2, !A,declare that copies i'R d/CR-2070, andof"UEIC/CR-2198" "Intervanor's 3}hein t above-captioned proceeding ra c baan served by ne en the following b-/ deposit, in the

'~ n ited 3tatus : ail, first class. this ')laL day of Jul; ,1991:

Elizabeth S. Bowers, Esq., Chairman Christine Helwick, Esq. ,

Administrative Judge Glenn R. Woods, Esq.

Atomic Safety and Licensing 3 card Cffice of General Counsel U.S. Nuclear Regulatory Commission 590 University Hall Vashington, D.C. 20555 2200 University Avenue 3erkeley, CA 94720

'h. Emmeth A. Luetke Administrative Judge . Counsel for NRC Staff Atomic Safety and Itcensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatcry Commission Washington, D.C. 20555 Washingtcm, D.C. 20555

,l Docketing and Service Section (3)

Dr. Oscar H. Paris Office of the Secretar/

Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing 3oard Washington, D.C. 20555 U.S. Nuclear Regulatory Commission l Washington. D.C. 20555 William H. Cormier, Esq.

Office of Administrative Vice Chancellor -

University of California 405 Hilgard Ave.

Los Angeles, CA 90024 l 'lendy dehnel'cer

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