ML20010C579
| ML20010C579 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 08/14/1981 |
| From: | Woods G CALIFORNIA, UNIV. OF, LOS ANGELES, CA |
| To: | COMMITTEE TO BRIDGE THE GAP |
| References | |
| NUDOCS 8108200212 | |
| Download: ML20010C579 (15) | |
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#3 Y 3 UNITED STATES OF AMERICA /.f NUCLEAR REGULATORY COMMISSION 'V y 4 m
.BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5
6 7
8 In the Matter of )
~ ) Docket No. 50-142 9 THE REGENTS OF THE UNIVERSITY .) (Proposed Renewal of Facility OF CALIFORNIA ') License Number R-71) 10 )
(UCLA Research Reactor) ) August 14,
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15 APPLICANT'S SUPPLEMENTAL RESPONSES TO CERTA INTERVENOR'S FIRST AND SECOND SET OF INTERROGA E
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16
-17 18 DONALD L. REIDHAAR GLENN R. WOODS 19 CHRISilNE HELWICK 590 University 9all 20 2200 University Avenue Berkeley, California 94720 21 Telephone: (415) 642-2822 22 Attorneys for Applicant 23 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 25 o"3 26 I 27 l f l 28 .
~ i 8108200212 810814 PDR ADOCK 05000142 O PDR N
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1 Applicant, THE REGENTS OF THE UNIVERSITY OF
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2 CALIFORNIA, supplements its responses-to certain of'Intervenor's 3 first and second set interrcgatories as follows.
4 -
-5 Supplemented Response to Interrogatory No. 17h, i and j 6 (CONTENTION I).
7 8 h. Not to the knowledge of Applicant's staff.
9 i. Not applicable 10 j. Engineering courses 135AL, 135BL, 135F, 139A and 11 XL497.17. In addition, without changing curricular objectives 12 or diminishing the educational ef fectiveness of each, the 13 following laboratory courses, a portion of which require the use 14 of the reactor to perform neutron activation analyses, could 15 also not be taught without the use of the reactor: Physics 180A, 16 Chemistry 184 and 223" and Earth and Space Science 298.
17 18 Supplemented Response to Interrogatory No.18 (CONTENTION I).
19 20 [ Applicant's iotective order request denied.]
21 Currently, approximately 14 graduate students and 22 post-doctoral scholars are known to depend upon the reactor for 23 all or part of their research study. Additional graduate 24 students may deperd upon the reactor for part of there research; 25 however Applicant's reactor staf f does not track the progress of 26 gradua'te student research related to the reactor and only knows i
27 of such research as it identified by project title, name of !
i 28 principal inves,tigator (usually the ' faculty advisor for certain j i
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I graduate students) and sometimes the name of the -students that 2 appear on the Experimental Saf ety Analysis forms.
3 4 a. J. Grossman, G. Kallemeyn, F. Kyte, G. Rambaldi, 5 D. Sears, P. Warren and-C. Zhou, Meteorite and Lunar Rock 6 Analysis (UCLA; J. Wasson, advisor); J. Conca, R. Heuser and J.
7 Jones, Track Radiography (Call'f. Institute of Technology; D.
8 Burnett, advisor); M. Dunmke, C. Meins, R. Mendenhall, 9 Sputtering of U-235 (California Institute of Technology, T.
10 Tombrello, advisor); G. McMurtry, Studies of Boron Distribution II (UCSD, J. D. McDongall, advisor).
12 13
- b. Unknown 14
- c. Unknown 15
- d. Not applicable 16 17 Supplemented Response to Interrogatory No. 28h (CONTENTION I).
18 19
[The Board ruled: " Deny protective order as 20 modified. Has any analysis been performed at UCLA on the SPERT 21 and BORAX tests? What is the basis for the statement in the 22 application? Was UCLA data furnished to Pacific Northwest 23 Laboratory (Battelle) on SPERT 'and BORAX tests for 24 NUREG/CR-2079, PNL-36917"]
25
- h. To Applicant's knowledge no analyses have been performed at UCLA on the SPERT and BORAX tests. The statement, 27 ,
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I which was poorly paraphrased in the Application, follows from 2 the 1960 Hazards Analysis wherein results from the SPERT and 3 BORAX tests are discussed generically (cf. page 4 of 4 NUREG/CR-2079). Applicant's staff did not directly furnish any 5 data to Pacific Northwest Laboratory (PNL). PNL did reference 6 the UCLA Argonaut Safety Analysis Report (1980) and had a copy, 7 presumably, of UCLA's license renewal application, or excerpts 8 thereof.
9 10 Supplemented Response to Interrogatories Nos. 54 and 55 II (CONTENTION II) 12 13
[ Applicant's protective order request denied.]
14 15
- 54. The names, academic programs and last known 1G addresses are as follows: James Everett, Engineering, 401 Circle 17 Drive West, Box 121, Los Angeles, CA 90024; Dave Proffer, 18 Computer Science, 196 Sandberg, Thousand Oaks, CA 91360; Robert 19 Schaffer, Engin3ering, 1611 Penmon Ave. #1, Venice, CA 90291; 20 Paul Smith, Computer Science, 350 De Neve Circle Drive 21
- 572, Los Angeles, CA 90024; Karen Ujihara, Engineering, 401 S.
22 Barrington #105, Los Angeles, CA 90025; Philip Wheaton, 23 Engineering, 3733 Keystone Ave. #5, Los Angeles, CA 90034.
24
- 55. Profer and Smith, computer programmers, were 25 used to develop data reduction procedures; the.others prepared 26 sa'mples, loaded and unloaded samples and recorded data.
27 28
1
- a. No 2 b. Yes 3 c. The activities enabled students to learn 4 experimental techniques and the use of sophisticated nuclear 5 engineering equipment and instruments which could not be learned 6: in the classroom.
7 8 Supplemented Response to Interrogatory No. 60 (CONTENTION II).
9 10 [The Board ruled: " Deny protective order as modified 11 but UCLA does not have to chart or tabulate the data.
12 Information should be released if it exists in its present 13 form."]
14 To Applicant's knowledge subsequent to the 15 publication of the 1967-68 Annual Report the data requested by 16 this question was not routinely or systematically collected by 17 the NEL staff. Some data does appear in the 1976 and 1977 18 Annual Report, which have already been made available to 19 Intervenor; however, Applicant's staff is unaware of any 20 compilation of the requested data for other years.
21 22 Supplemented Response to Interrogatory No. 38 (CONTENTION III).
23 24 Yes, February 25, 1980.
25 26 Supplemented Response to Interrogatory No. 43a 27 ,(CONTENTION III).
28
- . . _ s %
I a. Neill C. Ostrander, Nuclear Energy Laboratory, 2 Room 2567, Boelter Hall, UCLA, telephone (213) 825-2040.
3 4 Supplemented Response to Interrogatory No. 58 (CONTENTION III).
5 6
7 a. July 10, August 1 and 4, and September 23 and 24 8 of 1975; October 12, November 22 and Dece:aber 1, 3 and 9 of 9 1976; September 6, 7, 8, 9, 21 and 23 of 1977; November 29 and 10 30, and December 7 of 1978; December 13, 17 and 19 of 1979; 11 October 21, 23 and 28 of 1980; and January 28 and 29 of 1981.
12 b. Yes 13 c. No 14 d. Not applicable 15 e. Not applicable 16 f. C. E. Ashbaugh of NEL; yes.
17 g. None 18 h. Not applicable 19 1. Not applicable 20 j. Not applicable 21 k. Not appli able 22 k. Not applicable 23 1. Not applicable 24 m. Not applicable 25 n. Not applicalbe 26 O. Not applicable 27 p. Not applicable 28 o
1 Supplemented Response to Interrogatory No. 11 (CONTENTION IV).
2 3 [The Board ruled: " Deny protective order as 4 modified. UCLA need not compile a study but should furnish 5 relevant information if it exists."]
6 Applicant does not possess information sufficient to 7 permit answering the question. Applicant would need information 8 for each hypothetical situation concerning the follouing: the 9 purity of the ore sample, the en: chment level of the ore 10 sample; whether a positive or negat ive reactivity is being 11 introducted; where and how the sample is being inserted in the 12 reactor; the nature of the diluent and the concentration; and 13 the nature of the impurities present in the ore.
14 15 Supplemented Response to Interrogatories Nos. 39, 43, 45, 47, 48 16 and 50 (CONTENTION V).
17 18 [The Board ruled: " Deny protective order as 19 modified. UCLA need not create a complex and extensive study 20 but should furnish existing information. Under 10 C.F.R. Sec.
21 2.740(e) UCLA should supplement its response if it develops 22 additional information prior to the hearing."]
23 24 Respecting Nos. 39, 43, 45, 48 and 50, information 25 sufficient to enable Applicant's staff te answer these questions 26 and th'e subparts of each does not exist beyond that which is 27 contained in the 1960 Hazards Analysis and what may be found in 28 NUREG/CR-2079.
1
- 47. Probably -not.
2 a. There is no unique or direct relationship 3 b. A!.most everything 4 d. Unknown; applicant's staff have not examined 5 this question.
6 e. Not for samples of reasonable size 7 (" rabbits") in the UCLA reactor.
8 9 Supplemented Response to Interrogatory No. 21 (CONTENTION VI).
10 11 The film badges are responding only to beta rays 12 (electrons) and are not suf ficiently sensitive to detect the 13 gamma (photon) radiation. The TLD's discriminate against the 14 electron radiation and see only the gamma radiation. An 15 electron is intensely ionizing in a local domain, the photon is 16 weakly ionizing in a large domain.
17 18 a. The individual outside of the stack is 19 well-shielded from the non-penetrating electron flux within the 20 stack (film badge 203). Sitting with a head height of four 21 feet, the head is 8.5 feet from the top of the stack (film badge 22 265). An electron must have a minimum energy of about'O.82 MeV 23 to penetrate 8.5 feet of air. Approximately 6% of the electrons 24 . f rom the decay of argon-41 have that energy or greater. Because 25 of this and the inverse square law, the beta radiation level at 26 a distance of 8.5 feet from the stack top can be expected to 27 fall from 350 mr/yr to 350 X 0.06 X (1/8. 5 )2 = 0.29 mr/yr. This 28 calculation ignores the shadowing effect of the stack '
elf.
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1 The referenced quotation refers _to the gamma radiation level 2 measured by the.TLD's.
3 4 b. Since film badges and TLD's are:not measuring the-5 same thing, comparing a curacies is meaningless.
6 7 Supplemented Response to Interrogatory Nos. 3, 4, 8(c), and 15 8 (CONTENTION VII).
9 10 [The Board Ruled: "What language does UCLA use to 11 describe the occurrences which would be reported under this 12 contention? 8(c) and 15 should be answered."]
13 14 In addition to the information contained in the May 15 20 " Answers" of Applicant, the following information is 16 submitted in general response to Nos. 3, 4, 8(c) and 15.
17 18 Applicant would use, where appropriate, the language 19 of Part VIII of the Technical Specifications. A report to the 20 NRC would typically begin with the phrase "Puruant to UCLA's 21 Technical Specification, VIII. M.l.a (for example), this will 22 advise you that ...
Intervenor's list of " unusual episodes" 23 includes some terms that coincide with the terminology of the 24 Technical Specifications (items a and b). Item c is an apparent 25 synonym for item b and item e is an apprent synonym for item a.
26 Items 'g, k, 1, and m are not used in any precise sense by 27 Applicant and, in any case, are not necessarily " unusual."
28 However these items may be considered as corresponding to
I certain. items in the Technical Specifications: 9 to VIII. K.6, 2 L. 3.c , M.I.G, M.3.e;'j to VIII. . K. 9, _ M. 3.g; k to VIII K.3, 3 L. 3.d , M. 2.c , M. 3.c; l~.to VIIII. L.3.e; and m to VIII. L.3.a.
4 "Scri -can mean an unscheduled shutdown but is often used as a 5 synonym for a scheduled shut down (for example, " Scram time will 6 be 11':15"). The word " scram" is often modified by such words as 7 " full," " overpower," " period," or " drop rod." Item f is not 8 used in any special sense; item h is not used. Item n may 9 induce an unscheduled shutdown (scram report) but would not 10 normally be regarded-as reportable unless it falls under 11 Technical Specification VIII L.3.c or'VIII M.I.G. Item i is 12 only used to describe a utility failure or break' that initiates 13 an unscheduled shutdown in accordance with the reactor's design 14 and should not be confused with a power reactor's load-change, 15 turbine-trip event. Anything else that would fall under item o 16 would be covered by Technical Specification VIII.L.3 (abnormal 17 occurrence).
18 19 Applicant's specific responses to Nos. 8(c) and 15 20 follow, 21 22 8(c).' Applicant has the three categories of 23 procedures required by Technical Specification VIII.J.2, J.3, 24 . and J . 4 to take care of specific malfunctions and emergencies.
25 These procedures (referred to generally as " Operating and 26 Radiological Control Procedures") were identified as document 27 number 37-of " Exhibit A" attached to Applicant's May 20 28 " Answers" and have been made available to Intervenor. Applicant
l I _does _ not have specific written procedures for any of 2
~
Intervenor's " unusual event" items a through o. There are no 3 health' and safety considerations that would suggest that written 4
procedures were needed for each of these items in view of that 5
fact that Applicant has more generally applicable radiological G
control procedures.
7 8
- 15. Applicant's staff.does not maintain any file of 9
" unusual events" distinct from the record keeping requirements of Technical Specification VIII.K. In addition to the documents 11 mentioned in response to Interrogatory No.14, scram reports are 12 made and some of the inspection reports may contain descriptions 13 of " unusual events." All of these documents have previously 14 been made available to Intervenor.
15 0
Supplemented Response to Interrogatory No. 8 (CONTENTION VI'II).
17 18
[The Board denied Applicant's protective order 19 request).
20 Although the assumed operating conditions are 21
-specified adequately, as Applicant understands the assumed 22 conditions Applicant's current license operating limits would 23 permit operating under a through g. and i, h and j would not be 24 permitted.
25 26 Supplemented Response to Interrogatory No. 14 (CONTENTION 27 VIII).
28
i z.,
1 Applicant doesl not possess .the required
} 2 information.
3 a. Not applicable 4 b. Not applicable 5
6
-7 Supplemented Response to Interrogatories Nos. 22e, 23c and d, 8 and 24 (CONTENTION VIII).
9 10 [The Board ruled: "UCLA is neither expected nor 11 required to perform any additional studies in order to respond 12 to ,these interrogatories, but it may have sor existing 13 information which would be responsive to some degree to the 14 in T +matio'.4 being sought. If so, it should be furnished. If 15 not, UCLA should so state."]
16 17 22e. Applicant dGes not possess the information 18 needed to respond to the question.
19 20 23c. Because the half-life is long relative to the 21 assumed periodicites, the inventory is approximately the 22 equilibrium inventory for the average power level of 24 kw 23 (100 X 40/168). Using 24 percent of the I-131 inventory of 24 Table 3, NUREG CR/2079 yields 39 Curies.
25 26 23d. The calculation is similar to that in 23c 27 above, except that the percent is doubled and the result is 28 doubled, that is 78 Curies.
- o. ,
1 24. Applicant does not possess the information 2 needed to respond to the i_'estion.
3 Supplemented Response to Interrogatory No. 28 4 (CONTENTION VIII).
5 6 [The Board ruled: "If UCLA has other information, it 7 should be provided."]
8 9 Applicant has no information other than that 10 provided in its previous responses to this question. Applicant 11 possesses no specialized information on this general subject.
12 13 . Supplemented Response to Interrogatory No. 64 (CONTENTION XX).
14 15 The only portion of coolant or coolant-related 16 equipment on the third floor is a water Gemineralizer. There is 17 no such equipment on the eigth floor. The demineralizer is 18 jonce-through, non-circulating equipment that provides "make-up" i
19 water on-demand. Make-up water is required only at infrequent ,
20 intervals, and the reactor normally operates for several months 21 between additions of make-up water.
22 23 . Supplemented Response to Interrogatory No. 6 (CONTENTION II; 24 Intervenor's First Set of Interrogatories).
25 26 [In our "Further Answers" of June 11, 1981 we 27 provided a chart (" Exhibit C" of that document) in response to 28 Interrogatory No. 6. The chart (of reactor usage) covered the I
.a t years 175 to 1980. We state on page 15 of that document that 2 we would attempt to supplement that answer at a future- time by 3 providing_ data for earlier years. The following information 4 extends the data in the . chart back to the year 1972.]
5
.6 See " Exhibit A" attached hereto.
7 8
9 10 Dated: August 14, 1981 11 12 13 DONALD L. REIDHAAR GLENN R.. WOODS 14 CHRISTINE HELWICK 15 By D +
17 Glenn R. Woods 18 19 20 21 22 23 24 25 26 - '
27 28 1
~ - - ,-r - - , , ,. - -
's 1 " EXHIBIT A" 2
REACICR USAGE 3
4 USE CATEGORY 1972 1973 1974 5 - - -
PORT PORT PORT 6j HOURS $ HOURS S HOURS S 7 Classroom Instruct- 25 25 36 ion 8
l Maintenance 52 12 41 9!
! Besearch 10 l NEL Staff Users 41 1 31 11 Other UCIA Users 81 3345 122 5076 105 4258 12 ,
(bilege and Uni- 25 2760 31 3720 45 5520 13 versity Users 14 Other Extramural 2 240 1 120 - -
Users 15 Danonstrations 13 9 5 249 16 17
'IUPALS . $6345 $8916 $10018 18 19 NOTE: 'Ihe totals do not agree with the annual reports for 20 the corresponding years. Ib attempt has been nudo to reconcile 21 the dif ferences. Ibn-UCIA users were charged a higher rate than the rate which applied to UCIA users during this perial. In 23 l 1975 a single rate was adopted which has been applied to all 24lul sers from 1975 to the present .
25]
26 27 28 1
i .
1 INITED STATES OF RERICA NUCLEAR REGUJ1 DORY CCf 7GSSIOt1 2
BEFORE DE IGNIC SAFLTY AND LICENSING EGARD .
3 4 In the Patter of )
) Docket No. 50-142 5 TE REGEtnS OF DE UNIVERSITY ) (Proposed Penewal of Facility OF CALIEDIMIA ) License Number R-71) 6 )
(UCIA Research Pcactor) )
7 ) .
8 uauvICurE OF SERVICE 9 I hereby certify that copics of the attached:
APPLICANT'S SUPPLEMENTAL RESPONSES TO CERTAIN OF INTERVENOR'S 10 PTngm utn snrnNn RET nF TNTERROGATORIES in the above-captiened proceeding have been served on the follcwing by deposit Il in the United States nail, first class, postage prepaid, addressed as in-dicated, on this date: August 14, 1961 .
13 Elizabeth Bowers, Esq. Counsel for NBC Staff U.S. Nuclear Regulatory Ccrnission Office of the Executive Icgal Director 14 Atanic Sa#ety & Licensing Board U.S. Nuclear Pegulatory Caimissicn Washington, DC 20555 Washington, DC 20555 Dr. Erinnth A. Luebke Daniel Hirsch 16 U.S. Nuclear Pegulatory Commission Ccmnittee to Bridge the Gap Atcmic Safety & Licensing Board 1637 Butler Avenue, #230 17 Washington, DC 20555 Ios Angeles, CA 90025 18 Dr. Oscar H. Paris Mr. Park Pollock U.S. Nuclear Regulatory Comission Pollack & Willis 19 Atonic Safety & Licensing Board 1724 M. La Drea Avenue 20 Chief, Docketing and Service Section (3) 21 Office of the Secretary
.U.S. Nuclear Pcqulatory Ccmnission '
22 Washington, DC 20555 23 24 pW 25 Uilli'am H. Cormier UCLA Representative 2G 27 28 m ,