ML20010H192

Requests Withdrawal of Demand for ASLB Direction Before NRC Will Answer Committee to Bridge the Gap 810731 Interrogatories.Forwards List of Admitted Contentions. Related Correspondence

ML20010H192
Person / Time
Site:	05000142
Issue date:	09/14/1981
From:	Pollock M COMMITTEE TO BRIDGE THE GAP, POLLOCK, M.
To:	Woodhead C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8109240117
Download: ML20010H192 (16)

Text

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ruaTED CoaFaspOymm the nuclear aw center 1724 NORTH LA DREA AVENUE e LOS ANGELES CAUFORNIA 90046 . 213/851 9201 September 14, 1981 Ms. Colleen P. 'loodhead, Esq.

Counsel for NRC Staff

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U.S. Nuclear Regulatory Commission [&

Washington, D.C. 20555 COWro 1

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1 TIP I 8198f . I In the Matter of the m CD.s-Regents of the University of California g EU " O $2@ty (UCLAResearchReactor) h ['W Docket No. 50-142 y (Proposed Renewal of Facility License) g (P P'

yQ[%dp" ,1 RE: STAFF IETTER OF AUGUST 19 AND BOARD CRDER OF AUGUST 27

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Dear Ms. Woodhead:

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I have tried unsuccessfully to reach you by phone several times since receipt of your August 19 letter, in which you decline to '

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provideanswerstoanyoftheinterrogatoriessubmittedbyInterv(en;or i on July 31. Inasmuch as the Board, in its Order of August 24 directe d parties to attempt to resolve discovery disputes among themselves prior to making motions to the Board, I had wanted to ask you to reconsider ~

( your demand in your August 19 letter that Intervenor, should it wish

( its interrogatories anskered, bring the matter before the presiding officer l of this proceeding for a direction to Staff to answer. I wanted to request this in part because the Board Order of July 1 opening discovs;y r co the recently released Staff documents in question seems to prov11e the direction you request, and because Staff had w:.1ved for UCIA the procedure ;,ou now demand of Intervenor.

Not being able to reach you, Intervenor has gone ahead and asked the presiding officer for the direction you request. So as to expedite the procenngs and reduce the burdens being placed upon the prasiding officer by the various discovery disputes in this proceeding, I respectfully request you consider withdrawing your demand for (in Intervenor's view, redundant) direc+1en by the presiding officer to ananer the interrogatories in question. The motion (eaclosed) for action by the presiding officer would thus be made moot and the proceedings expedited. O3 In another matter, I note that in the Board's Order of August 27 I l

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(" Order Relative to the Admitted enntentions"), the Board requests

" Staff as a courtesty to the Board and the other parties to prepare /If

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one document which sets forth the language of the admitted contentions."

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ColleenP.Woodhead/page2 As Intervenor has already prepared such a document, for purposes of clarity and for your cor.venience, it is enclosed. The document contains both those contentions which have been admitted and those ruling on which has been deferred.

Sincerely.

Marh Pollock

[Attoatey for Intervenor Coma 1.ttee to Bridge the Gap enclosure: "Intervenor's Contentions Admitted. . . "

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INTERVEIOR'S CONTENTIONS AEMITIED AS AT ISSUE  ; SEP18198f 3

BEWRE THE ATOMIC SAFETY AND LICEISI:iG 30ARD 9

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Re: APPLICATION FOR RDTEWAL OF OPERATING 00 k s  ? /

LICETSE FOR UCLA RESEARCH REACIOR, FURSUANT Ecc4 y/

W TO BOARD ORDER ISSUED MARCH 23, 1981. j he p I. The application, together with its supporting appendices, is deficient in failing to meet the minimum standards for such app'. cations. Speci-fically:

1. The Application reference to experimental vibration of the reactor is misleading.

2. The application submitted by UCLA was not " original" in all respects as shown by

a. its submission of a 1980 Safety Analysis Report (SAR) which repeats virtually verbatim its 1960 Hazards Analysis, and

b. its submission of an environmental impact appraisal which repeats virtually verbatim the language of a 1974 AEC memorandum on " Environmental Considerations Regard-ing the Licensing of Researen Reactors and Critical Facliities."

3. The application contains the following material and inaccurate statements:

a. "The reactor and its supporting laboratories will be used for the education of senior undergraduate and graduate students in nuclear engineering and related sciences. In addition to fomal courses and demonstra-tions, the reactor will be used to support research at the M.S. and Ph.D levels." page 5.

b. "No structural weaknesses (earthquake vulnerability) have ever been identified." page 7.

c. "No attempt has been made to alter the content and provisions of the technical specifications other than the four changes noted in the forward to the technical specifications. " page V/1. This statement is inaccurate because ,

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(i) the excess reactivity limits have been changed from 2.3% k/k to $3.54; (ii) the definition of ' annual' for the purpose of instrument calibration requirements has been changed from 12 months to 14 months; (iii) the requirement to do heat balance instrumentation calibrations has been removed; (iv) the requirement that ALARA be met has been removed; and (v) the specification regarding exhausi stack height, flow rate out of the exhaust stack, and access restrictions to tne roof area have been removed.

d. "No deep wells have been drilled on the campus of UCLA or in the vicinity of the campus." page III/3-1.

e. " Accidents ranging from failure of experiments to the largest core damage and fission product release consi-dered DJssible result in doses of only a small fraction of 10 CFR Part 100 guidelines and are considered negli-gible with respect to the environment." page II/3-1.

f. "There are no suitable or more economical alternatives which can accomplish both the educational and the research objectives of the facility." page II/5-1.

g. "SPERT and BORAX tests showed that plate type fuel elements survived step radioactivity insertions of 53.54." page V/3-6.

II. The Applicant has applied for the wrong class of license. Applicant has applied for a Class 104 license despite the fact that in the past, more than fif ty percent of reactor funding and more than fif ty percent of the hours of reactor usage have been devoted to the sale of services, rather than research or education. Given this history, and without any indication that Applicant intends to change reactor usage, Applicant under 10 CFR H 50.21(b) and 10 CFR 9 50.22 should have applied for a Class 103 license. Specifically:

Applicant should apply for a Class 103 license because

a. Applicant's financial statements indicate that more than half of the reactor funding comes from sources other than the UCLA School of Engineering and Applied Sciences, and 2

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b. the application indicates more than half of t.he reactor operating time is spent on commercial, non-educational projects.

III. Applicant has failed to demonstrate adequate managerial and administra-tive controls in the application, as required by 10 CFR i 50.34(b)(6)(ii),

and further, has demonstrated throughout its operating history grossly inacequate controls. These inadequacies make it impossible to find that Applicant's managerial and administrative controls are adequate to responsibly protect the public health and safety. Specifically:

1. Applicant failed to provide the information required in 10 CFR 5 50.34(b)(6)(ii).

2. Applicant failed to get prior approval from the Reactor Use Committee or the Reactor Director for changes in reactor systems and for non-s tanda rd. experiments.

3. Applicant failed to get prior Commission approval for facility changes.

4 The Lab Director and/or Assistant Director were absent for extensive periods of time and proviaed inadequate supervision.

5. Unlicensed visitors to the reactor facility were invited to oper-ate the reactor controls in violation of 10 CFR is 50.54j, k,1, 55.2; 55.3a and b; 55.d and f; and 55.9a and b. l

6. Applicant kept inadequate records and lost a maintenance log, and

7. Applicant failed to hold administrative meetings and conduct reviews required by the Technical Specifications.

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l IV. Applicant has been co.wistently cited for violations of NRC regulations as well as violations of the provisions of its own Technical Specifi-l ca tions . This consistent pattern of regulatory non-compliance and the lack of assuranccs that the pattern will not continue in the future indicates that the Applicant cannot adequately demonstrate that future operation of the facility will comply satisfactorily with the regu-

./' lations to protect the public health and safety.

V. The amount of excess reactivity which is permitted by the Technical .

li Specifications to be installed in this reactor is too great in that it does not provide a sufficient safety margin and thus could lead to a serious power excursion which could bring about melting of the fuel l cladding and significant release of fission products, seriously endanger-ing the public health and safety. Specifically:

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1. The amount of excess reactivity permitted at this facility under its license should be limited to less than that needed for prcmpt cri tical i ty.

2. The reactor has lost several significant se10 limiting features in that

a. the h ': of excess :tactivity has been changed so that it is now higher than that needed for prompt criticality,

b. a deflector plate which prevented repeated excursions has been removed,

c. the assumption that there is a large negative temperature coefficient appears to be wrong in light of infornation regarding a positive graphite temperature coefficient, and

d. the reactor's power level has been increased from 10 Kw

,, a y to 100 Kw. , __ _

3. The licensed amount of excess reactivity (2.3% 0. k/k) could cause melting of the fuel cladding according to the 1960 Hazards Analysis.

4. The reactor's void coefficient has changed since the initial calculations were done.

5. Through the conversion of 2.3% . k/k as the excess reactivity limitation in the current Technical Specifications to $3.54 in the i,roposed Technical Specifications and the use of ? 5 different from that used in the Hazards Analysis, the Applicant nay have changet the limitation from 2.3% +,o 2.60., thus presenting the potential for a serious excursion and melting of the cladding.

6. The assumption that Borax I test results can be extrapolated to the UCLA reactor is questionable, particularly in the absence of error bars for the Borax I data.

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8. The analysis of excess reactivity cnaracteristics of this reactor submitted in the application fails to include a current review of the nuclear safety literature relating to the relationship between excess reactivity and destructive power excursions.

9. Applicant's Hazards Analysis regarding excess reactivity is based on unverified and unidentified assumptions which c:.n be used merely to estimate a range of excess reactivity additions and -

their possible hazard and is thus inadequate to support present J. licensed limits. Additionally, Applicant has not provided error

<A bars for its canputations and analyses.

10. The reactor has a pneumatic " rabbit" system that allows rapid insertion of excess reactivity. This system did not exist when the reactor was built and has experienced frequent

' operating problems since installation.

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11. The proposed licensed limit on canbined experiments (: 53.54) or '

the current licensed limit (= 2.3:ak/k) could cause melting of the fuel cladding.

12. Removal of a beam tube could cause insertion of excess reactivity into the reactor because neutron absorption would be removed and reflection savings would be increased.

13. Applicant has violated excess reactivity limits suggesting it is impossible to prevent possible excursions, 14 Applicant failed to analyze the possibility ofqadt q.LMc-

f c melting.

VI. Applicant has in the past and is at present emittinc excessive radiatien, violating radiation standards, and conducting inadequate monitoring.

Applicant has failed to demonstrate in its application or in its recent perfomance any evidence that these conditions can reasonably be expected to improve in the future, in the absence of which demonstration, grant of an operating and Sim license cannot be made without undue threat to public health and safety. Specifically:

2. Several conditions which cause present emissions to be in excess

, of applicable standards have not been changed; therefore, emissions which are in excess of applicable standards can be expected in the

,fu tu re .

3. Applicant has not in the past nor in the present application been able to reasonably demonstrate that exposure in unrestricted areas is not in excess of applicable standarcs because it lacks an ace-quate radiation monitoring system.

4 Applicant has not complied in the past and presently doe' not comply with the radiation standards in 10 CFR li 20.lc, 20.106(b)(1) and (2), 20.106(c), and Part 20, Appendix B.

l l 5. Applicant does not now, has not in the past, nor can it re. scaably

( assure that it will in the future meet the requirements of section V.d of its current technical specifications which states that

"[t]he release of radioactivity from the reactor facility shall be kept to as low a level as practicable."

VII. The reactor has in the past experienced a persistent pattern of numerous unscheduled shutdowns, abnormal occurrences, and accicents. These occurrences are so pervasive that they avince a pattern of unreliability ~

which makes it impossible for Applicant to reasonably assure that the reactor can be operated in a mariner which does not endanger the public health and safety.

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VIII. The analysis of an accident ar.d the calculations regarding the resultant radiation exposure to the public contained in the Applicant s Safety Analysis Report is based on unrealistic assumptions which tend to minimize the expected public exposure. However, despite the minimi-zation of the hazard the conclusion of the analysis postulates an unacceptably high public radiation dosage of 1800 rems thyroid.

1. The safety analysis is flawed because

a. Applicant assumes a release limited to only 10% of the volatile fission products and none of the non-volatile products,

b. Applica?1 essumes the reactor has been operated at 10 r.w long enougn to have attained equilibrium concentrations of relatively short-lived fission products,

c. Applicant assumes the reactor is in a two-story building with possible exposure to the public occurring outside the building,

d. Applicant assumes a building leakage rate of 20% of the reactor room volume per hour for a 30 mile per hcur wind, assumed to be directly proportional to wind velocity, and

e. Applicant has not adequately tested the assumptions upon which the analysis is based and failed to include a current review o'f nuclear safety literature regarding dose and dispersion models.

IX. The Appifcant in the past has not adequately maintained its equipment nor calibrated its instruments properly, thereby increasing the chances of equipment failures and erroneous ins trument reading. Due to this failure, the NRC cannot conclude that the issuance of a license for this facility will not be inimical to the public health and safety.

Specifically:

1. Applicant has failed to calibrate instruments at the required inte rvals.

2. Applicant's personnel are not familiar with the calibration requirements of their own technical specifications.

3. Applicant has failed to maintain, or has lost, calibration records, making accurate calibrations and data interpretation .

impossible.

4 Applicant has significantly underestimated radioactive enmissions for extensive periods of time due to errors in its calibration i

me thods .

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Applicant has had continuing problas witr heat balance cali-bra tions.

6. Applicant has not devoted adequa te time to maintenance and calibration.

X. The relicensing of the UCLA n~ 1 ear reactor is a major Federal action which will significantly affes. the quality of tne human environment.

Therefore, an Environmental Impact Statement must be prepared by the NRC. There are suitable alternatives to the operation of this reactor which would not involve a significant impact on the environment.

2. The relicensing of the llCLA research reactor will significantly affect the quality of tne human environment because

a. A design basis accident at the resctor is likely, . would expose great numbers of people to dangerous radiatn.

dosages.

b. The reactor is located on a densely populated campus with classroom and office facilities enveloping the reactor build-ing on three sides and above the building.

c. The reactor 'acks inherent and engineered safety features, including the lack of a containment structure.

d. A design basis accident is 1.ikely because of the reactor's use as a training facility and because of the history ot' lax administrative controls, abnomal occurrences, unscheduled shutdowns and minor accidents.

e. The facility is sits! in a seismically active area and suf-fered significant damage ir the 1971 earthquake.

f. The facility utilizes highly enriched (93%) fuel and is vulnerable to criticality accidents.

g. A design basis accident would esult in fission product

, releases in amounts that would endanger the public healt..

and safety.

1 Therefore, he NRC must p'repare an EIS which considers the fol-lowing alternatives:

k a. Training, reraarc' ano education could all be accomplished at other exie, ting facilities lor.ated in southern California. .

' b . The reactor could be Jsed as a simul & tor Withcut fu21 for k the training of reactor operators.

c. Commercial users of the reactor could rent reactor time at other facilities in souchern California.

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f. The benefits provided society by the reactor do not outweigh

/ the costs of c,perating the reactor becadse ~

a. Only a very small percentage of the reactor operating time is devoted to training operators and educating students.

[ b. Most of the important and significant research done at UCLA

% which utilizes nuclear reactors is accomplished at other q facilities.

c. The research that is done at this facility could be accom-plished at other facilities in southern California.

d. A major percentage of the reactor operating time is devoted to commercial projects for paying customers.

e. The reactor costs the Universit' over $150,000 to operate and would cost over $750,000 to decommission in 1980.

f. Over the proposed twenty year license period the beneficial uses of the reactor are likely to decline while the risks and costs associated with its operation are likely to increase.

II. The safety features of the UCLA reactor are inadequate to protect the public health and safety. Certain engineered safety features are lacking; particularly lacking are features that are redundant and independent. Specifically:

1 The reactor is surrounded by a housing rather than by an adequate containment structure. -

2. The high level radiation monitor system which activates the' scram system is inadequate.

3. 5e' reactor does not have an adequate boron-injection system, a radioactivity removal system, emergency liquid and gaseous emissions holding tanks, HEPA filters, an emergency core cooling system, or spare control blade motors.

4. The reactor lacks adequate shielding ard access restrictions in areas where the public might be exposed to radiation.

5. The reactor has inadequate or non-existent interlock systems.

6. The reactor lacks missile shields, particularly for control blade drives.

7. Graphite used in reactors undergoes physical changes and thus ~

potes a hazard. -

8. The reactor has e history of fuel failures, particularly tie bolt failures.

9. The reactor's control blades are inacequate.

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XIII. The infomation which Applicant has provided regarding the special nuclear materials license is inadequate to meet the requirements of 10 CFb70.22(a)(7) and (a)(8) and 70.24(a)(1), (2), and (3)./ FurtheD5

. more, the enrichment level requested and the quantity requested of U are excessive and thus pose an unnecessary threat to public health and sa fe ty.

XIV. Applicant in its Safety Analysis Report has failed to analyze problens connon to Argonaut ty;ed reactors. In the absence of such an analysis, Applicant cannot reasonably assure that the operation of the reactor will not endanger the public health and safety.

XV. The operating license for this facility shouWnot be renewed because 9 the adverse consequences which flow from,1ts location and siting are too great. The following circumstances have' exacerbated the adverse conse-

<- quences of a facility accident and,of nomal operation. S;ecifically:

1. The density of the population in the unrestricted area immediately surrounding the reactor and within a ten mile radius of the reactor makes the protable consequences of an accident at the facility unacceptably great. This population density has increased grectly over the past twenty years.

2. The reactor building which was originally separated from any other structures is now enveloped on three sides and above by clysroom and office buildings. .These buildings house a large population during working hours in close proximity to the reactor.

3. The heating, air-conditioning, and air-flow systems of the new buildings enveloping the reactor building interface directly and indirectly with those systems at the reactor facility.

XVI. The UCLA reactor and the principal component pieces of reactor equipment are so old that relicensing the reactor, particularly for a twenty-year period poses an unacceptable hazard. Because of the age of the reactor it is very diffierlt to obtain spare parts and key safety features required of near facilities--specifically, an emergency core cooling system and a containment structure--are lacking in this facility. In addition, the following items of equipment are unreliable, difficult to repair and/or replace: reactor instrumentation and console instrumenta-tion.

1. The reactor was built in 1959 by a conpany whien is no longer in .

the reactor business.

khe raactor equipment is old and outdated and deteriorating. The Applicant has not devoted the money to properly update or maintain the equipment in the past and without a change in Applicant's practices the equipment will continue to deter 1 orate with age.

X7II. The UCLA reactor should not be licensed because the physical location

- and site characteristics of this reactor unacceptably endanger the public health and safety. A rthernore, the license application does not con-

. tain current info =ation and analysis conceming the site related safety problems sufficient to support the issuance of a licence. Specifically:

1. The reactor is located on one of the most seismically active regions of the country.

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3. The reactor sustained significant damage in the 1971 earthquake.

4. The existence of three floors of classrooms and offices, supported on columns, directly above the reactor structure creates a signifi-cant danger of collapse through the reactor building roof and onto tne reactor itself in the event of an eartgquake.

5 The application does not centain the current info m ation on siting required by 10 C7R 50 34(b)(1).

XVIII. The Applicant does not possess and cannot give reasonable assurance g of obtaining funds sufficient to cover the costs of operating the v facili ty. Given this lack of assurance, Applicant fails to qualify financially for an operating license. Specifically:

1. Applicant has deferred maintenance in the past due to lack of funds .

2. Applicant, as a public institution and subject to yearly funding, cannot reasonably assure that it will obtain sufficient funding for operation of the reactor frcn year to year.

3. If Applicant, as contended by Intervenor, is operating a facility described in 10 CFR 50.21(b) or 50.22, Applicant has not met the recuirement of 10 CFR 50.33(f) that: Applicant poesess or have reasonable assurance of obtaining the funds necessary to cover the estimated cost of operation for the license period, plus the estimated cost of pennanently shutting down the facility and maintaining it in a safe condition.

XIX. The Application's Safety Analysis is flawed because it does not include an analysis of the 'nax1=us creditable accident' or a

' design basis accident'. In providing such an analysis the fol'owing hazari scenarios for the facility have not been considered, j

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1. Sabotage, such as explosives being thrown at or placed on the reactor itself, causing major damage and broken fuel plates, i

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Airplane c. ash such as a DC-10 or Boeing 747 scheduled to arrive

@ at LAX or 3 trbank airports crashing into the reactor room, or into the void art.a above the reactor, causing the building or portions thereof to collapse breaking apart fuel assemblies and releasing radiation.

3 M.titiple failure modes-- worst possible series of events.

4 Operator error which leads to design basis accident.

XX. Applicant has in the past and is at present taking inadequate fixed site physical security precautions to protect against radiological sabotage as well as protection against theft and diversion of the special nuclear materials it possesses pursuant to 10 '.:FR 73 60 and 73.f7, thus indicating that the Applicant's physical security plan is inadequate and its inplementation of said plan is inadequate. Applicant has failed to demonstrate in its ref e :t perfor=ance any evidence that its physical security measures can r==sonably be expected to improve

in the future, in the absence of which demonstration grant of an oper-at.tng license and a SNM license cannot be made without undue threat to puilic health and safety.

1. Applicant has at its facilities areas containing vital equipment and special nuclear materials, areas which should be adequately protected against possible acts of radiological sabotage or attempts at theft or diversion of SNM, and to which access should be adequately controlled. Specifically:

a. the reactor room,

b. the control room,

c. the third floor equipment room,

d. the fresh fuel storage area, and

e. the " restricted area" immediately surrounding the reactor stack and exhaust fan on the eighth floor of Boelter Hall.

2. There exist areas adjacent to the above-mentioned vital and material access areas which should be sufficiently isolated and secured to prevent them from being used as penetration points or staging areas for penetration of the vital and material access areas.

Specifically:

a. The " access court" used for truck loading and unloading, located between the reactor building and the Engineering Building to its west,

b. the Tokamak lab adjacent to the reactor room,

c. the main entrance (reception lobby) to NEL,

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d. the presently unrestricted roof areas of Boelter and Math Sciences adjacent to the " restricted area" around the reactor stack,

e. the roms within Math Sciences whose windows open to the

" restricted area" around the reactor stack, and

f. the entryway for the single locked door to the "restr1cted area" around the reactor stack.

3. Applicant's physical security measures for its vital and material access areas and the areas adjacent to them have been in the past and are at present inadequate to properly protect, isolate, and centrol access to these areas in that

a. presence by guards and watchmen is too infrequent;

b. methods fce detecting concealed guns, explosives, or incendiary devices tnat could be carried by people enter-ing these areas, and SNM that could be carried by people leaving these areas, are inadequate;

i. Applicant lacks mechanical devices to detect firee ms, explosives, incandiary devices, or SNM and

11. Applicant fails M routinely search visitors and staff for fireanus, explosives, incendiarf devices, or SNM

c. physical barriers to penetration are inadequate;

i. fences and walls are too short, lack barbed wire at the top, and otherwise fail to fully enclose the area to be protected 11, windows and doors in ualls that are u act as physical barriers are made of construction and fastening of insufficier.t strennth such that the integrity of the wall is lessened by the opening provided by the windows and doors 111. dual or redundant barriers are lacking; penetration af these areas can be made by breaching a single ba rrier

d. security measures with regard to keys and locks are inadequate; and ,

i. doors that should be kept locked have been lef t open

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ii. locks are of insufficient construction and strength to prevent tampering and penetration

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iii. too many keys to areas that are supposed to be locked have been given out iv. control of those keys is inadequate in that copies can be made, keys can be lent to unauthori:ed person-nel, and keys that are signed out are not required to be returned when not in use

e. procedures to control access are inadequate, i, groups that are too large for adequate supervision are given tours of the facility by one or two staff people alone ii. these tours 'nclude visits to vital and material access areas iii. NEL personnel unassociated with the reactor have ready access to vital and material access areas through egresses connecting their parts of the NEL complex with the parts of the complex utili:ed by the reactor.

XXI. Applicant's present Ehergency Response Plan is insufficient to denen-strate that the plan provides reasonable assurance that appropriate measures can and will be taken in the event of an energency to protect public health and safety and prevent danage to property.

1. The prohibition against notifying non-university individuals until instructions to do so come from the Campus police unnec-essarily delays energency response.

2. The requirement that the evacuation of Boelter Hall and the Math-Sciences addition be cleared through the Vice Chancellor's office entails unnecessary delay.

3. The plan does not adequately provide for alternative personnel with evacuation authority.

4 The plan does not prov(de for alternative personnel with the autho*ity to carry out the role of Health Physicist, as general director and supervisor of energency response, l .

l 5. Applicant does not have adequate radiation. measuring deviccs to accurately determine the extent and seriousness of an accident which would make the University initiate its emergency response plan.

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6. There is no indication that a viable plan for evacuating the entire campus exists.

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7 The plan does not provide for any emergency centers other than _

the UCLA Medical Center, despite the fact that it might be shut down in the event of a major accident.

8. The plan fails to indicate which equipment and what quantities of it are available at each equipment location listed in the plan.

9. The training exercises and drill specified in the plan are not carried out on a regular basis and therefore the plan will be ineffective in the event of an actual emergency.

XXIII. Applicant, in ics license application has improperly dealt with intended changes to its faility. Speci fically:

1. Applicant improperly relies on an intended future action--

installation of decay tanks--in defense of its ALARA perfomance.

a. Present and past observance of ALARA or other radiation i standards cannot be defended by an action not yet taken.

j} b Promise of intention to reduce the emissions in the future if relevant at all to the issue of license renewal, if cannot be based on an action applicant asserts it intends W

c to undertake in the future but has not yet proposed as an amend.:ent to its license.

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2. Applicant makes statments in its application regarding intended d future actions that are contradicted by the fsets and by each other.

a. On page V/3-11 of the application Applicant incorrectly states that an Amendment will be prepared and rubmitted prior to September 1,1980, to authorize the installation of hold-up/ decay tanks. No such Amendment was subnitteo prior to September 1,1980.

b. The statement on page V/3-11 is further contradicted by a statement on page V/7-1, indicating the preparation of such a license amendmene.will " commence upon receipt of infomation confiming the acceptability of the present appl ica tion. "

3. If Applicant is pemitted t7 rely on future intended actions in defense of a claim that relicensing will not likely lead to emissions unduly hamful to the public health and safety, then all intended future actions linked to the decay tanks should be included, not merely those future actions which might tend to reduce emissions,

a. The intention to increase the reactor use factor which -

Applicant has communicated to the Commission ano public a: being tied into the installaticn of decay tanks, and which would tend to increase emissions.

b. The intention to increase reactors maximum pemitted power, which Applicant has publicly stated its intention to do and which wc"1d likewise increase emissions.

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