ML20030D364
| ML20030D364 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 08/26/1981 |
| From: | Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8109010284 | |
| Download: ML20030D364 (20) | |
Text
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NUCLEAR REGULATORY COMMIT.? ION 5
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 8bbf[b t g.:
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In the Matter of
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Dacket No. 50-142 THE REGENTS OF THE UNIVERSITY ) (Propored Renewal of Facility 11 OF CALIFOR' IIA
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!.icense Number R-71)
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12 (UCLA Research Reactor)
)
August 26, 1981
)
13 14 APPLICANT'S RESPONSE TO INTERVENOR'S 15 UPDATED MOTION TO COMPEL
't G 17 18, DONALD L.
REIDHAAR 19 GLENN R. WOODS CHRISTINE HELWICK 20 590 University Hall 2200 University Avenue 21 Berkeley, California 94720 Telephone:
(415) 642-?S22 22 Attorneys for Applicant 23 THE REGENTS OF THE UNIVERSITY lI OF CALIFORNIA 24 l
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1 Applicant, THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, 2
respo:.ds to Intervenor's " Updated Motion to Compel as to 2nd 3
Set Interrogatorias, as per Board Order of July 15, 1981; and 4
Related Discovery Matters", dated August 10, 1981, as follows:
5 6
I.
INTRODUCTION 7
8 Intervenor served its " Motion to Compel Further Answers 9
from Applicant to Invervenor's Second Set of Interrogatories; 10 and Response to Applicant's Motion for a Protective Order" on 11 June 12, 1981.
Applicant submitted two documents in response 12 to this motion to compel on June 29, 1981:
" Applicant's Respons5; 13 to Intervenor's Motion to Compel and Request for Production:
14
(" Response to the Motion to Compel") and " Applicant's Supple-15 mental Responses to Intervenor's Second Set of Interrogatories" 16
(" Supplemental Responses of June 29").
17 18 By order, dated July 15',
1981, the Board directed CBG 19 "to update its request" and directed UCLA "to inform CBG of 20 its current effort to furnish further information".
In a letter 21 to Intervenor's attorney, d.ated July 31, 1981, Applicant 22 informed Intervenor of the status Applicant's interrogatory responses.
On August 14, 1981, Applicant submitted " Applicant's 23 24 Supplemental Responses to Certain of Intervenor's First and 25 Second Set of Interrogatories"
(" Supplemental Responses of 20 Adgus't 14")..
27 Intervenor indicated in.ts " Updated Motion to Compel" 28 1
1 1
that its request for furtner arswers remains as to the following 2 questions (the relevant contention specified by a roman 3
numeral) :
I.
24e, 26d; II.
4, 4a, 5, 6, 8, 9a-b; III. 43d, 4
LS-57, 59, 52, 63; IV. 22, 24a; V.
13-18; VI. 8c, 23a-b; and 5
Applicant's further response or 6
opposition to the motion to compel any further altswer to each of 7
these questions appears below in the discussion.
In addition, 8
Intervenor in its " Updated _ Motion to Compel" discusses certain 9
other "related discovery matters" to which Applicant responds in 10 the discussion below.
11 12 II.
DISCUSSION 13 14 A.
The Updated Motion to Comoel Questions 15 16 Applicant has responded in detail tc Intervenor's Motion 17 to Compel of June 12 in Applicant's June 29 Response which 18 included responses to all of the questions identified above 19lstillbeingdisputed.
Applicant incorporates herein by reference 20
.ts June 29, 1981 Response to Intervenor's Motion to Compel.
21 In its " Updated Motion to Compel" Intervenor has modified certain 22 of its June 12 arguments pertaining to the still-disputed 23 questions.
Applicant's additional responses to these new 24 arguments appear below.
25 26 Interrogatory No. 24e (I).
Applicant stands by its 27 previous responses.
Intervenor's question (as revised per its 28 latest motion to compel asks what was the original purpose for 2
i
V 1
j 1
"a.
the exhaust stack height, b.
the flow rate out of the exhaust 2
stach (as opposed to capability of exhaust fans)."
3 4
Applicant has..aponded on two previous occasions 5
that the purpose for includi.ng either of these items as " require-6 ments" in the techn*
?. specifications is simply not known by 7
Applicant's current reactor staff.
The current technica] specifi-8 cations were developed, drafted and negotiated with the AEC in 9
1971 by individuals who are no longer NEL employees; indecd, the 10 Director of the NEL at the time the current fschnical specifica-11 tions were adopted is now deceased.
The only current NEL 12 employees who were "around the NEL" at the time these require-13 ments were incorporated into the technical specifications were 14 either students or in subordinate positions.
None had any manage-15 ment reponsibilities nor were involved in any way in drafting 16 and/or reviewing the technical specifications.
17 18 Interrogatory No. 26d (I).
Applicant stands by its 19 previous responses.
The statement in questions was made by an 20 NRC official and intended to apply generically to all research 21 reactors of Applicant's type.
Without conducting any studies or t
l 22 analyses but relying instead on general scientific and engineering i
23 judgement, Applicant subscribed to'the NRC's assessment and 24 repeated the relevant portion of the NRC official's statement 25 in the application.
26 27 Applic_nt has no precise' figures for "the largest 28 fission product release", the " largest possible core damage",
3
f I
nor the extent of a " negligible" environmental impact.
Applicant 2
relied on common 2ngineering sense in making its statement in its 3
May 20 Responses that "in Applicant's judgement even if a severely 4,( destructive earthquake.:were. toccollapse the building and lead to 5
fragmentation of the fuel the fission product release would be 6
far less than that attendant to any hypothetical core melt scenario."
7 Applicant submits that the recently-released "SER" AND "EIA" 8
(NRC) staff documents fully r.upport that judgement as well as the,
9 earlier statement by the NRC official which was repeated in part 10 in the applicativn.
11 12 Interrogatory No. 4 (II).
Applicant stands by its 13 previous responses.
Intervenor claims in its " Updated Motion 14 to Compel", to be confused with Applicant's June 29th explanation..
15 Applicant does not understand Intervenor'a confusion.
16 17 Intervenor's question is "Are supplies and expenses l
18 for the Reacter operation accounted for separate of (sic) s ' :.ii l a r l l
19 supplies and expenses for other functicns of the NEL" (Applicant's i
20 emphasis).
Applicant explained that contract and gran tivities ae
..tg is 21 represent the only " function" for which separat3 22 done.
All other activities of the NEL, including reactor-related j
i 23 and non-reactor-related activities are accounteI for together 24 without any separation of costs; that is, as was said, "there is 25 no more (separately) detailed cost accounting of the non-contract l
I 26 and grant supplies and expenses."
The figures appearing on page 27 I/2-1 of the application regarding the allocation of NEL expenses; i
28 and supplies to the Reactor operation were estimated, ao is stated I
4
~
v 1
on that page of the application.
2 3
Intervenor complains "Intervenor didn't ask. whether 4
contracts and grants are accounted for separately, but whether 5
costs related to reactor are accounted for separately."
" Separate 6
frcm what, then?
If the contract and grant function is included 7
the answer is a qualified "yes"; if the contract and grant func-8 tion is ignored the answer is "no".
Applican'_ does not know how otherwise to explain its anster.
10 11 Interrogatories Nos.
5, 6,
8 and 9 (II).
Applicant 12 stands by its response to these questions.
As Applicant explained, 13 these questions were identical to questions submitted under 14 Contention XVIII (questions 3, 4,
6, and 7, respective;1, of 15 Contention XVIII).
Applicant made particularized requests for IS protective orders as to each of these questions as they appeared 17 in Contention XVIII and directed Intervenor, in responding to 18 each of the same questions as they appeared in Contention II, to "cee" those requests as they appeared for 'the corresponding 19 20 question in Contention XVIII.
Intervenor did not object to Applicant's protective order requests for this questions in 21 22 its Motion to Compel of June 12, 1981.
23 24 Intervenor's sole excuue for notobjecting to these 25 particular protective order requests earlier is, as Intervenor 26 stated (on page ii of its Update Motion to Compel) 27 Intervenor'was unable to "get to" interrtgatories beyond 28 Contention VIII that it felt were inadequate, the burden of 5
1 l
e-1 the discovery problem being too great for a small organization 2
to bear completely."
Apparently, although Intervenor was 3
able to muster the effort to submit over 2,283 questions to 4
Applicant about matters it claimed a need for information it was 5
unable to read, or as Intervenor.put it, "get to" all of 6
Applicant's responses.
Applicant submits that Intervenor has failed l
7 to comply with the procedural requirements of 10 C.F.R. 52.740 (f).
8 9
Interrogatory No. 4 3d, (YII).
Applicant sta nds by 10 the response made in its Supplemental Pesponses of June 29, 1981.
11 12 Interrogatoriys Nos. 59, 62, and 63 (III).
Applicant i
13 stands by its previous responses to chese questions as 14 supplemented herein below.
15 16 In its Updated Motion to Compel Intervenor complains 17 that its review of the document offered by Applicant in response 18 to this question provided "only part of the information requested" 19 and that.
"it is likely that information other than that in 20 the operating log or visitors log is available."
Intervenor 21 asks, in particular, whether " screening" of the visitors was done, i
22 what was the age and educational background of the visitors, what' f
23 was the name of the " tour leader", whether " specific Commission 24 OK" was given and whether " academic credit in a nuclear 25 engineering course was received."
Applicant can state generally; 26 that'for all these visits no formal " screening" of the visitors 27 was done by the NEL staff and that the only " screening" that 28 6
1 occurred was that done by the tour leader (typically a high l
2 s c.. col or college physics teacher) who " selected" tL< studeats 3 in his class who were to attend the reactor damonstration.
4 Applicant can state generally that for all the visits in question, 5
the visitars were high school students, 15 to 18 years of age, 6
or college students.
Applicant can state generally that for each 7
of the visits in question no specific Commission OK's were 8
solicited and none was received and no academic credit in 9
nuclear engineering was given by UCLA to any of the visitors as 10 a result of their attendance at such demonstrations, except for 11 the UCLA Extension Course, Engineering Course 497.17, which was 12 identified in the statement quoted in Intervence 's Interrogatory 13 No. 60.
14 15 Applicant submits that there is no factual dispute 16 concerning these high school or college reactor demonstration 1
17 visits.
Applicant has stated that Applicant does not formally 18 screen these visitors, that during these visits the students 19 were allowed to manipulate the switch controlling the movement 20 of a reactor control blade in accordanco with the specific 21 instructions of the reactor supervisor, and that Applicant 22 did not deck specific Commission approval for conducting these 23 visits in this manner.
According to the interpretation of 24 Commission rules made by Applicant, the practice is not a 25 violation of NRC rules.
The Commission has recently conducted 26 an in'vescigation of this activity of Applicant.
The Commission 27 investigators conc 2.uded that Applicant's actions "may not be in i
28 strict compliance" with the Commissions regulations, but that l
7
I
l 1
- the provisions which apply to these circumstances "are 1
2 subject to differin'g interpretation".
To ensure that 3 Applicant is in strict compliance, the Commission recommended 4' that Applicant seek NRC approval for this practice.
A copy of the investigative report has bean attached hereto as 5
t 1
6
" Exhibit A" and is of fered as ~ additional information relevant to-7 these interroga: cries.
8 9
Interrogatories Nos. 22 and 24e (IV).
Applicant 10 stands by its previous responses to these interrogatories.
Both 11 interrogatories ask Applicant the meaning of a statement made 12 ' in an inspection report by an NRC official.
Applicant's current 13 reactor staff does not know any more about the circumstances 14 of the matter than can be ascertained from the inspection report i
15 itself and since the statements in question were made by NRC 16 officials, those officials only can explain precisely what they 17 meant in those statements.
13 l
19 Interrogatories Nos. 13-18 (V).
Applicant stands by i
20 its previous responses to these interrogatories.
Applicant 21 explained the difficulty it was having with these questions in 22 its June 29 Response to the Motion to Compel, to which the 23 Board is referred.
Applicant adds'only that it does not 24 i intend to make any representations concerning the " physical l
Impossibility", or not, of inserting a certain sample " worth",
25 26 or re' activity, into the reactor.
Applicant's scientific I
27 t and technical staf f are professional enough not to hazard I
J 28 ! comments regarding " physical impossibilities" without having 8
9 s
I conducted a Study and performed the calculationc needed to 2
respond with confidence.
Such studies have not been conducted 3
nor have such calculations been performed.
The answer to such 4;, speculative, questions is not in anyway relevant to Applicant's 5
prosecution of its license renewal application.
6 7
Intervenor, in its Updated notion to compel, stated 8
that its question goes to the " size limitations" of the 9
pneumatic system " rabbit ~.
At an earlier document examination i
10 session Applicant presented Intervenor with a sample " rabbit" is (the small cylindrical plastic container used to transport 12 samples to the reactor).
The volume of such a cylinder is given 2
13 according to the following formula, V =7f r h, where r is the 14 radius of the cylinder and h is the height of the cylinder.
In 15 the extreme case, the " size" may be considered to equal the 16 volume.
Intervenor can perform the required calculation.
17 18 Interrogatory ?:3. 8 (VI).
Applicant's previous 19 response to this question is correct and complete.
Respecting 20 the "TLD" data, Applicant's staff concluded that the TLD's 21 were " reading" radiation from the concrete structures although 22 at the time that conclusion was drawn (expressed on Page V/3-1 23 of the Application) Applicant's staff had not designed nor 24 conducted any study nor analyzed any data which would have 25 confirmed that concrete was affecting the readings.
26 27 As Applicant stated in its May 20 Answers, a new TLD l
l 28 i program has been undertaken.
Although the program is not yet complete, the memorandum and accompanying attachments which-i 9
L
l i
1 have been attached hereto as " Exhibit B" provide an update 2
on those TLD results.
3 4:
Interrogatory No. 21 (VI).
Applicant's response to this 5
interrogatory appears in its Supplemental Responses of August 14.
6 7
Interrogatory No. 7e-h (VIII).
Applican; stands by its 8
Previous responses to this interrogatory.
9 10 In its Updated Motion to Compel Intervenor requested:
11 "If Applicant, however, doesn't have relevant information, it 12 should simply say so clearly."
Applicant does not have relevant 13 information.
However, in February 1980, Applicant contracted 14 to have run a computer program called ORIGEN.
The program l
15 calculates fission product and actinide activity as a function 16 of fission rate and time.
The program was run for 2.5kw steady 17 state operation for twenty years.
The results of this calculation l
18 verify the steady state iodine in.ventory quoted in Attachment B j
\\
19 of Applicant's license application.
The program was also run for!
20 the above conditions plus an eight hour run at 100kw.
The 21 computations are available, but the results of these compator 22 runs do not provide answers to any parts of Interrogatory No.
7.
l 23 24 Interrogatory No. 18a-h (VIII).
Applicant stands by its 25 previous responses to this interrogatory.
Applicant has not 26 had an opportunity to analyze the "Battelle" study and does not 27 intend to redo that study.
However, Applicant has full 28 confidence in the technical and scientific judgements and 10 l
I l
I conclusions made by the Battelle group in the study.
1 2
3 Interrogatory No. 19 (VIII).
Applicant stands by its 4
previous response to this interrogatory.
5 6
Interrogatory No. 30 (VIII).
Applicant stands by its 7
Previous responses to this interrogatory.
Applicant does not 8
know on what basis the analyst who wrote the 1960 Hazards 9
Analysis arrived at his leak rate estimates.
10 11 B.
Related Discovery Matters 12 13 Intervenor has requested th.at it be provided an opportu-14 nity to serve follow-up interrogatories to certain of Applicant's 15
" supplemental responses", and to certain of the documents 16 Produced by Applicant subsequent to the time Intervenor submitted 17 its June 10 " Third Set" (follow-up) questions.
18 19 Applicant has no objection to responding to such follow-20 up questions provided such questions are in fact " follow-up" 21 questions and not questions designed to further broaden the 22 scope of Intervenor's inquiry.
Applicant does request that all 23 parties consolidate all follow'up questions to be asked in a 24 single document which once submitted will constitute the last 25 set of interrogatories a responding party will have to answer.
26 27 28 11
1 III.
CONCLUSION 2
3 Applicant has responded above to each of the outstanding 4
questions identified in Intervenor's Updated Motion to Compel.
5 Applicant's responses serve to further explain and clarify 6
its previous answers and in several cases to supplement its 7
previous answers with recently acquired information.
Applicant 8
submits that with this effort Applicant's responsibility to answeg 9
Intervenor's second set interrogatories has been fully discharged.
10 11 Responding to a related discovery matter, Applicant 12 has requested that the Board direct all parties'to consolidate 13 all follow-up questions in a single document.
14 15 Dated:
August 26, 1981 16 s
17 DONALD L.
REIDHAAR IO GLENN R. WOODS CHRISTINE HELWICK 19 20 By/
/,
A 21 William H. Cormier UCLA acpresentative 22 THE REGENTS OF THE UNIVERSITT 23 OF CALIFORNIA 24 26 27 28 12
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EXIIIBIT A p we.
o UNITED STATES m g,j NUCLE AR REGULATORY COMMISSION
- g'g(44.4 7 gQgfgj HEGION V o,
1993 N. CALIFORNI A COULEVARD C
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SUITE 2C2, WALNUT CREEK PLAZA WALNUT CR EEK, CALIFORNI A 94500 July 28, 1981 Docket No.
50-10 University of California at Los Angeles Los Angeles, California 90024 Attention:
Walter F. Wegst, Director, Res ath & Occupational Safety Gentlemen:
5"hject:
fiRC Investigation of Manipulation of Reactor Controls by fionlicensed persons.
TV ; refers to the investigation conducted by Messrs 0. C. Shackleton Jr., and A.D. Johnson of this office on June 10, 1981, of activities authorized by flRC License I;o. R-71, and to the discussion of our find-ings held by Mr. Johnson with Mr. Ostrander and other members of your staff at the conclusion of the investigation.
Areas examined during this investigation are described in the enclosed investigation report. Within these areas, the investigation consisted of selective examination of records, interviews with personnel, and observations by the investigators.
We have evaluated the circumstances and management controls that existed in the past wherein high school and other students had been permitted to manipulate the switch controlling movement of a reactor control blade.
We have concluded that your actions may not be in strict compliance with flRC rules and regulations.
lhe provisions of 10 CFR 50.54(i), 55.9, and 55.4(d), which apply to these circumstances are subject to differing interpretation.
Manipulations of a reactor control blade by individuals not exempt under 10 CFR 55.9 with only general supervision but without direct specific instructions from a licensed operator would be deemed a clear violation of !!RC rules. We recognize that specific direction to the high school students was provided by a licensed operator in the programs you have conducted in the past and discontinued about 1 1/2 years ago.
lievertheless, to assure strict compliance with flRC rules and regulations, we believe you should seek l-iRC aporoval for your educational or other programs wherein unlicensed individuals may manipulate reactor controls under the direction of licensed personnel and may r.ot be speci-fically exempt pursuant to 10 CFR 55.9.
WLGSl 9 c%cj
2_
In accordance with 10 CFR 2.790 of the Comtaission's regulations, a copy of this letter and the enclosed investigation report will be placed in the NRC's Public Document Room.
If this report contains any information that you believe to be exempt fro:n disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within ten (10) days frcm the date of this letter of your intention to file a reqJest for withholding; and (b) submit within 25 days from the date of this letter a written application to this office to withhold such i n forma tion.
If your receipt of this letter has been delayed such that less than seven (7) days are available for your review, please notify this office promptly so that a new due date may be established.
Con-sistent with section 2.790(b)(1), any such application must be acccmpanied l
by an affidavit executed by the owner of the information which identifies the dccument or part sought '.o be withheld, and which contains a full statement of the basis on which it is claimed that the infomation j
should be withheld from public disclosure. This section further requires
~
the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4).
The information sought to be w#thheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified periods noted above, the report will be placed in the Public Document Room.
Should you have any questions concerning this investigation, we will be glad to discuss them with you.
Sincerely, f
/
I 7 A f
V
/
A. D. John on Director /stigations 4
Enforcement and Invt cc:w/o attachment Dr. 1. Catton, Director, UEL, UCLA f
U.S. t:UCLEAR REGULATOP,Y CO NISS10tl 0FFICE OF If;SPECT!0:1 AfiD El:FORCEMEliT REG I O:1 '.'
Report f!o.
50-142/81-01 Docket tio.
50-142 License i;o.
R-71 Lafeguards Group Licensee:
University of California at Los Angeler, 1
Los Angeles, California 90024 facility llame:
UCLA Research Reactor (100 KW Arconaut) l Investigation at:
fluclear Energy Laboratory, Boelter Hall, UCLA Investigation condacted:
Juny10,,/981 f Investigat [ ors
/.. /}f' e f lpt
___ ]
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mv y
0.C. Shackl C~~ r.,'a c n i o r Investigator Da Jigned f
D.
b v/W P' /.lL/
f/
n[ Director, ldte Signed A.D. Johnso/& Investigations Enforcemer;t Date Signed l
o Approved By:
[ e[
M A.D Johnso Director a'te Signed En arceme
& Investigations Sum ry:
Investigation on June 10, 1981, Report tio. 50-142/81-01 Area Investigated:
t;onroutine announced Investigation of circumstances surrounding manipulation of the control of the fe~ actor regulating blade by unlicensed science students not enrolled in nuclear engineering courses and by Utility Company personnel in training for Operator licensees for nuclear power plants.
The investigation involved 12 investigator hours on site by two investigators.
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pETAll.S 1.
Persons Contacted _
Dr I. Catton, Director, fluclear Energy Labor tory Mr. t;. Ostrander, Manager, flEL Mr. A. Zane, Reactor Supervisor l'r. C. Ashbaugh, Senior Operator fir. W. Cornier, Counseler,-At-Law 2.
Backgrunj Region V staff members were made aware that during tha current licensing proceeding before the Atomic Safety and Licensing Coard for the relicensing.7f the research reactor at i!CLA, the intervenor, Ccmmittee to Bridge tne Gap, propounded interrogatories dated
-il 20, 1981, concerning operation of the reactor by unlicensed individuals.
The licensee responses to the interrogatories affinned that unlicensed individuals had manipulated the reactor controls.
The pertinent interrogatories and licensea response follow:
In terroga tory "54.
On page 16 of the flEL Annual (Specialized Activity) Report for 1976 it is indicated that a group of students frcm Culver City liigh School were able to come to UCLA to individually operate and observe the UCLA reactor...
"c. Did any of thesc visi tors wi th or without supervision, manipulate the controls of the reactor during this visit...
lieE n_sj; "Yes "e.
If the answer to c. is yes, precisely which controls were manipulated and precisely which reactor operations were manipula ted.
If power or reactivity was altered by the visitor, please specify the range of alteration...
Response
" Control rods were manipulated.
See the operatino logs and strip charts.
"j.
Please specify the age and educational background in nuclear engineering for each visitor who operated the reactor...
Response
" Age 16 to 18 years, high school physics students with previous orienta-tion in nuclear reactor physics."
-3 Interrocatory "63.
Does applicant content that in,tances in which visitors such is the high school students from Culver City High School manipulated the reactor controls did not constitute unlicensed operation?
If so, please detail all facts in Applicant's possession which support such a contention.
Resconse "Yes; in all cases applicant's licensed reactor operator is deemed to have operated the contrcls of the reactor."
In view of the above, the investigators visited the subject facility on June 10, 1931, to obtain the facts and circunstances relating to manipula-tion of reactor controls by unlicensed persans 3.
Maniculation o# 9eactor Control by unlicensed persons.
Accordir; to the licensee representatives, one of the primary purpose, of the reactor at UC A is for use as an education tool to interest students and teach them the principles of nuclear ptsics, engineering, reactor operation, and associated subjects.
70 further this purpose, the licensee explained that the university cooperatas with other colleces in the area by providing instruction at the laboratory in the control of radiation, and the theories and principles associated with the controls of nuclear reactors.
In addition, instruction had been provided to employees of utilities that were in training for reactor operator licenses for nuclear power plants.
Also, to entourage high school students studing physics and interested in nuclear enerny, the Licensee had provided a half day indoctrination type tour where these special students received lectures in control of radioactive waste, radiation, and reactor operations.
As a part of the instruction given to the special students the irstructor, an NRC senior licensed operator, demonstrated how the reactor power level was increased and decreased by requesting each student to sit at the reactor control console while the reactor was operating. Af ter questioning and receiving appropriate answers from the student on how to increase and decrease the power level, t
the instructor would direct the student to depress the appropirate spring return switch to either withdraw or insert the reactor control blade.
Upon reaching a predetcmined rod position the instructor would direct the studer.u to release the control switch.
Af ter completing the foregoing exercise the student would then discuss what had occurced.
Each student was thereaf ter given the opportunity to nanipulate the control switch for the control blade in the foregoing described manner. According to the instructor, the :ndividuals, especially the high school physics students, had participated in the exercise with enthusiasm.
-a-The records of reactor operations were examined for the years of 1977 thru 1931 to the date of the investigation.
Entries in the records show that the cost recent hich school physics class permitted to ranipulate the reactor control blade was on May 18, 1979.
The licensee representative stated that the practice was discontinued in early 1980 when questions arose within the staf f of the UCLA t;uclear Energy Labora t sry as to whether the practice of allcwir.g high school students to manipulate the control switch was in ccm-pliance with MRC rules and regulation.
The Senior Operator / Instructor contended that the provisions of 10 CFP 55.4(d) permitted the practice.
Other nembers of the staf f agreed, but were unsure of what NRC's interpretation of the orovision would be.
the prcvision relied on by the Senior Cperator reads:
"Cperator is any ir.dividual who nar.ipulates a control of a f a cili ty.. An individual is deemed to manipulate a control if he directs another to nunipulate a control."
4.
Exit Interview The Investigators net with Messrs Ustrander, Zane and Cormier at the conclusion of the investigation to discuss the scope findings of the investigation.
The licensee representatives stated that thc program involving high school physic students would not be reinsti-tuted until the legal aspect of the matter was clarified. The investigators indicated that the licensee's program involving utility personnel and students from other colleges and universities appeared to be pernitted by the provisions of 10 CI R 55.9, Exemption Fron License.
1 LOS ANGELES: SCHOOL (W EN GINEERING AN D APPLILI) SCIENCE EXHIBIT B MEMORANDUM 21 July 1981 T0:
W. F. Weast, Director Office of Research and Occuoational Safety 112 Pp3 FR0":
N. C. Ostrander, Manager Nuclear Energy Laboratcry 2567 Boeiter Hall SUBJ:
Update on TLD Results We now have three calendar quarters (9 ronths) of TLD results and snould think about a continuation, possible imorovinq the program. The available results are summarized in the attached table.
'uring the first quarter, locatico 4 was considered to be a possible control (backgrour.d) location, and the TLD there (#7) was placed on the top surface of an upward facing lead brick. The reoorted value was indeed low, less than the Sunnyvale reference control.
In the second quarter, the use of lead bricks was extended to locations A, B, D, and E.
During the second quarter, the lead brick and TLD at location N were lost / stolen, and the TLD at location E was not reported by the vendor.
For the third quarterv the lead brick was replaced at station N.
It was acain stolen, but the TLD had been discarded and was found at a dif ferent roof level some distance from the desired location. The reported value of 7 mR has no meaning in view of the uncertain history of location.
The location was abandoned at the start of the fourth quarter.
The data indicate that the use of lead bricks substantially alters the total dose received by TLD's and cJds weight to our earlier statements that concrete is a source of radiation. TLD locations 0 and P were remote from the reactor, within parking structures, and positioned in corners so that the TLD would "see" concrete over at least 37 steradians. The effect is pronounced.
In an earlier, unfinished version of this memorandum, the TLD data were adjusted upward by defining background as the lowest value recorded by any dosimeter regardless of location.
As you noted, this does bias all of the data upward, and I have returned to the original use of RDC Lockground.
The tabular data here are restated based upon RDC backgound. All negative values are reoorted as zero.
The table identifies TLD iocations by a mnemonic as well as by range and and azimuth.
The three entries represent thr readings 'or successive calendar quarters, special symbols are used to indicate unreportable or suspect (perturbed) situations.
Separate columns are used to identify those TLDs counted on 2 inches of lead. All were upward facing on top of the brick.
1,OS ANGE!J5: SCitOO!.0F FNGINFE! LING AND APPf, LED SCIENCE Ostrander to Negst, 21 July 1981 Page 2 Locations F, A, C, G,it, I, and fi, closely raplicate locations used in the 1976-1978 nrogram. The only marked change is the single value at location N where a lead brick had not been used oreviously.
The new observations do not apoear to reflect the current 33*., increase in reactor usage over that of the earlier program (currently 20.0 ISth/hr versus 15.0 Mwh/yr rate for the 1977-1978 period).
Cc? es of the three RDC recorts are attached i
Attachment:
Reports (3) by the Radiation Detection Company esseeg r e n c ae v rier to g t ro n eg, g a g,,,,,%,,,8 f ae laime*8eneef =ea t el use l
I S&iMRY OF TLD OBSERVATIONS / AW/JST 26, 1930 -
l I
n R (EAOi QUARTER)
AVERACE LOCATICN DIST/DIR g, p 3,
. r / p ti 19 7r,. _19 7 3 F
NEL STACK 0
12/12/10 11.6 i
A MSA 9318A 47/000 06/--/--
--/00/00 6.0 B
MSA 9318A 50/020 05/--/--
--/00/00 Of /Of+/Of*
'#. 5 7f/029 i
C tiSA VENT. ItJAKE i
D MSA 9318C 111/051 05/--/--
--/00/00 E
MSA 9318C 102/058 06/--/--
--/NR/00 l
H
- 1SA 9318D 98/070 03/Of+/Of+
f f.4 i
G rs:i WINDSCREEN 33/180 03/04/03 Sf/14R 06/06/04 fe.6 M
BH 8500
(
t L
LIB. COOLING TOWER 165/110 04/Ofe/03 K
PLNETARIUM 166/092 05/05/04 I
MS MET STATICf1 183/063 02/05/05 3.8 J
MS EAS? END 353/086 03/03/02 N
KNUDSEN 4ALL 760'956
--/--/--
00 /t P /tto 3.9 d
PARKING STRUCT, 3 3040/022 20/16/15 P
PARKING ' TP.UCT. 5 1690/006 21/19/16 DIST/DIR = DIS.V'CE FROM STACK IN FEET NJD AZIMUTH MEASUREC CLOCKWISE FRCM 140RTH (IN DEGREES').
NR = NOT RECOVERED OR NOT READ MO = MOVED, HISTORY UNKNOWN
1
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t 62 Wdfc Read
- P O. 80v 1414
- Sunnyva'e, Calfornia 94C88 * (408) 735 8700 Account Number 9108 Samples Recd:
December 5, 1380 Samples Read:
December 12, 1980 UCLA Nuclear Energy Lab.
2367 30elter llall 405 Hilgard Ave.
Los Angeles, CA 90024 Atta:
Jack Horner, Health Physicist ENVIRONMENTAL TilERMOLDiINESCENT DOSIMETEY REFORT Exposure Period:
9/01/80 - 11/31/80 Sample No.
Obs.
Av3 Ey osure, mR RDC Bkt.
Net 1
4.81, 4.97 4.S9 4.04 0.85 6
5 2
4.69, 4.78 4.73 4.04 0.69 C
4 3
4.75, 5.14 4.94 4.04 0.90 0
5 4
4.36, 5.19 5.02 4.04 0.98 6
6 5
4.61, 4.49 4.55 4.04 0.51 H
3 6
4.14, 4.67 4.40 4.04 0.36 1
2 kno 6 a.Aad 7
3.18, 1.46 1.32 4.04
-0.72 N
0 6
S 5.05, 4.94 5.09 4.04 1.05 gA 4.76, 4.42 4.59 4.04 0.55
~*, 6 3
10 5.12, 5.09 5.10.
4.04 1.C6 tM 6
11 5.18, 4.62 4.90 4.04 0.86 oK 5
a 12 4.83, 4.45 4.64 4.04 0.60 L
4 13 4.18, 4.15 4.16 4.04 0.12 7
0 14 6.10, 6.G~
6.12 4.04 2.08 F
12 Fu Phun f a.),4,,3 15 7.22, 7.59 7.40 4.04 3.36 0
207 21} is. w 16 7.82, 7.30 7.56 4.04 3.52 P
_TLD Type RDC__ Sk g.
Calibration Factor CaSO4: Dy 8/21/80 4.04 5.99 Precision: + 2 tR or 10%
Calibrated to Co-60 s
NU' b.
N
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Llij R AD!AYlON DEYECYiON COh1PANY lf / 162 *,.'c'fe Road P o. com 1414 Sunnfvale. ca!;fornia 94088 - (408) 735 8700 ' ?./ .a# Account tiumber 9108 i,0 k, p /) L,(' Samples Recd: March 9, 1981 b Samples Read: March 14, 1981 D 4 2 d UCL A t'uclear Energ~" Lab. V, ' ya n 2567 Coelter Hall 405 Hilgard Avenue g Los Angeles, CA 90024 Attn: Jack Horner, Health Physicist ENVIR3.', MENTAL THER"0LUMIf;ESCENT DOSIMETRY REPORT Exposure Period: 12/1/80 - 2/28/81 Sample t;o. Obs. Avc. RDC Bka. I,e t Excosure, n,P, 1 6.74, 6.74 6.74 5.64 1.10 c 4 2 5.61, 5.43 5.52 5.64 -0.12 A 0 3 n, ? 5.64, 4.92 5.28 5.64 -0.36 0 0 5 6.49, 6.69 6.59 5.64 0.95 H 4 6 7.00, 6.72 6.86 5.64 1.22 I 5 8 5.60, 5.30 5.45 5.64 -0.19 6 0 9 6.79, 6.67 6.73 5.64 . 09 6 4, 10 7.34, 7.12 7.23 5.64 1.59 < 01 6 11 6.99, 7.00 7.00 5.64 1.36 .? K 5 12 6.75, 6.69 6.72 5.64 1.08 dL 4 13 6.44, 6.42 6.43 5.64 0.79 jT 3 14 8.63, 8.57 8.60 5.64 2.96 F 12 15 9.27,10.1 9.69 5.64 4.05 0 16 16 10.5, 9.64 10.1 5.64 4.46 P 18 TLD Tyne RDC Bka. Calibration Factor Ca SO,, : Dy 11/20/80 5.64 3.97 Precision: + 2 mR or 10:s Calibrated to Co-60 ttn. 4 N et a ig..d..! tar.1 L od p b b ' NSt)
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g;}/}.; nhD!hTION DETECTION COi,1PhNY u / 162 Wo fe Road a P.O. Co. !414 Sunnyvale catifornia 940ss. (408) 735 87c0 xs,- ~ Account Number 9108 Samples Recd: May 28, 1981 Sam.ples Read: June 2, 1981 UCLA Nuclear Energy Lab. 2567 Boelter Hall l 405 Hilgard Ave. i Los Angeles, CA 90024 Attn: Neil Ostrandar ENVIRONMENTAL THERMOLUMINESCEi:T DOSIMETRY REPORT l Exposure Period; 3/01/81 - 5/31/81 Sample + th. Obs. Avg. UCLA Bkg. Net Exposure, mR 1 3.83, 3.83 3.83 3.83 0 B 1 0 1 2 5.04, 4.84 4.94 3.83 1.11 c 0 j 3 3.99, 3.75 3.87 3.83 0.04 oS O i 4 4.44, 4.00 4.22 3.83 0.39 E 4, o t i 5 5.76, 6.38 6.07 3.83 2.24 H 4 +- 6 6.02, 6.46 6.24 3.83 2.41 1 ' 8-C 7 6.42, 7.36 6.89 3.83 3.06 N 'l l, CD 8 4.34, 4.66 4.50 3.83 0.67 A4 0 9 6.27, 5.27 5.77 3,83 1 94 g6 % 3 a 10 6.05, 6.04 6.04 3.83 2.21 qM 4 4 11 5.91, 6.37 6.14 3.83 2.31 o K 4 12 6.26, 5.49 5.88 3.83 2.05 j L 4 3 13 0.33, 3.43 0.39 3.83 1.56 J '5 ?- 14 7.61, 7.75 7.68 3.83 3.85 F '13.. IO i 15 8.78, 9.64 9.21 3.83 5.38 0 '19-15 j 16 9.61, 9.31 9.46 3.83 5.63 P '19, l 'e i TLD Type RDC Bkg. 3alibration Factor CaSo : Dy 2/23/81 4.89 3.44 4 Precision: + 2 mR or 10% Y T'o. 3,d. O n m1 und _wL { Calibrated to Co-60 8" h'n. o l A l L P,oc. bed M p 7
- O
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Health Physicist JMM/kjg 6/11 $ttVICE 15 OUa P90 DUCT f lm and thermo4m.neuent Ocsieretty'
- X Ear Col.trations
- Red at.on bev.ys
- Heni h Physics Coesul** Fen
- fnvironmee.tal Analyses
- B.oanays
l 1 1 UNITED STATES OF A!' ERICA NUCLEAR REGUI1 DORY CCIMISSION 2 BEEDRE DE A'IU4IC SAFLTI AND LICE!ISING BOARD 3 i 4 In the Matter of ) ) Docket No. 50-142 5 UE REGENPS OF DE UNIVERSITY ) (Proposed Penewal of Facility OF CALI.EDFlIIA ) License Nu:rh2r R-71) 6 ) (UCIA Research Peactor) ) 7 ) 8 CERPIFICATE OF '2ERVICE 9 I hereby certify that mpics of the attached: APPLICANT'S RESPONSE TO INTERVENOR'S UPDATED MOTION TO COMPEL in the abwe-captioned proceeding have been served en tM folicwing by deposit Il in the United States mil, first class, postage prepaid, addressed as in-dicated, on this dato: August 26, 1981 13 Elizabeth Bowers, Esq. Counsel for NRC Staff U.S. Nuclear Regulatory Ccmnission Office of the Executive Icgal Director 14 Atcmic Safety & Licensing Board U.S. Nuclear Regulatory Camtission Washington, DC 20555 Washington, DC 20555-Dr. Dmeth A. Luebke Daniel Hirsch 16 U.S. Nuclear Pegulatory Camtission Ccmnittee to Bridge the Gap Atanic Safety & Licensing Board 1637 Butler Avenue, #230 i 17 Washington, DC 20555 Ios Angeles, CA 90025 18 Dr. Oscar H. Paris Mr. Mark Pollock U.S. Nuclear Regulatory Ccmnission Pollack & Willis I 19 Atartic Safety & Licensing Board 1724 N. La Drea Avenue Washington, DC 20555 Ios Angeles, CA 90046 Chief, Docketing and Service Section (3) Daniel Hirsch 21 office of the Secretary c/o Quaker Center U.S. Nuclear Pegulatory Ccmnission P.O. Box 686 Washington, DC 20555 Ben Lomond, CA
- 95005, 23 24 25 William H. Cormier UCLA Representative 26 27 28
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