ML20052F407
| ML20052F407 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 05/03/1982 |
| From: | Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8205120430 | |
| Download: ML20052F407 (12) | |
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' l NUCLEAR REGULATORY COMMISSION 4 6 9 w 10 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 11 ,
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l'In the Matter of 13 .Ti!E REGENTS OF THE UNIVERSITY )
) Docket No. 50-142 (Proposed Renewal of Facility OF CALIFORNIA ) License Number R-71) 14 )
, (UCLA RESEARCH REACTOR) ) May 3, 1982 15 ___)
16, l . 17 UNIVERSITY'S RESPONSE TO CBG'S MOTION TO COMPEL 18 l
19 20 DONALD L. REIDIIAAR GLENN R. WOODS 21 CIIRISTINE HELWICK 590 University Hal3 22 2200 University Avenue Berkeley, California 94720 23 Telephone: (415) 642-2822 24 Attorneys for Applicant 25' THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 26: -
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. l 1 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA (University) 2 responds to CBG's Motion to Compel, dated April 8, 1982, as 3 follows.
4 5 On November 17, 1981, University submitted to a five-6 , hour inspection and tour of its Nuclear Energy Laboratory (NEL) 7 and adjacent facilities, including the rooftop areas of the -
8 l> Reactor Building, Mathematical Sciences Building and the 9 ; Engineering Building (Boelter Hall) . That inspection was reported ,
lto the Board by letter dated November 23, 1981 (Attachment "A",
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11 ' ereof) . As reported, University representatives were present h
12 during the inspection to identify equipment and controls, to 13 explain the ventilation and air exhaust systems, and to answer 14 uestions. An NRC official was present during the inspection as 15 'an observer. At no time has CBG taken issue with the matters 16 reported in University's November 23, 1981 letter and attached 17 checklist'and map.
18 10 University objects to CBG's-request.for additional 20 inspection on the grounds that any further discovery of this I
l 21 s {ortisnotreasonablycalculatedtoleadtothediscoveryof 22 admissible evidence. Moreover, CBG's September 3 and 11, 1981 23 lequests r for inspection and testing are defective, in part, in 24-}f ailing to specify "the manner of making the inspection and l
25 performing the related acts" as required by 10 C.F.R. Sec. 2. 741(c) .
!I 26 furthermore, submission to any further inspection would un-27fl reasonably hurden University, in light of the very. extensive l
28 discovery that has occurred in this proceeding and, in particular,
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1lthe five hours of facility inspection already provided. Specific I
2 ' grounds for objection are discussed below with respect to the 3 I specific items mentioned in CBG's motion to compel.
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I 5 ]A. Control Panel Equipment b
G 1. CBG claims that it was not permitted to inspect 7[certain items of equipment which it requested to inspect in its I
8' September lith pleading. Unfortunately, CBG's motion is not 9 entirely clear in identifying the items that allegedly were not 10 available for inspection. The motion names some specific items 11 lof equipment, but uses language suggesting that the listing of f
12 lnameditems is not exhaustive. The motion then lists twenty i
13" numbered items (the numbers corresponding to CBG's September llth 14 list of items), which include all thone specifically named as i
15 'well as others. The motion then refers to "the above equipment" 16 without a hint as to whether the non-specific set of named items I
. 17 'or the specific and all-inclusive set of numbered items is 18 intended. Regardless of what CBG int: ended, its claim is based 19 on a misrepresentation of the facts and, as a result, is l
20 ' groundless.
21 l
22 2. University's letter to the Board of November 23, 1981, 23 contains a checklist prepared by the facility manager, who led 24 lthe tour andinspection, of the items that were pointed out and 25 l described during the inspection. CBG has never complained, and ll 26 could not now in good faith complain, that the chocklist is i
27 erroneous. Yet, a review of that checklist reveals that, except 28 for itom 51, all of the numbered items in the instant motion i
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1 (which includes all the items named in the motion) appear on 2 the checklist, indicating 'that these items of equipment were 3 , pointed out for CBG'n inspection. Item 51 (high level radiation i
4 ' monitor) is the same as the item identified in CBG's September lith l
Sjrequest as item 2 (. . . "high level GM radiation stack and area l
6/ monitor"). This area monitor on the east wall of the reactor l
7 room was pointed out to CBG's representatives, who apparently 8 did not recognize that the items were one and the same. Note 9 that on page 2 of University's checklist (Attachment "A", hereof)
I 10 that under item "2" the east area monitor is listed as one of 11 ,the items that was shown. In fact, CBG was permitted to inspect I
12 'every item listed on the checklist which includes every item 13 ; identified in CBG's motion.
14 l; 15 l 3. CBG was not permitted to disassemble'or break down 16 ny items of equipment, nor would University submit to having
. 17 the control console pulled apart to permit an examination of the 18 nterior electronic components. University did unfasten and 191emove one of its rear panels so CBG could observe the type of 20 lectronics that were contained within. University refused to f
21,take apart the other panels not for "no reason", as CBG falsely 22 :las se r ts , but to avoid any unnecessary delays in the inspection, 23 which was eventually to take just over five hours to complete.
k 24 frhis was clearly explained to CBG's representatives and, in fact, i
25 esulted in a brief discussion. But more to the point, CBG's 26 priginal request for inspection and testing (its September llth l
I 27 lrequest) never specified a particular " manner of making the 28 inspection or performing the related acts", as is required by l
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J 1 10 C.F.R. Sec.2.741(c). University met with CBG on several 2 . occasions in an attempt to get CBG to clarify its request. CBG j 3 never suggested that its " inspection" would entail the disassembly i
4 of part of the control console. In this respect the inspection 5 . University.provided is fully responsive to CBG's original
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7 6 September lith request.
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! 8 4. There are other misstatements in CBG's motion that 9 should be pointed out. Contrary to CBG's claim, "the above 10 equipment" was not all contained within the control console.
11 .The dual linear amplifier, for example, was one of the items of 12 equipment that University specifically placed on a bench top to 13 permit a more detailed examination. Moreover, much of item 3, 14 lmost of item 6, and all of items 51 and 75 are not at all within 15 the control console, but are located in the reactor room or other 16 remote areas. 'Also contrary to another CBG claim, the equipment l
i l 17 that is in the control console is not "readily accessible for i 18 maintenance purposes by simple removal of a door-like panel at
! 19 the rear of the console." In fact, the basic items of electronic I
l 20 .cquipment are removed from the console for maintenance from the 21 front of the panel. Finally, despite its suggestion otherwise, 22 :CBG was permitted a detailed examination of the safety amplifier 23 (item 28) , since its interior electronics were exposed when the 24
- single rear panel was removed. Apparently, CBG was totally un-25 !aware of what it was observing despite University's explanations.
26 27 5. It is obvious to University that with respect to 28 the control console electronics, CBG did not always recognize
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I 1 (lwhat was being displayed and did not fully understand what was 2 'being explained. None of 'BG's C representatives appeared to have h
3 'any special electronics knowledge and none exhibited any i
I 4 familiarity with the console equipment being shown. For example, l
Sjthe " strip chart recorders", which open up for servicing from the h
6 ' front of the console, were shown to CBG in the opened-up position.
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Perhaps CBG did not recognize these as its so-called " recording 8l mechanisms for effluent activity". For example, items 21 9 h(interlocks and inhibits) , 43 (control blade logic system),
10 ;70 (bypass mechanism), and 74 (mechanism in inhibit) are not l
11/ discrete items of equipment, but functional names for diffuse F
12(circuitry that is interconnected to several subsystems. For 13 'e xample , item 73 (mechanism for clearing inhibit) is a procedure 14 'not an item of equipment. Item 71 (flourescent light) was shown.
15 It was explained that item 67 (fuse and resister) had been dis-16 carded. Either CBG was not listening during the inspection or it I
. 17 did not understand. In any case, further inspection of these 18 items, as CBG requests, cannot be considered as reasonably l
19 calculated to lead to the discovery of admissible evidence.
I 20 Whether based on deliberate or negligent misrepresentation, CBG's 21! claims regarding the inspection it received are false; CBG's 22 claim for further inspection of the control console lacks all 23 !meri t.
24 !
I 25 B. Areas Inspected
- 26) 1. University permitted CBG to inspect ~all areas of i
27 the Nuclear Energy Laboratory (NEL) that had any reasonable 28 relation to reactor operations. As can be seen from the diagrams !
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1 'hich appear in Attachment "A", the inspection included a tour w
4 2 of the perimeter of the reactor room and the immediately adjacent l.,
) 3 areas of both the first and second floors of the NEL. More 4 remote areas, including the "Tokomak" area, were excluded both l
5 because they are entirely unrelated to research reactor operations 6 and because inspecting all outlying areas would have added I
7 several hours to what was already planned to be a five-hour .
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1 8 inspection. With respect to the "Tokomak" area, an additional I
9 ' concern was not to disrupt the activities of that intense research i
10 activity (fusion physics research) , which takes place under an lllorganizational unit entirely distinct from the NEL. A final 12 ! concern was that certain of the remote areas are high security 13 . areas respecting which no inspection could be permitted. Under 14 .all the circumstances, the areas provided for inspection were
, 15 more than reasonable.
16 17 2. CBG's sole claim for inspection of the remote areas 18 was "to accurately determine dispersion pathways and subsequent l.
19 public doses." However, CBG's postulated radiological releases l 20 and presumed pathways have absolutely no basis in fact. All l
21 studies and analyses which have been conducted of the reactor by 22 the NRC, its contractees and University indicate that the 23; radiological relaase potential of the UCLA reactor is quite small.
24 (Even in the event of the worst accident considered credible for 25 the f acility, releases would not be expected to escape the reactor 2G room itself. ) CBG has yet to provide any credible evidence that I
27 lwouldcontradictthisconclusion.
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- 3. CBG has made no showing that inspection of its 1h 4
2idispersion pathways through the remote areas as it proposes is 3[4 reasonably calculated to lead to the discovery of admissible
- E 4 fevidence . For the inspection it was permitted to conduct, CBG l
5 lused no measuring instruments, made no air volume or flow rate i
6 measurements or otherwise gathered data (other than what was 7 ! observed) that would pennit it "to accurately determine h
8 0 dispersion pathways and subsequent public doses. " CBG's request i
9 lto make dispersion pathway determinations in remote areas is 10 lreally a thinly-disguised attempt to gain access to certain I
11 'of the high security areas of the facility.
I 12 13
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.C . Additional Photographs 14 CBG states that it has records of having taken 217 Il 15Lphotographs during the inspection, although the number of photo-i 1G graphs developed by University is 215. CBG assumes that two 1
. 17 ' hotographs p did not turn out and requests that it be permitted to 18 l retake the missing two photographs and any that did not turn out.
l 10 20 In fact, none of the photographs failed to come out and 21 all are of more than satisfactory quality. University suggests i
22 Jthat CBG may have made mistakes in recording the photographs.
l 23 IJ n any case, the omission of two photographs out of a set of 24 215 (or 217) should not be the occasion for an additional l
25 inspection. University requests that this aspect of the motion 26(be deferred until CBG has had an opportunity to ekamine the h
27 full set of photographs.
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1 jD. TLD and Film Badge Locations I !
2 CBG requested that it be permitted to inspect the
{ 3 jlocation of all past and present thermoluminescent dosimeters ,
! 4 (TLD's) and film badges, including the location of control 5_ badges, placed outside the NEL to monitor releases from that 6 facility. CBG claims that it needs to know the " specific 7 geometry of placement" of those devices "in order to interpret ,
i j 8 'the radiation readings from those devices."
9 i'
10 University objected to the request for several reasons.
11 In the first place, CBG's alleged concern with " specific geometry 12 of placement" suggests that CBG really does not understand 13 precisely how the devices function. The devices are not uni-14 directional; they read from all directions. They intrinsically 15 measure radiation from a variety of sources and do not discriminate.
I 16 against naturally occurring radiation. CBG'sconcernwithpossiblel-17 shielding from the exhaust stack is misplaced. In fact, the j 18 problem is in the other direction. With TLD's, as University has 19 learned from its first TLD program, some shielding (usually lead) l l 20 must be introduced to ensure that the TLD's do not read the 21 l radioactive releases naturally released from concrete for those 22 TLD's that are to be mounted on concrete.
23 24 Many film badges are located outside the NEL, but few 25 are used by the UCLA Radiation Safety Office to monitor for NEL f
26 Ireactor releases. Most of those used to monitor for NEL releases 27:iare located either inside the reactor exhaust stack or inside the l
28 ? air supply shafts of the adjacent building. These are not readily l
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4 1 'acce s sible . A number of film badges located in the adjacent 1
2 laboratory monitor releases from the fusion physics research 3 project and have no relevance to NEL operations. Several film 4 badges have been placed in the offices of individuals in the
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5 ladjacentbuildingsattherequestofthoseindividuals and are
- I G outside the control of the Radiation Safety Office. Except for 7 the film badges located in the reactor exhaust stack, over the
- 8 years area film badges monitoring NEL reactor releases have 9 generally yielded zero radiation readings. For either the TLD's l
- inspecting to determine the precise geometry 10llor the film badges, j 11 of placement will not produce any useful information. Moreover,
- 12 lno readings can be obtained from_a direct inspection of these 13 l devices.
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15 University will have problems in attempting to comply i
1G with CBG's request. The location of all past TLD and film badge I
. 17 sites are known only generally. Sites used in the past have not t l l
18 .been marked and precise locations are not determinable. In I !
19 general, except for the TLD's placed in the immediate rooftop 20 area which are readily observable from the roof, the TLD's are 21 placed in inaccessible locations to discourage any tampering 22 with the devices. To reach these TLD's requires climbing ladders, 23 ascending towers, or rigging scaffolding especially for the 24 l purpose. For general safety and liability reasons University 25 lcannot permit such an inspection. From a single vantage point l
2G 'on the Reactor Building roof top University could point out the l
27 ilocations of nearly all of its currently in place TLD's, most 1
28 of which could be seen from that spot with the unaided eye. Most l
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1 !of the relevant film badges have been affixed to the insides of I 2 air shafts and cannot be directly accessed. Except for pointing 3 I out the locations of TLD's from the rooftop, CBG's proposed
, 4 inspection would impose an unreasonable burden on University's
- 5 staff. In any case, CBG's proposed inspection of the precise l
l 6 placement of TLD's and film badges is not reasonably calculated 7 to lead to the discovery of admissible evidence. -
8 l 9 E. Conclusion 10 For the reasons discussed above, University respectfully f
11 requests that CBG's motion to compel further inspection be denied.
l t 12 1
13 Dated: May 3, 1982.
j 14 15 DONALD L. REIDHAAR 3 GLENN R. WOODS 16 CHRISTINE HELWICK 17 18 By i William H. Cormier i 19 UCLA Representative
- 20 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 21 22 23 24
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l ATTACHMENT A UNIVERSITY OF CALIFORNIA, LOS ANCELES UCLA r
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,m.........mm.m i GT@Y OFFICE OF Tile Cil ANCELLOR LOS ANGELES. CALIFORNIA 90024 November 23, 1981 Elizabeth S. Bowers, Esq., Chairman Dr. Emmoth A. Luebke Administrative Judge Administrative Judge Atomic Safety and Licensing Board - Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Dr. Oscar H. Paris Washington, D.C. 20555 Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
' Washington, D.C. 20555 In the Matter of The Regents of the University of California (UCLA Research Reactor)
Docket No. 50-142 (Proposed Renewal of Facility License)
Dear Administrative Judges:
This is to inform you that on Tuesday, November 17, 1981, the University permitted representatives of the Committee to Bridge the Gap (CBG) to inspect the UCLA Nuclear Energy Laboratory and surrounding areas in response to CBG's two requests for inspection and testing dated September 3 and 11, 1981.
CBG had agreed to the conditions set by the University for the inspection to take place in the parties' discovery I
conference held on November 12, 1981, although CBG stated that by agreeing to the inspection as proposed by the University it was not waiving any of its discovery rights (to additional inspection and/or testing) . The University permitted eight CBG representatives j to accompany UCLA representatives on the inspection tour (six CBG representatives were actually present) . The areas inspected
, included the reactor room on two levels, adjacent offices, class-
- rooms, laboratory areas, the area immedi~ately above the reactor room known as the third floor equipment room, and the stack area on the eighth floor roof of the reactor building.
University representatives were present to identify equipment and controls, to explain the ventilation and air j exhaust systems, and to answer questions. Items which CBG asked to be identified in its requests of September 3 and 11 were iden-tified, except for certain "TLD's" which were located in other buildings on the campus and certain other items which were either non-existent or could not be identified without dissassembling the reactor or other equipment.
D g j g o i n c /n o ,,w t "(yy
1 4 .
Administrative Judges 2 November 23, 1981
'According to the prior agreement, CBG was permitted to take photographs of the facility and its equipment (over 200 photographs were taken) ; the film is being processed by the University and the parties will meet to discuss which
- photographs are relevant to the proceeding and can be released without compromising security.
The map of the inspection tour and the checklist of .
equipment and other objects identified during the tour is attached here as " Exhibit A." Mr. IIal Bernard of the NRC's
) Division of Licensing was present during the inspection.
Respectfully submitted, ,
1) w William II. Cormier UCLA Representative J
TIIE REGENTS OF TIIE UNIVERSITY OF CALIFORNIA Attachment cc: Service List I
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I ' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1 2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3 In the Matter of ) 4 ) Docket No. 50-142
, THE REGENTS OF THE UNIVERSITY ) (Proposed Renewal of Facility 5 OF CALIFORNIA ) License Number R-71)
)
6- (UCLA Research Reactor) )
)
7 0 CERTIFICATE OF SERVICE 9 I hereby certify that copies of the attached: 10 UNIVERSITY's RE9pOMRE Tn enne n MOTION TO COMPEL 11 in the above-captioned proceeding have been served op the following by deposit in the United States mail, first class, 12 postage prepaid, addressed as indicated, on this date: May 3. 1982 . 13 9 14 John H. Frye, III, Chairman Mr. Daniel Hirsch Administrative Judge Cte. to Bridge the Gap 15 ATOMIC SAFETY AND LICENSING BOARD 1637 Butler Avenue, #203 U.S. Nuclear Regulatory Commission Los Angeles, Calif. 90025 16 Washington, D.C. 20555 Mr. John Bay, Esq. , , 17 Dr. Emmeth A. Luebke 3755 Divisadero #203 Administrative Judge San Francisco, CA 94123 18 ATOMIC SAFETY AND LICENSING BOARD U.S. Nuclear Regulatory Co}mmission Mr. Daniel Hirsch Washington, D.C. . 20555 19 Box 1186 Ten Lomond, CA 95005 20 Dr. Oscar H. Paris ~ Administrative Judge . 21 ATOMIC SAFETY AND LICENSING BOARD U.S. Nuclear Regulatory Commission Nuclear Law Center i 22 Washington, D.C. 20555 c/o Dorothy Thompson l 6300 Wilshire Blvd. #1200 23 Counsel for the NRC Staff Los Angeles, CA 90048 OFFICE OF THE EXECUTIVE LEGAL DIRECTOR 24 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chief, Docketing and Service Section 26 OFFICE OF THE SECRETARY U.S. Nuclear Regulatory Commission 27 Washington, D.C. 20555 ,, 28 ' WILLIAM H. CORMIER UCLA Representative
') THE REGENTS OF THE UNIVERSITY
', OF CALIFORNIA
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