ML20055B930

Request for Production of Documents Re Security Regulations Per ASLB 820630 Order.Certificate of Svc Encl

ML20055B930
Person / Time
Site:	05000142
Issue date:	07/20/1982
From:	Bay J COMMITTEE TO BRIDGE THE GAP
To:	CALIFORNIA, UNIV. OF, LOS ANGELES, CA
References
NUDOCS 8207230587
Download: ML20055B930 (7)

Text

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JOliN H. BAY 00CKETED DOROTHY THOMPSON 'J3NRC NUCLEAR LAW CENTER 6300 Wilshire Blvd., Suite 1200 "- *-- --

Los Angeles, Califo rnia 90048 43 d1 22 E9M Telephone: (415) 393-9234 (213) 653-3973 Attorneys For Intervenor (Contention XX) C"??E It- '4 I"jyOF f. '.U<wsrcagg Committee To Bridge The Gap ""w 1

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

IN THE MATTER OF )

) Doc. No . 50-142 THE REGENTS OF THE UNIVERSITY )

OF CALIFORNIA )

) (Proposed Renewal (UCLA Research Reactor) ) of Facility

) License No. R-71)

REQUEST FOR PRODUCTION OF DOCUMENTS RE SECURITY REGULATIONS PURSUANT TO i COURT ORDER TO: APPLIC ANT, THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, AND ITS ATTORNEYS OF RECORD:

Intervenor Committee to Bridge the Gap, hereby requests, pursuant to Title 10 of the Code of Federal Regulations Section 2.741, that Applicant the Regents of the University of California, shall serve its written response to- these requests no later than August 9, 1982, and produce the documents described below at 1:00 p.m. on August 12, 1982, at the applicant's of fices, UCLA campus, Los Angeles, California and permit intervenor and its attorneys to inspect and copy said documents, or any of them. This request is made pursuant to the Board order made at the Pre-Hearing con-ference held on Wednesday June 30, 1982.

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SPECIFICATION OF DOCUMENTS TO BE PRODUCED I.

INSTRUCTIONS

1. In responding to this request for production of documents you must produce all requested documents in your possession, custody, or control, or in the possession, custody or control of your agents, employees, represen ta tive s , inve stiga tors or attorneys.

II.

DEFINITION OF TERMS

1. The te rm " document" as used herein means and includes:

a. The original; or

b. If the original is not in your custody or under your control, then a copy thereof; and in any event

c. Includes any nonidentical copy or copies which dif fer from the original for any reason, including, but not limited to, the making of notes thereon; of any writing , as that term is defined in Rule 1001(1) of the Federal Rules of Evid e nce ,

paper, book, or record of whatever kind or de scription, which is not privileged , whether inscribed in hand or by mechanical, electronic, photographic, or other means, which shall include any recorded, taped or graphic matter in any phonic, (e.g., a tape recording) or a visual reproduction or record of any statement, conversation or event.

2. The term "UCLA/NEL" shall mean the Regents of the University of California, the University of California Los Ang ele s , the Nuclear Energy Lab at UCLA, their agents, employees 2.

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and representatives.

3. The terms "you" and "your" shall refer to UCLA/NEL.

4. The te rm " reactor" shall refer to the Argonaut type nuclear reactor which is located in Boelter Hall on the UCLA c ampus .

5. The term " reactor facility" shall mean the build-ing, rooms and structures containing and surrounding the reactor which are used in or related to the operation of the reactor or storage of f uel there for and the operation of the Nuclear Energy Lab.

6. The term "SNM" shall mean special nuclear materials as that te rm is defined in 10 CFR Section 73.2(x).

III.

DOCUMENTS REQUESTED

1. All documents constituting, referring or relating to conmitments to the NRC by the UCLA/NEL to maintain an external radiation dose rate in excess of 100 Rem per hour at 3 feet unshielded, for U-235 in the core of the reactor.

2. All documents constituting, referring or relating to canmitments made by UCLA to the NRC to keep its SNM inven tory at levels below those requiring compliance with 10 CFR 73.60.

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3. All documents constituting , referring or relating L

to calculations regarding the operating conditions necessary to maintain an external radiation dose rate of greater than 100 Rem per hour at 3 feet unshielded for the U-235 in the reactor core.

l 4. All documents constituting , referring or relating to rules and procedures for maintaining the U-235 in the reactor

! at an external radiation dose rate in excess of 100 Rem per hour l

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at 3 feet unshielded .

5. All documents constituting , referring or relating to short term and long term plans for insuring that the SNM there is at all times less than 5000 grams at U-235 enriched more than 20%, with a total external radiation dose rate of less than 100 rems per hour at a distance of three feet unshielded at the reactor f acility.

6 All documents constituting , referring or relating to plans or procedures for keeping the U-235 in the reactor core in a state of having an external radiation dose rate in excess of 100 Rem per hour at three fee t unshielded in each of the follow-ing situa tions :

a. Long weekends;

b. Final examination periods;

c. Holidays or vacations;

d. Quarter breaks;

e. Refueling;

f. In-core maintenance;

g. Experiments requiring in-core placements;

h. Experiments requiring reactor shutdown several days prior to or af ter the ex periment;

i. Maintenance or calibration requiring a reactor shutdown of several days; I

j. Unintentional SCRAMS or other malf unctions, the cause or repair of which cannot be determined or accomplished within several days;

k. Lack of business or other reason to operate j the reactor other than for the purpose of maintaining the radia-t 4.

tion level of the f uel .

7 All documents referring or relating to NRC require-to ments for procedures, structures and other measures designed minimize the potential for radiological sabotage at the reactor

' f ac ility.

If any of the documents requested in this Request No. +:.,....

7 contain protected information please identify each such docu-ment and produce those portions which do not contain protected

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from the NRC, ~a -; , y 8 All documents sent or received of violation, res ponse s including but not limited to notice:

to the need thereto , and inspection reports referring or relating for UCLA/NEL to either reduce its SNM inventory levels or to -

increase its security consistent with higher levels of SNM.

9. All written communications between NRC and UCLA, or -

for the period 1960 through the present, internal UCLA documents, ~

referring to or relating to:

a. The need to reduce SNM inventories at the reactor f acility;

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b. The applicability of 10 CFR 73.60 or 73.67 to .

the UCLA/NEL reactor operation; .V t% _

c. The radiation level of irradiated fuel at the reactor f acility.

to the quantity

10. All documents referring or relating of U-235 at the reactor facility and its radiation level. .h!jp

11. All documents referring or relating to the radia-J

,y; y.+

the raw .n-y;h.i"l tion level of the U-235 in the reactor core including is camputed.

data from which such radiation level -

12. The letter of December 12, 1974, from UCLA/NEL to

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a NRC regarding SNM inventory.

13. The letter of October 28, 1974, from UCLA/NEL to NRC regarding SNM inventory.

14. All documents referring or relating to the site visit and review described in Jim Miller's 1/12/81 letter to ,-

bd LA/NEL's Dr . Weg s t.

15. All written canmunications between NRC and UCLA/NEL as to the need to transfer the irradiated f uel in storage at the reactor facility in order to comply with the Upgrade Rule to 10 CFR 73, from January 1, 1977 to January 1, 1981.

16. The following documents from Janaury 1,1981, through the most current entries:

a. Ope ra ting Log ;

b. Maintenance Log and Records ;

c. Calibration Log and Records;

d. Reactor Supervisor's Notebook / Log--reac tor use sched ule;

e. Engineering Change Order;

f. Minutes of the Radiation Use Conmittee and Campus Radiation Safety Committee.

DATE D: July 20, 1982. p/'

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By f John IJF Eay

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AttorYeys For Intervenor (Contention XX) 6.

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UNITED STATE 3 0F AMERICA fiUCLEAR REGUIATCRY COMMISSION

, BJEFCRE .T E ATOMIC SAFE"Y AND LICENSI!!C E0ARD In the Matter of ,

I Docket No. 50-142 OL ,

TIE RECENTS OF TIE UNIVERSITY (Proponed Renewal of 0F CALIFORNIA J Facility Licenne)

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(UCLA Research Reactor) , )

CERTIFICATE OF SERVICE I hereby certify that copics of the attached: Regnest For Production Of Documents Pursuant to Board Order .

in the above-captioned proceeding hsvu been served on the following by deposit in the United States mail, first class, postage prepaid, addressed as indicated.

on this date: July 20, 1382 .

John !!. Frye, III, Christine Helwick Chairman .

Glenn R. Wooda Atomic Safety & Licensing Board Office of General Counsel U.S. Nuclear Regulatory Co$ mission 590 University Hall Washington, D.C. 20535 '

2200 University Avenue Berkeley, CA 94720 Dr. Emmoth A. Luotko Administrative Judge Sarah Shirley Atomic Safety & Licensing Board Deputy City Attorney U.S. Nuclear Regulatory Commission Office of the City Attorney Washington, D.C. 20555' City 1h11 1685 Fain street Dr. Oscar H. Paris

• Santa Monica, CA 90401 Administrative Jud60 i Atomic Safety and Licensin6 Board Committee to Bridge the Gap U.S. Nuclear Regula tory Commission 1637 Dutler Avenue, Suite 203 i Washington, D.C. 20555 . Los Angeles, California 90025 l .. .

Chief. Docketing and Service Section (3) Daniel Hirsch Office of the Socrotary . . . P.O. Box 1186 U.S. Nuclear Regulatory Commission Ben Lomond, CA 95005 p Washington, D.C. 20555 l

Dorothy Thonpson .

Counsel for NRC Staff . Nuclear Law Center U.S. Nuclear Regulatory Coi. mission 6300 Wilshire Blvd., Suite 1200 . .

l Wanhington. D.C. 20555 Los Angeles, CA 90048 .

attention: Ms. Colleen P.' Woodhead

! William H. Cormler I

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Office of Administrative Vice Chancellor Unjversityn6f California 405' Hilgard Avenue *

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. Johnssay ,

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i Los Angeles, California 90024 Counsel for Intervenor COMMITTEE 'ID BRIDGE THE GAP l .- - .. - _ . - .