ML20062G856
| ML20062G856 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 08/09/1982 |
| From: | Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8208130204 | |
| Download: ML20062G856 (14) | |
Text
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00CKETED US!!RC i? :D 1~9 em . m' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
) Docket No. 50-142 THE REGENTS OF THE UNIVERSITY ) (Proposed Renewal of Facility OF CALIFORNIA ) License Number R-71)
)
(UCLA Research Reactor) ) August 9, 1982
)
UNIVERSITY'S RSSPONSE TO INTERVENOR'S FIRST SET OF INTERROGATORIES ON CONTENTION XX PROPOUNDING PARTY: Intervenor Committee to Dridge the Gap RESPONDING PARTY: Applicant The Regents of the University of California SET NUMBER: One DONALD L. REIDHAAR GLENN R. WOOD 3
-CHRISTINE HELWICK 590 University Hall 2200 University Avenue Berkeley, California 94720 Telephone: (415) 642-2822 Attorneys for Applicant THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 8208130204 820809 PDR ADOCK 05000142 -
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F THE REGENTS OF THE UNIVERSITY OF CALIFORNIA (University) responds to the Committee to Bridge ~the Gap's first set of inter-rogatories on Contention XX as follows:
RESPONSE TO INTERROGATORY NO. 1 University objects to the question to the extent that the question seeks specific figures on the quantity of the fuel i present at the facility for each day since 1970 on the grounds that the compilation of such specific information would be unreasonably burdensome, would require the release of protected i
information and that such specific information is not reasonably calculated to lead to the discovery of evidence admissible on the question of the applicability of 10 CFR Part 73 safeguards regulations, which is the extent of the scope of discovery that has been permitted by the Board. Motwithstanding, and without waiving, the aforesaid objections, University answers as follows:
For each day of the period less than 6 kilograms of U-235 enriched more than 20% was at the reactor facility and not in the core of l the reactor except for periods of major "in-core" maintenance I
when the "in-core" fuel was removed from the core. The last l . period of major "in-core" maintenance occurred in 1974. As a i
result of the most recent transfer of fuel off-site, unirradiated l
fuel in storge on-site has been reduced to 1.39 kilograms.
Irradiated fuel in the core is 3.53 kilograms.
RESPONSE TO INTERROGATORY NO. 2 University objects to the question to the extent that the question' seeks specific figures.on the quantity of the fuel i
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present at the facility for each day since 1970 on the grounds that the compilation of such specific information would be un-reasonably burdensome, would require the release of protected information and that such specific information is not reasonably calculated to lead to the discovery of evidence admissible on the question of the applicability of 10 CFR Part 73 safeguards regulations, which is the extent of the scope of discovery that has been permitted by the Board. Notwithstanding, and without waiving, the aforesaid objections, University answers as follows:
For each day of the period, less than 3.6 kilograms of U-235 enriched more than 20% was in the core of the reactor, RESPONSE TO INTERROGATORY NO. 3 University objects to the question to the extent that the question seeks specific figures on the quantity of the fuel present at the facility for each day since 1970 on the grounds that the compilation os such specific information would be un-reaconably burdensome, would require the release of protected information and that such specific information is not reasonably calculated to lead to the discovery of evidence dismissible on the question of the applicability of 10 CFR Part 73 safeguards I regulations, which is the extent of the scope of discovery that has been permitted by the Board. Notwithstanding, and without waiving, the aforesaid objections, University answers as follows:
For each day of the period, less than 4700 grams of U-235 enriched more than 20% was in the fuel storage holes. In general, irradiated fuel is either in the core or in the storage pits, and the total quantity of irradiated fuel in the reactor room has not exceeded 4700 grams.
RESPONSE TO INTERROGATORY NO. 4 University objects to this question to the extent that the question seeks to explore operating conditions that may have occurred in the period prior to the adoption of the upgraded safeguards regulations applicable to University's facility which became effective November 21, 1979 on the grounds that such information is not relevant and is not reasonab1y calculated to lead to the discovery of evidence admissible on the question of the applicability of 10 CFR Part 73 safeguards regulations, which is the extent of the scope of discovery that has been permitted by the Board. Notwithstanding, and without waiving, the aforesaid objections, University answers as follows: To the knowledge, of University's staff for the period since November 21, 1979, no.
(a) Not applicable (b) Not applicable (c) Not applicable RESPONSE TO INTERROGATORY NO. 5 See the objections stated and the response given to Interrogatory No. 4, above. - .
RESPONSE TO, INTERROGATORY NO. 6 The precise dose rate is not determined except that calculations have been made to determine the conditions that would result in an external dose rate of 100 rem per hour at 3 feet, unshielded. The basic calculation is presented in the attached Exhibit "A".
RESPONSE TO INTERROGATORY NO. 7
.Not applicable.
' RESPONSE TO INTERROGATORY NO. 8 See response to Interrogatory No. 6, above.
RESPONSE TO INTERROGATORY NO. 9 See response to Interrogatory No. 6, above. .
RESPONSE TO INTERROGATORY NO. 10 Approximately 14 days.
RESPONSE TO INTERROGATORY NO. 11 --
Level of operations or schedule of operations or other variations in_ power history.
RESPONSE TO INTERROGATORY NO. 12 The parameters of the problem have been incompletely described, but in any case, the answer involves a complex calculation that has not been made. See response to Interrogatories Nos. 6,10 and 11, above.
RESPONSE TO INTERROGATORY NO. 13 There are no written rules or procedures. However, the reactor is operated an average 200 KWH per week which provides a conservative operating margin for meeting the self-protecting conditions.
(a) See response above (b) Specific attention was made to observing the self -protecting conditions beginning in January 1981.
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RESPONSE TO INTERROGATORY NO. 14 As a result of the recent reduction in total fuel inventory at UCLA, the University is no longer concerned with maintaining the self-protecting conditions.
(a) through (k), not applicable.
RESPONSE TO INTERROGATORY NO. 15 University agreed to maintain the self-protecting conditions for the "in-core" fuel or to reduce its fuel inventory.
The committment was communicated by lettc.r from Wegst to Miller, dated January 29, 1981, attached hereto as Exhibit "B".
RESPONSE TO INTERROGATORY No. 16 Assuming "No. 14" should read "No. 15", the answer is there are no such dates.
RESPONSE TO INTERROGATORY NO. 17 Yes. There are no such procedures; see response to Interrogatory No. 14, above.
RESPONSE TO INTERROGATORY NO. 18 University cannot speculate on such hypothetical situations except to note that there is no requirement to maintain the radiation level given the current fuel inventory at the UCLA facility.
RESPONSE TO INTERROGATORY NO. 19 Not to the knowledge of University's staff but see the Miller to Wegst letter, dated January 12, 1982, attached hereto as Exhibit "C .
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RESPONSE TO INTERROGATORY NO. 20 University objects to the question to the extent that the question seeks security information unrelated to radiation dose rate of the irradiated fuel on the grounds that such information is protected information and is not reasonably calculated to lead to the discovery of evidence admissible on the question of the applicability of 10 CFR Part 73 safeguards regulations, which is the extent of the scope of discovery that has been permitted by the Board. Notwithstanding, and without waiving, the aforesaid objections, University answers as follows: With respectt to maintaining the self-protecting conditions for the "in-core" fuel, University has never been found in non-compliance with NRC security or safeguard regulations.
RESPONSE TO INTERROGATORY NO. 21 There are no specific dose rate limitations.
RESPONSE TO INTERROGATORY NO. 22 No . - During period of major "in-core" maintenance and lower than average operational intensity.
RESPONSE TO INTERROGATORY NO. 23 The precise minimum quantity is unknown.
RESPONSE TO INTERROGATORY NO. 24 The precise maximum is unknown. Under the present configuration with the presently availabic fuel composition no more than 4 kilograms U-235.
RESPONSU TO-INTERRO gTORY NO. 25 University objects to the question on the grounds that it is unclear, ambiguons and imprecise in that it seems to require that the University speculate on what regulatory requirements will be in effect throughout the proposed relicensing period.
Notwithstanding, and without waiving, the aforesaid objections, University answers as follows: There are no additional fa' cts not provided in response to the interrogatories above.
Dated: August 9, 1982 DONALD L. REIDHARR GLENN R. WOODS CHRISTINE HELWICK By
- William H. Cormier UCLA Representative
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VERIFICATION Neill C. Ostrander, being duly sworn, deposes and says.
that he is the Manager of the fluclear Energy Laboratory of University, TI:e Regents of the University of California; that he has read the annexed " University's Response to Intervenor's First Set of Interrogatories on Contention XX" and knows the. contents thereof; and that the same are true to the best of his knowledge, inforn.ation and belief.
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Neill C. Ostrander Subscribed and sworn to before me this 9th day of January,1982 L m/s a Notary Public j
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Exhibit "A" O
Fuel Self Protection Calculation The radiation intensity D at distance r from the core center af ter.
an operational history P(t) extending over a time interval T followed by a down time t is approximately D= 2 P(T)(T 4 t - T)-1.2dT .
4iir 0 This fonaulation assumes that all of the delayed gantnas are emitted at the core center, and the numerical calculations assume that three feet-from the nearest accessible surface is equivalently four feet from the core center. The constant A depends upon the units chosen but represents the conversion from the energy release P(T)dt at T to the incremental dose dD at t.
The precise evaluation of the equation over the entire operating iiistory of the reactor amounts to a surrmation of all contributions to the integral for those times for which P(3) > 0. The results shown below are based upon the following simplificd modei vhich underestimates the actual radiation level.
- 1) fleglect all contribution from the history prior to 5 years ago.
Thus, today, T=0 corresponds to approximately August 1, 1977.
2} Assume 3 years (say8-1-77through7-31-80)atan,averageuniform power level of 1514wh per year.
- 3) Assume that the subsequent 2 years'(say 8-1-80 through 7-31-82) can be characterized by two components:
a) a periodic component produced by a 200 kwh energy generation (treated as a Dirac delta function) every seven days, and superposed thereupon; b) a random, smoothed, average power level of 5.0 Mwh/yr.
flote that the sum of (a) and (b) is equivalently 15.4 Mwh/yr.
These assunptions lead to the following radiation dosa rates at 3 feet from the nearest at.cessible surface following a shut down of t weeks.
Tipq, t (weeks) Dose Rate (R/hr) at 3 feet 1 142 2 107 3 91 4 83 The dates indicated in assumptions (1),(2) and (3) are arbitrary and could have been represented by phrases such as five years ago and two years ago to reflect the moving average aspect of a calculation which is not actually performed on a day-by-day or any other periodic basis.
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The conservative (under-estimating) nature of the dose rate calculation resides in the fact that the assumed five year annual power of about 1514wh/yr has been exceeded for every year since 1976, and is currently running at a rate greater than 2011wh/yr. .
fleill C. Ostrander fluclear Energy Laboratory UCLA .
July 1982 O
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- . COS'MUNITY SA FF.TT DEPAIt BLENT OfflCE OF RESE AbCil & OCCUPATION AL SAFt.7Y tos asccu s.cautoma aox January 29, 1981
. 1 James R.,11 iller, Chief .
Standardization and Special Projects Branch Division of Licensing .
U.S. Iluclear Regulatory Commission Washington, D.C. 20555
Dear fir._14 iller:
In reference to your letter of January 12, 1981: We are scheduling reactor operations to conform with the self-protection criteria for the in-core fuel. As this represents a temporary arrangement, we are proceeding to identify viable options for the reduction of our unirradiated Slim inventory. , .
Two options have been identified; (1) transfer to the DOE Lawrence Livermore flational Laboratory (LLl!L), and (2) return to DOE, Idaho Falls. The DOE and LLitL have tentatively indicated the acceptability of either destination, subject to approval of final plans. .
Very truly yours,
${ it. b- :h. .
Walter F. Wegst, Director Research & Occupational Safety WFil/flC0/lc g
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p a uem'A p, NUCLEAR REGULATORY COMMISSION WASHtNG T ON, 0. C. 20%5 t
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JAN i? 199f '
Dr. Walter F.11egst .
University of Caiifornia at Los Angeles Director of Research and ,
Occupational Safety ,
Office of Environmental llealth and Safety Los Angeles, California 90024 .
Dear Dr. 1legst:
Following a site visit and review of your Physical Security Plan by flRC, we have determined that the UCLA reactor operating and Stim storage sites are contiguous. As such the facility must impicment interim Category I physical security requirements. These requirements are currently contained in 10 CFRParts73.67(a)(b)(c)(d)and73.60.
In order to be exempt from the above requirements, the fuel in storage would have to be shipped to another location or the reactor would have to be operated to maintain the fuel irradiation level at a dose rate of 100 rem /hr
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at 3 feet,frop any accessible surface. (See 10 CFR 73.6(b) and 73.67(b)(1)(i)).
By January 31, 1981, please indicate your confirmation of the above and your plan for compliance with this temporary adjustment.
Sincerel ,
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e James R. Miller, Chief
/ Standardization & Special Projects Branch Division of Licensing I
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE hTOMIC SAFETY AND LICENSING BOARD In the Matter of )
) Docket No. 50-142 THE REGENTS OF THE UNIVERSITY ) (Proposed Renewal of Facility OF CALIFORNIA ) License Number R-71
)
(UCLA Research Reactor) )
CERTIFICATE OF SERVICE I hereby certify that copies of the attached: UNIVERSITY'S RESPONSS TO INTERVENOR'S FIRST SET OF INTERROGATORIES ON CONTENTION XX _
in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, postage prepaid, addressed as indicated, on this date: August 9, 1982.
John H. Frye, III, Chairman Mr. Daniel Hirsch Administrative Judge Cte. to Bridge the Gap ATOMIC SAFETY AND LICENSING BOARD 1637 Butler Avenue, #203 U.S. Nuclear Regulatory Commission Los Angeles, CA 90025 Washington, D.C. 20555 Mr. John Bay, Esq.
Dr. Emmeth A. Luebke 3755 Divisadero #203 Administrative Judge San Francisco, CA 94123 ATOMIC SAFETY AND LICENSING BOARD U.S. 11uclear Regulatory Commission Mr. Daniel Hirsch Washington, D.C. 20555 Box 1186 Ben Lomond, CA 95005 Dr. Oscar H. Paris Administrative Judge Nuclear Law Center ATOMIC SAFETY AND LICENSING BOARD c/o Dorothy Thomson U.S. Nuclear Regulatory Commission 6300 Wilshire Blvd., #1200 Washington, D.C. 20555 Los Angeles, CA 90048 Counsel for the NRC Staff Ms. Sarah Shirley OFFICE OF THE EXECUTIVE LEGAL DIRECTOR Deputy City Attorney U.S. Nuclear Regulatory Commission City Hall Washington, D.C. 20555 1685 Main Street Santa Monica, CA 90401 Chief, Docketing and Service Section OFFICE OF THE SECRETARY U.S. Nuclear Regulatory Commission Washington, D.C. 20555 WILLIAM H. CORMIER UCLA Representative THE REGENTS OF THE UNIVERSITY OF CALIFORNIA
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