ML20063N272

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Forwards Exhibit Sheets to Committee to Bridge the Gap Motions for Summary Disposition,Which Were Incompletely or Incorrectly Duplicated
ML20063N272
Person / Time
Site: 05000142
Issue date: 09/14/1982
From: Hirsch D
COMMITTEE TO BRIDGE THE GAP
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8209200150
Download: ML20063N272 (37)
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COMMITTEE TO BRIDGE THE GAP 1637 BUTLER AVE. !UE =203 00CKETED l LOS ANGELES, CALR.'4NIA 90025 USNRC (213) 478-082<. --

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'52 S P 17 f40 59 3eptember 14, 1982 In the Vatter of The Regents of the University of California Docket 50-142 OL IGMO TO BOARD AND PARTIES: ,

It has come to my attention that certain portions of CBG's Motion fe Summary Disposition were inecapletely or incorrectly duplicated.

Some copies apparently were missing one or both exhibit sheets, as well as Exhibit V to the Contention XIII Motion.

In addition, the particular copying machine employed appears to have turned the light yellow underscoring of emphasized passages into a black mark obliterating the intended sections.

Therefore, please find enclosed exhibit sheets for both Motions and Exhibit V for the Contention XIII Motion and Exhibit G and M for the Contention XVII Motion.

Also, please note that the first sentence on'page 18 of the S~

Contention XIII Motion should read: " Records provided by UCLA's Neill Ostrander, transmitted by cover letter of '4111iam Cormier on August 26, 1982 indicate only three shipments took place thereafter, of 730 grams, 600 grams, and 2360 grams, which would leave the University still with about 5350 grc.ms."

Res' c fully qubmitted, -

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Daniel Hirsch President COMMITTEE TO BRIIG3 SIE GAP -

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8209200150 820914 -- -

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Cod . ZTff EXHI3IT 3HEET

'3I3IT A Declaratien of Dr. David W. Hafemeister 3 3 election from Office cf Technology A"casient's Nuclear Proliferation and Safeguards Report "

C International Nuclear Fuel Cycle Evaluation, Report of INFCE Working Grcup 8, Advanced Fuel Cycle and Reactor Concepts **

D Department of Energy Fiscal Year 1981 Sudget: Nuclear Nonproliferation Programs, Hearing before Foreign Affairs Committee, U.3. House of Representatives, April 16,19c0**

E Progress in U.S. and International Nonproliferation Efforts 4

- Hearing before Foreign Affairs Committee, Farch 12, 1979*

F U.3. DOE 3econd Annual Report on Nuclear Non-Proliferatien,,,

dupplement to decretary's Annual Report to Congress, 19E0 y G First Annual Report on Nuclear Non-Proliferation, DOE /PE-0014/R1 H Nuclear Proliferation and Civilian Nuclear Power, Report of the Nonproliferation Alternative systems Assessment Program, June 1980,DCE/NE-000l**

I Use of High-Enriched Uranium (HEU) in Research Reactors:

NRC Policy Statement, August 24, 582, 47 FR 37007 J Rulemaking Issue Physical security Requirements for Nonpower Reactor Licensees Possessing a Formula Quantity of SdNM, SECY-81-376 K 10/10/78 Letter, University of Flofida to NRC, regarding use of 4.8% enriched UO2 fuel in U of F Argonaut reactor L 3ection of UCLA Application for License Renewal, containing GNM license request and indication of Radium-startup source use M Argonaut Reactor Databook, Sturm and Daavettila, January 1961, ANL-6285 N 25 August 1982 Memorandum from Neill Ostrander re 1 gn./yr burnup &

9NM inventories 1970 to date 0 10/28/74 letter Ashbaugh to Goller, indicating 9.047 kg U-235 as of 12-21-74, as opposed to 8.62 indicated in Ostrander Memorandum, a discrepancy of nearly half a kilogram P University of Florida Hazards Analysis, indicating 20% fuel use Q Sumnary Report on the Hazards of the Argonaut Reactor by Lennox and Kelber, ANL-5647, December 1956 R Directory of Nuclear Reactors, Volume V, International Atomic Energy Agency 3 AEC Hazards Analysis of Amendment 2 to UCLA license, regarding replacement of Pu-Be source with Ra-Be source Original License showing 3.34 kg use, with 10 grams suppleenting original shipment every 4-5 years Original Application T 16 pages of SNM license correspondence U IAEA-TECDOC-233, Research Reactor Core Conversion from the Use of Highly Enriched Uranium to the Use of Low Enriched Uranium Fuels Guidebook, International Atomic Energy Agency, 1980 V WASH 1192, Operational Accidents and Radiation Exposure Experience Vithin the Atomic Energy Commission, issued fall 1971

  • as per 28 U.S.C. E1746, declaration format is employed
    • as cited in-Hafemeister declaration Notes emphasis added by C3G

[oad M [

EXHIEIT 3HEfr Exhibit

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A Declaration of Dr. Sheldon C. Plotkin 3 Photograpns taken by Dr. Plotkin C FEMA Report selections 4 D Estirates of the Risks Associated with Dam Failure"6/ selections

! E Photos of 1971 Olive View Hospital Quake Damage and related items fron Second Report of the Governor's Earthquake Council F Abstract from California Division of Mines and Geology Special Report 114 "A Review of the Geology and Earthquake History of the Newport-Inglewood Structural Zone, i Southern California", 1974 G portionofNUREG/CR-2198 H 1958 Uniform Building Code I 1979 Uniform Building Code

, J portions of CBG's July 31, 1981 Interrogatories to NRC Staff as to the SER K portions of Staff's responses to said Interrogatories L portions of CBG's 4/20/81 Interrogatories to Applicant g M portions of Applicant's 5/20/81 responses to said Interrogatories N portions of Preliminary Geologic Environmental Map of the Greater Los Angeles Area, California (A Study Pertinent to Nuclear Facility Siting and Design) prepared by National Center for Earthquake Research USGS, prepared on behalf of USAEC,1970 g 0 Map of the Newport-Inglewood Structural Zone and Other Structural Features of the by California Los Angeles Division Area, of Mines and Southern Californ%,o/

Geology,1974 <

P Map of Beverly Hills Quadrangle Special Studies Zone hy 10/ s California Division of Mines and Geology i

6/preparedunderAECcontractbyUCLASchoolofEngineering two of the authors were Thomas Hicks, the late Director of NEL, and David Okrent, i formerly on Radiation Use Committee, currently on Radiation Safety Committee, l at UCLA.

i l 7/ emphasis has been added by underlining key admissions 8/ reactor site location has been added by an "+" mark p/ reactor site location has been added by an "+" mark 1_0/themaponlyshowsthefaultswithinthespecialstudieszone, 0 marked by straight-line segments connecting encircled turning points: in this case, all that is shown is one trace of the Newport-Inglewood Fault, indicating its proximity to UCLA and possible even closer proximity due to uncertainties about its endpoint.

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,970 Section 2 i uc l lI.'m 52,498 CRITICALITY ACCIDENTS r 52,300

' In the AEC's operational activities (not 11- behind heavy shielding and three of them oc-censea) for the past 28 years there have been a curred in facilities remotely' located with re-

' sWet to personn_el. Hence, the probability of total or uti occasions (see Chart XV) when th_e l

power level of tissile systems became uncon- 15 juries to people was reduced almost to the Erollable -because of unplanned or unexpected vanishing point. It is also noted that fourteen 51,050 changes in the system reactivity. On three oc- of the accidents occurred during experiments, l casions, the power excursions were planned; six occurred in production or processing facili-l 51,000 however, the fission energy released during the ties, and five in reactor activities. In these l excursion was significantly larger than was laboratory, production, and reactor facilities l

! expected. There have been a total of six deaths there were, respectively, two, one, and three attributable to criticainty accidents. The prop- fdlities.

erty damage resulting from these excursions A review of these incidents has been made by

! 51',000 50 000 has been approximately $4,455,000; however, W. R. Stratton, University of California, Los 50,000 98% of the property loss was due to the SL-1 Alamos Scientific Laboratory, Los Alamos, reactor excursion.

Further study of this accident record reveals N. Mex. All we have done below is to prepare that nine of the unplanned excursions occurred a brief description of each incident.

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Before the incident, fuel along the core axis CRITICALITY EXCUR$10N INCIDENT was replaced by additional moderating elements Cok Ridge, Tenn., Jan. 30, 1968 to investigate flux-trap elTects. Instead of the Unexpected criticality was achieved in a usual step-wise interchange of elements, the

% volume of an aqueous solution of a salt of U"' entire moderating island was installed. Then, during a series of routine critical experiments instead of step-wise multiplication measure-in progress in a well-shielded assembly area of ments while inserting the core into the reflec- '

- a critical experiments facility. The criticality- tor, which is proper for initial approaches to radiation alarm system functioned as designed, criticality, there were no measurements during

- the evacuation of personnel from the building interrupted insertion. It had been inferred from

- was prompt and orderly, and the excursion was the behavior of difTerent moderating elements i

terminated expeditiously by a negative coefli- in an earlier mockup that the overall reactivity cient of reactivity and was prevented from re- change would be minor. This was a serious curring by the action of the safety devices. The mistake, for the actual change proved to be fission yield was 1.1 X 10". Gamma-ray sensi- about $10. Before complete closure was tive personnel dosimeters read immediately achieved,'a very short period and scram (drop-following the excursion showed no direct ex- ping the core and actuating the safety drums) posure greater than 5 mr to any person present. occurred.

There was no property damage or loss of fissile materials. An estimated 100 cm' of solution NUCLEAR EXCUR510N AND FIRE (15 g of U) were spilled when a rubber- uvermore, Calif., Mar. 26, 1963 stoppered connection immediately above the A nuclear excursion and subsequent fire took i sphere was dislocated. place during a suberitical experiment in a The purpose of the particular experiment in shielded vault designed for critical assembly

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progress was to establish the critical concen- experiments. The excursion was estimated at tration of a sphere of the solution of uranyl 4 X 10" fissions and was followed by oxidation

- nitrate surrounded by a thick water reflector. of the enriched uranium metal in the assembly.

In the course of approaching criticality by in- The cause of the excursion is believed to have "k" cremental additions of solution, a small volume been directly attributable to mechanical failure.

cf air was observed entrapped in a flexible The total property loss was $94,881.

transparent tube. Supercriticality occurred dur.

  • = ing an attempt, by remote manipulation of NUCLEAR EXCURSION liquid levais, to remove the air. Richland, Wash., Apr. 7,1962 An unplanned nuclear excursion occurred in ACCIDENTAL CRITICALITY EXCUR510N A plutonium processing facility because of the Los Alamos, N. Mex., May 18, 1967 inadvertent accumulation of approximately A nuclear excursion of 4 X 10" fissions took 1500 grams of plutonium in 45-50 liters of place in the critical mockup of a high power dilute nitric acid solution in a 69-liter glass den:lty reactor. There was neither damage to transfer tank. The sequence of events which the equipment nor significant exposure to per- led to the accumulation of the plutonium in

- sons; nevertheless, the incident indicated poor the tank cannot be stated positively. However, practice and an undesirable interpretation of it is believed that, when a tank valve was

  • " operating procedures which has been corrected. opened, the solution from another process vessel The reactor mockup is fueled with elements overflowed to a sump and was drawn into the composed of fully enriched uranium in n graph- transfer tank through a temporary line be.

.ite matrix, and a smaller number of graphite tween this tank and the sump.

moderating elements. This permits a relatively When the excursion occurred, radiation and

"" small core volume (250 liters). The core, housed evacuation alarms sounded. All but three em.

in a graphite cylinder, drops out of its Be re- ployees left the building immediately, according flector for loading. Control and safety drums to well-prepared and -rehearsed evacuation are within the annular reflector. plans. Fortunately, they were not in close prox.

29

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'  ! Imity to the involved system nor in a high 6 X 10" fissions occurred in a first-cycle prod. tio

! radiation field. uct evaporator at a 6emical processing plar$

M= The course of the nuclear reaction involved The criticality accident resulted when a solu! gn m:

i ,, jl- initial criticality (10" fissions); a subsidence; tion of enriched uranyl . nitrate accidentali7 ri :

); I one or more later peaks; and after approxi- surged frcm a geometrically safe section of the

]! mately one-half hour, a declining rate of fission, evaporator into the upper critically unsafd ra dg},[ ':

which terminated in a suberitical condition 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> later. The total number of fissions was vapor disengagement section. The accidenj on occurred behind thick concrete walls in a proeg wi f approximately 8 X 10".

Of the 22 persons in the building at the time, essing cell wtich is part of the first cyc!t. m:

2. for processing highly radioactive spent fuel bo d only four employees, those who were in the elements.

ldi f room with the system, were hospitalized for Personnel response to the radiation alarim I, observation. Three of them were the system and the evacuation signal was prompt and Ti C  ; operators, who were in close proximity to the orderly. , v.

< . excursion, and who received estimated radia- Analyses of badges from 65 individuals indi.

'. tion doses of 110,43, and 19 rem. None of them cated a maximum exposure of 55 milliren( Cl g"Q.'l showed symptoms definitely referable to their gamma and 0 beta. The maximum thermal neu4 Id k ,, j radiation exposures. The fourth was sent to tron exposure detected in the badges analyzed

.g , the hospital only because he was in the room was less than 10 millirem. Analyses of nuclear at the time of the incident, accident dosimeters indicated that ,g there

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. Some fission product activity, airborne via negligible fast neutron flux associated withI

}h. the vent system and the exhaust stack, was personnel exposures.

j lj detected in the atmosphere for a brief period The radioactivity released to the atmosphere g

t j after the accident. The physical damage as a result of the accident was about twice t, j .

amounted to less than $1,000. (See TID-5360, normal background when it left the area. Loss Suppl. 4, page 17.) r

( of $6,000 resulted from cleanup of the incident.

NUCLEAR EXCUR$10N cc TIE 53G0, Suppl. 4, p. O 1961 Mear t.

l Calc Ridge, Tenn., Nov. 10, 1961 * * * *b
  • I A criticality excursior occurred as enriched 'tSL-l EXCUR510N-uranium metal, neutron reflected and -moder - Idaho Falls, Idaho, Jan. 3,1961 ated by hydrogen, was being assembled. The

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excursion was caused by a too rap,d i npproach A nuclear excursion occrrred within the re . i of the two pieces of metal used in the experi- actor vessel, resulting in .xtensive damage of i

**"* the reactor core and room and in high radia- 1 tion levels (approximately 500-1,000 rem /hr) i g'c , , There was no personnel exposure or property damage. The energy release was estimated t within the reactor room. I

, At the time of the accident, a three-man crew '

g be between 10'{ and 10" fiss,ons. i Fission prod- was on the top of the-reactor assembling the y uct contamination, both airborne and contained in the metal, decayed sufficaently overnight t control rod drive mechanisms and housing. The i

nuclear excursion, which resulted in an explo .

g. allow unhindered continuation of the experi-

' **"* sion, was caused by manual withdrawal, by 8 2 . one or more of the maintenance crew, of the g The m.eident occurred in a critical experiment laboratory specifically designed to accommodate central control rod blade from the core con. 5 such occurrences, since events of thm, nature siderably beyonil the limit specified in the cannot be considered entirely unexpected in an maintenance procedures.

I i experimental facility of this sort. (Sce TID- Two members of the crew were_ killed _in-

[ 5360, Suppl. 4, p.14.) stantly 6y tne torce of the explosion, and the

, . third man died within two hours following the ,

[, CRITICALITY ACCIDENT

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inciffeiR as a result 01 an injury to the head. '

f Idaho Falls, Idaho, Jan. 25, 1961 Of the several hundred people engaged in re-l 3 A nuclear excursion of approximately covery operations, 22 persons received radia-y# !

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-cycle prod. tion exposures in the range of three to 27 rem ing the emulsion. A criticality excursion oc-curred immediately after starting the motor

< sing plant. gamma radiation total-body exposure. The maximum whole-body beta radiation was 120 to a propeller type stirrer at the bottom of the hen a solu.

accidentally second tank.

rem.

The operator fell from the low stepladder on etion of the Some gaseous fission products, including which he was standing and stumbled out of the ally unsafe, radioactive iodine, escaped to the atmosphere door into the snow. A second chemical operator he accident outside the building and were carried down-wind in a narrow plume. Particulate fission in an adjoining room had seen a flash, which is in a proc.

first cycle mate.ial was largely condned to the reactor probably resulted from a short circuit when the motor to the stirrer started, and went to the o spent-fuel building, with slight radioactivity in the imme-diate vicinity of the building. man's assistance. The accident victim mumbled he felt as though he was burning up. Because

' tion alarms The total property loss was $4,350,000. (See of this, it was assumed that there had been a orompt and TID-5360, Suppl. 4, p. 8; 1962 Nuclear Safety, chemical accident with a probable acid or Vol. 3, #3, p. 64.)

plutonium exposure. There was no realization viduals indi- that a criticality accident had occurred for a 55 millirem CRITICALITY INCIDENT number of minutes. The quantity of plutonium

' hermal neu- Idaho Falls, idaho, Oct. 16, 1959 which actually was present in the tank was ges analyzed A nuclear incident occurred in a process about ten times more than was supposed to

""C * *# equipment waste collection tank when an acci- be there at any time.during the procedure.

E era was dental transfer was made of about 200 liters of The employee died 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> later from the

,ctated with uranyl nitrate solution, containing about 34 effects of a radiation exposure with the whole-kilograms of enriched uranium (91 percent body dose calculated to be 12,000 rem e.

atmo phere U"), from critically safe process storage tanks Two other employees received radiation ex-ibout twice to a geometrically unsafe tank through a line posure of 134 and 53 rem, respectively. Prop-

" "'** . L ss formerly used for waste transfers. erty damage was negligible. (See TID-5360, t ha incident. Limited visual inspections and test indicated Suppl 2, p. 30; USAEC Serious Accidents Issue W udear that no significant property damage or loss re. # 143, 1-22-59.)

sulted beyond the approximately $60,000 cost to recover contaminated uranium solution re- y htlCLEAR EXCUR5 ION ~

sulting from the incident. Oak Ridge, Tenn., June 16, 1958 Of the 21 personnel directly involved in this incident, seven received external exposures to A nuclear accident occurred in a 55-gallon ithin ths re- stainless steel drum in a processing area in damage of radiation. The exposures were 8, 6, 3.95, 1.50, i high radia- 1.38,1.17, and 1.17 rem. Two individuals also which enriched uranium is recovered from var-received external exposures to the skin of 50 tous materials by chemical methods in a com-100 rem /hr) rem and 32 rem. No medical treatment was re- plex of equipment. This recovery process was quired for the 21 personnel involved. (See being remodeled at the time of the accident.

ee-min crew The incident occurred while they were drain-

.embling the TID-53M, Suppl. 3, p.14; USAEC Serkus Accidents Issue #163,4-18-60.) ing material thought to be water from safe 5-housmg. The - inch storage pipes into an unsafe drum.

in an explo-E ght employees were in the vicinity of the hdr1wal, by JjfAL INJURY ACCOMPANIES CRITICALITY /

crew, of the ACCIDENT

/ drum carrying out ro'Itine plant operations tos Alamos, N. Mer., Dec. 30, 1958 and maintenance. A chemical operator was par-he cora con-ified in the ticipating in the leak testing which inadvert-The chemical operator introduced what was ently set off the reaction. He was within three believed to be a dilute plutonium solution from to six feet of the drum, while the other seven re killed in- one tank into another known to contain more . employees were from 15 to 50 feet away.

'.i n, and the plutonium in emulsion. Solids containing plu- Using special post hoc methods for determin-ollowing the tonium were probably washed from the bottom ing the neutron and gamma exposures of the to tha head. of the first tank with nitric acid and the re-

. gaged in re- sultant mixture of nitric acid and plutonium- employees involved, it was estimated that the eight men received: 461 rem, 428 rem, 413 etved radia -

bearing solids' was added to the tank contain-31 5 ,-

h q .

rem, 341 rem, 298 rem, 86 rem, 86 rem, and come promptly critical. The burst yield was 135 MW 29 rem. .

3.2 X 10" fissions. More .

Area contamination was slight, with decon. There were no radiation exposures nor an! on de 1 tamination costs amounting to less than $1,000. property damage as a result of the incident. I accident During this incident 1.3 X 10" fissions oc. L up to tl.

I curred. (See TID-5360, Suppl. 2, p. 25; EXPERIMENTAL REACTOR L tion.

I USABS Serious Accidents Issue #136, 8 Oak Ridge, Tenn., Feb.1,1956 TheI; 1

} 59; USAEC Health and Safety Information

' A homogenous UOJ: water-moderated criti' four of :

Issue #82,3-5-58; 1950 Nucliar Safety, Vol.1, I
  1. 2, p. 50. cal assembly was made prompt critical by as the rem overaddition of fuel to the assembly. Befon The fift GODIVA EXCURSION reaching the critical point, the hand. operated means- .

Los Alamos, N. Mex., Feb. 12, 1957 valve was turned off. However, fuel continued ejected to be added to the reactor because of air pres. control r The "Godiva" assembly was to be used to ir- sure in the line. Although the automatic safety in the ,

^

radiate uranium-loaded graphite samples. The system operated, assuring termination of the mechan samples were to be heated in a shielded furnace, burst, considerable fuel was displaced from the mile, tli i

' [I exposed to a " prompt" burst of neutrons and reactor. The number of fissions in the burst sonnel h then transferred to a counter for evaluation. was estimated to be about 1.6 X 10". No m The experiments are conducted at an isolated No serious exposures resulted, since all lQ- site in a building separated from the control sonnel were shielded by a minimum of five feet ment. E the reu

, i. j room and all personnel by about a quarter of of concrete. There was no significant property

, a mile. damage and all uranium was recovered. (See Y{.h} On the occasion of the accident, preliminary TID-5360, Suppl.1, p. 5.) .

EXCURE I Mn+1"- bursts were being produced. In the process of '... tion ex WATI

[ ii lowering the top safety block, an unexpected CORE MELTDOWN

. . .. j ook Ri burst occurred that was estimated to have pro. Idaho Falls, Idaho, Nov. 29, 1955 j duced 1.2 X 10" fissions. The energy was great i enough to tear the uranium parts from the The Experimental Breeder Reactor (EBR-I)' inc e assembly, knocking one to the floor, and to dis- was undergoing a series of experiments. -

Without modification, certain safety instru.! critical tort the steel rods in the frame. The uranium tions i

- mentation would not permit the conduct of the-

  • was deformed and there was much more sur- experiment; therefore, reliance was placed on: The l

face oxidation than usual.

manual control to shut down the reactor. t of the There were no personal injuries or overexpo-sures. No gamma radiation above background During an experiment, the scientist in charge ' a regb g told the operator to press the " emergency reacJ resdt was detected outside the reactor building. Ra.

diation levels in the building were high ini- tor off" button. This would have instantaneously spider ,

y s

tially. . . seven roentgens per hour gamma just removed sufficient reactivity. Owing to a mis . II4"*d inside the door (12' from Godiva) and 5,000 to understanding, the operator began by with j the s.u 20,000 counta per minute (per 55 cm' probe) drawing the control rods at normal speed. This t spider

alpha on horizontal surfaces about the room; allowed the reactor to reach a higher power the co i therefore cleanup procedures were delayed 2% than meltinganticipated and resulted in consequent of the fuel elements. of the i days until they could be completed without un-Shortly after the accident, there was a rise ; ment necessary exposure to cleanup personnel.

The total property loss was estimated at In the radiation level in the building. The build. { large '

$2,400. (See TID-5360, Suppl. 2, p. 18; ing was evacuated. There were no personnel * * * "

USAEC Health and Safety Information Issue injuries.There was minor contamination of the Th.

3 #75,1-8-58.) sodium potassium coolant. (See TID-5360, p. mally i

30.) cally.

HONEYCOMS EXCUR$10N incide BORAX l EXPLO510N feet et l Los Alamos, N. Mex., July 3,1956 Idaho Falls, Idaho, July 22, 1954 '

expos.

! Too rapid assembly caused the system to be. Destruction of the Borax I Reactor released 18-)

32

\ ,

I w _ _ _ . _ _ _ _

SUPERCRITICALITY EXPERIMENT

yield w u 135 MW.see of fission energy Los Alamos, N. Mex., Feb. 3,1954 Store than 200 safety experiments were made
res nor any on the Borax ! Reactor simulating control rod The incident occurred in the course of an ex-

. incident. accidents. For the last test, conditions were set tensive study of the properties of supercritical up so that the reactor would be run to destruc- radiation bursts produced by an assembly of LIOD- fissionable metal. This study waa' covered by a The tests were carried out by withdrawing specific procedure. A reference check of critical conditions preceded each supercritical burst.

.ertted criti. fourof the nye control rods far enough to make itical by an the reactor critical at a very low power level. To attain rapidly sullicient power for a de-ibly. Before The dfth rod was then fired from the core by layed critical check, it was customary to set

.nd. operated means of a spring. In this test, the rod was control rods at the position of minimum reac.

el continued ejected in approximately 0.2 seconds. After the tivity and insert a reactivity booster in the of air pres. control rod was ejected, an explosion took place form of a fissionable metal slug. This time, when matic safety in the reactor which carried away the control the booster was inserted, radiation indicators ition of the mechanism and blew out the core. At half a and the assembly temperature recorded went ed from the mile, the radiation level rose to 25 mr/hr. Per- oliscale (to return in a few minutes), and n th) burst sonnel were evacuated for about 30 minutes. scrams were actuated. The resulting shock

~

'"* No one was injured and the destruction of separated parts of the assembly and damaged ince cli per. the reactor was part of the cost of the experi. steel supporting members.

i of five feet ment. (See TID-5360, p. 29.) There was no injury. The property loss was l int property an expenditure of $600 for repair of the as-IXCURSION IN AN ENRICHED URANtUM WATER SOLUTION SUDDEN INCREASE IN REACTIVITY DURING Cok Ridge Tenn., May 26, 1954 CONTROL ROD TESTS Lemont, Ill., June 2,1952 The experiment in progress at the time of the or (EBR-1) incident was one in a series designed to study Manual withdrawal of a control rod from a

' " "L8- critical assembly caused an accidental super-criticality conditions of uranium-water solu-fety instru- t ons in annular cylindrical containers. criticality.

. duct of the The operation being conducted was the com-The cau:e of the accident was a displacement parison of a series of newly-manufactured con-1 4 plactd on actor, of the central tube, effectively a poison rod, t trol rods. The assembly had been operated with at in chrrge a region of less importance. This displacement the standard control rod. It was then shut down resulted from a dislocation of the posittomng by inserting all control rods and draining the

gincy reac.

) .mtaneously spider by a pin, used to connect sections of the water moderator, a standard safe method of

.g to a mis.

liquid level indicator rack, protruding beyond shutting down the assembly when core changes the side of the rack.and engaging a leg of the are to be made. The standard rod was removed a by with-

, ; speed. This spider as the indicator was raised. Removing and the first of the series of control rods to be

<h:r power the compressional force from the top of the tested was inserted.

central tube allowed it to fall against the maide The assembly was filled with water with the c:nsequent of the 10-inch cylinder. Although the displace- test control rod fully in and the standard type ment was small, it was sufficient to cause a control rods fully inserted. Withdrawal of one was a rise large increase in the effective neutron multiph,- of the standard control rods 32 centimeters

'. Tha build.

cation, caused the assembly to become critical and the o personnel inti:n cf the The safety system apparently operated nor- power was leveled off while the desired meas.

!D-5360, p. mally and the reaction was stopped automati- urements were made. The control rod was then cally. All personnel in the building during the reinserted into the original "in" position.

Incident were protected by a minimum of five With the water still in the assembly, the four feet of concrete shielding; therefore, no serious members of the crew then went into the assem-exposures were incurred. (See TID-5360, p. bly room for the purpose of replacing the con.

tcr released 18.) trol rod which they had just tested. The group 33

1 f li leader went up on the platform, reached out too short a time to determine whether or not. tofore, with his right hand and started to pull out the the assembly was critical. The operators next; for saf.

tested rod. As soon as he had withdrawn it heard the safety controls actuate, instrument' Nort.

i about one foot, the center of the assembly indicators moved otiscale, scalers jammed, andi control emitted a bluish glow and a large bubble the most startling manifestation was that ofI by a ke I formed. Simultaneously, there was a mufTled the breakdown of " counters" playing back mamial

, explosive noi.ae. The group leader let go of the through the public address system. The portable control rod which he was removing and it fell " Juno" in the control room was ofTscale. Pre.! ture n back into position. The crew left the assembly sumably, a further rod withdrawal had been sensitis room immediately and went to the control room. made. the nei Four employees received radiation exposures There were no injuries. The building was suc- after t!

i ranging from 12 to 190 rem. (See TID-5360, cessfully decontaminated, except for the test had rit

p. 23.) room and assembly. Before decontamination of ' The

[ this area was completed, a fire occurred and,, A K of

{ CRITICALITY RESULTS FROM ERROR IN subsequently, the building was abandoned be- tial pi c CALCULATIONS cause of the respread of contamination. (See measui Los Alamos, N. Mex., Apr. 18, 1952 TID-5360, p.14.) mately d Two stacks of fissionable disks were being tempe
I built up stepwise to give a slightly suberitical SCRAM MECHANISM CAUSES CRITICALITY suflicit assembly with the two stacks brought together Los Alamos, N. Mex., Mar. 20, 1951 by the I f' I j by remote control. The individual stacks were Interactions between two masses of fission. Thei

!; 4 built up by hand in fixed assemblies and the able material in water were measured at pro- r the w.

f two stacks brought together only by remote gressively decreasing horizontal separations. accoral P. mechanisms. Remotely controlled operations established the age do

. After two members of the operating crew desired horizontal separation of the two com. mat er' calculated erroneously from previous steps that ponents and flooded the system.

one more disk could be added safely, the disk After the final measurement, the system was INADW was added and, with attempted caution, the " scrammed" (a rapid disassembly mechanism IN I i! ,

system was assembled remotely. Radiation in- Los Al-dicators went oti. scale, actuating scrams, neu- was actuated). Safety monitor indicators went g g off-scale, neutron counters jammed, and the . A I tron counters jamme:1, and a puff of smoke was television viewer indicated steaming. Within a ' techni observed on the television viewer. Within three few minutes, indicators and counters returned tud' to five minutes indicators and counters returned to operating ranges and indicated a rapid de- l TheI to operating ranges. cay of radiation.  ; .

q There was no injury, no loss of material, no There was no injury, no loss of material, and I b

ll damage to facilities, and negligible loss of no damage to facilities. (See TID-5360, p.13.) which l

operating time. (See TID-5360, p. 7.) .

j' CRITICALITY DURING CONTROL ROD TESTS EXCURSION IN A PLUTONIUM NITRATE Los Alamos, N. Mex., December 1949 The spacci SOLUTION Richland, Wash., Nov. 16, 1951

  • I'" U# was Wng remdeW M Mer , lower power operation. As part of the required al-matet Upon completion of volume measurements, it terations, two new control rods had been placed ' time.
  • was thought that some additional information in the system.in addition to the three existing Thi j as to the required dilution could be determined control rods. I edge i by finding where criticality might occur on the The employee who had built the rod control ' lower rods.The control rod was pulled first with very mechanism wanted to test the comparative fall hemi

.g, J

minor reactivity effect. Following this, the times of these new rods. lie opened the enclo , This 1 safety rod was withdrawn intermittently at sure on top of the reactor and manually lifted lowe, high speed (3.3"/sec). A waiting period for the rods, neglecting the possibility that this screv.

the delayed neutron effect of about 15 seconds would affect the reactivity of the reactor be- uppei i lj was made just prior to the incident. This was cause of its higher power arrangement. Here- ing a*

i 34 h -

m i I

t l

tofore, the three existing rods were suflicient At that time, the screwdriver apparently her or not slipped and the upper shell fell into position alors next . for safety, around the fissionable materia). Of the eight

'nstrument Normally, rods are raised remotely from the mmed, and control room when the control panel is activated people in the room, two were directly engaged in the work leading to this accident.

as that of by a key switch. Since the rods were pulled out The " blue glow" was observed, a heat wave ying back manually with the panel being ott, no equipment fcit, and immediately the top shell was slipped I he portable was turned on except a direct reading tempera- - off and everyone left the room. The scientist scale. Pre. ture meter. Therefore, there were no neutron who was demonstrating the experiment received had been sensitive devices to record or warn of a rise in suflicient dosage to result in injuries from the neutron level. It was not observed until which he died nine days later. The scientist ag was suc. after the incident that the reactor temperature had risen about 25' centigrade. assisting received sufficient radiation dosage to er ths test cause serious injuries and some permanent

'inati:n of The removal of the two rods probably gave a arred and, e.K of about 0.86 percent, producing an ini- partial disability.

The other six employees in the room suffered ndoned be- tial period of about 0.16 second. Since the measured temperature coeflicient is approxi- no permanent injury. (See TID-5360, p. 4.)

ition. (See mately -0.034 percent k/C', the observed temperature rise indicates the rods were out (/ATALITY FROM CRITICAL MASS EXPERIMENTS

- Los Alamos, N. Mex., Aug. 8,1945 LITY sulliciently long so that the reactor was stopped by the negative temperature coefficient. During the process of making critical mass There were no injuries. The employee doing studies and measurements, an employee work-of fission.

ed at pro. the work received 2.5 rem of gamma radiation ing in the laboratory at night alone (except for pzr ti:ns. according to his film badge. There was no dam- a guard seated 12 feet away) was stacking

,lished the age done to the reactor and no loss of active blocks of tamper material around a mass of material. (See TID-5360, p. 21.) fissionable material, twa c:m. *# " *~

  • "" .oyee was I fling one last piece of vatem was INADVFETENT SUPERCRITICALITY RESULTS I "'

iN DEATH # # "" quite heavy. As this aechInism "#

et:rs wint ten ~ Alamos, N. Mex., May 21, 1946 piece neared the setup, the . instrument indicated that fission multiplication would be produced,

  • A senior scientist was demonstrating the and as the employee moved his hand to set the I" " technique of critical assembly and associated block at a distance from the pile, he dropped 4 returned studies and measurements to another scientist. the block, which landed directly on top of the reoid de- The particular technique employed in the dem.

onstration was to bring a hollow hemisphere of setup.

, A " blue glow" was observed and the employee

', tert I, rnd beryllium around a mass of fissionable material proceeded to disassemble the critical material

  1. ' E' N'I which was resting in a similar lower hollow and its tamper. In doing so, he added heavily to hemisphere. the radiation dosage to his hands and arms.

(1575 The system was checked with two one-inch The employce received sufficient radiation spacers between the upper hemisphere and the dosage to result in injuries from which he died for higher lower shell which contained the fissionable 28 days later.

'luired al- material; the system was suberitical at this The guard suffered no permanent injury.

cen placed time. (See TID-5360, p. 2.)

is existing Then the spacers were removed so that one edge of the upper hemisphere rested on th UNANTICIPATED CRITICALITY IN WATER.

,g g lower shell while the other edge of, the upper SHIELDED ASSEMBLY g hem, i sphere was supported by a screwdriver. Los Al m s, N. Mex., June 4,1945 the enclo- This latter edge was permitted to approach the sally lifted An experiment was designed to measure the lower shell slowly. While one hand held the th:t th,si screwdriver, the other hand was holding the critical mass of enriched uranium when sur.

rounded by hydrogenous material. The enriched

<cactor be. upper shell with the thumb placed in an open-ient. E re. ing at the polar point. uranium was in the form of cast blocks of the 35

. p --- .

.k

{:  !

metal, %"X %"X %" and %"X %"X1". The ply valve and opening the drain valve. The blocks were stacked in a pseudospherical ar- building was evacuated.

rangement in 12 courses in a 6"X6"X6" poly- The three individuals involved received ex-

- ethylene box. The voids in the courses were cessive radiation exposures, estimated in two filled with polyethylene blocks of appropriate cases as about 66.5 rem, and in the third as

dimensions. The polyethylene box was sup- 7.4 rem. The doses delivered to the head and ported by a 2-foot-high stool withm a 3-foot neck of these individuals may have been con-

, cubical steel tank. The tank had a 2-inch open- siderably greater. They were hospitalized for I ing in the bottom through which it could be observation, but no untoward symptoms ap-

filled and drained by means of supply and peared. No significant changes in blood counts ,

l drain hoses attached to a %-inch tee. The were observed, and sperm counts on one occa.

AEC il opening in the tank was fitted with a shutoff sion, sometim'e after the incident, were normal.

j valve, as was the drain hose. A polonium. It is not believed that the individuals concerned

,  ; beryllium source of about 200 me strength was received any significant radiation damage.

i'  ; placed on top of the assembly. A fission chamber There was no damage to equipment, no loss of

?

j and a boron proportional counter were used to active material, and no local contamination follow the experiment. problem. (See TID-5360, p.10.)

? '

The immediate supervisor was absent from T

$ the scene when the experiment was begun. Ac. DRAGON REACTOR EXCURSION 7 cording to one of the operators, t'he water level Los Alamos, N. Wx., Feb. 11, 1945 h was raised above the polonium-berryllium vt This was the first reactor designed to gener- V

$ , source with the supply valve almost fully open.

At this point, a slight increase in counting ate prompt power excursions. Prompt critical 5' 9 3 was obtained by dropping a slug of Ull. In QI i rate was observed, which corresponded with styrex through a vertical hole in a small as. &"i' i,; 4 what had been observed previously when the sembly of the same material, which was diluted p!! source alone was immersed in water. A few [

w th polyethylene and reflected by graphite .:

seconds later, the countmg rate began to in-3 i crease at an alarming rate.

and polyethylene. Near the end of the planned sequence of burst of increasing power, ' a

[

At this point, the supervisor returned, walked 6 X 10" fission burst blistered and swelled the t y . to within three feet of the tank and noted a small cubes comprising the assembly matrix. I blue glow surrounding the box. Simultaneously, No material was lost, there was no contamina. Archii

' -]  : i the two operators were hastily closing the sup- tion, and there were no exposures. i

' 3 l 1 Geve 1

1

(

4

- t *Re

.)

't l

h I ,

q .

.I 36 L. .

EXHIBITli Applicant's Interrogatory Answers dated 5/20/61 t

l t

i

Applicant's Response To Interrogatory No. 8.

Applicant has no information or documentation that would indicate that any specific forms of maintenance have had to increase because of the age of the reactor.

Applicant's Response To Interrogatory No. 9.

Console logic, log N and period amp., area radiation monitors, CIC power supplies, rod position power supply, Argon-41 monitor, secondary effluent monitor, NEL intercom, Compensated ion chamber.

Applicant's Response To Interrogatory No. 10.

Assuming " plans" referse to drawings and tech manuals, the answe r is none known.

(CONTENTION XVII)

Applicant's Response To Interrogatory No. 3.

v/ a. Not known.

l b. It was moved to NEL, probably in 1968 but the date in not known for sure.

c. Not applicable.

! d. Not applicable.

v' e. No.

v f. Unknown.

/ g. Unknown.

I i

149 l

l

h. Not to applicant's knowledge.
1. Not applicable.
j. Unknown, but possibly the USGS, Menlo Park, Calif ornia ,
k. This likely pertains to accelerometers used in comjunction with the vibration testing studies.

Applicant does not know precisely where they were placed.

Applicant's Response To Interrogatory No. 4.

Applicant is aware that the State of California Division of Mines and Geology placed approximately ten accelerometers in or on the Math-Science Structure directly above the reactor building sometime in the late 1970's. This activity was not related to reactor operations but apparently to the fact that the Math-Sciences Building has been the subject of several dynamic response tests during and since its construction. To applicant's knowledge the earlier studies were reported in masters thesis which can probably

'be located in the engineering library under thenames R. Shannman, J. Scott and B. Bunce. Applicant's staff have not examined this literature. To applicant's knowledge the Division of Mines is using Kinemetrics accelerometer systems, Model CR-1, although it is believed that no records have been generated yet by this system since its installation. Apparently the testing is part of a larger sampic testing of buildings in Los Angeles that is being conducted by the Division of Mines. H. LaGesse of the Division of Mines is 150

I i

I the individual who services the instruments and collects any data:

California Divisions of Mines, 2811 O Street, Sacramento.

Applicant's Response To Interrogatory No. 5.

Applicant is unaware of any instruments other than those described in the vibration studies of C.B. Smith, those installed by the Bureau of Mines, and the USGS instrument.

a. Not applicable.

Applicant's Response To Interrogatory No. 6.

v a. Applicant has no special knowledge of the results. The results should be reported in "A Simulation of Earthquake Effects on the UCLA Reactor Using Structural Vibrators" by Matthiesen and Smith, October 1966.

/ b. See response above.

  1. c. See response above.

v/ d. No.

e. Unknown.
f. Unknown.

Applicant's Response To Interrogatory No. 7.

a. Applicant objects to the question on the grounds that it is vague, ambiguous and uncertain.

y b. None.

j c. Unknown, but see operating logs.

151

g- d. Not known, but see any reports made from the study referenced in Interrogatory no. 6.

e. No+. applicable.

, f. Not to applicant's knowledge.

Applicant's Response To Interrogatory No. 8.

s a. Yes.

A b. None.

e c. Unknown.

'd. Unknown.

e e. Not to applicant's knowledge.

/ f. Unknown.

g. Not applicable.
h. Not applicable.

y L. No.

' j. No.

l

k. Not applicable.

l l 1. There was no reason to believe that that earthquake experience was relevant.

p m. None.

/ n. None.

/ o. None.

.5ppilcant's Response To Interrogatory No. 9.

v a. Applicant objects to the question on the grounds that the question seeks information whien 152

applicant cannot provide without conducting extensive scientific and engineering studies and evaluations. The applicant has neither the time, nor the personnel, nor the resources to conduct such studies,

b. See response above.

Applicant's Response To Interrogatory No. 10.

a. In practice, the mass is mass minimized under a constant volume constraint, and the Rudman/Vitti statement represents a more general situation.

Realization of the positive reactivity effect l

requires a physical expansion of the core and the addition of wate r. There is no contradiction.

b. Not applicable.
c. See response to a, above.

, d. Applicant objects to the question on the grounds that the question seeks information which I

applicant cannot provide without conducting extensive scientific and engineering studies and evaluations. The applicant has neither the time, I nor the personnel, nor the resources to conduct l

j such studies.

l l

l l

l 153 l

l 1

Applicant 's Response To Interrogatory No. 11.

v a. No.

b. The statement adds little to the discussion; in any case, applicant was unaware of the particular statement.

v c. No,

d. Not applicable.

Applicant's Response To Interrogatory No. 12.

Yes.

a. The system provides demineralized water upon demand.
b. There are three vessels, one of which contains a resin de-ionizing bed. The system volume is not more than 100 gallons.

Applicant's Response To Interrogatory No. 13.

Yes.

a. Applicant objects to the question on the grounds that the question seeks information which 1

applicant cannot provide without conducting extensive scientific and engineering studies and evaluations. The applicant has neither the time, nor the personnel, nor the resources to conduct such studies.

b. See response above.

154 1

Applicant's Response To Interrogatory No. 14.

a. The floor panels are approximately 6 inches, f
b. Reinforced concrete.
c. Yes.

v d. Unknown..

e. Approximately 2000 square feet.
f. Approximately 625 square feet.
g. Unknown.

v h. Unknown.

/ i. Unknown.

- j. Unknown.

v k. Unknown.

v 1. Unknown.

v m. Unknown.

n. Reinforced concrete of approximately 150 pounds per cubic foot.
o. 0; ten tons.
p. It is not.

/ q. Unknown.

r. Unknown.

' s. Yes.

t. Applicant objects to the question on the grounds that the information sought is privileged material that has been held in strict confidence by applicant in order to insure the security of

, the facility and its contents, including its critical records and documents.

155 1

u. Approximately three weeks.
v. Applicant objects to the question on the grounds that it is vague, ambiguous and uncertain.
w. Probably the center.

l Applicant's Response To' Interrogatory No. 15.

a. Reinforced concrete.

/,

b. Unknown; requires detailed examination of working drawings and specifications.

l , c. See response above.

f d. See response above.

v e. See response above.

vf. See response above.

<g. See response above.

- h. See response above.

f

1. Applicant objects to the question on the grounds that the question seeks information which appli-cant cannot provide without conducting extensive scientific and engineering studies and evalua-tions. The applicant has neither the time, nor the personnel, nor the resources to conduct such studies.

v j. See response above.

f k. See response above.

  1. 1. See response above.

/

m. See response above.

156

n. See response above.

- o. See response above.

- p. See response above.

Applicant's Response To Interrogatory No. 16.

Applicant objects to the question on the grounds that the question seeks information which applicant cannot provide without conducting extensive scientific and engineering studies and evalua-tions. The applicant has neither the time, nor the personnel, nor the resources to conduct such studies,

a. See response above.
b. Not applicable.
c. Not applicable.
d. None; applicant does not know the " largest capable fault" although applicant assumes the Inglewood fault is the most likely seismological feature to cause a severely destructive earth-quake at UCLA.

Applicant's Response To Interrogatory No. 17.

Unknown to applicant.

a. Not applicable.
b. Not applicable.
c. Not applicable.
d. Not applicable.

157

i Applicant's Response To Interrogatory No. 18.

p Unknown to applicant.

a. Not applicable.
b. Not applicable,
c. Not applicable.
d. Not applicable.

Applicant's Response To Interrogatory No. 19.

v No.

a. Not applicable.
b. Not applicable.
c. Not applicable.

i

d. Not applicable.

k Applicant 's Response To Interrogatory No. 20.

- No.

a. Not applicable.
b. Not applicable.
c. Not applicable.
d. Not applicable.

Applicant's Response To Interrogatory No. 21 '.

/ Not to applicant's knowledge. ,

a. Not applicable.
b. Not applicable.
c. Not applicable.

158

Applicant 's Response To Interrogatory No. 22.

The seismic scram interlocks are not specifically earth-quake sensors, and are referred to by applicant as " closure sensors." They are conventional microswitches, six in number, wired in series, and are actuated by displacements of the shield blocks.

a. Assuming the sensor is actuated, the sensor response time is almost instantaneous. The shut down time in dictated by rod drop time (less than one second) or time to dump core water (approxi-mately 20 seconds to dump 20% of the water).

Af ter either of these events, the power level will decay exponentially from the prompt-drop level on an 80 second period.

b. Displacements of approximately one-eighth to three-sixteenths inches will actuate the sensors.
c. Not to applicant's knowledge.
d. Circuit continuity is checked prior to each reactor start-up. Positioning is checked whenever shield blocks are moved for core maintenance.

l

[

e. Not applicable.
f. Not to applicant's knowledge.

l

g. None, except for what applicant has mentioned in l response to these interrogatories.
h. None.
i. No.

159

r u _

j. Yes.
k. Unknown.
1. None.
m. Applicant is undecided at this time and will make a determinaton as to the documents it will produce only af ter a request for production is received.

Applicant's Response To Interrogatory No. 23.

' Applicant makes no contention.

- a. Not applicable.

' b. Not applicable.

- c. Not applicable.

Applicant 's Response To Interrogatory No. 24.

t Not applicable.

a. Not applicable.

V y b. Not applicable.

, c. Not applicable.

Applicant's Response To Interrogatory No. 25.

/ Not applicable.

a. Not applicable.

/

/ b. Not applicable.

/ c. Not applicable.

160

Applicant's Response To Interrogatory No. 26.

a. Yes.
b. Those that would bond (in tension) the foundation to any underlying soil that might be hypothesized to accelerate downward at more than one g.

g c. Applicant's response is not based on any specific facts, information or documents but instead on the absence of any facts, information or documents which would contradict applicant's response. Applicant is undecided at this time and will make a determinaton as to the documents it will produce only af ter a request for production is received.

d. Anything less than one g. The facts are normally expressed by the physical laws of Sir Isaac Newton (1642-1727), English mathematician and natural philosopher.

v e. Unknown in the directions specified.

f. Not applicable.
g. See Exhibit B.

/ h. It is a general observation to the effect that 1

most soils have negligible tensile strength.

Applicant's response is not based on any specific facts, information or documents but instead on the absence of any facts, information or l documents which would contradict applicant's response.

161

/

1

(

i. It is a general conclusion based upon the stated premises and has no other independent documentation.

- j. Not to the knowledge of applicant's staff.

k. Applicant objects to the question on the grounds that it is vague, ambiguous and uncertain.' . ,

- 1. Unknown. - 's.

/.,

, m. Unknown. /

n. No. '
o. Applicant objects to the question on the grounds - ,, -

that it is vague, ambiguous and uncertain. '

/ p. Unknown.

y q. No.

k a9,,

Applicant's Response To Interrogatory No. 27. -

j Applicant objects to the question on the grounds that the question seeks information which applicant cannot provide without conducting extensive scientific and engineering studies and evaluations. The applicant has neither the time', nor the personnel, nor the resources to conduct such studies.

Applicant's Response To Interrogatory No. 28.

v None to applicant's knowledge.

Applicant's Response To Interrogatory No. 29. m

/

- / None to applicant's knowledge.

~.

162 -

i s d

9 A

I f

t a

, Applicant's Response To Interrogatory No. 30.

.j v None to applicant's knowledge.

y a. None.

- b. Unknown.

6 c. None.

Applicant's Response To Interrogatory No. 31.

v Unknown.

f ,

a. None.
b. Not applicable.

, Applicant's Response To Interrogatory No. 32.

u Applicant is not; the items are merely relevant factors.

, i, r

^ - p a. Nothing to applicant's knowledge.

y b. Nothing to applicant's knowledge.

~

c. None.

- Applicant's Response To Interrogatory No. 33.

V Unknown.

j .

J Applicant's Response To Interrogatory No. 34.

b Unknown.

/ [ f a. Unknown.

/ -'

b. Not applicable.

r,?

/

s .'

, n

.f l

163 O

d

- . i. -/ .

Applicant's Response To Interrogatory No. 35.

To applicant's knowledge the only data that may be in existence relates to routine maintenance reports, work orders, etc.

Applicant is undecided at this time and will make a determinaton as to the documents it will produce only af ter a request for production

! is received.

Applicant's Response To Interrogatory No. 36.

Applicant's staff believes that the attribution of a water leak to the earthquake was found, upon core entry, to be either erroneous or at least not clearly related to the earthquake.

Applicant's staff believes that the leak source was ultimately traced to corrosion in piping that was embedded in concrete below the core rather than piping or fuel box failure within the core.

To the extent that the applicant has knowledge of the information requested it is contained in applicant's records and documents, although such records and documents are likely to be incomplete particularly for the earlier years of reactor operations. The following records and documents are the main sources of such information as applicant has available: documents no. 1, 2, 3, Sa and 10.

a. See response above.

i b. See response above.

c. See response above. Applicant has observed that the imbedded piping was abandoned and new piping was substituted by core drilling for passage 164 t

through the concrete. New fuel boxes were built to adapt to the new piping.

d. See response above. Applicant is undecided at this time and will make a determinaton as to the documents it will produce only after a request for production is received.

Applicant's Response To Interrogatory No. 37.

a. The information requested can be found in the follouing records and documents: document no.

41.

b. See response above.
c. See response above.
d. See response above.
e. Unknown.
f. Unknown.
g. None.
h. See a above.

Applicant's Response To Interrogatory No. 38.

Approximately one-eighth inch.

Applicant 's Response Tb Interrogatory No. 39.

To the extent that the applicant has knowledge of the information requested it is contained in applicant's records and documents, although such records and documents are likely to be 165

incomplete particularly for the earlier years of reactor opera-tions. The following records and documents are the main sources of such information as applicant has available: document no. 1.

Applicant 's Response To Interrogatory No. 40.

- Unknown.

Applicant? ? Response To Interrogatory No. 41.

p None to the knowledge of applicant's staff.

Applicant 's Response To Interrogatory No. 42.

Not to applicant's knowledge; it is unlikely that the Uniform Building Code was in effect.

Applicant's Response To Interrogatory No. 43.

/ Unknown.

Applicant's Response To Interrogatory No. 44.

The Daily Bruin article is in error. The University has contracted with outside consultants to prepare a study of UC build-ings. The study is to establish priorities for the funding of seismic studies by the state in the future. The current study is not a seismic study at all. The study is in progress but it is expected that the study will be completed and reported to the state within the next several months. The buildings will apparently be ranked according to square footage, occupancy, type construction, 166

reconstruction costs and other factors. The entire " findings" for each building will be contained on a single line entry and will consist only of the type factors mentioned above. On the basis of the rankings the state will decide for which buildings it will fund seismic studies,

a. See response above.
b. See response above,
c. Unknown.
d. None.
e. Applicant is undecided at this time and will make a determinaton as to the documents it will produce only af ter a request for production is received.

Applicant's Response To Interrogatory No. 45.

s' Unknown.

a. Not applicable.
b. Not applicable.

Applicant's Response To Interrogatory No. 46.

v' Unknown,

a. Not applicable.
b. Not applicable.

Applicant's Response To Interrogatory No. 47.

v/' Unknown.

167

a. Not applicable.
b. Not applicable.

Applicant's Response To Interrogatory No. 48.

No information is required.

a. Not applicable.

Applicant's Response To Interrogatory No. 49.

Not to the knowledge of applicant's staff.

(CONTENTION XVIII)

Applicant's Response To Interrogatory No. 3.

Applicant objects to the question on the grounds that the information sought is privileged material that has been held in strict confidence by applicant in order to insure the security of the facility and its contents, including its critical records and documents. Academic reviews are part of the peer review process which is deemed to be confidential by the applicant. Moreover, the academic reviews of the School of Engineering and Applied Science ,

are not relevant to the financial qualifications of the applicant, The Regents of the University of California.

a. Applicant is undecided at this time and will make a determinaton as to the documents it will produce only after a request for production is received.

168

O o

.. . .. IXHI3IT G ilUREG/CR-2198 4

Fuel Temperatures in an Argonaut React:r Core Following a Hypothetical Design Sasis Accident (USA)

Prepared by G.E. Cor:

June 1981 .

Los Alamos National Laboratory Los Alamos, NM 87545 -

for the .

Division of Licensing Office of Nuclear Reactor Regulation

- U.S. Noclear Regulatory Commission Washington, DC 20555 NRC FIN A7122 i

i.

l

'l i

the " graphite stack can safely withstand the 0.25 G maximum earthquake loadinga. The review also concluded that vertical motion was unlikely to dislodge the stack of graphite blocks and that large deformations in any direction would be resisted by the biological shield.

The acceleration forces that should be applied to the ARGONAUT for seismic analysis will depend on local conditions such as the distance from the nearest fault. Therefore, it cannot be estimated whether 0.25 g's ground acceleration would be conservative or unconservative.

However, if we assume an extreme acceleration of 1 g's, the maximum compressive stress in the graphite is still less than one-tenth the compressive strength. Because the blocks are not interlocked, tensile stresses should not occur. There may be some chipping at corners and .

abrasion from compressive shear, but these small changes in geometry should not adversely affect the heat transfer. Horizontal acceleration can cause the graphite blocks to slide against the metal fuel box..es and, if theget is severe, crush the box and eduel elements laterally.

The probability and extent of crushing cannot be predicted without dynamic structural analysis. The dynamic analysis of the seismic.

response of an HTGR core (Ref. 1) that was campleted at Los Alamos in 1975 is an example of the type of modeling needed to predict lateral crushing. It is interesting that the maximum impact force between adjacent graphite blocks with a 1 g's horizontal base acceleration was calculated as 0.3 MN (67,000 lb). If this analysis _were to hold for the ARGONAUT,1ateral crushing seems possible under the severe acceleration.

The core might also be crushed in the vertical direction _byging lead bricks, ac y lugi,_luel box shielding plugs. or the massive

@ {ble concrete shield blocks. These components are interlocked and l supported by the reirforced concrete shield. Even thougn the concrete in l the shield may crack and spall, it is difficult to imagine that large displacements could occur that would allow these interlocked components to fall.

In summary, crushing in the lateral direction. seems possible under

-.- v ~

severe accelerations, and crushina in the vertical direction __se_ ems less likely. Any crushing that takes place will tend to "scueeze the air out"

! from between the fuel plates so that heat conduction to the surrounding graphite will be imoroved relative to the uncrushed state.

qw; ad/

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