ML20069E843

Requests ASLB Ruling on Committee to Bridge the Gap Motion for Partial Summary Disposition of Contention Xvii.No Matl Facts Are in Dispute.Related Correspondence

ML20069E843
Person / Time
Site:	05000142
Issue date:	03/15/1983
From:	Hirsch D COMMITTEE TO BRIDGE THE GAP
To:	Frye J, Luebke E, Paris O Atomic Safety and Licensing Board Panel
Shared Package
ML20069E846	List: ML20069E843 ML20069E858 ML20069F119
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NUDOCS 8303220203
Download: ML20069E843 (4)

Text

n COMMITTEE TO BRIDGE THE GAP 1637 BUTLER AVENUE #203

• LOS ANGELES, CALIFORNIA 90025 D'y' QO (213) 478 0829 March 15,1983 Dr. Emmeth A. Luebke NI I23 John H. Frye, III Administrative Judge Administrative Judge Chaiman Atomic Safety and Licensing Board; ,

Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commissi'o n n

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Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar H. Paris Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of The Regents of the University of California (UCLA Research Reactor)

Docket No. 50-142 (Pronosed Renewal of Facility License)

RE: AGREHISIT REACHED ON CBG MOTION FOR SUEAF.Y DISPOSITIQU OF SEISiIC CONTSITION: REQUEST FOR IMMEDIATE RULING

Dear Administrative Judges:

By Motion dated September 7,1982, CBG oved for summary disposition of Contention XVII (Seismic) or, in the alternative, partial summary disposition thereof. To the motion was affixed, as required, a short, concise statement of the material facts asserted by CBG to not be in dispute.

By letter dated October 29, 1982, the Staff infomed the Board "that it does not dispute any statement attached to the CBG motion for partial summary disposition of Contention XVII."

By letter dated January 7, 1983, the Applicant notified the Board that it disputed none of CBG's facts. on the seismic contention except facts 2,3,6, and 8.

At the February 23, 1983, prehearing conference the Board directed CBG and the Applicant to confer as to possible resolution of the disputes We have done so and reached agreement by making as to those four facts.

minor language modifications to the statements to resolve semantic difficulties The modifications are attached.

perceived by the Applicant in those statements.

Thus, none of the material facts affixed to CBG's motion as to Contention XVII on the seismic matter are now disputed by any party:

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2 The seismicity of the site, the ability of a major earthquake to damage the reactor fuel and release fission products to the environment, and ensuing consequences of at least 10 Rom to the thyroid to members of the public are admitted by all parties. The only r==4ning dispute for hearing on this matter is how much greater than 10 Rem to the thyroid those doses might be.

CBG thus respectfully requests, in light of this new development, that the Board rule now on CBG's motion for partial summary disposition of Contention XVII. CBG ist entitled to such a ruling now, as there are no longer material facts in dispute and because such a ruling would greatly facilitate preparation by all parties for the summer evidentiary hearings on the inherent safety issues. As seismically-induced fission product release is one of the key hazard scenarios to be reviewed at that hearing (it is, in fact, the hazard sequences Staff has proposed as the maximum credible),

a prompt ruling at this time would greatly facilitate scoping hearing preparation on this particular accident sequencej

.su tted,

<U Respectfully % L Daniel Hirsch President COMMITTEE TO BRIDGE THE GAP-ccw/ enclosures service list

. o STATB4FUT OF MATERIAL PACTS AS TO WICF NO GUTUINE DISPUTE EXISTS AS TO COPITHlTION XVII

1. The reactor is is a seismically active area.

• • 2. The UCLA reactor may be in the path of at least one active earthquale fault.

• • 3. The Newport-Inglewood fault is about two miles from the UCLA reactor, and may extend closer.

4 The Newport-Inglewood Fault was responsible for the Long Beach earthquake of 1933.

5. The Newport-Inglewood Fault is capable of an earthquake of a magnitude 7.5 on the Richter Scale.

• • 6 The current probability of occurrence of a 7.5 magnitude earthquake along the Newport-Inglewood Fault is approximately .1% annually, or a one in fifty chance during the proposed twenty-year license period.

7. The Santa Monica Fault Zone is within one mile of the reactor.

• • 8. The Santa Monica Fault Zone is variously estimated as being capable of an earthquake of magnitude 6.7 to 7.5 on the Richter Scale.

9. The reactor could also be affected by a quake along the southern San Andreas Fault, which has a capacity of 8 3 magnitude with a probability of occurrence of between 2 and 5% annually, or greater than 50% over the next thirty years.

10. A major earthquake could bring down the several-story structure built atop the reactor building and crush the reactor core.

11. Mechanical damage to the fuel (i.e. breaks in the cladding and fuel meat) could result from core-crushing.

12. Core-crushing could result from lateral accelerations in an earthquake, with or without the above structures collapsing.

13. Mechanical damage to the fuel resulting from an earthquake could result in fission products escaping to the environment.

16. It is conceivable that subsequent flooding of the reactor room could occur as the result of earthquake-induced failure of the Stone Canyon Reservoir which is positioned in the hills to the north of the UCLA campus.

15. Subsequent flooding of the reactor could result,in the dispersion of fission product releases in the flood water.

16. Neither Staff nor Applicant has done a detailed seismic analysis of the l

reactor site nor a detailed structural analysis of the reactor structure and related buildings as to how they would respond to potential earthquakes (i.e., ability to withstand various response spectra without suffering displacemert

17. Earthquake-induced fission product release could cause doses in unrestricted areas of at least 10 Rem to the thyroid.

18. The Unifom Building Code according to which the reactor structure and the bnilaing above it were built had no provisions for reactors and has since been substantially strengthened: and builds built to UEC standards have failed in relatively moderate earthquakes.

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F NOTES

• Facts 2,3,6, and 8 underwent minor language modifications to accomodate semantic objections raised by UCLA. The previous language is identified below.

• • 2 The UCLA reactor is in the path of at least one active earthquake fault.

• • 3. The UCLA reactor is within two miles of the Newport-Inglewood fault.

• • 6. The current probability of occurrence of a 7 5 magnitude earthquake along the Newport-Inglewood Fault is at least .1% annually, or a one in fifty chance during the proposed twenty-year license period.

• • 8 The Santa Monica Fault Zone is capable of a 7.5 magnitude earthquake.

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