ML20069F731

Page 6 & Page of Corrections to UCLA 820903 Motion for Summary Disposition

ML20069F731
Person / Time
Site:	05000142
Issue date:	09/20/1982
From:	CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20069F717	List: ML20069F714 ML20069F731
References
NUDOCS 8209280213
Download: ML20069F731 (2)

Text

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,CBG's argument is fatally flawed. CBG',s basic assumption, that e credible accident could result in significant fission product releases, is incorrect and controverted by the considerable weight of technically competent evidence of record in this proceeding.

University will demonstrate below by affidavit and discussion that because of the inherent,'solf-limiting characteristics of UCLA's 100 kw Argonaut research reactor, the UCLA reactor poses no credible threat to public health and safety. The conclusions as to the safety of the reactor rest on general engineering principles and on several generic accident analyses of Argonaut reactors published by the NRC. Additional support for these basic conclusions can be found in the history of safe operations at the UCLA facility and other Argonaut reactor facilities All of CBG's allegations on safety issues must be examined in light of that evidence, which~is substantial, reliable and uncontroverted.

CBG has well disguised its case against the reactor in an elaborate statement of contentions. However, examined properly, CBG's entire case is dependent on a single, critical assumption: that a credible accident could recult in significant fission product releases at the UCLA facility. CBG has not -

understood or simply ignored the basic engineering principles

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CORRECTIONS TO UNIVERSITY'S MOTION FOR

SUMMARY

DISPOSITION Corrections to the Motion On page 78, a clause has been omitted from the first line. As corrected, this line should read: "found that the University had not complied with proper calibration procedures and that there were inaccuracies in certain calibrations that University performed. . . ."

On page 92, the reference on the 3rd line should be to Appendix "C".

Corrections to the Affidavit of Ostrander -

On page 2, the first subheading should read: " Basic Premises of '

Accident Analyses."

On page 6, the symbol for " beta", "p", should be inserted at the end of the 16th line. ,

On page 12, 27th line should read: " fast flux in the UCLA reactor is approximately 2 x 1010 , , ,-

On page 13, 4th line from the bottom, delete ". . . and Sec. 21.1(c)."

On page 17, 3rd line from bottom, the reference should be to "subpart 2.c."

Corrections to the Affidavit of Wegst On page_2, 5th line from the bottom, the symbol for "less than", "< ",

should be inserted before "100%".

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t UCLA September 20, 1982 1

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