ML20071P315

Requests for Clarification of ASLB 830513 Order Scope of Upcoming Hearing.Ucla Must Be Allowed to Present Testimony on Seismic Questions to Answer Issue of Worst Case Accident. Certificate of Svc Encl

ML20071P315
Person / Time
Site:	05000142
Issue date:	06/02/1983
From:	Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8306070416
Download: ML20071P315 (4)

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UNITED STATES OF AMERICA '83 JUM -6 P1.45 NUCLEAR REGULATORY COMMISSION 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)

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(UCLA Research Reactor) )

)

UNIVERSITY'S REQUEST FOR *LARIFICATI0ft 0F BOARD'S MAY 13,1983 ORDER i

l DONALD L. REIDHAAR l GLENN R. WOODS CHRISTINE HELWICK 590 University Hall 2200 University Avenue Berkeley, California 94720 l Telephone: (415) 642-2822 l

Attorneys for Applicant j

j. THE REGENTS OF THE UNIVERSITY l OF CALIFORNIA

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r-I. INTRODUCTION In its May 13, 1983 Memorandum and Order (Concerning Contention XVII) the Board deferred ruling on the summary disposition motions related to Contention XVII pending the outcome of the upcoming safety hearings. The Board also stated that those hearings will not go into UCLA's position that no substantial damage to the building housing the reactor would result from any credible accident. Because University does intend to introduce evidence on the likelihood of core-crushing damage to the reactor and other seismic-induced effects on reactor performance, University seeks clarification as to the scope of the upcoming hearing.

II. DISCUSSION In its April 20, 1983 letter to the Board University noticed that it intended to introduce testimony of Dr. Craig Smith on seismic matters. This evidence will be relevant to NUREG/CR-2079 (the Battelle Study) and NUREG/CR-2198 (the Los Alamos Study) as well as to certain of the assertions contained in the declarations of CBG's Dr. Kaku, Dr. Plotkin and Mr. Norton. Basically, the testimony of Dr. Smith will support University's assertion that core-crushing is not a credible accident scenario for UCLA's Argonaut reactor.

Most of this testimony will also be relevant to Contention XVII. University does not seek to disturb the Board's ruling d'eferring Contention XVII.

However, in order for University to satisfy its burden at the July hearing

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that the public is not endangered from the worst reactor accident deemed credible, University must have an opportunity to present testimony on the seismic qu'estions.

III. CONCLUSION For the. reasons above, University respectfully requests that' the Board clarify its March 13, 1983 Order to insure that University will not be precluded from offering evidence relating to reactor core-crushing accidents.

Dated: June 2,1983 DONALD L. REIDHAAR GLENN R. WOODS CHRISTINE HELWICK By_ r William H. Cormier Representing UCLA O

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rr UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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) )

CERTIFICATE OF SERVICE I hereby certify that copies of the attached: U:.iversity's Request for Clarification of Board's May 13,1983 Order.

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: June 2,1983 .

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 9203 Administrative Judge San Francisco, CA 94123 ATOMIC SAFETY AND LICENSING BOARD U.S. Nuclear 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 Thompson U.S. Nuclear Regulatory Commission 6300 Wilshire Blvd., #1200 Washington, D.C. 20555 Los Angeles, CA 90048 Counsel for the NRC Staff Ms. Lynn G. Naliboff 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 DY, WILLIAM H. CORMIER UCLA Representative THE REGENTS OF THE UNIVERSITY OF CALIFORNIA

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