ML20082T417
| ML20082T417 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 12/13/1983 |
| From: | Hirsch D COMMITTEE TO BRIDGE THE GAP |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8312160010 | |
| Download: ML20082T417 (17) | |
Text
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I 00CKETED i
USNRC December 13, 1983 1
C T M TO BRIDGE THE CAP 137 Butler Avenue, Suite 203.
'83 EC 15 N0:20 2
Ios Angeles, California 90025 (213) 478-0829
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4 UNITED STANS & AMERICA NUCIEAR REGULATGtY COMMISSION BEFOR THE ATOMIC SAFETY AND LICENSING BOARD I-In the Matter of Docket No. 50-142 oL g
0F CALIFORNIA (Proposed Renewal of 9
Facility License No. R-71)
(UCIA Research Reactor) 10 1
11 12 CBG MMORANDUM AS TO STATUS & COU1ENTION II (SBCURITY) 13 1
14 I.
Introduction 15 16 In its Memorandum and Order of November 23, 1983, the 17 Atomic Safety and Licensing Board directed the parties to file briefs 18 as to the status of Contention II.
That contention alleges that Applicant's 10 security plan, and implementation thereof, are inadequate to meet the 20 requirements for protection against sabotage' and against theft of 21 weapons-grade nuclear material.
i 22 Interrogatories filed April 20, 1981, and other discovery 1
23 requests as to this contention have been held in abeyance' pending resolution 24 of certain matters perceived by the Board to be threshold issues.
- 25 Likewise, the bulk of a summary disposition motion filed by Staff 26 before completion (or mn, for that matter, commencement) of discovery '
27 and which has repeatedly been ruled by the Board untimely.until completion
- 2g of disco.ary, remains deferred. CBG's motion, ande last July, that E312160010 831213 PDR ADOCK 05000142 G-PDR w
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discovery be reopened, hearing dates set, and determination expedited 3
has not yet been acted upon.
(Because of the upcoming Olympics to be held a few hundred feet from the reactor this summer, CBG has repeatedly 4
5 indicated the necessity of determination of major issues in the contention 6
by late winter at the latest. Published reports identify the reactor as i
7 a prime target for sabotage during the Olympics. Because of the time that would be necessary to cool the reactor fuel down and make other g
arrangements for its shipment off-site prior to the Olympics, should g
10 CBG's positi n n the necessity of that precautionary measure be upheld, decision must be reached many aonths before the Olympics.)
yy The Board has made its rulings on the preliminary threshold 12 matters. It has determined that UCLA has finaHy gotten its inventory 13 of weapons-grade nuclear materials a hair below the " formula" quantity:
p 4.9 kilograms, with a 5 0 formula level. And it has ruled that the 15
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16 despite repeated protestations to the contrary by both Applicant and Staff.
I,s, The threshold issues resolved, discovery should be reopened, early hearing date set, and CBG's motion for expedited procedures granted because of the rapidly approaching Olympics and the seriousness of the proliferation and public safety riska associated with potential thef t of weapons material or radiological sabotage of a reactor in a crowded urban area.
23 As to what remains still to be resolved regarding Contention XX, essentially everything remains in contest as to the adequacy of UCLA's measures to protect against theft of Strategic Special Nuclear Materials.
j Only two words in that portion of Contention IX have been resolved:
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, 1 2
"73.60 and" in the citation of applicable theft-protection regulations.
3 CBG, three years ago when the contention was written, alleged that UCIA's 4
88ouritY failed to oo8P y with 10 CFR 73 60 and 73 67 Dat was true at l
5 the time--despite denials by Staff and Applicant, UCIA had far more than 6
a formula quantity at the time, and for a considerable period thereafter.
7 he Board has now ruled that UCIA's belated off-shipments of some of its g
excess Highly Enriched Uranium have finally brought it just below the g
73.60 level and that W applicable regulations are therefore only 73 67 10 As CBG has contended all along that UCIA is in violation of both provisions, and since there is little substantive difference between the the central issue raised W the contention remins to be resolved: will the weapons-grade anterials at UCIA be ensured of adequate protection against theft or diversion? CEG intends to demonstrate that security is so lax at the facility that theft or diversion of weapons-grade uranium would be very easy.
18 19 20 1/ As Counsel for staff said at the June 29, 1982, prehearing conference:
21 "As a matter of fact, I would like to point out that 73.60 is not different froa73.67 except in the matter of searches. Here is no significant difference between 22
_the regulations, but there is that difference.'
23 It should be noted that even in the one area where Staff identifies a 24 difference, the difference is trivial, as both 73.60 and 73.67 g
have search requirements, ard sabotage protection would necessitats oher kinds of searches as well.
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. I 2 e sabotage protection issue is now resolved. Applicant has 2
repeatedly indicated that its security plan is not designed to protect 3
against sabotage, but asserts instead (as does staff) that no such 4
protection is required. As Applicant stated in its August 25, 1983, 5
pleading in support of Staff's Motion for Reconsideration of the Board's 6
rulings in this regard 7
University wishes to note that its security l
g plan, wl}ich is not designed to provide protection against sabotage, has been approved by the Commission's 9
safeguards branch and that the low-power university 10 research reactor licensees have never been required to adopt security plans designed to protect against 13 sabotage.
12 l
Se Board has ruled squarely that Applicant and Staff are both wrong 13 in asserting that UCIA's security plan need not be designed to provide 14 protectica against sabotage, that the regulations do indeed so require.
15 Taus, the facts and the law regarding this portion of the contention 16 have now been resolved. UCIA says its plan is not designed to protect 17 against sabotages the Board says it must.
18 C]r, respectfully suggests that the Board act on CBG's previous 10 motions for expedited procedures to resolve the issues remaining in this 20 i
contention, including setting af a February hearing date.
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22 23 24 25 26 27 28
(
1 2 II.
Background
3 4
A brief review of how we got to this point regarding this i
5 contention and why expedited resolution of the remaining issues is 6
important fonows.
7 8
The Issues 9
There are two admitted contentiona in this proceeding 10 aneging related public health and safety and commond defense and security 11 threats posed by the virtually unprotected presence of weapons-grade 12 nuclear materials at the UCLA reactor facility. These are Contention 13 xx and Contention InI.
14 Contention II alleges that the security required to protect 15 th'** **** rials is woefuny inadequate, that security at shampoo factories 16 or record stores is many times better than that at UCLA, where what is 17 to be protected is material which, if stolen, could to used to'make a 18 nuclear bomb, as won as a device which, if sabotaged, could release 39 radiation resulting in exposures in excess of legal limits out at least 20 75 kilometers ih a highly populated urban area.
21 Contention IIH anages that the threat to public health 22 and safety and common defense and security is unnecessary and violates 23 the Policy of reducing amounts of weapons grade materials to the minimum t
24 necessary. Only when absolutely necessary-which CBG contends is
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g clearly not the case at UCLA--ere such materials to be chosen over non-weapons 26 grade materials, and only then if adeounte security can be provided, which brings us back to Contention II.
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l 1 l 1
he reason why expedital proceedings on these Contentions 1
2 is so necessary--and w~ny the three-year delay has been so potentially I
3 injurious-is precisely the unique nature of the materialh possessed 4
by UCIA. Se material requested in the Application pending before this 5
Board is 93% enriched uranium. Unlike power reactor fuel, this is 6
weapon -grade, i.e., it can be used, if stolen or diverted, directly 7
in the making of a nuclear weapon.
Intheformrequested(aluminum-8 uranium plates), it is a trivial matter to extract the uranium.
)
9 And the principal barrier to acquisition of a nuclear weapon is acquisitic7 10 of the weapons-grade materials the construction of the weapon itself is 11 relatively easy.
And lastly, because of its very high enrichment, 12 very small quantities of the material are needed to make a clandestine 4
13 fission explosive, primarily because the critical, mass goes down as the 14 i
15 1
16 17 2] See, for example, declarations in this proceeding by CBG declarants 18 Dr. Herbert Scoville (former Deputy Director of the Central Intelligence t
Agency, former Assistant Director of the Arms Control and Disarmament Agency, 19 and former Technical Director of the U.S. Armed Forces Special Weapons Project): Dr. Beodore Taylor (former nuclear weapons designer at Ice Alamos, 20 perhaps the leading authority in the country on non-proliferation, member of Kameny Commission, co-designer of TRIGA reactor, author of 4
i 21 Nuclear Beft Risks and Safestuards for the Ford Foundation, subject of McFhee's book Se Curve of Binding Enerry); and Professor David Hafemeister 22 (former State Department non-proliferation official, now Professor of Physics at Cal Poly, on leave at MIT).
i 23 i
J/ Two methods that can be performed by Chen I students are described I
24 in Profsseor James Warf's declaration (Professor Warf was Group Leader of the Analytic and Inorganic Sections of the Manhattan Projects currently 25 a Professor of Chemistry at USC). An even simpler method is described by i
Dr. hylor in the section of 2e Curve of Binding Energy c.ttached to his 26 declaration.
27 Y John Foster, former Director of Iawrence Radiation.Iab and a leading weapons authority, is quoted in the sections of Dr. hylor's book attached 28 to his declaration as writing. "It must be appreciated that the only difficult part of making a fission bomb of some sort is the preparation of a supply of fissionable material of adquate purity the design of the bomb itself is relatively easy..."
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square of the increase in density in an implosion device.
Bus, theft 2
of kilogram quantities or the kind of material at UCIA would be very, very serious in its implications to international order.M i
3 4
Recognising these severe dangers, the Commission has taken 5
two steps. It has required, as a condition of receiving a license to 6
posoess such highly dangerous materials to national security, security 7
sufficient to protect against thef h or diversion. And the Commission, 8
in compliance with the Nuclear Nonproliferation Act of the Congress 9
and the policy of DS, State Department, and other as encies of government, 10 assumed a policy of using its licensing authority to the maximum extent 11 possible to reduce quantity of highly enriched uranium at research reactors.
12 These are the two issues raise by Contentions XX and XIH, and are why 13 it is so important that tney be expeditiously resolved, after the years 14 of delay already having occurred.
15 should 4.9 kilograms of weapons-grade uranium be stolen from 16 the UCIA reactor facility because of inadequate security or failure to 17 reducs-}EU inventories to the maximum extent possible--and should that 18 theft or diversion occur while the Board has before it unresolved issues 19 as to the adequacy of that security or the propriety of possession of that 20 EU--an event of almost inestimable potential harm to public safety 21 and international order as well as national security could have occurrei.
22 he matter demands expeditious resolution. Bere have been too many delays al: ready 23 g See nylor book section, attached to his declaration. hylor indicates fast critical mass for }BU with a 3" beryllium reflector at normal density 24 as 11 kg.
Bus, an implosion device =hiah produces a factor of 2 compression will reduce critical mass requirements by a factor of 4, to less than 3 kgs 2a, a factor of 3 increase in density in an implosion device will reduce critical mass by a factor of 9, to about 1 kg. Dr. Foster, in the hylor attachment, 26 is quotal as writing that increases in density "several times" normal are readily achievable with conventional high explosives.
M See hylor,. Hafemoister, and Scoville declarations.
. The His 2
he ]roblem of theft of nuclear satorial was not an issue 3
for the original Argonaut, because it ran on low enriched fuel from which 4
weapons could not be directly produced. Se University of Florida 5
Argonaut, built before UCLA's, purposely initially utilized low enriched 6
fuel also, indicating in its hasards analysis it did so in order not to 7
have to arrange substantial security precautions.
UCIA's initial license app 7 ication, in 1960, was for 4 kg 9
of highly enriched uranium,.5 kg of which it returned to AEC shortly j
after going on line. For its first decade, the UCM reactor facility possessed only 3 5 kg.
In 1970 UCLA requested a license amendment to increase possession authorisation 250A to 10 kg.
It said it did 13 so as a temporary measure, because it wished to reload the reactor with I4 fresh fuel and would, for a short time, have on site both new and the old 15 core, before off-shipping the old. However, full reloading never occurred, 16 and the excess rossined on site fe the next decade, almost continually II in violation of Commission security requirements.
18 Every couple of years during the 1970's, the Commission would 19 find that UCu had on site more uranium than its security plan was 20 qualified to possess. UCu would say it would ship off some of the fuel 21 that was excess, to come tack into compliance. It would take a couple of 22 years to accomplish this, and thereafter the Commission would discover 23 that UCIA still had too much on site, in violation at the security requirements.
24 It was with this history as backdrop that Contention XX came before this 25 Board.
26 2/ This is suasarised from CBG's past. pleadings on Contention IX and its 27 still-pending motion for sumanry disposition of Contention III (see particu-larly p.14-18 of the 3atter for citations).
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1 Se Procedural History UCIA filed its renewal application in February 1980 CBG petitioned for leave to intervene when the notice of such opportunity was finally printed in the Federal Register, and in August 1980 submitted its supplemental contentions, including those that form the basis for Contention II and IIII. At a prehearing conference in September 1980,
,t Staff requested the Board defer ruling on at least Contention XX until the Staff had an opportunity to brief CBG on the nature of the NRC 9
safeguards regulations. Rose briefings never occurred (although prior 10 to the September 1980 conference the Staff's James Miller, then in charge 11 of the Staff's security review for UCLA, told CBG'that it would have 12 discovery on its security concerns "over my dead body.").
Calls weren't 13 returned, and so Contention II went to the Board five months later 14 for admission, which was granted. At that prehearing conference, 15 Staff proposed, and all parties agreed to, a stipulation as to schedule, 16 with summary disposition not to occur until close of discovery. Se Board 17 adopted the stipulation and ordered that schedule in its March 20, 1981 18 Order.
19 CBG, pursuant to the schedule stipulated to and ordered by 20 the Board, submitted interrogatories on April 20 Rose included 21 interrogatories as to Contention II.
However, on April 13, Staff submitted 22 a notion for summary disposition on Contention II-before discovery had i
23 I
even commenced, let alone been completed. CBG moved for the action to 24 be struck as untimely, granted by the Board in its Order of April 30.
25 he Board determined that the action is premature and need not be responded 26 to until the close of discovery, asrstipulated to, which was then scheduled 27 for July 30, 1981. Staff moved the Board to reconsider the Board affirmed 28 its previots ruling in an Order of June 9, saying, "It would be patently unfair to hold CBG to the ' terms' of a stipulation that are not those l
. 1 to which it agreed."
2 In the meantime, UCIA requested a protective order as to 3
the interrogatories submitted on Contention XX, which was granted by 4
th* 3**** **"*****il' ""*11 * ""i**DI* P'*****1'* **d** *" "*"~di'*1 '"**
l whereuPon the interrogatories and other discovery requests l
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were to be 18 mediately reePonded to.
(Certain other interrogatories 7
were subsequently objected to on security grotada, with a temporary deferral of response granted until the non-disclosure agreements are in g
place. )
g Cac has proped nonesclosure agremnts and a fora d 10 protective order, and moved that the protective order and non-disclosure g
commitments apply to all parties. Sese matters have been fully briefed, and remain pending. As long as they repain pending, discovery cannot commence, and until discovery is complete, summary disposition cannot proceed.
So Board, in a June 1982 prehearing conference, attempted to see if certain threshold issues could not be resolved first, without access to sensitive security information, issues which, if resolved, might affect l,e the scope of the security information necessary to be disclosed. Rose issues involved (1) the amount of SSNM (Strategic Special Nuclear Material) on site, (2) its irradiation level (as to whether it could properly be exempted under the 100 Resq/ hour / bundle exemption), and (3) whether Staff and UCIA were correct in their assertions that sabotage protection was not required under the regulations.
UCIA's application was for 4700 g fresh, and 4700 g irradiated U-233 24 plus a 2 curie plutonium-239 source. CBG conteaded that UCIA had more than 25 a formula quantity (5000 g), which was denied by UCIA and Staff.
26 However, at the very time they were making those initial assertions to the 27 licensing bosrd (early 1981), the NRC Staff had just written UCIA that it 28 had, based on an inspection found UCIA to possess more than a formula quantity.
Bis letter as not provided the Board and parties until a year later.
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1 Attached to Staff's motion were two affidavits, one by 2
Donald Carlson and the other by James Miner, which raised issues that 3
the Board asked CBG to address in trying to resolve these threshold 4
matters.
Mr. Miner asserted, under oath, that he had personally verified 5
that UCIA's fuel met, the 100 Rom exemption. Mr. Carlson asserted that 0
research reactors like UCLA's were only subject to 10 CFR 73.67 and.37 (specifically omitting 73.40) and there are "no explicit NRC regulations O
for the protection of non-power reactors against radiological sabotage..."
O Both sworn statements were materiany false, and CBG obtained documents 10 under the Freedom of Information Act and supplied to the Board in its II responses to these affidavits that demonstrated that both men knew their 12 assertions were incorrectk UCIA had submitted to the NRC several documents 13 indicating they could not reach 100 res/ hour protection levels, ani Mr.
14 Miller himself had authored a memorandum that said the same thing.
15 Mr. Carlson had repeatedly stated, at a conference of non-power reactor 16 operators, a tanscript of which was obtained under FOIA, that such reactors 17 must comply with 73 40 protection requirements against sabotage.
18 UCIA's new assertion that it could meet 100 Rom exemption 19 levels was ksed on an unsupported assertion by Mr. Ostrander, referring, 20 in a fashion very similar to the current episode over his supposed neutron 21 transport calculations, to calculations that were not initiany providei.
22 CBG fought for access to those calculations, which, like the current 23 neutron ones, were performed on Mr. Ostrander's programsable hand-calculator, 24 and demonstrated that, like the finany-produced neutron calculations, 25 there were based on fundamental assumption mrars.
(Mr. Ostrander had 26 calculateddoseforthefullcore,ratherthaneachreadilyseparablebundle.)
27 When the errors were corrected, the result was that the fuel fell below 28 the 100 Rom exemption after just eight hours of shutdown.
(See declaration of Dr. Roger Xohn). 'Ihus, far the bulk of the period in question, E / To CBG's knowledge, no action has been taken rosarding these false statemaats.
_m
. UCLA had in excess of 73 60 SSNM limits with admittedly no 73 60 protection.
2 In the Board's Order of July 26, 1982 CBG was directed-3 significantly, only after discovery on these points-to address the 4
issue of how audt SSNM was on site and if the 100 Rom exemption was 5
being complied with, in addition to the sabotage matter.
Eleven days 6
later, UCIA infcrmed the Board that it had shipped off what it asserted 7
was sufficient excess fuel to bring the inventory finally below 8
5 0 kg (to 4 9!), so that W issue of whether it had failed to comply 9
with the 100 Rom exemption, it asserted, was now moot. Bere followed 10 a year of trying to figure out if UCIA really was below 5 kg, because of numerous and frustrating discrepancies in the available records, I2 as well as the issue of whether to count the Pu-Bo sources, which the 13 Board initially ruled had to be counted.
(Ittooksonomoremonths, I4 and more prodding by CBG, before UCIA finally amended its application 15 request from 9.4 kg highly enrichd uranium to "less than 5 kg," so we IO are no longer even litigating the application initially filed.)
II So what is the message of all this history? he theme is 18 clearly that of delay, of material falsehoods and omissions, of four 10 years of security violations while the central issues in contest regarding i
20 the security contention have sat idle. Se Board was told initially there was 21 less than 5 kg on site, which was falso that the fuel in h core never 22 fell below the 100 Rom per bundle exemption, which was falseg and that 23 no sabotage protection was required, which was false. A stipulation and 24 Board Order that summary disposition motions not be filed until completion 25 of discovery was violated. And during much of.-these delays, UCIA was, 26 as asserted by the contention, in violation of the security requirements 27 mandated for h excessive amount of bomb-grade' uranium by possessed.
28 8[ Counsel for Applicant at the February 23, 1983, prehearing conference (tr 961) said, "the University does not comply with 73.60 complied with 73 60, does not propose to comp y with 73.66.has never l
13-Objec11ons to Procedure as to Final Board Determination of SNM 2
Inventory at UCLA 3
4 For the record, CBG wishes to note its objections to the 5
procedure by whidt the issue of SNM inventory was finally ruled upon.
6 CBG notes that the procedure must fonow the rules regarding sn==ary 7
disposition, as this was all consideration of a certain portion of 8
Staff's motion for summary disposition that the Board had ruled was 9
ripe for determination because discovery had been completed on those 10
- natters, 11 In response to Staff assertions about the amount of material 12 on site, CBG respond e with evidence and argument that indicated the 13 matter was in dispute, with contradictory records and other evidence.
14 Sat should have entailed a determination that ei==avy disposition could 15 not be grantoi and the issue resolvd by evidentiary hearing, with sworn 16 witnesses available for cross-examination. Instead the Board providai 17 addditional response opportunities to the moving party and its supporter 18 (interestingly, as in so many other aspects of this case, it is the Staff 19 carrying the weight of advocacy for the Applicant). After CBG demonstrated 20 that there remainsi inconsistencies in the records of serious import, 21 with which the Board agreed, the Board still permitted additional response
'22 from the other parties.
23 I" thi" **8"*d'
- 1""1 d****"i"*ti'" '# *h' 1**"* DT th* 3*"'d-24
- as based UPon a response by UCLA to CBG's last pleading in the matter.
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Id (generally prohibited by 10 CPR 2.$9), and it was on the basis of 26 asserti na made by Applicant's counsel in that pleading, to which CBG 27
- 88 n t Permitted response, that the Board made its determination.
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. 1 In particular, the Board's determination rests on unsworn 2
factual assertions sade by Applicant's counsel and unsworn " corrected" 3
(by hand) documentary assertions. 1hroughout the pleading counsel asserts 4
facts, for which there is no evidentiary basis (e.g., that the NRC inspectors 5
tasai hir SNM inventory figures on Exhibit G, that Exhibit G errs in 6
leaving out 19 g of scrap and two fuel bundles in the core).
7 Suasary disposition must rest on the same evidentiary standards as hearings:
8 unsworn assertions are insufficient. Cleveland Elec. Illuminating Co.,
9 (Perry Nuclear Power Plant, Units 1 and 2) AIAB 443, 6 NRC 741 (1977).
10 No affidavits were provided, just long assertions attempting to put forward 11 facts not in evidonee and for whom no qualified sponsor had submittai an 12 affidavit. CBG was thus denied both the opportunity to put forward 13 countering inforsation and the opportunity to cross-examine on the contradictozy 14 information.
15 CBG notes h t the 1978 and 1979 inspection reports, and 16 UCIA's own 1989 letter to h NRC, all continue to indicate higher 17 SNM levolm than UCLA asserts. UCLA's explanation that all three are in 18 error is interesting, but surely not dispositive without cross-examination i
10 for example, of h authors of the reports.
20 CBG also notes *that the fact that the most recent NRC " audit" 21 came up with the same figures as UCIA puts forward with its Exhibit G 22 is not dispositive. The Staff did not, as requested ty the Board, do a 23 nhysical inventory. It merely checked UCLA's records-i.e., Exhibit G.
24 1he fact that when Staff reviews Exhibit G (and the documents from which it 25 cane) and when UCIA reviews the same saterial the same result obtains tells 26 us nothing as to why when the NRC on two previous inspections, and UCIA 27 in its letter to NRC, came up with higher results.
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. 1 cBG is also concerned by the Board's reliance on a proposed 2
regulation-not yet in effect and subject to modification prior to 3
acceptance or rejection-for resolving what the current regulations 4
require as to PuBe smeces.
(73 60 contains the current formula definition 5
of U-235 + 2 5 x Pu-239, removed from the proposed regulations.)
6 7
IH. VHERE DO MATMRS STAND?
8 The Board has before it proposals for non-disclosure agreements 9
to apply to all parties. cBG has also put forward actions to expedite 10 the, proceedings on these contentions (contention xx and xIII are closely 11 linked, including the experts who will be involved). The Board has j
12 deferred discovery pending resolution of threshold issues now resolved:
13 discovery should commence. Summary disposition has been deferred pending 14 completion of discovery it should be scheduled for that completion time.
15 A February hearing date should be set.
(If profiled testimony is to be 4
l 16 utilismi in the securit f hearing--and perhaps it would be best for secwity 17 reasons for it to be oral g m-that written testimony can perhaps 18 constitute response to summary disposition actions. A hearing uan always 19 be canceled or reduced in scope, but it takes considerable time to schedule 20 oneanew). cBG's sunnan disposition motion on contention XIII, and its 21 action to expedite partial sumanry disposition on the non-criticality aspects 22 thereof, which are not disputed, should be expedited.
23 cBG, at a previous prehearing conference, suggested that f
i 24 the resolution of these security contentions--which are among the post 25 important issues in this case--could be readily resolved by a hearing l
26 scheduled soon in which all parties and the Board tour the facility, 27 review the security plan and security inspection reports, and the experts I
28 in an g camera setting expeditiously present opinions as to whether the security is adequate. It is not a terribly complicated procedure,
......... - ~. -.. -.
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. 1 and should be capable of being accomplished quickly.
Die issues which 2
are at stake are, however, extremely important, and the public interest is best served by it being expedited. Very serious risks to national 4
sectrd'.y and public safety would result if CBG is right about the inadequate 5
security and something untoward occurs before the matter is resolved.
6 7
f Re.spectfully su
- tted, V'
Daniel Hirsch 10 dated at Ben Lomond, CA II this 13th day of December,1983 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
1 UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the htter of i
Docket No. 50-142 THE REGENTS OF THE UNIVEISITY
& CALIFORNIA (Proposed Renewal of Facility License)
(UCLAResearchReactor)
DECIARATION OF SERVICE I hereby declar t copi of the attached: CN StAoradvA M
~4o S
c
& K%~
'x.X ( M& M it in the above-captioned proceeding have been served on the following by 1
deposit in the United States mail. fig /Jec_eu de-,t class, postage prepaid, addressed as indicated, on this dates
/3 "
/fdA2.
John H. Frye, III, Chairman Christine Helwick Atomic Safety & Licensing Board Glenn R. Voods U.S. Nuclear Regulatary Commission Office of General Counsel 390 University Hall Dr. Emmeth A. Imebke 2200 University-Aver.tde i
Adminiatrative Judge Berkeley, CA 94720 Atomic Safety & Licensing Board i
U.S. Nuclear Regulatory Commission Mr. John Bay Vashington, D.C. 20555 3755 Divisadero #203 San Francisco, CA 94123 Glenn O. Bright A42inistrative Judge g y,ygg,ff Atomic Safety and Licensing Board Deputy City Attorney U.S. Nuclear Regulatory Conaission City Hall h einst e, D.C. 20555 1685 Main Street Chief,-Docketing and Service Section Office af the Secretary
-Dorothy 'Ihompson U.S. Nuclear Regulatory Commission Nuclear Iaw Center Washington, D.C. 20555 6300 Vilshire Elvd., #1200 Ias Angeles, California 90048 Counsel for NRC Staff U.S. Nr. clear Regulatory Commission Washington, D.C. 20555 Ms. Carole Kagan, Esq.
Atomic _ Safety and Licensing Board Panel attentions Ms. Colleen Woodhead U.S. Nuclear Regulatory Commission Villiam H. Corater Washington,' D.C. 20555
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Office of Administzative Vice Chancellor University of California 405 Hilgard Avenue
[
Los Angeles, klifornia 90024 Daniel Hirsch President COMMITTEE TO BRIDGE THE GAP I
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