ML20005C050

Response to Applicant 810922 Followup Set of Interrogatories.Documentation in Support of Allegations of Inadequate Controls Discussed.Declaration of Svc Encl. Related Correspondence

ML20005C050
Person / Time
Site:	05000142
Issue date:	11/09/1981
From:	Hirsch D COMMITTEE TO BRIDGE THE GAP
To:	CALIFORNIA, UNIV. OF, LOS ANGELES, CA
References
NUDOCS 8111180327
Download: ML20005C050 (18)

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00CKETED USNRC

'81 N0Y 12 PS:52 UNITED STATES CF AERICA

~ CF SECRETARY

1. NUCLEAR REGUIATCRY CCITISSICN C 'iG a SERVICE

. ;:A NCH EFCRE THE ATO:GC SAFETY AND LICENSING 3 CARD In the Fatter of Docket No. 50-142 TEE RECENTS OF THE UNIVERSITY I

(Proposed Renewal of Facility License Number R-71)

(UCIA Research Reactor) e e A n- -

$ k. J. e 6 NOV171981> ^_94 ANS'4ERS CF TEE CCDITTEE TO 3 RIDGE TEE GAP Q u.s.pxuu uca^ma 7 TO APPLICANT'S FCILCV-UP SET OF INTERRCCATCRIE3 \g comt55C ,-

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Dated: November 9,1981 CCDITTES TO 3 RIDGE TEE GAP 1637 Butler Avenue, Suite 203 Los Angeles, California 90025 (213) 478-0829 Intervenor i

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1 INTRCOUCTION Cn September 22, 1981, Applicant, the REGENTS CF THE UNIVERSITY CF CALIFORNIA, submitted to Intervenor, THE CCITITTEE TO 3 RIDGE TEE i

GAP, follow-up interrogatories as to matters in the above-captioned proceeding. Said interrogatori'es are answered in the responses that follow, subject to certain agreements between the parties made at a discovery conference on October 16, held pursuant to Board Crder.

Those agreements modified the language of Interrogatory 9 ty removing the phrase "and such personnel had knowledge . . . operation?"

Interrogatory 14 was modified by replacing the phrase "all calculations" with " principal calculations." Certain language in Applicant's introduction to the interrogatories regarding possible affiliations of individuals was also removed. By agreement between the parties, responses were to be filed November 9.

Discovery is proceeding on all the matters touched on in the Applicant's interrogatories. The fo n cuing answers are provided without prejudice to Intervenor's ability to introduce subsequently discovered material ata later date at hearing or related proceeding. As Interrogatories 1-9 are requests for staplementation of previo'us answers, only supplementary material is provided; previotsly provided information is not repeated.

Intervenor. objects to Interrogatory 26 and declines to attempt to answer it. The parties were unable to reach agreement about this particular Interrogatory despite several attempts during discovery conferences, although agreement may yet te reached. Intervenor objects to the interrogatory on the grounds that it is vastly overbroad & unduly burdensome. The question essentially asks Intervenor to identify every document, letter, note, or other written item in Intervenor's pcssession which is "in any manner whatsoever related to any of the issues in this

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proceedirs." The question is so broad that an answer is inpossible, and Intervenor declines to attempt an answer to such a question. 3y sgreement between the parties, a motion for protective order is not being filed at this time. Additional discovery conferences with Applicant are scheduled in an effort to avoid having to bring the natter to the j 3oard for action.

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Eated: Novenber 9, 1981 // 9 g /

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Daniel 0. Hirsch President COEMITTEE TO 3 RIDGE T'2 r CAP Intervenor l

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, 1. Yes.

(a) Since answering this question in the previous set of interrogatories, an IGC inspection has been conlueted, based on revelations by UCIA in response to Intervenor's interrogatories to Applicant. Those responses indicated that Applicant had indeed permitted unlicensed operators to manipulate the IIL reactor's controls, a principal asserticn made by Intervenor in support of its c mtention of inadequate nanagerial and administrative controls. On July 28, 1981, A.D.' Johnson, Director of Enforcement and Investigations for IGC Region V, wrote to Valter Wegst at UCLA,-stating: "We have evaluated the circumstances

ard management cmtrols that existed in the past wherein hi6h school ani other students had been permitted to manipulate the switch controlling movement of a reactor control blade. We have concluded that your 4

actions may not be in strict complisnce with NRC rules and regulations." ,

Since the time of that 130 inspection, Applicant has admitted in pleadings

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i' that there have been nunerous times when unlicensed operators manipulated the reactor's controls. Intervenor has observed during document inspection at UCIA numerous such instances in the operating logs, including

instances when junior high school children were permitted to operate the reactor controls and when young students were permitted to scram, the reactor. All of this is additional support for Intervenor's contention thatinadequate controls and supervision have existed at

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1 l In addition, the finding by the IGC that the practice has continued I for more than a decade since the AEC on two previous occasions explicitly denied UCLA permission for operation by unlicensed operators provides additional support for Intervenor's concern about poor administrative

! procedures and controls. AEC directive'was clear to the licensee in i the past; yet despite clear direction against the practice existing in the docket for this reactor (direction that wr.s appealed by UCIA and given again in very clear language by AEC), the practice continued for a decade. The ability of this facility to obey Commission regulations, and to use good internal controls to maintain proper procedures, is' seriously called into question by NEL management's disregard for or ignorance of. previous AEC explicit direction to this facility.

l Cther facts which support C3G's allegation of inadequate controls l

were fourd during document review at UCIA. In particular, there were i numerous instances of documents which required signature by 1;EL '

administrative, canagerial, or supervisorial entities which were not j

so signed and approved (particularly ECCs and ESAs). Intervenor only L received copies of certain of these documents within the last few days, l so tabulation of ani itemization of each such poor practice has not begun.

i In addition, there were numerous indications of log-keeping errors ard l record-keeping deficiencies. The 1980 Audit Report--which Intervenor

! inspected and requested copied but which has not been provided--

i indicated numerous concerns about record-keeping. The recommendations

! therein for better compilation of procedures manual was contradicted

[ in the RUC minutes which discussed those findings--indicating tha.t in fact there was no procedures ranual as such and one should be created.

When we reviewed the procedures nanual provided to-us, an out-dated-emergency procedure with incorrect ide tification of irdividuals and phone numbers to contact was included.

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4 (b) The documents referred to above ard identified below were reviewed by Daniel Hirsch, Steven Aftergood Werdy Schnelker, Sheldon plotkin, and David rupont primarily, and it is from their personal knowled6e of those documents that these facts have been detailed. Ito compilation of the caterial from those documents has yet been produced by Intervenor.

(c) The documents which support the alle6ation are the RUC ani ESC minutes, the operating logs, the June lo,1981 IinC inspection of UCIA, the ECO and ESA forns.

2. Yes (a) The answer continues to be lased on UCLA's own Fazards Analysis, which as indicated in previous sets of answers irdicates melting could begin in the 2.35 range (and because of the error in use of incorrect void coefficient, actumHy 2.15) with substantial uncertainties requiring a far lower excess reactivity level inorder to meet prudent safety standards. !!othing in the Battelle analysis chare es that view of Intervenor's; in fact, the opposite, there is reinforce:ent of Intervenor's position that excess reactivity net.ds to be substantially lowered. See answers to questions 14-17.

Intervenor has rade no firm conclusion as to the nest credible accident scenario. Applicant's Hazards Analysis indicates it to be insertion of a large worth (negative) sample into the reactor and failure of operator to reinsert control blades prior to withdrawing sample. That scenario seems quite credible to intervenor, although the other scenarios identified in response to previous set #24-continue to appear quite credible.

(b) The inferration comes from docunents, primarily Applicant's own Hazards Analyc'.s. Dr. Eichio Kaku has provided some useful additional infor:ation regarding pcuer excursions at other research 4 reactors, primarily SL-1.

(c) UCI.A Eazards Analysis, the documents identified in questions 14-17, the GE report on the SL-1 accident, and Thorpson and Zeckerley.

3. Yes Intervenor means by the phrase " inadequate monitoring" the same as it indicated in answering this question in the previous set.

(a) In addition to the information previously provided, Intervenor now believes the annual area surveys to be extremely poorly conducted.

Very few areas are monitcred (for exanple, right above the reactor the equipnent room is monitored, uhich is supposed to te uneccuuled, but thesnackbarontheothersideofthewallisn'tmonitored). ??o in-place long-tern neutron neasurements are made at key locations; the hard-held neutron readings are very hi 6h, ard yet there is no evidence of follow-up to check then out. :?o signature of supervisorial staff reviewing the results of area surveys is in evidence, nor recedial action directed or outlined. The film badge threshholds are so elevated that they could read zero ard people still be gettinc; very significant doses. There seems, continued disa6reenent over what those threshholds are, even after to be l

5 policy has been set. A review of the specs on the hand-held GE counter ard the hard-held neutron counter reveals that they simply aren't adequate for detecting the levels of radiation of concern. RUC minutes from late 1979 or early 1980 indicate that the secondary effluent nonitor can't see several times ITC. Einutes also irdicate an attempt to salvage monitors from an old reactor at Atomics International, devices which turned out to be even worse than the outmoded devices at ISL. The annual shield survey is with the neutron 6enerator off ard the ports closed ard all the shielding in place--certainly not the way to determine conservatively doses in unrestricted areas.

The weekly surveys are always with the reactor off--high exposures could continue for a year before detection, if then.

(b) The above facts are fourd in the documents identified telow are were identified in the review of said documents by the irdividuals idnetified in 1(b) above.

(c) annual radiation area surveys; Horner to Vegst memo regardirs film badge minimums; weekly radiation surveys, specs for the NEL radiation monitors.

4. Yes (a) - (c) The answers to 3 above are included herein by mference, because they do not refer to past monitoring procedures alone but current practice as well.

5. Yes.

(a) A review of the scram reports iniicates constant or frequent ralfunction of the following devices, irdicating inadequate maintenance:

log N input, North area monitor, RFPS, safety amplifier, period circuit input tubes, ccatrol and power wiring of sump pump, long N and period monitor, lattery power supply, exhaust stack dagers, dump valve, CIC power supplies, reactor stack exhaust fan, control rod logic, Keithley 421 IT Amp, secordary water supply line. In addition, a review of UEL maintenance records irdicates extremely little maintenance performed--

entire maintenance log for 1974-1980 is only 70 pages.

(b)see1(b) .

(c) NEL scram reports and maintenance logs

6. Yes REM-meter, Argon-41 monitor, GM hard-held counter, TLDs and film lad6es (in terms of proper controls).

7. Intervenor at this time has no information regarding Applicant's compliance or non-compliance during the past year with its technical specifications as to raintenance and calibration. No such contention at this time.

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E. Yes (a) secordary effluent monitor, secondary effluent recorder, control l

blade gear box and torsion rod, control blade notors, control hhde logic, control blades themselves, startup counter and logic system, Heathkit Model 13-1100 Frequency Counter, linear Freamp, linear Arp, Proportional Amplifier, micro ammeter, Al? rod drive mechanism, flexo-rabbit pneucatic transfer system, ratemeter in effluent monitor, scintillation probes, linear reccrder, los reccrder, relay alarn unit, solu tridge controller, level switches, canometer, vibratirg capacitor electrometer, safety amplifier, period and log N amplifier, exFaust stack da=per ard damper controls, Argon 41 recorder, hand and foot counters, activation analysis equipment, hot cell, temperature recorder, the fuel itself, rupture diaphragm, control room intercom, control room instrumentation irdicating open doors in facility, warning lights, dupn valve sensing switch, CIC's ard UICs, low count rats meter innibit ard low count rate meter, Argon 41 monitor, thermocouples, conductivity meter, dump valve The above list is preliminary, prior to actual inspection cf the facility.

The hazards to the public from unreliability, difficulty to repair or replace, or inability to obtain spare parts are both individual ard cumulative. Individually, failure of the secordary effluent monitor or recorder can lea:1 to release of highly contr.ninated secordary effluent into the envirennent; failure of control blade components er use when not in perfect conditien because of difficulty in replacing or repairir4 can lead to loss of a crucial safety cevice for regulating reactivity and could, for exacple by droppingout of core or being thrown out,

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lead to power excursion; the various rateteters ard flowneters ard safety a=plifier and period meters all could, through unreliability, severely reduce the engineered safety features of the facility; pneumatic transfer system failure can lead to public radiation exposures because of the highly radioactive =aterial whibh travels through it; inadequate hand ard foot counters could permit individuals to becoce contaminated ard 3

not know it, thus centaminating others; failure of exhaust stack da. per and controls could 3e ad to public releases of radioactivity because of failure of reactor " confinement,"; Argon 41 recorder failure or monitor failure could lead to excessive enissions without control room being alerted ard taking corrective action; inadequate hot cell could lead to significant radiation exposures; improper temperature recorder ard thernoccuples cculd give inaccurate temperature irdications leading to overheating of fuel or insertion of excess reactivity through

addition of very cold water; failure of warning lights, open door indicators,

! or control room intercom could rean failure to warn people so that corrective and protective neasures could be taken in case of urgent situation (security vulnerability, radiation release, bomb threat); failure of dump valve and dump valve sensing switch could disable a key tackup shutdown mechanis=;

Argon 41 nonitor problems could lead to excessive emissions; thermoccuple failure or inadequacy could lead to localized heating and bowing;

inadequa+e conductivity meter could mean significant corrosion occur without detection and thus fissien product release from corroded fuel or significant activation producta created in effluent.

(b)-(d) the facts are identified in (a) above, they are known by the individuals who reviered EL's records identified in 1(b) above, and

were revealed in EEL naintenance records, iCP.AM reports, Al7 maintenance

tanual, and instrument specification booklets.

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9. Yes (a) Af ter reviewing the records referred to in 8(d) above, it is Intervenor's clear impression that the.NEL staff has for rany years continued to operate its reactor despite knowledge of the unreliability and aged condition of crucial equipment. The reactor would scran, the cause would be undetermined, and the reactor would be brought lack on line nonetheless. The reactor would scram, the cause would be the long N ard peried meter, and yet the staff would wait years to replace it, despite failure after failure. The cause would be the safety amplifier, and it would never get replaced. Line transients would occur repeatedly; nothing would be done. Control blades would 6et stuck during long runs; the staff would try to avoid long runs, rather than resolve the problem.

The Argon monitor was questionable and questioned since the early 1960s, yet still today there is question as to what is the precise concentration of Argon being emitted. The REM ceter produces strange readings; yet it continues to be used and no one checks to see if those raadings are accurate (at least, there is no record of a prompt check in the raterial provided Intervenor). The hard-and-foot counters are ancient; yet visitors and workers alike are checked out of radiation rooms with a cursory stop at the counter. The " hot cell" is referred to in NEL's own documents as the " poor ran's hot cell,"

(b) See 1(b) above.

(c) NEL raintenance records, SCRAM reports, ECOs, instrument specification booklets, operating log 3. *

10. The following portions of the Application are not original and should be: p. 53 all of Apperdix I, Attachment 33 p. II/3-1 to 7-1; III/1-1 to 5-16 (some phrases ard sentences have been added and are original; 905 is not); Appendix III, Attachments A and 3.

As Intervenor stated in response to the previous set Interrogatory 2, "An elementary requirement for an adequate application for facility

, license is that it be written about the facility for which the license is being applied." In order to =eet the concon stardards for granting of the license requested (10 CFR 50;40) that adequate assurances exist in the application that grant of license will not endanger health and safety of the public, an application clearly must te about the facility for which the license is intended. 10 CFR 2.743(c) indicates that the Application cannot be admitted into evidence if it is not reliable, relevant and material. An application for a different facility than the one in question, written by unknown individuals not present for cross-exacination, without independent review by Applicant of the relevance and reliability of the non-original caterial, cannot meet the 2.743(C) s+m dard.

i 10 CFR 50.30 requires that applications te filed urder oath or affirmation by these responsi'cle for the application; non-criginal portions of applications cannot be sworn to or affirmed absent some clear effort to determine the accuracy and validity of those cections, effort not shown in the application currently before the ASL3.

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11. '*The core was observed for signs of structural damage or for pctentially damaging displacements. None were observed. About 6 months after the vibration experiment routine tests indicated that one of the control blade insertion times had increased. A few months later safety blade No. 1 stuck in the 'out' position during a routine prestart checkout of the reactor control system.

'"ihen the reactor was dismantled, we discovered that lead shielding bricks under the control blade drive shaft had been . displaced upward, causing the shaft to bird."

One of the purposes of the vibration tests was to determine whether the!'

UCIA reactor was vulnerable to structural damage or potentially damagin6 displacemsnts. One of the results of the vibration tests was immobilization of a key safety device--a control blade-caused by core shifting leading to damage to the control blade drive shaft and the lead shielding. Since these tests were conducted at vibrations representing a small fraction of possible accelerations due to a real earthquake at this location, the reactor failed the test--it was demonstrated to be potentially vulnerable-to structural damage or potentially damaging displacements in an actual major earthquake.

Note further that the Smith article also irdicated that " core vitrations could cause transients in the reactor power" ard suggests some extra safety mechanisms that could reduce the magnitude of the transients, mechanisms which Intervenor has not seen evidence of having been ins talled at the UCIA reactor.

12. Intervenor subscribes to the no-threshhold theory regarcling radiation exposure, a premise assumed by virtually all experts in the field ard irdeed all regulatory ard official advdQ,roy organizations. There is no " safe" level of radiation, increased dose produces increased biological insult.

Thus all radiation doses produce some level of biological harm (i.e.

increased risk of induction of cancer, leukemia, or genetic damage);

the extent of harm being a function of the extent ani type of radiation.

See the NAS ZEIR reports, the UNSCEAR report, the Tri-State Leukemia study, the Hanford radiaticn workers study, the S. Utah leukenia-in-chilren studgo.

Thus, all radiation doses are clearly harmful. Harm is a function of se; no threshhold can ':e assumed

13. Yes. Violations 5,6,10,11,12,13 all contributed to long-term emissions of excessive radiation and radioactivity. The actual doses received a- e difficult to assess accurately because NEL has to date made no scientifically controlled, accurate measurements of those doses.

What data do exist from university measurements indicate emissions at the stack while the reactor is running of about 250 times EPC; doses to members of the public in unrestricted areas in the range of 5-900 mr/yr.

The date ard time (if available) cf the violations are included in the inspection reports identified in response to First Set Interrogatory 21; the resultant exposures have been long-tern ard are continuing.

Please note that although Intervenor makes no assertion regarding radiation exposures due to violations 1-4,7-9, and 14-16, Intervenor believes those violations are evidence of extremely poor practices that make it impossible for a favorable determination to be made irdicating that reasonable assurance exists Applicant will obey URC regulatiens in the futu-e and take the necessary safety precautions over the 20 years of the proposed license.

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14. Intervenor's statement at this time of the primary calculations, computations, assumptions and conclusions of the Battelle study with which Intervenor is in disagreenent must be prefaced with the following remarks:

A significant part of the Battelle study is (1) conclusory, with no data presented to support the conclusion, (2) contradictory, with no explanation given to explain the apparent internal contradictions, (3) lacking in prolative value, for example, assuming certain numerical values for key calculations without any evidence given of the validity or even of the nunber employed.

There nay be explanations for these apparently crucialdefects. What appear: upon reading to be internal contradiction may be non-contradictory when additional information is presented. Sources of probative value may exist for apparently arbitrary assumptions. Conclusory statements may actually be lased upon more than mere opinion of the authors.

Until the interrogatories submitted to IGC Staff ani its consultants responsible for the Battelle study are answered, Intervenor can only give its disagreements hsed upon what appears to be the import of the Battelle study ani what aprears to be missing.

First of all, both the abstract ard summary appear to be in direct contradiction with the text of the report. Intervenor can fird nowhere in the body' of the documert support for the conclusion that "the only credible accident involving offsite doses was determined to be a fuel-handlir4 accident." In fact, quite to the contrary; the report seems to Intervenor to describe numerous accident scenarios that are credible ard would result in significantly 8reater effect.

The conclusion of 12 Ws energy release from an excess reactivity insertion seems unsupportable from the caterial presented in the report and from aralysis of the SFERT, 30P.AX, and SL-1 original reports, and is in direct contradiction with the Hazards Analysis for the UCLA-type '

Argonaut reactor ard, indeed, with the relicensing Application. No explanation of the contradictory values for power release is given; particularly there is no explanation of why the Battelle analysts took, in what was to be a conservative analysis, the least conservative of values for energy release from the values they themselves report from the literature (see p. 6-7). For exargle, the GNEC material concitxies that 32 Ws is the resulting release from 2.4% delta k/k insertion; yet Battelle assumes--with virtually no b ,is from a greater reactivity insertion (2.6%)given-that the than would be less ener{/ release 2 that which GUEC assumes for 2.45 In a ratter of such importance, such vast variation in assumption leads only to the ccnclusion of vast uncertainty and the need for vast rargins of safety because of that uncertainty.

The report made clear that certain accident scenarios or initiating or ccntribut$ngevents uere outside the scope of the report ard not included.

(p. 8, botton paragraph details the additional research necessary for a prointive conclusion to be reached.) Accidental or delib= rate irradiation of explosives or common materials with explosive properties was inadequately addressed. The shock wave phenomenon was, by the author's admission, only touched upon ard needs further research. "It is conceivable that substances could be deliberately added to cause rapid dissolution of the fuel plates," but then the authors stated that consideration of such an incident was "beyord the scope of this report." Thus the conclusions

10 identified in the surnary ani abstract have no weight, when the universe of possible initiatir4 events ard centribution events was so arbitrarily and restrictively draun.

The disagree:ents Intervenor has with the 3attelle section on reactivity insertions will be discussed in answer to Interrogatcries 15 ani 16 telow. As to the section on Catastrophic Mechanical Rearrange ent or Flooding, as ue read the section, it cutlines a massive amount of excess reactivity which can te inserted through rearrargements and/cr flooding, ard even if only a small pertion of that potential reactivity were inserted, a rajor excursion could ensue. Note for example, that

p. 27 irdicates potential insertions of 5 65 from flooding, partial collapse producing 8.75, ae complete collapse of 18.55 Those are immense values .

considering the current detate over uhether 2.3% could cause meltira.  ;

If even a fraction of the available reactivity were inserted through  !

rearrangement ard/or flooding, a very serious incident would be possible, ,

in Intervenor's view.

The discussion of a core-crushire accident is most confusing.

It states very clearly that the consequences "from a core-crushing accident would be some multiple of ;be consequence of the fuel-hardling accident",

which is quite legical, aui yet Coever wrote the abstract concludes that it is the fuel-hardling accident which causes the raxicum off-site deses.

In addition, the analysis only seems to dea' pith droppire a shield block en the cere, not the problem of earthquake ard building collapse onto the core. -

The explosive chemical reactions section is likewise inadequate.

The explosive reactions possible in case of graphite fire (ard the complications of fire fighting) are not considered. carefully. SP.":.RT ard SL-1 both had explosive chemical reactions (see Thompson ard Beckerley);

the uncertainties of interaction with schock waves are, by admisston, not dealt with. Eetal-water reaction is not well understood (see appendix to 'JASH-1400 dealing with such reactions); the calculations cade on page 29 cannot be rade with any certainty and 7equire huge error bars and safety margins, which have not been taken into consideration.

The graphite fire section appears to Intervenor to describe numercus credible scenarios for reactor fire which could lead to release of considerable fission products into the environment. Earthquake-induced fire pla core dacage increasing airflow was not considered in detail.

P. 32.statenent "it would take an act of ignorance or willful disregard of proper procedure" appears to igrore the fact that these are research reactors operated by students ard, in the case of UCLA, with a long history of disregard of proper procedures and NRC regulations.

Intervenor cannot fird in Nightingale the energy accumulate rate cited by the 3ctte11e study. The applicable fidure appears much higher.

In additien, the k'id figure given for UCLA is unreasonably low--both for current history ard for the accumulated operatirs history by the end of the proposed license renewal period. The amount of absorbed energy thus is clearly not " trivial."

The various tuilding fire and accidentally-iniuced reactor fire scenaries presented all support the conclusion on p. 43 "the aluminun fuel boxes and fuel could te at risk for celting." The entire section appears to contradict the abstract and suc=ary's assertions about fuel hardling being the only credible accident scenario.

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The section of fuel-handling accident seems to raise serious questions as well. For example, the x/Q figure has no source or basis given in the study. In addition, it is most remarkable to Intervenor that Battelle assumed more curies of I-131 getting out of the reactor

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room than did UCLA's Hazards Analysis,~ ard yet the dose to the nearest irdividual in an unrestricted area was determined by 3attelle to be nearly 50 times lower than in UCLA's application. No attempt to

) resolve those discrepancies has been rades that range of uncertainty is such as to make even the fuel handling incident, which Intervenor believes to be a relatively minor accident considering the accident potential for this facility, an unacceptable possibility. Note also that direct exposure to radiation from an exposed, dropped fuel j element is not considered.

I 15 Intervenor has at this time no figure for the level of excess reactivity that wi g produce melting in any fuel plate in Applicant's l _

l Argonaut reacter. We believe that there is an unacceptable likelihood

that the current and proposed license limits g m produce such melting,

and therefore believe that the original hazards analysis for UCLA and the original license granted by the AEC were quite prudent in limiting i the excess reactivity to less than that z.scessary for prompt criticality.

Given the uncertainties in comparing 2 reactors of very different design, moder- t ation, core configuration, clad: ling and meat and channel thicknesses, neutron lifetin.es ani flux ratios ani figures of merit , each of which  !

increases the necessary error tars, the prudent safe level-is no higher than .65 delta k/k. The only way to know for sure what level of excess reactivity will cause fuel melting at the UCIA Argonaut is to conduct an extensive Borax or Spert type series of experiments on a reactor with precisely UCLA's characteristics, and under varying cc.nditions (such as ambient temperature, graphite temperature and energy almorption history). In the absence of that necessary research, the error bars are too lar6e to allow UCLA to operate at, beyond, or near the levels its own Hazards Analysis and current Application irdicate could cause melting. For ia description of how the Hazazds Analysis shows melting could begin around 2.5, see the Supplemental Contentions and the previous set of Interrogatory answers; in addition, because of use of an inaccurate void coefficient in the original calculations, simple correctior. of that single error brings the danger level down to 2.15

16. Yes. First of all it should be moted that the 2.65 Eattelle calculation is lased upon a 2.% figure at normal temperature, which is the equivalent of 2.65 at very low temperatures. We have explained in 14 above our disagreement with the estimate cf 12 G's energy release.

Note that on page 19 the study determines that such a reactivity insertion (with what we feel is a vastly unrealistically low estimate of energy release) nonetheless gets one to 74 C from the meltira; point of the t fuel meat, according to the authors. However, note that p. 18 indicates  ;

melting occurs at 6400 C, so there is a 200 error--3attelle is actually 540C from melting, even with the unrealistic assumptions about small energy release. Note further that 3attelle assumes a starting fuel 0

tegperature of 60 0 whereas IGC Staff assumes a starting 0 temperature of 75 C. If one takes the Staff figure, one is now 39 0 from melting--

with no error lars, no room for any other factor affecting the calculation.

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12 Given the numerous factorn that make such an extrapolation and interpolation of SPER* data to UCLA (and all Argonauts, no less!)

difficult if not impossible, a 3900 cargin of safety is no cargin whatscover. For example, if Applicant's analysis is correct rather than 2atte11e's as to the energy release, ard one uses Battelle's energy release-to-tenperature rise correlation, the tenperature of the fuel would be cany hundreds of degrees over melting.

In addition, note that whereas tha original UCLA analysis converted fron 3crax data to UCLA by cakir4 corrections for different cladding, neat and coolant channel thickness, different figures of nerit, different neutron flux ratios, and so on, Battelle cakes none of these corrections. It makes only one nodification, that of neutron lifetine.

The Battelle analysis then is even nore crude than the UCIA application's analysis, ard even with all those non-conservancies, it still gets within 39 of nelting.

Sources: "Experinental Study of Transient 3ehavior in a Subecoled, Water-Ecderated Reactor" by F. Schroeder, et al, Nuclear Science and Engineering, 2,96-115(1957); Report on spert I Destructive Test Results, Trans. ANS, 1963; I00-16683 Eiller, Sola and McCardell Spert report for Phillips; Experinental Deterninations of the Self-Regulation and Safety of Operatirg Water-Moderated Reacters, 3.2. Dietrich; UCIA Application

17. Intervener has indeed tegun analyses of these ard other accident scenarios, although it continues to believe very strongly that it is Applicant that has the responsibility for thoroughly analyzing potential reactivity accidents, and other accidents. Intervenor needs additional infor ation, both from Staff and Applicant, information uhich it has requested, to nove further uith these analyses. In particular, Intervenor still has not been provided enough data to estimate accurately mxinun fission product inventory at time of accident; to esticatd fission product release rate for UCLA's particular kind of fuel over a wide temperature range; and to make an indeperdent, site-specific determination of x/Q at various locations in unrestricted areas near the reactor. Intervenor is actively pursuing its atte npts to obtain that inforcation.

For the reactivity accident scerarios referred to by Applicant in this interrogatory, Intervenor's prelininary analyses have focussed on insertions in the $3 00 to $4.00 range, although because of the uncertainties existing because of lack of reactivity research on Argonaut reactors, for the purpose of said analyses all that is required is the assumption of enou6h rmetivity inserted to cause nelting, and as stated in 15 and 16 above, not enough research has been done to determine conclusively what level of reactivity insertion will produce nelting and/or steam explosion. The darage assuned to result was the same for each scenario--tuo levels of damage 8 l

fuel melting on one level of severity, fuel nelting ard stean explosion i on the other. Substantial fissicn product inventory release occurs in either case, but Intervenor has not yet made a determination of specific l f3 ssion product release f- agnent. The 100 volatile release assuned by

! Applicant in its Application appears at this stage of analysis by Intervenor l to be reasonable for sone accident cases but not sufficiently conservative for others, particularly the scenario in which the excursion is initiated l by an earthquake that also produces core damage.

Sources: CR:iL-2616 Experinents en theaelease of Fission Products from Molten Reactor Fuels" b- 22, 1959; l

" Properties of Fission bCreek, Fartin ard Park, Julyoduct Aerosols Produced by Cverheated Reac

13 ,

by G.W. Parker et al, in CRNL-3547, March 1964: Thompson ard Beckerley:

District Surveys follcwing the Wirdscale Incident, by H.J. Dunster, et al.

from 2nd Peaceful Uses of Atomic Energy, Geneva, 1958, Vol. 18, p. 296:

Airborne Radioactivity After a Reactor Accident, by Joh.' 31ok, also from Geneva Peaceful Uses Conference: IDO 16285 " Experimental Investigations of Reactor Transients" Appendix VI to WASH-1400 " Calculation of Reactor Accident Consequences"

18. The organization referred to is the Intervenor organization, the Committee to 3 ridge the Gap. Intervenor does not know that it will reach a decision or juigment as to the most credible accident scocario, as it doesn't think that determination particularly relevant to the proceeding. The central issue is whether the maximum credible accident could produce unacceptable consequences. As we understand the position of Applicant, the consequences from m credible accident are minor and acceptable. Our position is quite the cpposite. There are quite a number of credible accidents, in Intervenor's view, that could produce extremely serious and unacceptable consequences.

What Intervenor is in process of attempting to do-ard it should be reiterated that it rerains Intervenor's position that it is Applicant's burden to corduct such a thorough analysis, not Intervenor's-is to determine a number of credible serious accident scenarios for this facility, and attempt to determine the range of fission produce release possible, and from there consequential doses to the public in unrestricted areas.

Although Intervenor may reach a conclusion, when more information from Staff and Applicant becomes available, as to the raximun credible accident, it does not interd to focus on only one major accident, because its current analysis irdicates roughly a dozen accident or hazard scenarios, each of which would produce unacceptable consequences ard each of which is credible.

Preliminary opinion, however, is that a reactor fire (caused either within UEL or by a general building conflagration) is probably both the most likely ard most serious of the accident scenarios currently urder review by Intervenor.

This is because such a fire could continue over an extended period of tine, the flames could provide a significant driving force to spread toth volatile and non-volatile fission products into the environnent, ard the emergency plans for fire-fighting (a particularly complicated response given the nature of graphite, uranium-metal, aluminum reactors) are so unclear.

Intervencr notes that 20,000 Ci of I-131 were released from a graphite reactor fire at Winscale, through heavy filters in the stack (non-existent at UCIA).

The above represents a very preliminary view, as Intervenor's inspection of the facility has not been conducted yet, Staff answers to interrogatories on these ratters have not yet been provided, a x/Q and fission product maxinum inventory reasonable ard conservative for this facility over the next 20 years still are not available.

14

19. The stardards being violated are identified in Contention VI.

The levels of radioactivity released are 1-2 x 10-5pCi/n1 of Argon-41; 100,000 cpn of Cobalt-60; 1 nr/hr neutrons. The source of the stardaris are also identified in Contention VI.

20. Dr. Lycn received his A.3. in 1942 in Zoology and his M.A. in 1949 in Physiology at UCIA, ard his Ph.D. in Physiology at UC 3erkeley in 1952. He has been a Rockefeller Fourdation Fellow in the Eedical Sciences at Earvard? School of Public Health, held a dual appointnent as Assistant Professcr in the Dept. of 31ological Chenistry at the University of Illinois College of Eedicine ard as a Research Associate in the Physiology ani 31cchenistry of Bone at Presbyterian-f,t. Luke's Ecspital in Chicago, was an Associate Professor in the Dept of Eicchemistry at the Chicago Eedical School, Professor of Biology at 3ennington College, a Senior Visitor at the Institute of Biological Chenistry at the University of Copenhagen, a Special Consultant to the California State Energy Concission, and has most recently taught at UCLA courses on radiation ard hunan health focusing en exposures from the nuclear fuel cycle. He has more than 30 publications in biochenistry and biophysics in journals such as J. Biol. Chen., J. Aner. Pharm. Assn., Sci. Ed., J. 3one and Joint Surg.,

J. Eact. , Eycopathol et Kycol. Appl. , etc. ard his written nunerous reports for the State Energy Connission on Draft Environnental Inptet Eeports conceming nuclear power projects, EIR guidelines, reactor safety, etc.

He was a researcher and author of the 400 page report for A>JP on radioactivity in California nilk. Intervenor does not at this time intend to qualify Dr. Lyon as a witness in this proceeding.

Dr. Plotkin received his 3.S. in Electrical Engineering in 1946 at University of Colorado; he has an additional 3.S. in Aeronautical Engineering, also fren University of Colorado,1949; Ph. D. in Electrical Engineering from UC 3erkeley, 1956. Fe is a registered Professional Engineer in safety engineering in the State of California; he is President of Plotkin and Associates, a consulting erfi neering firn specializing in accident analysis ard consulting systens ard safety engineering natters. He has worked at Los Alanos designing nuclear instrumentation; at US Air Missile Test Center at Pt. Eugu corductire missile flight test analysis and evaluation; in charge of instrumentation for Cosmic Ray laboratory, UC 3erkeley; designed and developed high power pulse nodulators for Energy Systems; Assistant Professor of Electrical Engineering at 13C; systens engineer for Hughes Aircraft; systens en6 1neer for TRW, specialized in security systen I

development for California Dept. of Corrections ard TRW, anong other projects; PAND Corp. as senior engineer. Anong hic publications are a book entitled Accident and Product Failure Analyses. Intervenor I

l suspects it will call Dr. Plotkin as a witness in the UCLA proceedire, but has nade rc determination as to which contention (s) nor nade a '

firn decision on the natter. For his part, Dr. Plotkin has indicated tentative agreenent to testify, pending determination of date of hearing and certain other uncertaf nties not yet resolved. When a firn decision

! is made, this answer will ce supplenented as per 10 CFR 2.740(e)(1).

e*

l

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15

21. The " twenty volunteer" researchers were not described as havirs helped write the report but as having helped make the report possible.

The writing was done by a small sub-group. The other volunteers did the follouirq kirds of research: searching IRC public documents regarding the reactor, subnitting Freedom of Information requests for documents not otherwise available, doing computer searches throu6h the medical library on research regarding the effects of Ar6cn41, searchin6 for and pulling technical reports from the ergineering library on 13C dispersion models ard radiation limits, ard researching !!RC I & E policy ard 2.206 ard license intervention procedures. The Research Director for the project is no longer on the Eridge the Gap staff ani she is the person with knowledge as to names ard back6 rourd of most of the volunteers. Michael Schwartz was a 3rd year law student at the time ard well-schooled in legal research. Eichael Rose, a UCIA graduate student with considerable backgrourd in news research, conducted much

>f the FCIA effort. A graduate student in nuclear engineerings a grad student in public health, ani a 6:ad student in statistics did preliminary research into and analysis of the Rubin thesis, the effluent records, ard the properties of ArEon Generally. The backgreurd of Eaniel Hirsch, Dr. Lyon ani Dr. Plotkin have been provided Applicant previously. Three law students helped Idchael Schwarts in his legal research; we resenber then to be associated with the Environmental law Society but have no record of their names. Ardy Lieberman's contribution consisted of witnessing a radioactivity spill at the

!!EL reactor uhile being given a tour ard providing details. We received valuable assistance regarding radiation effects and standards from Dr. Rosalie 3erte11, for:erly of the Tri-State Leukemia Study.

The above represents the extent of records er memory as to nanes ard tackgrounis of the volunteers.

/

22. UCIA Response to liotice of Violation, sent by Thomas Hicks on Farch 13,1975 at the botton of the second-to-last page that certain conclusions as to dispersion facters can be drawn from the Applied

?!ucleonics study. Referring to that study, Dr. Eicks states that the study shows that the present stack would have a worst case dispersion facter of 1/120 whereas a modified stack would have a dispersion factor of 1/570, a core than four-fold change.

23. SF6 has been used by ? EL to simulate ATon41 dispersion from the stack. See the Rubin thesis, " Atmospheric Disperion of Argon 41 from the UCLA Iiuclear Reactor." As that thesis indicates, Mr. Rubin released a known concentration of SF6 from the stack and attempted to measure its concentration at various locations away from the stack. :!RC Staff ard UCLA I2L Staff have relied heavily on those measurenents in atterpting to esticate Argon 41 concentration in unresMeted areas, dispersion factors, ard consequential radiation exposure.

24. In addition to those abnormal occurrences reported by :EL as such, Intervenor includes in the term "non-standard incident" all the scrats identified in SCRAM reports, the sunrer 1979 pneucatic tube radioactivity spill incident, the January 1981 radioactivity spill incident, the sprirg 1981 flooding incident, thecontrolpanelshortinE/floodinginfall1979, the leakirg start-up sources, the primary coolant leak, and the Cohilt-60 contamination incidents.

O

- p 26 .

25. he cede specific. sections The rissin6 cited in Intervener's information includes: previous answer are quite detail to determine adequacy of the reactor shieldina description in sufficient shieldirq on all sides and abe re the reactor (1.e. and the supplemental andradicactive for the shielding in the reactor room walls and roof), handling devicesthe reactor substances and contamirated objects and individuals as well as spent fuel itself, det. ailed description of raduaste storage facilities, detailed description of workin6 areas, detailed description cf threshholds and history ani accuracy of measuring and monitoring instruments; detailed description of reactor procedures, particularly thse such as procedures to avoid accidental criticality, precedures procedures, radwaste shipment procedures (high ard lou proceduras for the public, precedures re6arding operation of reactor eentrols by unlicensed operators, procedures for fighting reactor fires precedures for controlling flam:able loading in ::EL, procedures for ,

cleaning up contaminated liquid in case of significant flooding, detailing the natureprecedures for freeing pinned centrol blades or dump valves; infer and the emergency pre,cedures for each area in which SNE is h of radiation survey instruments in accessible locations. stored 27.

better::oidea arrangements of when hearing forcay expert witnesses possibly occur. have yet teen made, perdirs Ir. plotkin, as indicated in 20 above, has irdicated a tentative willingness to serve in that but that capacity, contingent renains a very tentativeupon hearin6 dates and certain other factors expression. ,

Likewise, Dr. :1chio I~aku, a nuclear physicist from the City University of New York, has in recent days expressed a tentative willingness to testify, again contingent upon dates for hearing being set and certain other factors not yet resolved Until Intervenor has a clearer idea of approximately when hearirgs .

might occur, it cannot nake arrangenents with expert uitnesses, ard has not.

Intervenor currently possesses about Dr. Kaku ons (not detaile about serving as an expert recain quite preliminary) is that he received is a tentred professor of nuclear physics at CUNY; and s vely research reactor accidents, in particular, reactivity accidents.

No decision has but Vbeen and X rade as candidates.

are likely to which contentions he nicht address, should he testify ,

(a) - (c) see above. Intervenor will supplement as per 10 CFR 2.740 28.

sane "o arrargements reasons for27other as given in uitnesses have been finalized, for the above.

certain of its nenbers who participated in document review at UCIAIntervenor during which Applicant produced certain dccurents that cay te introdu as evidence, ced in order to authenticate said documents. Ianiel Hirsch and David rupont uculd likely be the irdividuals so calleda the documents- j involved would be taken fren anong those prcduced by Applicant , determination of which not having teen rade at this time idea of when hearings say occur, no arrange. Until there is a better to te finn H zed.

Intervenor will supplement as per 10 CFR 2.740nents for witnesses a (a) - (d) see above.

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s' VERIFICATION I, DANIEL 0. HIRSCH, says

1. I am the President of the CChMITTEE TO 3 RIDGE TEE CAP, Intervenor in this action, and I have been authorized to sign this verification on its tehalf.

2. All of the information provided in the attached ANS'4ERS CF THE CCMMITTEE TO 3RIDG7 TEE CAP TO APPLICANT'S FOI1C*d-UP SET CF I'TIERROCATORIE5 represents the information currently possessed by the Intervenor relevant to those Interrogatories.

3. I have read all said ANS'lERS and do believe them to be true and correct.

Signed on November 9,1981, at Los Angeles, California.

I hereby affirm that the foregoing is true ani correct.

,A

^

/ ,/) /

lb /

Daniel (O. Hirsch O

CIITED STATE CF AMERICA TUCLEAR ?.EGUIATCRY CCD2SSICH 3EFCRE "'FE ATCMIC SAFETY AND LICEMSI"G 3 CARD In the Patter of )

Docket No. 50-142 THE RzG & 5 CF THE UNIVE3S C CF CALIFCP3IA (?roposed Renewal of Facility License)

(UCI.A Research Reactor) )

EECIARATICN CF SERVICE I hereby declare that copies of " ANSWERS CF TE COEMITTEE TO 3RIDG TE CAP TO APPLICANT'S FOLLCW-UP SET OF INTERROGATORIE" in the above-captioned proceeding have been served on the following,by deposit in the United States mail, first clasc, this 9th day of November,1981.

Elizabeth S. 3cwers, Esq., Chairman Christine Helwick, Esq.

Administrative Judge Glenn R. Woods, Esq.

Atomic Safety ard Licensing 3oard Cffice of General Counsel U.S. Nuclear Regulator / Commissien 590 University Hall Vashington. D.C. 20555 2200 University Avenue 3erkeley, CA 94720 Dr. Emmeth A. Luebke Administrative Judge Counsel for NRC Staff Atomic Safety and Licensing 3 card U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Vashingtcm, D.C. 20555 Docketing and Serrice Section (3)

I Dr. Oscar H. Paris Office of the Secretarf Administrative Judge U.S. Nuclear Regulaterf Commission Atomic Safety ard Licensing 3 card Washington, D.C. 20555 U.S. Nuclear Regulatcry Commissien Vashingten. D.C. 20555 l

t

! Villiam H. Cernier, Esq.

Office of Ad=inistrative Vice Chance 11er l University of California

! 405 Hilgard Ave.

Los Angeles, CA 90024

! Mb ebb 1, Wendy Schfielker i

I