ML20010C131

Update to 810612 Motion to Compel Further Answers to Second Set of Interrogatories Directed to Ucla,Per ASLB 810715 Order.Declaration of Svc Encl

ML20010C131
Person / Time
Site:	05000142
Issue date:	08/10/1981
From:	Pollock M COMMITTEE TO BRIDGE THE GAP, POLLOCK, M.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8108190165
Download: ML20010C131 (12)

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'TCI2AR IGUI.CO27 CCI.hIS3ICT 3E"C3E "'EE ATCGIC SAFUZ: ArD I.ICESI G 2 CARD In the Eatter of Docket:To. 50-142 TEE EECE'r3 CF TE ET/ ERST ~f

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(Proposed Renewal of Facility CF CALIFCRTIA

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UEDATED ECTIO:7 TO Cer.rr.a e TC 2'3 SSI I:TERRCGACCEIH3, A5 PER 30ARD O3 DER CF JULY 15, 19813 C r.r us su DISCCVERI EATTEE.2 I, T7ECDU("IC" On J';ne 12, 1981, Intervenor filed a notien to conpel further answers to its Secord Set of InterroCatories. UCIA had served its answers to said Interrogatories on or about Eay 20, 1981, ard responded with additional explarations to the notion to compel on June 29, 1981.

At the sane time, Applicant also submitted "Supplenental Responses."

Applicant further st.ated it was continuing to derive informt'.on and would supplement answers as soon as it had obtained the information.

'Wcing that "several of the UCIA ansuero iradvertently omitted from the 3

origital response and promised in the supplenental response are still DSO nissinC" and roting further "that UCIA believes the recently released

/ I Staff docunents provided sor.e of the requested inforcaticn," the 2 card directed Intervenor to update its nction "since it appears sone line items ray now be r. cot."

UCIA was directed to inform C.4 cf its efforts l PDR ADOCK 8108190165 810810 05000142

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i to fu-r.ish :supplenental anscers an? uhen said answers were expected to be provided.

Cr Aucust 3, the Applicant respctded with a sunnary of outstandir.- itens and indicated tl.at the follouine questicrs would be arsuered cr supplenanted by Aucust 14: I,17(h),(i) ard(j); III.32; 7I. 21; VI!!. 14.

Certain irterrogatories as to ;ortertien 7.7.I (h. 29(n), 3f, 41 and h2) Applicant said it could not firnly estir. ate wher it cou2d answer as it does not presertly Ecu "hcu we intend to respond to certain energency situations ander the provisions of our energency P R"."

3 As per the Joani Crder of July 15, Interverer herewith respectfull-;

sulnits its update to its Motion to Conpel Further Answers. The update of the line ite s is included cerein as Attachnent A.

For the convenience of the 2oard, a sunrary of the status of the outstanding itens is incitr'ed as Attachnert 2 II.

EI3C"33IC" Certain itens the subject of the previous : otion have beer supplenented ir Applicart in its "3upplenertal Arsuers" of Jure 29 Other itens Pave been arsuer 6, at ler.st in part, by Applicant's discussion in its "3espcnse to Ir'erveror's Ection to Conpel", also of June 29 In particular, where Applicant has explicitly stated that it has ro other infernation as to the questicrs at issue, and where Interveno-did not have reason to pursue the ratter, Interverer has witFdrawn its request for further arsuers thereto.

I':us, a wn'cer of the itens ir Intervenor's 'ction of June 12 are now rade nace noot and nave *been uithdraun.

Certain other it.rs still rerain for uhich further arsuers appear to Interveror to be in enler. Ard certain othez ' tens, while r.ct answered to date, are pronised by Applicart to te provided five days her ce.

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for thich further answers Prve been promised, Interveror Pas withdraur its regrest, althouch should these answer prove inadegrate, Interverer Mill te forced to rereu said requests as the" apply to the supplenented a-suers.

Those itens for which supplenerted nnsuers have rot been pronised and for unich ansuers retain inadequate, Interverer respectfully requests the 3 card to conpel further answers.

As to.' plicant's a icertion that release of the recent 3taff decurents q

mhes L. cot a crent ~ar" of Interveror's inter-ora +sries, Interveror does

-ot see tPe logic therein, aside fron one or tuo questiors uhereir Applicant refers Interveror to the docunents, inplicitly statirs t'..at it has no inforration of its cun other than that ircluded in said Staff d ocuner ts.

In certain cases Intervenor has requested that Applicant be directed to he explicit as to whether it cercurs with estinates ir 3taff docunents to which it refers and whether it has ar; irfernation c its own otber than that uhich is included in the 3tr.ff docunents.

o Irtervenor's I-terro,patorie? to Applicant go to irferna. tion Applicant possesses (in particular, possessed prior to the Staff docunents beirc released) relevant to its cun 1.pplication and 3afety Analysis.

'be Otaff's 3afety Evaluaticn Report ard ]nvircrnental Inpact Repcrt, and the tuo rela ed studies, represent 5taff opininn.

Intervercr's Interrocatories to Applicant co te irferratier and positior of Applicant.

Ir. particular, nary InterroCatories refer directly to portions of Applicant's '.pglication.

L'e do not seo how release of 3taff docunents altera irterrocatcries as to Applicant's docunents.

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As to <.pplicai.'s assertion t'at it cannot supplenert its answers to irterrogatories as to its cur-ent enersenc; plan ur til "ve are able to clarif: uit5 the.':C techrical sta wPnt enercerer response recairer.ents are to appl: te our facilit; ar.d to reurite our plar accc: fin;1,.,"

I:P erveror 'otes Rat the cuestion of the adequac; of AppIlcant's current plar is at questicn ir these proceedirgs, a.-d that Applicant r.ust have scne procedures fer respondiv to ar energencc that ni6t occur prior to firal clarification with :TO staff as to revisien of the curren^'- snbniu.ed plar. Therefoie, Interverer believes that, should ev 19?crratic' 2,1r rart to the particular inergency Ila questions for which supplerertea 'nswers have been pronised arise prior to the revision of the enerserc:l plan, it should b? provided to Interver.or in a tinely fasFion. Interveror further nctes that it has seen no corresponrience or other documents betueen Staff and Applicant as to

.~'nergenc: Ilar, and uhile infernal contact is "ct prohibited, are uritten naterials passed totueen the other parties should be provided to Inter /eror as well, 4-y%,-.y, la1 f.4.1 t'.. m.e

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. 14.3 Crder of Jul:

1, lc81, the Ioard opened discovery on ' cur documents 37 recer :ly released by Sta#f, but suspended the discovery schedule as to other rntters. pendirc a forthconirc 2oard Crder.

C~C, havirs been rotified 4 phone k a secretar - to the 3 card of the proposed alteration, requested

".7at it be pernitted to -ke suggestiors as to the revised schedule, which it did b-letter on June 30.

Juhseguent to the July 1 Crder suspendinc the 11scover.; sch edule, C2O has. aside fron the afore-tentiored natters recardirs 5taff docunents, suspended its fcrral discovery.ctivit/.

For example, C G 1,as r.ot served follow-up interro6atories to certair supplenental arswers of Applicant,

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nor ' as it served plarred produc.icn recuests.

IM ervencr brirts this to t!.e :: card's atter_tior. to request tha,,

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tSe 2cari lam:es its revised diccovery schedule, tir.a is provided fer cc7 "ticr of these matters, jarticularly doctnert producticr, 1

'icP 'ac a Ir..Ger de'x. tine associated with it fc response arr: additierally "cr schedulir cf p cductier sessicrs and actual revieu a:d ccprir,

In additicr. C' requests t' at the Icari,1" possiSle, include in that schadule a rough estirate or' uher hearirca cicht tecin.

I.tervonor un 'erstards ti.a larce urcer'.tinties involved, bu t ic is Navir; difficulties inhin:' firn arran-enents for expert ui te. esses 11thout bei c,_tle to ir?icate to the prospective witness rough tire f:are.

Inte::venor has or.e further request fer clarification when the revised diservery schedule is issued. Au.11c:.nt 'res, ir-runerous respo ses to C.C's Interrocatories, referred Intervencr to docunents ir lieu " irterrogatory arsuers. Ac copies of docunents were cenerally :ot available prior to C20's follow-up irterrocatories heirr served on June IC (answers to which have teen suspended awaitief resunption of t!.e discover" schedule), Interve.ar requests clarification of the fcllcuins intter: dees Intervenor have the right to follow-up interrcratories as to mtters raised ir said dccunents, ard if so, as per what schedule?

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As per 2 card Crder. Interveror i.as nodified its : otier to Conpe.1 ir licht cf subsequent resperscs ' y Applicant.

Certain itens have 'ceen dropped. others have been pronised by Applicant in suppler.ents, and others rerai" ratters which Interveror believes r2quir" Zoard acticr.

Intervenor has also requested clariffcatien of several ancillary rntters remrdirg discovery schedule.

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Dated: August 10, 19P1 fiJ.f 7G2CCK

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Irterveror cor '.irues to raquest further arsuer as it applies to Eh a and b.

to ielieve that rore of Applicart's I ' =rver or co-t."-nes to fird it Par d 3*a'f, acne of when have l'eer at facility sirce considerably he'ere the Techrical 3pecificaticrs were adopted, Fas ary irfornaticr alcut

" e original purpos of these requirenents.

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Irterverer cortirues to request further ar suer. Applicant states ir. its Applicatier "Acciderts ra: girc fron failure of experinerts to the larcest core danace and fissior product release considered pcssible result in doses of crly a erall fraction of 10 C7? Fart 1CO guidelires ard are considered agligible with respect to the ervirornert." i'his statenent uns made before the TEC staff released its 3E3, ZIA, ard related docunents.

Thus, these irterrogatories pertain to Arrlicart's fiEures, studies, andaralysiswhichsupportorcontradictthestater.entorFaceII/3-1 cf their Application. Applicsrt still gives ro figure as to precisely what fissier product release it considers the largerc possible, rcr does it specify what is the largest ccre danage it ccrsiders possible, ror how extersive ar ervirornental inpact is considered reclicitle.

Irterverer withdraus request for further arsuer or basis of Applicart's 24e explaratier in its its Resperse to the not' cr to conpel, indicatirc that Applicart did *ot base the statenent on ary studies.

27e Irtervenor withdraws request.

20k Interverer withdraus request or basis of Applicart's explaraticr ir its 7esperse the' Applicart krcus of ro other studies.

Co-tertior II 4

Intervenor continues to request further arsuer. Applicant's explaration ir its 3espense renairs confusing--Irterveror didr't ask whether contracts ard grarts are accourted for separately, but uhether costs related to reactor are cccounted for separately.

Irrerverer contirues to re We still don't haven't been told Fou the figures on page I/ quest further arsuer.

4a 2-1 of the Application were arrived at.

I"terven:2 contirues to request further answers. Tha " answers" to which Applicant refers Interveror cor.tair ro infornatior. Applicart has ro shouirc that aca enic revieus of departnertal,rorrr.ns (as d

nad e opposed to ircivf auals) are by formal uriversi'v molicy kept cerfidential; I"tervercr's urderstai.dirr is that such procran reviews are rot by rule corfidential. They ar9 relevant to Irtervencr's contertion that the original research and educational functions of the reacter have been duirdling, recessitatirc "extranural" (to use Applicart's reu tern for connercial) activity to cenpersate for lost scholarly usefulress.

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!rterveror contirves to request further answers. Agair the arsuer refers to ar arsuer which does not provide the required infornaticr.

Ine crly reference to a document, the general ledcers, does rot 1" any way idertify "all letters, reviews or other documents which cortair reconnerdatiors" to the Eean of 3EAS corcernirr the firancial support of the reacter.

Irterveror certends los-of scholarly activity at reactor has c sated a trerd of reduced firancial support fron the university, recessitatirg the reactor to go more and more into

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(e-ter tir~ :I c o*.Poed )

connercial activity to nake up the shortfall.

2 e requested irferraticr is essertial f;r documer tatier of such a contenticr, ard thus very releva-t.

Certairly docuner(s' related te recorr.erdattors for furding levels of the reactor nust he available.

C Interveror co-tirves to request an arsver.

It nust krow ul.a dccunents exist regardirg the tudgetary process for the reactor to request said docunerts, ard those docurents are directl: relevart to the questior of v' at part corrercial activity plays 1-the re2cter operatior,

prticularl: whether budgetar: pressures fron reduced levc's of suppcrt can be expected to further 1 cad the reactor irto noro connercial vertures.

%.b Interve"or contirues to request an answer. It firds the 2.' erred -to answer iredequate ard evasive. The irterroiatory requests specific i-ferration as to the specific factcrs i-specific years which led to shortfalls ir allocatier as opposed i,o budget requests as well no identificatier of docunents.

Interveror reeds to krou uhether the shortfall has 'ceen ircreasirg ir size, is related te

.' ction ir student populatien served by reactor or lack of scholarly research produced, cr other factors which could cortirue to push reactor use irto greater corr.ercial activity ard even less research and education.

31nple denial, if rade, of such factors would not be enough; the docunents invo3ved ir these decisiers need to te exatired. Applicant's statere-t that "forral records or lists are seldon actually produced" tegs the questier of describirg with specificit: the records that do exist.

"C"E as to 5,6,P." ail): Applicart referred Intervenor to answers to Irterroratories X'/III 3,4,6, ard 7, for which it had requested a protective order fer part and answered ir part. Applicart did not request a protective order for II5,6,2,Caor C'3.

(Also please rote erroneous refere-ce ir Intervercr's i:otion to Ocnpel referrir g to its argunents as to those irterrogatories regardirg contentier X'/III; as is clear, Ir+ e ' c-or uns ura'cle to "yt to" irterrogatories 'ceyer? certentior TIII th '

felt were iradequate, the burden of the disc: fury problen leirc too great for a srall organization to tear cc pletely.,

hl Interverer withdraus its request on Msis that Applicant new Pas stipulated that the tern "extranural user", for all users to date, refers to "cannercial users" as Inturverer has used the tern with recards this Cc-tertion.

M Irterveror withdraws its request 46

1. cv fur ^her answers as to 50,a,these irterrocatories b cr Msis or 1,a Applicart's further answers.

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Vit:drcu request; new previded.

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' lit';dren request; Applicant says it uill provide by ?.ugust 14 430 Reques t rencirs.

3uppler.ertal arsuers doesr't specify ul.ere in the co-trol recr the procedures are kept ar? does ret address bou m' operator cairs access to all of the procedures (not nerel; ec.er ;ency ).

ef 7 3cquest renairs; Irterverer has reviewed the operatirg locs ard visitors 59, lor, which provide or.% a part of the infernation requestad. Fcr exanple,

1. C-3 these logs do rot irdicate uhat, if any, screeninc was 'cne prior to permittirc the visitors to operate the centrcls, their age, educatioral M ckgrourd, tour leader : ane. whether specific ' lor J ssion CK was given, ror whether ecademic credit in a cuclear encireerirc course was received tv the visitors for the visit. As these Inttars were addressed with recards the Culver City Eich 3chool visit, it is likel:' that irformation other thar that i operatirc Icc or visitors log is available. Furtherncre, sirce UCIA Staff led and supposedly supervised these visits, perscral krculedge beyord that ir docunents is !.ost likely.

A2a-3equest renairs; argunert abcVe holds; locs cannet tell us about d supervision durirg withdrawal of cadniun sanple, rcr whether nuc'. ear ergineerirc course credit received.

63a 3ane a$gunents as above; nust be persoral krouledge as to gereral patterr of visitors. Request rerairs.

Co-tertica 17

• ?ithdraw request; row supplemented.

Ca 13a-c !!ithdrau request; 3esponse to i:otion says Applicant's' 3taff car't retenber any of the details requested about those violations.

Ica-e '.fithdraw request.

17 Applicant clains 17a 3taff carrot l'

renenber any details.

(Interveror "ctes that it will raise corcern if nenorr of Applicant's staff apnears r.t hearing to have vastly inpr6ved. )

Applicant states (Respense, p.14):

"Alti.ough applicart's current s aff recall, gererally, that such events occurred ecd Lut, on occasien, rotices of violation were issued. by the :~3C, nore of the curront staff krous with ary particularity the details of these cecarrencer,"

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Request renairs. Staffpersors at UCLA's reacter now were, at 1.;ast none, on staff nany years prior to the 197 5 neno.

Lsrtainly sone staffpersor nust have sone persora3 knowledge that can shed light en hcu long over the discharce linits enissions had gens prior to detection.

24a Pequast retains. Althouch Applicant again irdicates nore of its staff lus k culedge of what regative experience the Ccwaission irspectors "ad had with lack of disciplired naracenent at the facility previous to the 1974 AEC nero, because several of Applicant's staff uere at UCLA for nany years previous, Tntervencr firds it Sard to telieve rene have any idea uhat that neto refers to.

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iv Cn, ter t4 cr 7 13-Request for further arsuers renains. As to 13-13: Intervercr 1"

is of course referrirc to the reactivity ucrth of sanples at UCll's particular reactor.

It is that reactor which is up for relicensi g.

Ard of course Irterverer was referri; g to Applicart's rabbits and rot to ratbits used at other facilities. Again, it is this facilit; that a sanple ra" "'it" irto a rd. tit (as our questior asks,clains about uhich the questiens are addrersed. Lastly, Applicart j tut still rot to able to te irserted irto the reactor because it is too Peavy to te lif ted by the pneuratic tube systen. That is irteresting irforra:.icn. which should have been included ir the answer, but the questica, still not addressed, goes to sice linitations, not weight.

7e still reed to knou whether size linitations prevent a sanple worth 2.3 at this reactor fitti. c ir to a rabbit used at this reactor.

As to 16-16: To irfornaticr whatscever is civen to the questicrs as to physical linitations to insertier of aanples of varicus reactivity worths fat this facility) into irradiatier ports.

To krcu whetber ar excess reactivity insertior is credible one reeds to knou whether objects of sigrificant erouch reactivity ucrth can physically be placed inside the reactor. The Applicart evades the questi en, a-d the requested inf ornation is reeded for an adecuate addressirg of this cortention.

44 Uithdrau request. Applicant seens to say that that is the extent of Frefessor Catter's knowledge of the natter and the basis for his rerarks in question.

Cn-+ er'ior 7I c

Eequest ncdified. Applicant in supplenented answer refers completely O

to 1978 Arrual Report as the basis fer its cerclusicrs r carding the TLD pro?ran.

In its previous answer it stated it was currently attenptire to corduct reasurenents to assess that interpretation.

Intervenor requests: 1) that Applicant either state explicit 1, it has ro other inferration on uhich it based its staterent that the TLD readings were pickirg up radiation frcn the cercr te other than the referred-to 1979 Annual Report, en provide all other infernation it has; ard 2) that Applicant be directed to supplenen t its arsuer uher inforration (conplete er not) tecones available ; n its effort to deternire 'e. ether radiation fron the cercrete was affectirg the TLD raadirgs.

KI EST CF T:-2 I"~ERECGATCRII3 FC1 Cu.:.m0:' VI hsyc i ter either supplemented, or the requested infornatior is contaired in Applicant's Response to C:G's notion to conpel; thus requests uithdraun.

Conter'ict 7II f.o,7 3equest withdraur; partial ansuer provided in Applicant's " Response" 9c 3equest withdraunt supplenented.

v Cn-ter tiv 7:IT fn Request witPdraun; supplenented in supplenental arswer to 7d 76 Request uitifiraun; supplenented.

7e-h Hequest re ains. It renairs cifficult for In_tbevancr ;o.bblieve that m o inforraticr to provit'e W uhich to corpnre ler;? recessary Applicas of tire at current power to reach the irvertor; assuned in its Application at 1/10'1 its present po ar.

If Applicant, however, doesn't have relevant infornation, it should sinply sa" so clearly.

11-2 2equest withdraun; Applicant states in 2esponse its 3taff 1.as to inferration as to how the assunptions in queszior were arrived at.

Ih Pequest withdrawn; Applicart states it will supplanent by August 14 I',a-b 3equest renains. Applicant in its responso indicates part of the inferration car 'm foura in the 2attelle study. That study provides ore estinate of c.1xinun inver.tcrJ for several isotopes each of iodine, kr"ptor, ard neron as to one fuel eletent, with calmlation possible therefron for irventory of these three elenents in the whole core.

The 2attelle study does ret provide a figure for naxinun total invic; cry (i.e. of all fissim. products / nor does it provide figures for any isotope other than those of krypten, xencn, and iodine.

In addition, the study cane cut af ter the irterrogatories were answered, whereas the reacscr has operated for tuenty years previously.

If 1pplicant has no irfernatien other than that which is included f.r the Cattelle study, it should so s tate. If it has other inferration, it should provide said infernation.

Furthernore, ir referr! g tc the 2atte11e study, Applicant bas not stated whether it agrees with the estina+es therein; it should so state, and if it disagrees, provide its cun figures.

The question is a central or.e in detertiring corsequences fron accidert. Cae needs _to 'treu bcu nuch total, vi %u nuch of individuel fission products are pcssible to be ir the reactor in crder to calculate.hcu nuch could get out and whht the corsecuences would be of that kird of release.

If.pplicant Sas no infornation as to naxir..un l

possible irvertocy, it should so ctate explicitly; ctherwise it should j

provide uhat it has.

19b,c The argunerts above for 19,a-h apply equally here. The fact of power fluctuations is irrelevant tc a corservative estirate of n1xinun fission product invertory.

Interveno uell understands the differerce l

in operating sc..edule of a pouer and a research reacter. That is, l

in part, uhr it asked tb questions about naximun irver. tory for this reactor. Request renains, t

20 Eequest reral s.

qucatier asks for ircis o' leak rate estinates.

If they don't krcu how the assunption was arrived at, that is sufficiert arsuer, but should be so stated explicit 1;..

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ne Arswers which Applicant has not - at supplenented, rcr did it state in its Au. ust 3 letter tl'at the arsuers would be forthconirc:

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UNITED STATES CF A!GRICA NUCLEAR REGUIATORY CCMhISSICN 3EFCRE "'ME ATCMIC SAFETY AND LICE!3I"C 30ARD In the ratter of Docket No. 50-142 THE RECH*"'S OF THE UNIVERSITY CF CALIFCRNIA (Proposed Renewal of Facility License)

(UCLA Research Reactor)

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L'ECLARATICN CF SERVICE I hereby +1eclare that copies of '"JDA~lJ ::CIC" TC CC::22. A3 ':C 2"3 lI T72301A"C2I:3. A2 m. ;uca C2~23 C7.'rZ 15,19P1; AFD E 4~l3 313CC'!EEI

'A T O.3" the above-capticred proceedi~c have beer served ar. the felicuir.6

'.r depcsit ic t'te "nited 3tates rail, first c' ass, this 10th day cf Aue_ust, 19 1 :

Elizabeth S. Bowers, Esq., Chairman Christine Helwick, Esq.

Administrative Judge Glenn R. Woods Esq.

Atomic Safety and Licensing 3oard Office of Geneal Counsel U.S. Nuclear Regulatory Commission 590 University Hall Washin6 ton. D.C. 20555 2200 University Avenus 3erkeley, CA 94720 Dr. Emmeth A. Luetke Administrative Judge Counsel for NRC Staff Atomic Safety and Licensing Board U.S. Nuclear Regulatory Cot: mission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Yashingtcm, D.C. 20555 Docketing and Service Section (3)

h. Oscar H. Paris Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Commission Atomic SMety ard Licensing 2 nard Washington, D.C. 20555 U.S.' Nuclear Regulatory Commission Washington, D.C. 20555 l

William H. Cornier, Esq.

Office of Administrative Vice i

Chancellor i

University of California 405 Hilgard Ave.-

Los Angeles, CA 90024 Y24Leb Ac/ d k Wendy ScJdelker l-I

-.