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Category:INTERVENTION PETITIONS
MONTHYEARML20108A9601984-11-13013 November 1984 Answer Opposing Committee to Bridge the Gap 841024 Petition for Hearing & Leave to Intervene.Petition Fails to Satisfy Requirements & No Good Cause Exists for Deferment of Ruling on Petition.Certificate of Svc Encl ML20094A4741984-10-24024 October 1984 Petition of Committee to Bridge the Gap for Leave to Intervene & Request for Hearing Re Proposed Issuance of Orders Authorizing Disposition of Component Parts & Termination of License R-71.Certificate of Svc Encl ML20083G1821984-01-0606 January 1984 Memorandum Clarifying Paragraphs 1,2 & 3 of Contention Xx Re Compliance w/10CFR73.40 & 10CFR73.67.Certificate of Svc Encl ML20072T5631983-04-0101 April 1983 Response Opposing Committee to Bridge the Gap Request for Expedited Ruling on Contention Xiii.Ucla Has Not Been Given Opportunity to Respond Fully to Gap Motion for Summary Disposition.Certificate of Svc Encl ML20065C2941982-09-20020 September 1982 Addl Bases to Be Added to Contention Xxi on Emergency Plan ML20058B9061982-07-22022 July 1982 Response to Committee to Bridge the Gap 820712 Proposed Mods to Contentions.Listed Mods Unrelated to Application Should Be Rejected.Certificate of Svc Encl ML20055A4081982-07-12012 July 1982 Mods to Contention Due to UCLA Recently Submitted Amends to Application ML19338D3581980-09-0909 September 1980 Response in Opposition to Committee to Bridge the Gap Supplemental Petition to Intervene.Discusses Irrelevancy & Lack of Merits of Contentions & Expresses Desire to Explain & Elaborate Concerns at Prehearing Conference ML19331D9061980-08-25025 August 1980 Supplemental Contentions to 800522 Petition to Intervene. Alleges Omission of Essential Info by Applicant Re Severe Reactor Damage & Lack of Spare Parts.Supporting Documentation & Certificate of Svc Encl ML19320B0551980-07-0303 July 1980 Response to Committee to Bridge the Gap June 1980 Petition to Intervene.Petitioner Relied on Case Law Not Wholly Applicable to Instant Action.Allegations Re Aspects Are Not Specified W/Clarity & Detail.W/Certificate of Svc 1984-11-13
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20108A9601984-11-13013 November 1984 Answer Opposing Committee to Bridge the Gap 841024 Petition for Hearing & Leave to Intervene.Petition Fails to Satisfy Requirements & No Good Cause Exists for Deferment of Ruling on Petition.Certificate of Svc Encl ML20094A4741984-10-24024 October 1984 Petition of Committee to Bridge the Gap for Leave to Intervene & Request for Hearing Re Proposed Issuance of Orders Authorizing Disposition of Component Parts & Termination of License R-71.Certificate of Svc Encl ML20083G1821984-01-0606 January 1984 Memorandum Clarifying Paragraphs 1,2 & 3 of Contention Xx Re Compliance w/10CFR73.40 & 10CFR73.67.Certificate of Svc Encl ML20072T5631983-04-0101 April 1983 Response Opposing Committee to Bridge the Gap Request for Expedited Ruling on Contention Xiii.Ucla Has Not Been Given Opportunity to Respond Fully to Gap Motion for Summary Disposition.Certificate of Svc Encl ML20065C2941982-09-20020 September 1982 Addl Bases to Be Added to Contention Xxi on Emergency Plan ML20058B9061982-07-22022 July 1982 Response to Committee to Bridge the Gap 820712 Proposed Mods to Contentions.Listed Mods Unrelated to Application Should Be Rejected.Certificate of Svc Encl ML20055A4081982-07-12012 July 1982 Mods to Contention Due to UCLA Recently Submitted Amends to Application ML19338D3581980-09-0909 September 1980 Response in Opposition to Committee to Bridge the Gap Supplemental Petition to Intervene.Discusses Irrelevancy & Lack of Merits of Contentions & Expresses Desire to Explain & Elaborate Concerns at Prehearing Conference ML19331D9061980-08-25025 August 1980 Supplemental Contentions to 800522 Petition to Intervene. Alleges Omission of Essential Info by Applicant Re Severe Reactor Damage & Lack of Spare Parts.Supporting Documentation & Certificate of Svc Encl ML19320B0551980-07-0303 July 1980 Response to Committee to Bridge the Gap June 1980 Petition to Intervene.Petitioner Relied on Case Law Not Wholly Applicable to Instant Action.Allegations Re Aspects Are Not Specified W/Clarity & Detail.W/Certificate of Svc 1984-11-13
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20247Q7371989-07-28028 July 1989 Order Authorizing Dismantling of Facility & Disposition of Component Parts ML20211Q3021986-07-14014 July 1986 Order Authorizing Dismantling of Facility & Disposition of Components in Accordance W/Phase I of Dismantling Plan & NRC Rules & Regulations,Per 851029 Application ML20205G6071985-11-0808 November 1985 Order Terminating Proceeding Since Committee to Bridge the Gap Withdrew Petition for Leave to Intervene.No Other Petitions Remain.Served on 851112 ML20205G6551985-11-0808 November 1985 Memorandum & Order Approving Parties 851010 Stipulation to Dismantle & Dispose of All Reactor Components & Equipment Except for Biological Shield & Components Described in Stipulation.Served on 851112 ML20133Q2781985-10-30030 October 1985 Response to ASLB 851016 Memorandum & Order Re Settlement Agreement & Proposed Order on Matters in Dispute Concerning Proposed License Renewal & Dismantlement Proceedings. Paragraph 6 of Proposed Order Should Be Revised ML20133Q2941985-10-30030 October 1985 Affidavit of Dj Kasun Re Question 3 in ASLB 851016 Memorandum & Order Concerning Effect of Release of UCLA Security Plan to Public on Security of Other Nonpower Reactors W/Similar Plans.Certificate of Svc Encl ML20133J0691985-10-16016 October 1985 Memorandum & Order Requesting Parties to Respond by 851030 to Listed Questions Re 851010 Settlement Agreement & Proposed Order Terminating Proceeding.Served on 851017 ML20108A9601984-11-13013 November 1984 Answer Opposing Committee to Bridge the Gap 841024 Petition for Hearing & Leave to Intervene.Petition Fails to Satisfy Requirements & No Good Cause Exists for Deferment of Ruling on Petition.Certificate of Svc Encl ML20094A4741984-10-24024 October 1984 Petition of Committee to Bridge the Gap for Leave to Intervene & Request for Hearing Re Proposed Issuance of Orders Authorizing Disposition of Component Parts & Termination of License R-71.Certificate of Svc Encl ML20097A1271984-09-0707 September 1984 Response to ASLB 840806 Order Part B.Prompt Shipment of SNM, Removal of Metallic Core Components & Prompt Dissolution of Protective Order Required by Order,Regulations & Public Policy.Declaration of Svc Encl ML20097A0181984-09-0707 September 1984 Reply to Committee to Bridge the Gap 840801 Response Re Request to Withdraw Application.Aslb Should Approve Withdrawal of Application & Terminate Adjudicatory Proceedings.Certificate of Svc Encl ML20096G8791984-09-0707 September 1984 Response to ASLB 840806 Order Re Other Parties Responses to UCLA Motion for Withdrawal of Renewal Application. Clarification of Ambiguities in Proposals Progressing.W/Svc List ML20094C1371984-08-0101 August 1984 Response Opposing Staff Proposed Conditions for UCLA Withdrawal of License Renewal Application.Aslb Should Follow Required Practice Consistent W/Nrc Case Law.Certificate of Svc Encl ML20093H9281984-07-20020 July 1984 Reply Opposing Committee to Bridge the Gap (Cbg) 840703 Response to Univ Request to Withdraw Application.Cbg Not Established as Participant in License Termination Proceeding.Certificate of Svc Encl ML20093G1541984-07-20020 July 1984 Withdrawal of 840622 Emergency Petition for off-shipment of Reactor Fuel Prior to Arrival of Olympic Athletes.Petition Moot.Declaration of Svc Encl ML20090C7851984-07-11011 July 1984 Response Opposing Committee to Bridge the Gap 840622 Petition for Commission Order to Remove SNM Prior to Olympics.Motion Lacks Factual Basis & Does Not Conform to Procedure.Certificate of Svc Encl ML20092P2431984-07-0303 July 1984 Response Supporting Univ 840614 Request to Withdraw Application for License Renewal.Proposed ASLB Order Accepting Withdrawal Request Encl.W/Certificate of Svc ML20151J9891984-06-25025 June 1984 Memorandum Explaining Reason Underlying 840622 Telegraphic Memorandum & Order Suspending All Further Proceeding. Licensee Has Shown No Desire to Retain Fuel Longer than Necessary.Served on 840626 ML20092G2821984-06-22022 June 1984 Emergency Petition for off-shipment of SNM from Site Before Olympics,Due to Withdrawal of Renewal Application & Security Risk Associated W/Olympics.Declaration of Svc Encl ML20140C6651984-06-18018 June 1984 Order Canceling Contention Xx Evidentiary Hearings Due to Licensee 840614 Request to Withdraw License Renewal Application & to Decommission Reactor.Served on 840619 ML20197H3831984-06-14014 June 1984 Request to Withdraw License Renewal Application on Condition That Application Be Made to Decommission ML20197H4051984-06-14014 June 1984 Motion to Suspend Proceedings Pending ASLB Action on Request to Withdraw Application.Hearing on Security Contention Should Be Canceled Immediately to Avoid Unnecessary Expense.Certificate of Svc Encl ML20197G7651984-06-11011 June 1984 Motion to Compel Further Written Response of B Ramberg or for Alternative Relief & Costs.Committee to Bridge the Gap Has Not Revealed Documents Per Interrogatory Requests. W/Certificate of Svc.Related Correspondence ML20091Q6071984-06-11011 June 1984 Objection to ASLB 840606 Notice of Evidentiary Hearing Specifying That Portions of Contention Xx Evidentiary Hearing Will Be Closed to Public.Only Portions Dealing W/Protected Info Should Be Closed.Certificate of Svc Encl ML20091M8351984-06-0707 June 1984 Motion to Compel Committee to Bridge the Gap to Provide Further Written Answers to Questions 6 & 7 of Univ 840525 Interrogatories Re Security Contentions.Certificate of Svc Encl.Related Correspondence ML20091G8411984-05-30030 May 1984 Notice of T Taylor & D Hafemeister Depositions on 840604 & 05,respectively.Certificate of Svc Encl.Related Correspondence ML20091B3371984-05-25025 May 1984 Interrogatories Re Security Contention.Certificate of Svc Encl.Related Correspondence ML20090J6721984-05-0909 May 1984 Response to Applicant Request for Reversal of ASLB 840413 Finding of Matl False Statements.Requests Hearing in Which Questions Unanswered by Two UCLA Responses Can Be Thoroughly Explored.Declaration of Svc Encl ML20084H1991984-05-0404 May 1984 Notice of Disposition of Plotkin & Gt Cornwall on 840510 Re Physical Security & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20084F7061984-05-0101 May 1984 Estimate of Level of Threat Facing UCLA Reactor in Response to ASLB 840420 pre-hearing Conference Order.Facility Attractive Theft & Sabotage Target.Certificate of Svc Encl ML20084F1971984-05-0101 May 1984 Declaration of Wh Cormier in Response to ASLB 840413 Memorandum & Order Re Questions About Apparent Misrepresentations Made by Univ & NRC ML20084F1641984-05-0101 May 1984 Response to ASLB 840413 Order Directing Univ to Indicate Whether Any Representatives Had Reviewed Cormier 830825 Statements.No Representative of Regents Reviewed Statements Before or After Submittal ML20084F1881984-04-27027 April 1984 Declaration of Nc Ostrander Re Review of Cormier 830825 Statements.No Member of Staff Requested to Review Documents Before or After Submittal ML20084E7271984-04-27027 April 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20084D0711984-04-25025 April 1984 Motion for Reconsideration & Clarification of Portions of ASLB 840420 Prehearing Conference Order Re Contention Xx. Certificate of Svc Encl ML20084C4001984-04-24024 April 1984 Reply Opposing Applicant Motion for Reconsideration of ASLB 840322 Order & Further Suppl to Rebuttal.Source Term Issue Under Investigation Should Not Be Litigated in Individual License Proceeding ML20084C4151984-04-23023 April 1984 Response to Committee to Bridge the Gap (Cbg) 840406 Motions for Reconsideration of ASLB 840322 Memorandum & Order Ruling on Cbg Objections to Rebuttal Testimony.Motions Should Be Denied.Certificate of Svc Encl ML20088A0551984-04-0606 April 1984 Motion to Reconsider Portions of ASLB 840322 Memorandum & Order,Overruling Objections to Untimely Filed Rebuttal Testimony.Aslb Has Placed Interest in Complete Record Above Statutory Interests of Proceedings.W/Certificate of Svc ML20088A1611984-04-0606 April 1984 Motion for Reconsideration of Certain Portions of ASLB 840322 Order.Only Penalty for Violation of ASLB Orders Is Further Delay & Continued License Possession,Precisely What Licensee Desires.Declaration of Svc Encl ML20088A2011984-04-0606 April 1984 Response to Applicant 840330 Rept Re Reactor Shutdown, Repair & Testing Schedule.Certificate of Svc Encl ML20088A6911984-04-0606 April 1984 Petition Per Reconsideration of ASLB Order Ruling on Committee to Bridge the Gap Objections to Rebuttal Testimony.Certificate of Svc Encl ML20087D7111984-03-0909 March 1984 Response to ASLB 840224 Order Indicating Concerns on Security Plan & Security Insp Repts Re Sabotage Matters Raised by Contention Xx & Directing Univ & Staff to Respond by 840309.Certificate of Svc Encl ML20235Z3661984-03-0606 March 1984 Affidavit of MD Schuster in Response to Question Raised by Aslp in UCLA Proceeding in Aslp 840224 Order Re Physical Security Insp Repts to UCLA & Every Licensee Inspected ML20080N2431984-02-16016 February 1984 Motion Denying Committee to Bridge the Gap 740109 Motion for Reactor Curtailment.No Factual or Legal Basis Exists to Support Extreme Remedy Sought.W/Certificate of Svc ML20080B7491984-02-0101 February 1984 Response Objecting to Applicant/Nrc Proposed Witnesses & Proposed Mod to Protected Order.Witnesses Do Not Qualify as Experts.Declaration of Svc Encl ML20080B6871984-01-31031 January 1984 Response Objecting to Release of Certain Protected Info. Proposed Sanitized Portions of Security Plan Should Be Released Only to Qualified Witnesses.Certificate of Svc Encl ML20079H8501984-01-20020 January 1984 Reply Opposing Applicant 840117 Request for 24-day Extension to Respond to Committee to Bridge the Gap 840109 Motion for Curtailment.Reasonable Extension Not Opposed.Certificate of Svc Encl ML20079H4011984-01-17017 January 1984 Application for Extension of Time Until 840216 to Respond to Committee to Bridge the Gap 840109 Motion for Curtailment III (Irreparable Injury Associated W/Any Further Delay). Extension Will Not Delay Matters.W/Certificate of Svc ML20079H3751984-01-17017 January 1984 Response to Committee to Bridge the Gap Memorandum Clarifying Contention Xx,Paragraphs 1,2 & 3.Committee Should Be Made to Respond to NRC Motion Re 10CFR73.67. Certificate of Svc Encl ML20079J1881984-01-16016 January 1984 Review of UCLA Analysis of Facility Shutdown Mechanism. Postulated Power Excursion Will Not self-terminate as Assumed by Expulsion of Water Out Top of Fuel Box Region Through Surrounding Brick Walls 1989-07-28
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{Y* 9 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD PANEL In Re: ) Docket No. 50-142
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THE REGENTS OF THE UNIVERSITY ) (Proposed Renewal of CALIFORNIA ) Facility License (UCLA Research Reactor) ) Number R-71)
UNIVERSITY'S RESPONSE TO PETITION TO INTERVENE OF THE COMMITTEE TO BRIDGE THE GAP DONALD L. REIDHAAR GLENN R. WOODS CHRISTINE HELWICK 590 University Hall 2200 University Avenue Berkeley, California 94720 Telephone: (415) 642-2822 Attorneys for THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 800709087 4
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12' 13-14 ' UNIVERSITY'S RESPONSE TO PETITION TO INTERVENE OF THE COMMITTEE'TO BRIDGE THE GAP 15 16 17 18 19-20 DONALD L. REIDHAAR 21' GLENN'R. UOODS CHRISTINE HELWICK 22 590 University Hall 2200' University Avenue 23 Berkeley, California 94720 Telephone: (415) 642-2822 24 Attorneys for THE REGENTS OF THE
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.' A . , Intervention In NRC Licensing l ., 7 ' Proceedings ~ . . - 2 8- ; B '. Standing of Petitioner . . . '3 9 'C. Relevant Aspects . . . . 4 10 III. ' CONCLUSION . . . . . . 6 11-1
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4: '10 Code'of. Federal Regulations Section 2.701(b).
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110 - 'THE REGENTS OF: THE -UNIVERSITY ) (Proposed Renewal of CALIFORNIA _..
_ _) Facility' License 11 -(UCLA ResearchnReactor) '
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.x 13 UNIVERSITY'S RESPONSE TOL PETITION TO INTERVENE-OF THE COMMITTEEzTO BRIDGE Tile GAP 14-15 16 I.- INTRODUCTION'
, ~17 18 On June 6, 1980, a copy of a Petition-for Leave to b
- 19 Intervene: 'in ' this proceedin', g apparently (filed. by The -
- 20. . Committee . to Bridge the ' Gap, was received'from:the Nuclear -
E21 . Regulatory. Commission on - the Los Angeles ~ campus of the 22? University?of California. Because of certaih-defects in the
'232 is'ervice- of L that Petition upon The Regents-of the University-off. California (hereinafter " University").(see-10 C.F.R.: S
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. ,--2.'701(b)),_-and in:orderjthat the University:have an. adequate 26 3
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I time to evaluate the .11egations of the Petition, the 2 University applied for an extension of time to July 8, 1980, 3 to answer the Petition for Leave to Intervene. This 4 applic.ation . for an extension of time was approved by 5 Elizabeth S.' Bowers, Chairman of the Atomic Safety and 6, Licensinh Board in an order dated June 18, 1980.
'7 8 Pursuant to that order, the University now submits 9 'its respon'se to the' Petition to Intervene.
10 11 II. DISCUSSION 12 A. Intervention In NRC Licensing 13 Proceedings 14 According to the provisions of 10 Code of Federal 15 Regulations section 2.714, any person whose interest may be affected by a proceeding and who desires to participate as a party in a NRC licensing proceeding shall file a written petition for leave to intervene. The petition must set forth with particularity the interest of the petitioner in l the proceeding, how that interest may be affected by the results of the proceeding, and the special aspect or aspects of the subject. matter of the proceeding as to which petitioner wishes to intervene. (10 C.F.R. S 2. 714 ( a) . )
. 25 26 2
In determining whether a petitioner should be 1
2 admitted as a ~ party to an NRC proceeding, the Commission 3 applies contemporaneous judicial concepts of standing, which 4 require the ' petitioner to demonstrate that the proposed
~5 licensing action could result in " injury-in-fact" to an
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.6' 'Jinterest " arguably with$n^the zone of interest" protected by 7 the statute.
8 to. establishing its right to 9 In addition 10 intervene, petitioner must identify, with specificity, those 11 " aspects" of the proceeding as to which intervention is 12 sought.
13 14 B. Standing of Petitioner 15 16 The NRC Staff response to the Petition to Intervene has thoroughly briefed the standing issue. The 17 18 University does not contest any of the authority cited by 19 the NRC staff, but notes that both petitioner and the NRC 20 Staff have relied on a series of power reactor case holdings 21 which are not wholly applicabia to the instant action 22 involving the application for license renewal of a 23 research reactor.
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.3' . Petitioner has~ set.forth a number of allegations
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' Wh,'ilei the" Uni'versity["ssbmits ~.,
that these allegations are not 6 supported by-the' facts, a straightforward reading of 10 Code
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-of Federal , Regulations ~ section 2.714 suggests ithat the .
'8 University's'p_oint-by-point' refutation of these " contentions" l
9c at this time would not constitute an-appropriate response.
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--10 Instead, -the University Junderstands that - such should 11 properly be the = subject; of ~ a later stage of the proceeding.
12: lIndeed, as-the NRC. Staff l response indicates, the statute and 13 ' the case law provides little guidance on the distinction.
14 - .that ~ is - to be'. observed between . the terms " aspect" and 15
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^" contention" as' the terms- are used ~.in 10 Code of Federal 16 Regulations section'2.714.
~17 y -18f Moreover, .w hether petitioner's allegations are 19 properly termed " aspects" or " contentions," they-have not~
f- 20 been made in all' respects 'with the degree of clarity and-21'
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detail that should-reasonably be required in order for~the 22 = University tot enter . an . informed and precise response. .
- 23' 24- Nevertheless, 10 Code of Federal Regulations
- 25 =
...- section-'2.714Ldoes notJ specify the manner or time in -which 1 '
26' th'e 1 University will be -permitted to respond in writing ' to
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/v n 2 ' object! ; atithis, time. to - the- - scope of the investigation
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3~ suggested bys petitioner an~d ._ requests that the Atomic Safety ;
- e.s 4 Licensi'ng<,-- Board' issue ~ at j the ' proper time an appropriate-
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y .e 5 : protective, order restricting inappropriate, irrelevant, 1 6 duplicative, , or . repetitive evidence or ~ argument, and o Ji- '
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7- lotherwis'e limiting and controlling the scope of any hearing ,
8 in this matter.. " The ' University requests that~ it be 9 permitted _at some later time to make specific recom- l i
- 10 mendations as' to -the language of - any such order.
11
[12. In particular, the University notes that all of 13 petitioner's claims herein were already raised in a recent 14 attempts by 'it to shut down the UCLA researchl reactor in the
'15 Fall' of 1979'. - At that time, the Regional Director of the
' 16 Commission 's . ' Division of Reactor Operations ~ Inspections -
conducted L a - thorough investigat' ion of petitioner's claims
~
17 l
18 and -found ' noysubstantive ' basis for the issuance of an order ~l 19~
to shut down'the--reactor. Extensive factual information has
- 29 already.been! developed in the' various reports and findings 21 '
'of'the Commissionlon the'UCLA research reactor.at that time, 22 - and at the very 'least 'that factual'information ought,to?be 23 . conclusive with+regardfto:the petitioner's attempt to raise 24' the' same issues in this proceeding. The University submits i .
25- : thats;the; findings of that earlier investigation should also 26 bei relevant . a'nd .~ admissible .in : any . hearing on this matter. -
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, conclusion that' _th'ere .Lis'~ no? nexus J between -those matters
.3 Lalleged . in athe ' petit'i'on,1whicho reach.back'into the distant
.past, and.the proposed renewal of the facility license. The
'5- '. University submits that in addition'to it em (2) summarized
- 6. in - the" Staff . Response - ( Petition, . pp. 3-4, at least a.part 7 of item-(4)f(Petition,~pp. 5-6) falls within.this category 8 and'thus has'no place in'this proceeding. Certainly=neither 9 evidenceinor' claims 'as to ' reactor performance prior 'to 't-he
-- $ 0 ~- istablishmenti by -the Commission in- 1976 (in amendment 10 to
, 11- . thef 'licens$)) o'fl the maximum permissible concentration
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12 standard; :should be permitted in any hearing .on this
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, 15 III. CONCLUSION 16 .
17 -Thef University . understands the permissible' scope l
.18- of.its response to ;. thelPetition to Intervene to be limited- j 19' at : this . stage. ' The University, however, reserves and
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-20 requests 1. the. ' opportunity to make a more - specific > .and _
s 21 l detailed written ; response, to petitioner's claims at a- later
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, .22 time, fshould the: petition bel .grante'd.
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.In .that event, the Universityn will ' also look to
--.. 25 : the, Commis'sion properly to limit and control L any hearing in 26- ~ this matter,- and' requests- an - opportunity to participate , in m x 6
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1 that process. In that regard, the University now questions 2 and objects to petitioner's reasons for requesting that any 3 hearing in this matter take place on the UCLA campus and 4 during the school year. Without. doubt such would create 5 complex security problems for the campus, which would not be 6 present in nearby federal facilities. In addition, it is 7 submitted that locating the hearings on the UCLA campus 8 would unavoidably disrupt ordinary campus life and would 9 afford no particular counterbalancing advantage to either 10 the Board or to petitioner.
11 Dated: July 3, 1980 DONALD L. REIDHAAR 13 GLENN R. UOODS CHRISTINE HELWICK 14 By 16 "
Christine Helwick Attorneys for THE REGENTS OF 17 THE UNIVERSITY OF CALIFORNIA 18 19 20 21 22^ >
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7
Q l DECLARATION OF SERVICE BY MAIL (CODE CIV. PROC. SS1013a S 2015.5)
- 2 I, the undersigned, say: I am a citizen of the United States, 3 over 18 years of age, employed in Alameda County, California, in 4 which county the within-mentioned mailing occurred, and not a party 5 to the subject cause. My business address is 590 University Hall, 6 2200 University Avenue, Berkeley, California 94720. I served the 7 attached: UNIVERSITY'S RESPONSE TO PETITION TO INTERVENE 8 _
OF THE COMMITTEE TO BRIDGE THE GAP 9
10 11 by placing a copy thereof in a separate envelope for each addressee
- named hereafter, addressed to each such addressee respectively as 12 13 follows:
14 15 SEE ATTACHED 16 17 18 Each envelope was then sealed and with the postage thereon fully 19 prepaid deposited in the United States mail by me at Berkeley, 20 California, on July 3, 1980 .
l 21 There is delivery service by U.S. mail at each place so 22 addressed or regular communication by U.S. mail between the place 23 of mailing and each place so addressed.
24 I declare under penalty of perjury that the foregoing is true 25 and correct.
26 Executed on July 3, 1980 at Berkeley, California.
o l ?) ; Y JYvonne Costalupes /
1 Elizabeth Bowers, Esq.
U.S. Nuclear Regulatory Commission 2 Atomic Safety & Licensing Board Washington, DC 20555 3
Dr. Emmeth A. Luebke 4 U.S. Nuclear Regulatory Commission Atomic _ Safety & Licensing Board 5 Washington, DC 20555 6 Dr. Oscar II. Paris U.S. Nuclear Regulatory Commission 7 Atomic Safety & Licensing Board Washington, DC 20555 8
Counsel for NRC Staff 9 Of fice of the Executive Legal Director U.S. Nuclear Regulatory Commission 10 Washington, DC 20555 11 Mr. Jim Miller U.S. Nuclear Regulatory Commission
. 12 Washington, DC 20555 13 Committee to Bridge the Gap 1637 Butler Avenue, #203 14 Los_ Angeles, CA 90025 15 Mr. John Bay 1633 Franklin Street 16 Santa Monica, CA 90404 17 Mr. D'On'Voelyke c/o University Religious Conference 18 900 'llilgard Avenue Los Angeles, CA.
90024 19 Chief ~-Docketing and Service Section 20 Office,of the Secretary U.S. Nuclear Regulatory Commission 21 Washington, DC 20555 22 Atomic Safety snd Licens~ing Appeal Panel U.'S.: Nuclear Regulatory" Commission 23 Washington, DC 20555 24 25 26 i
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