ML19345H064
| ML19345H064 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 04/20/1981 |
| From: | Helwick C, Reidhaar D, Woods G CALIFORNIA, UNIV. OF, LOS ANGELES, CA |
| To: | COMMITTEE TO BRIDGE THE GAP |
| References | |
| NUDOCS 8104300357 | |
| Download: ML19345H064 (39) | |
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" A g 5 y %gg UNITED STATES OF AMERICA 6- s'S / NUCLEAR REGULATORY COMMISSION 7
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 8 '.
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10 U,In the Matter of ) Docket No. 50-142
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) (Proposed Renewal of 11'!THE REGENTS OF THE UNIVERSITY Facility License
)
12, h0FCALIFORNIA ) Nunber E-71) i(UCLA Research Reactor) )
13
) April 20,1981 b
14-15 :
16 j APPLICANT'S FIRST SET OF INIERROGATORIES TO 17 INTERVENOR COMMITTEE TO BRIDGE THE GAP
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l l 18 19 PROPOUNDING PARTY: THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 20 l
RESPONDING PARTY: COMMITTEE T0' BRIDGE THE GAP..___ _ ~
21 l SET NUMBER: ONE 22 1
23 DONALD L. REIDHAAR -
24 GLENN R. WOOD .
CHRISTINF HELWICK 25 590 University Hall 2200 University Avenue 26 Berkeley, California 94720 g 27 Telephone: (415) 642-2822 pS O{k
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1 j Applicant, the Regents of the University of California requests 2 Intervenor Committee to Bridge the Gap to answer the following interrogatories 3 under oath within thirty days in accordance with 10 code of Federal 4 Regulations Section 2.740 and the schedule contained in the order issued March 5 20, 1981 by the Atomic Safety and Licensing Board in the instant action.
6.
7 l. In answering these interrogatories, you must furnish all information b
8 4 as is known or available to you regardless of whether this information is 9
hpossesseddirectlybyyou,yourofficersormembers,orbyagents, employee i
10 ' representatives, investigators, consultants, or the officers or members of 11 :other so-called " anti-nuclear" organizations on which you intend to rely in 12 any way, their agents, employees, representatives; investigators, or 13l consultants, or your attorneys. Your answers should be numbered corresponding l
14 to the number of the interrogatory and where an interrogatory has subparts 1
15 ; "(a)," "(b)," etc. , your answer should be comprised of the ssee subparts.
16 17 If any of these interrogatories cannot be answered in full, answer 18 to the extent possible, specifying the reasons for your inability to answer 19 the remainder, and stating whatever information, knowledge, opinion, or belief 20 you do have concerning the unanswered portion.
21 22 As used herein from time to time, "NEL" refers to the Nuclear Energy 23 Laboratories; " Contention I," " Contention II," etc., refers to specific 24 contentions (and, where indicated, their subparts) contained in the proposed 25 Stipulation of November 28, 1980, as amended by the order issued March 20, 26 1981 by the Atomic Safety and Licensing Boar ( in this action, which 27 amendment effectively integratts the three attachments to i:he Stipulation but 20 with the same numbering sequence as appears in the Stipulation; " Supplement"
9 I refers to intervenor's document Committee to Bridge the Cap's Supplemental 2 Conte 4tions to Petition for I, eave to Intervene on file in this action, which 3 Supplement will be referenced by applicant's numbering system that numbers all 4 pages of the Supplement consecutively from 1 to 137, page 1 being the page 5lvherethe" Introduction"begins.
6 ll As used herein, the terms " document or documents" refers to papers, 7 books, photographs, tapes, and all other tangible things on which any 8l; handwriting, typing, printing, photostatic copy, magnetic or electrical J
9 impulse, or other form of communication is recorded or reproduced, including, il 10" but not limited to, letters, notes, diaries, correspondence, contracts, II . agreements, files, records, reports, telegrams, bulletins, memoranda, orders, ,
12] invoices, brochures, maps, diagrams, agendas, minutes, studies, analyses, 13 manuals, transcriptions, pictures, photographs, and recordings, all notations i
14 ,on the foregoing, all summaries thereof, and all copies of the wxD een matter I
15
- described in the preceding paragraph by whomever prepared.
I 16 I7 As used herein, " identify the person (s)" means state with respect to I8 each such person, the person's full name and other names by which he or she 19 may be known; the person's present or last known residential address; the 20 p,,,,,,s present or last known residential telephone number; the person's 2l ' employer, job title, address of employment, and business telephone number at 22 tne present; the person's affiliation, if any, with any " anti-nuclear" 3 organization; the person's technical qualifications if the person is offered 4 as possessing technical knowledge; and the specific facts or knowledge for 25 which the person is being offered in support of your allegation (s).
26 27 As used herein, " identify the document (s)" means provide for each j 28 the names, present or last known address (business and residence) document, l
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1 and telephone number (business and residence) of the person who presently has 2 custody or control of the document and each copy thereof; the nature and 3 substance of the document with sufficient particularity to enable the sans to 4 be identified; the form of the document, that is shether the document is a 5 letter, telegram, memorandum, or other type of writing; the date of the 6 document; the date the document was executed or prepared if different from the 7 date it bears, or if it bears no date; the number of pages in the document; '
8 'the name, present or last known address (business and residence) and telephone 9 .
number (business and residence) of each person who draf ted it or participated 10 in its draf ting; the name, present or last known address (business and 11 residence) and telephone number (business and residence) of each person who 12 ! signed it or over whose name it was issued; the name, present or last known
! 13 , address (business and residence) and telephone number (business and residence) 14 of each person to whom it was addressed, or directed or sent. To the extent 15 :that a copy of the document (s) referred to in this interrogatory supplies the 16 information requested by this interrogatory, you may answer this interrogatory 17 by attaching a copy of the document to your answers to these interrogatories.
l 18 Please label the document to indicate the number (s) and subpart(s) of the 19 interrogatory it answers.
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21 INTERROGATORY NO. 1 (CONTENTION I):
22 Describe in detail "the minimum standards for such applications" as 23 this expression is used in contention I and explain the source of any such 24 " standards" including reference to applicable governmental regulations, 25 statutes or case law.
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j 1:INTERROCATORY NO. 2 (CONTENTION I):
6 2 i .
Do you contend that applicant's license renewal application must be 3 " original in all respects"? If yes, provide the following 4' information:
I 6'! (a) Explain what is meant by the expression " original in all 0
7 respects"as used in Contention I.2; 8 ,
9, (b) State the source of this requirement in the applicable I;
10 governmental regulations, statutes or case law.
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12 t INTERROGATORY NO 3 (CONTENTION I):
13 Describe in detail the basis of the allegation contained in i
14 ' contention I.1 by providing the following !aformation:
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16 (a) State the facts upon which you base your allegation; 17 18 (b) Identify the person (s) with knowledge of the facts which 19 support your allegation; and 20 21 (c) Identify the document (s) which support your allegation.
22 23 INTERROCATORY NO. 4 (CONTENTION I):
24 i Describe in detail the basis of the allegation appearing on page 4 25 of the Supplement that "the UCLA reactor failed the experimental vibration 26 tests" described in the C.B. Smith article by providing the following 27 information:
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(a) State the facts upon which you base your allegation; 3 l I
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(b) Identify the person (s) with knowledge of the facts which 3
- 4. support your allegation; and 5
I (c) Identify the document (s) and the specific language within said i
6 i-7 document (s) which support your allegation.
8' .
I l 9 ; INTERROGATORY NO. 5 (CONTENTION I):
I 10 Do you contend that the application as submitted failed to contain i
11 information required for such license renewal applications? If yes, specify I i -
12 j the information that was omitted and as to each such item of information 13 iomitted identify the source of the requirement that the information be p
14 pr ovided in the application.
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16 INTERROGATORY NO. 6 (CONTENTION I): ,
17 Do you contend that the applicant has not followed the instructions 18 of the NRC staff with respect to the information to be pr6vided in the license 19 renewal application? If yes, cite each instance of an instruction not 20 followed and as to each provide the following information:
21 22 (a) State the facts upon which you base your allegation; 23 24 (b) Identify the person (s) with knowledge of the facts which 25 support your allegation; and 26 27 (c) Identify the document (s) which support your allegation.
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- 1 lINTERROCATORY NO. 7 (CONTENTION I):
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Do you contend that the applicant has not responded'to NRC staff I
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requests for additional inforisation with respect to this license renewal 4 gapplication? If yes, cite each instance of a response not made and as to each f
5lprovidethefollowinginformation:
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7;; (a) State the facts upon which you base your allegation; l'
8' 9 (b) Identify the person (s) with knowledge of the facts which 10 ', support your allegation; and i
11 (c) Identify the document (s) which support your allegation.
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P 14'l INTERROGATORY NO. 8 (CONTENTION I):
i Do you contend that the application contains any materially false
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16 ' statements? If yes, specify each materially f alse statement and as to each 17 provide the following information: .
18 19 (a) State the facts upon which you base your allegation that the 20 statement is false and that the falsity is':saterial; 21 22 (b) Identify the person (s) with knowledge of the facts which 23 ' support your allegation that the statement is materially false; and 24 ;
25 (c) Identify the document (s) which support your allegation.
26 27 28 6
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- 1 fINTERROCATORY NO. 9 (CONTENTION I):
2 ,
Do you contend that in support of this license renewal application 3 applicant has made materially false statement (s) to the NRC staff other than 4.. any that you may have alleged appear in the application? If yes, specify each 5 l materially false statement and as to each provide the following information:
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7 (a) State the facts upon which you base your allegation that the 8 statement is false and that the falsity is material; i
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10 t (b) Identify the person (s) with knowledge of the facts which 1
11 ! support your allegation that the statement is materially false; sad 12 1,
13 (c) Identify the document (s) which support your allegation.
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- 15 INTERROGATORY NO. 10 (CONTENTION I)
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16 With respect to each of applicant's statements which appear as 17 Contentions I.3.a. b,c, and f, do you contend the statement is materially f
18 inaccurate? If you answer yes to any of the statements, ior each such 19 statement prcvide the following information:
20 21 (a) State the f acts upon which you base your allegation that the
! 21 statement is inaccurate and that the inaccuracy is material; l
23 24 (b) Identify the person (s) with knowledge of the facts which 25 support your allegation that the statement is materially inaccurate; 26 27 i (c) Identify the document (s) which support your allegation; and I
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(d) If you answered yes with respect to the statement appearing 2 j as Contention I.3.d in addition to the information to be provided above, 3 l identify,specifically,theallegedhydrologymapwhichappearsaspage23of 4 the Supplement by indicating in what document the map appears, the date of the 5 document, the maker of the document including the maker's educational 6 . experience and qualifications, the specific wells that are alleged to be on or li 7 ; within the vicinity of the campus, the depth of each such well, the date each 8.l such well was drilled, and whether each such well is currently functional or 1
9 inot.
I' 10 11 IhiERROCATORY NO.11 (COhiEhTION I):
12 With respect to contention I.3.f., do you contend that there are t
13 other suitable or more economical alternatives which can accomplish both the 1
14 educational and research objectives of the facility? If yes, specify each 15 such alternative, its cost and its economic advantage and provide the 16 following information:
17 18 (a) State the f acts upon which you base your silegation; 19 i 20 j (b) Identify the person (s) with knowledge of the facts which 21 support your allegation; and 22 23 (c) Identify the document (s) which support your allegation.
24 25 IhTERROCATORY No.12 (C0hTENTION I):
26 Do you contend that there are other " omissions, misleading 27 statements, inaccuracies and inadequacies contained in the Application" 28 l (Supplement, page 10) other than those which have been specified in Contention 8
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. j lI. If yes, cite each such omission, misleading statement, inaccuracy or i
2 j inadequacy by reference to the page of the application in which it appears and 1 .~
3 j as to each provide the following information:
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(a) State the facts upon which you base your allegation including 5
6 :' for any omissiou or inadequacy the source of the !
requirement in the applicable 7
I governmental regulations for the information omit'ted; l - 1 I
8d g (b) Identify the person (s) with knowledge of the facts which i
10 lsupportyourallegation;and i .
11 l 12' (c) Identify the document (s) which support your allegation.
13 ;
I. i 14 INTERROCATORY No. 13 (CONTENTION II):
a 15 Do you contend that applicant should have applied for a " class 103" l
16 licenze? If yes, provide the following information:
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17 18 (a) State the facts upon which you base your allegation; i
l 19 l I 20 ! (b) Identify the person (s) with knowledge of the facts which 21 support your allegation; and 22 23 (c) Identify the document (s) which support your allegation.
i i 24 25 INTERROCATORY NO. 14 (CONTENTION II):
26 Do you contend that the applicant devotes more than 50 percent of 27 the annual cost of owning and operating the facility to the sale of services, 28 9
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. 1 other than research and nevelopment or education or training? If yes, provide 2 the following information:
3 4 (a) State the f acts upon which you base your allegation including 5 your financial analysis and conclusions; I
6 7 (b) Identify the person (s) with knowledge of the facts which
! 8 . support your allegation; and I
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10 ' (c) Identify the document (s) which support your allegation.
11 12 INTERROGATORY No. IS (CONTENTION II):
13 If you rely on 10 CFR 50.22 in support of your Contention II, do you l
14 ' contend that the expressions " sale," " services," "research," " development,"
15 " education," " training," " industrial," or " commercial" have any spec:.alized i
16 mear.ing othcr than that which could be found in any good dictionary, for 17 example, Webster's New Collegiate Dictionary (1977 edition)? If yes, provide 18 .as to each expression the definition you are relying on an'd the source of each 19 such definition.
20 21 INTERROCATORY NO. 16 (CONTENTION II):
22 Do you contend that if at applicant's freility more than fifty 23 percent of the hours of reactor usr.ge have been devoted to the sale of 24 services, rather than research or education, applicant does not qualify for a 25 class 104" license? If yes, provide the following information:
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1 I (a) State the facts upon which you base your allegation including 2 any applicable provisions of the governmental regulations, statutes or case 3 law; 4
5 (b) Identify the person (s) with knowledge of the facts which 6rsupport your allegation; and 7 .
8- (c) Identify the document (s) which support your allegation.
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INTERROCATORY NO. 17 (CONTENTION II):
11 Do you contend that 10 CFR 50.34(b)(6)(ii) applies to license 12 renewal applications for research reactor facilities? If yes, provide the 13 f ollowing information:
14 D
I 15 (a) State the facts upon which you base your allegation including l
16 the source of the requirement in the federal regulations; l
17 18 (b) Identify the person (s) with knowledge of the facts which 19 support your allegation; and 20 21 (c) Identify the document (s) which support your allegation.
22 23 INTERROGATORY NO. 18 (CONTENTION II):
24 Do you contend that applicant has demonstrated throughout its 25 operating history grossly inadequate controls? If yes, cite each incident 26 including the date, place and time of each and as to each provide the 27 following information:
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(a) State the facts upon which you base your allegation that the 2 incident is an example of " grossly inadequate controls;"
3 4 (b) Identify the person (s) with knowledge of the facts which 5 support your allegation; and 6 ',
1 7 (c) Identify the document (s) which support your allegation.
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9 [INTERROCATORY NO.19 (C0hTENTION III):
10 With respect to any incidents cited in response to the Interrogatory I
11 l above, do you contend that there did result any actual harm to the public i
12 ' health and safety? If yes, cite each such incident and as to each provide the 13 following information?
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15 ', (a) State the f acts upon which you base your allegation including 16 the date, place and time of each, the nature of the resulting harm, the 17 individual (s) harmed and the supporting medical evidence; .
18 f 19 (b) Identify the person (s) with knowledge of the facts, which 20 support your allegation; and 21 22 (c) Identify the document (s) which support your allegrtion.
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24 : INTERROGATORY No. 20 (CONTENTION III):
25 Do you contend that applicat's existing managerial and 26 administrative c.ontrols are inadequate to responsibly protect the public 27 health and safety? If yes, cite those aspects of the current controls which 20 are deficient and as to each aspect provide the folicwing information:
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1 (a) State the facts upon which you base your allegation; 2 ,
3 (b) Identify the person (s) with knowledge of the facts which support your allegation; and -
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6 (c) Identify the document (s) which support your allegation.
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8 ,IhrERROCATORY NO. 21 (CONTENTION IV):
9 Do you contend that applicant has been consistently cited for f
10 violation of NRC regulations? If yes, specify each such violation and as to 11 each provide the following information:
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13 (a) State the facts upon which you base your allegatioc including 14] the date, place and time of each such violation and the specific NRC 15 regulation violated; 16 17 (b) Identify the person (s) with knowledge of the facts which 18 support your allegation; and l
I 19 20 (c) Identify the document (s) which support your allegation.
21 22 INTERROCATORY NO. 22 (CONTENTION IV):
23 Do you contend that applicant has been consistently cited for
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24 violation of its own technical specifications? If yes, specify each such 25 violation and as to each provide the following information?
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(a) State the facts upon which you base your allegation including t
2 lthe,date, place and time of each such violation and the specific technical 3 l specification violated; 4
I (b) Identify the person (s) with knowledge of the facts which 5 ;
l 6 l support your allegation; and 7I I
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! (c) Identify the document (s) which support your allegation.
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10 IlfrERROCATORY No. 23 (CONTENTION IV):
11 !
With respect to any incidents resulting in violations which you have l
- 12. specified in response to either of the two interrogatories immediately i
13 : preceding, do you contend that there did result any actual harm to the public 14 health and safety? If yes, describe each such incident and as to each provide 15 the following information:
l 16 17 (a) State the facts upon which you base your allegation including la the date, place and time of each such incident, the nature of the resulting 19 harm, the individual (s) harmed and the supporting medical evidence; 20 21 (b) Identify the person (s) with knowledge of the facts which l 22 support your allegation; and 23 f
l 24 (c) Identify the document (s) which support your allegation.
25 1
26 ItrrERROCATORY NO. 24 (CONTENTION V):
27 Do you contend that the amount of excess reactivity permitted by the 28 technical specifications could lead to a serious power excursion which could l
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1 bring about melting of the fuel or fuel eladding in applicant's reactor? If 2 yes., provide the following information:
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' 3 I 4 (a) State the facts and provide the tichnical analysis and f
5 calculations regarding excess reactivity effects upon which you base your 6 allegation including a detailed explanation of the most credible accident 7
I scenario which you contend would lead to a melting of the fuel or fuel 8 icladding; I
9 10 l (b) Identify the person (s) with knowledge of the facts which 1
11 I support your allegation; and -
i 12 13 (c) Identify the document (s) including technical materials which 14 lj support your allegation.
i 15 l l
i 16 INTERROGATORY No. 25 (CONTENTION VI):
17 Do you contend that applicant has in the past emitted " excessive 18 radiation"? If yes, explain what you mean by the expression " emitting 19 excessive radiation" and provide the following information:
20 21 (a) State the f acts upon which you base your allegation including i
22 the date, place and time or period during which excessive radiation was 23 emitted; 24 25 (b) Identify the person (s) with knowledge of the facts which 26 support your allegation; and 27 20 (c) Identify the document (s) which support your allegation.
15
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, j INTERROCATORY NO. 26 (C0hTENTION VI):
Do you contend that applicant is at the present " emitting excessive 2
If 7e8e explain what you mean by the expression " emitting
, 3 lradiati n"?
4 excessive radiation" and provide the following information:
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l (a) state the f acts upon which you base your allegation including l 6..
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7 lthedate,placeandtimeorperiodduringwhichexcessiveradiationwas i
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(b) Identify the persan(s) with knowledge of the facts which l
11 ! support your allegation; and I
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(c) Identify the document (s) which support ;your allegation.
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15 INTERROCATORY No. 27_(CONTENTION VI):
16 Do you contend that applicant has in the past violated radiation 17 standards? If yes, specify esch such radiation standard violated and as to 18 each provide the following information:
19 20 (a) State the facts upon which you base your allegation including 21 the date, place and time or period of each such violation; '
22 23 (b) Identify the person (s) with knowledge of the facts which 24 support your allegation; and R
25 26 (c) Identify the document (s) which support your allegation.
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Do you contend that applicant is at present violating radiation
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3 standards? If yes, specify each such radiation standard violated and as to 4 each provide the following information: .
5 6
' (a) State the facts upon which you base your allegation including 1
7
- the date, place and time or period of each such violation; 8
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(b) Identify the person (s) with knowledge of the facts which 10 support your allegation; and I
l 11 l-12,; (c) Identify the document (s) which support your allegation.
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t 13 l l l 14 :INTERROCATORY No. 29 (CONTENTION VI):
15 .
Do you contend that applicant has in the past conducted " inadequate limonitoring"? If yes, explain what you mean by the expression " inadequate 16 17 monitoring" and as to each instance of inadequate monitoring provide the 18 following information:
19 (a) State the f acts upon which you base your allegation including 20 21 the date, place and time or period of each such instance of inadequate 22 monitoring; 23 24 (b) Identify the person (s) with knowledge of the facts which 25 support your allegation; and 26 27 (c) Identify the document (s) which support your allegation.
28 17
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1 { INTERROGATORY NO. 30 (CotTIENTION VI):
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Do you contend that applicant is at present conducting " inadequate I f
3 monitoring"? If yes, explain what you mean by the expression " inadequate 4i monitoring" and as to each instance of inadequate monitoring provide the l l
5 following information: ;
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7 ! (a) State the f acts upon which you base your allegation including l l
8 l the date, place ana time or period of each such instance of inadequate i
9 l monitoring; I
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i 11 (b) Identify the person (s) with knowledge of the facts which 12 support your allegation; and l!
13' 14 l, (c) Identify the document (s) which support your allegation.
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16 INTERROCATORY NO. 31 (CONTENTION VII):
17 Do you contend that the reactor has in the past experienced a at
} 18 persistent pattern of numerous " unscheduled shutdowns"? If yes, explain 19 you mean by the expression " unscheduled shutdowns" and provide the following 20 information:
21 22 (a) State the f acts upon which you base your allegation including 23 the date and time of each such incident; 24 25 (b) Identify the person (s) with knowledge of the facts which i
26 support your allegation; and 27 28 ' (c) Identify the document (s) which support your allegation.
I 18
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1 iINTERROGATORY NO. 32 (CONTENTION VII):
2 ,
Do you contend that the reactor has in the past experienced a 3 Persistent pattern of " abnormal occurrences"? If yes, explain what you mean 4 : by the expression " abnormal occurrence" and provide the fo119 wing information:
5 !,
i 6 l (a) State the f acts upon which you base your al1%gation including 7 ' the date and time of each such incident; 8 ;t ll 9 '; (b) Identify the person (s) with knowledge of the facts which 10 support your allegation; and 11 l 12 i (c) Identify the document (s) which support your allegation.
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( 14 INTERROCATORY No. 33 (CONTENTION VII):
15 li Do you contend that the reactor has in the past experienced a I
16 persistent pattern of " accidents"? If yes, explain what you mean by the 17 expression "acci4t.nts" and provide the following information:
18 19 (a) State the facts upon which you base your allegation including 20 the date, place and time and a description of each such accident; 21 22 (b) Identify the person (s) with knowledge of the facts which 23 suppcrt your allegation; and 24 25 (c) Identify the document (s) which support your allegation.
26 27 28 ', ,
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1 INTERROGATORY NO. 34 CONTENTION VII):
i 2 I With respect to any incident cited in response to the i 3 interrogatories 31, 32 or 33 above, do you contend that there did result any ,
4 ' actual harm to the public health and safety? If yes, specify each such 5 incident and as to each provide the folloting information:
i 6ll '(a) State the facts upon which you base your allegation including 71 8yspecifyingthenatureoftheresultingharm,theindividual(s)harmedandthe l'
9]supportingmedicalevidence; 10 ,
11 ! (b) Identify the person (s) with knowledge of the facts which f i
12 support your allegation; and 13 ,
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(c) Identify the document (s) which support your allegation.
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16 INTERROGATORY NO. 35 (CONTENTION VIII): 8 I
Do you contend that applicant's safety analysis is flawed because it 17 ]
18 is based on unrealistic assumptions? If yes, specify the assumptions in 19 question and as to each provide the following information:
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1 21 (a) State the facts upon which you base your allegation that the 22 assumption is unrealistic; 23 24 (b) Identify the person (s) with knowledge of the facts which 25 support your allegation; and 26 27 28 ,
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' (c) Identify the document (s) which support your allegation 2 l including all technical analyses related to dose and dispersion models that 3 j appear in any nuclear safety literature.
l n l 4 5 : INTERROGATORY NO. 36 (CONTENTION II):
( i 6' Do you contend that the applicant has not adequately maintained its 11 7 equipment. If yes, list each piece of equipment not maintained and as to each 8 ; provide the following information:
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9 10,i (a) State the facts upon which you base your allegation including a l 11 ' description of the defective condition of the piece of equipment; l
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l 12 I 13 (b) Identify the person (s) with knowledge of the facts which !
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i 14 support your allegation; and i 15 I I
16 (c) Identify the document (s) which support your allegation.
l 17 18 INTERROGATORY NO. 37 (CONTENTION II): l f 19 Do you contend that the applicant has not properly calibrated its 20 instruments? If yes, list each instrument not properly calibrated and as to 21 each provide the following information:
22 23 (a) State the facts upon which you base your allegation including a 24 description of the improper calibration; 25 26 (b) Identify the person (s) with knowledge of the facts which 27 6 support your allegation; and 28 21
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(c) Identify the document (s) which support your allegation.
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3 INTERROGATORY NO. 38 (CONTENTION II):
I 4 Do lyou contend that any of applicant's present personnel who are 1
5 , responsible for equipment and instrument calibrations are not familiar with a
6 j the applicable calibration requirements? If yes, identify the individual (s),
i 7lll the unfamiliar requirement, and the facts which support your allegation.
I I 8i l
9 iINTERROGATORY NO. 39 (CONTENTION IX):
10 Do you contend that as a consequence of inadequately maintained 11 equipment o improperly calibrated instruments any actual harm to the public 12 health and safety has resulted? If yes, describe the incident and the 13 equipment or instrument involved and as to each provide the following 14 'information:
15.;
16 (a) State the f acts upon which you base your allegation including 1 -
17 the date, place and time of each such incident, and the nature of the 18 resulting harm involved, the individual (s) harmed and the " supporting medical 19 evidence; 20 ,
21 (b) Identify the person (s) with knowledge of the facts which 22 support your allegation; and 23 24 (c) Identify the document (s) which support your allegation.
25 26 INTERROGATORY NO. 40 (CONTENTION II):
( ;
l 27 Do you contead
- hat applicant during the preceding year did not I 28 perform the maintenance and calibration it was required to perform by its ,
22
I i
1 technical specifications? If yes, describe those items of maintenance and 2 ! calibration not performed which were required to be performed by the technical l 3 specifications.
! i -
4" 5 INTERROGATORY NO. 41 (CONTENTION IX):
6 Do you contend that "a review of the correspondence bibliography 7 !between the applicant and the Commission from the early sixties on indicates
?
8 I that the calibration problems have been long-term and are continuing"? If 9 yes, identify each item of the " correspondence bibliography" upon which you 10 base your allegation.
11 12 INTERROCATORY NO. 42 (CONTENTION X):
13: Do you contend that an accident at the reactor which would expose 14 great numbers of people to dangerous radiation dosages is likely? If yes, 15 describe this accident or accidents in detail and provide the following 16 information:
17 18 (a) State the facts upon which you base your aklegation that such l 19 an accident is likely and that dangerous radiation dosages would result; l 20 i 21 (b) Explain your use of the expression " design basis accident";
22 23 (c) Identify the person (s) with knowledge of the facts which ;
24 support your allegation; and l 25 i l
26 (d) Identify the document (s) which rupport your allegation.
27 !
l iD 28 23 ,
t L
l l
. 1 I i
l i l
' - INTERROGATORY NO. 43 (CONTENTION III): l 1
2 .
Do you contend that safety features of the UCLA reactor are 3 inads:uate to protect the public health and safety? If yes, specify each such l I
4 safety feature which is inadequate or lacking and as to each provide the l I
! 5 following information:
1 6
7 i (a) State the facts upon which you base your allegation; 8
l (b) State whether you contend that the safety system is one which 9 :
l 10;! is normally present at Argonaut-type research reactor f acilities; 1
11 i
12 ,
(c) Describe in detail how the lack or inadequacy of the safety I
I 13 lsystemcouldresultinactualharmtothepublichealthandsafety; i
14 15 (d) Identify the person (s) with knowledge of the facts which i
16 support your allegation; and I
17 18 (e) Identify the document (s) including any technical materials f 19 which support your allegation.
20 21 INTERROGATORY NO. 44 (CONTENTION XII):
1 22 Do you contend that graphite swelling and cracking may lead to j 23 problems at applicant's facility such as occurred with other reactors using 24 graphite, namely "Hallam and Piqua reactors"? If yes, identify those other 25 reactors, the power level of each, neutron fluence of each at the time the l 26 problems were observed, the typical graphite temperatures of each and provide 27 the following information:
1 28
24
\ -
I r
~
l 11! (a) State the facts upon which you base your allegation; h
2[ -
3.i f (b) Identify the person (s) with knowledge of the facts which
, p I il -
l 4 , support your tilegation; and l l
! 5' ll 60 (c) Identify the document (s) upon which you base your allegation.
b 7 '.f 8 INTERROCATORY NO. 45 (CONTENTION XIII):
93 Do you contend that the information which applicant has provided 10 regarding the special nuclear materials license does not meet governmental 11 ' regulatory requirements? If yes, specify the requirements in question and 12;. provide the following information:
I!
13 14 (a) State the facts upon which you base your allegation; l
15;i 16 '
i (b) Identify the person (s) with knowledge of the facts which 17 jsupport your allegation; and -
1 18 19 (c) Iden*ify the document (s) which support your allegation.
20 21 INTERROGATORY NO. 46 (CONTENTION XIV):
22 Do ycu contend that applicant has f ailed to analyze problems common 23 to Argonaut-type reactors? If yes, specify each such problem common to 24 Argonaut-type reactor facilities, indicate all Argonaut-type reactor 25 facilities which have experienced the problem and as to each provide the
- 26 following information
i 27 i
! base your allegation; !
l
' 28 (a) State the facts upon which .,u l
I 25
~_ , _ _ _ _ _ _ _ . . . _ _ _ .
1 (b) State whether you contend that the safety system is one which 2;; ia pormally present at Argonaut-type research reactor facilities; 8
h 3!i 4 (c) Identify the document (s) including any technical materials 5 !which suppport your allegation; and 6
b (d) Specify the harm to the public health and safety caused by the 7 ;;
ll 8;. problem.
h 9 !,
1 10kINTERROGATORYNO.47(CONTENTIONXV):
11 Describe in detail the basis of the allegation that applicant's i
12jl, !
license should not be renewed because the adverse conse 13 : the location and siting of the facility are too great by providing the
- I l
14 F following information:
ll
( 15' i
16l ,
(a) State the facts upon which you base your allegation including a 17 ! detailed description of any accident the probable concequences of which you 18 contend are unacceptably great; 19 l
20 I (b) Identify the person (s) with knowledge of the facts which 1
21 ! support your allegation; and 22 ,
1 23 ;l (c) Identify the document (s) upon which you base your allegation.
24 25 INTERROGATORY NO. 48 (CONTENTION XV): 1 26 Do you contend that the circumstances described as Contention 27 ! XV.1,2, and 3 have exacerbated the adverse consequences of normal operation of l
28 the facility? If yea, provide the follwing information. ,
I i
25 l
l I
i 1 l (a) State the f acts upon which you base your allegation including a 2 ' det. ailed explanation of the " adverse consequences";
3 !
t 4f (b) Identify the person (s) with kncvledge of the facts which 5 support your allegation; and 1
6 I 7 ,
(c) Identify the document (s) upon which you base your allegation.
I 8'
9 INTERROCATORY NO. 49 (CONTENTION XV):
1 10 ! State the facts upon which you base the " increased population l
11 ! density" assert, ions appearing on page 114 of the Supplement including the
, 12 campus population increases and identify the document (s) upon whie.h you base
! l l 13 lyourassertions.
i 14 I 15 , INTERROGATORY NO. 50 (CONTENTION XVI):
16 I Do you contend that because of the age of the reactor, the i
17 difficulty in obtaining spare parts, the unreliability of certain items of f '
18 equips. ant, and the difficulty in repairing certain items of equipment that 19 relicensing the reactor poses an unacceptable hazard to the public health and l
20 safety? If yes, provide the following information:
21 22 (a) Specify each spare part it is difficult to obtain and the hazard to the public caused by the inability to obtain the spare part, each 23 24 item of equipment that is unreliable and the hazard to the public caused by 25 the unreliability of the item of equipment, and each item of equipment it is 26 difficult to repair or replace and the hazard to the public caused by the 27 difficulty in repairing or replacing the item of equipment; 28 27
I 1
(b) State the facts upon which you base your allegation with 2 respect to each part or item of equipment specified in (a) above; 3
I 4 (c) hr each such part or item specified in (a), above, identify 5 the person (s) with knowledge of the facts which support your allegation; and 6
7 (d) For each such part or item specified in (a), above, identify _
l 8 f the document (s) upon which you base your allegation.
i 9!
i )
10 ! INTERROGATORY NO. 51 (CONTENTION XVI): !
i i
11 ;
.Do you contend that applicant's currently enployed reactor personnel ]
12 have ever operated the reactor without a required part or with an unreliable
\
l 13 or faulty item of equipment where such a part or item of equipment was l
l 14 critical for reactor safety and such personnel had knowledge that a serious 15 hazard to the public could result by such operation? If yes, describe each 16 such occasion and as to each provide the following information:
! 17 1 .
18 (a) St' ate the facts upon which you base your allegation; 19 20 (b) Identify the person (s) with knowledge of the facts which 1 21 support your allegation; and 22
(
23 (c) Identify the document (s) which support your allegation.
l 24 25 INTERROCATORY NO. 52 (C0!rrENTION XVI):
26 Do you contend that the applicant in the past has not devoted the ,
27 r.oney to properly update or maintain the equipment? If yes, describe each l
l 28 l such instance and as to each provide the following information:
28
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ . . _ _ _ _ _ ~ _ _ _ _ . _ . _ _ _ _ _ _ , , _ _ _ _ _ _ _ _ _ . . ___.__._._._ _ _.____ ____
I 1,-
(a) State the facts upon which you base your allegation including i.
2h., spe,cifying each item of equipment that was not properly updated and/or l
1 3 l maintained,theperiodduringwhichitwasnotmaintainedandanyhazardto 4, the public caused thereby; 6' (b) Identify the person (s) with knowledge of the facts which I
{ 7 fsupportyourallegation;and 8,
I 9; (c) Identify the document (s) which support your allegation.
I 11 !INTERROGATORYNo.53(CONTENTIONXVIII):
f l,
i 12 ;
Do you contend that applicant has deferred maintenance in tR past l
l 13 due to lack of funds? If yes, describe each such instance and provide the 14 following information:
15 l'
16 (a) State the facts upon which you base your allegation including 17 specifying the maintenance that was deferred, tue period over which it was 18 deferred and whether the deferral of maintenance resulted 'in any actual hara 19 to the public; 20 21 (b) IdentiQ the person (s) with knowledge of the facts which
- 22 support your allegation; and 23 24 (c) Identify the document (s) which support your allegation.
25 26 INTERROGATORY NO. 54 (CONTENTION XVIII):
27 Do you contend that applicant's situation, as a public inrtitution 28 and subject to yearly funding and unable to assure that it will obtain 29
. _ - - , - . - _ _ , . , - - _ _ . . _ - . , . . , . , . _ - . _ _ , . . - . . _ , . _ - _ , . . . _ . . _ . _ _ _ . . _ _ . , . . . , . ~ . . - . - - - - .
~
l.
1 fsufficientfundingforoperationofthereactorfromyeartoyear,is 2 l dif,ferent from any other government entity, in particular, other I 3 state-supported universities which operate research reactors? If yes, provide I
the followir.d information:
l 4.
5 i i
, 6' (a) . State the facts upon which you base your allegation that ]
' l l 7 . applicant's financial situation is different; ~
l l 1 8 9,
1 (b) Ilentify the person (s) with knowledge of the facts which i
10 !supportyourallegation;and i 1 11 l l 12 (c) Identify the document (s) which support your allegation. !
I 13 14 INTERROCATORY NO. 55 (CONTENTION XIX): 1 l
Do you contend that applicant failed to comply with any federal ,
1 1 i 15l0 16 regulatory requirement applicable to research reactor license renewal 17 applications by not considering in applicant's safety analysis any or all of l i
18 the " hazard scenarios" which appear as Contention XIX.1.2,3 or 4? If yes, as 19 to each such " hazard scenario" required to be considered provide the 20 following information:
21 22 (a) State the facts upon which you base your allegation including
! 23 i the federal regulation requiring its consideration; l
24 25 (b) Identify the person (s) with knowledge of the facts which 26 support your allegation; and 27 1
28 (c) Identify the document (s) which support your allegation.
30 l
l
i l
l l
I:
1 j INTERROCATORY NO. 56 (CONTENTION III):
1 2' ,
Do you contend that sabotage is a credible accident scenario for 3
this facility? If yes, explain in detail the specific sabotage scenario you 4 . contend ought to have been considered and provide the following information:
I 51 li (a) State the facts upon which you base your allegation; 6"
75 i
(b) Identify the person (s) with knowledge of the facts which 8/
11 9:!jsupportyourallegation;and 10 ]
11 j (c) Identify the document (s) which support your allegation.
12 I
13 h INTERROGATORY No. 57 (CONIENTION XIX):
14 Do you contend that a DC-10 or Boeing 747 airplane crash is a 15 , credible accident scenario for this facility? If yes, explain in detail the 16 specific airplane accident scenario you contend ought to have been considered 17 and provide the following information:
18 19 (a) State the facts upon which you base your allegation that such a 20 scenario is credible including a description of the approach paths and 21 approach elevations used by Los Angeles International and Burbank Airports for 22 arriving commercial airplanes; 23 24 (b) Identify the person (s) with knowleoge of the facts which 25 support your allegation; and 26 27 (c) Identify the document (s) which support your allegation.
I 28 31
, _ _ . . _ - - _ _ _ _ _ _ . _ , _ _ _ . . . _ - - _ _ _ _ . - - . _ _ . ~ _ . _ . _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ ___ _ _ . _ _ _ _ _ _
~
1 .INTERROCATORY NO. 58 CONTENTION XII):
2 - Do you contend that applicant should consider in applicant's safety 3 analysis an accident scenario characterized as " multiple failure modes w orst 4.' possible series of events"? If yes, provide the'following information:
5 6 (a) Describe in detail exac:1y what you mean by the expressions a
! 7 "m itiple failure modes" and " worst possible series of events" and state ,
8 . whether you intend a credible accident scenario or an incredible accident 9 l scenario; I
10 11 (b) If you intend that only a credible accident scenario be 1 ,
i.
12 l considered state the facts upon which you base your allegation that the 13 " mitiple failure modes" scenario is credible and identify the person (s) and 14 ' document (s) which support your allegation.
15 ,
16 INTERROGATORY NO. 59_(CONTENTION XIX):
17 Do you content that applicant should consider in applicant's safety 18 analysis an accident scenario characterized as " operator error which leads to 19 design basis accident"? If yes, provide the following information:
20 21 (a) Describe in detail what you mean by the expression " design 22 basis accident" and state whether you intend that a credible accident scenario 23 be considered or an incredible accident scenario be considered; 24 (b) If you intend that only a credible accident scenario be 25 considered state the facts upon which you base your allegation that the j 26 design basis accident" scenario is credible and identify the person (s) and 27 document (s) which support your allegation.
28 32
i I
1 lINTERROGATORYNO.60(CONTENTIONXX):
i 2'., -
Do you contend that applicant's fixed site physical security 3
Precautions are not in conformance with 10 Code of Federal Regulations Section 4 :73.677 If yes, provide the following information:
t 5I (a) State the' facts upon which you base your allegation; l ii !
l 7;l Identify the person (s) wit $ knowledge of the facts which 8 (b) g support your allegation; and i 10 ,
jj ! (c) Identify the document (s) which support your allegation.
12 f li 13h INTERROCATORY NO. 61 (CONTENTION XX):
14 '
F Do you contend that applicant's fixed site physical security li j
15'; Precautions are not in conformance with 10 Code of Federal Regulations Section 16 f 73.607 If yes, provide the following information:
! l 17 I
18 (a) State the f acts upon which you base your allegation; i
19 l (b) Identify the person (s) with knowledge of the facts which 20 ?
21 support your allegation; and 22 23 lj (c) Identify the document (s) which support your allegation.
I 24 25 INTERROGATORY NO. 62 (CONTENTION XX):
26 Do you contend that applicant's security precautions have not 27 achieved early detection and assessment of unauthorized access or activities 28 by an external adversary within the controlled access area containing special I
33
l 1
nuclear material? If yes, provide the following information:
2 (a) State the facts upon which you base your allegation; 3
4; 5
(b) Identify the person (s) with knowledge of the facts which l 6 support your allegation; and 7
8 (c) Identify the document (s) which support your allegation.
I 9
10 . INTERROGATORY No. 63 (CONTENTION XX):
11 !
Do you contend that applicant's security precautions have not 12 achieved early detection of removal of special nuclear material by an external 13 l adversary from a controlled access area? If yes, provide the following 14 '
information:
i 1
15 l
16 (a) State the facts upon which you base your allegation; 17 18 (b) Identify the person (s) with knowledge of clie facts which ;
19 support your allegation; and 20 /
21 (c) Identify the document (s) which support your allegation.
22 .
23 INTERROGATORY NO. 64 (C0hTENTION IX):
Do you contend that applicant's security precautions have not l 24 25 assured proper placement and transfers of custody of special nuclear 26 material? If yes, provide the following information:
i 27 28 (a) State the facts upon which you base your allegation; f I f 34 l b i
i
. i i
1 3 (b) Identify the person (s) with knowledge of the f acts whic'ai 2 ! support your allegation; and 3
4 (c) Identify the document (s) which support your allegation.
5 6 INTERROGATORY No. 65 (CONTENTION XX):
7 Do you contend that applicant has not responded to indications of an 8 unauthorized removal of special nuclear material and then has not notified the 9 appropriate response forces of its removal in order to facilitate its 10 recovery? If yes, provide the following information:
11 l l
12 . (a) State the facts upon which you base your allegation; i 13 l
14 (b) Identify the person (s) with knowledge of the facts which l
15 support your allegation; and i
16 17 (c) Identify the document (s) which support your allegation.
18 19 INTERROGATORY NO. 66 (CONTENTION XX):
l 20 Do you contend that applicant has in the past and is at present l 21 taking inadequate fixed site physical security precautions to protect against 22 radiological sabotage as well as protection against chef t and diversion of the 23 special nuclear material it posse.sses? If yes, specify each security 24 deficiency and as to each provide the following information:
25
~
26 (a) State the facts upon which you base your allegation; 27 28 .
35
- l 1
(b) Identify the person (s) with knowledge of the facts which 2 support your allegation; and 3
~
4 (c) Identify the document (s) which support your allegation.
! 5 6 INTERROGNa0RY NO. 67 (CONIENTION II):
i j 7 With respect to each " security def,1ciency" you specify in response 8 to the preceding interrogatory indicate whether you contend that applicant has 9 failed to conply with a federal regulatory security requirement and if yes i,
10 identify the requirement.
11 l t
12 [ INTERROGATORY NO. 68 (CONTENTION XX):
i 13 : Do you contend that security measures with regard to keys and locks I
14 : are inadequate? If yes, provide the following information:
l 15 i t 16 (a) State the facts upon which you base your allegation including I
17 which doors have been left open and when, which locks are of insufficient 18 j strength, which keys to what areas have been given out and to whom have the l
19 keys been given out, which keys can be copied, which keys have been lent to 20 unauthorized personnel and which personnel, and which keys are signed out and 21 not required to be returned; 22 23 (b) Identify the person (s) with knowledge of the facts which 24 support your allegation; and 25 26 (c) Identify the document (s) which support your allegation.
27 l
28 36 f
. _ . . _ . , , _ , . . . . _ . . , , . . . , _ . - _ _ _ _ _ - - . . ,_.-.._,.,_,,y_. . _ , . , _ . _ , _ . . _ , _ _ _ . ,,,..-_,._____._..-._~_.--_____,-_._m_
l 1 iINTERROGATORY No. 69 (CONTENTION XXI):
Describe in detail the basis of the allegation contained in 2 ,
3 Contention XII that application's emergency response plan is inadequate by
! 4 providing the following information:
5 ,
6 I
(a) State the facts upon which you base your allegation; l
7 ..
8 (b) Identify the person (s) with knowledge of the facts which i
9 ' support your allegation; and 10 l 11 (c) Identify the document (s) which support your allegation.
12 ,
13 l
14 l Dated: April 20, 1981 15 16 l
DONALD L. REIDHAAR
! 17 GLENN R. WOODS .
CHRISTINE HELWICK 18 By .
GLENN R. WOODS 21 Attorney for Applicant 22 l 23 1
24 25 l
26 i
i g
27 1,
28 6 37
t 1 (DEC6ARATION OF SERVICE BY MAIL (CODE CIV. PROC. SS1013a & 2015.5) i I, the undersigned, say: I am a citizen of the United States, 2
3 over 18 years of age, employed in Los Angeles County, California, in 4
which county the within-mentioned mailing occurred, and not a party to the subject cause. My business address is 2214 Murphy Hall, 5
405 Hilgard Avenue, Los Angeles, California 90024. I served
. 6 _
7 the attached: APPLICANT'S FIRST SET OF TNTERROCATORTER g TO INTERVENOR CO.5!ITTEE TO BRIDGE THE CAP 9 .
10 '
11 by placing a copy thereof in a separate envelope for each addressee named hereafter, addressed to each such addressee respectively 12 13 as follows:
- 14 SEE ATTACHED t
15 16 ,
17 13 Each enevlope was then sealed and with the postage thereon 19 fully prepaid deposited in the United States mail by me at .
Los Angeles, California, on April 20, 1981 .
20 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.
April 20, 1981 at Los Angeles, California.
26 Executed on l gh GCthu O
DARLENE OTTEN i
-. -- . . . . - . . . . . . . . , . ~.__ -- , . , _ ,
}
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 Washington, DC 20555 S ,
6 Dr. Oscar H. Paris U.S. Nuclear Regulatory Commission 7
Atomic Safety & Licensing Board Washington, DC 20555 .
8 Counsel for NRC Staff 9
Office of Executive Legal Director U.S. Nuclear Regulatory Commission. ,
10 , Maryland National Bank Building 7735 Old Georgetown Road Bethesda, Maryland 20015 j}
12 , Daniel Hirsch ,
Committee to Bridge the Gap 13 1637 Butler Avenue. 4230 '
Los Angeles, CA 90025 ,
14 Mr. Mark Pollock" Mr. John Bay 15 1633 Franklin Street ~
Santa Monica, CA 90404 .
16 17 Chief, Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission ,
18 20555 Washington, DC 19 20 21 22 23 .
24 25 .
26 ..
, _4 . _-,_ - - , -, . . . . , ~ . _ . , . , . , , . . - , . - . . . . . . _ , . . . _ _ - - , , , . . . , _ , , , , , . , _ . . _ . , _ _ . . , _ _ . , . ,_
_ . . _ _ , , , , . .