ML19346A167
| ML19346A167 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 05/28/1981 |
| From: | Woods G CALIFORNIA, UNIV. OF, LOS ANGELES, CA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8106050306 | |
| Download: ML19346A167 (17) | |
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- h 3 u 'C*MIE UNITED STATES OF AMERICA <s. Q l NUCLEAR REGULATORY COMMISSION' X 4 z ,( .;~ , ,,, l',
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5 BEFORE THE ATOMIC SAFETY AND LICENSING BOAR @ '
6 ,
7 g In the Matter of )
9 ( ro o F I RN A
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License Number R-71) FacMtyl 10 (UCLA Research Reactor ) May 28, 1981 11 : )
12 _
13 APPLICANT'S MEMORANDUM IN OPPOSITION TO INTERVENOR'S ;
l THIRD MOTION TO COMPEL: REQUEST FOR SANCTIONS !
14 15 . ,
16 ,, at N
17 S/ DONALD L. REIDHAAR 00c8ETED 7,. GLENN R. WOODS 18 ~
Usw , CHRISTINE HELWICK t
L. . JUN. .: 1 1981.:
.. . 5 9 0 university Hall ..
19 2200 University Avenue
- ehkj.I.' 3metery Berkeley, California 94720 '
20 g,,, , 3f u e Telephone: (415) 642-2822 Y (,ls t \
21 t* Attorneys for Applicant I
22 -
THE REGENTS OF THE UNIVERSITY i I
OF CALIFORNIA '
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3 I 4 TABLE OF CONTENTS 5 Page 6 I. PRELIMINARY STATEMENT . . . . . . . . . . . 2 7 II. DISCUSSION . . . . . . . . . . . . . . . . 3 8
A. PRODUCTION OF RECORDS . . . . . . .. . . 4 9 B. FURTHER ANSWERS . . . . . . . . . . . . 5 10 C. SPECIFIC OBJECTIONS . . . . . . . . . . 7 11 D. INTERVENOR'S THIRD MOTION TO COMPEL . . 10 12 III. CONCLUSION . . . . . . ... . . . .. . . . . 13 '
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i i If Applicant, THE REGEUTS OF THE UNIVERSITY - OF f, -
1
- 2) CALIFORNIA, responds to Intervenor, Bridge the Gap's " Third '
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3[: Motion to Compel Answers; Request for Sanctions" concerning 0 Intervenor's first set of interrogatories as follows.
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1 6 I. PRELIMINARY STATEMENT 1 .
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8 Applicant objects to Intervenor's third motion to ,
j 9 compel; this motion has been propounded without substantial l 50 justification'in any respect. In fact, Applicant has complied I
11" fully with what it has understood to be the command of the
} 12 Board and has in good faith attempted to co, operate'with the i I i i 13 Intervenor, the NRC Staff and the Board in facilitating the '
14 resolution of the issues in this proceeding.- Applicant has
. 15 permitted the examination of its records and'has gone to some 16 length to explain the ambiguities in Intervenor's questions l 17 which prevent Applicant from providing further answers.
, 18
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'1 .' ' 6ISCUSSION i"'
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Applicant is unaware of the particular arguments D 21 which Intervenor intends to advance in support of its " wrong
! 22 ,- . - 3 I class of. license" contention.
However, it is clear to Appli-23 j ~
cant on the basis of the first set of interrogatories that 24 Intervenor is confused as to the meaning of 10 C.F.n.H50.22.
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This confusion has resulted in Intervenor's framing ambiguous ; t 26 l 27
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questions. Intervenor states that Applicant is " strenuously 1/l 2lti " resisting disclosing" information relevant to Intervenor's -
3 contention. Such is not the case. Applicant's inability to 4 respond further is based solely on the fact that Intervenor's 5 questions are unclear. Moreover, since Applicant has made an i
6 appropriate offer of its records and documents which will en- .
7 able Intervenor to extract whatever information exists relative :
I 8 to Intervenor's claim, Applicant has fu'.ly complied with the j 9 Federal Rules of Civil Procedure, Nuclet.: Regulatory Commission 10 practice and the Board's Order.
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12 A. Production of Records ,
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14 Applicant has permitted'the examination of all the I i
15 records and documents in Applicant's possession offered in re- ,
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16 sponse to Intervenor's first set of interrogatories and has l
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i 17 photocopied for Intervenor's convenience over 1200 pages of 18 ! The effect of the Board's March 10, 1981 this material. ;
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19 order was to fault' Applicant for failing to' provide Intervenor 20 with the May 13, 1981 document (the table of reactor port-hours) l 21 as a document which should have been offered in response to i i
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_Intervenor's interrogatory no. 9 (Intervenor's first set of 23 interrogatories.) Applicant accepts that admonishment as 24 Applicant's May 1, 1981 letter to'Intervenor's counsel clearly 25 states. Applicant still intends to demonstrate at the appro-t 26 priate time in the proceeding that the subject document is not .
f 27 I 8 !'See Declaration of William H. Cormier, at* ached hereto.
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t 1 ; what Intervenor claims it to be and that it. does not provide ..;
2 the answer to Intervenor's question no. 9.
3 L 4
. 4 Never theless , Intervenor has the questioned document j 5 -in its possession and has had use of the information it con- ,
6 tains. In addition, Applicant has just responded to the Conten-7 tion II questions contained in Intervenor's.second set of inter-
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- 8 rogatoriss. In Applicant's response to one of Intervenor's i
9 questions, Applicant has extended the compilation of the May 13, 1
Ir 1991 document data for the year 1980 and the first four months i
111, of 1981. (Prior to the preparation of the May 13, 1980 document 12 this data had not been compiled in this form.)
13 i
, 14 Applicant also indicated in its second set responses
- 15 that it was preparing a brief study of the " educational" uses.
I 16 that are made of' the reactor and that this data would be made I 17 available to Intervenor when it is completed. Applicant had i
18, previously offered its general ledgers for all years of reactor ;
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19 operations and 'the available supporting finhncial' documentation, ,
20 but Intervenor has chose to avail itself of only part of this 21 data. Applicant has repeated the offer of its general ledgers 22 - in. its second set responses (see " Exhibit A," the document list .
I 23 of Applicant's Answers of Intervenor's second' set of-Interrog- !
l 24l atories.
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[ 26 Since Applicant has made available or Intervenor 27 i
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l' otherwise has in its possession, the records Applicant has ,
2 of fered. in response to the first set interrogatories, the only 3 issue remaining with this motion is whether Applicant was com-l 4 manded by the Board to provide additional answers to questions :
I 5 4, 5, 6 and 9 of Intervenor's first set of interrogatories. If l 6 not, there is no merit to Intervenor's motion.
7 l 8 B. Further Answers 9 -
10
- Applicant has explained in its answers of November 14,,
11 1980, its memorandum of December 12, 1980, its further answers :
1 12 of January 22, 1981 and finally in its memo,randum of February _ t I
13 23, 1981 that Intervenor's questions (interrogatories 4, 5, 6 14 and 9) were unclear and ambiguous. Applicant has explained in 15 detail the reasons for the ambiguities and has provided Inter-
- 1 16 venor with enough suggestions on how Intervenor could restate 17 its questions to resolve the ambiguities. Applicant need not 18 repeat those. discussions here, but urges the Board to refer to
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19 those previous discussions.
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21 Applicant should not be required to provide answers .
22 .to. interrogatories that are as ambiguous as those propounded by !
i 23 Intervenor. Furthermore, applicant does not believe that the 24 Board's March 10 Order commanded Applicant to redo its answers, i
.25 If, in fact, the Board's intent was otherwise, the Applicant
- I 26 respectfully submit that the Board's Order was unclear and that '
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- 1' Applicant's interpretation was arrived at i.n good faith. Under
, i 2 ! such circumstances it would be unfair to impose the requested 3
l sanctions.
4 5 But, Applicant believes that the Board was clear in its 6 i March 10 Order and that it did 7
8 . . . direct UCLA to be open and candid as to the details of all existing records. At the same time, 9 we again advise CBG that the Applicant is not re- I quired to create new information or engage in a work l 10 ef fort to reshape its records to the Intervenor's categories . . . "
12 ,
The Order of the Board stated as follows:
13 14 "That UCLA shall respond to CBG interrogatories with :
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a complete disclosure of all relevant informat. ion." l 16 17 Unlike its previous Order (December 22, 1980) the Board did not 18 state "The Motion to Compel is . . . GRANTED." Applicant does i 19 not believe that the Noard's order contemplated further answers j
l 20 to Intervenor's past interrogatories but instead accepted Appli-i 21 cant's explanations of the difficulties it had in interpreting l
22 Intervenor's questions and ordered that Applicant disclose all l 23 of its records and documents in any way relevant to Intervenor's 24 questions. i b t I
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26 In that regard, Applicant has identified the relevant 27
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I l 2 ! document examination sessions that have occurred by instructing
- I 3 -Intervenor in the proper interpretation of its documents. The .,
4 l May 13, 19 80document (reactor port-hours) is simply a classi-5 fication by user of the reactor as is explained in that docu-6 ment. As to any other words, terms., definitions or expressions I 7 which Intervenor needs explained, Intervenor need only specify 8 the context in which each appears and Applicant will explain the 9 usage. What Applicant cannot do without Intervenor providing 10 some additional clarification is respond furth'er to Intervenor's 11 first set interrogatories nos. 4, 5, 6 and 9.
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13 C. Specific Objections ,
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15 Applicant has discussed the kmbiguities in Intervenor's
- 16 questions at length in its previous me.moranda on this matter and I
17 those explanations are incorporated herein by reference. How-i 18 ever, it is worth repeating part of that discussion here to in-193 ! sure that Applicant's position is made clear.
20 21 Applicant's objections to Interviewer's questions are i I
3ase'd on the fact that the questions as understood by Applicant f
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! 22 23;.are vague, ambiguous and uncertain. Consider by way of example 24l interrogatory no. 4, which asks for'the definitions of "re-j t 25 search", " education", " training" and " sold services." Appli-l 26 cant has urged Intervenor simply to specify the context in which I I
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1h; the words appear and Applicant can explain the usage. Inter-2 fvenorhasnotdonesowithrespecttoitsfirstsetofquestions.. .
3 contrast this first set of questions with a similar question, I
41 representing a vast improvement, that Intervenor has included l 5 in its second set of interrogatories (question 56 (a) of Con-6 tention II.) That question asks Applicant for its definition 7 of "research" as the word is used by Applicant on page III/I-5 8 of the license application. This question represents a restate-9 ment of the first set question and, as restated, Intervenor's 10 question is clear and unambiguous and Applicant has been able 11 to provide a clear response. Intervenor has not thus restated t 12 the question with respect to the other terms and as a result 13 Applicant has no idea of where in~ Applicant's records the terms 14 are used. Without knowing the context Applicant cannot provide
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15 a definition. ,
16 17 Indeed, to Applicant's knowledge " education", " train-18 lt ing" and " sold services" are not categories or classifications 19 that applicant' regularly uses in reporting any of its' financial' I
20 or operating usage data. Applicant reports reactor operating 21 time in the following categories: clascroom instruction, main
-l 22 tenance and research. Port hours of usage were aggregated for ,
l 23 i the first time in the May 13, 1980 response to the NRC staff's i 1
24 l specific request and the exe'rcise'has been repeated for the 25 period through the first quarter of 1981 to satisfy Intervenor's 26 request made in its second set of interrogatories (see page 23 27 l.
28
- s e. e ,e s 7
. . t-1 of " Answers of the ' Applicant to Intervenor's . Second Set of ;
2 Interrogatories" where'"other extramural-users" is Applicant's I 3 corrected exp,ression for what Intervenor contends are "commer- .
4 cial" users and categories b, d, e,. f and g correspond roughly .
I 5 to "research" as that is reported in the operating time tables
- 6 although, as Applicant has explained elsewhere, port-hours of l j
7 usage cannot be converted simply and directly into operating i 8 time hours of usage.)
9 10 Applicant submits that Intervenor may have come up 11 with four terms in question no. 4 in 10 C.F.R. S50.22, where
~12 those same expressions are prominent, and n * ' rom any specific -
i 13 hlaceinApplicant'srecords. Intervenor may have assumed that I 14 since those terms appear in Section 50.22 that Applicant would
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15 be using the same categor_es to report specific data sets relat-16 ing to Applicant's operations. If so, then Intervenor is simply.
17 mistaken. If not, Intervenor can clear up the confusion by speci-l; 18 fying the place in Applicant's records and documents where 1
19 Intervenor's " question 4"' terms appear'.
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21 Indeed, it appears to Applicant that Intervenor's .
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1 22 . confusion and hence the-ambiguity of its questions derives not '.
I 23 from anything prompted by terms or expressions found in Appli-cant's records and documents'but instead from its misreading !
24 25 and misinterpretati'h e.' certain phrases contained in 10 C.F.R. 26 550.22, 27 -
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Ir For example, consider further question 5s:
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3! "For' each of the years 1960 up to and including 1980 please specify: (a) What percent of the 4l income derived from operating the Reactor was devoted to the sale of services?" (Applicant's 5 emphasis.)
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7 As it stands the question makes no' sense. The phrase " devoted-8 to", in the sense of having directed resources towards an object-9 ive, is properly applied to " costs", not " income", which, of 10 course, is the way the term is used in 10 C.F.R. 550.22. The 11 same confusion is apparent in questions Sb, Sc and 6a.
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13 Similar arguments applyL to the other first set ques- ,
i 14 tions and the Board is referred to Applicant's earlier memor- l-1 15 anda where these matters have already been discussed. -l 16 17 D. Intervenor's Third Motion to Compel 18 19 'Intervenor's ' third motion to coepel has been pro-4 20 pounded without substantial justification. It is not only un-21 clear, but it contains several incorrect and misleading state- i l
22 ments. Applicant believes its discussion above is fully dis-23 positive of the legal issues raised by Intervenor's motion.
24 Nevertheless, Applicant feel's compelled to respond to certain ;
4 i 25h specific points.
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I 1] In the first ~ place, Intervenor asserts that "two of ,
l 2 the interrogatories in question (4 and 9) request definitions of ;
3 terms . . . (which) definitions must exist, for Applicant's 4, letter to staff (the May 13, 19'. document) divides reactor I
5 I usage into virtually the categories for which Intervenor has 6 requested definitions . . ." (Intervenor's motion, page 8) .
7 That is simply not correct. None of the " question 4" terms
- l 8 (education, training, research, and sold services) appears as a !
9 category in the May 13, 1980 document. . The terms that, are used 10 in that document are explained sufficiently in that document 11 beginning immediately below the table that lists the . categories.
12 Applicant does not possess any more precise, definitions of 13 those terms. The table is simply a breakdown of port-hour usage ,
14 (not operating time, as question 9 requests) into categories of j 15 users cs the NRC staff requested be done. For example, if the 16, one whose experiment is being run in the reactor is a professor i 17 of physics at UCLA then his use would be categorized as a "UCLA 18 User" use. Likewise, if the use were that of the ' notorious Dr.
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19 Kalil who is not a "UCLA User" nor a " College and University i
20 User" but instead runs his own business that use would have 21 been categorized as " Commercial" or, as.it will be referred to ,
l 22 . in . the future , "Other Extramural User." There is nothing very i l
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mystical about this classification scheme; indeed, Applicant :
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24 i believes it is rather too obvione..
25 26 Intervenor goes on, contradicting itself (see Inter-- l 27 28 ,
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1 . senors statement discussed immediately above) , to state that: ;
i 2 "these are Applicant's categories, used either in the letter to ,
l 3 ; Staff or in the Application (pages 5, II/7-1, and III/1-5, for i l
4 example)" (Intervenor's motion, bottom of page 8). The empha-5 I sized phrase, including the parenthetical page references, is 6 the first reference Intervenor has ever made in the six months ;
7 that the parties have been considering:these questions to a 8 specific context for the terms respecting which it has been 9 seeking definitions. These references are revealing. They dem-10 onstrate beyond reasonable question the insincerety of Inter-11 venor's claims of disadvantage in the discovery process. As 12 Applicant expected the expressions.are used_in their simple 13 common (dictionary meaning) sense.
14
. 15 Intervenor's reference to page II/7-1 of the Applica- ,
i 16 tion directs one to the following ' sentence: "The benefits (of 17 the Nuclear Energy Laboratory facility) include, but are not I 18 limited to: (a) education of students and public . . . (b) .
19 research . . . and (c) trai ning .' "' The' reference to page 5 'of 20 the Application directs one to the fcllowing sentence: "The 21 reactor and its supporting laboratories will be used for the 1
22 -education of senior undergraduate and graduate students." Thesel 23 contexts are in no way related to Applicant's financial records .
24 ; and documents. Moreover, ca'n Intervenor be seriously insisting i
25 that the meaning of -the " question 4" terms as they are used in 26 the above sentences is anything more than the straightforward i
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. 1 common sense meaning? Applicant thinks not and suggests instead i
' that Intervenor's continued insistence on this line of argument :
2 3 has as its main purpose the harassment of Applicant and' its ;
4 Staff. .
5 6 As to Intervenor's third point complaining that Appli- '
7 cant has not. extended the May 13, 1980 document data for the 8 Post-1979 period, the matter is moot. The requested data ap-9 pears on page 23 of Applicant's second set answers offered in 10 response to Intervenor's second set interrogatory no. 41 (Con-11 tention II).
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13 The remainder of Intervenor's motion is concerned 14 with Intervenor's interpretation.of the Board's orders, its 15 interpretation of the Staff's response, its conclusions on what
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16 it thinks the information it now possesses demonstrates, and its 17 hollow assertions ab,nt what information it contends Applicant ;
18 is presently withholding. Applicant has discussed the relevant I 19 matters above and has demonstrated that there is little merit 20 to Intervenor's arguments. Consequently, Applicant believes i
21 that there is no further need to- comment on these collateral 22 . matters.
23 24 III. CONCLUSION 25 i 26 For the reasons above, which are supported by explana , '
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1 tions contained in Applicant's previously filed memoranda on 2 this matter, Applicant respectfully requests that the Board deny 3 Intervenor's motion.
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5 Dated: May 28, 1981 6
DONALD L. REIDHAAR 7
GLENN R. WOODS CHRISTINE HELWICK 8
By 10 Glenn R. Woods 11 ,
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1 UNITED STATES OF AMERICA-2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 .
In the Matter of )
5 ) Docket No. 50-142 THE REGENTS OF THE UNIVERSITY OF ) (Proposed Renewal of Facility ,
6 CALIFORNIA ) License Number R-71)
)
7 (UCLA Research Reactor) )
8 .
DECLARATION OF WILLIAM H. CORMIER 9
10 I, WILLIAM H. CORMIER, declare as follows:
-11 1. I am an attorney licensed to practice law in the State of California and the UCLA Representative for the 12 Applicant, THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, in ~
the above-entitled action.
13
- 2. On three separate occasions I have arranged for, 14 and there has occurred, an examination of Applicant's records and documents by representatives of the Committee to Bridge ,
15 the Gap (CBG) , which records and documents were offered by Applicant in response to Intervenor CBG's first set of i 16 interrogatories relating to Contention II in the proceeding.
, 17 3. The records and documents which were made available
! for examination consisted of the following: general' ledgers '
18 of the University detailing Nuclear Energy Laboratory (NEL) financial transactions for the most recent five-year period of :
19 INEL operations and such supporting dc7umentation as was requested by CBG and was available; NEL Operating Logs, 1960 through 1980; 20 certain Specialized Activity Reports; certain NRC Annual Reports;
. and a current reactor operating schedule.
21
- 4. In connection with the above examination sessions 22 I.made arrangements to have an accounting officer of the 1 University explain to CBG the interpretation of thu financial !
23 documents and for the NEL Manager to be present at an Operating !
Log examination session to explain to CBG the interpretation of l
24 some typical log entries.
l j 25 5. Respecting the footnote remark appearing in l Intervenor's " Third Motion to Compel" (page 8) and contrary to 26 the suggestion made there, I personnally confirmed with the CBG ;
office on May 13, 1981, that the examination session I had i' 27 proposed by letter to occur on May 14 and 15 was acceptable and that I had made all the required arrangements. The confirmation 28 was made b' a telephoned message left on the CBG office message
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I ' (DECLARATION OF WILLIAM H. CORMIER; page 2) 2 recorder after my several earlier attempts to reach anyone in 3 l:the CBG office and my efforts to get my calls returned had' failed..
!I received a call on May 14 from one Wendy Schneckler i. spelling i 4 ! uncertain) who. identified herself as a representative of the CBG. She acknowledged my call of the previous day and stated 5 that she had only just discovered my message and that the team '
f CBG investigators would be unable'to make the examination
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6 scssion sche duled for that day or the r. ext. In response to her j inquiry I indicated that arrangements for the following week 7
could probably be made and, in fact, an' examination session did take place on May 21 and 22.
8 9 May 26, 1981.
Dated:
10 11 esv;/.
P William H. Cormier 12 UCLA Representative 13 THE REGENTS OF THE UNIVERSITY OF M IFORNIA 14 15 16 17 18 19 20 21 22 - -
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t 1 ;(DECLARATION OF SERVICE BY MAIL (CODE CIV. PROC. SS1013a & 2015.5) 2 I, the undersigned, say: I am a citizen of the United States,
' l 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 5 to the subject cause. My business address is 2214 Murphy Hall, 6 405 Hilgard Avenue, Los Angeles, California 90024. I served 7 the attached: APPLICANT'S MEMORANDUM IN OPPOSITION TO I
I g INTERVENOR'S THIRD MOTION TO COMPEL: REOUEST FOR 9 SANCTIONS 10 ;
i 11 by placing a copy thereof in a sep'arate envelope for each addressee !
named hereafter, addressed to each such addressee respectively 12 13 as follows:
14 SEE ATTACHED SERVICE LIST 15 ..
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18 Each enevlope was then sealed and with the postage thereon 19 fully prepaid deposited in the United
- States mail by me at ,
20 Los Angeles, California, on May 28, 1981 .
There is delivery service by U.S. mail at each place so j 21 - i 22 addressed or regular communication by U.S. mail between the place
. i 23 of mailing and each place so addressed. i l
24 I declare under penalty of perjury that the foregoing is true l 25 and correct.
Executed on at Los Angeles, California; 26 gg. 79, 1997
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I SERVICE LIST NRC Docke t No. 50-112 l I" '*
(UCLA Research Reactor) 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 H. Paris U.S.-Nuclear Regulatory Commission 7 -Atomic Safety & Licensing Board
, Washington, DC 20555 Counsel for NRC Staff 9 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission 10 Washington, D.C. 20555
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11 Daniel Hirsch Committee to Bridge the Gap .
12 1637 Butler Avenue, #230 ,
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Los Angeles, CA 90025 Mr. Mark Pollock ~
14 Mr. John Bay -
1633 Franklin Street * -
15 Santa Monica, CA 90404 .
16 Chief, Docketing and Service Section Office of the Secretary
~17 U.S. Nuclear Regulatory Commission Washington, DC 20555
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