ML20004C618

Request for Production of Documents Directed to Applicant. Documents Were Identified in Applicant Response to Intervenors 810420 Interrogatories.Certificate of Svc Encl

ML20004C618
Person / Time
Site:	05000142
Issue date:	05/26/1981
From:	Pollock M COMMITTEE TO BRIDGE THE GAP, POLLOCK, M.
To:	CALIFORNIA, UNIV. OF, LOS ANGELES, CA
References
NUDOCS 8106040337
Download: ML20004C618 (7)

Text

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Attorneys for Intervenor Con:n=3 TC 3RIncE sE CAP w . p/ %of U:il"ED STATES CF'

                                 !!UCISAR REGULATC3Y CCEMISSIC!*

M'thek 8 2EFCPS T E ATOMIC SATETY A:D LICE"SE!G 3 CARD N In the Matter of Docket I?o. 50-142 T3 RECE"TS CT THE U"IVERSITY (Proposed Renewal of Facility CF CALIFCR!!IA License !!o. R-71) , (UCIA Research Reactor) E"5RVE:iCR'S FCREAL FSGlEST FOR . PRCDUCIIC:' 3Y AFFLICAt:T CF C::RTAEi DCCUIC73 IDE"TIFIED I: RI37C"SE TO ITERVE:'OR'S APRIL 20,.1981 E;TERECCATORIES FRC?CC:'DE*C FAR*Y: CCEI" TEE TO 3 RIDGE TE CAP R23?C"Dr!G PAR *Y: PSGE"*3 CF TE U'iIVERSITY CF CALI7CR:'IA Intervenor, the Comnittee to 3 ridge the Cap, hereby formally requests Applicant, the Regents of the University of California, to produce for inspectionand/orcopying,asIntervenorchooses,certaindocumentsand specimens identified telow. The documents and specimens are ones identified by Applicant in response to Intervenor's A M 1 20, 1981, Inte=cgatories. Intervenor had asked in said Interrogatories whether Applicant would produce said documents absent a forral request for production. Applicant's response was that it was undecided at this time. Intervenor thus hereby subdts a fornal request for production of all docunents identified in answer to said Interrogatories, to wit l l

• current version of the UCLA Radiation Safety Handbcok

                  *ReactorSupervisor'srecordsidentifiedinresponsetoInte=ogatcryII/61

[ 810604033Q , 9l\\ e l , Cr

      *-

• lieso, UCD's Hicks tc likins,' June 26, 1975
• All ventilation drawings, blueprints, and plans for the Fath Science  !

3uilding and 3oelter Hall, including both original plans and plans for mjor alterations and additions. Ihese should include but not be limited to those drawings, blueprints and plans identified in responsetoIntoxrogatoriesVI/37candXV/7-10

• All "as built" architectural plans for 3oelter and Esth Sciences, including drawings and blueprints, and including both original plans, drawings and blueprints as well as those for major alterations and but not limited to those identified in response additions, including to Interrogatories XV /7-10

                            + Design criteria for the reactor building, as identified in response toInterrogatoryXV/lle                                                                               f

• Personnel dosimetry records, including but noty limited to those identifiedinresponsetoInterrogatoryIV/23
• Daily sales figures for all locations identified in response to t Interrogator /19 of part XV
• All documents identified in Attachment A (attached her to)  :

                              . of Applicant's response to Intervenor's Interro6atories of April 20; and all specimens therein identified.

i Should Applicant object tu providing any of the above documents, , Applicant should state its objection (s) individually and provide all documents to thich it does not object. Should an objection only go to l part of the informtion contained in the document, those parts that are l not objected to should be provided and the objection to providing the i remainer detailed.  : Intervenor's formal request for production of said documents in no way should be an indication that Intervenor believes that any interrogator /  ; I or interro6atories have been fully answered merely by the provision of said t i

j. documents. For should provision of said documents at this tine be seen  :

I

1) Intervenor notes that Applicant riegularly publishes in its annual f report annualized figures for personnel exposure, including identification l of said personnel by cane. Should Applicant nonetheless object to providing the more detailed scords sought because they are private medical records, -{'

          -             Applicant is requested to delete the names of.. individuals ard rrovide the records of exposure in that fash* ton.                                                                     l
          ._.. _               _    _ . . ,              _ _ . ~ _ . . _ _ _ _  . _ . . _ - . _ _ . _ _   _ _ . . _ _ . . _ _

1 3_ as limiting in any way Intervenor's discovery rights regarding docunent provision at-some future date. Intervenor notes that Applicant has offered a " rabbit" for inspection. Intervenor hereby requests that Intervenor's investigators be present when

                                                        'he specific " rabbit" for. inspection is selected,' and that choice of l

which " rabbit" is inspected be mutually determined, to insure that. the

                                                       " rabbit" inspected is representative of the " rabbits" ised.

Intervenor likewise notes that in Attachment A' Applicant nas identified operating lo6s. Although Intervenor has inspected some of these legs, it  : requests that all the logs be produced at the same time as the other doc. 2nts, for cross-reference purposes and because many of the operating logs which Applicant has seen to date were produced in response to' interrogatories  ; about the contention as to class of license. Since the adnission of that l contention other contentions have been admitted into the proceeding, and Intervenor wishes to review those same logs for discoverable material l relevant to the newly-admitted contentions.

                                                               -Intervenor suggests that the docunents and specimens in question be produced f:om 1:00 to 5:00 p.m. , June 3-5 and June 8-10.             should
                                                      - those times not be possibls for Applicant, Applicant should propose alternative dates for the earliest possible time when inspectier. can be arTanged.                                                                                                                      j Intervenor requests that Applicant's response as to dates of inspection
                                                      ~ be nade,. if possible, both by phone and rail.

If possible by phone, please contact Intervenor's investigators by calling Liniel Hirsch at o s _ _ _ . - - _ _ _ _ . _ _ _ _ _ _ . _ _ _ . m___ _. __ - _<, _ - , , , ,, - , . . . , , _ p,,,.,-_.. gm._ ,%.,..n y, g , ,.r . 3e, ,.%_,_.,_-.ey

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(213)478-0829. Fail shot 1d be directed to Attorney for Intervenor, Fark Pollock,1724 ". Ia Ires Avenue, Los Angeles, CA 90046, with a copy to Kr. Hi;sch, 1637 Eutler Avenue, Los Angeles, CA 90025 As there was some problem regarding a recent inspection of documents, wherein Intervenor did not receive confirmation of dates and location , of inspection room until.the day of the inspection, Intervenor requests that it receive notification of date and location at least two days.beforehand. Respectfully submitted. J -- F.azk Poll'ock rated: Pay 26, 1981 Attorney for Intervenor COMETTEE TO 3 RIDGE TF2 CAP 4 1 I a f 5 . 3 I L

9 EXHIDIT A g APPLICANT'S RECORD, DOCUMENT AND SPECIMEN LIST

1. Reactor operating logs, 1960 through 1980

2. Specialized Activity Reports ,

3. hRC Annual Reports

5. Committee Meeting Minutes:

a. Radiation Use Conunittee

b. Reactor Hazards Committee (until about 1971) i

c. Campus Radiation Safety Committee

7. Experimental Safety Analysis Forms

9. Visitor log

10. Inspection Reports (containing notices of violation, if any) '

a. Inspection Reports

b. Responses to notices of violation, if any 11.

Scram reports

12. Misc. Documents relating to Inspection Report 80-02

13. Misc. Documents relating to Amendments

14. " Failed Rabbit" Procedure

15. Reactor Use Authorizatior. Forms ,

16. Health physicist's log

17. Calibration Files (Misc.)  ;

20. Reactor Operator License File f

21. Requalification Log

22. Strip charts

24. Area film badge records l .

l 25. Neutron Monitor Manual

   , ,f         26. Film badge minimum detectable doses letter

27. Area Surveys

             ~

f

      ..                                                          EXHIBIT A page 2 l

28. Wegst to Curtis latter, December 3, 1980 '

29. Amendment 10 file

30. Special Reports to NRC

31. UCLA Hazards Analysis (1960) 1

32. General ledgers, 1960 through 1980

33. Health physicist's instrumentation file

35. Current Technical Specifications  !

b

36. Misc. maintenance and calibration records 4

37. Operating and radiological control procedures -(misc.) -

38. TLD data i

39. Maintenance log

41. Reactor drawings (misc.)

SPECIMEN: " Rabbit" Specimen  !

• I Applicant's records, documents and specimen offered in response to any of the interrogatories herein responded to f t

will be made available for examination at a mutually convenient time upon applicant's receipt of a request for production. . Arrangements can be made with applicant's UCLA representative. ' i I f l  : l i i

~

                               .                    UllITED STATES OF M4 ERICA UUCLEAR REDULATORY C0:UISSIDH BEFORE THE AT0 HIC SAFER AND LICEISIIG SOAg In the Matter of                     )
                                                            )               Docket No. 50-142 THE REDE;TS OF THE UNIVERSITI )                           .

0F CALIEDRNIA ) (Proposed Renewal of Facility

                                                            )                      License)

(UCLA Research Reactor) )

                                                            )

ChumCATE OF SERVICE I hereby certify that copies of "r3VE: 0R'S F02EAL RETJE37 FCR PRCDUCTIC* SY APPLICANT CF CEHrAE DCCUIG:TS IEE:TIFIED 2: RESPCI:SE TO IGRVC:0R'S APRIL 20, 1981, ICRRCCATCRIES" in the abo re-captioned proceeding have been  ! served on the following ty deposit in the United States l' ail, first class, this 26th day of Fay 1981 Elizabeth S. Bowers, Esq., Chairman Counsel for NRC. Staff .. .. Administrative Judge U.S. Nuclear Regulatory Conunission Atomic Safety and Licensing Boani Washington, D.C. 20555  : U.S. Nuclear Regulatory Commission

                                                                                        ~

l Washington, D.C. 20555 Docketing and Service Section Office of the Secretary Dr. Ersneth A. Lumbke U.S. Nuclear Regulatory Commission M-4n4 strative Judge . Wi-h4ngton, D.C. 20555 , Atomic Safety and Licensing Board ' U.S. Nuclear Regulatory Commission Rodger Holt, Esq. Washington, D.C. 20555

• office of City Attorney ,

200 North Main Street  ! Dr. Oscar H. Paris City Hall East, Room 1700 l Administrative Judga Los Angeles, CA 90012 Atomic Safety md Licensing Board  ; U.S. Nuclear Regulatory Cennaission Waehington, D.C. 20555 William H. Cormier, Esq. I Office of Administrative Vice  ! Chancellor 'l University of California M5 Hilgard Ave. ' Los Angeles, CA 90024 Christine Helwick, Esq. Glenn R. Woods, Esq. Office of General Counsel 2200 University Avenue 590 University Hall Berkeley, CA 94720 lV Mark Pollock Counsel for Intevenor ColGITTEE TO 3 RIDGE THE GAP

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