ML20004E175
| ML20004E175 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 06/10/1981 |
| From: | Woodhead C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | COMMITTEE TO BRIDGE THE GAP |
| References | |
| NUDOCS 8106110302 | |
| Download: ML20004E175 (5) | |
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UillTED STATES OF AllERICA (h
D NUCLEAR REGULATORY C0ril11SSlull 2
I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
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Docket No. 50-142
.THE REG 64TS OF THE V;1IVERSITY OF
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(Proposed Renewal of Facility
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CALIFORNIA License)
(UCLA Research Reactor)
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NRC STAFF SEC0 tid ROUND IrlTERR0 GAT 0 RIES TO INTERVENOR CBG The NRC Staff hereby requests the Intervenor, Committee to Bridge the Gap (CBG) pursuant to 10 CFR s 2.740b to answer separately and fully in writing and under oath or affirmation the following second round interrog-atories which refer to first round responses of CBG. The letters "SR" are added to the nuabers of first.round interrogatories to distinguish the two sets of discovery.
Tne Staff points out tnat the purpose of discovery is to avoid surprise dt hearing concerning the evidence which each party must be prepared to address.
To this end Staff directed its first round interrogatories and seeks clarifi-cation by the following second round questions.
The Intervenor's attention is again directed to 10 CFR 6 2.740(e)(1)-(3) which sets forth a duty to supplement certain responses to interrogatories upon acquisition of further knowledge.
8106 110 %
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General flatters Ques,+ ion A-SR
- a)
Ine original interrogatory asked for nanes, addr sas and professional e
qualifications of the person or persons upon am;>. sie.is Interveno-relies to substantiate each contention as well as toe persons whon Intervenor will present as expert witnesses at he3rio].
Your response to this question:
"No arrangements have yet been made by Intervenor regarding expert witnesses."
By this response do you mean that Intervenor he3 na evidence (docu-mentary or expert testimony) to present at hearing in supp3rt of any of Intervenor's contentions otner than the references red; in Intervenor's responses to Staff's first round interrogatories?
( b.' Since your fii st-round response merely referenced A-(a), is is cv ect tnat you nave no documentary evidence to support your contentions otor to q the following references cited in your first-round responses?
1.
Iiaterial already on the UCLA docket, such a.s tue UCLA application; C8G Supplemental Contentions, all IM Report: ru UCLA annual reports, correspondence, etc.
2.
UCLA ructor operating logs and financial records.
3.
WASH-740 and the ANL-5647 r2 port mentioned in response 50(b).
(b-1)
If not, please explain.
(d)
In light of your responses to A(a), (b), and (c), is it correct tnat the views and calculations contained in your firs:-ro;nd respanses are solely those of !!r. Hirsch oc 11r. Pollock?
P00R ORIGINAL
question 52-SR (a)
Please clarify your respcnse stating you do not contend (in Conten-tion VIII.1.ta.) that "tne SM assumption that reactor operation has been long enough to attain equilibriul concentrations of short-livej fission products i3 invalid" s i na que:,ti o, 5.: quotad frou jour contention, onitting only the poser level.
Res ectfully subnitted, G
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Colleen P. Woodhead Counsel for tiRC Staff Dated at Catnesda, Marf and l
tnis lutn u.if of June,19dl l
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UNITED STATES OF AMERICA
.w i fiUCLEAR REGULATORY COMMISS10fi
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BEFORE THE ATOMIC SAFETY AtlD LICEllSING BOARD in the Matter of
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Docket No. 50-142 In:. R &..Td 4 THE UaIVERSITi 0F
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CAL:F m IA
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Proposed Renewal of Facility
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License)
(U e Research Reactor)
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CERTIFICATE OF SERVICE I nereby certify that copies of "fiRC STAFF SEC0:4D R0utlD INTERROGATORIES Tu INTtRVEiiOR CBG" in the above-captioned proceeding have been served
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on tne folloaing by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the fiuclear Regulatory Comission's internal mail system, this 10th day of June,1981:
n Elizabetn S. Bowers, Esq., Chairman
- Mr. John Bay Administrative Judge 1633 Franklin Street Atonic Sofety and Licensing Board Santa Monica, CA 90404 J.S. kuclear Regulatory Commission Wasnington, DC 20555 Christine Helwick, Esq.
Glenn R. Woods, Esq.
Dr. Erneth A. Luebke*
Office of General Counsel Adninistrative Juage 2200 University Avenue Atonic Safety and Licensing Boara 590 University Hall U.S. huclear Regulatory Commission Berkeley, CA 94720 Wasnington, DC 20555
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Roger Holt, Esq.
Dr. Oscar H. Paris
- Office of City Attorney Administrative Judge 200 North Main Street Atomic Safety and Licensing Board City Hall East, Room 1700 U.S. Nuclear Regulatory Commission Los Angeles, CA 90012 Wasnington, DC 20555
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Mark Pollock, Esq.
Mr. Daniel Hirsch 1724 140. La Craa Avenue Comittee to Bridge the Gap Hollywood, CA 90046 1037 butler Avenue, #203 Los Angeles, CA 90025 Atomic Safety and Licensing Board Panel
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Uilliam H. Cormier, Esq.
U.S. Nuclear Regulatory Comission '1
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Office of Administrative Vice Washington, DC 20555 g.
Cnancellor
~~r University of California at W~
Los Angeles I
405 Hilgard Avenue f
Los Angeles, CA 90024 a
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.. - 9 Atomic Safety and Licensing Appeal t
.. Panel (5)*
U.S. Nuclear Regulatory Concission Washington, DC 20555
. Docketing and Service Section (7)*
Of fice of the Secretary U.S. Muclear Regulatory Co.uission Washington, 00 20355
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'f gyy' Colleen P.'
oodhead Counsel for NRC Staff i
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P00fi OftlGINAL gr N4
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