ML20004E560

Motion Requesting Permission for D Hirsch to Engage in Exam or cross-exam of Expert Witnesses

ML20004E560
Person / Time
Site:	05000142
Issue date:	06/03/1981
From:	Pollock M COMMITTEE TO BRIDGE THE GAP, POLLOCK, M.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20004E561	List: ML20004E560 ML20004E567
References
NUDOCS 8106120338
Download: ML20004E560 (2)

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(213) 876-4700 Attorneys for Intervenor /f U0CDC COEITTE TO BRIDGE THE GAP s ,

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UIETED STATES OF XERICA Ik . ,:,:

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NUCLEAR REUL,JtRI CCEISSION

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7 3EFORE THE ATCMIC SAFETY MiD LICS!STIG ECARD DI O In the Matter of ) Docket No. 50-142

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(Proposed Renewal of Facility THE REGETTS OF THE UNIVERSITY )

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) TOTION REQUESTING PIRESSION (UCLA Research Reactor) FDR EXAMINATION BY EXPERT,

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PURSUX;T TO 10 CFR 3 2.733 At the special pre-hearing conference on February 5,1981, Judge Bowers informed Intervenor of the regulations pemitting an individual to qualify as an " expert interrogator" to participate in examination or cross-examination of expert witnessas, and suggested that Intervenor consider whether it wished "to go that route or not" regarding Mr. Daniel Hirsch. TR, 328.

Pursuant to 10 CFR 2.733, Intervenor hereby requests that the presiding oiricer pemit Daniel Hirsch to engage in examination or cross-examination of expert witnesses, consonant with the Board's rules regarding " double-teasing" and such other rules as the Board may impose.

Permission for Hr. Hirsch's participation is sought for all Contentions ad=itted to date in the proceedings, with the exceptien or Contention .G l '

(" Inadequate Security"), for which no request is currently naae, pending Board's detemination of M camera procedures and protective order requests.

This action is requested at this time because depositisas =ay be taken in the near future for which Mr. Hirsch's axpertise would be useful in 0$

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attemoting to obtain a comprehensive record. Mr. Hirsch will be under the direction of Mr. Mark Pollock, counsel for Intervenor, who sill be responsible for his conduct.

Intervener asserts: (a) That Mr. Eirsch is qualified, by virtue of his scientific and technical experience, to contribute to the development of an adequate decisio.tal record in the proceeding by the conduct of examination or crosscexamination, (b) that he has committed to read any written testinony on which he intends to examine or cross-examine and any documents to be used or referred to in the course of examination or cross-examination, and (c) that he has committed to prepare himself to conduct a meaningful and expeditious examination er cross-examination.

An affidavit fron Mr. Eirsch is attached detailing his relevant qualifications.

As Interveno.- anticipates no objections from the other parties to this request-Staff having indicated by phone conversation with Intervenor's counsel that they anticipated no objection fmm Staff, and the Applicant in another setting .hsving approved Mr. Hirsch's competence in the general area by his academic appointment by the UCLA Academic Senate to teach j

nuclear and other energy natters as a Visiting Lecturer--no letters of 1

l recommendation nor affidavits of suppo:4. are included herein.

Should the Soard desire, or should unanticipated objections arise, numerous such letters and/or affidavits from nuclear physicists, engineers, i radiation biolo;;icts and others can be provided upon request.

Respec fully submitted,

'a2dlPollock

. Attorney for Intervenor Dated at Los Angeles, CA CC:OIITTEE TO 3 RIDGE THE G.G i

this 3rd day of June,1981 l

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