ML20009C976

States Univ Position Re Intervenor Request to Qualify Hirsch as Expert Interrogator & Schedule for Summary Disposition Motions.Hirsch Qualifications Are Vague & Insufficient.Opposes Intervenor Request to Delay Proceeding

ML20009C976
Person / Time
Site:	05000142
Issue date:	07/16/1981
From:	Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:	Bowers E Atomic Safety and Licensing Board Panel
References
NUDOCS 8107220272
Download: ML20009C976 (2)

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UNIVEllSITY OF CALIFOllNIA, LOS ANGELES f ..-4.;

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OFFICE OF Tite Cll ANCELLOR LOS ANCELES CALIFORNIA tM102

, July 16, 198 V A g 3y-- _,,

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l 1 t;j Elizabeth S. Bowers, Esq., Chairman -

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Administrative Jtdge  !- C 31 + -

Atomic Safety and Licensing Board E- C Washington, DC 20555 l's Lm .ua $$flM co

!O In the Matter of D- ~4 koN a The Regents of the University of Californi 4 sD (UCLA Research Reactor) /s/ g i Docket No. 50-142 3 g L -

(Proposed Renewal of Facility License) -

JUL 3 3.19g7 i4 u.s. tocitAn armroar

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Dear Judge Bowers:

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In response to two matters pending before the Bod g , h /

the University's position is as.follows.

Intervenor's Request to Qualify Mr. Hirsch as " Expert Interrogator" We have had an opportunity to examine the additional in-formation provided by Mr. Hirsch regarding his qualifications.

In regard to Intervenor's request to qualify Mr. Hirsch as an expert interrogator we would like to point out that although we understood that Mr. Hirsch did not possess an advanced academic degree nor any degree at all in a science or field of engineering, we were unaware of the extent of Mr. Hirsch's technical and scientific training and experience. The Junc 30 statement of Mr. Hirsch suggests that his technical and scientific training and experience is at best very limited. Mr. Hirsch is vague about what science and engineering courses, if any, were part of his "Special Studies" program and he has not mentioned the subject matter of his "Special Studies" thesis. Mr. Hirsch states that his competency to address public policy questions requires "a deep immersion in the scien-tific and technical aspects of the policy questions (he addresses)."

Mr. Hirsch also states that the course he teaches is "interdisci-plinary in attempting to create an interface between the technical D503 s

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Elizabath S. Bowers page*2 July 16, 1981 and scientific information and skills necessary for making informed judgements about complex issues and the understanding of social theory as to how complex decisions are actually made in a society such as ours." Such statements are vague and insufficient in demonstrating that Mr. Hirsch is qualified to function as an expert respecting any single contention in this proceeding and certainly not all twenty contentions that have been admitted.

Schedule for Summary Disposition Motions In Mr. Pollock's memorandum of June 30, 1981 regarding

" Response to Applicant's ' Request for Change in Discovery Schedule'",

it is stated "As Applicant's request for discovery schedule change does not address summary disposition, Intervenor assumes that the stipulated agreement . . . remains in place. To wit: that summary disposition motions will be filed thirty days af ter answers are submitted to the second round of questions." '

However, the Board ruled on June 9, 1981, that " motions for summary disposition are not to be filed prior to July 30, 1981."

Applicant understands that ruling as meaning that such motions may be filed on or after July 30, 1981. We oppose Intervenor's implied request to further delay beyond the above date the beginning day of the period for filing motions for summary disposition.

Respectfully submitted, William H. Cormier UCLA Representative THE REGENTS OF THE UNIVERSITY

. Of CALIFORNIA cc: Service List f

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