ML20010B164

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Forwards to Intervenor Attorney for Action Re Proposed License Renewal Which Responds to Directive in ASLB 810715 Order.Supplemented Response to Interrogatories Will Be Submitted by 810814.Certificate of Svc Encl
ML20010B164
Person / Time
Site: 05000142
Issue date: 08/03/1981
From: Cormier W
CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To: Bowers E, Luebke E, Parris O
Atomic Safety and Licensing Board Panel
References
NUDOCS 8108140173
Download: ML20010B164 (4)


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.O OFFICE OF Tile ClinCELIA)H LOS ANGELES CALIFORNI% 9xc4 j

August 3, 1981 Elizabeth S. Bowers, Esq., Chairman Dr. Emmeth A Luebke Administrative Judge Administrative Judge i

Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Washington, D.C.

20555 U.S. Nuclear Regulatory Commission 208) Q M

Dr. Oscar H. Paris Washington, D.C.

N Administrative Judge

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Atomic Safety and Licensing Board

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U.S. Nuclear RcJulatory Commission

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r In the Matter of

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s The Regent.s of the University of California h'

(UCLA Research Reactor)

M Docket No. 50-142 QTTg' (Proposed Reneval of Facility License)~

Dear Admin;strative Judges:

Attached is a copy of our letter to the attorney for the Intervenor in the above-entitled action responding to the directive contained in the Board's Order of July 15.

In the attached let.ter we inform Intervenor that we intend to submit supplemented responses to certain of Intervenor's first and second set interrogatories by August 14, 1981.

We trust that we have included in those proposed responses the questions to which the Board was referrin

.i s order of July 15.

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Respectfully submitted, AUG 7198'1 >

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William H. Cormier j

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E THE REGENTS OF THE UNIVERSITY D1 OF CALIFORNIA 03 cc:

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OFFICE OF TIIE CilANCELLOR LOS ANGELES, CALIFORNIA 90024 July 31, 1981 i

Mark Pollock, Esq.

Pollock and Willis 1724 North La Brea Avenue Los Angeles, California 90046 RE:

NRC Docket No. 50-142:

Status of Interrogatory Responses

Dear Mr. Pollock:

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In the Board's Order of July 15-(" Order Relative to Intervenor's Motion to Compel to Intervenor's Second Set of Inter-rogatories"), the Board directed UCLA "to inform CBG of its cur-rent effort to furnish further information and when it expects to be able to furnish same."

The following information is pro-vided in response to that Board directive.

j In our " Answers" of May 20, 1981, to Intervenor's Second i

Set of Interrogatories, we indicated that we would supplement our responses to the following questions (the roman numeral indicates the contention):

I.

17(d) to ( j ) ; II. 35; VI. 21; and XXI.

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29 (a), 36, 41 and 42.

In addition, in our "Further Answer 2" of June 11, 1981, to Intervenor'.s First Set of Interrogatories, we indicated in response to Interrogatory No. 6 that we would " con-tinue to pursue this matter and...(would) supplement _... (our).

answer accordingly."

i In our June 29, 1981 " Response to Intervenor's Motion l

to Compel" we acknowledged the inadvertent omission of several answers in our " Answers" of May 20, 1981:

II. 42 and 46; III. 20, 43(d) and 38; VI. 25 (a) ; and VII. 9 (c).

We also indicated that we would provide supplemental responses in an attachment

(" Applicant's i

Supplemental Responses to Intervenor's Second Set of Interroga-tories", dated June 29, 1981) to certain of our May 20 " Answers":

IV. 9 (a); VI. 8(c), 11(a), 40 (a), (c) and (d), 36 (a), 41(b) and 47 (a) ; and VIII. 7(d), 14 and 18 (a) to (h).

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Of the above questions, we-have yet to answer fully and/or supplement the following:

I.

17 (P J,. (i) and ' (1) ; III. 38; VI. 21; VIII. 14; XXI.

4, 29 (a), 36,.41 and 42; and Interrogatory No. 6 of Intervenor's First Set of Interrogatories.

Moreover, we have yet to answer those questions.respecting which the Board denied our request.for a protective order in the' Board's July 1,.1981 Order.

Except for.the Contention XXI questions, we intend to. submit our supplemented responses to all these questions by August 14, 1981.

As an administrative convenience we intend to consolidate all our responses in a single document.

The Contention XXI questions relating to hhe Emergency Response Plan cannot be answered until we ire able to clarify with the NRC technical staff what emergency response requirements are to appit' to our facility and to rewrite our: plan accordingly.

Only at that time will be be able to respond to your questions which ask, generally, how we intend to respond to certain emergency situations under the provisions of our. emergency plan.

i Very truly yours, I

William H. Cormier UCLA Representative THE REGENTS OF THE UNIVERSITY i

OF CALIFORNIA.

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UNITED STATES OF AMEPlCA NUCLEAR REGUIAIORY OCfMISSION 2

BEFORE ME WIMIC SAFLTI AND LICENSING BOARD 3

4 In the Matter of

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Docket No. 50-142 5

MIE REGENIS OF TE UNIVERSITY

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(Proposed Penewal of Facility OF CALIFORNIA

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License hbnber R-71)

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(UCIA Research Pcactor)

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8 ea<nrICATE OF SERVICE 9

I hereby certify that copies of the attached:

AUGUST 3 LETTER TO E.S.

BOWERS, ET.AL.

in the above-captioned proceeding have been served on tre following by deposit 8h in the United States.: ail, first class, postagc prepaid, addressed as in-dicated, on this date:

AUGUST 3, 1981 13 Elizabeth Bowers, Esq.

Counsel for NPC Staff U.S. Nuclear Regulatory Carmission Office of the Executive Ingal Director 14 Atanic Safety & Licensing Board U.S. Nuclear Recpilatory Ccmtission Washington, DC 20555 Washington, DC 20555 Dr. Ennath A. Luebke Daniel Hirsch 16 U.S. Nuclear Pegulatory Ccmnission Ccmnittee to Bridge the Gap Atanic Safety & Licensing Board 1637 Butler Avenue, #230 17 Washington, DC 20555 Ios Angeles, CA 90025 18 Dr. Oscar H. Paris Mr. Mark Pollock U.S. Nuclear Regulatory Ccmnission Pollack & Willis 19 Atanic Safety & Licensing Board 1724 M. La Drea Avenue Washington, DC 20555 Ios Angeles, CA' 90046 Chief, Docketing and Service Section (3)

Mr. Daniel Hirsch 21 O#fice of the Secretary c/o Quaker Center

.U.S. Nucler Regulatory Ccmnission P.O. Box 686 22 Washington, DC 20555 Ben Lomond, CA 95005 23 24 D],

25 Willi'a6 H. Cormier UCLA Representative 26

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