ML20028B408

Response to 821112 Request for Production of Documents on Contention Xxi.Certificate of Svc Encl

ML20028B408
Person / Time
Site:	05000142
Issue date:	11/24/1982
From:	Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:	COMMITTEE TO BRIDGE THE GAP
References
NUDOCS 8211300358
Download: ML20028B408 (7)

Text

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'02 NOV 29 mo:08 UNITED STATES OF AMERICA ;r- - _

NUCLEAR REGULATORY COMMISSION i

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket No. 50-142 THE REGENTS OF THE UNIVERSITY ) (Proposed Renewal of Facility OF CALIFORNIA ) License Number R-71)

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(UCLA Research Reactor) ) November 24, 1982

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UNIVERSITY RESPONSE TO CBG REQUEST FOR PRODUCTION l

DONALD L. REIDHAAR I GLENN R. WOODS CHRISTINE HELWICK 590 University Hall 2200 University Avenue Berkeley, California 94720 Telephone: (415) 642-2822 Attorneys for Applicant THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 1

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8211300358 821124 PDR ADOCK 05000142 O PDR -

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University responds to CBG's " Request for Production of Certain Documents as to Contention XXI", dated November 12, 1982 (The Request) as follows.

Except for documents objected to below, University will produce the documents requested at a document examination session to be held on Monday, November 29, 1982, from 1:00 to 3:00 p.m.

in Boelter Hall, Room 5750, and from 3 to 4:45 p.m. in 112 Physical Plant Building (601 Westwood Plaza), Room 212. The date suggested by CBG in its request, November 26, 1982, is a University holiday and is unavailable as a document examination date.

It is to be noted that several of CBG's specifically-numbered requests are satisfied by production of the same document or set of documents and the absence of a specific University objection does not imply that a separate and distinct document exists for my particular item in the request. University's search of its files is continuing. University reserves the right to produce after-acquired documents at a later date.

I University will photocopy documents as requested by CBG according to the procedures used at earlier document examination I

sessions in this proceeding. CBG will identify pages of documents to be copied by affixing a paperclip to the top of each page or set of pages to be copied making sure that there is an unambiguous

indication of whether or not both sides of a page are to be copied.

In addition, CBG should provide a list of documents and specific pages of documents it wishes copied.

To the extent that in any of its specific requests CBG seeks the production of documents of portions of documents that are unrelated to University's Emergency Response Plan and CBG's Contention XXI, University objects on the grounds that the discovery authorized by the Board is limited to contention XXI. With reference to CBG's numbered list of documents requested, University makes the following specific objection' and remarks:

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2. No such documents exist (the procedures are not distinct from the plan) .

5. No such documents exist.

6. No such documents exist.

7. NEL drill records for 1982 will be provided; drill records for earlier years were provided CBG at previous document examination sessions.

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8. The smoke alarms have not yet been installed and the specific device to be installed is not known at this time. A copy of the request made for the installation work will be produced.

10. No such documents exist.

11. No such documents exist.

15 and 16. University objects to these request on the grounds that they are not reasonably calculated to lead to the discovery of admissible evidence relevant to the adequacy of the University's Emergency Response Plan. Moreover, the requests are overbroad and unreasonably burden some in seeking the production of all documents concerning any incidents or inspections which may have occurred in all of Boelter Hall without limitation as to period of concern. Notwithstanding its objections, University will provide a file containing all records of incidents, inspections and sundry maintenance matters that have occurred in the Boelter Hall building in the past 5 years.

18 and 19. University objects to these requests on the grounds that they are not reasonably calculated to lead to the discovery of admissible evidence relevant to the adequacy of the University's Emergency Response Plan. Moreover, the requests are overbroad and unreasonably burdensome in seeking c'.1 records of fires which occurred at UCLA and all records of inspections conducted at UCLA.

20. University's procedures will be provided (see items 3, 4, 12 and 13 of the Request) but no specific NEL procedures handbook exists.

22. No information related to Contention XXI is contained in the two sets of campus Radiation Safety Committee minutes that have been prepared in 1982. University objects to this request on

the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence.

24. No such documents exist except for cards affixed to fire extinguishers which by law cannot be removed and which were identified during CBG's physical inspection of the facility.

25, 26, 27 and 38. University objects to these requests that relate to a fire that occurred in a chemical storage area of Young Hall in July, 1982 (the Young Hall fire) as not reasonably calculated to lead to the discovery of admissible evidence relevant to the adequancy of University's Emergency Response Plan.

28. University has no such documents.

31. No such documents exist.

36. No such document exists. The internal audit for 1981 is still in progress and the audit report is not expected to be available until after the first of the new year.

37. No such documents exist.

39. No such documents exist. The Los Angeles Fire Department's agreement to respond in the event of a fire at UCLA reactor facility is contained in a letter attached to the Emergency Response Plan and has been provided to CBG previously.

40, 41, 43, 44 and 45. No such documents exists.

Dated: November 24, 1982.

DONALD L. REIDHAAR GLENN R. WOODS CHRISTINE HELWICK

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N William H. Cormier UCLA Representative THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 5 -

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4 h UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket No. 50-142 THE REGENTS OF THE UNIVERSITY ) (Proposed Renewal of Facility OF CALIFORNIA ) License Number R-71)

)

(UCLA Research Reactor) )

CERTIFICATE OF SERVICE I hereby certify that copies of the attached: UNIVERSITY RESPONSE TO CBG REQUEST FOR PRODUCTION.

in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, postage prepaid, addressed as indicated, on this date: November 24, 1982 .

John H. Frye, III, Chairman Mr. Daniel Hirsch Administrative Judge Cte. to Bridge the Gap ATOMIC SAFETY AND LICENSING BOARD 1637 Butler Avenue, (203 U.S. Nuclear Regulatory Commission Los Angeles, CA 90025 Washington, D.C. 20555 Mr. John Bay, Esq.

Dr. Emmeth A. Luebke 3755 Divisadero (203 Administrative Judge San Francisco, CA 94123 ATOMIC SAFETY AND LICENSING BOARD U.S. Nuclear Regulatory Commission Mr. Daniel Hirsch Washington, D.C. 20555 Box 1186 Ben Lomond, CA 95005 Dr. Oscar H. Paris Administrative Judge Nuclear Law Center ATOMIC SAFETY AND LICENSING BOARD c/o Dorothy Thompson U.S. Nuclear Regulatory Commission 6300 Wilshire Blvd., #1200 Washington, D.C. 20555 Los Angeles, CA 90048 Counsel for the NRC Staff Ms. Lynn G. Naliboff OFFICE OF THE EXECUTIVE LEGAL DIRECTOR Deputy City Attorney U.S. Nuclear Regulatory Commission City Hall Washington, D.C. 20555 1685 Main Street Santa Monica, CA 90401 Chief, Docketing and Service Section OFFICE OF THE SECRETARY U.S. Nuclear Regulatory Commission Washington, D.C. 20555 WILLIAM II. CORMIER UCLA Representative THE REGENTS OF THE UNIVERSITY OF CALIFORNIA