ML20028D178
| ML20028D178 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 01/11/1983 |
| From: | Naliboff L SANTA MONICA, CA |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20028D173 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8301170205 | |
| Download: ML20028D178 (2) | |
Text
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1 ROBERT M.
MYERS City Attorney 2
LYNN G.
NALIBOFF Deputy City Attorney 3
]685 Main Street Santa ?!onica, California 90401 4
(213) 393-9975 ext. 321 5
Attornevs for CITY 0" SA::TA MONICA 6
l 7
8 UNITFD STATES OF A*1 ERICA 9
MUCLEAR REGULATORY CO?WISSION 10 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 11 12 In tne Matter of
) Docket No. 50-142 OL
)
13 TFC REGENTS OF THE UNIVERSITY ) (Proposed Renewal of Facility OF CALIFORNIA
)
License No. R-71) 14
)
(UCLA Research Reactor
)
15
)
16 17 18 CITY'S OPPOSITION TO MOTIONS 19 FOR SU"XARY DISPOSITION SUB-20 MITTED BY STAFF AND ADPLICANT 21 22 The CITY OF SANTA MONICA has reviewed the motions for summary 23 disposition filed by Staff and Applicant as well as the other 24 pleadings and documents on file herein.
Based on the record in 25 this case, it is the City's opinion that genuine issues of material l
26 fact exist with respect to each matter in contention in this i
27 proceeding.
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8301170205 830111 PDR ADOCK 05000142 C
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i 1 !These issues of material fact can only be resolved pursuant to a 2 : full hearing on the merits.
3 Should summar; disposition of any or all of the contentions 4
be granted, the City will be greatly prejudiced.
The City's rights
, ' 's 4 ipursuant to 10 C.F.R. 2.715(:7) come fully into play only at hearing, i
\\
1 6 at which time the opportunity to cross-examine witnosses becomes 7lavailable.
Without such opportunity, the Cit; cannot participate s
e !in this proceeding in a meaninaful wav 9
In opnosit ion to Sta f f 's and Applicant 's motions for summary 10 l disposition of Contention I,
the City submits the attached Affi-I 11 jdavit of Arden E. Wallum.
The Affidavit Indicates that the City 12 has productive groundwater wells located in the vicinity of the 12 lUCL; Nuclear Reactor, contrary to the assertions of Staff and 14 ; Applicant.
t i
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The Cit) of Santa Monica respectfully requests that the 16 lBoarddenythemotions for sunmary disposition filed by Staff and 17 Applicant so that the issues herein may be resolved pursuant to 18 ihearing on er merits.
I 19 j
23 DATED:
Januari 11, 1983 21 i
22 i
Respectfully submitted, 23 ROBERT M.
MYERS City Attorney 24 25 26 By pi tt il b.
4 [t[W -
^
i LYqiG. NALIBOFF
~
{
27 Deputy City Attorney
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25 l
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