ML20031A441

Request for Production of Documents Directed to Applicant. Certificate of Svc Encl.Related Correspondence

ML20031A441
Person / Time
Site:	05000142
Issue date:	09/11/1981
From:	Pollock M COMMITTEE TO BRIDGE THE GAP, POLLOCK, M.
To:	CALIFORNIA, UNIV. OF, LOS ANGELES, CA
References
NUDOCS 8109230520
Download: ML20031A441 (5)

Text

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map coanEEPo~mENG NUCLEAR LAW CENTER 9/11/81 c/o 1724 North Ia Brea Avenue W

Los Angeles, California 90046 (213) 876-4700

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4 BEFORE THE ATOMIC SAFE"TY AND LICENSING BOARD g

In the Matter of Docket No. 50-142 (Proposed Renewal of Facility THE REGENTS OF THE UNIVERSITY License No. R-71) 0F CALIFORNIA INTERVENOR'S REQUEST FOR PRCDUCTION (UCLAResearchReactor) 0F CERTAIN DOCUMENTS BY APPL

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COMMITTEE TO ERIDGE THE GAP h = :2 9 RESPONDING PARTY:

REGENTS OF THE UNIVERSITY T CALIFORNIA 1 Q g y 7',

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Intervenor, the Committee to Bridge the Gap, hereby formally-reggag Applicant, the Regents of the University of California, to produce for inspectionand/orcopying,asIntervenorchooses,certaindocuments identified herein.

Should any of the documents identified herein not exist, or not be in the possession of the Applicant, Applicant should so specify and provide what documents are in its possession.

dhould Applicant object to any part of this request for production, Applicant should specify th3 objection and provide the material to which no objection is raised.

Intervenor is prepared to meet and confer with Applicant over any items which may require clarification or for which possible objections may be resolved among the parties without resort to motions to the Board.

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Intersenor proposes that the documents be produced for inspection from 1:00 to 5:00 p.m., Monday, October 19, 1981, or Tuesday, October 20 Should either of these dates be unacceptable, a mutually agreeatle time can be determined by consultation between the parties.

The documents requested to be produced for inspection and/or copying are:

1. The reactor supervisor's records identified in response to Interrogatory II/61 submitted by Intervenor on April 20, 1981.

These records were previously requested on 5/26/81, but Applicant's response of June 29 overlooks these particular records.

2. TLD report, Radiation Detection Company to UCLA, for exposure period forTLDdataafter5/31/81. Applicant's August 26 filing includ6d RDS reports through 5/313 please pro' vide any more recent TLD data.

3. NRC inspection reports, other than that of June 10, 1981, for period subsequent to November 14, 1980s in particular inspection report for inspection conducted during week of June 22, 1981.

4. On page 10 of Applicant's August 26, 1981, filing, it is indicated that in February, 1980, " Applicant contracted to have run a computer program called ORIGEN. 'Ihe program calculates fission product and actinide activity as a function of fission rate and time." Please produce the computer program, and all documents summarizing and/or detailing results of runs of said computer program.

5. In July 21, 1981 memorandum from N.C. Ostrander to W.F. We6st, regarding Update on TLD Results, a previous version of that memo is referred to.

Please produce said previous version.

6. All records on which document " Class Use of the UCLA Reactor" by C.E.

Ashbaugh, June 29, 1981, is based.

7. Documents, if any, detailing x/Q (dispersion) calculations and measurements besides the Rubin thesis, Battelle Study, SER, Application, or Amendment 10 records.

8. Documents from and ct.rrespondence with NRC, FEMA, state and local emergency agencies regarding reactor emergency plan.

9. Correspondence with and audits and reviews by Fire Eepartment as to prevention of and response to potential fire in Boelter Hall, including all documents related to fire-fighting procedures in case of such fire, particularly one potentially involving reactor.

10. Scholarly papers of which Applicant is aware publishing results cf research done utilizing the NEL reactor.

11. Course outlines fana the courses identified in the June 29 " Class Use of the UCLA Reactor" document.

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12. Correspondenes with and documents from airport and FAA officials as to plane and/or helicepter overflights near campus.

13. Correspondence with and documents (including maps) from water officials I

regarding wells on or near campus.

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14. Contamination and clean-up records for leaky Co and ha-Be sources, 1960-81.

15. Floor drawings of the NEL facility, if they exist, more accurate or more current that those contained in Application at pages III/4-4 and 4-5

16. ECO's, SAR's and other records 1960-1981 detailing ani analyzing changes in reactor shielding.

17. Any seismic analyses done of Boelter Hall.

18. UC Campus-wide building survey regarding earthquake vulnerability referred to at page 166 of Applicant's response to Interrogatory Set Two.

19. Time and effort reparting forms for present and past NEL Directors, as described at page 44 of Applicant's answers to Interrogatory Set Two.

20. Follow-up letters, to and from AEC, regarding the July 22, 1969, letter, Smith to Meris, regarding control blade problems.

21. All records of training exercises and drills for emergencies, including dates and evaluations, 1970-1981.

have been ma!ntained)g augmentation requests and responses (records of w

22. Records of fundin as per answer at page 175 of Applicant's Set Two responses.

23. Reviews of NEL "on the insis of the general contribution the program makes to the academic mission of the SEAS" as per answer on page 172 of Set Two responses.

24. " Shopping lists" as described at page 171 of Set Two responses for which formal or informal records or lists exist as to items for which l

NEL, 1970-1981, requested funding "in addition to what they can fund out of their base budget."

25. Base budget requests, 1970-1981, for NEL, ani responses thereto.

26. NEL budget, as approved and augmented, year-to-year, 1960-1981 i

(either summary document covering bottom-line budget total for the years in question, or the records from which such a summary can be made).

27. Records, proposals, publications, reports, or other documents detailing current research projects utilizing the reactor.

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28. Enrollment records for classes identified in June 29 report " Class Use of the UCLA Reactor) for all years prior to 1980-1 for which Applicant has records.

29. Records of the November 1979, January and May 1981 incidents at NEL involvingfloodingand/orspills.

30. Records of the summer 1979 pneumatic tube incident involving a sample

contsminating the pneumtic tube, followed roughly a week later by spill of liquid involved in cleaning the contaminated pneumatic tube.

Intervinor renews its previous request for the 1981 records of the documents Applicant offered in Attachment A of its Second Set Interrogatory answers.

Intervenor trusts those documents will be provided prior to Applicant's response to this current request, making this part thereof moot.

Should Applicant not be in possession of any part of the above 4

requests, it should merely so state an1 provide what it does possess.

Should Applicant have no additional documents relevant thereto, but believes part of the information can be found in documents already offered, Applicant should explicitly state it has no additional information and direct Intervenor to the relevant documenta previously offered.

Applicant is not required to create new records and documents, bat should produce those records and documents it possesses.

If Applicant is unaware of further documents beyond the ones it offers in response to this request, it should merely produce the documents of which it is aware and specify that those are the sole documents of which it is currently aware.

Respectfully submitted, f.

Jark Pollock Attorney for Intervenor Dated: September ll, 1981 COMMITTEE TO BRIDGE THE GAP

a UNITED STATES CF APERICA NUCLEAR REGUIATORY COMISSICN 3EFCRE '53 ATCMIC SAFETY AND LICEMSIG 3 CARD In the Matter of

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Docket No. 50-142 TRE REGRd CF THE UNIVERSI""?

CF CALIFCR'!IA (Proposed Renewal of Facility License)

(UCI.A Research Reactor)

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DECIARATICN CF SERVICE I hereby declare that copies of "INTERVENORdS REQUEST FOR PRODUCTION OF CERTAIN DOCUMENTS BY APPLICANT" in the above-captioned proceeding have been served cn the following by deposit in the United States mail, first class, i

this 12th day of September, 1981.

.,112abeth S. Bowers, Esq., Chairman Christine Helwick, Esq.

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Administrative Judge Glenn R. Woods, %q.

Atomic Safety and Licensing 3oard Office of Ceneral Counsel U.S. Nuclear Regulatory Commissien 590 University Hall Washington, D.C. 20555 2200 University Avenue 3erkeley, CA 94720 Dr. Emmeth A. Luebke Administrative Judge Counsel for NRC Staff Atomic Safety and Licensing Board U.S. Nuclear Regulator / Commission U.S. Nuclear Regulatory Commission Vashington, D.C. 20555 Washingtcm, D.C. 20555 l

Docketing and Serrice Section (3) l Dr. Oscar H. Paris Office of the Secretar/

Administrative Judge U.S. Nuclear Regulatorf Cormission Atomic Safety and Licensing 3 card Washington, D.C. 20555 U.S. Nuclear Regulator / Commission Washington. D.C. 20555 l

William H. Cormier, Esq.

Office of Administrative Vice Chancellor University of California 405 Hilgard Ave.

Los Angeles, CA 90024 WM bdw]k i

Wendy Sd(nelker

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