ML20032B062
| ML20032B062 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 10/27/1981 |
| From: | Hirsch D COMMITTEE TO BRIDGE THE GAP |
| To: | Bowers E, Luebke E, Paris O Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20032B063 | List: |
| References | |
| NUDOCS 8111040341 | |
| Download: ML20032B062 (2) | |
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COMMITTEE TO BRIDGE THE GAP 1637 BUTLER AVENUE =203 00CKETED LOS ANGELES. CALIFORNIA 90025 USNRC (213) 478-0829 Cctober 27,1981.gj E 30 Pi:05 Ule.a Elizabeth S. Sowers, Chairman Dr. Cscar H. Paris OFFICE OF SECRETARY Adhinistrative Judge Administrative Judge 00CKEffNG & SERVICE Atomic Safety and Licensing Board Safety and Licensing 3oarjRANCH U.S. Nuclear Regulatory Commission /'
- N ear Regulatory Commission f
Washington, D.C. 20555 a4
, D.C. 20555
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Dr. En ath A. Luebke Is Adminis.rative Judge f.
NOVO 319ap 3cCxET 50-142 Atomic Safety and Licensing Board, u.s. euun amu,o.
PROPOSED REIEWAI/UCLA REACTOR U.S. Nuclear Regulatory Commission Washington, D.C. 20355 L
RE: PROGRESS REPORT ON EFFORT h%
OVERY DISPiJfES
Dear Administrative Judges:
As per your recent Czders, representatives of Applicant and Intervenor have met and conferred cn September 17, Cctober 16, and October 22 in attempts to resolve discovery disputes extant between the parties.
Agreement was reached on a number of issues, and progress made towards agreement on certain other issues. The parties will meet again on November 4, with at least one more discovery conference likely thereaf ter.
Intervenor and Applicant will serve responses to outstanding interrogatories on November 9 Should there be dispute about the adequacy of the responses, the parties will meet shortly thereaf ter in an attempt to resolve any such disaereements. Applicant has offered to product certain documents for inspection the week of November 9, although some dispute remains as to certain items requested to be produced.
Hopefully those disagreements will be resolved at the discovery conference on November 4 After reaching some tentative agreements as to Intervenor's two requests for permission to enter upon Applicant's facility for purposes of inspection, photographing and measuring, Applicant has indicated it will attempt to bring to the November 4 conference a proposal that may resolve the remaining disputes about the inspection requests.
Written stipulations have been drafted as to agreements reached at each discovery sessicn generally presented for signature at the subsequent conference, they have required some modification and/or consultation with, in the case of Applicant, counsel not present at the conference. To date, none of the stipulation drafts have been signed in final forms when they are, they will be forwarded to the Board.
However, because of the time delay involved between agreement reached at discovery conference and ng final signature on written stipulation, it is likely that, should agreement v
I be reached on Intervenor's requests for inspection of the UCLA facility, actual inspection will take place several weeks af ter initial agreement
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has been reached.
8111040341 811027 PDR ADOCK 05000142 C
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r3 Intervenor has placed on the agenda of these discovery conferences C0' [ 9 CE ithe af.'spute over whether Applicant has a duty to serve on Intervenor copies of Applicant-Staff correspondence. And Applicant has placed on the agenda certain suggestions it wishes to make regarding withdrawal or modification of Intervenor's contentions.
Intervenor and Applicant.will continue to meet and confer in order to resolve those disputes which can to resolved between the parties without necessity of Soard intervention. ' The Board will be kept apprised of progress towart resolving, these disputes.
With regards the dispute between Staff and Intervenor as to Intervenor's interrogatories to Staff, we are, as per Board Order of Cctober 13 and Staff's letter of October 14, in process of reviewing the interrogatories prior to the meeting and prioritizing the items in an effort to reduce their number. We have requested that the Staff, as per the Board Crder, review the interrogatories and recognize, prior to the meeting, those questice which are r.ccessary to furnish information for a sound decision and for which the information is not otherwise available.
We have also suggested that two other items be discussed at the Intervenor-Staff meetings service on Intervenor of Staff-Applicant correspondence (and notification of Staff-Applicant meetings), and the language, as admitted, of the contentions, due to the discrepanciec between the version Staff forwarded to the Board on September 2 and the language Intervenor understands as having been admitted. We trust the discrepancies are typographical or editorial errors and readily resolved.
As soon as Intervenor and Staff have conducted the reviews of the interrogatories directed by the Board to be done prior to meeting, a meeting will be arranged to attempt to reach a resolution on the matter.
The Board will, of couise, be kept informed of developments.
Respectfully submit)ed,
,Daniel Hirsch President COEMITTEE TO 3 RIDGE THE GAP
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