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Category:AFFIDAVITS
MONTHYEARML20133Q2941985-10-30030 October 1985
Affidavit of Dj Kasun Re Question 3 in ASLB 851016 Memorandum & Order Concerning Effect of Release of UCLA Security Plan to Public on Security of Other Nonpower Reactors W/Similar Plans.Certificate of Svc Encl
ML20235Z3661984-03-0606 March 1984
Affidavit of MD Schuster in Response to Question Raised by Aslp in UCLA Proceeding in Aslp 840224 Order Re Physical Security Insp Repts to UCLA & Every Licensee Inspected
ML20083J2121984-01-0909 January 1984
Affidavit of Nc Ostrander Supporting Univ 830909 Response to Citizens to Bridge the Gap Comments on Fuel Inventory. Certificate of Svc Encl
ML20064K3781983-01-12012 January 1983
Affidavit of Do Hirsch.Shipment of Spent Fuel Left UCLA Control in Highly Contaminated Condition.Contaminated Shipment Released to Uncontrolled Area Due to Failure of UCLA Monitoring Sys to Detect Contamination
ML20064K0391983-01-12012 January 1983
Affidavit of Aftergood Re Contention I.Statement on P 5 of Application for License Renewal Re Educational & Research Uses of Reactor Is Materially False.Prof Qualifications Encl
ML20064K0601983-01-12012 January 1983
Affidavit of Sc Plotkin Re Contention I.Insufficient Info Provided in Application for License Renewal for Proper Review & Determination of Safety & Environ Impacts of Continued Operation.Prof Qualifications Encl
ML20064K1791983-01-12012 January 1983
Affidavit of Sc Plotkin.Maint & Calibr at Facility Inadequate.Reactor & Equipment Are Aged & Outdated & Parts Are Hard to Get.Facility Has History of Regulatory Noncompliance Including Violations of Safety Significance
ML20064K2961983-01-12012 January 1983
Affidavit of Sc Plotkin Re Contention Vii.Reactor History Shows High Degree of Operational Unreliability.Continual Failure to Rectify Repeated Instrumentation & Operator Errors & Failures Indicates Substantial Risk to Public
ML20064K3211983-01-12012 January 1983
Affidavit of Aftergood on Contention Viii.Two Categories of Accidents Examined Result in Extraordinarily High Doses in Unrestricted Areas
ML20064K4301983-01-12012 January 1983
Affidavit of Aftergood Re Contention Viii.Facility Could Be Converted from Using Weapons Grade Fuel to Low Enriched U,While Retaining Same Educational & Research Capabilities & Increasing Safety
ML20064K4401983-01-12012 January 1983
Affidavit of Sc Plotkin Re Contention Xiv.Thorough Analysis of Past Operating History of Other Argonaut Reactors to Identify Generic Problems Necessary
ML20064K4551983-01-12012 January 1983
Affidavit of Sc Plotkin Re Contention Xvi.Reactor Suffers from Old Age,Lack of Availability of Spare Parts & Inadequate Funds for Maint.Design Seriously Outmoded
ML20064K0171983-01-10010 January 1983
Affidavit of Wj Davis Re Inadequacy of Renewal Application. Submission of Irrelevant Matl Evades Fundamental Purpose of License Reappraisal.Prof Qualifications Encl
ML20064K4511983-01-0909 January 1983
Affidavit of Ma Pulido.Reactor Fire Is Credible Accident Scenario.Interaction of Bldg Ventilation Sys & Particular Configuration of Bldgs Around Reactor Could Lead to Great Public Radiation Exposure.Prof Qualifications Encl
ML20064K4591983-01-0909 January 1983
Affidavit of L Baefsky.Univ Attempt to Show Funding Available & NRC Review Thereof Insufficient to Show Availability of Continued Funding at Adequate Level for Reactor Needs
ML20064K1251983-01-0909 January 1983
Affidavit of L Baefsky.Accounting Summaries Do Not Reflect Shift from Emphasis on Educ & Research.Sixty Percent of Costs of Owning & Operating Reactor Are Devoted to Commercial Activity.Prof Qualifications Encl
ML20064K2011983-01-0808 January 1983
Affidavit of Ih Monosson.Reactor Facility Mgt Has Exhibited Chronic History of Noncompliance W/License Terms.Many Violations Are of Safety Significance.Prof Qualifications Encl
ML20028D1831983-01-0707 January 1983
Affidavit of AD Wallum Opposing Summary Disposition of Contention 1.Forty Percent of Water Used in Santa Monica Comes from Groundwater Wells.Several Productive Wells Exist within Vicinity of Reactor.Declaration of Svc Encl
ML20064K0741983-01-0707 January 1983
Affidavit of N Donova-Gantz.Records Available as of Spring 1980 Indicate Presence of Water Wells in UCLA Vicinity
ML20064K2571983-01-0707 January 1983
Affidavit of Le Foster.Results of Radiation Monitoring Program Established by UCLA Unreliable.Even If Data Was Reliable,Radiation Doses to Public Unacceptable from Safety Standpoint.Prof Qualifications Encl
ML20064K3391983-01-0606 January 1983
Affidavit of J Beyea.Release of 600 Ci I-131 Would Cause Doses W/Regulatory Significance Out to Distances of Many Kilometers & Even Further Depending on Weather Conditions. Certificate of Svc Encl
ML20064K2201983-01-0606 January 1983
Affidavit of B Norton.Amount of Excess Radioactivity Requested by UCLA Too High,Safety Margins Too Small & Potential for Destructive Power Excursion Unacceptable Due to Nearby Population Density.Prof Qualifications Encl
ML20064K2781983-01-0404 January 1983
Affidavit of I Lyon.Actual Emissions of Ar-41 Underestimated by Factor of Several Hundred for Over 15 Yrs.Actual Concentrations Exceed Max Permitted Conditions,Violating License Conditions & Regulations.W/Prof Qualifications
ML20064K4681983-01-0101 January 1983
Affidavit of M Kaku.Number of Credible Accident Scenarios for Reactor Exist,Each of Which Could Result in Substantial Fission Product Release to Environ.Prof Qualifications Encl
ML20064K4731982-12-23023 December 1982
Affidavit of Dr Dupont.Analyses Seriously Flawed in Assessment of Potential for Fire & Other Potentially Destructive Reactions in Reactor.Prof Qualifications Encl
ML20064K4041982-12-16016 December 1982
Affidavit of TB Taylor Opposing Application for Any Quantity of 93% Enriched U.Weapons Grade Fuel Not Necessary for Research.Prof Qualifications Encl
ML20064K3651982-12-15015 December 1982
Affidavit of El Cooperman Commenting on IE Insp Rept 50-142/82-01.Lapses Identified Have Safety Significance & Represent Serious Breaches of Good Radiation Safety Practice That Could Negatively Impact on Public Health
ML20064K4701982-11-17017 November 1982
Affidavit of Jc Warf.Statement Incorrect in Hazards Analysis That No Matls in Reactor Const Flammable.Graphite,U, Magnesium & Aluminum Combustible Under Certain Conditions
ML20064K3961982-10-17017 October 1982
Affidavit of H Scoville.Facility Should Use Low Enriched Fuel,Not U-235 at 93% Enrichment Which Is Weapons Grade Matl.U Enriched to 93% Is Extremely Sensitive & Must Be Carefully Safeguarded.Prof Qualifications Encl
ML20052B6921982-04-21021 April 1982
Affidavit of ML Rose Re Facility Tours & Photographing
ML20041F8861982-03-0202 March 1982
Affidavit of Do Hirsch Re Events of 820129 & Commissioner Roberts Alleged Ex Parte Contacts
ML20041F8931982-03-0202 March 1982
Affidavit of D Thompson Re Events of 820129 & Commissioner Roberts Alleged Ex Parte Comments
ML20041F8991982-03-0202 March 1982
Affidavit of AD Bosiago Re 820126 Events & Commissioner Roberts Alleged Ex Parte Contacts
ML20041F9081982-03-0202 March 1982
Affidavit of Wk Schnelker Re 820126 Events.Certificate of Svc Encl
ML20009B8201981-07-0909 July 1981
Affidavit Re Article in Science.Article & Declaration of Svc Encl
ML20004E5671981-06-0303 June 1981
Affidavit on Technical & Professional Qualifications. Certificate of Svc Encl
1985-10-30
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20247Q7371989-07-28028 July 1989
Order Authorizing Dismantling of Facility & Disposition of Component Parts
ML20211Q3021986-07-14014 July 1986
Order Authorizing Dismantling of Facility & Disposition of Components in Accordance W/Phase I of Dismantling Plan & NRC Rules & Regulations,Per 851029 Application
ML20205G6071985-11-0808 November 1985
Order Terminating Proceeding Since Committee to Bridge the Gap Withdrew Petition for Leave to Intervene.No Other Petitions Remain.Served on 851112
ML20205G6551985-11-0808 November 1985
Memorandum & Order Approving Parties 851010 Stipulation to Dismantle & Dispose of All Reactor Components & Equipment Except for Biological Shield & Components Described in Stipulation.Served on 851112
ML20133Q2781985-10-30030 October 1985
Response to ASLB 851016 Memorandum & Order Re Settlement Agreement & Proposed Order on Matters in Dispute Concerning Proposed License Renewal & Dismantlement Proceedings. Paragraph 6 of Proposed Order Should Be Revised
ML20133Q2941985-10-30030 October 1985
Affidavit of Dj Kasun Re Question 3 in ASLB 851016 Memorandum & Order Concerning Effect of Release of UCLA Security Plan to Public on Security of Other Nonpower Reactors W/Similar Plans.Certificate of Svc Encl
ML20133J0691985-10-16016 October 1985
Memorandum & Order Requesting Parties to Respond by 851030 to Listed Questions Re 851010 Settlement Agreement & Proposed Order Terminating Proceeding.Served on 851017
ML20108A9601984-11-13013 November 1984
Answer Opposing Committee to Bridge the Gap 841024 Petition for Hearing & Leave to Intervene.Petition Fails to Satisfy Requirements & No Good Cause Exists for Deferment of Ruling on Petition.Certificate of Svc Encl
ML20094A4741984-10-24024 October 1984
Petition of Committee to Bridge the Gap for Leave to Intervene & Request for Hearing Re Proposed Issuance of Orders Authorizing Disposition of Component Parts & Termination of License R-71.Certificate of Svc Encl
ML20097A1271984-09-0707 September 1984
Response to ASLB 840806 Order Part B.Prompt Shipment of SNM, Removal of Metallic Core Components & Prompt Dissolution of Protective Order Required by Order,Regulations & Public Policy.Declaration of Svc Encl
ML20097A0181984-09-0707 September 1984
Reply to Committee to Bridge the Gap 840801 Response Re Request to Withdraw Application.Aslb Should Approve Withdrawal of Application & Terminate Adjudicatory Proceedings.Certificate of Svc Encl
ML20096G8791984-09-0707 September 1984
Response to ASLB 840806 Order Re Other Parties Responses to UCLA Motion for Withdrawal of Renewal Application. Clarification of Ambiguities in Proposals Progressing.W/Svc List
ML20094C1371984-08-0101 August 1984
Response Opposing Staff Proposed Conditions for UCLA Withdrawal of License Renewal Application.Aslb Should Follow Required Practice Consistent W/Nrc Case Law.Certificate of Svc Encl
ML20093H9281984-07-20020 July 1984
Reply Opposing Committee to Bridge the Gap (Cbg) 840703 Response to Univ Request to Withdraw Application.Cbg Not Established as Participant in License Termination Proceeding.Certificate of Svc Encl
ML20093G1541984-07-20020 July 1984
Withdrawal of 840622 Emergency Petition for off-shipment of Reactor Fuel Prior to Arrival of Olympic Athletes.Petition Moot.Declaration of Svc Encl
ML20090C7851984-07-11011 July 1984
Response Opposing Committee to Bridge the Gap 840622 Petition for Commission Order to Remove SNM Prior to Olympics.Motion Lacks Factual Basis & Does Not Conform to Procedure.Certificate of Svc Encl
ML20092P2431984-07-0303 July 1984
Response Supporting Univ 840614 Request to Withdraw Application for License Renewal.Proposed ASLB Order Accepting Withdrawal Request Encl.W/Certificate of Svc
ML20151J9891984-06-25025 June 1984
Memorandum Explaining Reason Underlying 840622 Telegraphic Memorandum & Order Suspending All Further Proceeding. Licensee Has Shown No Desire to Retain Fuel Longer than Necessary.Served on 840626
ML20092G2821984-06-22022 June 1984
Emergency Petition for off-shipment of SNM from Site Before Olympics,Due to Withdrawal of Renewal Application & Security Risk Associated W/Olympics.Declaration of Svc Encl
ML20140C6651984-06-18018 June 1984
Order Canceling Contention Xx Evidentiary Hearings Due to Licensee 840614 Request to Withdraw License Renewal Application & to Decommission Reactor.Served on 840619
ML20197H3831984-06-14014 June 1984
Request to Withdraw License Renewal Application on Condition That Application Be Made to Decommission
ML20197H4051984-06-14014 June 1984
Motion to Suspend Proceedings Pending ASLB Action on Request to Withdraw Application.Hearing on Security Contention Should Be Canceled Immediately to Avoid Unnecessary Expense.Certificate of Svc Encl
ML20197G7651984-06-11011 June 1984
Motion to Compel Further Written Response of B Ramberg or for Alternative Relief & Costs.Committee to Bridge the Gap Has Not Revealed Documents Per Interrogatory Requests. W/Certificate of Svc.Related Correspondence
ML20091Q6071984-06-11011 June 1984
Objection to ASLB 840606 Notice of Evidentiary Hearing Specifying That Portions of Contention Xx Evidentiary Hearing Will Be Closed to Public.Only Portions Dealing W/Protected Info Should Be Closed.Certificate of Svc Encl
ML20091M8351984-06-0707 June 1984
Motion to Compel Committee to Bridge the Gap to Provide Further Written Answers to Questions 6 & 7 of Univ 840525 Interrogatories Re Security Contentions.Certificate of Svc Encl.Related Correspondence
ML20091G8411984-05-30030 May 1984
Notice of T Taylor & D Hafemeister Depositions on 840604 & 05,respectively.Certificate of Svc Encl.Related Correspondence
ML20091B3371984-05-25025 May 1984
Interrogatories Re Security Contention.Certificate of Svc Encl.Related Correspondence
ML20090J6721984-05-0909 May 1984
Response to Applicant Request for Reversal of ASLB 840413 Finding of Matl False Statements.Requests Hearing in Which Questions Unanswered by Two UCLA Responses Can Be Thoroughly Explored.Declaration of Svc Encl
ML20084H1991984-05-0404 May 1984
Notice of Disposition of Plotkin & Gt Cornwall on 840510 Re Physical Security & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence
ML20084F7061984-05-0101 May 1984
Estimate of Level of Threat Facing UCLA Reactor in Response to ASLB 840420 pre-hearing Conference Order.Facility Attractive Theft & Sabotage Target.Certificate of Svc Encl
ML20084F1971984-05-0101 May 1984
Declaration of Wh Cormier in Response to ASLB 840413 Memorandum & Order Re Questions About Apparent Misrepresentations Made by Univ & NRC
ML20084F1641984-05-0101 May 1984
Response to ASLB 840413 Order Directing Univ to Indicate Whether Any Representatives Had Reviewed Cormier 830825 Statements.No Representative of Regents Reviewed Statements Before or After Submittal
ML20084F1881984-04-27027 April 1984
Declaration of Nc Ostrander Re Review of Cormier 830825 Statements.No Member of Staff Requested to Review Documents Before or After Submittal
ML20084E7271984-04-27027 April 1984
Notice of Appearance in Proceeding.Certificate of Svc Encl
ML20084D0711984-04-25025 April 1984
Motion for Reconsideration & Clarification of Portions of ASLB 840420 Prehearing Conference Order Re Contention Xx. Certificate of Svc Encl
ML20084C4001984-04-24024 April 1984
Reply Opposing Applicant Motion for Reconsideration of ASLB 840322 Order & Further Suppl to Rebuttal.Source Term Issue Under Investigation Should Not Be Litigated in Individual License Proceeding
ML20084C4151984-04-23023 April 1984
Response to Committee to Bridge the Gap (Cbg) 840406 Motions for Reconsideration of ASLB 840322 Memorandum & Order Ruling on Cbg Objections to Rebuttal Testimony.Motions Should Be Denied.Certificate of Svc Encl
ML20088A0551984-04-0606 April 1984
Motion to Reconsider Portions of ASLB 840322 Memorandum & Order,Overruling Objections to Untimely Filed Rebuttal Testimony.Aslb Has Placed Interest in Complete Record Above Statutory Interests of Proceedings.W/Certificate of Svc
ML20088A1611984-04-0606 April 1984
Motion for Reconsideration of Certain Portions of ASLB 840322 Order.Only Penalty for Violation of ASLB Orders Is Further Delay & Continued License Possession,Precisely What Licensee Desires.Declaration of Svc Encl
ML20088A2011984-04-0606 April 1984
Response to Applicant 840330 Rept Re Reactor Shutdown, Repair & Testing Schedule.Certificate of Svc Encl
ML20088A6911984-04-0606 April 1984
Petition Per Reconsideration of ASLB Order Ruling on Committee to Bridge the Gap Objections to Rebuttal Testimony.Certificate of Svc Encl
ML20087D7111984-03-0909 March 1984
Response to ASLB 840224 Order Indicating Concerns on Security Plan & Security Insp Repts Re Sabotage Matters Raised by Contention Xx & Directing Univ & Staff to Respond by 840309.Certificate of Svc Encl
ML20235Z3661984-03-0606 March 1984
Affidavit of MD Schuster in Response to Question Raised by Aslp in UCLA Proceeding in Aslp 840224 Order Re Physical Security Insp Repts to UCLA & Every Licensee Inspected
ML20080N2431984-02-16016 February 1984
Motion Denying Committee to Bridge the Gap 740109 Motion for Reactor Curtailment.No Factual or Legal Basis Exists to Support Extreme Remedy Sought.W/Certificate of Svc
ML20080B7491984-02-0101 February 1984
Response Objecting to Applicant/Nrc Proposed Witnesses & Proposed Mod to Protected Order.Witnesses Do Not Qualify as Experts.Declaration of Svc Encl
ML20080B6871984-01-31031 January 1984
Response Objecting to Release of Certain Protected Info. Proposed Sanitized Portions of Security Plan Should Be Released Only to Qualified Witnesses.Certificate of Svc Encl
ML20079H8501984-01-20020 January 1984
Reply Opposing Applicant 840117 Request for 24-day Extension to Respond to Committee to Bridge the Gap 840109 Motion for Curtailment.Reasonable Extension Not Opposed.Certificate of Svc Encl
ML20079H4011984-01-17017 January 1984
Application for Extension of Time Until 840216 to Respond to Committee to Bridge the Gap 840109 Motion for Curtailment III (Irreparable Injury Associated W/Any Further Delay). Extension Will Not Delay Matters.W/Certificate of Svc
ML20079H3751984-01-17017 January 1984
Response to Committee to Bridge the Gap Memorandum Clarifying Contention Xx,Paragraphs 1,2 & 3.Committee Should Be Made to Respond to NRC Motion Re 10CFR73.67. Certificate of Svc Encl
ML20079J1881984-01-16016 January 1984
Review of UCLA Analysis of Facility Shutdown Mechanism. Postulated Power Excursion Will Not self-terminate as Assumed by Expulsion of Water Out Top of Fuel Box Region Through Surrounding Brick Walls
1989-07-28
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Text
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UNITED STATES CF APERICA NUCLEAR FIGUIATORY CCEISSION 3EFORE THE COMMISSION In the .va tter of Docket No. 50-142 THE RECENTS CF THE UNIVERSITY (Propossd Renewal of 0F CALIFORNIA Facility License No. R-71)
(UCLAResearchReactor) M 2, 1982 AFFIDAVIT OF ANDREW DANIEL 2ASIAGO STATE CF CALIFORNIA ss.
COUNTY CF LCS ANGELES I, ANDREW DANIEL 3ASIAGO, being duly sworn, depose and state as follows:
- 1. On Tuesday, January 26, 1982, I proceeded in my role as an investigative reporter for the UCIA Daily 3 ruin to the 3celter Hall office of School of Engineering and Applied Sciences Dean Russell O'Neill.
I had been informed the previous afternoon that a tour of the Argonaut nuclear reactor facility was scheduled between UCIA legal representatives, NRC d ficials, and the Committee to Bridge the Gap. I entered O'Neill's office at 9:15 a.m.
- 2. I encountered UCIA atterney William Cormier,whom I had met previously, in the out er office of the engineering dean. Carmier angrily e am informed me that the campus press would not be invited en the tour and ou "that this is not a media event." He seemed consternated by my very "8 presence, and anxiously made two phone calls in my presence within a minute g or two of encountering me.
R At 9:20 a.m., two men and a woman arrived and met with Cermder.
- s:0 3 o" Cormier's demeanor was that of an affable hest and I remember thinking gg his attitude reminded me of that of an auto dealer.
oo o .3 4 Cormier intreduced the ::1 o to the dean at ti.e door to his
@7 private office and the group met behind closed decrs until at least 9:45 a.n.,
when I left with 3 ruin photographer Andy Schlei and C3G member Steve Aftergood, who had arrived a few minutes earlier, to proceed to the reactor to see what pictures and comment we could obtain even if we would te excluded from the tour. Schlei left our company in transit to the reactor. Pricr to
leaving the dean's office, Tom Tugend, university public information officer, emerged from the room where the meeting was being conducted ard said that Dean C'Neill did not want any press on the tour.
5 At the entrance to the Argonaut Reactor /Tokomak Fusion Iab facility I met CBG president Daniel Hirsch ard KNXT Correspondent Kim McTiner and told them of the meeting I had witnessed. The group gathering at the reactor entrance expressed concern as to the whereabouts of Mr.
Cormier and the NRC Staff. Dorothy Thompson informed me that such a meeting was a possible violation of ex parte procedure.
- 6. P.eceding the tour, the female present during the earlier meeting was identifisi as Jessica Iaverty. Mr. Cormier and the woman I had seen upstairs in the Dean's office came out of the reactor room ani talked with Daniel Hirsch ard Dorothy Thompson. The woman was then identified as Jessica Laverty. NRC Commissioner 'Ihomas Roberts was not visually revealed to the press, and the third man has never been identified.
- 7. Following the tour, I confronted Mr. Cormier with the facts of what I had seen earlier in the morning. I asked Mr. Cormier, "Do you deny I saw you meet with the NRC team this morning in Dean O'Neill's office?" Cormier resporded, "No. But it was only a greeting, not a meeting." Iater, Mr. Hirsch told me Cormier said the greeting lasted between 9:50 and 10:00 a.m. This conflicts with reality as I recorded it, for I am certain I witnessed a longer discussion from at least 9:20 a.m.
to 10 a.m.
- 8. Iater I spoke with Dean O'Neill in person. Dean O'Neill confirmed that the meeting had occurred, ard indicated that among the subjects discussed was enrollment in Engineering classes ard the crisis in financing. - -
Executed this O day of 1%rch 1982 at Los Angeles, California.
LA*W p ew Daniel 3as o Sworn and subscribed to before me this 2 day of March 1982.
(* e ~
Of FICIAL SEAL f
O .N gP.Q V % , @* '1 DOROTHY THCMPSCN g gg -
,g 29 No3W DUauc CAL!romNIA
, LOS ANGELES CO?:fGY fly c::::. l. mies FE3 21,1934,
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