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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
[Table view]
Category:NOTICES
MONTHYEARML20091G8411984-05-30030 May 1984
Notice of T Taylor & D Hafemeister Depositions on 840604 & 05,respectively.Certificate of Svc Encl.Related Correspondence
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
ML20084E7271984-04-27027 April 1984
Notice of Appearance in Proceeding.Certificate of Svc Encl
ML20066H4731982-11-16016 November 1982
Notice of Appearance in Proceeding.Declaration of Svc Encl
ML20071E6391982-06-29029 June 1982
Notice of Appearance in Proceeding
ML20071E6251982-06-29029 June 1982
Notice of Appearance in Proceeding
ML20052F3801982-05-0606 May 1982
Notice of Intent to Participate as Interested Municipality Per 10CFR2.715(c).Santa Monica City Council Resolution & Declaration of Svc Encl
ML20042B7241982-03-12012 March 1982
Notice of J Bay Change of Address
ML19337B0391980-09-26026 September 1980
Notice of Appearance in Proposed Renewal of Ucla Research Reactor License Proceeding.Certification of Svc Encl
1984-05-04
[Table view]
Category:OTHER LEGAL DOCUMENT
MONTHYEARML20097A1271984-09-0707 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
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
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
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
ML20197H3831984-06-14014 June 1984
Request to Withdraw License Renewal Application on Condition That Application Be Made to Decommission
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
ML20091G8411984-05-30030 May 1984
Notice of T Taylor & D Hafemeister Depositions on 840604 & 05,respectively.Certificate of Svc Encl.Related Correspondence
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
ML20084E7271984-04-27027 April 1984
Notice of Appearance in Proceeding.Certificate of Svc Encl
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
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
ML20088A2011984-04-0606 April 1984
Response to Applicant 840330 Rept Re Reactor Shutdown, Repair & Testing Schedule.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
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
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
ML20235Z3051983-12-23023 December 1983
Committee to Bridge the Gap Memorandum as to Status of Contention Xx (Security) Re UCLA Application for Renewal of Ol.Allegations of Three NRC Employees Made
ML20083A6601983-12-13013 December 1983
Position on Contention Xx.Aslb Should Clarify Specific Factual Matters in NRC Motion for Summary Disposition. Whether Univ Must Provide Protection Against Sabotage Is Only Issue.Certificate of Svc Encl
ML20082T4171983-12-13013 December 1983
Memorandum as to Status of Contention Xx (Security),Per ASLB 831123 Memorandum & Order.Declaration of Svc Encl
ML20080G7511983-09-14014 September 1983
Memorandum as to Committee to Bridge the Gap Witness Panel Composition,Per ASLB 830902 Memorandum & Order.Declaration of Svc Encl
ML20080L9551983-09-0909 September 1983
Response to Committee to Bridge the Gap 830830 Comments on IE Insp Rept on SNM Possession.Gap Alleged Discrepancies Based on Conjecture & Misinterpretation of Reported Info. Certificate of Svc Encl
ML20076H6481983-08-30030 August 1983
Response & Comment on IE SNM Inventory Insp Repts 50-142/83-02 & 70-0223/83-01.NRC Inventory Does Not Provide ASLB W/Sufficient Factual Basis to Establish Actual SNM Onsite.Certificate of Svc Encl
ML20071H0431983-05-13013 May 1983
Response to Judge Laurenson 830422 Order Re Contention Ii. Parties Stipulated to Witnesses & Exhibits.Summarizes Witnesses Testimony.Ucla Case Will Be Presented in 4 H. Certificate of Svc Encl
ML20073R2161983-04-29029 April 1983
Response to ASLB 830414 Order Detailing Licensee Legal Position Re Committee to Bridge the Gap Motion for Summary Disposition of Contention Xvii.Summary Disposition Should Not Be Granted.Certificate of Svc Encl
ML20069K6291983-04-22022 April 1983
Answer to Applicant 830412 Reply to Committee to Bridge the Gap 830404 Comments on Sabotage Consideration.Regulation to Authorize Specific Contention Unnecessary.Certificate of Svc Encl
ML20073C6841983-04-0707 April 1983
Memorandum Re Order of Presentation of Witnesses at Hearing. Objects to NRC Presenting Case Before Util.Proposal Would Be Improper Shifting of Burden of Proof from Util to Nrc. Declaration of Svc Encl
ML20073B7631983-04-0707 April 1983
Objections to Certain Scheduling Matters Detailed in ASLB 830323 Memorandum & Order.Allowing NRC to Present Case First Creates Appearance of Improper Shift of Burden of Proof. Declaration of Svc Encl
ML20072T5171983-04-0404 April 1983
Response to ASLB 830323 Memorandum & Order Memorializing 830223 Prehearing Conference.Motions for Summary Disposition of Contentions II & Xviii Should Be Dismissed.Burden to Show Absence of Genuine Dispute Not Met.Certificate of Svc Encl
ML20072U2171983-04-0404 April 1983
Memorandum Opposing UCLA & NRC Motions for Summary Disposition of Contentions II Re Class of License & Xviii Re Financial Qualifications & in Response to ASLB Concerns Re Contention Xix on Sabotage.Declaration of Svc Encl
ML20066H4731982-11-16016 November 1982
Notice of Appearance in Proceeding.Declaration of Svc Encl
ML20058J7971982-08-0606 August 1982
Response to NRC & UCLA Concerns Re 820712 Language Mods to Contention Viii Reflecting Proposed Application Amends.Basis for Contention Does Not Refer to 1982 Amended Application. Declaration of Svc Encl
ML20071E6251982-06-29029 June 1982
Notice of Appearance in Proceeding
ML20071E6391982-06-29029 June 1982
Notice of Appearance in Proceeding
ML20054H7681982-06-22022 June 1982
Identification of Subjs Upon Which City of Santa Monica,Ca Intends to Participate,Per ASLB 820604 Memorandum & Order. Declaration of Svc Encl
ML20054F3191982-06-11011 June 1982
Response to ASLB 820604 Order Re Release of Photographs. Proposes Alternative to Order Wherein Univ Would Retake Photographs Excluding Objectionable Physical Security Sys Features.Certificate of Svc Encl
ML20052F3801982-05-0606 May 1982
Notice of Intent to Participate as Interested Municipality Per 10CFR2.715(c).Santa Monica City Council Resolution & Declaration of Svc Encl
ML20052F2461982-05-0303 May 1982
Memorandum Re Addl Discovery Matters Per ASLB 820416 Memorandum & Order.Certificate of Svc Encl
ML20052F2491982-05-0303 May 1982
Memorandum Re Disposition of Photographs,In Response to ASLB 820416 Memorandum & Order.No Compelling Interest Supports Committee to Bridge the Gap Proposal for Unconditional Release of Photos.Certificate of Svc Encl
ML20052B6871982-04-26026 April 1982
Memorandum Re applicant-intervenor Disagreements Over Release of Intervenor Photographs,Per ASLB 820416 Memorandum & Order.Excerpts of Transcript of 820209 Discovery Conference Encl
ML20042B7241982-03-12012 March 1982
Notice of J Bay Change of Address
ML20009B8181981-07-0909 July 1981
Forwards Wh Comier Affidavit in Response to ASLB 810625 Order Re Article in Science
ML19337B0391980-09-26026 September 1980
Notice of Appearance in Proposed Renewal of Ucla Research Reactor License Proceeding.Certification of Svc Encl
ML19338D3611980-09-0909 September 1980
Certifies Svc of Response to Committee to Bridge the Gap Supplemental Petition to Intervene,On 800909
1984-09-07
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Text
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COMMITTEE TO BRIDGE THE GAP 1637 BUTLER AVENUE #203 LOS ANGELES, CAUFORNIA 90025 ctm (213) 478 0829 Iarch 12,1985 WR 23 P i .O In the Matter of h['~ . .
The Regents of the University of California - ),ic .
(UCLA Research Reactor)
Docket !!o. 50-142 (Pronosed Penewal of Facility License)
RE: CHAMCE CF ADDRESS II; SERVICE LIST To: A3L2, Parties, Docketing and Service Section Flease note that effective today, the address for Jchn lay should be changed from 2261 Columbia Street, Falo Alto, CA 94306, to 3755 Divisadero #203, San Franciscc CA 94123.
The current service list for Intervenor, thus, is:
COMMITTEE TO 3 RIDGE THE CAF 1637 Butler Avenue #203
- A Los Angeles, CA 90025 p John Bay #
3755 Divisadero #203 . gDEWEa San Francisco, CA 94123 2 of4gg -9 E; ISB2a.
% Ih $9am 10 Daniel Hirsch 74;c 44 Box 686 Ben Lonond, CA 95005 . ,
Y N ,
S c ely
$1$1F.irsch -
President l
i cc: service list
- Flease continue servin6 both the 3 ridge the Gap office in Los Angeles and,nyself in Ben Lonend (to which I shall return in a few weeks).
3
$$ga2gggf o%$8S g ggd G b k i
1
"- ' COMMITTEE TO BRIDGE THE GAP
{ -
1637 BUTLER AVENUE #203 LOS ANGELES. CALIFORNIA 90025 (213) 478-0829 7y..
Earch 12.1982 23 p t :a7 Es. Christine Heluick Office of the Cencral Counsel ,
590 University th11 la ,
2200 University Avenue Q((' ' _
Eorkeley, California 9f720 4
In the Intter of The Regents of the University of California (UCIA Research Reactor) boeket No. 50-122 4 (Proposed Rencual of Facility License)
RE: STIPULATION A3 TO RELEASE OF PHMOGRAFIG
Dear 1:
- s. Ecluick:
Enclosed please find a copy of the Interim Stipulation Ao To Release of Photographs as discussed in our last discovery conference.
We have reviewed the draft ecipulation you drew up and have made some ainor language modifications to bring the temporary stipulations into closer agreement with our understanding of the tentative agreements t reached at the di6covery conference.
Picaso sign where indicated and return to me. Wo will then sign and arrange to have it filed in this proceeding, expeditin6 the release of the negatives.
We would also appreciate you indicating when (or uhother) you in'.cnd to move the ASL3 for protective orders as to the two sets of photographs (those you have indicated complete objection to and those you have indicated conditional objections to release thereof).
Please note that our records indicate the total number of photographs in question are 217 those subject to the enclosed temporary stipulation are 196, Please feel free contact me at the abovo phone number if you have any questions.
S cerely, ,
lg.,l- LK Daniel Hirsch President Enc.
ces servico list e