ML20042C528

Confirms Agreement Re Scheduling & Discovery Matters. Intervenor Will Await NRC Answers by Battelle Consultants to Intervenor Interrogatories Before Discussing Dispute Re Contentions C16-24

ML20042C528
Person / Time
Site:	05000142
Issue date:	03/26/1982
From:	Hirsch D COMMITTEE TO BRIDGE THE GAP
To:	Woodhead C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20042C524	List: ML20042C523 ML20042C528
References
NUDOCS 8203310486
Download: ML20042C528 (2)

Text

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, n COMMITTEE TO BRIDGE THE GAP >

1637 BUTLER AVENUE #203 i LOS ANGELES, CALIFORNIA 90025 l (213) 478-0829 l March 26, 1982 i

Ms. Colleen P. Woodhead Counsel for NRC Staff '

U.S. Nuclear Regulatory Commission .

Washington, D.C. 20555 "" WR 30 N1 :0; In the Matter of i ,

s The Regents of the University of California < M

' (UCLA Research Reactor)

Docket No. 50-142 ,

(Proposed Renewal of Facility License) _ j l

RE: AGREEENTS AS TO CERTAIN SCHEDULING AND DISCOVERY MATTERS l

Dear Ms. Woodhead:

l This letter is to confirm certain agreements recently made between ,

Staff and Intervenor as to certain scheduling and discovery matters.

We have agreed to await submission by Staff of answers by its Battelle consultants to certain of Intervenor's interrogatories before l discussing further the dispute as to Contentions C16-24 Discussion of ,

the Cort and Staff answers of March 17 will likewise await the submission of the Battelle answers. Intervenar will review the Battelle responses  ;

and shortly thereafter Intervenor and Staff will confer as to any matters related to any of the interrogatory answers as to which concerns may remain. '

Intervenor and Staff will confer as to these matters prior to any motions to the Board, should disputes remain. ,

Additionally, when Intervenor and Staff confer as to these matters, the matter of whether and what discovery may be necessary regarding the  ;

recently-released Brookhaven analysis will be discussed. Deferral of these matters until the Battelle responses are served in no way waives either  !

party's rights to request relief from the Board should agreement not be  !

possible between the parties. i Finally, Staff some time ago agreed to an extension in time for i Intervenor to respond to summary disposition motions, when filed, due to  !

expected very extensive motions by Staff. I have contacted Mr. Cormier i in an attempt to ascertain how extensive Applicant' anticipates its motions,  !

if any, to be. He indicates Applicant is not decided at this time, and l although he has no objection to a reasonable extension, a more precise estimate j of the additional time reasonably required to respond to any summary disposition motions by Applicant cannot be made at this time. I indicated I would await moving the Board for an extension until Applicant is more.sure of its plans.  !

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8203310486 820326 PDR ADOCK 05000142 0 PDR i

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Applicant and Intervenor have likewise agreed to await attempting to determine certain scheduling matters, primarily related to the conclusion of discovery and beginning of summary disposition, until Applicant has served its Amendments to its Application and Intervenor had a chance to review those Amendments and conferred with Applicant as to any discovery that may be necessary thereto. You indicated by phone you had no objection to these scheduling matters awaiting service and review of the Amendments and the Battelle responses and conferring among the parties on these matters.

If the above description is not in agreement with your recollection of our discussions, please let me know. May I also suggest that we attempt to discuss similar matters that may arise by phone in oder to attempt to smooth out minor scheduling matters and not unduly buden the Board? I have made the same suggestion to Mr. Cormier in response to the " requests" he made of the Board in his March 15 discovery report.

In siimmey, we will be in touch shortly after we have had an opportunity to review the Battelle responses and will attempt to resolve the few remaining matters. I understand you expect those responses in the next few weeks.

Likewise, Mr. Cormier expects the Application Amendments in roughly the same time frame, after which he and I will confer as to remaining issues and implications of the new material.

A Cordially,

~ ~ ~ ~

Daniel Hirsch

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President COMMITTEE TO BRIDGE THE CAP cc: service list

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