ML20052B692

Affidavit of ML Rose Re Facility Tours & Photographing

ML20052B692
Person / Time
Site:	05000142
Issue date:	04/21/1982
From:	Maret Rose AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20052B688	List: ML20052B687 ML20052B692
References
NUDOCS 8205030461
Download: ML20052B692 (10)

Text

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1 UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION 3

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4

1 5

In the Matter of

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THE REGENTS OF THE UNIVERSITY

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Docket No. 50-142

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(Proposed Renewal of 7

0F CALIFORNIA

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Facility License No. R-71 )

)

8 (UCLA Research Reactor)

)

April.2_/, 1982

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9

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10 11 AFFIDAVIT OF MICHAEL L. ROSE 12 STATE OF CALIFORNIA

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13 COUNTY OF LOS ANGELES

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14 I, MICHAEL L. ROSE, being duly sworn, depose and state as 15 follows:

1 16

1. I have twice requested permission to tour the UCLA nuclear 17 reactor.

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2. In both cases, I was permitted to tour the facility, and

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19 in both cases I was permitted to take as many photographs as I 20 wished.

No items or areas I wished to photograph were denied me; 21 No conditions were placed on my tour or my photographing; and, 22 in both cases,- I left the reactor facility with the exposed film.

23 No conditions whatsoever were placed on my use of said film.

4 24

3. The first occasion involved filming with a movie camera. I 25 shot two fifty-foot rolls of film, consisting'of, roughly, a total 26 of 6000 frames.

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4. During the movie filming, I was permitted to shoot in the l

2 control room and the reactor room.

Nothing I wished to shoot was 3 disallowed; no conditions were extablished or expressed.

4

5. During the movie filming in the reactor room, reactor 5

operator Charles Ashbaugh demonstrated how to remove shield blocks j

from the top of the reactor and how to remove material from the 6

7 reactor core.

I believe that he was demonstrating how to remove 8 fuel from the core in a fuel loading / unloading operation; however, 9 he could have been demonstrating how to remove samples from'the j

10 core.

In either case, Mr. Ashbaugh's voluntary demonstration 11 involved removal of some of the top shielding blocks and simulated 12 the removal of something from the core.

j 13

6. While in the reactor room, no attempt was made to prevent 14 my photographing any aspect of the security system for the reactor.

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7. I was not given a film badge for my tour.

I.

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8. The tour occurred simply by my showing up at the Nuclear 17 Energy Lab, requesting permission to film parts of the reactor 18 facility, and being allowed to do so.

'The NEL personnel were 19 most helpful in arranging for me to shoot the film.

This occurred 20 in the spring of 1979.

.21

9. In 1981 a friend and I went to NEL, asked for a tour and l

22 for permission to take still photographs, which was given.

On 23 this occassion I was given a film badge -but, again, no restrictions 24 whatsoever were placed on what we could see or photograph; We took i

25 photos of the control room snd of the reactor room.

We were allowed 26 to leave with the exposed film.

We still possess the negatives and 27 prints from that film.

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10. Although I am not certain of the exact date of my second 2

tour of the facility, one of the photographs we took on the day 3

of the tour shows a photograph of Daniel Hirsch, clipped from the 4

UCLA Daily Bruin, posted to a sign which reads " Caution, Pulserad 5

Firing;" Mr. Hirsch's finger points to part of the sign, which 6

reads, "Date: 3/27/81, Time: 8:30 a.m."

7

11. I have no security clearance.

I was not asked at any time 8

in either of the above-described tours to refrain from photographing 9

any area or item, nor to refrain from showing any of the photographs 10 or film to anyone else.

In short, no conditions whatsoever were 11 placed on my filming or photographing.

12 I declare under penalty of perjury that the foregoing is true 13 and correct.

14 Executed this day of April, 1982, at Los Angeles, 15 California.

16 Michael L. Rose 17 18 19 20 STATE OF CALIFORNIA

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' COUNTY OF

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oa before me.

3,e the undersigned, a Notary Public in and for said County and State, n,

FOR NOTARY SEAL OR STAMP personally appeared ti

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known to me F F i C I A *. C ; A '.

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to be the person whose name aubscribed to the n instrument and acknowledged tha' executed the

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Do ck et No. 50-142 THE R EIPS 0 THE UNIVERSITY

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N R-71)

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(UCLA Research Reactor)

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April 25 1982

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f DECLARATION OF WENDY SCHNELKER I, Wendy Schnelker, state as follows:

1 I. upon certain occassions, provide clerical assistance to the Committee to Bridge the Gap.

2.

I was provided, by Daniel 0. Hirsch, President of the Committee to Bridge the Gap, a copy of a tape of which he indicated was a recording of the February 9, 1982 discovery.

t conference between the Applicant and the Intervenor, and was asked to transcribe portions thereof,which I completed.

L 3

The transcript provided represents a true and accurate rendition of those sections of the tape to the best of my knowledge and belief.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on April 25,11982 ff ' ]AA, 3endy p hnelker

UNITED STATES OF AMERICA NUCLEAR REGULATCRY CCEMISSICN 3EFORE THE ATOMIC SAFETY AND LICENSING 30ARD In the Matter of Docket No. 50-142 THE REGEES CP THE UNIVERSITY (Proposed Renewal of CF CALIFCRNIA Facility License)

(UCLA Research Reactor)

April 26, 1982 DECLARATICN CF DANIEL O. HIRSCH I, Daniel 0. Hirsch, say:

1 I am the President of the Committee to 3 ridge the Gap, Intervenor in the above-captioned proceeding, and am currently representing C3G as a pro se, litigant.

2.

I participated in a discovery conference, on behalf of CBG, at which were present FM. Glenn Woods, Es. Christine Helwick, and Pt. William Cormier, all representing the University of California. Accompanying me were Es. Dorothy Thompson and Mr. Steven Aftergood. This conference took place at UCLA on February 9, 1982.

3.

At that conference, both parties audiotaped the meeting. This was done with the knowledge ard consent of both parties.

4 After the meeting was over, I took into my possession CEG's tapes of the meeting. They have been in my possession since.

5.

On April 25, 1982, I provided to Wendy Schnelker, a woman who provides clerical services to 3, the tapes from the above-mentioned conference and requested that shs transcribe certain portions thereof relating to the dispute between Applicant and Intervenor over Intervenor's photographs of Applicant's reactor facility. She did so.

6 The tapes provided to Es. Schnleker were true and accurate reproductions of the discussions that took place on the record on February 9,1982.

7.

I have, in my possession, clippings from various newspapers showing photographs of the UCLA reactor facility. These include the Santa Monica Evening Outlook of July 3, 1981, the Los Angeles Reader of August 7, 1981, the Los Angeles Times of Cetober 4,1979, the UCLA Daily Bruin of September 30, 1981, January 31, 1980, and May 30, 1979 8.

I have seen more than half a dozen television news stories about the UCLA reactor, all of which contained footage of the reactor facility.

I have videotape copies of several of these news broadcasts.

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! 9.

On April 23, 1982, one week after issuance of the Board's April 16 Memorandum and Order directing Intervenor and Applicant to report to the Board if they could not agree upon release of certain photographs of the i

facility, I received several phone calls from Ms. Susan Freedman, a reporter E

for KCETI-TV, the Public Broadcasting Service affiliate in Los Angeles.

Among other things, she told me that she had requested being able to film inside the Nuclear Energy Iab at UCLA but was told by NEL staffperson Neill Ostrander that she couldn't. The reason she was given by Mr. Ostrander, she said, was that CBG had a contention that UCLA's security wasn't good l

enough, and because of the NRC proceeding on their license NEL,had to stop permitting media to. film incide. She said she was told directly that if they let her film inside, they would have to let CBG do the same, and they didn't want to do that, so she couldn't film inside NEL.

10 I told Ms. Freedman we had been told just the opposite by UCLA--

l that CBG couldn't have free access to the photos we had taken, and particularly couldn't let the media see them, because UCLA has a supposed recent policy of prohibiting anyone, particularly the media, from taking photos inside NEL.

Ms. Freedman told me no, she was told just the opposite-that NEL wouldn't mind the media taking photographs, that what they were worried about was CBG taking photos, and to prevent us from being able they had to prohibit the I

media as well. Also, because of the security contention, NEL had to-until they got relicensed--take such measures, or else, she was told, CBG would 1

make an issue of it before the Board.

l 11.

I know of my own personal knowledge that Thomas Tugend, public information l

officer for UCIA, took roughly half a dozen television cameras on a tour of the UCIA rector on October 3,1979, because he interrupted a press conference i

in which I was participating and announced that he would take any media who wished into the reactor facility for filming. At least half a dozen television cameras and some still photographers went I saw that evening stories on several stations about the reactor.

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I declare under penalty of perjury that the f egoing is true and correct.

Executed on April 26, 1982.

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4 da ly bru n Volume CX, Number 4 University of California, Los Angeles Wednesday, September 30,1931 g 6Q Parking Battle over relicensing g' scarcer of reactor hingeson a*

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,t he prospects for parking on start writer 7u <

,.h campus, which hase neser been En The small nuclear research reactor, standing

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hours a weck, 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> per year. ~len feet of

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concrete surrounds the' reactor core, and a fl remain that way.

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handful of engineers monitor its use on the first

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computer run of parking appli-2 The Argonaut Nuclear Reactor has been

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Regulatory Commission's Atomic Safety and

~fhis y ea r's waiting list for y%]

I.icensing lloard could affect the fise other parking permits is the longest it campus reactors in California.

has been during the past fise or 2

Opposing the relicensing is the Committee to h;y six yea rs, llook said. " A p-plications are up by about 1.000 liridge the Gap, a I,200-member, non-profit,

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educational organization in West I.os Angeles, g a_muc.-gay 7;

g arking' permits are allocated l'he N RC has granted Ilridge the (rap q-on a point system. Applicants

ntervenor status, w hich enables them io submit e 4 gMD are awarded a predetermined legal questionnaires which the NRC must

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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION HEFORE THE ATOMIC SAFETY AND LICENSING BCARD In the Matter of Docket No. 50-142 THE RECElrTS OF THE UNIVERSITY OF CALIFORNIA (Proposed Renewal of Facility License)

(UCLA Research Reactor)

LECIARATION OF SERVICE FEECRANDUM TO TEE BOARD AS TO I hereby declare that copies of the attached:

APPLICANT-INTERVENOR DIaAGREEMENIS OVER REIEAM w Lucn.ci v.ra rnwu, NAPES and ATTACEMETS THEREIO in the above-captioned proceeding have been served on the followin6 by deposit in the United States sail, first class, poeta6e Prepaid, addressed as indicated, on this date: April 26,1982 John H. Frye, III, Chairman Christine Helwick Atomic Safety & Licensing Board Glenn R. Woods U.S. Nuclear Re6ulatory Conaission Office of General Counsel

$90 University Hall Dr. Emmeth A. Imebke 2200 University Avenue Administrative Judge Berkeley, CA 94720 Atomic Safety & Licensin6 Board U.S. Nuclear Re6ulatory Commission Mr. John Bay Washington, D.C. 20555 3755 Divisadero #203 San Francisco, CA 94123 Dr. Oscar H. Paria Mainistrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission vashington, D.C. 20555 Chief Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washin6 ton, D.C. 20555 Counsel for NRC Staff U.S. Nuclear Regulatory Commission Washington, D.C. 20555 attention:

Ms. Colleen Woodhead William H. Cormier Office of Administ:ative Vice Chancwllor

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University of California j

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405 Milgard Ave ue 4

CL Los Angeles, California 90024 President COMMITTEE TO BRIDGE THE GAP