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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20091M8351984-06-0707 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 ML20091B3371984-05-25025 May 1984 Interrogatories Re Security Contention.Certificate of Svc Encl.Related Correspondence ML20028B4081982-11-24024 November 1982 Response to 821112 Request for Production of Documents on Contention Xxi.Certificate of Svc Encl ML20069L8421982-11-12012 November 1982 Request for Production of Certain Documents Re Contention Xxi.Declaration of Svc Encl ML20062G7391982-08-0909 August 1982 Response to Committee to Bridge the Gap 820720 Request for Production of Documents Re security-related Contention Xx. UCLA Will Provide Outlined Documents at 820812 Document Exam Session.Certificate of Svc Encl ML20062G8561982-08-0909 August 1982 Response to First Set on Interrogatories for Contention Xx. Certificate of Svc Encl ML20055B9301982-07-20020 July 1982 Request for Production of Documents Re Security Regulations Per ASLB 820630 Order.Certificate of Svc Encl ML20054F7531982-06-14014 June 1982 Request for Addl Info on Interrogatories 17,18 & 19 Re Fission Inventory & Heat Output After Shutdown ML20041E0841982-03-0303 March 1982 Supplemental Responses to Certain of Third & Fourth Sets of Interrogatories.Certificate of Svc Encl ML20005C0501981-11-0909 November 1981 Response to Applicant 810922 Followup Set of Interrogatories.Documentation in Support of Allegations of Inadequate Controls Discussed.Declaration of Svc Encl. Related Correspondence ML20010C5791981-08-14014 August 1981 Supplemental Responses to Certain Intervenor First & Second Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20009H0551981-07-30030 July 1981 Interrogatories & Request for Production of Documents Directed to NRC Re Proposed Renewal of Ol.Declaration of Svc Encl.Related Correspondence ML20005B5231981-07-0101 July 1981 Followup Interrogatories to Univ of CA Further Answers to Committee to Bridge the Gap First Set of Interrogatories. Responses Should Include All Info Available to Applicant. Certificate of Svc Encl ML20005B4781981-06-30030 June 1981 Answers to NRC 810610 Second Round of Interrogatories Re Proposed Renewal of License.Affidavit & Certificate of Svc Encl.Related Correspondence ML19347A3911981-06-11011 June 1981 Further Answers to Intervenor First Set of Interrogatories, Per ASLB 810529 Order.Certificate of Svc Encl ML19346A3511981-06-10010 June 1981 Third Set of Interrogatories Directed to Applicant Re Contentions I-X & XII-XXI.Certificate of Svc Encl.Related Correspondence ML20004C6181981-05-26026 May 1981 Request for Production of Documents Directed to Applicant. Documents Were Identified in Applicant Response to Intervenors 810420 Interrogatories.Certificate of Svc Encl ML19352A8801981-05-20020 May 1981 Answers Directed to NRC 810420 First Set of Interrogatories Re Experimental Vibrations.Certificate of Svc Encl ML19352A9681981-05-20020 May 1981 Response to Applicant First Set of Interrogatories.Info Addresses Contentions I Through Xxi,Save Contentions XI & Xvii.Certificate of Svc Encl ML19345H0641981-04-20020 April 1981 First Set of Interrogatories Directed to Intervenor Committee to Bridge the Gap Re Contentions I-X,XII-XVI & XVIII-XXI.Declaration of Svc Encl.Related Correspondence ML19345H0781981-04-20020 April 1981 Intervenor Committee to Bridge the Gap Interrogatories Directed to Applicant Re Class of License,Adequacy of Managerial & Administrative Controls & Contention Iv. Declaration of Svc Encl ML19341B4331981-01-22022 January 1981 Supplemental Answers of Regents of Univ of CA to Intervenor First Set of Interrogatories,Per ASLB 801222 Order.Addresses Interrogatories 4,5,6 & 9.Certificate of Svc Encl ML19343A9061980-11-14014 November 1980 Responses to Intervenor First Set of Interrogatories. Includes Info Re Percentage of Operating & Maint Devoted to Sales,Svcs & Research.Certificate of Svc Encl 1984-06-07
[Table view] 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
e C0KMITTEE TO BRIDGE THE GAP 11~/Y2'8ZD 1637 Butler Avenue, Suite 203 '[
Los Argeles, California 90025 (213)478-0829 82 My p p1 g f .
UNITED STATES OF AKERICA ' T 'c0 A Sr'iSb5
- MCH NUCLEAR REGUIATORY C0KKISSION BEFORE "WE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket No. 50-142 TE RECENTS CF THE UNIVERSITY (Proposed Renewal of Facility CF CALIFORNIA License No. R-71)
(UCIA Research Reactor)
RECUEST FOR PRODUCTION OF CERTAIN DOCUKENTS AS 'IO CON"JNTION IXI PROPOUNDING PARTY: CCEMITTEE TO EIDGE THE GAP RESPONDING PARTY: THE REGENTS OF THE UNIVERSITY OF CALIFORNIA Pursuant to 10 CFR 2.741, the Committee to Bridge the Gap hereby formally requests Applicant, the Regents of the University of California, to produce for inspection and/or copying, as CBG chooses, certain documents identified herein.
Should any of the documents herein not exist, or not be in the possession of the Applicant, Applicant should so specify and provide what documents are in its possession. Should Applicant object to any part of this request for production, Applicant should make its objection known substantially before the date set by the Board for said production, November 26, 1982.
8211180280 821112 I PDR ADOCK 05000142 0 PDR 3563
The documents to be produced are as follows:
- 1. The campus emergency plan, as identified at page IV/3-2 of the revised emergency plan included in the Application.
- 2. Written emergency response procedures associated with the plan identified in 1 above.
- 3. The procedures and lists, including draft procedures and lists, identified at page IV/ll-1 of the revised emergency plan.
- 4. All written procedures for responding to emergencies at NEL, other than those included in response to item 3 above.
- 5. Campus-wide evacuation drill records, including critiques thereof.
- 6. Evacuation drill records for Boelter Hall, including critiques thereof.
- 7. Evacuation drill records for NEL, including critiques thereof.
- 8. Documents regarding reactor room smoke alarm / detector and fire alarm / detector, including capabilities and calibration of said device (s).
- 9. NEL training curricula materials and exam questions thereon as to emergency response procedures and techniques.
- 10. Campus police department nuclear emergency response procedures.
- 11. Campus fire marshal NEL. fire response procedures.
- 12. Copies of emergency procedures as currently posted at NEL.
- 13. Emergency call and notification list and Emergency Directors call and notification list, as currently posted or possessed at NEL.
- 14. Previous versions of items 12 and 13.
- 15. Records of fires, explosions, toxic releases, water damage from flooding or pipe breaks, contamination incidents, and other emergencies that have occurred in Boelter Hall.
- 16. Reviews of Boelter Hall for compliance with local, state and federal fire-safety regulations.
- 17. Reviews and inspections by insurance company representatives for fire protection or other safety protection deficiencies at Boelter Hall
- 18. Records of inspections conducted at UCLA by local, state, or federal fire safety officials as to fire safety precautions at UCLA.
- 19. Records of fires at UCLA, including identification of causation, detail of damage created, and description of fire suppression response.
i 1 .
- 20. The NEL procedures handbook i 21. Radiation Use Committee minutes, January 1982 to date i
- 22. Campus Radiation Safety Committee minutes, January 1982 to date
- 23. 1981 NEL Annual Report
- 24. Fire Extinguisher check records for NEL, and other operability test records for other fire response equipment designed for use at NEL
- 25. All records of the July 28, 1982 Young Hall fire, including any inspection records and warnings or citations by inspecting authorities of the area involved in the fire prior to the event, j and any investigation records as to cause of fire and possible UCLA responsibility for the injuries suffered by the firefighters due to improper warning signs at the site.
, 26. Documents identifying the 8 violations of fire safety standards referred to by Acting Chemistry Chairperson Foote in the 8/5/82 Daily Bruin.
- 27. Documents detailing the investigation of other chemical storage areas at UCLA which the Daily Bruin of 8/5/82 indicated Dr. Wegst was planning to undertake.
i 28. All procedures and plans for fighting a fire involving the UCLA reactor, including methods to be employed.
- 29. All procedures and plans for responding to an emergency at the reactor at night or on weekends or during vacations, when NEL staff is not at facility.
- 30. Procedures and plans for emergency response at reactor if NEL Staff is not at facility and cannot be reached by phone or otherwise.
- 31. Documents identifying which NEL personnel are assigned " beepers" for emergency response when away from NEL and range (i.e. distance) of said devices.
- 32. 1982 operating log
- 33. NEL Emergency Response Log i 34. Radiation monitor and portable survey calibration records, January 1982 to present
- 35. Maintenance log or records, January 1982 to present, and ECOs, for the same period
- 36. internal audit for 1981, as required by Tech Specs
- 37. records of emergencies and emergency responses at NEL i
l
. i
_4_
- 38. Any correspondence by the LA Fire Department to the Regents, and vice versa, as to the 7/28/82 Young hall Fire, and any such correspondence as to NEL fire response procedures and agreements, other than " Attachment A" of emergency plan.
- 39. All documents identifying fire response procedures by LA Fire Department and LA County Department of Health Services in case of
- 40. All agreements with LA County Department of Health Services as to offsite emergency services to be provided in case of radiological emergency at NEL, including but not limited to fire.
- 41. Records of drills with Radiological Defense Officers of the LA County Department of Health Services as to response procedures at NEL.
- 42. Records identifying location of standpipes ar.d hydrants for fire fighting use in case of fire at NEL and nature and specifications of fire hoses and other fire response equipment at those locations.
- 43. Records of the training received by campus fire officials in fighting a fire involving a reactor or radioactive materials.
- 44. Procedures and analyses detailing how fire involving a Pu-Be source is to be responded to at NEL.
- 45. Procedures and analyses detailing how fire involving radioactive materials other than the reactor fuel or the Pu-Be source is to be responced to at NEL.
e 0
9 Unless otherwise identified above, records to be produced are for the period 1960 to the present. Records are to be produced for inspection beginning at 9:00 a.m. and continuing until 5:00 p.m.
on November 26, 1982. CBG will contact Applicant early in the week of November 22, 1982 to confirm the inspection and to indicate to Applicant the location at which the documents shall be produced.
Respec ful ub ted,
~/
Daniel Hirsch l
President Committee to Bridge the Gap dated at Los Angeles, CA November 12, 1982
', UNITED STATES OF AMERICA NUCLEAR REULATORT COMMISSION BEFORE THE ATOMIC SAFETI AND LICESING BOARD In the Matter of )
) Docket No. 50-142 THE REETS OF THE UNIVESITI )
0F CALIFORNIA ) (Proposed Renewal of Facility
) License)
(UCLA Research Reactor) )
)
nalARivION OF SERVICE I hereby declare that copies of 'L* QUEST FOR FRCDUCTION CF CERTAIN DOCoKENTS AS TO CCNTE: TION XXI" in the above-captioned proceeding have been served
, en the following by deposit in the United States rail, first class, this 12th day of November, 1982:
John H. Frye, III Chaiman Christine Helwiek Atonio Safety & Licensing Board Glenn R. Woods U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C. 20555 590 University Hall 2200 University Avesne Dr. Ehmeth A. Luebke Berkaley, CA 94720 A M nistrative Judgo Atonio Safety & Licensing Board Mr. John Bay U.S. Nuclear Regulatory Commission 3755 Divisadore f203 Washington, D.C. 20555 San Francisco, CA 94123 Dr. Oscar H. Paris Lynne Naliboff A M nistrative Judge Deputy City Attomer Atonio Safsty & Licensing Board City Hall U.S. Nuclear Regulatory Commission 1685 Main Street Washington, D.C. 20555 Santa Monia% CA 90401 Chief Docketing 'and Service Section Dorothy Thompson Office of the Secretary .6300 Wilshire Suite 1200 U.S. Nuclear Regulatory Comission Los Angeles, CA 90048 Washington, D.C. 20555 Counsel for NRC Staff U.S. Nuclear Regulato17 Consissica Washington, D.C. 20555 .
Attention Ms. Colleen Woodhead William H. Cormier l Office of Ad=4n4strative Vice Chancellor University of California
/ - '
405 Hilgard Avenue f 4, ~j Los Angeles, CA 90024 f ~
Daniel Hirsoh President CCBGEITTEE TO BRIDGE THE GAP
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