ML20071K977

Objects to City of Santa Monica Proposed Protective Order & Affidavit of Nondisclosure & Responds to Committee to Bridge the Gap 820712 Mods to Contention Language

ML20071K977
Person / Time
Site:	05000142
Issue date:	07/26/1982
From:	Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:	Frye J, Luebke E, Paris O Atomic Safety and Licensing Board Panel
References
NUDOCS 8208020289
Download: ML20071K977 (2)

Text

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UNIVEllSITY OF CALIFOltNIA, LOS ANGELES UCLA snuur non muu im smus nnensun . sss ima, COLKE.m sss e nm iu o f f($g\l sssis ninnins . sisis tat 2 7< ,

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%A OFFICE OF Tile Cll ANCELLOR IpF G CLOsANC 'p, CALIFOHNIA 90024 "Y' ="T ! % 5 EL -

BPJuly 26, 1982 John H. Frye, III, Chairman Dr. Emmeth A. Luebke Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and U.S. Nuclear Regulatory Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Dr. Oscar H. Paris Washington, D.C. 20555 Administrative Judge Atomic Safety and Licensing Board d.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of The Regents of the University of California (UCLA Research Reactor)

Docket No. 50-142 (Proposed Renewal of Facility License)

Dear Administrative Judges:

University wishes to inform the Board with respect to the following two (2) matters.

l City's Proposed Order and Affidavit i

University received City of Santa Monica's proposed Protective Order and Affidavit of Non-Disclosure, dated

! July 12, 1982, for use in connection with the discovery of l physical security information in the above-captioned proceeding.

! City's proposed order and affidavit appear to be identical to the order and affidavit proposed by CBG, except that part of paragraph EL of CBG's proposed order has been deleted in City's proposed order.

University objects to City's proposed order and affidavit. University has previously responded with its objections to CBG's proposed order and affidavit in a July 12, 1982 pleading, " University's Proposed Protective Order and Affidavit of Non-Disclosure for Discovery of Physical Security i

Information." Since the versions proposed by City and CBG are nearly identical, the objections and reasons explained in University's July 12th pleading should be considered fully l

applicable to the order and affidavit proposed by City.

l l 8208020289 820726 PDR ADOCK 05000142 G PDR SO3

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John H. Frye, III, Chairman Page 2 Dr. Emmeth A. Luebke Dr. Oscar H. Paris July 26, 1982 University does not intend to make any further response to City's proposed order and affidavit.

CBG's Modifications to Contentions Language University wishes to make only a brief response to the " modifications to contention language" submitted by CBG July 12, 1982.

Most of the modifications are editorial in nature and unexceptionable. However, the re-writing of Contention VIII retains reference to the 1960 Hazards Analysis, confusing certain assumptions allegedly made in that Analysis with what is or may be contained in the 1980 Safety Analysis Report, presumably, as recently amended. In the amendments to the application submitted this past June (as noted by University, the "4-30-82" amendments) the 1960 Hazards Analysis was withdrawn from the application and replaced by an amended Safety Analysis Report (to avoid confusion, the "1982 Safety Analysis Report"),

which incorporated by reference NUREG/CR-2079 and NUREG/CR-2198, the Argonaut accident analyses published in 1981. As modified, Contention VIII is ambiguous and imprecise in specifying the assumptions, if any, that are being challenged in the 1982 Safety Analysis Report.

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Respectfully submitted, l sa's -

William H. Cormier UCLA Representative cc: Service List

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