ML20084H495

Confirms 840428 & 0502 Telcons Re Facility Site Tour Per ASLB 840420 Order & Discusses Disposition of Committee to Bridge the Gap (Cbg) Expert Security Witnesses & Rl Kohn Appearance for Cbg.Related Correspondence

ML20084H495
Person / Time
Site:	05000142
Issue date:	05/02/1984
From:	Kohn R COMMITTEE TO BRIDGE THE GAP
To:	Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
References
OL, NUDOCS 8405080078
Download: ML20084H495 (6)

Text

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o g.gp cca WWU Roger L. Kohn, c/o Committee to Bridge the Gap 00t6gTf0 B utler Avenue, Suite 203 fob' Angeles, CA 90025 (213) 379-3956, (213) 478-0829

.g4 gy -7 P2:21 William H. Cormier, Esq.

Office of the AdministrativerVicVi Ch'ancellor UniversityofCaliforniilatCLyb2AnEMles 405 Hilgard Avenue Los Angeles, California 90024 In the Matter of THE REGENTS OF THE UNIVERSITY OF CALIFORNIA (UCLA Research Reactor)

Docket No. 50-142 ol-

@rocosed Renewal of Facility License)

Dear Mr. Cormier:

This is to confirm our telephone conversations of April 28 and May 2, 1984 concerning (1) the facility site tour per Board Order of April 20, 1984, (2) the deposition of CBG expert security witnesses, and (3) my appearance for CBG.

(1) Our witnesses can make themselves available with CBG attorneys for the site tour on your suggested date of Monday, May 7, 1984, at 7:00 am, at NEL. We will expect that we will be permitted to direct the tour and pace, where our witnesses so desire, that the whole day until 4:30 pm be available for the tour and document inspection, and that the tour include the following:

-reactor room;

-fresh-fuel (storage) room and suberitical facility;

-equipment room;

-third and eighth floors;

-key cabinet;

-phone lines and phone-line tunnels and communication lines to University police;

-power lines and backup power sources;

-doors, access ports, openings, crawl spaces, fences, and barriers, through or attached to the above;

-alarms, wiring and conduits, control panels and boxes, on-off and arming and testing controls and control stations where alarms are received or monitored, 8405080078 840502 PDR ADUCK 05000142 O PDR

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1 Mr. Cormier

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related or affixed to the above; and any other security items and NEL features which we are entitled to inspect but which we may not have specified in detail above as we tried to so do for your convenience.

We have also requested to inspect security documents, including but not limited to the following which, for your convenience, we are attempting to specify in some detail:

1. Security plan: (a)-current; (b) previous (all);

(c) amendments (all); and (d) all correspondence related.thereto, sender and recipient;

2. Inspection reports:

(a) by NRC; (b) by any other entities (regarding security);

(c) all correspondence re-lated thereto;

3. Notifications by the University to the NRC regarding security developments, occurrences, and problems;

4. Security audits;

5. Security logs, and records of all re-views and incidents;

6. All correspondence in the ' security files and that related to response'and de-

-tection;

7. Minutes of the Radiation Use Committee, security committee, and other committees on security matters;

8. Records of alarm installation, maintenance,-

repair, verification and testing, and any-problems related~to these;

9. Records and logs of keys, including issuance and return, and locks, includ -

ing installation, maintenance, repair, verification and testing, rekeying,-and-any problems related to these, and including locksmiths' records;

10. Wiring diagrams, mechanical-plans',

specifications, and records of instal-lation, maintenance, repair,,verifica-tion and testing, and. problems, regarding-

-intrusion' alarms,

-detection systems,-

-communication systems and. lines,- ..

-power sources and lines,

-doors, barriers, locks,.

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Mr. Cormier

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. May 2, 1984 1 and interlocks;

11. Records and' logs of watchmen, guards, police, and other security personnel and response forces, related to routine NEL security and non-routine incidents, '

whether logged by NEL personnel or others; and

12. All special documents related to Olympic security measures for or by NEL.

These requested items are to include all those for the-duration of the past license period, present, and future..

We view items 3. through 12. above as-within our i approved request for the security. file and. security log. We reiterate that we are entitled to inspect the University's se-curity files concerning NEL, and not merely Mr. Ashbaugh's security files. Thus, insofar as, e.g.,_ locksmith personnel, i

or the Facility Division, or the University police, or=the Chancellor's Office maintain files related to security and l locatable or filed or indexed to NEL activities, we-view 1 1 these as part of-the security files. That-is, CBG-regards j it as irrelevant that Applicant, the-Regents of-the University '

of California,.may have chosen to maintain.some security files at locations other than.NEL. We hope _that, as' attorney for_ Applicant, you will locate.and make.available-any such files not in fact located.in Mr.,Ashbaugh's files. If you-still object.to giving us access to_any such documents 1

developed, received or_ maintained.by1the Univer~sity, or to any of the items on the above-site or document list, please notify-me at least-one working day before1the tour' date so that we can place theLmatter before Judge Frye to- .

resolve.

4 We will-expect that you will supply us withicop'ies of the above documents that,we so designate,cor-that you

' give us continuing. access.to'all the above security information, at a minimum during all working 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />,-subsequent toLthe i

tour and~ document inspection.

-(2) . We--have scheduled lourLexpert' witnesses-to be=

available for depositions on your suggested.date of Thurs .

day, May.10, 1984-- Dr. Plotkin at.9:00.am, andLMr. Cornwell'.

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- at 1:00 pm.'AsTwe' discussed,1 our witnesses expect 1to beJ j' ' pai4 in advance of lthe- depositions, 'their usual and customaryJ fees as experts. Mr. Cornwell's rate is~$50/ hour with a minimum-of eight hours-($400)._Dr.-Plotkin's-fee is.$150--

each of the first three~ hours,i$100?for'each' additional-i- - hour'of travel or work, with a minimum off$600. We'would. -

~ expect that,'within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of receipt 1of this: letter, j you will inform meJoffyour, intent;tondepose orenot.JFurther,

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Mr. Cormier

' 'l Page four May 2,- 1984 3 if you do not notify me at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> before the scheduled a

depositions, Dr. Plotkin and Mr. Cornwell will expect to be paid their minimum fees for the time they have set aside.

(3) I have been accepted as associate counsel'for i CBG on Contention XX under the protective order, per' verbal i

order of Judge Frye on Friday, April 27, 1984 If you have not received written confirmation of that order, please verify it to your satisfaction with Judge Frye or John Bay in time for the site tour on Monday, May 7.

j Ver uly yours, y

,p p Roger L. Kohn of>~

, Attorney for Intervenor Committee to Bridge the Gap 1

j and Associate Counsel on 4

Contention XX 4

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RELATED CORRESPONDENCi.

UNITED STATES OF AMERICA  !

NUCLEAR REGULATORY COMMISSION 00LKETED U%RC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'84 MY -7 P2:21 in the Matter of )

) Docket No. 50-142 GFFICE OF SECRf.iA"'

THE REGENTS OF THE ) DCCKEigtgEP'lijt UNIVERSITY 0F CALIFORNI A ) (Proposed Renewal of

) FaciIity License)

(UCLA Research Reactor) )

)

DECLARATION OF G. THOMAS CORNWELL I, G. Thomas Cornwell, do declare as follows. I have been given a copy of the Protective Order issued by the Atomic Safety and Licensing Board dated January 18, 1984, and revised April 20, 1984 I have read i t and I agree to abide by its terms.

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

?!!A f19/LfY

" G. Thomas Cornwell Executed at 1 N*rfs , CA on this day of /[M , 1984 g - ,

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p,o NTED peggG UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00llfETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD U EC N HAY-7 p2 gy in the Hatter of ) o

) OocketNo.Skg .- UfSECHL1 THr REGENTS OF THE ) Il6}gg$c *;,n .

f UNIVERSITY CF CALIFORNI A ) (Proposed RenewalBR of NCh

) Facili t'y License)

(UCLA Research Reactor) )

}

DECLARATION OF DR. SHELDON C. PLOTKIN t , Sheldon C. Plotkin, do declare as follows. I have been given a copy of the Protective Order issued by the Atomic Safety.and Licensing Board dated January 18, 1984, and revised April 20, 1984 I have read it and I agree to abide by its terms.

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

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' Sheldon C. Plotkin Executed at de , CA on this M day of 1984

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