ML20091B337

Interrogatories Re Security Contention.Certificate of Svc Encl.Related Correspondence

ML20091B337
Person / Time
Site:	05000142
Issue date:	05/25/1984
From:	Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:	COMMITTEE TO BRIDGE THE GAP
References
NUDOCS 8405300255
Download: ML20091B337 (8)

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'84 MAY 29 Pl2:25 CFF cE OF :t,;.. -

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket No. 50-142 THE REGENTS OF THE UNIVERSITY (Proposed Renewal of Facility 0F CALIFORNIA License Number R-71)

(UCLA Research Reactor) May 25, 1984

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UNIVERSITY'S IhTERROGATORIES TO CBG CONCERNING SECURITY CONTENTION PROPOUNDING PARTY: THE REGENTS OF THE UNIVERSITY OF CALIFORNIA RESPONDING PARTY: COMMITTEE TO BRIDGE THE GAP SET NUMBER: ONE DONALD L. REIDHAAR GLENN R. WOODS CHRISTINE HELWICK 590 University Hall 2200 University Avenue Berkeley, California 94720 Telephone: (415)642-2822 Attorneys for Applicant THE REGENTS OF THE UNIVERSITY OF CALIFORNIA B405300255 840525 PDR ADOCK 05000142 g PDR fC3

l University hereby requests the Committee to Bridge the Gap, pursuant to 10 CFR 92.740 and particularly s2.740(e)(1)-(3), to answer separately and fully in writing and under oath or affirmation the following interrogatories.

In answering these interrogatories, you must furnish all information as is known or available to you regardless of whether this information is possessed directly by you, your officers, members, agents, representatives, consultants, witnesses, or attorneys. Your answers should be numbered corresponding to the number of the interrogatory and, where applicable, its subparts.

If any of these interrogatories cannot be answered in full, answer to the extent possible, spsecifying the reasons for your inability to answer the remainder, and stating whatever information, knowledge, opinion, or belief you do have concerning the unanswered portion.

As used herein, " document" or " documents" refers to papers, photographs, tapes, and all other tangible things on which any handwriting, typing, printing, photostatic-copy, magnetic or electrical-impulse, or other form of communication is recorded or reproduced, including, but not limited to, letters, notes, diaries, correspondence, contracts, agreements, . files, records, reports, telegrams,' bulletins, memoranda, orders, invoices, brochures, maps, diagrams, agendas, minutes, studies, analyses, manuals, transcriptions, pictures, photographs, and. recordings, all notations on the foregoing, and all summaries thereof.

As used herein, " identify the document (s)" means provide for each document, the name and address of the person who presently has custody or control of the do_cument and each copy thereof; the nature and substance of the document with sufficient particularity to enable the l same to be identified; the form of the document; the date of the document; and the name and address of each person who drafted it or participated in its drafting. If the document to be identified is a document in the custody of the UCLA staff that has been made available to CBG, its witnesses or attorneys, during document examination sessions conducted in connection with this security contention proceeding, the l document may be identified by describing it as a "UCLA" document and indicating with sufficient particularity the nature of the document and the page or portion of the document that contains the information requested (for example, UCLA Security Plan, page 12-8; UCLA Security Log, entry of May 30,1984).

As used herein,. " depositions" refers to the May 10, 1984 depositions taken of CBG's witnesses Dr. Sheldon C. Plotkin and Mr. G.

Thomas Cornwell. To the extent that the opinion or conclusion of a witness, or the basis for such an opinion or conclusion, or other information requested in an interrogatory has not changed from the l information provided at the time of the depositions, the interrogatory

! may be answered by so stating.

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i Question 1 Has Dr. Sheldon Plotkin~ changed any of the opinions expressed in his deposition? If so:

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. (a) state each such opinion that has been changed; (b) explain the substance of the change made in the opinion; (c) identify each , document on which the change in the opinion is based; (d) specify the particular information in each such document on which the change in the opinion is based; and (e) explain how the information provides a basis for the change in the opinion.

Question 2 Has Dr. Sheldon Plotkin formed new opinions to be offered as part of his testimony which were not expressed in his deposition? If so:

(a) state each such opinion; (b) explain the facts on which the opinion is based;

, (c) identify each document which supports the opinion; (d) specify the particular information in each such document on which the opinion is based; and (e) explain how the information provides a basis for the opinion.

Question 3 Has Mr. G. Ihomas Cornwell changed.any of _the opinions expressed i s deposition? If so:

(a) state'each such opinion that has been changed;.

(b) explain the substance of the change made in the opinion; l

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.. (c) identify each document nn which the change in the opinion i is based; (d) specify the particular information in each such document on which the change in the opinion is based; and (e) explain how the information provides a basis for the change in the opinion.

Question 4 Has Mr. G. Thomas Cornwell formed new opinions to be offered as part of his testimony which were not expressed in his deposition? If so:

(a) state each such opinion; (b) explain the facts on which the opinion is based; (c) identify each document which supports the opinion; (d) specify the particular information in each such document on which the opinion is based; and (e) explain how the information provides a basis for the opinion.

Question 5 With respect to your Contention XX, do you contend that any of the UCLA response procedures are inadequate?

If so:

(a) identify each such response procedure you claim is  ;

inadequate; l

(b)describetheinadequacy; I

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. (c) specify the basis for the claim that the procedure is l

inadequate; and (d) identify each document on which you intend to rely in s'upport of the claim that the procedure is inadequate.

Question 6 Do you intend to offer any documents as evidence at tne security contention hearing? If so:

i (a) identify each such document and if the document is a UCLA document so state; (b) specify the particular information in the document on which you intend to rely; and (c) explain how you are relying on the information.

Question 7 Aside from Dr. Plotkin and Mr. Cornwell, identify each other witness who will testify.on behalf of CBG at the security contention hearing. As to each such witness provide the following information:

(a)name; (b) address; (c) statement of professional qualifications (if previously provided so state);

(d) the substance of the_ testimony to be provided by the witness; (e) identify each document on which the witness intends'to rely; ano

. .3 '* ' (f) specify the particular information in each such document l

. on which the witness intends to rely.

Dated: May 25, 1984.

DONALD L. REIDHAAR GLENN R. WOODS CHRISTINE HELWICK By  !'

WILLIAM H. CORMIER 3

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1 UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMISSION

%dEdE' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'84 lim 29 Pl2:25 In the Matter of _

Docket Nd H50-142 h THE REGENTS OF THE UNIVERSITY (Proposed Renenal#offFpdi]Tt'y" 0F CALIFORNIA ) License Number R-71)

) l (UCLA Research Reactor) ) l CERTIFICATE OF SERVICE I hereby certify that copies of the attached: UNIVERSITY'S INTERROGATORIES TO CBG CONCERNING SECURITY CONTENTION.

in the above-captioned proceeding have been served on the following by deposit in theon as indicated, United States mail,25,1984first this date: May class, postage prepaid, addressed John H. Frye, III, Chairman Mr. Daniel Hirsch Administrative Judge Cte, to Bridge the Gap ATOMIC SAFETY AND LICENSING BOARD 1637 Butler Avenue, #203 U.S. Nuclear Regulatory Comission Lcs Angeles, CA 90025 Washington, D.C. 20555

• Mr. John H. Bay, Esq.

Dr. Emeth A. Luebke Chickering & Gregory Administrative Judge Three Embarcadero Center ATOMIC SAFETY AND LICENSING BOARD Suite 2300 U.S. Nuclear Regulatory Comission San Francisco, CA 94111 Washington, D.C. 20555 Mr. Daniel Hirsch Mr. Glenn 0. Bright Box 1186 Administrative Judge Ben Lomond, CA 95005 ATOMIC SAFETY AND LICENSING BOARD U.S. Nuclear Regulatory Comission

• Nuclear Law Center Washington, D.C. 20555 c/o Dorothy Thompson 6300 Wilshire Blvd., #1200 Counsel for the NRC Staff Los Angeles, CA 90048 0FFICE OF THE EXECUTIVE LEGAL DIRECTOR U.S. Nuclear Regulatory Comissicn Ms. Lynn G. Naliboff Washington, D.C. .20555 Deputy City Attorney Attn: Ms. Colleen P. Woodhead City Hall

'1685 Main Street Chief, Docketing and Service Section (3). Santa Monica, CA 90401 0FFICE Oc THE SECRETARY ,

U.S. Nuclear Regulatory Comission Washington, D.C. 20555

• Express Mail \

WILLIAM H. CORMIER Representing UCLA  !

l THE REGENTS OF THE UNIVERSITY l 0F CALIFORNIA 1

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