ML20091G841

Notice of T Taylor & D Hafemeister Depositions on 840604 & 05,respectively.Certificate of Svc Encl.Related Correspondence

ML20091G841
Person / Time
Site:	05000142
Issue date:	05/30/1984
From:	Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:
References
NUDOCS 8406040380
Download: ML20091G841 (5)

Text

~NMS o ..

to coRRESPON 00gTED

'84 JtN -4 All :12

.:n,,- ,

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 30, 1984

)

NOTICE OF DEPOSITION AND REQUEST FOR PRODUCTION DONALD L. REIDHAAR k GLENN R. WOODS g 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 i [E O a

o NOTICE IS HEREBY GIVEN, pursuant to 10 C.F.R. 52.740a, to s

intervenor Committee to Bridge the Gap (CBG) and its attorneys John Bay, Roger Kohn, Dean Hansell, and Dorothy Thompson, that University requests the appearance of CBG witnesses DR. THE0DORE TAYLOR and DR. DAVID HAFEMEISTER at depositions to be taken on June 4-5, 1984. The deposition of Dr. Taylor will begin at 8:30 a.m. on June 4, in room 3125B Murphy Hall on the UCLA campus. The deposition of Dr. Hafemeister will begin at 8:30 a.m. on June 5, in room 2211 Murphy Hall on the UCLA campus. The deposition will concern matters relating to the physical security of the UCLA research reactor facility, threats directed against the UCLA research reactor facility, matters relating to claims in CBG's Contention XX of the above-entitled proceeding, and matters relating to any information upon which said witnesses will rely or may be expected to rely in providing testimony at the hearing to consider Contention XX

'in the above-entitled proceeding.

University further requests that each of the above-named witnesses produce and bring with him at the tine of the deposition the following documents:

1. All documents relating to the physical security of the UCLA research reactor facility which he has considered or upon which he intends to rely in providing testimony on Contention XX of the above-entitled proceeding.

2. All documents containing information concerning threats of damage directed against the UCLA research reactor, or the reactor

facility, which he has considered or upon which he intends to rely in

{

providing testimony on Contention XX of the above-entitled proceeding.

3. All documents caused to be created by said witness, or in the creation of which said witness participated, that contain information relating to the physical security of the UCLA research reactor facility, or threats directed against the facility, including any information sent to CBG or to any of its officers or representatives or sent to any other CBG witnesses.

As used herein above, " 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, momoranda, orders, invoices, brochures, maps, diagrams, agendas, minutes, studies, analyses, manuals, transcriptions, pictures, photographs, and recordings, all notations on the foregoing, and all summaries thereof.

University will arrange for a court reporter to take the deposition and will insure that the court reporter is advised that the deposition will contain " Protected Information" which is to be protected in accordance with the Board's protective order requirements. The court reporter will be asked to sign an affidavit of non-disclosure consistent with those requirements. .

V w a

g Mr. William Cormier will conduct the examination for the University and will be assisted by Mr. Charles Ashbaugh, the security officer at the UCLA facility. University requests that it be notified if there is any objection to Mr. Ashbaugh's conducting part of the examination.

Dated: May 30, 1984.

~

DONALD L. REIDHAAR GLENN R. WOODS CHRISTINE HELWICK By l WILLIAM H. CORMIER 4

)

1. 1

e UNITED STATES OF AMERICA NUCLEAR REGULATORY C0f911SSION

=

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)

CERTIFICATE OF SERVICE I hereby certify that copies of the attached: NOTICE OF nrpn9TTinN AND DFnllF9T FOR PRnnflCTION in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, postage prepaid, addressed as indicated, on this date: MAY 30,1984 .

• 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 Los 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 l U.S. Nuclear Regulatory Comission Ms. Lynn G. Naliboff Washington, D.C. 20555 Deputy City Attorney j

Attn: Ms. Colleen P. Woodhead City Hall 1685 Main Street Chief, Docketing and Service Section (3) Santa Monica, CA 90401 0FFICE OF THE SECRETARY U.S. Nuclear Regulatory Comission Washington, D.C. 20555

• EXPRESS MAIL fM WILLIAM H. CORMIER  !

Representing UCLA l

THE REGENTS OF THE UNIVERSITY 0F CALIFORNIA

<