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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 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 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 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 ML20084E7271984-04-27027 April 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl 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 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 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 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 ML20079H9711984-01-16016 January 1984 Reply to NRC & Applicant 831230 Pleadings Re Contention Ii.Ucla Ceased Using Reactor in Fashion for Which License Granted & Therefore,Should Not Be Permitted to Receive License.Declaration of Svc Encl 1989-07-28
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55h'!D
'02 NOV 29 mo:08 UNITED STATES OF AMERICA ;r- - _
NUCLEAR REGULATORY COMMISSION i
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=a s:;cy -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
) Docket No. 50-142 THE REGENTS OF THE UNIVERSITY ) (Proposed Renewal of Facility OF CALIFORNIA ) License Number R-71)
)
(UCLA Research Reactor) ) November 24, 1982
)
UNIVERSITY RESPONSE TO CBG REQUEST FOR PRODUCTION l
DONALD L. REIDHAAR I 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 1
l .
~~
8211300358 821124 PDR ADOCK 05000142 O PDR -
0J
University responds to CBG's " Request for Production of Certain Documents as to Contention XXI", dated November 12, 1982 (The Request) as follows.
Except for documents objected to below, University will produce the documents requested at a document examination session to be held on Monday, November 29, 1982, from 1:00 to 3:00 p.m.
in Boelter Hall, Room 5750, and from 3 to 4:45 p.m. in 112 Physical Plant Building (601 Westwood Plaza), Room 212. The date suggested by CBG in its request, November 26, 1982, is a University holiday and is unavailable as a document examination date.
It is to be noted that several of CBG's specifically-numbered requests are satisfied by production of the same document or set of documents and the absence of a specific University objection does not imply that a separate and distinct document exists for my particular item in the request. University's search of its files is continuing. University reserves the right to produce after-acquired documents at a later date.
I University will photocopy documents as requested by CBG according to the procedures used at earlier document examination I
sessions in this proceeding. CBG will identify pages of documents to be copied by affixing a paperclip to the top of each page or set of pages to be copied making sure that there is an unambiguous
indication of whether or not both sides of a page are to be copied.
In addition, CBG should provide a list of documents and specific pages of documents it wishes copied.
To the extent that in any of its specific requests CBG seeks the production of documents of portions of documents that are unrelated to University's Emergency Response Plan and CBG's Contention XXI, University objects on the grounds that the discovery authorized by the Board is limited to contention XXI. With reference to CBG's numbered list of documents requested, University makes the following specific objection' and remarks:
t
- 2. No such documents exist (the procedures are not distinct from the plan) .
- 5. No such documents exist.
- 6. No such documents exist.
- 7. NEL drill records for 1982 will be provided; drill records for earlier years were provided CBG at previous document examination sessions.
l
- 8. The smoke alarms have not yet been installed and the specific device to be installed is not known at this time. A copy of the request made for the installation work will be produced.
- 10. No such documents exist.
- 11. No such documents exist.
15 and 16. University objects to these request on the grounds that they are not reasonably calculated to lead to the discovery of admissible evidence relevant to the adequacy of the University's Emergency Response Plan. Moreover, the requests are overbroad and unreasonably burden some in seeking the production of all documents concerning any incidents or inspections which may have occurred in all of Boelter Hall without limitation as to period of concern. Notwithstanding its objections, University will provide a file containing all records of incidents, inspections and sundry maintenance matters that have occurred in the Boelter Hall building in the past 5 years.
18 and 19. University objects to these requests on the grounds that they are not reasonably calculated to lead to the discovery of admissible evidence relevant to the adequacy of the University's Emergency Response Plan. Moreover, the requests are overbroad and unreasonably burdensome in seeking c'.1 records of fires which occurred at UCLA and all records of inspections conducted at UCLA.
- 20. University's procedures will be provided (see items 3, 4, 12 and 13 of the Request) but no specific NEL procedures handbook exists.
- 22. No information related to Contention XXI is contained in the two sets of campus Radiation Safety Committee minutes that have been prepared in 1982. University objects to this request on
the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence.
- 24. No such documents exist except for cards affixed to fire extinguishers which by law cannot be removed and which were identified during CBG's physical inspection of the facility.
25, 26, 27 and 38. University objects to these requests that relate to a fire that occurred in a chemical storage area of Young Hall in July, 1982 (the Young Hall fire) as not reasonably calculated to lead to the discovery of admissible evidence relevant to the adequancy of University's Emergency Response Plan.
- 28. University has no such documents.
- 31. No such documents exist.
- 36. No such document exists. The internal audit for 1981 is still in progress and the audit report is not expected to be available until after the first of the new year.
- 37. No such documents exist.
- 39. No such documents exist. The Los Angeles Fire Department's agreement to respond in the event of a fire at UCLA reactor facility is contained in a letter attached to the Emergency Response Plan and has been provided to CBG previously.
40, 41, 43, 44 and 45. No such documents exists.
Dated: November 24, 1982.
DONALD L. REIDHAAR GLENN R. WOODS CHRISTINE HELWICK
~,
By//; '
N William H. Cormier UCLA Representative THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 5 -
f
4 h 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 OF CALIFORNIA ) License Number R-71)
)
(UCLA Research Reactor) )
CERTIFICATE OF SERVICE I hereby certify that copies of the attached: UNIVERSITY RESPONSE TO CBG REQUEST FOR PRODUCTION.
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: November 24, 1982 .
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 Commission Los Angeles, CA 90025 Washington, D.C. 20555 Mr. John Bay, Esq.
Dr. Emmeth A. Luebke 3755 Divisadero (203 Administrative Judge San Francisco, CA 94123 ATOMIC SAFETY AND LICENSING BOARD U.S. Nuclear Regulatory Commission Mr. Daniel Hirsch Washington, D.C. 20555 Box 1186 Ben Lomond, CA 95005 Dr. Oscar H. Paris Administrative Judge Nuclear Law Center ATOMIC SAFETY AND LICENSING BOARD c/o Dorothy Thompson U.S. Nuclear Regulatory Commission 6300 Wilshire Blvd., #1200 Washington, D.C. 20555 Los Angeles, CA 90048 Counsel for the NRC Staff Ms. Lynn G. Naliboff OFFICE OF THE EXECUTIVE LEGAL DIRECTOR Deputy City Attorney U.S. Nuclear Regulatory Commission City Hall Washington, D.C. 20555 1685 Main Street Santa Monica, CA 90401 Chief, Docketing and Service Section OFFICE OF THE SECRETARY U.S. Nuclear Regulatory Commission Washington, D.C. 20555 WILLIAM II. CORMIER UCLA Representative THE REGENTS OF THE UNIVERSITY OF CALIFORNIA