ML20054E712
| ML20054E712 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 06/04/1982 |
| From: | Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8206140096 | |
| Download: ML20054E712 (10) | |
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'82 I?!10 UI N 4
i 5 0 UNITED STATES OF AMERICA r
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NUCLEAR REGULATORY COMMISSION"'
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 7'
8 hIntheMatterof
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Docket No. 50-142 fTHE REGENTS OF THE UNIVERSITY
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(Proposed Renewal of Facility 10lI OF CALIFORNIA
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License Number R-71)
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llI(UCLA Research Reactor)
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June 4, 1982
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12i 13 li 14 j; 15 UNIVERSITY'S RESPONSE TO CBG'S MAY 18th REQUEST l
FOR RELEASE OF A CERTAIN PHOTOGRAPH 16 17 lj l
18 19 k DONALD L. REIDHAAR GLENN R. WOODS l'
20(
CHRISTINE HELWICK 590 University Hall I
21 ll*
2200 University Avenue b
Berkeley, California 94720 22 ll Telephone:
(415) 642-2822 23 Attorneys for Applicant 24 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 26,,
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B206140096 820604 PDR ADOCK 05000142 O
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On May 18, 1982, Intervenor (CBG) served a response 2j seeking to compel the release of a certain photograph which n
3;: University had previously objected to releasing on the ground that i
4] the photograph was irrelevant to issues being considered in the proceeding.1!
CBG rests its argument for release of the 5
6 photograph on the faulty premise that the political associations il7 of certain of University's employees (and presumably students) 8 h are in some way cognizable in this relicensing proceeding.
CBG's F
9,, argument is contrived and insubstantial.
Whether or not the 10' single photograph is released is a matter of little consequence to lli these proceedings and University declines further argument on the 12 issue.
- However, University must briefly note that once again r
I, 13 h CBG has relied on a deliberate misrepresentation of fact in I!
14I support of an argument.
This matter is explained below.
15 16 CBG argues that the photograph in question provides 17 evidence suggesting a connection between a certain " extremist" 18 npolitical organization and the staff of the UCLA reactor, raising "a serious question about screening and security precautions". !
19 n
20 As further evidence of such a connection CBG notes that a 21 candidate of the allegedly extremist organization "was sponsored 22,in a public talk at UCLA by an organization working out of the 23 i il 24[ l/
"CBG's Response to Certain Matters in Applicant's ' Memorandum
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Concerning Disposition of the Photographs'", dated May 18, 1982 25l (hereinafter May 18th Response).
The particular matter in d
question concerns whether or not a certain photograph of a 26,
car bumpersticker is to be released.
TheBoardaddressedthel 9
matter in its April 16, 1982 Order.
27 !'
28[2/
May 18th Response at 5.
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1 Nuclear Energy Lab at UCLA and supervised by the reactor's chief f security!"3/
CBG then quotes an excerpt from a paragraph 2
3 appearing in the 1976 Annual Report of the Nuclear Energy i:
4 Laboratory (NEL) to the effect that the NEL openly provides 5; resources and assistance to the organization, that is, the 6:" organization working out of the NEL".
CBG frils to identify that 7 organization.
Instead CBG insinuates that it is a political 8 organization possibly linked to CBG's allegedly extremist political 9: organization and thereby constitucing a threat to facility security.
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10 !CBG knew otherwise.
5 11 12; In fact, the organization working out of the NEL which 13 CBG fails to identify is the UCLA Student Chapter of the American li 14: Nuclear Society (ANS), an internationally respected professional i
15 society of scientists and engineers working in the nuclear field.
16 In quoting from the 1976 Annual Report CBG has conveniently 17 deleted the heading and first sentence of the quoted paragraph i;
18;which clearly identify the ANS.
The excerpt appearing on page 4 i
19 llof CBG's May 18th Response is to be compared with the complete b
20l paragraph from page 18 of the 1976 Annual Report, which is 21 freproduced here:
h 22; "IV.
D.
Student Chapter of the American Nuclear Society (ANS) l 23 l
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The NEL provides space, telephones, and 24; secretarial support for the Student Chapter of the ANS.
g Meetings were held periodically in the laboratory 25 lj lecture area, the elected officers were allowed to make 26[i chapter business phone calls, mail was sorted for the officers, and typing and mailing costs for the Chapter 27!
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May 18th Response at 4. l t
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were borne by the Laboratory.
When applicable, technical 2[
assistance was provide to the chapter by the staff and j
j director of the NEL."
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4 ll By deleting the opening sentence identifying the li 5 " organization working out of the NEL" as the Student Chapter of the 6[ANS, CBG has attempted to deliberately deceive the Board as to the U7htrue nature of the organization that supposedly forms the l'8[ dangerous link to the organization described as " extremist" by 9 CBG.5/
Such argument has no place in pleadings filed in this 10 proceeding.
11l[
12j Dated:
June 4, 1982.
I:
131 14j DONALD L. REIDHAAR GLENN R. WOODS 15 CHRISTINE HELWICK 16' ObV 17 By s
William'R7 Cormier 18 UCLA Representative g
e 19 J THE REGENTS OF THE UNIVERSITY 20 [i OF CALIFORNIA f
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23 (4 /
The source of the passage quoted is page 18 of the Annual y
Report for 1976, included herein as Exhibit "A" together with l
24 f the title page and table of contents to the report.
25 5/
The " extremist" organization's candidate mentioned by CBG as i
speaking at UCLA (as evidence of the link) appeared as part 26 i of an unexceptional two-part speakers program presenting ll both " pro" and " con" views on nuclear power, which was 271:
sponsored by the UCLA Student Chapter of the ANS.
The 28 ['
announcement for that program appears herein as Exhibit "B".
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EXHIBIT "A"
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ANNUAL REPORT NUCLEAR ENERGY LABORATORY January 1, 1976 to December 31, 1976 Ivan Catton, Director
,e s
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TABLE OF C0hTENTS 1
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- Page, Chapter I.
The Year in Review..............
1 Chapter II. Historical Background................
2 II.A.
Reactor.......................
2 II.B.
Subcritical Facility 4
Chapter III.
Description and Status of Facilities........
5 III.A.
Reactor 5
III.B.
Suberitical Facility................
6 III.C.
Supporting Facilities 7
III.D.
Undergraduate Laboratory..............
7 III.E.
Heat Transfer Laboratory..............
8 III.F.
Tekamak Laboratory.................
9 III.G.
Nuclear Safety Research Library 10 III.H.
Laboratory Organization 11 Chapter IV. Academic and Community Support 14
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IV.A.
Classroom (UCLA) 14 IV.A.1.
Engineering 135 A, B, C...........
14 IV.A.2.
Engineering 139 A..............
15 IV.A.3.
Chemistry 103................
15 IV.A.4.
Engineering 235 C..............
15 IV.B.
Community Support.
16 IV.B.I.
Engineering Extension'X497.17........
16 IV.B.2.
Other School Systems 16 IV.B.3.
Weekend Seminars 17 IV.C.
Miscellaneous....................
17 IV.D.
Student Chapter of the American Nuclear Society (ANS) 18 Chapter V.
Reactor Research.......... '........
19 V.A.
Survey.
19 V.B.
O pe ra ti on s......................
19 V.C.
Users and Their Areas of Research 21 V.C.I.
UCLA (Excluding NEL).............
21 V.C.2.
Other UC Campuses 22 V.C.3.
Other Schools 22 V.C.4.
NEL 23 Chapter VI.
Research Support (Non-Reactor) 24 11
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TABLE OF~ CONTENTS (ContinuGd)
Page 4
VI.A.
School of Engineering and Applied Science......
24 VI.A.1.
Contract Research..............
24-VI.A.2.
Unfunded Research..............
28 Chapter VII.
Student Support 30 Chapter VIII.
Financial Report 32 Chapter IX.
Future (1977) Nuclear Energy Laboratory Projects and Business 33 IX.A.
Engineering 139 A..................
33 IX.B.
Other Classes....................
33 IX.C.
Reactor Operator Training Class...........
33 IX.D.
High Schools 34 IX.E.
Local Utilities Education..............
34 IX.F.
Utility Reactor Operations Course..........
34 IX.G.
Mutation Studies 35 IX.H.
Organic Synthesis............
35 IX.I.
UCLA Reactor 35 IX.J.
NEL Minicomputer 36 IX.K.
Activation Analysis.................
36 IX.L.
Colleges and Universities..............
36 iii
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Miscellaneous lecture tours were also given to UCLA Alumni, the UCLA Chapter of the Society of Women Engineers, minority recruitment, and j
so on. The NEL participated as usual in the Annual Engineering Week at UCLA by providing tours and a lecturer.
IV.D.
StudentChapteroftheAmericanNuclearSociety(ANS1 The NEL provides space, telephones, and secretarial support for the Student Chapter of the ANS. Meetings were held periodically in the laboratory lecture area, the elected officers were allowed to make chapter business phone calls, mail was sorted for the officers, and typing and mailing costs for the chapter were borne by the laboratory.
When applicable, technical assistance was provi,ded to the chapter by the staff and director of the NEL.
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EXHIBIT B"
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A TWO PART SPEAKERS PROGRAM TO PROV1DE THE UCLA COMMUNITY WITH THE OPPORTUNITY TO EEAR OPPOSING VIEWS ON NUCLEAR POWER.
10 FEBRUARY 1982 23 FEBRUARY 1982 6:00 to 8:00 p.m.
12:00-to 1:00 p.m.
100 MOOR 7 ::ALL 51 KINSEY HALL Af1ORY LOVINS, FROM FRIENDS WILLIAM WERTZ, FROM FUSION OF THE EARTH, SPEAKS ON:
ENERGY FOUNDATION, SPEAKS ON "THE LINK BETWEEN NUCLEAR "THE TRUE HISTORY OF TOM AND WEAPONS, NUCLEAR POWER, AND JANE AND THE ANTI-NUCLEAR THE SOFT ENERGY ALTERNATIVE" MOVEMENT" PLEASE COME AND LISTEN BROUGHT TO YOU BY A.N.S. STUDENT CHAPTER j
STAY INFORMED AND MAKE YOUR OWN DECISIONS, BASED ON FACT!
l l
Funded by CPC Mini-Fund, PAB i
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
In the Matter of
)
5-4
)
Docket No. 50-142 THE REGENTS OF THE UNIVERSITY
)
(Proposed Renewal of Facilf,ty 5
OF CALIFORNIA
)
License Number R-71) J
-)
6-(UCLA Research Reactor)
)
)
7 0
_ CERTIFICATE OF SERVICE 9
I hereby certify that copies of:the attached: UNIVERSITY'S 10 RESPONSE TO CBG'S MAY 18th REQUEST FOR RELEASE OF A CERTAIN PHOTOGRAPH 11 in the above-captioned proceeding have been served en the follcwing by deposit in the United States mail, first class, 12 postage prepaid, addressed as indicated, on this date: June 7, 1982 13
'4 John H. Frye, III, Chairman Mr. Daniel Hirsch Administrative Judge Cte. to Bridge the Gap 15 ATOMIC SAFETY AND LICENSING BDARD 1637 Butler Avenue, #203 U.S. Nuclear Regu'latory Commission Los Angeles, Calif.
90025 16 Washington, D.C.
20555 Mr. John Bay, Esq.
17 Dr. Emmeth A. Luebke
' 3755 Divisadero #203 Administrative Judge' San Francisco, CA 94123 18 ATOMIC SAFETY AND LICENSING BOARD.
U.S. Nuclear Regulatory Commission' Mr. Daniel Hirsch 19
' Washington, D.C.
20555
, Sox 1186 Ben Lomond, CA.95005 20 Dr. Oscar H. Paris Administrative Judge v.
21 ATOMIC SAFETY AND LICENSING BOARD U.S. Nuclear Regulatory Commission Nuclear Law Center 22 Washington, D.C.
20555 y c/o Dorothy Thompson
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6300 Wilshire Blvd. #1200 23 Counsel for the NRC Staff Los Angeles, CA 90048 OFFICE OF THE EXECUTIVE LEGAL DIRECTOR 24 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 1
25 Chief, Docketing and Service Section 26 OFFICE OF THE SECRETARY U.S. Nuclear Regulatory Commission f
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27 Washington, D.C.
20555 28 WILLPAM 8. CORMIER UCLA Representative TEE REGENTS OF THE UNIVERSITY OF CALIFORNIA e4 i
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