ML19341A606

Amend to Petition for Leave to Intervene to Establish Identity & Interests of Individual Members & Authority for Representation.Nine Affidavits & Certificate of Svc Encl

ML19341A606
Person / Time
Site:	Armed Forces Radiobiology Research Institute
Issue date:	01/16/1981
From:	Entwisle E CITIZENS FOR NUCLEAR REACTOR SAFETY, INC., ENTWISLE, E.B.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8101270282
Download: ML19341A606 (12)

Text

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// NUCLEAR REGULATORY CCMMISSION 0(Fee of the T-)

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SLdORE THE ATOMIC SAFETY AND LICENSING BOARD Occ W ng g

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In the Matter of Docket No. 50-170 ARMED MRCES RADICBIOIX)GY RESEARCH INSTITUTE (Application to Renew Opera ting License No. R-84)

(TRIGA-Type Research Reactor) l AMENDMENT TO PETITION MR LEAVE TO INTERyJNE On December 10, 1980, Petitioner filed a timely Petition for Leave to Intervene in the abov,e-captioned matter, alleging that the renewal of Applicant's opera ting license would be inimical to the health, safety, property, and environmental interests of Petitioner's members. Petitioner did out at that time identify the individual members it purported to represent; consequently, Petitioner's standing was challenged -

by Applicant and by the NRC Staff in their responses to the Petition.

For these reasons, Petitioner a t this time amends its Petition to establish for the record: 1) the identity and interests of several of its individual membehs; and 2) its F.athority to represent these individuals in the above-captioned ma t t e r. For this purpose, affidavits of nine of s Petitioner's members a re a ttached hereto as pa rt of this Amendment.

Respectfully.

Dated at Washington, 4 7-r , dr7 D.C. this 16th day Elipcech B. Entwisle o f Ja nua ry , 1981. Counsel for Petitioner 3 _g o 810 u 7OR'L 500l( 1 G

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AFFIDAVIT OF BRUCE MOYER _

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Bm-I, Bruce Moyer, duly sworn, do state: g g

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1. that I live and own a home at 4529 Fairfield ,

Bethesda , Ma ryland 20015, 0.3 mile from the site of the Armed Forces Radiobiology Research Institute ( AFRRI) nuclear reactor;

2. that my wife and newborn child also live et the above address;

3. that by reason of our proximity to the AFRRI reactor I am concerned about the consequences to the health, safety and property interests of my family and myself of renewing AFRRI's operating license; that I am a memb'r of' the Citizens for Nuclear Reactor

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4 Safety, Inc. (CNRS), attest that the information con-tained in the Petition for Leave to Intervene and Amendment thereto is true and correct to the best of my knowledge, and authorize CNRS to represent me as an intervenor in AFRRI's license renewal proceedings.

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WlD Bruce Moyer SUBSCRIBED AND SWORN to before me this day of Jan' ua ry, 1981.

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AFFIDAVIT OF REBECCA MOYER hL W ce w %,,

Achting 4 .9,9, St:n:' /y I, Rebecca Moyer, duly sworn, do sta te: * )"'

1. that I live and own a home a t 4529 Fairfield Drive, Bethesda, Ma ryland 20015, 0.3 mile trom the site of the Armed Forces Radiobiology Research Institute

( AFRRI) nuclear reactor;

2. that my husband. and newborn child also live at the above address;

3. that by reason or our proximity to the AFRRI reactor I am concerned about the consequences to the health, safety, and property interests of my family and myself of renewing AFRRI's opera ting license; 4

that I am a member of' the Citizens for Nuclear Reactor Safety, Inc . ( CNRS ) , a t tes t tha t the informa tion con-tained in the Petition for Leave to Intervene and Amendment thereto is true and correct to the best of my knowledge, and authorize CNRS to represent me as an intervenor in AFRRI's license renewal proceedings. ,

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Rebecca Moyer SUBSCRIBED AND SWORN. to before me this / y of Janua ry, 1981.

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AFFIDAVIT OF BEVIN GRYLACK Q 'S N i ' }g g , C '

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1, Bevin Grylack, duly sworn, do state: s,,Y

1. that I live and own a home at 8606 Rayburn Road', sda, Ma ryland 20034, 1 5 miles from the site of the Armed Forces Radiobiology Research Instituth'( AFRRI).nDelear reactor;

2. that my husband also lives and owns a home at the above address; 3 that by reason of osar proximity to the AFRRI reactor I am concerned about the consequences to the health, safety, and property interests of my husband and myself of - enewing AFRRI's operating license; 4 that I am a member of the Citizens fc Nuclear Reactor Safety, Inc. (CNRS), attest that the information cen-tained in the Petition for Leave to Intervene and Amendment thereto is true and correct to the best of my knowledge, and authorize CNRS to represent me as an intervenor in AFRRI's license renewal proceedings.

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• a Bevin Grylack SUBSCRIBED AND Sw'ORN to before me this / 3 7I t day of January, 1981. .

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t AFFIDAVIT OF IRVING STILLMAN $ Jg y , h

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Dc:w, ; 6 3.,g, I, Irving Stillmer duly sworn, do state: " '

1. that I live at 4721 Dorset Avenue, Bethesda, Ma- '

20015, 2.2 miles from the site of the Armed Forces Radiobiology Research Institute ( AFRRI) nuclear reactor;

2. that my wife also lives at the above address; 3 that by reascn of our proximity to e AFRRI reactor I am concerned about the consequeneta to the health and safety of my wife and myself of renewing AFRRI's opera ting license:

4. that I am a member of the Citizens for Nuclear Reactor Safety. Inc. (CNRS), attest tha t the information con-tained in.the Petition for Leave to Intervene and Amendment thereto is true and correct to the best of my knowledge, and authorize CNRS to represent me as an intervenor in AFRRI's license renewal proceedings.

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• Irvina; Still . n SUBSCRIBED AND SWORN to before me this / #3 day of January, 1981.

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AFFIDAVIT OF BERNARD PHILLIPS' p ga gg y {2 g n d the W 9 y s::w:gf M"i** dl I, Berna rd Phillips, duly sworn, do sta te: N

1. that I 1.*ve at 3912 Denfield Avenue, Kensingto ,"

Ma ryla nd ' 00795, 2.6 miles frem the Armed Forces Radiobiology Research Institute ( AFRRI) nuclear rea e tor, site;

2. that by reason of my proximity to tr

• AFRRI reacter I am concerned about the consequences to my health and safety of renewing AFRRI's operating license; 3 that I am a member of the Citizens for Nuclear Reactor Safety, Inc. (CNRS), a ttest tha t the informa tion con-tained in the Petition for Leave to Intervene and Amendment thereto is true and correct to th'e best of my knowledge, and authorize CNRS to represent me as as an intervenor in AFRRI's license renewal proceedings.

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%\ c-\c q Lw Berna rd Phillips SUBSRIBED AND SWORN to before me this /hday of January, 1981.

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AFFIDAVIT OF DOIORES HELMAN J4y y 3 %*i -

b ony.,,,h 4 .. g E I, Dolores Helman, duly sworn, de state: \

1. that I live at 2912 Denfield Avenue, Kensington, -

Ma ryland 20795, 2.6 miles from the Armed Forces T<adiobiology Research Institute ( AFRRI) nuclear reactor site;

2. that by reason of my prcximity to the AFRRI reactor I am concerned about the consequences to my health and safety of renewing AFRRI's operating license; 3 that I am a member of the Citizens for Nuclear Reactor Safety. Inc. ( CNRS ) . a t t es t that the information con-tained in the Petition for Leave to Intervene and Amendment thereto is true and ccrrect to the best of my knowledge, and authorize CNRS to represent me as an intervenor in AFRRI's license renewal prcceedings.

G gki-LC4 ll%2v Dolores Helman '

SUBSCRIBED AND SWORN to before me this / day of Janua ry, 1981.

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AFFIDAVIT OF ELIZABETH FRENCH M4 f3 1 l I, Elizabeth French, duly sworn, do state: ],

1. that I live and own a home at 8'817 Chalon Drl bet,h esda, Ma ryland 20034, 3.0 miles frem the site of the Armed Forces Radiobiology Research I6stitute ( AFRRI): nuclear reactor;

2. that my husband also lives and owns a home at the above address; 3 that by reason of our proximity to the AFRRI reactor I am concerned about the consequences to the health, safety, and property interests of my husband and myself of renewing AFRRI's operating license; 4 that I am a member of the Citizens for Nuclear Reactor Sa fety, Inc. (CNRS), a ttest that the inform'a tion con-tained in the Petition for Leave to Intervene and Amendment thereto is true and correct to the best of my knowledge, and authorize CNRS to represent me as an intervenor in AFRRI's license renewal proceedings.

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SUBSCRIBED AND SWORN to before me this l1U day of January.

1981.

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4 AFFIDAVIT OF ELIZABETH ENTWISLE kg ' /p 1h

• J * *y I, Elizabeth Entwisle, duly sworn, do state: cs g gj

1. that I live at 8118 Hartford Avenue, Silver Spring.

Ma ryland 20910, 4.4 miles from the site of the Armed Forces Radiobiology Research Institute ( AFRRI) nuclear reac tor;

2. that by reason of my proximity to the AFRRI reactor I am concerned about the consequences to my health and safety of renewing AFRRI's operating license; 3 that I am a member of the Citizens for Nuclear Reactor Safety, Inc. ( CNRS ) , a t tes t tha t the info rma -

tion contained in the Petition for Leave to Intervene and Amendment thereto is true and correct to the best of my knowledge, and authorize CNRS to represent me as an intervenor in AFRRI's license renewal proceedings.

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Eliza beth .Entwisle SUBSCRIBED AND SWORN to before me this / day of January, 1981.

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AFFIDAVIT OF EDITH VILLASTRIGO - /N /p

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1. that I live and own a home at 10216 Sutherland Road, Silver Spring, Maryland 20910 4.6 miles from the site of the Armed Forces Radiobiology Research Institute ( AFRRI) nuclear reactor;

2. that my husband also lives and owns a home at the above address; 3 that by reason of our proximity to the AFRRI reactor I am concerned about the consequences to the health, safety and property interests of my husband and myself of renewing AFRRI's operating license; 4 that I am a member of the Citizens for Nuclear Reactor Safety, Inc. (CNRS), a ttest tha t the information con-tained in the Petition for Leave to Intervene and Amendment thereto is true and correct to the best of my knowledge, and authorize CNRS to represent me as an intervenor in AFRRI's license renewal proceedings.

$ k.6 Edith V111astrigo SUBSCRIBED AND SWORN to before me this /4/ day of Janua ry, 1981.

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UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION (9- g /pg y BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '?%

'Siu In the Matter of )

Docket No. 50-170 ARMED FORCES RADIOBIOIOGY RESEARCH INSTITUTE (Application to Renew Opera ting License No. R-84 )

(TRIGA-Type Research Reactor)

NOTICE OF CHANGE' OF ADDRESS Notice is hereby given of a change of address' for Elizabeth B. Entwisle, counsel for Petitioner in the above-captioned ma tter.

OLD ADDRESS: 8401 Flower Avenue Takoma Pa rk. Ma ryland 20012 NEW ADDRESS: 8118 Ha rtford Avenue Silver Spring. Ma ryland 20910 -

Counsel's office and home telephone numbers and Petitioner's mailing address remain unchanged.

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Elir.abeth B. Entwisle Counsel for Petitioner ,

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Dated at Washington, D.C. this 16th day of Janua ry, 1981. l

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UNITED STATES OF AMERICA ta;:.7 d the Santwy

. 8 NUCLEAR REGULATORY COMMISSION b

g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .

In the Matter of Docket No. 50-170 ARMED FORCES RADICBIOIDGY (Application to Renew RESEARCH INSTITUTE Opera ting License No. P-84 )

(TRIGA-Type Research Reactor)

CERTIFICATE OF SERVICE I hereby certify tha t copies of " AMENDMENT TO PETITION FOR LEAVE TO INTERVENE" and " NOTICE OF CHANGE OF ADD for Elizabeth B. Entwisle in the above-captioned matter have been served on the following by depositing in the United. States Mail, First Class, this 17th dPy of January.

1981:

Mr. Richa rd G. Bachmann. Esq.

Louis J. Ca rter. Esq. , Chairman Counsel for NRC Staff Administrative Judge Office of the Executive Legal Atcmic Safety and Licensing Director Boa rd U.S. Nuclear Regulatory Commission

' 23 Wiltshire Road Washington, D.C. 20555 Philadelphia PA 19151 Mr. Stuart A. Treby, Esq.

Mr. Ernest E. Hill Assistant Chief Hearing Counsel Administrative Judge for NRC Sta f f Lawrence Livermore Laboratory Office of the Executive Legal Universit?c of California Director P.O. Box 808, L-123 U.S. Nuclea r Remna tory Cori. mission Livermore, CA 94550 Washington. D.t. 20555 Mr. David R. Schink Atomic Safety and Licensing Administrative Judge Boa rd Panel

• Department of Oceanography U.S. Nuclea r Regula torv Commission ,

Texas A & M University Washington. D.C. 2055 College Station. TX 77840 Atomic Safety and Licen. ng Mr. Robert L. Brittigan, Esq. Appeal Panel (5)*

General Counsel U.S. Nuclear Regulatory Commission Defense Nuclear Agency Washington, D.C. 20555 Washington. D.C. 20305 Docketing and Service Section (7)*

Office of the Secreta ry a u'N Entwisle [.cM.L d -

U.S. Nuclear Regula tory Commission Eluaceth B.

Counsel for Petitioner Washington, D.C. 20555