ML20008G239

Amends to Unstipulated Contention 5 Re Routine Emissions to Clarify Bases Offered in Support & Correct Citation Date Error.Certificate of Svc Encl

ML20008G239
Person / Time
Site:	Armed Forces Radiobiology Research Institute
Issue date:	05/05/1981
From:	Entwisle E CITIZENS FOR NUCLEAR REACTOR SAFETY, INC., ENTWISLE, E.B.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8107020517
Download: ML20008G239 (3)

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NUCLEAR REGULATORY COMMISSION 'I ge, et ce Se::e'aff Do:kcir; & Servi e BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ISD p In the Matter of )

1. II

) Docket No. 50-170 ARMED FORCES RADIOSIOLOGY RESEARCH )

INSTITUTE ) (Application to Renew

) Facility License No. R-84)

TRIGA-Type Reactoc )

AMENDMENT TO UNSTIPULATED CONTENTIONS A special pre-hearing conference in the above-captioned =atter was conducted by the Atomic Safety and Licensing Board ("the Board")

on May 1, 1981, pursuant to 10 C.F.R. 2.751a.

In the course of that conference the Board requested that the Petitioner' amend certain of its unstipulated contentions in order to (1) clarify the bases of fered in support, and (2) correct an error in a date citation.

After reviewing the language of the proposed a endments, counsel for the Applicant and counsel for the Nuclear Regulatory Co==iasion Staff each stated that he would oppose the admissibility of the contentions as amended.

In accordance with the Board's reques:, the Petitioner at this ti=e sub=its its amendments to (2), (3), and (4) of Unstipulated Contention (! 5, entitled " Routine E=issions I," set forth at pp. 3-4 of Attachment B to the parties' Stipulation.

Respectfully, Dated at Washington, D.C. this 5th day (g

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T of May, 1981. Elifabeth E. Entwisle q Coun'sel for Petitioner 3 Y7 b,I O

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l Amendments to Unstipulated Contention A 5, entitled " Routine Emissions I."

(2) REPLACE EXISTING LANGUAGE WIDi THE FOLLOWING:

Applicant's incineration of 160 boxes of contaminated solid

-waste, cited in NRC Inspection Reports for the year 1965, Docket No. 50-170, resulted in the release of radioactive gases and parti-culates in excess of the limits set forth at 10 C.F.R. Part 20 and Appendices thereto.

(3) LEAVE EXISTING PARAGMPH AS IS, AND ADD AS A SEC0h"O PAMGRAPH THE FOLLOWING:

Petitioner bases this conclusion on (1) the AFRRI Environmental Release Data and Perimeter Monitoring Reports, Docket No. 50-170 (including but not limited to the 5/27/66 report, 9/20/66 report, and 12/lt/77 report), and (2) AFRKI's written response to Mr. Joe Miller's (fro = Citizens for Nuclear Reactor Safety, Inc.) question

- -- - --# -kl i - Au t u=n- 19 7 9 . -(The written questions and responses are in Petitioner's possession.)

(4) LEAVE EXISTING PAMGRAPH AS IS, .AND ADD AS A SECOND PARAGRAPH THE FOLLOWING:

Because these =easure=ents are taken only a few times a year, 1: =ust be asst =ed, in the absence of more comple..: data, that these dose rates represent the average dose rater to unrestricted areas over long du.ations of time.

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USNRO

' '* UNITED STATES OF MIERICA ,

NUCLEAR REGULATORY COMMISSION MAY 71981 * }

OHice ef the Semby 3EFORE THE ATOMIC SAFETY AND LICENSING BOARD D::ksm si St.wi:e

- Eraa.:a

• E In the Matter of ) ,A l l L4

) Docke No. 50-170 ARMED FORCES PADI03IOLOGY RESEARCH )

INSTITUTE ) (Applica:1on to Renew

, racility License No. R'S4)-

TRIGA-Type Reactor )

CERTIFICATE OF SERVICE I hereby certify that copies of " POSITION OF PETITIONER ON UNSTIPULATED CONTENTIONS," " PETITION FOR RAIVER OF COMMISSION REGULATIONS ," and " AMENDMENT TO UNSTIPUI.ATED CONTENTIONS" in the above-captioned =atter have been served on the following by depositing in the United States Mail, First Class, this 6th day of May, 1981:

Louis J. Carter, Esq., Chair =an Mr. Richard G., Bach = ann, Esq.

Ad=inistrative Judge Counsel for NRC Staff A c=ic Snfa:y and Licensing 3 ard Offi: rf the Executive Legal 23 Wiltshire Road Director Philadelphia, PA 19151 U.S. Nuclear Regulatory Co==1ssion Washington, D.C. 20555

- ~~" - Mr.--Ernes c~ t -Hill - -

Ad=inistrative Judge Mr. Stuart A. Treby, Esq.

Lawrence Livermore Laboratory As sistan: Chief Hearing Counsel University of California for NRC Staff P.O. Box 808, L-123 office of the Execu:ive Legal Liver = ore, CA 94550 Director U.S. Nuclear Regulatory Co==1ssion Mr. David R. Schink Washington, D.C. 20535 Ad=inistrative Judge Depar:=en of Oceanography A:o ic Safety and. Licensing Texas A & M University Board Fanel College Station, TX 77840 U.S. Nuclear Regulatory Cc==ission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary Ato:ic Safety and Licensing U.S. Nuclear Regulatory Co= ission Appeal Panel Washing:en, D.C. 20355 U.S. Nuclear Regulatory Co==ission

- Washington, D.C. 20555 Mr. Rober: L. Brit:igan, Esq.

General Counsel "*

Defense Nuclear Agency _- /

Washington, D.C. 20305 (O ~td>_/ ' ) . - 4 _ef '_ "v '--

Ilfzabeth 3. Entwisle Cou'Isel for Petitioner

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