ML20008G240
| ML20008G240 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 04/14/1981 |
| From: | Entwisle E CITIZENS FOR NUCLEAR REACTOR SAFETY, INC., ENTWISLE, E.B. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20008G241 | List: |
| References | |
| NUDOCS 8107020518 | |
| Download: ML20008G240 (2) | |
Text
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At UsHR0 UNITED STATES OF AMERICA h.
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SEFORE THE ATOMIC SAFETY AND LICENSING BOARD eesstr.d e
In the Matter of
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ARMED FORCES RAD 10 BIOLOGY )
Docket No. 50-170 RESEARCH INSTITRE
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(Application to Renew Facility License
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No. R-?4)
(TRIGA - Type Reactor)
)
PETITICN FOR WAIVER OF COMMISSION REGULATIONS The facts of this case present "special circumstances" within the meaning of 10 C.F.R. {2.758, such that application of the concentration and dose limits set forth at 10 C.F.R. Part 20 and Appendices S and C thereto would not serve the purpose for which these-limits were adopt'ed, i.e. would not adequately protect the public health and safety.
Petittor.er therefere ;etiticr.s the Cer~ission te wa'ive tne application of tne concentration anc core ieveis in Part 20- an-d Appendices-B and C -in this proceeding, and attaches an affidavit
- setting forth the facts that establish the "special circumstances" warrantin5 such a waiver.
1 Respectfully, Ya h alu &
L.
Elifabetn B. Entw'sle Counsel for Petitioner
- Petitioner is prepared to orcvide more detailed population k
and siting statistics than the Af fidavit sets forth if called upon to do so.
b Dated at Washington, D.C.
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this 14th day of April, 1981.
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O AFFIDAVIT I, Elizabeth B. Entsisle, duly sworn, do state:
1.
that the AFRRI facility is in close proximity to two hospitals (National Naval Medical Center and National Institutes of Health), whose patients and staff are exposed on a daily, continuous, long-term basis to emissions and effluents from tne facility.
2.
that the AFRRI f acility is in close proximity to '
many residential dwellings, whose occupants are exposed on a daily, continuous, and long-term (i.e. year-in, year-out) basis to emissions and efflU6nts from the facility.
3.
that the AFRRI facility is in close proximity to several schools, including elementary schools, whose students and staff are exposed on a daily, continuous, and long-term basis to emissions and effluents from AFRRI.
The elementary school students, by reason of their age, are particularly vulnerable to the radiological hazards of the AFRRI emissions and effluents; 4.
that the AFRRI facility is in close proximity to many businesses, whose ersployees are exposed en a d a i,1 y, continuous, and long-term basis'to the emissions ar.d effluar.:s fr:m tr.e facility; 5.
tnat because it is sited in the midst of a densely populated urban /resicential area, the population
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--"-~d e s e T h a t results f rom the routine emissions and effluents of the AFRRI f a cili ty is significantly higher than wou_id be the case if the facility were more remotely sited.
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Eliface n 5. Entwisle m
SUBSCRIBED AND SWORN to before me this
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day of April, 1981 dVA fall 6+>w Ndtary Puolic v
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