ML20011A211

Interrogatories Directed to Nrc.Certificate of Svc Encl. Related Correspondence

ML20011A211
Person / Time
Site:	Armed Forces Radiobiology Research Institute
Issue date:	09/30/1981
From:	Entwisle E CITIZENS FOR NUCLEAR REACTOR SAFETY, INC., ENTWISLE, E.B.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8110080290
Download: ML20011A211 (4)

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UNITED STATES OF AT1 ERICA <

NUCLEAR REGULATORY CO?' MISSION o z)no DEFORE THE ATOMIC SAFETY AND LICENSING B .D g\h h E C.T OC m r0:OINCE

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y In the Matter of ARMED FORCES RADIORIOLOGY N Docket No. 50-170 RESEARCH INSTITUTE 1 E_" 0 1, ) I90Ih IS (Renewal of Facility (TRIGA-Type Reactor) t- u.s. c g u d2 M License No. R-84)

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INTERROGATORIES TO THE NRC STAFF FROM THE CITIZENS FOR NUCLEAR REACTOR SAFETY, INC.

Pursuant to 10 CFR 2.740b, the Citizens for Nuclear Reactor Safety, Inc. requests that the following interrogatories he answered fully, in writing, and under oath or affirmation by any employees or members of the NRC staff who have personal knowledge thereof or are the closest to having personal knowledae thereof. The person answering each question should set forth his or her name and title, and should identify any other individual who furnishes information on which the answer to the question is based.

QUPSTIONS:

1. For each contention and sub-contention thereof, stipulated to by the HRC, AFRRI, and the Intervenor (" Attachment A" of the Stipu-lation signed by said parties on March 31, 1981), and for each unstipu-lated contention ("Atta hment B" of said Stipulation) approved by the Atomic Safety and Licensing Board in its Memorandun and Order served September 1, 1981, state what the staff's present position is (insofar 8110000290 810930 PDR ADOCK 05000170 g, D PDR I

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-as it has formed an opinion at this stage) with respect to each such contention and sub-contention'and identify all documents and studies relied.upon by the staff now or in the past which serve as the basis for each position taken. Any such document shall be identified with reference to its title, author (s), any identifying serial numbers or

. filing _ numbers, the particular parts thereof which are relied upon, ar.1 the places where it is known to be available for inspection. In lieu thereof, attach a copy of each document and study to the answer.

2. For each contention and sub-contention referred to in cuestion 1,_ identify all documents and studies, and the carticular parts thereof, known to exist but not relied unon, which pertain to the subject matter

-of the contention or sub-contention. In lieu thereof, attach a copy of each document and study to the Answers and identify the contention or sub-contention to which it pertains.

3. Explain whether APRRI, the NRC Staff, or any other individual, agency,.or organization is engaged in or intends to engage in turther research or tudies which may affect any answers. Identify such research or work and, to the extent possible, its projected completion date (including but not linited to the Staff's Safety Evaluation Report and Environmental Impact Appraisal)'.

4. For each contention and sub-contention referred to in question 1, identify the expert (s) , if any, whon the Staff intends to have testify on the subject' natter of the contention or sub-contention.

I State the qualifications of each expert.

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i I Respectfully subnjtted, f

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p' Counsel for the Citizens for

?!uclear Peactor Safety, Inc.

Dated this 30th day of Septenber, 1931.

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j'!,, t UElTED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IP In the matter of ECT' )

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ARMED FORCES RADIOBIOLOGY ) ,

RESEARCH INSTITUTE )

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(Renewal of Facil License No. R-84' ,

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(TRIGA-Type Reactor) ) gy y CERTIFICATE OF SERVICE tt}

A 7 hereby certify that copies of Intervenor's Interrogatorie 4 AFRRI and to the NRC Staff in the above-captioned matter have ,G,l h t$b . Kr/

been served on the following by depositing in the United States M,il, First Class , this 1st day of October, 1981:

Louis J. Carter, Esq., Chairman Mr. Richard G. Bachmann, Esq.

Administrative Judge Counsel for NRC Staff Atomic Safety & Licensing Board Office of the Executive Lc3al 23 Wiltshire Road Director Philadelphia, Pa. 19151 U.S . Nuclear Regulatory Conn'ission Washington, D.C. 20555 Mr. Ernest E. Hill Administrative Judge Mr. Stuart A. Treby , Esq .

Lawrence Livermore Laboratory Assistant Chief Hearing Counsel University of California for NRC Staff P.O. Box 808, L-123 Office of the Executive Legal Livermore, C 1. 94550 Director

_Mr. David R. Schink U.S. Nuclear Regulatory Commission Ao. nistrative Judge Washington, D.C. 20555 Dept. of Oceanography Texas A&M University Atomic Safety & Licensing College Station, TX 77840 Board Panel U.S . Nuclear Regulato ry Commission Docketing & Service Station Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Comm. Atomic Safety & Licensing Washington, D.C. 20555 Appeal Panel U.S . Nuclear Regulato ry Commission Mr. Robert L. Brittigan, Esq. Washington, D.C. 20555 General Counsel Defense Nuclear Agency Washington, D.C. 20305

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o w r (Q('*;T Vff I a D , $ iq 'i-( i nk,f Elizabeth B. Entwisle Counsel for Intervenor

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