ML20063G807

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Motion for Leave to File Reply to Licensee 820817 Response to Citizens for Nuclear Reactor Safety 820802 Motion for Leave to Further Suppl Interrogatory Responses.Reply Needed Due to Util Request for Sanctions.Related Correspondence
ML20063G807
Person / Time
Site: Armed Forces Radiobiology Research Institute
Issue date: 08/20/1982
From: Entwisle E, Macklin L
CITIZENS FOR NUCLEAR REACTOR SAFETY, INC., ENTWISLE, E.B., INSTITUTE FOR PUBLIC REPRESENTATION
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20063G813 List:
References
NUDOCS 8209010173
Download: ML20063G807 (2)


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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION O ED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD k 4 31 MI:i3 In the Matter of )

) Docket No. 50-170 fhfkCf g7 -

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B ARMED FORCES RADIOBIOLOGY ) "ICf RESEARCH INSTITUTE ) (Application to. Renew

) Facility License No. R-84)

(TRIGA-Type Reactor) )

INTERVENOR CNRS' MOTION FOR LEAVE TO FILE A REPLY Intervenor CNRS filed a Motion for Leave to Further Supplement its Interrogatory Responses on August 2, 1982. On August 17, 1982, the Licensee filed a response to the pending CNRS" motion.~1/

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Intervenors CNRS respectfully requests the right to file the attached reply to the Licensee's August 17th Response, in accord-ance with 10 C.F.R. 'S2. 730 (c) . While CNRS recognizes that the s regulations do not contemplate the' filing of a reply in most instances, they do prov'ide for exceptions when approved by the presiding officer. CNRS submits that a reply is both appropriate and important in this instance, because in its response the Licensee has reqtiested' the Board to impose severe, and CNRS submits, inapproprlate, discovery sanctions.

Counsel for CNRS contacted Judge Hoyt by telephone to inform her of CNRS' interest in filing a reply on August 30, 1/ C unsel for the NRC Staff notified the Licensing Board and the parties by letter dated August 16th that the Staff did not intend to respond to the pending motion.

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5-2 1982, and was informed that a reply would be received. Counsel for CNRS provided prompt telephonic notice to counsel for the Licensee (Mr. Brittigan) and counsel for the NRC Staff (Mr.

Bachmann) of this contact and of Judge Hoyt's. statement.

_ Respectfully . submitted,. .

E%M B. GM -k L M Elizapeth B. Entwisle 1 8118 Hartford Avenue Silver Spring, Maryland 20910 baa N.(~. %

Laura Macklili I dc O Institute for Public Representation 600 New Jersey Avenue, N.W.

Washington, D.C. 20001 5 (202) 624-8390 s

Counsel for Intervenor CNRS 4