ML20148A883
| ML20148A883 | |
| Person / Time | |
|---|---|
| Issue date: | 04/16/1979 |
| From: | Lieberman T NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7906020026 | |
| Download: ML20148A883 (1) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD Yh
^
In the Matter of Radiation Technology, Inc.
By-product Material License Lake Denmark Road No. 29-13613-02 Rockaway, New Jersey 07866 STAFF'S MOTION FOR LEAVE TO FILE BRIEF IN EXCESS OF 70 PAGES The Staff hereby requests leave to file a brief in excess of the 70 page limitation guideline of Appendix A to '10 CFR Part 2.
As the Staff sees it, the facts of this case tend to be controlling.
However, the substantial factual record here is at times confusing and disorganized at least in part, we submit, because the Licensee was permitted, over the Staff's objection, to testify and cross examine at the same time. (Tr. 596).
For the purposes of clarity, the Staff believes it important to set out the material facts in a separate Statement of Facts (beginning at page 2 and ending at page 29).
However, due to their impo.rtance, the facts are also discussed again in the Staff's arguments on both the question of violations and the question of the appropriate sanctions.
Fashioning our brief in this matter (with detailed citations to the record) has resulted in our exceeding the guideline page limitations by 14 pages, pennission for which is hereby requested.
Respectfully submitted, p
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James Lieberman
' Y'p[i'/ a Counsel for NRC Staff D
t Bethesda, Maryland g
6th day of April,1979.
T For the Appea; Br3 79060200 8 b_h,
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