ML20155A602

Notice of Author Appearance on Behalf of All Chemical Isoptope Enrichment,Inc in Proceeding.Listed Info Provided Per 10CFR2.713 (B).W/Certificate of Svc

ML20155A602
Person / Time
Site:	05000603
Issue date:	05/26/1988
From:	Irving S ALL CHEMICAL ISOTOPE ENRICHMENT, INC.
To:	Atomic Safety and Licensing Board Panel
References
24363, 88-570-01-CP-OL, 88-570-1-CP-OL, CP-OL, NUDOCS 8806100151
Download: ML20155A602 (8)

Text

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b ASLBP No. 88-570-01-CP/OL BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of: All Chemical Isotope Enrichment, Inc.

(A1ChemIE)

RE: Facility -1, known as "Centrifuge Plant Demonstration Facility" (CPDF) located at Oak Ridge, Tennessee NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney enters an appearance on behalf of All Chemical Isotope Enrichment, Inc.

(A1ChemIE) in the above-captioned matter. In accordance with section 2.713 (b) 10 C.F.R., Part 2, the following information is provided:

Name:

Stephen A. Irving Address:

702 S. Illinois Avenue, Suite 202-B, Oak Ridge, Tennessee 37830 Tolophone No:

613T 482-0028 -

Admitted to Practico (Tennessee):

October 12, 1977 United States District Court: October 12, 1977 United States Tax Court: May 24, 1979 Name of Party Represented:

All Chemical Isotope Enrichment, Inc. (A1ChemIE)

Respectfully submitted on this the 26th day of May, 1988 7

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Ste) hen /A. Trfing, Counsel A1ChemIE, Inc.

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Docket No. 50-603-CP/OL ASLBP No. 88-570-01-CP/OL BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of: All Chemical Isotope Enrichment, Inc.

(AlChemIE)

RE: Facility -1, known as "Centrifuge Plant Demonstration Facility" (CPDF) located at Oak Ridge, Tennessee CERTIFICATE OF SERVICE I hereby certify that true and exact copies of Notice of Appearance and Answer in the above-captioned proceeding have boon served on the following by deposit in the United States Mail, first clasu, on this the 26th day of May, 1988:

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Docketing and Service Station Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Bernard M. Bordenick, Esq.

Counsel for NRC Staff U.S. Nuclear Regulatory Commission Washington, DC 20555 Morton B. Margulies, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555

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Dr. Emmeth A. Luebke 5500 Friendship Boulevard, Apt 1923N Chevy Chase, Maryland 20815 Dr. Oscar H. Paris Atomic Safety and Licensing Board Panel U , P. . Nuclear Regulatory Commission W&chington, DC 20555 Michael H. Mobley, Director Division of Radiological Health Tennessee Department of Health and Environment T.E.R.R.A. Building 150 9th Avenue North Nashville, Tennessee 37203 Tennessee Department of Public Hea3th ATTN: Director, Bureau of Environmental Health Services Cordell Hull Building Nashville, Tennessee 37219 Mr. Wayne K. Scharber Director of Environment Tennessee Department of Hoalth and Environment 1st Floor Terra Building 150 9th Avenue North Nashville, Tennessee 37203 Mr. Frank Scanlon Deputy Attorney General Tennessue Attorney General's Office 450 James Robertson Parkway Nashville, TN 37219-5025 Ms. Carol White Federal Affairs Coordinator State of Tennessee 309 John Severe Office Building 500 Charlotte Avenue Nashville, TN 37219 l

The Honorable Roy F. Pruett Mayor Post Office Box 1 Oak Ridge, Tennessee 37831 l

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Mr. Jeffrey Broughton City Manager Post Office Box 1 Oak Ridge, Tennessee 37831 Mr. William D. Harris Fire Chief Post Office Box 1 Oak Ridge, Tennessee 37830 Ms. Virginia Dale Chair Environmental Quality Advisory Board Post Office Box 1 Oak Ridge, Tennessee 37831 The Honorable Kenneth E. Yager Roane County Executive Roane County Courthouse P.O. Box 643 Kingston, Tennessee 37763 The Honorable David O. Bolling County Executive, Anderson County Courthouse Main Street Clinton, Tennessee 37716 The Honorable Stanley Justice Mayor Post Office Box 303 Oliver Springs, Tennessee 37840 Mr. Howard Elliott City Administrator Post Office Box 303 Oliver Springs, Tennessee 37840 Mr. Ronald Herbert U.S. Department of Housing and Urban Development Office of Urban Development Action Grants 451 7th Street, S.W., Room 7274 Washington, DC 20410 Mr. Richard Duncan U.S. Departinent of Energy MS NE-34 Germantown Washington, DC 20545 e ,

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i Mr. Joseph Parks U.S. Department of Energy Post Office Box E Oak Ridge, Tennessee 37831 Ms. Jennifer Fowler U.S. Department of Energy Post Office Box E Oak Ridge, Tennessee 37831 Commission's Public Document Room 1717 H Street NW Washington, DC 20555 Division of Industrial and Medical Nuclear Safety Director U.S. Nuclear Regulatory Commission Washington, DC 20555 Reepectfully submitted,

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St'ephenX,trfing,\Counse1[korAlChemIE, 702 S. Illinois Avenue, SuMe 202-B Oak Ridge, Tennessee 37830 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Docket No. 50-603-CP/OL ASLBP No. 88-570-01-CP/OL BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of: All Chemical Isotope Enrichment, Inc.

(A1ChemIE)

RE: Facility -1, known as "Centrifuge Plant Demonstration Facility" (CPDF) located at Oak Ridge, Tennessee ANSWER Comes now All Chemical Isotopo Enrichment, Inc., (A1ChemIE), by and through its counsel, Stephen A. Irving, and for Answer to Notice flied by United States Nuclear Regulatory Commission in the Federal Register on April 28, 1988 would say:

1. Your applicant, A1ChemIE, by and through its attorney, Stephen A. Irving, will appear and make necessary presentations at the Pre-Conference Hearing conducted pursuant to the referenced notice.

2. Your applicant urges favorable findings to its request for 1,a construction permit and operating license at Facility -

(CPDF)

3. In support thereof, your applicant would show that the as listed issues pursuant to the Atomic Energy Act of 1954, amended, should bo resolved as follows:

Issue Pursuant to the Atomic Energy Act of 1954, as Amended

1. Whether in accordance with the provisions of 10 CFR 50.34, the applicant has described the proposed design of the facility including, but not limited to, the principal architectural and engineering criteria for the design, and has identified the major features or components incorporated therein to assure adequate protection of the common defense and security.

1 A1ChemIE Response: Yes

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2. Whether the applicant is technically and financially qualified to construct the proposed facility in such a way as to assure adequate protection of the common defense and security.

AlChemIE Response: Yes Whether the issuance of a permit authorizing 3.

construction of the facility will be inimical to the common defense and security.

AlChemIE Response: No Issue Pursuant to National Environmental Policy Act (NEPA)

4. Whether, in accordance with the requirements of 10 CFR f Part 51, the construction permit should be issued as f proposed.

AlChemIE Response: Yes

4. Additionally, ' your' ~ applicant would aver that its proposed operation involve .no radiological hazard to the environraent, and the environmental report filed igursuant to National Environmental Policy--Act of 1969 (NEPA) is sufficient to address and satisfact_orly cover concerne raised thereunder.

5. That your applicant will be prepared to present relevant information addressing matters raitynd in the Federal Register notice, as appropriate. -

1 Respectfully submitted,

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St'ephen/A.7r~ing,CounplforAlChemIE, v

702 S. Illinois Avenue, Suite 202-B Oak Ridge, Tennessee 37830

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