ML20236D386

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Memorandum of Telcon Between NRC Staff & Jp Larsen Re Discovery.* States Documentation NRC & Larsen Agreed to Produce,Per 890313 Telcon.W/Certificate of Svc
ML20236D386
Person / Time
Issue date: 03/15/1989
From: Hodgdon A
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
References
CON-#189-8312, REF-QA-99990004-890315 89-582-01-SC, 89-582-1-SC, EA-87-223, NUDOCS 8903230080
Download: ML20236D386 (5)


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. . March 15, 1989 DOCEifD cM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '89 tp 20 P 3 57 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

,n, sn In the Matter of Docket No. 9999004 (General License Authority WRANGLER LABORATORIES, LARSEN of 10 C.F.R. 40.22)

LABORATORIES, ORION CHEMICAL COMPANY AND JOHN P. LARSEN E.A.87-223 ASLBP No. 89-582-01-SC MEMORANDUM 0F TELEPHONE CONFERENCE BETWEEN NRC STAFF AND JOHN P. LARSEN REGARDING DISCOVERY On March 13, 1989, Ann P. Hodgdon and Norman Romney of the NRC staff participated in a telephone conference with John P. Larsen regarding discovery by the parties. During this telephone conference the Staff advised Mr. Larsen to review the discovery rules contained in 10 C.F.R.

Sections 2.740 g seq.

Mr. Larsen requested that the Staff produce formal documentation on Pry meetings or conference calls involving Region IV, the Office of Enforcement, or the Office of Investigations wherein the revocation of Mr.

Larsen's General License was discussed. The Staff agreed to make such documents available in so far as they may exist and are subject to ,

discovery under the Commissions regulations. Mr. Larsen was informed that '

formal documentation, or " meeting minutes," of meetings and conference calls are not prepared and that the results of such meetings in the form of Orders and letters addressed to Mr. Larsen have already been provided.

Mr. Larsen also requested, and the Staff agreed to provide, any correspondence between NRC and the states of Utah, Nevada, and Wyoming regarding the General License held by Mr. Larsen in so far as such 8903230000 890310 REo4 GA999 EXIWRANG 99990004 PDR D()k 7

correspondence may exist and is subject to discovery under the {

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l Commission's regulations. j Mr. Larsen agreed to provide the Staff a list of witnesses he intends to call by March 17, 1989, as provided by the Board's Order. 1/ Mr. l Larsen also agreed to provide to the Staff by March 29, 1989, the L following:

1) The names, addresses and professional qualifications of the persons Mr. Larsen will present as expert witnesses at the hearing;
2) The author, title, date of publication and publisher of all books, texts and papers upon which each expert witness will rely upon to support their testimony;
3) A discussion of each step of the process, including the chemical formulae for each step, by which UAA is produced from DU;
4) Information on the solubility of the UAA product;
5) A copy of the statement by Kevin Noack which describes Mr.

Larsen's operations and which 11r. Larsen made reference to during the pre-hearingconference(Tr.5)E/;and, 7.

i 1/ See Pre-hearing Conference Order,tiarch 1, 1989, page 11.

-2/ See transcript pages 1-76 from the pre-hearing conference held in Provo, Utah. Transcript pages are referenced as February)22,1989 (Tr. .

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6) A copy of the research results of.Dr. Narayani P. Singh of the 1 University of Utah regarding radiation toxicity levels in human bodies 'and which Mr. Larsen made reference to during the pre-hearing conference l

(Tr.6). l Respectfully submitted, y . 70 0  %

Ann P. Hodgdon Counsel for NRC Staff Dated at Rockville, Maryland this 15th day of March, 1989.

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March 15, 1989 1

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N UNITED STATES OF AMERICA  !

NUCLEAR REGULATORY COMMISSION 89 MR 20 P3 :57 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD kn n , ; . ib In the Matter of Me l Docket No. 9999004 WRANGLER LABORATORIES, LARSEN f

LABORATORIES, ORION CHEMICAL COMPANY (General License Authority of i AND JOHN P. LARSEN 10C.F.R.40.22E.A.87-223)

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l CERTIFICATE OF SERVICE I hereby certify that copies _ of " MEMORANDUM 0F TELEPHONE CONFERENCE BETWEEN NRC STAFF AND JOHN P. LARSEN REGARDING DISCOVERY" and "NRC STAFF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO JOHN P.

LARSEN" in the above-captioned proceeding have been served on the  !

following by deposit in the United States mail, first class, or as l irdicated by an asterisk through deposit in the Nuclear Regulatory l Comission's internal mail system, or as indicated by a double i asterisk by use of express mail service, this 15th day of March,1989:

Charles Bechhoefer, Chairman

  • Dr. Jerry R. Kline*

Administrative Judge Atomic Safety and Licensing l Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 John P. Larsen**

fir. Frederick J. Shon* Orion Chemical Company Administrative Judge 3853 North Sherwood Road Atcmic Safety and Licensing Provo, UT 84604 Board U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Washington, D.C. 20555 AppealPanel(5)* .

' i U.S. Nuclear Regulatory Comission ';-

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Atomic Safety and Licensing Washington, D.C. 20555 BoardPanel(1)*

U.S. Nuclear Regulatory Comission Adjudicatory File

  • Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Docketing and Service Section* Washington, D.C. 20555 I Office of the Secretary '

U.S. Nuclear Regulatory Comission D. Blair Spitzberg l Washington, D.C. 20555 U. S. Nuclear Regulatory Comission J 611 Ryan Plaza Drive Arlington, TX 76011 1

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-William L. Brown, Esq.* .

U.S. Nuclear Regulatory Comission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011, nn ,

6 M Ann P. Hodgdon Counsel for NRC Staff ce e

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