ML20236D453
| ML20236D453 | |
| Person / Time | |
|---|---|
| Issue date: | 03/15/1989 |
| From: | Hodgdon A NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Jim Larsen LARSEN LABORATORIES, INC., ORION CHEMICAL CO., WRANGLER LABORATORIES |
| References | |
| CON-#189-8320, REF-QA-99990004-890315 89-582-01-SC, 89-582-1-SC, EA-87-223, NUDOCS 8903230110 | |
| Download: ML20236D453 (5) | |
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[EWED gOMEJfgD,QLon Ifarch 15, 98 y 7,4 UNITED STATES OF AMERICA "j;;#>
NUCLEAR REGULATORY COMMISSION Ng'40ber C 01-4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s
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Docket No. 9999004 WQ ~
In the Matter of (General License Authority / M g 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 NRC STAFF INTERROGATORIES AND REQUEST FOR PRODUCTION OF 00CutiENTS TO JOHN P. LARSEN Pursuant to 10 C.F.R. il 2.740, 2.740b and 2.741, the NRC staff hereby files the following interrogatories to be answered fully and in writing and under oath and affirmation by the licensee, John P. Larsen.
For each response to each interrogatory the person providing the response shall be identified by name and educational qualifications.
INTERROGATORY 1 State the names, addres:es and professional qualifications of the persons the licensee will present as expert witnesses at the hearing.
7.
INTERROGATORY 2 State the author, title, date of publication and publisher all books, texts and papers upon which each person named in the response to Interrogatory 1 relies to support that person's testimony.
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l 8903230110 890315 REG 4 GA999 EXIWRANG 99990004 PDR psot
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INTERROGATORY 3 Discuss each step of the process, and provide the chemical formulae i
for-each of the respective steps-in the process, by which Uranyl Acetyl
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Acetate (UAA)isproduced'fromdepleteduranium(DU).
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INTERROGATORY 4 l
Provide information on the solubility of the UAA product.
INTERROGATORY 5 Provide dates on which air quality samples were taken at the licensee's Utah operations and the results of analyses on those samples.
DOCUMENTS REQUEST 1 Please provide copies of any documents pertaining to air quality I
l samples and test results referenced in Interrogatory 5.
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DOCUMENTS REQUEST 2 l
During the pre-hearing conference, held in Provo, Utah on
.l February 22, 1989, Mr. Larsen indicated that he had a written statement from Kevin Noack, a former employee, which he indicated would describe the 1
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licensee's operation.
(Tr.5).1/ Please provide a copy of the referenced statement prepared by Mr. Noack.
DOCUMENTS REQUEST 3 During the pre-hearing conference, held in Provo, Utah on February 22, 1989, Mr. Larsen made reference to research regarding toxicity levels in the human body by Dr. Narayani P. Singh of the University of Utah.
(Tr.6).
Please provide a copy of the referenced research results.
Respectfully submitted, hh OA.
p Ann P. Hodgdon Counsel for NRC Staff Dated at Rockville, Maryland this 15th day of March, 1989.
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See transcript pages 1-76 from pre-hearing conference held February 1989 in Provo, Utah. Transcript pages are hereinafter referenced 22,(Tr.
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March 15, 1989 t p! H i m
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 89 ttAR 20 P3 :57 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD fuhin ht In the Matter of UN Docket No. 9999004 WRANGLER LABORATORIES, LARSEN LABORATORIES, ORION CHEMICAL COMPANY (General License Authority of AND JOHN P. LARSEN 10C.F.R.40.22E.A.87-223)
CERTIFICATE OF SERVICE I
I hereby certify that copies of " MEMORANDUM 0F TELEPHONE CONFERENCE BETWEEN NRC STAFF AND JOHN P. LARSEN REGARDING DISCOVERY" and "NRC STAFF INTERR0GATORIES 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 ir.dicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, or as indicated by a double 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 Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 John P. Larsen**
lir. Frederick J. Shon*
Orion Chemical Company Administrative Judge 3853 North Sherwood Road Atomic Safety and Licensing Provo, UT 84604 Board U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 AppealPanel(5)*
l U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel (1)*
U.S. Nuclear Regulatory Commission Adjudicatory File
- Washington, D.C.
20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Docketing and Service Section*
Washington, D.C.
20555 Office of the Secretary -
U.S. Nuclear Regulatory Comission D. Blair Spitzberg Washington, D.C.
20555 U. S. Nuclear Regulatory Commission 1
611 Ryan Plaza Drive Arlington, TX 76011 l
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. j j William ~L. Brown, Esq.*
3 U.S.. Nuclear Regulatory Comission J
611 Ryan Plaza Drive, Suite 1000 l
Arlington, Texas 76011 1
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(fA, Ann P. Hodgdon Counsel for NRC Staff EB 4.
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