ML20033F225
| ML20033F225 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 03/01/1990 |
| From: | Rutherford P ROCKWELL INTERNATIONAL CORP. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#190-10027 89-594-01-ML, 89-594-1-ML, NUDOCS 9003190017 | |
| Download: ML20033F225 (24) | |
Text
-.
, te Y
C0ChETED MarcW V,c}ggo
'90 f1AR--8 A10 :42 I
UNITED STATES OF AMERICA
.:rocE cr ncgpa,;y NUCLEAR REGULATORY COMMISSION 00CKUWG !, wvirr MNl
~
ATOMIC SAFETY AND LICENSING BOARD i
Before Administrative Judge:
[
Peter B. Bloch-In the Matter of Docket No. 70-25 l
Request to renew till ROCKWELL INTERNATIONAL CORPORATION October 30, 1990 Rocketdyne Division (Special Material License ASLBP NO. 89-594-01-ML-Number SNM-21)
MOTION TO STRIKE' PORTIONS OF INTERVENORS' WRITTEN PRESENTATIONS
)
AND BRIEF IN SUPPORT:
(Proposed) MEMORANDUM AND ORDER Rockwell International Corporation, hereinafter referred to as the r
Applicant, hereby moves to strike the written presentations and/or portions thereof of the parties referred to below, and to dismiss from these proceedings those parties which have failed to submit proper written presentations within the time allowed. This motion to strike.is based on 10 CFR 2.1233(e) and 10 CFR 2.730 and is submitted within 10 days of receipt (February 20,1990) of the intervenors' briefs.
9003190017 900301
{DR ADOCK 070 g 5 12 @
0
l<L i
"3 Sh; :e A.
L
- Introduction
.The basis of this motion to strike is 10 CFR 2.1233(e) which states:
".... the presiding officer may, on motion or on the presiding -
officer's own initiative, strike any portion of a written presentation or a response to written question that is cumulative, irrelevant, immaterial. or unreliable." (underline added for emphasis)
The requirements for written presentations are set forth in 10 CFR 2.1233(c) and Judge Bloch's Memorandum and Order, dated October 5,1989
- (pages 3-4).
10 CFR 2.1233(c) states that:
"In a hearing initiated under 9 2.1205(c), the initial written presentation of a party that requested a hearing or petitioned for J
leave to intervene must describe in detail any deficiency or omission in the license application, with references to any particular section or portion of the application considered deficient, give'a detailed statement of reasons why any particular
'section or portion is deficient or why any omission is material, I
and de' scribe in detail what relief is sought with respect to each
~ deficiency or omission."
Judge Bloch's Memorandum and Order states that:
2
-l 4
h
.(
'"Each' concern ~ included in the. direct case must be clearly stated and accompanied by'a relevant reference to a licensing standard contained in 10 CFR 70 and applicable to a general special-materials license...
For each concern, the filing should specify the relief that is sought should the concern-be demonstrated to be true (e.g. denial of license or specification.of a condition of licensing)'.
Failure to comply with this paragraph of my order will invalidate the entire discussion of the concern, which may be treated'as if it had not even been filed..."(footnotes omitted)
Although some intervenors attempted to meet these requirements, they were not met for all concerns, as discussed below in the sections on individual intervenors.
The intervenors' briefs include numerous
- inadequacies and shortcomings.
These include irrelevant and immaterial issues which have no. bearing.en the renewal application, failure to comply with the hearing requirements discussed above, excessive redundancy and repetition both within and between briefs, discussion of mult'iple issues under one concern, subjective opinions, and unsubstantiated concerns and allegations.
The attached matrix (Exhibit 1) of the intervenors' concerns shows that there is a large amount of redundancy.
Some intervenors even voiced this themselves in their petitions (e.g. LAPSR and CTBTG).
Since there is no benefit in answering the same question more than once, we I
believe that the redundant concerns should be eliminated to permit more 1
3
7
- 7
,, 7, 4 efficient and effective responses. The Applicant interprets the word E
" cumulative" in 10 CFR 2.1233(e) as being synonymous with redundant and-LT repetitious.
This is supported by Webster's Ninth New Collegiate I
Dictionary which defines cumulative as " tending to prove the same point (asinevidence)".
Accordingly, cumulative, redundant or repetitious evidence should be stricken.
L The Committee to Bridge the Gap, the Southern California Federation of Scientists and the Susana Knolls Homeowners Association i
filed a petition (November 25,1989) for admission to these proceedings in partnership, expressing a single set of concerns.
Accordingly,.these three parties should be limited to a single presentation.
- Instead,
' three separate briefs were filed. The result of the separate briefs has l
i been, (1) two essentially redundant (cumulative) briefs by the CTBTG and
.J the SCFS and (2) a third br_ief by the SKHA which bears no relation to the concerns of the original petition. Accordingly, we respectfully request that.the CTBTG and SKHA briefs be stricken.
1 Specific actions are requested on the intervenors' briefs as folloWs.
Committee to Bridge the Gap f
The Applicant files no motion with respect to this brief at this time.
4 i
E
-l i
v,.
< e?
Los Angeles Physicians for Social Responsibility The Applicant respectfully requests that concerns 1, 2, 3, 4 and 5 be stricken from the record.
- s.
Concern 1.
This concern questions the Applicant's record and its ability to comply with radiation standards to protect the public.
No pertinent references are provided to any deficiencies or omissions in the application to substantiate this allegation.
In addition, there are no references to any standards with which the Applicant is in non-i compliance. The concern appears to address itself, in part, to the I
issues raised in the so-called Dempsey report. The Applicant intends to j
i respond to these issues in the 60 day response to Mr. Jon Scott's concern no. 111.
Concern 2.
This concern is addressed in our discussion of the 4
SKHA brief in which LAPSR joined.
i 4
Concern 3.
This concern, relating to the plutonium release accident analysis, duplicates the same concern expressed by the Committee to Bridge the Gap (# 1).
Since we intent to respond to the CTBTG brief in 60 days, we move to strike this LAPSR concern.
Concern 4.
This concern, relating to the cumulative addition of hazardous waste and R/A waste is not relevant to the SNM-21 license renewal. The reference cited, 10 CFR 70.22(i)(3)(xiii), does not 1
1
L 1
y
.m require the Applicant to compute combined health effects and' risks of~
R/A and hazardous waste as implied by the intervenors' concern.
The~
reference therefore is not relevant to the concern.
If guidelines were to exist-for comparing or adding health effects due to R/A and all possible hazardous meterials, we are confident we would comply in view of the exceedfegly low levels of exposure from both R/A and hazardous materials attendant with operation of the SSFL. With respect to R/A exposures, we comply with the limits of the existing regulatory framework,-10 CFR-20 and 10 CFR 100, which provide limits for operational and cccidental releases from nuclear facilities.
Concern 5.
This concern is related to worker health and safety but-does not refer to any radiation protection standards and OSHA standards that the Applicant fails to meet.
In fact the Application shows the exposure levels of workers to be well below the standards of 10 CFR 20.101 to 20.108 (e.g. Annual Review of Radiological Controls-1988,N00lTI000301). The intervenor asserts that 10 CFR 70.23(i)(3)(v) requires measures-to mitigate (minimize) doses to workers in the event of an accident.
The On-site Radiological Contingency Plan discusses a multitude of measures that exist to accomplish this objective, including engineered safety systems and alarm systems (chapter 2), on-site emergency response teams'(chapter 4), equipment, facilities and procedures-designed for emergency radiological response (chapters 6 and l
7).
In addition, radiation safety procedures that minimize worker exposure during normal operation also play a role in minimizing exposure during accidents.
There is no requirement to calculate potential doses N-6
?
a v
f
\\
to workers during' accidents.- The Applicant believes that an epidemiological ~ study of workers or the public is unnecessary, since the probabilities of either worker or public health effects, compared with the naturally occurring cancer rate would not be observable.
The Applicant is however willing to cooperate' with any state or local funded study.
Jon Scott The Applicant respectfully requests that the concerns I, II, IVA, IVB and V be stricken from the record.
Concerns no. I, and V of the brief do not comply with 10 CFR 2.1233(c) which requires that, for each concern, specific sections of the. Application be referenced and specific reasons given as to why the Application is deficient.
Much of the discussion in concerns I, IIIA, IIIB, IVA, IVB and V' refers to the dangers of toxic chemicals and/or hazardous wastes including beryllium. These non-R/A issues have no bearing on this SNM-21 renewal application.
Concern II relates to the requirement for a quality assurance plan in the application (10 CFR 70.22(f)).
Such plans are required only for
" plutonium processing and fuel fabrication plants" which are defined in 10 CFR 70.4(r).
Operations to be performed at the hot lab under SNM-21 7
t
<1-t:.
~ do not-include any of those described in 10 CFR 70.4(r).
The SNM-21 license is not a " plutonium processing and fuel fabrication plant"
- license (Memorandum to Peter B. Bloch from Colleen P. Woodhead (Counsel I
for NRC Staff), November 30. 1989).
a t
Concern IVA relates to earthquakes. Mr.-Scott refers to 10 CFR-70.22(f);as a basis for' this concern.
This standard applies only to
" plutonium processing and fuel fabrication plants" which are defined in 10 CFR 70.4(r).
Operations to be performed at the hot lab under SNM-21 3
do not include any of those described in 10 CFR 70.4(r).
The SNM-21 license is not a " plutonium processing and fuel fabrication plant" 1
license (Memorandum to Peter B. Bloch from Colleen P. Woodhead (Counsel for NRC Staff),' November 30. 1989). Mr. Scott also alleges that the Hot I
Lab (originally built to the Uniform Building Code (UBC) standards) will not meet today's UBC standards. We believe it does meet today's UBC standards for the following reasons. The thick inner walls of the Hot Lab were designed to more exacting shielding and containment-requirements, which exceed UBC requirements for industrial buildings.
For-instance, the wall thickness requirement for industrial buildings (per UBC) of the height of the Hot Lab is 5.5 inches.
The walls of the Hot Lab are 42 inch reinforced concrete, clearly exceeding UBC requirements either in 1957 or'1990. The Hot Lab' stands on bedrock, not on alluvial' sand and therefore liquefaction is not an issue.
The design basis earthquake forces specified in the current UBC (for zor.e 4) are
- equivalent to ground motion of approximately 0.4g peak horizontal ground acceleration.
This compares with a maximum expected horizontal ground l
8 l
y.,
z.
, L.
4 ' 1
.j acceleration of 0.3g ~at SSFL due to the Siri-Santa Rosa fault.
There is no requirement in either the UBC or in NRC regulations to upgrade-structures each time the UBC is changed, unless by NRC-mandated l
retrofits.
None have been'so ordered.
The Applicant finds the claims q
t of the-intervenor to be unsubstantiated and immaterial and requests dismissal of this concern.
Concern IVB relates to brush fires and their potential to impact
~
the integrity of the Hot Lab, and its contents. Mr. Scott refers to 10 CFR 70.22(f)'as a basis for this concern. This standard applies only to 3
" plutonium processing and fuel fabrication plants"'which are defined in 10 CFR 70.4(r). Operations.to be performed at the hot lab under SNM-21 do not include.any-of those described in 10 CFR 70.4(r).
The SNM-21 license ~is not a " plutonium processing and fuel fabrication plant" license (Memorandum to Peter B. Bloch from Colleen P. Woodhead (Counsel for NRC Staff), November 30. 1989). -This concern is therefore r
irrelevant.
Concern'V alleges thatL the Applicant has not adequately documented historical spills and incidents. On the contrary, the Applicant has fully documented, using pre-existing records, all incidents within the last 20 years in R. T. Lancet's submittals to Judge Bloch, dated September 27, and November 4, 1989.
The record has therefore been j
established and is completed on this issue. Mr. Scott has failed to-provide evidence of any additional incidents, not documented in the above submittals, and therefore the concern should be stricken.
9
Southern California Federation of Scientists The Applicant respectfully requests that the brief be stricken from.the record, and that the Southern California Federation of Scientists be dismissed from these hearings for the following four reasons.
Firstly, essentially all of Dr. Plotkin's concerns are identical (i.e. cumulative) to those of the Committee to Bridge the Gap.
These two parties were admitted together as intervenors, with a common set of concerns (Judge Bloch's Memorandum and Order, dated December 7,1989).
Since we intend to respond to the CTBTG brief, we see no reason to respond the SCFS brief.
Secondly, with a few exceptions (nos. 10,24,26) relating to criticisms of the Radiological Contingency Plan, the brief does not comply situ 10 CFR 2.1233(c) which requires that, for each concern, specific sections of the Application be referenced and specific reasons given as to why the Application is deficient.
Thirdly, the use of blanket references to 10 CFR 70.23(a)
(1),(2),(3),(4),(6),(9),(10) and (11), and 10 CFR 70.23(o) does not satisfy the requirements of Judge Bloch's Memorandum and Order of October 5, 1989.
Each concern listed should be related to a specific standard.
10
V,,.
And finally, much of Dr. Plotkin's discussion is irrelevant and/or repetitious. Dr. Plotkin makes unsubstantiated allegations and at times makes incorrect statements. Concerns no. 19, 20, and 31 have not been further substantiated since their original introduction. The following paragraphs detail on a case by case basis why each concern should be stricken.
1.
The NRC requested the application for 400 gm so as to maintain jurisdiction. There is not 394 gm of SNM contaminating the Hot Lab.
Mr. Plotkin's assertion that there is, is unsubstantiated.
2.
Item is not relevant.
3.
Item is not relevant.
Rockwell intends to start experiment using uranium then move on to the other transuranics, implication that Rockwell can substitute U for Pu is unsubstantiated. Assumptions about how TRUMP will be performed are incorrect and unsubstantiated.
4.
This item was not admitted as a relevant concern.
5.
The charge that transport into and out of the SSFL is " flawed" is unsubstantiated.
11
pj.
I..
6.
Charges of Rockwell's " propensity" for not releasing information, destroying of records, and " extensive site contamination" are L-unsubstantiated. The DOHS violation pertaining to Building 29 was an allegation and it has since been dropped by DOHS.
?
7.
Needing additional information is not a relevant issue. The I
remainder of the concern regarding releases and accidents is unsubstantiated.
8, Same as concern #1.
9.
Charges about " management attitudes", and "Rockwell Record" are unsubstantiated.
i 10.
Mr. Plotkin's claims about how the Hot Lab operates are u,nsubstantiated. His claim about filter testing is unsubstantiated.
His claim about the contingency plan is conjecture. His comments on D&D activity are irrelevant.
11.
This item was not admitted as a relevant concern.
- 12..
Intervenor's statement about " structural integrity" of the package involved in the Pennsylvania accident is unsubstantiated'in addition to being wrong. The fact that no specifications for material packaging are given in the documents available to Mr.
12
L c-l l
Plotkin does not mean that they don't exist and is therefore l
irrelevant.
l 13.
Statement about what Rockwell insists is unsubstantiated.
The 394
[
gm issue is raised again, which is unsubstantiated. Appendix C l
reference is inadequately defined.
Intervenor has not established the relevance between the experiment referred to and TRUMP-S other than to assert that it used Pu and operated at a temperature range of 410 650 C.
Intervenor's claim that fire and earthquake would de: troy and bypass filters is unsubstantiated.
Intervenor's claim that 5% of Pu would be released is unsubstantiated.
14.
This item was not admitted as a relevant concern.
4 15.
Mr. Plotkin's conjecture regarding additive exposures to plant personnel is not substantiated.
Intervenor has not substantiated why exposure to public from D&D operations at SSFL should be anything greater than trivial.
16.
Specification of D&D program is not relevant.
Rights of company with respect to NRC are not relevant.
Claim about license application being a ploy and Rockwell's intentions is unsubstantiated and irrelevant. Appendices A and B are not relevant.
C was included in 13 above.
17.
This item was not admitted as a relevant concern.
13 m.
F L
i j.
L e
18.
Mr. Plotkin's 394 gm claim is unsubstantiated. His claims about Rocky Flats are irrelevant and unsubstantiated. His comments about people changing jobs are irrelevant.
19.
Again, 394 gm is unsubstantiated.
His statement that Rockwell management d ~;n't have concern about contamination is incorrect i
and unsubstantiated. His remarks about record keeping, training, i
and accidents are unsubstantiated.
20.
Mr. Plotkin has given no substantiation on this item.
r 21.
Intervenor's allegation about the company's criticality controls i
are irrelevant and unsubstantiated.
The charges about Rocky flats are unsubste.ntiated. Claim about the amount of Pu that might be present is. unsubstantiated.
22.
Claim about how Rockwell can perform TRUMP experiment is unsubstantiated.
See #3 above.
23.
Intervenor has no complaint.
Security system is included in the Application which was sent to the NRC. Oversight is provided by the NRC.
24.
Claim that there is 400 gm Pu is not substantiated.
Basis for assumption of filter failure has not been substantiated.
14
I c,
l Assumption of 5% relNse fraction not substantiated.
Implicit i
r assumption that all releases remain airborne not substantiated.
Claim about test program not substantiated. Claim about change of filters not substantiated. Claim about hot cell circulation requirements not sutitantiated, j
t 25.
Implicit charge that the cost to D&D the hot lab is excessive is unsubstantiated and irrelevant, i
26.
394 gm charge unsubstantiated.
Statement about small amount of Pu release is unsubstantiated.
Statement about worst case fire is unsubstantiated.
Statements about fire fighting systems are unsubstantiated.
Statements about " loose ends", and fire departments are unsubstantiated.
t
-27, 394 gm charge is unsubstantiated.
28.
_ Charge that Rockwell management is simply not interested in safety is wrong and ansubstantiated.
Charge of excessive cost to D&D hot lab is repetitious, unsubstantiated, and irrelevant.
Conclusion that " place is so contaminated that such gigantic amounts of money are required" is misleading, unsubstantiated, and irrelevant.
Conclusion that "the only way such contamination takes place... is for management not to concern itself" is wrong and unsubstantiated, as are other statements about management.
Retirement of Mr. Lancet is irrelevant.
l.
uV:
^
^
.i^
s 29.
Statement about record keeping is unsubstantiated.
Statement about deficient' accident analyses not substantiated.
Statement about hazardous nature of D&D work not substantiated.
30.
Addressed in 28 above.
31.
No substantiation provided.
i 32.
Statement that Hot Lab. has outlived its usefulness is conjectural and unsubstantiated, t
33.
Statement about earthquake triggering a severe accident.is unsubstantiated.
Estelle Lit and Jerome E. Raskin The Applicant respectfully requests that the brief be stricken from the record, and that the intervenors, Lit and Raskin be dismissed from these hearings.
Neither the brief nor the amendment complies with 10 CFR 2.1233(c) which requires that, for each concern, specific sections of the l
Application be referenced and specific reasons given as to why the
-Application is deficient.
16 t
r w
m
/
- v.,
The use, in the amendment, of blanket references to 10 CFR 70.23(a)(3) and (4), 10 CFR 70.31(d), 10 CFR 20.l(c) and 10 CFR 70.9 does not satisfy the requirements of Judge Bloch's Memorandum and Order i'
of October 5, 1989.
Each concern listed should be related to a specific standard.
.Two of the concerns (Al and A3) in this brief are cumulative to Jon Scott's concern no. III and therefore should be stricken.
Concern A2 relates to demographics utilized in calculating off-site population doses.
This concern does not refer to any portion of the Application and does not refer to any deficiencies.
Rocketdyne's annual environmental reports which are part of the Application (e.g.
Environmental Monitoring and Radiological Effluent Report, RI/RD89-139) use demographics which are extrapolated from the last 1980 census data.
These demographics are not inconsistent with today's actual population.
Concern B relates to the recently published study by the BEIR committee, " Health Effects of Exposure to Low Levels of Ionizing Radiation".
The conclusions of this study have not resulted in any i
changes to the existing radiation standards.
Hence the concern is irrelevant to this licensing proceeding.
In addition, the practice of ALARA (as low as reasonably achievable) required of all licensees maintains personnel exposures well below the existing radiation standards and minimizes risk.
17
[
Susana Knolls Homeowners Association The Applicant respectfully requests that the brief be stricken from the record and that the SKHA intervenor be dismissed from these hearings.
THe SKHA was admitted together with the CTBTG and the SCFS with a common set of concerns. The SKHA brief does not address these 33 concerns admitted in Judge Bloch's Memorandum and Order, dated December 7, 1989, in which he admitted SKHA to intervenor status. The brief should therefore be ruled inadmissible.
The brief does not comply with 10 CFR ?.1233(c) which requires that, for each concern, specific sections of the Application be referenced and specific reasons given as to why the Application is deficient.
The demographics quoted by SKHA are not inconsistent with the demographics utilized in Rocketdyne's annual environmental reports which form part of the Application (see response to Lit / Raskin concern no.
A2).
The collection of newspaper articles is unreliable evidence (10 CFR2.1233(e)).
18
]
4 f
Natural. Resources Defense Council (NRDC) and Don Wallace l
The Applicant notes that two intervenors, the NRDC and Don Wallace have dropped out of the case. Given the failure of the parties to i
submit briefs by the February 20, 1990 deadline, the Applicant respectfully requests that they be dismissed from these hearings.
The Applicant respectfully submits this motion to strike the aforementioned portions of the intervenors' briefs and submits, as Exhibit 2, the attached proposed form of order (10 CFR 2.730(b)).-
r The Applicant affirms undtr nnalty of perfury that the foregoing
~
is true and correct to the best of its knowledge and belief.
e Philip D. Rutherford, Manager Nuclear Safety and Reliability Engineering Rocketdyne Division Rockwell International dated at Chatsworth, California this 1st day of March, 1990 19
~
m u
===========================================~-~.._..____================________==____=m=________________============
INTERVENORS* CONCERNS RELATIVE TO THE SNN-21 LICENSE RENEWAL CT8TG ' LIT / RAS SCFS.
LAPSR SCOTT. StHA
===.,==== =====______
______________33.-
LOW PLUTONIUM ACCIDENT RELEASE FRACTION / PLUTONIUM TONICITY 1,13-1,13,24,26 1,3 ROCKWELL REFUSAL TO SIGN 81NDING AGREE 8eENT TO CURTAIL ACTIVITIES 2
2 F!! LURE TO DESCISE TRUNP-S ADEQUATELY IN APPLICATION 3
3 TRANSPORTATION TO AND FROM MOT LAs 5
5 INADEQUATE MEASUREMENT OF R/A MATERIALS (SOIL, WATER, AIR) 6,20 A1,A3 6,20 1
I,III RELEASE OF R/A MATERIALS DURING ACCIDENTS DUE TO FAULTY EQUIPMENT OR OPERATOR ERROR 7
7 NO TMROUGMPUT LIMITATIONS INCLUDED 8
8 INADEQUATE TRAINING OF PERSONNEL 9
9
~ SAFETY OF SOURCE PACKAGlWG FOR SMIPMENTS (TRUCK INCIDENT) 12 A1 12 7
' SYNERGISTIC MINING OF EXPOSURES FROM MULTIPLE SOURCES 15 15 4
DEFICIENCIES IN APPLICATION (MISC.)
16 16 ENVIROWNENTAL IMPACT STATEMENT IS REQUIRED 17 17 SPECIAL NUCLEAR MATERIAL CONTROL AND ACCOUNTING 18,25 15 INADEQUATE HEALTN PHYSICS 20.
APPLICATION DOES NOT SPECIFY ISOTOPE OF PLUTON!UM 22 22 SECURITY PROTECTION AGAINST SABOTAGE !S INADEQUATE 23 23,34 INADEQUATE RECORDKEEPING 25 V
. INADEQUATE FIRE PREVENTION AND RESPONSE 26 26 6
IVB EZISSIONS FROM ROUTINE OPERATIONS HAVE 8EEN EXCESSIVE 27 27 SAFETY FEATURES ARE INADEQUATE 25 FAILURE TO ANALY2E ACCIDENT TRENDS 29 29 FACILITY 700 OLO TO BE OPERATED SAFELY 31 32 FACILITY IS LOCATED IN SEISMICALLY ACTIVE APEA 32 33 IVA Q
.. c SAFETY CONSIDERAf tN: OF MOT LA8 PROJECTS (h. <>
10 l
IADEQUATE MANAGERfa. AND ADMINISTRATIVE CONTROLS 19,28,30 INADEQUATE CRITICALITY CONTROLS 21
._4 F"ILURE TO ANALYZE ACCIDENTS AT SIMILAR FACILITIES 31 a
DEMOGRAPHICS. RISKS TO NEAR8Y POPULATION A2 2
I ROCKWELL UNFIT TO POSSESS SPECIAL MATERIALS LICENSE II l
STATE ATTOURNEY GENERALS MAZARDOUS WASTE VIOLATIONS At RECE!T STUDIES $NOWING R/A HEALTH EFFECTS TO BE MIGNER TMAN PkEVIOUSLY THOUGHT 8
1 UORKER HEALTH AND SAFETY 5
i DEFICIENCIES IN MEDICAL ASSISTANCE 6
DEFICIENCIES IN QA PROGRAM ll w========= ============n================ ============== m=== === m=== " = = = _________= m z=== =========== =======.________________====e===
l
~Lc i^
s i;:
i G
EXHIBIT 2.
March __, 1990
[
UNITED STATES OF AMERICA L
NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD r
L Before Administrative Judge:
Peter B. Bloch g
t n
L Ju
' In the Matter of Docket No. 70-25 Request to renew till i
ROCKWELL INTERNATIONAL CORPORATION October 30, 1990 Rocketdyne Division (Special Material License ASLBP NO. 89-594-01-ML Number SNM-21)
(Proposed) MEMORANDUM AND ORDER (Applicant's Motion To Strike Portions Of Intervenors' Written Presentations)-
Upon good cause shown, pursuant to 10 CFR 2.1233(e), the following written submissions and/or portions thereof of the following parties are hereby ORDERED stricken:
z L
1.
Los Angeles Physicians for Social Responsibility:
concerns 1, 2, 3, 4, and 5.
2.
Jon Scott: concerns I, II, IVA, IVB and V.
3.
Southern California Federation of Scientists: entire submission.
4.
Estelle lit and Jerome E. Raskin: entire submission.
5.
Susana Knolls Homeowners Association: entire submission.
I h
p,,g }.
Je a
e p, %o f.?
g ; ;- -,
N, y
f} }
,-fi' c.o L
IT.IS.FURTHER' ORDERED that the cases of the following parties be
^-
i
.. dismissed for failure to submit a proper written presentation within the y
u9 time allowed:
u l1 p
-1.-
Natural Resources Defense Council
't 2.-
Don Wallace
. 1 4
t.
3.
. Southern Califorhia. Federation of Scientists 4.
Estelle Lit and Jerome E. Raskin 1
V' 1
!?
Susana Knolls Homeowners Association u.--
r
'lI Respectfully ORDERED, i
L-V i
Peter B. Bloch; Presiding Officer
]
1 s
.i I
- )
c g
4 4!
?
y g
T
' I:.
._c
' [4
',4 4
I
.a. :-s
.i e
2 i
M.
1 o ',.
=
. g
.' /(
y 4
g W
3 c-ti er-*
s
+-*~ w e,
.a+w,*-=
->e-'*
+ ' " " -
e
s L
.. h l {,t hE ILO UdNitC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION n-8 A10:42 ATOMIC SAFETY-AND LICENSING BOARD t;r n u H EM.1w Before Administrative Judge:
(wcet % Gi. b vlCI Peter B. Bloch MN In the Matter of Docket No. 70-25-ML Request to renew till ROCKWELL INTERNATIONAL CORPORATION October 30, 1990 Rocketdyne Division, ASLBP NO. 89-594-01-ML (Special Materials License NumberSNM-21)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Motion To Strike Portions of Intervenors' Written Presentations and Brief in Support; (Proposed)
Memorandum and Order has been served upon the following persons by Federal Express, and in accordance with the requirements of 10 CFR Sec. 2.712.
Administrative Judge Administrative Judge Christine N. Kohl, Chairman G. Paul Bollwerk, III Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board Appeal Board
- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington DC 20555 Administrative Judge Howard A. Wilber 4
Atomic Safety and Licensing Board U S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Peter B. Bloch Presiding Officer Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comm.
' Washington, DC 20555 Atomic Scfsty and Licensing Qpeal Board U.S. Nuclear Reguletory Commission
- 'dashington, DC 20555 y
4 I
l i
1 Administrative Judge Gustave A. Linenberger, Jr.
Special Assistant Office of the General Counsel i
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission i
U.S. Nuclear Regulatory Commission Washington, DC 20555 i
Washington, DC 20555 l
Estelle Lit Jon Scott 18233 Bermuda Street 6 Roundup Road l
Northridge, CA 91326 Bell Canyon, CA 91307 j
l Jerom? t. Raskins, et al Cecelia Riddle c/o 18350 Los Alimos Senior Librarian Northridge,.CA 91326 Chatsworth Branch Library 21052 Devonshire St Chatsworth, CA 91311
, Donald W. Wallace Daniel Hirsch 1710 North Cold Canyon Rd.
Committee to Bridge the Gap Calabasas, CA 91302 1637 Butler Ave.
Suite 203, Los Angeles, CA 90025 Sheldon C. Plotkin Phd, PE Richard Saxon, President Executive Board Representative Los Angeles Physicians So. California Federation of for Social Responsibility Scientists 1431 Ocean Ave. Suite B 3318 Colbert. Ave.
Santa Monica CA 90401 Los Angeles, CA 90066 Barbara Johnson Mary Nichols, Esq.
President Natural Resources Defense Susana Knolls Homeowners Assn.
Council c/o 6714 Clear Springs Rd.
617 S. Olive St.
Susana Knolls, CA 93063 Suite 1210 Los Angeles, CA 90014 Da';ed at Los Angci 1 W day of Muc.p, CA, this 4
, 1990 Mcwicmet M. M Office tW Nuclear Safety and Reliability ROCKWELL INTERNATIONAL CORPORATION Rocketdyne Division ci l
.