ML20004D038

Further Particularization of Intervenor Reed Contentions 1 & 3,per 810421 Special Prehearing Conference Order. Certificate of Svc Encl

ML20004D038
Person / Time
Site:	Callaway
Issue date:	06/01/1981
From:	Jeffrey Reed AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8106080228
Download: ML20004D038 (20)

Text

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• UNIrt.D STATES OF n! ERICA i*/ - M' NUCLEAR REGULATWY CO!2ISSION m U .

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BhFORE THE AT0!GC SAFETY ,d:D LICtt:iiING BOARD d 7 ;cI . -

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In the Matter,of Q , '.....,;

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) 0i UNICH ELECTRIC C0!? pry ) Docket No. SDI 50-483 OL

._j' y.y i& Callaway Plant, Unit 1) )

o FURTHER PARTICULARIZATICU OF D REED'S CCNTENTICN 1 /JID CONTENTICU 3 f NI 051981m Y

$- Ed9td e Special Prehearing Conference Order, dated 21 April 1981, it

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, \d[ld'ispecified that Mr. Reed should further particularize. Contention N .' ?~; ~Y ,

l and required that Contention 3 should be made more specific. The undersigned will, within the parameters of available information which may be changed at this or some future time, provide further particularization or specificity to said Contentions.

DISCUS 3ICfi l'r. Reed's Contention Number 1 states, " Applicant has not made sufficient arrangements with local governments, nor local agencies and organizations to meet the requirements of 10 CFR, Part 50, Section 50.47(b)". Such contention is still valid and.is based upon the following facts:

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1. Appendix C of the Callaway Plant Radiological Emergency Response Plan (RERP) contains letters of agreement with the Callaway County Sheriff's Office, dated 18 July 1979; the Callaway Memorial Hospital, dated 22 August 1979; and the Callaway County Ambulance District, dated 29 August 1979. All of these documents are over one year old and in one case the local signatory is no longer in.. office and can not make binding agreements. Other deficiencies exist in these letters as indicated below:

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a. The Sheriff's letter, of 18 July 1979, makes mention of a previous letter dated 11 October 1978, which apparcatly sets forth some aid to the plant. This letter is not a part of the U.E. RiRP. ' A statement in the final paragraph of the Sheriff's July 18 letter reads, "... final authority for all actions on the site shall rest with plant management".

This is an abrogation of office and is contrary to the oath of office taken by elected officials upon receipt of their commissions. Whether or not the 3heriff is knowledgable

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of radiation dangers, he must retain full authority for law enforcement activities within Callaway County, It appears obvious to Mr. Reed that this letter of agreement is based upon scant information and an over-eagerness on the part of

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Sher,iff to " cooperate" with Union Electric. ,

b. "The letter from the Callaway Memorial Hospital, of 22. August 1979, simply expresses a willingness to provide emergency or non-emergency care to U.E. employees. There is no agree-ment to accept or treat radiologically contaminated injured individuals as is required by 10 CFR, Section 50.47(b)(12).

c. The letter signed by the Callaway County Ambulance District is not valid because of a change in the chairmanship of the District and failure of the Applicant to renew this agree-ment. The letter was prepared by Union Electric and was cigned by an individual who has no concept of radiation dangers, nor does the Applicant indicato a potential hazard in the transportation and/or treatment of radiologically contaminated injured persons. The letter states that U.S.

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will provide triining for ambulance personnel, but after

, more than twenty-one (21) months since the signing of this letter, no training has been provided to the ambulance personnel concerning the hazards of radiation, except for that provided by the Callaway County-Fulton Emergency Management Agency.

d. No letter of agreement is filed from the Callaway County-Falton Emergency Management Agency which is the primary county / city organization responsible for all emergency response activities of local agencies in the City of Fulton or the unincorporated portions of Callaway County. No valid reason can be given for this lack of contact with said county agency, but the fact - that the Director of this county agency has had first hand experience .n protective actions in radiation fields and is a qualified radiological defense instructor (Missouri State qualified) tends to indicate that Applicant does not want to deal with individuals at the local level of government who have knowledge that may interfers with their obtaining needed agreements and an operating license.

e. No letters of agreement are filed in the U.E. RERP which indicate that members of the hospital or the ambulance crews have volunteered to accept radiation doso levels which are specified in Chapter 6, 6.5.1.2 a and b or the PAG's indicated in Appendix D. Ucither are their letters indicating that members of the Sheriff's Department have volunteered to expose themselves to radiation dose levels i

-6 specified above.

f. I!o letters of agreement are filed from local governecnts indicating they will or have the capability to pcrticipate in annual drills or exercises as is prescribed in Chapter 8, 8.1.2 nor are letters of agreement from ambulance and/or medical treatment facilitics, doctors or rescue personnel that they will or have the cacability to participate as is specified in Cahpter 3, 8.1.2.

2. Chapter 5 of the U.E. RERP, 5.4, specifies, "Callaway County is the lead county designated as the prinary corrmunications and control

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point for coordination of c=crgency operations during an off-site nuclear incident." Yet U.E. circumvents Callaway County and goes directly to the Disaster Planning and Cperations Office (DPCO):

a. "Recorrended protective actions will be given to the DPCG based on projected dose to the population at risk (at 5-7) .

b. "Of f-site protective actions are the responsibility of the principal stato agency (DP00)." (at 6-11)

c. "All areas outside of Union Electric's ::roperty are the responsibility . f the DPCO." (at 6-14)

3. The above deficiencies are noted in the U.E. PlRP and indicate a lack of =caningful arrangements with local government (s) in the infictted neuLs.

4. Pctitiencr's Ecply to ::hC Ctaff Response, :Inled 10 ':ov::bcr 1930, Pertaining to Contention I:utbar Cnc in Amended Petition of John G. Reed, served on 06 !?.rch 1981 to all pnties hec not boon chnnged or altered by Applicent's F6RP and I~r. Reed herewith P00R BREL

reaffirns specific actions that hnvo net, to date, been undertaken by Applicant which would, in Mr. P.ced's view, constitute " sufficient arrangements . . . to meet the requirements of 10 CFR 3S 50.47(b) ..".

Listed below, under respective sub-paragraph numbers of Section 50.47(b), are situations as currently exist relating to " standards" and a general statement of what is necessary to rectify the cendition as viewed by the undersigned:

a. See sub-paragraph (1) . No primary responsibilities for radiological emergency response have been assigned by local govern:ents or accepted by local agencies, local governmental organisations lack sufficient staff and equipment to augment an initial re:ponse to a radiological emergency on a continuous basis. Apolicant should provide funding, technical supnort and such othc/ aid as is needed.

b. See sub-paragraph (2) . No interface exists among onsite and all local governmental offsite support and response agencies. Applicant should establish formal liaisons with local governmental agencies.

c. See sub-paragraph (3). All local respcnse assistance in the eight governmental entieties impacted by the 10 mile EP4 have not been identified, nor has arranger.ent for the effect,ive use of such assistance been ande. Local officiils are unaware of the existance of Apolicant's near-site t. 0.F.

(Ec.crgency Operations Facility) or how interface will be arranged between U.E. personnel and local governments if and when local government attains the ability to fully P00R OR'G NA.

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rescend to a nuclear accident at the Callaway Plant. The Applicant needs to establish a liaison with all local governrents.

d. See sub-paragraph (4). Lccal response plans still do not

, exist. Missouri State DPCO planners have been augmented by Union Electric employees (see attached news item) and are attempting to prepare such plans. No local government, p to the knowledge of the undersigned, has agrecd to accept any plan developed by the DPCO, or have agreed to expend local funds to pay any excense involved in the preparation, exercising or imolementation of such a plan if and when an accident occurs at the Callaway Plant. Funding support at the local levels of government will resolve this matter.

e. See sub-paragraph (5). Procedures have not been established between Applicant and all local governments for notifiention in emergencies. No system for ::.cssage authentication exists, nor have secure communications facilities been installed.

Applicant funding, cooperation and assistance with all local governments is required.

f. See sub-paragraph (6). No means exist for prcmpt, secure, communications between licensee and all local Eovern:ents (except dial telephone service which is provided by several I

i comoanies and affords some dialing delay). The establishment of secure primary, secondary and tertiary, fail-safe, means l of communication between plant and local governments will l

resolve this situation. Such a system will require funding from the Applicant.

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g. See sub-paragraph (7). Formal infornational links still do

, not exist between the Applicant and all local governmental

, entities. Public information and training should be directed

! from the 1, cal levels of government in order to increase the credibility of news releases and training information. Funding, 1

cooperation and technical support is needed from Applicant by all impacted local governments to resolve this issue.

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h. See sub-paragraph (8). Insufficient governmental off-site i

' facilities, equipment and personnel staff exist to support an initial commitment to a radiological emergency on a sustained 1

basis. Funding and material aid by Applicant to all local governments will resolve this pmblem.

i. See sub-paragraph (9). No methods, systems or eqaipment exist

, for detection, monitoring and assessing the potential harm or hazardous effects to persons or property of radioactive gas, aerosol liquid, or particulate matter released into the

, environment from the Callaway Plant at local levels of govern-ment. Hand-held Civil Defense equipment is available to all local governmental agencies which can detect beta particles and measure gamma rays. No alpha particle . detection or measuring capability exists, nor does an iodine detection or measuring capability exjst. An independent capability to monitor and verify data or information supplied by the Licensee or the State of 11ssouri is deemed critical by the Director of the Callaway County-Fulton Emergency Fhnagement Agency. Applicant funding is required to resolve this issue.

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j. See sub-paragraph (10). Stato Protective Action Guides have

' een b developed but no local official or agency has accepted the resnonsibility for the expenses involved in taking actions involved in the their use. Funding by Applicant may resolve this issue.

k. See sub-paragraph (11). No means for controlling radiological exposure of off-site emergency workers have been established, nor have personnel identified in the U.E. RERP or the State of Missouri Nuclear Accident Plan as emergency workers agreed to expose themselves to any level of nuclear radiation which may result directly or indirectly from the Callaway Plant's operation. Direct liaison between all parties and funding q

by the Applicant may resolve this matter.

1. See sub-paragraph (12). Arrangements with local' medical and ambulance facilities and/or doctors, nurses and other medical personnel appear inadequate to guarantee proper care i or treatment of radiologically contaminated persons.(see sub-t paragraphs b, c, and e, above and attached letters). Applicant i

may resolve these deficiencies through cooperation with and

, funding of local Sovernments and agencies concerned.

m. See sub-paragraph (13). Applicant rosconsibility only.

n. See sub-paragraph (14) . The ability of local governments to adequately participate in full-scale exerciscs and/or drills is non-existant at this time. Cnly after all of the above standards have been met by local governments will this situation change.

Funding by Applicant to local governnents may resolve this issue.

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o. See sub-paragraph (15). Radiological emergency response training is not currently scheduled to be conducted by the 4" State of Micaouri DP00, due to a lack of funding for the fiscal year of 1981 and possibly 1932 (per conversation with DPOO personnel on 27 May 1981). Qualified, volunteer instructors are available in Callaway County and are activly engaged in radiological defense programs of instruction.

Periods of instructicn are dependent upon free time.of said instructors and, as such, are not adequate to perform the training needed to bring all local response persennel up to the degree of proficiency needed to be able to respond to an ,

exercise or drill as is anticipated to be scheduled in the near future so that Union Electric Company can obtain its li cens e,, Apnlicant Ibnding of local training or establishment i

of a full-time training force by Apelicant may solve this i deficiency.

p. See sub-paragraph (16). On 26 January 1930, DP00 representatives

made a trip to all governmental jurisdictions requesting they 1

be permitted to prepare a " free" local governmental RERP. S ome i

of these local governmental officials agreed to permit this pl?nning, but coecified that they would not automatically accept or pay any costs involved in the preparation or implementation r

of activities included in such a plan. As of this date, no such plan exists. A list of potential local resources 'was obtained by DP00 from Callaway County and Fulton officials, hit while i

items of equipment listed on the lists arc in Callsway County, j no authority for their use has baen obtained from the ownces i .

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nor have provisions been established to pny for the co:sts of operating such equipment, etc. Apelicant fun:iing r.27 aid in

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resolving the problems inherent in acceptance of radiological emergency response plans by local governe.ents in rural areas.

tiote: 12C, fem, and the State of Missouri DP00 have first-hand knosledge of the difficulty in trying to meet specified f

time li=its as established by licensing goals, when faced by increased workloads, reduced staff and lack of funds. Each local government and agency is faced with the sc:te problem.

The Applicant has recognized this fact by its contracting with the HU3 Corporation of Rockville, l'ar/Isnd so that assistance would be available to DP00 in performing local planning (see attached news clipping). Failure of Apnlicant to roccgnize this sa:a problems exists at the local levels of govern:ent will have an adverse effect on the timely licenuing of the Callaway Pl nt.

Because of the above conditions and an arcarent reluctance on the part of the Applicant to resolve these issues, Mr. Reed amends his Centention

!: umber 1 to include all cf the above specifications in compliance with the Special Prehearing Naference Order, dated 21 April 1981. I'r. Reed, at this tire notifys Counsel for the Applicant that there may be information containci herein that may be deemed to modiff or exp nd his response to Appliennts interrogatories and requests of documents (Set :lo.1) :hich has been served to all parties under separate cover. Testimon:t of local witnesacc or potential witnesses will be uced to establich facts as have been presented herein.

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I~r. hood's Contentien Nurnber 3 was required to be raade more specific.

Pending r-:ceipt of a decision from the LIEC, te the cc.itrary, the

. fcllowing information is added to caid contention in at effert tc meet the conditionc of the order, identified above. The contention roads:

"There has not been an ade ;uate definition of the t 11ocation of re:<runcibilitics for offsite cieryncy ple.nning bute:cen stato end l cal crpnisationc, is preeri.ic.i :.n Lili.c.C-CQh."

In diccutaicas alth DP00 pirators and agents of the applic nt, there has be .n " uifference of definition cf Part II. ?laanire Str.. . dards a d E r:1vtion Criterie. of "UREG-OoSA. LPC0 plr_aners and U.::.. n. cents

c recced a c;ncept thst as long as a function was perfer:cd by the applic'nt (linecasec) and the Stete, that no further re pirc..cnt for recronce w s re uirei. The ft.ct thrt Local (loc.;l fcVern::-nt) nac

. indicst od as hwing the :: ace function una mt';- an i:riication th.it cho t]d

.;tato not f.21fi31 the functicn, it, could be har.dled b;. local i:vtr.ranent (if tSc infor stion conteined, above, is chrllewd b:r Counccl for the A,plicant, the undercigned will call the individur_lc cone'-:rned as d.tneacca at the hcnring an:! use their testicany to substar.tir.tc thic claia). In 3 F.fferin; o: inion, !*r. 3ced clairs thrt . ten a funct4 on is .rclicated l

in both State and Lccal culuma, it in a re.1uircrent for m durl ce,p-bi]ity l

ta c:d st. T'no caly problem to recolve in thic i:.ct" ice ic .t.o or which of the crrni .ati en, trill hrw prirr:f re:3 on:-ib:.:it;. Lo pcrform. Thic view is cubutantit ted in I!GC]-0654, /.ppendir. 5 (et 5-0 ; howcr r, in I na : tt< r"t to Wtrin further clr.rific;ti;n and . Finnl deciaian on this controvercy, Fr. Reed h tc s ;bmitted the proble to tho ::iC for reaclution (cco attc.ched Ictter) .  ?'r. Reed will rithhold furth ?r crocifj estions on I

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tM r c:r.ttnti on, dth the arrroval of the Conrd, pcmi.it c rcecirt or a fin 11 ruling by the I:RC. i}. Iw u, at this time, L,1vcc notice tu the Appliennt thtt the cpecificativna added to hic Curtcation ::ur..bcr 3, ntcyc, my be ae+.ted to codify or expand his re:>r:onse te W lic .nt's Interrog-tariec and Rcquects for Documents ('ict !!o.1) daich have beer servec to :31 pcrtics under scparat,c ccvar. udditicnally, i'r. ?.ced gives notice to Applicant that irrecpective of e.iscaver / dccclines, he makes availnble to the Applicant any and all anformntion ana/or matericl in his pesacccion on an origoing basis. It is requected that Applictet merely make ticely requests for such inforrntion needed cnd defer from am2: sing a large number of interregttories cnd requests and submitting them on the Ir.st day of a discovery eeriod. Such actions uives the apr.ccrance of use of judicial Fymtwstics intended to p}. ace o en opporing party in a po*sition of dicadvcntage by havi .; to respond to an inordinate number of inquiries in the chortest tire pouaible according tc ectablisted schedules. Applicant is advised that continuation of such activities, even inadvertantly, can racult in counter-actions being taken by the undersigned. Mr. Reed vehemently opeoses any use of procedural tactics by any parties involved in this matter to gain any supncsed advantage. The iscues are tco importcnt to be the subject of legalistic horse-play. Fr. Reed asks the Board to trJ:c due notice of such tactics if they reoccur in ibture interrogatcries, regardless of the permissibility of such activitics under cristing rules.

SUITARY Pursuant to the provisions of Special Prehearing Conference Order, dated 21 April 1981, Mr. Reed has frared as accurate a description of the P00R ORIGINFm 1

cirew.::t.nces, situations and ccwditions as currently c: dst in support of his Contentions 1 and 3. While it is a6 reed that possible future actions by any of the parties concerned migr alter or cocpletely cha::ge the status of any or all of the above specifications and pcrticular-i::ations; the undersinged reserves the right to a:nend, modify or other-uise change existing contentions in whole or part to confor= to future circu::: stances. Also, Mr. Reed may forte. and submit new contentions if situations are created or occur whereby existing contentions do nct provide adequate coverage.

Referenced letters and assorted material identified herein have been provided to parties earlier under separate cover, or are attached hereto and identified as follows:

Callaway Sheriff's letter,18 July 1979 - Attachment 1 i

Callaway Memorial Hospital letter, 22 Aug.1979 - Attachment 2 Callaway County Ambulance District letter, 29 august,1979 -

Attachment 3 Referenced attached news item,15 May 1981, Attachment 4 i

spectfully su'

• tm Dated at Kingdom City, John G. Reed Missouri on this %1st Citizen of the Urdted States

! day of June 1981. of America i

RFD #1 l Kingdom City, !D. 65262 (314) 642-2769 l

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At,t.acament 1 Callaway Count; Shariff's Office VOLLIE C. "TED" 9%' 40NS b JR. SHERIFF

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' hgN7 CH ARLts SINotN

. McITH O'NE AL -

Cumfis oRYANT July 18, 1979 Mr. Wesicy T. Whaley .c

}!anager of Security, Code 1330 -

Union Electric Company '

P.O. Box 149 _

St. Louis, Mo. 63166 ,p

Dear Mr. Whaley:

In addition to the information set forth in my letter of October 11, 1978, I wish to furnish the following:

- There is one County under the jurisdiction of the depart =ent with a total ainpower force of eight. The Callaway 5cclear Power Plant is within our jurisdiction and due to milease limitations officers do not patrol this vicinity daily.

Each officer is equipped with a 357 or .45 caliber revolvers, cighteen rounds of am=unition, one cannister of mace, a billy and a nightstick.

There are marked sheriff's patrol vehicles assigned to the district in which Callaway Nuc1 car Power Plant is located. Additional equipcont such as shotgun and tear gas are located at the sheriff's office. Each patrol vehicle is equipped with a shotgun and a radio for constant coccunication.

Available to us are emergency services, Bomb Squad, Arson Squad, etc. We caintain a constant updated mobilization procedure to handle any emergencies ~

and/or disasters and have available sufficient diverse vehicles to i=plement

) such procedures.

We are in constant contact with your site through radio and land'11ne and will respond to a call for assistance from an established list of authorized plant personnel. The response ti=e of two units in the surrounding arca of the plant wculd be approximately twenty =inutes. Within a hour eight 7, ten police personnel could be at the site with total mobilization taking approximately two to four hours. Total mobilization would include additional assistance from other LLEA with whom we have assistance commitments, such as the Missouri State liighway Patrol. Fulton Police Department and surrounding County Sheriff's Departments.

Response equipment and response routes will vary according to type of

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pg 2, lit,t.ach::ent,1 Mr. Wesley T. Whaley ' July 18, 1979 O

j, incident at the site.

. It is to be noted that all action taken_within the site will be co-ordinated with plant management and/or security personnel. Furthermore, i due to the dangers of radiation and/or the release of radioactive materials, the final authority for all actions on the site shall rest with plant

. management. It is also understood that an on-going orientation session will be held to familiarize Callaway Sheriff's personnel and all other

response agencies with your site.

Ver,y tru _yours 6 DNab4 V. C. "Ted" Salmons, Jr.

Sheriff, Callaway County, Missouri E

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CALLAWAY M aaonint HOSPITAL

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. 828 J EF'FER SO N STREET

.d.~l } -n. FULTON. MISSOURI G5251 2 1L.3 2!

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TELEPHONE 314 642-3376

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s August 22, 1979 .

Mr. D. F. Schnell Itmager-Nuclear Engineering Unica Electric Ccrpany P.O. Box 149 St. Louis, Missouri 63166

Dear Mr. Schnell:

Callr.iay Cot:ity P.e:c.-!.al E0 spital Scard of Trustees and the Staff hwe discussed and erressed their wi.llingness to provida health services for thion Electric e=ployees, fcr either cr-argency or non-e .crgenc'j care.

The Callray Cot::ty Fe crial Eospital offers E ergency Rocu service trenty-fot:- bot: s a day, with a doctor en call around tha clcck. We ~

have a 4-bed Intansive Car 2 L* nit. Also, cur X-ray and Imboratory de- ~

partrunts b2ve 24-het coverage. .

The Calle.:ay Cot::ty Arbulance Service is based at the hospital, with 24-hotr coverage. -

l At scce later date perhaps we could have a discussica regarding any I special services needed by yotr ccapsny's 'e:ployees.

( s Please feel free to call or drop by for any other infor:ntien needed, i

l Sincerely, -

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l Sbar$nR.Heinlen Chief Executive Officer l

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Att.:tchnent 3 UNION ELCC rHIC COMPANY

' sos c=4rior sincer .sr. Lovis i

M AIL 8MC ADOncs s:

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August 29, 1979 Sr. Lout S. MO."6 3 e s e i

Callaway CountfI Ambulance Service -

828 Jefferson. Street Fulton, Missouri 65251 Gentlemen:

This letter will serve to confirm the agreement between Callaway County Ambulance Service and Union Electric Company concerning the transportation of personnel from the Callaway Plant.

Callaway County Ambulance Service agrees to transport patients from callaway Plant, including those who may have been exposed to radiation or who may have injuries complicated by radioactive contamination, to Callaway Memorial Hospital or elsewhere, as directed by Union Electric. Union Electric agrees to be responsible for Payment of all customary fees and charges. In addition, Union Electric will provide appro-priate training for ambulance personnel, and agrees to be responsible for any decontamination which might be required -

as a result of providing the above services.

Please signify your agreement by executing the accep-tance and returning to me.

Very truly yours,

'/

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.' ' ',k ieal G. Slaten Nuclear Environmental Engineer NCS/sla 1

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Approved f6dte/, O t. -

Don 61d F. Schnell Manager-Nuclear Engineering,, Union Electric Company Approved %ffw,,[

CalIaway Coudty Amoul.ance: Service

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U COLVING PRC'3LEMS THROUGH INVENTION & 'NNoVATION

att,achn;ent 4 i

Firm selectedi =

to help write ;

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7 -5 nuccear 7 paan p ST. LOUIS - Union hical plans in other pansw.I Electric Co. has signed a of the country, they can !

I letter of intent with a provide a very important private health physics and professional sersice I conv.:lting firm to help to the county courts. We sia te and mid N1issouri can assure ihe residents of ef ficials in developing the mid N1issouri that ne plan emergency response plan will be submitted without for the mile radius of the approsal of all the ,

the Callaw?y Co unty counties involve ; " he '

nuclear power plant. saul. j The NUS Corporation 'lhe NUS officials who i pf Rock sille, Nid., w as will be w orkin g wit h selected by UE to work county officials ia with the State Disaster preparing the local ;.lan Planning and Operations are Ernest N!urri health Office as well as officials physics supervisor:

from the four counties-in - Charles A. Crowe, senior-the 10 mile plani radius - health physicist; and Gary Ca llaw ay. Gasonade. C. Beatty, staff health N1ontgomery and Osage. physicist.

"We are pleased that Dunng the first week of NUS has agreed to assist Nlay, Crowe and Beatty the counties in preparing sisited :he four county l the emergency plan," said courts and office of the Joh n Bryan, vi c e- Fulton mayor to discuss president nuclear, in mutual planning e x-announcing the selection. pect a tio ns, UE said.

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"With much training in Detailed pla r.ni n g is l

health physics and e x- expected to begin next periense in deseloping mon t h.

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UNITED STATES OF A!HtICA NUCLEAR REGULATORY COMMISSION BEFCRh THE aTCMIC SAFETY 4:D LICENSING UOARD In the Matter of )

)

UNION ELECTRIC CCIPANY *

) Docket No STN 50-483

)

(Callaway Plant, Unit 1) )

! CERTIFICATE CF SERVICE I hereby cert.ify th t copies of the foregoing "Further' Particularisation of Reed's Contention 1 and Contenticn 3" were served thin Y2 day of -[ ' t , 1931 by depcsit in the U.S. mail, first class postige prepaid, to the part.ics need en the attached Sertice List.

V

/ John G. Reed

, Citizen of the United States of Accrica I

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U';ITED STATES OF APERICA l'UCLEAR REGULATORY CCIO!ISSICN BEFORE THE ATC![IC SAFETY id:D LICE!!SI!!G BOARD In the Matter of )

)

UNICN ELECTRIC C0!PANY ) Docket No STN 50-a83

)

(Callaway Plant, Unit 1) )

SER'! ICE LIST Jar.cc P. Gleasca, r,cquire Tho tas A. Saxter, Esquire Chairm.on Shaw, Pit,tr.an, Fotts & Tro.ic ridge Atcrle Safety end Licensing Board 1800 I-: Street,, :ic.

5L3 Gilm.ourc Drive ..achington, D.C. 20036 Silver 3,cring, FD. 20901 Kenneth M. Ghackes, Esquire

'r. Glenn C. Brir,ht Chackos and Hoarc Atoric Safcty and Licensing 314 : . Broa.dusy Board Panel St. Louis, IV. 63102

.C. *:uclear ite::ulatory Con:raccion

..achington, D.C. 20335 Fr. floy P. Leary, Jr., Esquire Office of the .xecutive Legal Dir.

Dr. Jerry R. Kline U3 ::uclear Rerulatory Cor.Tission ntoric Safety and Licensing . iachington, D.C. 2C555 Board Panel .

U.S. !!uclear itogul,, tory Co : ~in tion Docketin.c, arrl s r7 ice icetion

'.lantlngton, D.C. 20555 Office of the :ecret ary-1 S : uclear Ecralrtcry Cor.misaien Trova J. IIcarno, E quire 'dashington, 0.0. 20555 Dcputy Gener:2.1 Counael "is so':ri Publi c Service Cor.-incien Fr. iioward Steffen P.O. Box 360 Chacois, ::0. 65024 Je f ferson City, ITJ. 65102 Fr. Harold Lottran I'r. Fred Luckey !toute 1

. i ral I'.ou t.c 0.:enaville, MG. 65066 T.hincl.'nd, l'O. 65C6')

Mr. Gr::uel J . Birk I:r. Ilobcrt. G. 'ilright dox ".43 I:oute 1  ::orrison, MO. 65061 Fulton,:D. 65251 "r. e.arl Orc.in Box 146 Auxvance, ID. 65231

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