ML20023D081

Proposed Findings of Fact & Conclusions of Law.Declaration of Svc Encl

ML20023D081
Person / Time
Site:	San Onofre
Issue date:	05/16/1983
From:	Pigott D ORRICK, HERRINGTON & SUTCLIFFE, SOUTHERN CALIFORNIA EDISON CO.
To:
References
ISSUANCES-OL, NUDOCS 8305190195
Download: ML20023D081 (5)

Text

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.BEFORE THE ATOMIC SAFETY AND LIC' ING BOARD s,q

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In the Matter of ) A Omcor twe. f

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COMPANY, et al. )

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(San Onofre Nuclear Generating )

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APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW DAVID R. PIGOTT EDWARD B. ROGIN SAMUEL B. CASEY JOHN A. MENDEZ of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation 600 Montgomery Street San Francisco, California 94111 Telephone: (415) 392-1122 CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY P.O. v.ox 800 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (213) 572-1212 Attorneys for Applicants, Southern California Edison Company, San Diego Gas & Electric Company, City of Anaheim, California and City of Riverside, California Dated: May 16, 1983 9305190195 830516 PDR ADOCK 05000361PDR g

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, o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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SOUTHERN CALIFORNIA EDISON ) DOCKET NOS. 50-361 OL COMPANY, et al. ) 50-362 OL

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(San Onofre Nuclear Generating )

Station, Units 2 and 3) -)

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APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW A. FINDINGS OF FACT.

1. Through contracts with three area hospitals and three area doctors, Applicants have made arrangements for medical services for members of the general public. The existance of those arrangements has been conveyed to the offsite agencies. (Applicants' Exhibit #51, Appendix A; Hauch, Tr 7118-19, 7123-24, Applicants' Motion to Augment Record, Attachments 3-6).

2. The emergency plans developed by the offsite agencies having the responsibility to provide medical services to persons having suffered excessive radiation include a listing of the local medical facilities that would provide necessary diagnosis and treatment. (Applicants' Motion to Augment Record; Attachment 1, County of San Diego, Emergency

Plan, Annex 5 Medical / Health, Appendix H, " Radiological Emergency / Disaster Response Procedure" and Attachment 2, Interjurisdictional Procedures to the Count? of Orange Incident Response Plan for San Onofre Nuclear Generating Station, Interjurisdictional Procedure #12, (Decontamination) with Attachment 7.6, Decontamination Support Hospitals.)

3. Regional medical facilities that may be of value in providing medical services on an ad, hoc basis have been identified by Applicants and that information has been conveyed to offsite agencies that may have need for such facilities. (Applicants' Motion to Augment Record, Attachment 3, Letter of May 13, 1983 from Fred Massey of SCE to Ms.

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Carole Hopwood, Manager, Emergency Management Division, General Services Agency, County of Orange.)

B. Conclusion of Law

1. Applicants have met their burden of proof and have demonstrated a reasonable assurance that the public health and safety can and will be protected in that adequate medical services for contaminated injured persons can be provided in compliance with 10 CFR S 50.47 (b) (12) .

Dated: May 16, 1983. Respectfully submitted, DAVID R. PIGOTT EDWARD B. ROGIN SAMUEL B. CASEY JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY By DAVID R. PlGOU David R. Pigott Counsel for Applicants 1

DECLARATION OF SERVICE BY MAIL I am over the age of eighteen years and not a party l

to the above-entitled cause. My business address is 600 Montgomery Street, 12th Floor, San Francisco, California 94111 I served the foregoing APPLICANTS' POSITION RE COMMISSION'S MEMORANDUM AND ORDER .CLI-8 3-10 ON OFFSITE MEDICAL SERVICES, APPLICANTS' MOTION TO AUGMENT RECORD and APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW, dated May 16, 1983, by depositing a true copy thereof enclosed in the United States mail or by Express Mail service, at San Francisco, California, on May 16, 1983, enclosed in a sealed envelope with postage thereon fully prepaid, addressed as follows:

Stephen F. Eilperin, Esq. *Dr. Cadet H. Hand, Jr.

Chairman, Atomic Safety and c/o James L. Kelley, Chairman Licensing Appeal Board Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board U.S. Nuclear Regulatory Dr. Reginald L. Gotchy Commission Atomic Safety and Licensing Washingtonn, D.C. 20555 Appeal Board U.S. Nuclear Regulatory Commission *Mrs. Elizabeth B. Johnson Washington, D.C. 20555 c/o James L. Kelley, Chairman Administrative Judge Dr. W. Reed Johnson Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• James L. Kelley, Chairman Robert Dietch, Vice President Administrative Judge Southern California Edison Co.

Atomic Safety and Licensing Board 2244 Walnut Grove Avenue U.S. Nuclear Regulatory Commission Rosemead, CA 91770 Washington, D.C. 20555

• Charles R. Kocher, Esq.

• Lawrence J. Chandler, Esq. James A. Beoletto, Esq.

Donald F. Hassell, Esq. Southern California Edison Co.

Nuclear Regulatory Commission 2244 Walnut Grove Avenue Office of the Executive Legal Rosemead, CA 91770 Director Washington, D.C. 20555

• DESIGNATES MAILING BY EXPRESS SERVICE

I-Mrs. Lyn Harris Hicks Mr. Lloyd von Haden GUARD 2089 Foothill Drive 3908 Calle Ariana Vista, CA 92083

, San Clemente, CA 92801 James F. Davis

• Richard J. Wharton, Esq. State Geologist University of San-Diego Division of Mines and Geology School of Law 1416 Ninth Street, Room 1341 Alcala Park Sacramento, CA 95814 San Diego, CA 92110 Phyllis M. Gallagher, Esq.

Janice E. Kerr, Esq. 1695 W. Crescent Avenue J. Calvin Simpson, Esq. Suite 222 Lawrence Q. Garcia, Esq. Anaheim, CA 92801 California Public Utilities Commission Atomic Safety and Licensing 5066 State Building Appeal Board San Francisco, CA 94102 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Charles E. McClung, Jr., Esq.

24012 Calle de la Plata Atomic Safety and Licensing Board Suite 330 U.S. Nuclear Regulatory Commission Laguna Hills, CA 92653 Washington, D.C. 20555 Alan R. Watts, Esq. Samuel J. Chilk Rourke & Woodruff Secretary of the Commission California First Bank Building U.S. Nuclear Regulatory Commission

-10555 North Main Street Washington, D.C. 20555 Santa Ana, CA 92701 James C. Holcombe Louis Bernath San Diego Gas & Electric Co. ,

101 Ash Street San Diego, CA 92101 Executed on May 16, 1983, in the City and County of San Francisco, State of California.

I declare under penalty of perjury that the foregoing is true and correct.

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