ML20023D804

Motion & Response to Applicant 830520 Motion for Summary Disposition of Jg Reed Contentions 1 Through 11 & 13 Through 20.Applicant Motion Should Be Denied Since Matl Facts Should Be Heard.W/Certificate of Svc

ML20023D804
Person / Time
Site:	Callaway
Issue date:	05/31/1983
From:	Jeffrey Reed REED, J.G.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8306030331
Download: ML20023D804 (17)

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i UNITED STATES OF AIGRICA- . .

NUCLEAR REGULATORY COMESSION '

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'ndtyETED BEFORE THE ATOMIC SAFETY AND LICENSING BCARD me^

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-) 'g3 $!-2 NO 57 1 In the Matter of

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$ UNION ELECTRIC COWAEY" ' , )- Docket No. STN $0-483

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, (Callaway Plant, Unit'l)- .) 7

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. INTERVENm?S M) TION AND RESPONSE TO . APPLICANT'S 30 TION FGt SUM'.ARY DISPOSITION- ,

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. .g On 20'May 1983, Ap' plicant submitted motions for sumary, disposition' c . . ,

of Mr. Reed's Contentions, numbers 1, 2, 3, 4, 5, 6,17, 's, 9; lof ilj ,

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13, 14, 15, 16, 17,'18,'19, and.20. Applicant claims that there.is cno

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siined;by Unic[kle$tric'Cciapan.y employees [ State ,anployees,(local. elected..

officials andN yfIanployeesk u

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Mr.' Reed will not"l conte'at' Applicant's motion for s6-ary disposition ,

i on his contentions, humb'erN 3,. 5[ Parts B a and C, 7, 9 10,'13,,17 ;18, y -, ;

19, and 20. While MS 5 teed does 'not agree' with Applicant that(the'se is' sues have been satisfactorily resolved, he feels that sufficient movement toward

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,t such resolution has been made that F.E.M.A. and N.R.C.1 reviews will be able 4 .g. '

to rectify the reatining problem.arsas. .

Mr. Reed will oppose sumns.ry disposition en Contentionsi numbers 1, 2, 4, 6, 8, 11, 14, 15, and 16. Each of these contentions will be enumerated and defended from Applicant's arguments, wtiich in some cases are merely biased opinions of Union Electric' Company employees and do not reflect the true state of affairs concerning local capabilities relating to implementing the Radiological Emergency Response Plan (s) of local govemment(s).

B306030331 830531 '

PDR ADOCK 05000483

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REED CWTENTION 1 (Staffing - Sheriff's Office)

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e Applicant supports'its' argument that there is no genuine issue to be

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. heard with' affidavits"from Mr. Walter M.' Clark and Mr. Gerald W. Stanfill.

Mr. Gerald W. Stanfill, in his affidavit) introduces himself hs "the Radiological Emergaicy Planner with the Missouri State Emergency Mana6ement sy

, Agency." Nowhere in said 'affi~ davit or qualifications and ' experience does

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Mr. Staafill indicate that he is an employee;of Union Electric Company.'who is merely working at the Missouri Emergency Management Agency. Mr._Stanfill a

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has been publica11FLintrodEced' at meetings.and his role in preparat'ich of

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- the R.E.R.P.s is ~welllinoisi locally.5 Failureofthisindividual-(andof g :. _

Counsel for' the Appliennt[to notify th ~ t'omic Safety and Licensing Board of this factiand make it a matter'of record in'these proceedings is

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looked upon by the uddersigned 'as subterfuge intended 'to present^ opinions -

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& without a taint of bia's'. "' f-

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The ApMeant Eed.suusary disposition of Reed Cententionsland.uses opinions' of itifeephoes jo suhrt its claims. Fai16re of said ampi 1'oyee

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4 to concur with ' App 5. cant s view.2ould result.in job loss and forfEiturd i

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income. At a time 'of high National unenployment, this enployee might not ,

jeopardize his livelihood, if he or she could agree with his or her employer's view on matters which will be the responsibility of' persons ,

other than said enployer. -

Mr. Reed can not'take the opinions expressed by Mr. Stanfill as those of an unbiased individual. Additionally, some of the basises by 'which ' ,

Mr. Stanfill reached his conclusions are faulty; i.e. his claim,that use of regular Sheriff's deputies to fulfill R.E.R.P. functions in Mmtgomery County are wrong. He has not talked with Sheriff Whyte, or he would have ,

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reached another opinion. On 19 and 21 May 1983, I talked with officers

.I e from Ceage, Gasconade and Montgomery counties and on 24 May 1983, I ,

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. talked with Sheriff Salmms of Callnway County. It is y understanding .a

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that no Sheriff has read the latest plan (REl P) or has he agreed that his office can operate without additional help. Letters of Agreement with the Missouri National Guard restrict use of its personnel-to areas "where the possibility of dangerous levels of radiation" do not exist.

l (see 10. N.G. ltr,idtd 6 January 1983, paragraph 2 (unnumbered), a. Also, Letters of Agreement with local ~ fire protection organizations do not include providing services as indicated by Mr. Stanfill.

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Mr. Clark's' assessment 'of how and whether or not the Callaway County Sheriff's Office cNop^erate is, based upon g talk with Sheriff Salmons, unfounded. Mr. 'Cidrd has visited with the Sheriff on several occasions, 4 but has not expressed.'the views of the Sheriff in his aff'idavit. '

Applicant's failure to obtain statenents from the four Sheriffs and

. ,9 ir. stead use the opinien of a hiased individual (it's ecployee) to support it's motim for summary position of this contention should be ' sufficient r

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l for the Board to,reath a conclusion that Applicant's Statement of Material

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! Facts are based upon faulty data and biased opinion and.that Applicant's

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action for surnary disposition should be denied.

REED CONTEttrION,2.(Staffing - Clerk's, Office)

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l Applicant, again,. has relied upon opinion other than that of the County Clerk in assessin'g d at' technical and legal requirements are for this

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office and in assigning duties to be performed has erroneously assumed that a non-trained individual (i.e. National Guardsmen) could move in to this office and perform the duties of the County Clork and his Assistant Clerks.

Mr. Clark, in his zeal to agree with Applicant, has not produced a shred

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'of real evidence that'"(R)outine. County /tity clerical functions would be disccntinued during the emergency period". No local R.E.R.P. makes this L ,

claim nor is there 'any statuent from an elected official to support this

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view. Mr. Clark's assertation that all special transportation assistence

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needs will have been'identh.fied prior to plant start-u'p and prior to the

c emergency period (Clask Affidavit, page 5, at 12.) is an indication of

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the naivete of"Mr.".Claxic's opinion'. Since, and ' hopefully, some period

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of time will pSeehiweerNjkad$ st' art-up and any' serious emergency,'it - '

r, is reasonable 'to; , tthti[ a Natio vehicle routing system 'and a' list ,

of handicapped I ni' i d Srs reqliiring transp' o rtation w' ill have changed. The l' ongary,the tias: span between " plant start-up" and the emergency

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the greater the change (in.p'et'ential, transportation ne'eds. Mr.l Clark is

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obviously wearing %oslp-coloredJgla'ases" ans he views.emergeEgy,needs.

I was advised by Mr. Clark, during a past conversaticn, that whm he

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left the enployment(at the.St'te a of. Missouri that he was to have. been ,

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hired by Union Electrio Company. This' employment was forbidden by a

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Pissouri State Statute which involves the hiring of government officials

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with whom private companiesy,have,had dealings. When the local Emergency Management Director'was ed, fir . J'Mr. Clark was imediately hired to* fill the 4 i G c. . : ,

,)ob. Since this joki, involves Federal funds, a replacement directar should I r. g. .

3 v, have been sought throuds advertisement. This' was not: done, as the equal opportunity law reqbres.' 'While I do not question Mr. Clark's credentials, I do question 'the independence of his opiniens. Since no written' guidance exists for the Cle it to follow during an emergency, and since Mr. Clark does not have the authority to order the County Clerk to follow any course of action; it is obvious that only a statement from the Clerk, to'the effect that he can perform all tasks assigned to him by the RERP, will suffice to

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('d i show that there is really no genuine issue of material fact to be heard

.I e in this matter. Mr. Reed's objection to opinions of Mr. Stanfill, in i

. this contention, are the same as in Contention number 1. Mr. Stanfill is a biased affiant and his opiniono do not reflect those of the other l

County Clerks for whom he professes to speak.

Based upm the fact that opinions expressed are faulty and filled with bias. Without' statements from the County Clerks involved that they l

can functim withouE additional help and perform all 'of the tasks' set forth in the RERP, it should be'no problem for the Board to reach a decision to deny Applicant's motion inlhis matter.

REED CONTENTION d (Emergency Action Level Scheme / Worker Notification)

Applicant presents an affidavit from Mr. John W. Baer to support its motion for summary disposition. Claims by Applicant that training for i

emergency response personnel (Applicant's Motion, at page 13) win be based upm the plans and inpler:enting procedures, is the basis for Mr. Reed's claim that there is a genuine issue to be heard in this matter since no implementing procedbIres or^ lesson plans have been developped to take the l place of simple guidance needed in the newly formed plans. As Mr. Baer ,

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( so aptly put it 'in his summary (Affidavit,19), "The development of l '

functional implementing procedures and proper training - - are key elements that will deternd.no efficient implementation of the emergency response plans." In the absence of such training and procedures, the only method of retaining operational concepts is to put it in the plans; therefore it

( should be viable for.the Board to see that there is a genuine issue

( outstanding in this h,ssue and deny Applicant's motion for sumary disposition.

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REED CONTENTION 8 (Radiation Detection Equipment)

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Applicant submits' an affidavit of Roger E. Linneman, M.D. to support

, its claim that'no genuine issue of fact remains to be heard in this issue. ,

fir. Iteed does r.ot question Dr. Linnoman's crodentials, but would rely upon i

his testimony to support his contention. In the event of a major release of radio-nuclides during a plant accident, all plans call for shelter to be the first defensive action to be taken. The length of the shelter phase o

is determined upm the' length of the release, but could be for a significant period of time. ~ This eliminates Dr. Linneman's assertation (page 4 of his Affidavit) that "- -the $bility to take appropriate protective action, ,e_.gs,,

evacuation." would eliminate the possibility of extremely high exposures t ,

to radiations. b Mr. Reed disagrees with Dr. Linneman's analysis that tests on contaminated persons can be performed in days to weeks after internal contamination by ItikanticipatedthatDr.Linnenanwilltestifytothe

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radio-nuclides.

fact that after specifid nuclides, which behave as normal body chemicals, are. ingested int 6 th4l metabolic system of man, a natural chelting action takes place which processes the elements through the body's bio-chemical '

l a system and locks some of these elements into the bone, muscle, lynph and other bodily parts. Those ingested chemicals that cannot be used by the l, system are excreted, along with those which do not have time to be locked I l

into bodily parts. ~ It ! is by expeditious identification of these radio-

! nuclides that their excretion from the body can be speeded by forced ingestion of cafe chemical conpounds which contain elements which vie with the radio-nuclides for bonding in the body. Example: If a body is injected with radio-iodine and sinultaneously non-radioactive iodine is

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injected into the system; both vie for space in the thyroid. Since the

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body does not differentiate between the radio-iodine and nomal iodine, it takes iodine from both sources, thereby reducing the ability of the thyroid to take only the radio-lodino. Additionally, the imediate intake of liquids has a tendency to wash the non-body-seeking elements from the

• system; thereby reducing intemal exposure from their presence. While this will not apply to extemal exposures, due to the fact that the damage will already have been caused by gamma and X-radiation which is not affected by internal flushing or forced ingestion of safe chemical conpounds to aid in replacing body-bonding radio-nuclides, it is the only method of reducing the body-burden of bee, muscle, ly::ph and body-seeking radio-nuclides.

Dr. Linneman's assessment that whole body counting is a far superior method for evaldating interna 1' incorporation of radionuclides is valid and is the most rapid system for' testing large numbers of people. The faster the populace can be processed for evaluation of internal uptake, the faster medical decisicas can be made as to what is needed to reduce potential body burdens of those who have serious internal contamination.

While Dr. Linneman'has a letter of agreemnt with Union Electric Co.;

to provide pertable'whole body counters ais not included, nor is there an agreement with the State of Missouri that such will be provided by Dr. Linneman for use in evaluating State and local emergency workers and citizens who may become internally contaminated by radionuclides released from the plant in the event of a plant accident.

Because of these obvious shortcomings; Applicant's motion for summary disposition of this issue is without merit and the A.S.L.B. should deny Applicant's motion.

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REED CONTENTION 11 (ReentryAtecovery Radiaticn Standards)

.1 Mr. John W. Baer,' in his affidavit, states that no inflexible standards i

i for radiation exponure should be incoroorsted into the' Neal RERP .and suggests that plant ' stability, some undefined level of residual contamination which will not result'in excess exposures of the population, preparedness, and social and' ecatomic costs of 'maintainin'g protective measures should be used to determine reentry and recovery activities. 'He uses PAGs as the deciding factor on radiological levels. .

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PAGs established by the State of Missouri (see MD. RERP, page B2, para.

, 4) under no circumstances ielies-acceptable dose. Add to this'the fact that no time limit'is included in a PAG, merely a projected dose rate (not an hourly, daily, weekly, monthly or yearly rate, just a rate). Under the circumstances outlined by.Nr,yBaer, it is conceivable.that reentry could he authorized anoe khe plant emergency was ended an'd ground contamination i .: . ..

l levels were 1 rem whole body and/or 5 rem thyroid because the costs of r

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! maintaining protective measures were considered in lieu of true consideration

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of rublic health risk. The authority for ordering reentry would not rest on the sholders of those' making recomendations, but en the local ~ official who issues such order. 'That' the rate of public exposure was 1 rem /hr and to the thyroid 5 rea/hr would not be considered; therefore permitting

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children and females of child bearing age to attain exposure levels of ~

12 rems whole body and 60 rems thyroid in a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period. It would constitute a grevious error, but be acceptable under Mr. Baer's stated views.

Mr. Reed's contention was directed at eliminating just this haphazard method of treating reentry. and recovery. If Federal and State officials are to reconnend when reentry / recovery is to be permitted, then they mst

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,g have some radiological' standard by which they form their decisions. It t is appropriate that= such be incorporated into the local RERP so that the s

local official will have some guidance by which he- or she can evaluate.the

., reconrnendations presented by' others. .Mr. Baer's statement (bottom line, page 6 to 7) that a rigidlradiation standard could be misleading and fails to ccnsider such factors as. plant stability and the potential for further uncontrolled radiation; releases is wrong and reflects a lack ofetrue understanding of h. some standard of exposure must be established if '

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the health and safety of persons- reentering an area porviously-evacuated because of radiological ocatamLnation. Because of Mr.'Baer's misuse of PAGs as acceptablevexpostre.or dose and his absence of knculedge that a dose is the result offexposurebat'ia 'given rate over a'specified time period) his assessment 'of .the need!for , reentry / recovery radiation standards is devoid i ..

i of merit and the ASLB >should deny Applicant's motion for sn-ary disposition on this iss'ue. NY7M i

l RF.ED CONTENTIONN1y(Inkrporated Cities, Towns and Villages) ' "

Applicant has relied upca :its'.deterndnation that the Commission's -

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regulations goverEk, sehgency plans to not state that Q incorporated municipalities within4he $PZ 'aust be assigned the role 'of a response organization in off eite.RNtPs@pplicant's argument, page 6); however j y.4 1- ,

Applicant has fairkidsted' t' hat the Concission is regulations provide :

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l. that an operating lic'ense applicant l'". .... shall submit radiological energency response plans for State and local govemmental entities in the United States that are wholly or partially within the plume exposure pathway Emergency Planning Zone (Applicants Governing Legal Standards).

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(10) i Under the terms of the Conscission's Regulation the only determination need is to decide whether' an entiety to be considered for inclusion in Radiological Emergency Response Plans (RERPs) is or is not a State .or 9

local governmental entity. If it is such an entity, it must be included in such RERPs. That it has or has no certain capabilities to fulfill the response needs required in RERPs is of no merit; Commission policy staten'ents have already acknowledged that RMtPs may have significant response impacts for n:any local jurisdictions, it still believed that RERPs were needed (see r )

44FR61123, NRC Policy). .Also,'that the operation of some reactors may be affected by the RERP} rule through inaction of State and local governments or an inability to comply [with such rules (see 45 FR 55402, hationale for the Final Rules). Applicant Nas' taken the view that for ease of planning, and elimination of duly established local governmental entities, it can ,

cut its financial involvement and speed the licensing of it's Callaway Plant. If thie were -tho' intent. of the Conenission rules on emergency plans, it is feasible to oldminate any governmental jurisdiction that fails to join in the emergency planning process and simply give that responsibility to the next higher governmental entity, County, State, or the Federal Government. This concept is not compatible with existing NRC Policy or the Connissicn's rules which include State and governmental entities that are wholly or partially within the plume exposure pathway EPZ.

Applicant's arguments aro understandable, but not consistant with NRC i

rules and as such the Board should have no problem in denying Applicant's notion for sunr:ary dispositius of this matter.

REED CONTENTICN 15 (Letters of Agreement)

Counsel for the Apolicant has relied upon the State Plan, Appendix 7, l

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! at 7.1, to substantiate its claim that " provisions set forth within these I letters of agreement ~ to which the State is signatory extend also to County i

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and municipal jurisdictions" (State plan, 7.1). Upon review of said l letters of agreement,-it is foand that no such understanding is included.

. The use of the National Guard is limited to areas where "the possibility exists that they might be exposed to dangerous levels of radiation or fal fallout" (see State Plan, page AG8) and letter from Hq, 70. N.G., dated 6 January 1983, para. 2, subpara' a.; which clearly states that in assuming the use of the Missouri National Guard, personnel will not be assianed to minnions g areas where tha possibility of dangerous levelg ,of radiation exists. ( Above ltr is Exhibit D' ,to Applicant's t,oI Clark Affidavit on Reed Contention 1) Additionally, App 3.icant has indicated that Appendix 4 of the RERPs for Gasconade,, Osage,and Montgomery Counties contain certain letters

. of agreement, but copies provided to the undersigned to not contain such *

, letters. In fact, no letters of agreement exist with such organizations listed in the RalPs of the counties indicated above, unless Applicant has withhold them from the undersigned's copies, or they have been obtained after Mr. Reed was provided copies of the aforenamed plans.

In an attenpt to obtain a letter of agreement with the Kontgomery County Sheriff's Reserve, an Applicant enployee wanted the letter to contain a l

statement 'that "all members had read the Montgomery RrRP and understood all of their duties and agreed to perform such", or words to that affect; when said enployee was well aware that no copy of the plan had been provided to any of the countics involved, and further, that no nember of the Montgomery Sheriff's Reserve had in fact road the document involved. This attenpt to obtain, in writing, a staten.ent of facts or urcunstances which do not reflect the truth, is cause to take serious review of all letters of

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t agreement. in order to essure that they actually reflect the offers of 1

assistance that they supposedly contain. It' appears that Applicant.is t

6 obtaining letters or agreenent that catein offers of limited assistance ; ,

and then,in its argmeents for suranary disposition of Reed's Contentions, broadening the terms of such letters to include areas ;which are not specified in said letters >of' agreement;i i .e. the letter of' agreement frost the Missouri National Guard which limits'inc1'sion u of guardsmen in areas where the l possibility of ' dangerous sediation exists, the same letter which Applicant e_. ,3t .

uses for its authoedty_td. include guardsmen as radiation monitors inside -

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the EPZ and as alte.r.,nktiesc W>

.; ,,c- perna law enforcement ddties~ inside'and en i

the periphry of thelEPZ, .all' areas where "the possibility of dangerous j , , - Op. ' , c# ,, , _ .,

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Mr. Reed'e 'ar tjis'not?' nit-picking [,words",buttheinconsstancy

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of what the .RERPs)&dt'.silyI,

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and what existing letters of agreement' .

agree t,o provide.. ,When';diffish.

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oes existf, problems exist. Applicant has,

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.y l in its arguments, failed.tof provide'any proof that invalidated Mer Reed's dd . ; q S ,7 5 - o ,

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[ Contention 15, an' ?the BeaWsh,W1d not ailow d

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its motienifor ' summary '

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REED CONTENTION [AND 16 (Protective Actions Against RadioiodiSes &

Messages With Instructions For Long-Term Sheltering)

Applicant has submitted a rather lengthly motion for sununary disposition of these issues and in doing'so, has substantiated Mr. Reed's contentions.

Intervenor'e concern was that citizens might be placed in the shelter phase for prolong periods of time and that 'such shelter, by Federal guide-lines,would prove effective'for not more than two hours against inhalants.

He concluded that to order ' shelter for more than said two hours, while retaining the protective mass between the shelteree and the radioactive

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deposits outside, protection ~ from radioiodines' woul'd'not be effective unless

.I e KI was made available to shelterees.

On page 10 of Applicant's motion,-lines 8 & 9, clearly states that KI provides thyroid protection and should be used in conjunction with sheltering, evacuation or other protective methods. KI is not an all-

. around defense against all'nuclides released in a plant accident.' It protects the thyroid only.i Possible adverse reaction to KI is not

. . t anticipated at the administered low doses proposed by the FDA '(see'page 11, lines 4,35f& 6 of Applicant's motien). Dr. Linneman, at page 4 of I

. A-his Affidavit, agrees that' *toit city reports on KI are related to chronic use, e.g., if administered' aver a period of years, and that the risk from a very small dose, g 130 mg., for an emergency situation is very small.

Additionally, Dr. Linnesun'has attested to the fact that pronpt use of KI will effective][reduceSiptekeof radioiodines, 'see Linneman affidavit at paragraphs 4 and:5. Linn'eman'a'grees that providing KI to individuals who are at risk of receiving "a dose of 25 rem or greater is sensible. His statements do not' cover' children and infants or pregnant women who are in a mors sensitive status regarding the effects of thyroid damage; however, during the course of 'an accidenh, one can not control the sequences of upcoming events; that is 'why it is called an accident, it is an occurance that is not under control.

Once a plant release occurs because of a breach of containment,and the population is ordered into shelter, all possible means of protection should be made available to them to protect themselves. These shelterees become, in effect, " institutionalized persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult". Their homes or shelters constitute the " institution" from which they. may not leave and

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I their immediate evacuation was previously'. determined to be infeasible or i

! very difficult. Such determination was the basis for issuing the order to take shelter. As such, these persons'are entitled to the same degree of

. radio-protection as patients in the State Hospital or emergency workers who are inalde the plume ~ exposure pathway or adjacent thereto en duty.

Applicant has presented'no viable reason for non-issuance of KI to the general populaticm based-upon either " danger to the public health cr 4 safety" or expenses involved in support of such issuance that may be

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" excessive"- (not balance as cost effective for the protection incurred).

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Indeed, its affiants have established that safe doses have been established by cor:petent authority for all age groups, that usage of such doses is most effective when.take prior to exposure to radiciodines and that even after such exposure, the' ingestion of KI can substantially reduce body uptake of said radioiodines. Any testimony relating to anticipated release l of radioiodines during'an accident can be countered by presentation of Nt' REG /CR-0388 SAND 78-0269;; Accident Descriptions for Emergency Response Exercise Scenarios, Accidents I, III, IV, & VI. , These are P'aR accidents and the views; expressed are those of the U.S. NRC. Such anticipated release estimates, as presented in NUREG/CR-0388 SAND 78-0269, cannot be waved away by Applicant's affiants.

There is no guarentee of what iodine concentrations will be released during a plant accident nor is there a guanentce that releases of significant time durations will not occur, In the event that citizens inside the EPZ are oniered into protective shelters (their homes, etc.) one does not know how long they will be inside such shelter or if contar::ination occurred before they went inside. KI has been proven to be safe and effective in

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, preventing uptake of radiciodinee by the thyroid. Applicant's affiants

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j have substantiated this fact in their testimony. ' Applicant has ndt given any reason for non-issuance other than opinions related to PAG exposures in excess of 25 rem. PAGs 'do not represent ' acceptable doses (W. RERP, page B2, para. 4).

Based 'upon the fa$ts, as presented above',' the' ASLB ~s hould have no

difficulty in deterndning that 'there a.e material facts' of genuine issue -

to be heaid in this nuiNer Md deny Applicant's mot' ion for sumary

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disposition of these c,ententions. .-

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For the above reasons,)z n$ej,% grvenor Reed respectfully moves that the ,

i Board firid that. ' Y.ref%. .r . , . .. . . i . . D.c hessisass) genuine issiles to be heard'in'the above captioned ,

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matter and deny Applican, t's motions for surmary disposition of Reed. <

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Contentions, numbers 1, 2, 4, 6, 8, 11, 14,:15, and 16.

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.r;. y es tfully . submitted,.- i Dated this 31stdayz a m .g u. neou .

s of May 1983, in "

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, ;Citisen of.the United States of: America, Kingdom City, W. RFD #1 q

.. , Kingdom City, Missouri 65262 >

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UNITED STATE 3 0F AMlRICA ,

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,y NUCLEAR nminrfmY COMESSI(3 i '.,..

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. IEPGtE TH5' ATOMIC SAFETY AND'LICBISING BOARD.

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UNION ELECTRIC C0MpANY f

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Docket ^ N'o'. 'S'I'W 30 483 ,

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(Callaway Plant, Unit 1)i' 4 ,

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I, John G. Reed,,'eblennly' affirm that' th's statements' contain'ed * ,

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in"INTEP.VENGt'5lA.;n,IOTION AND EESPONSE

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I T'O, s.APPLIEANT . ' l S')OT SUFF.ARY DISPOSI' TIM (RM.'aggp S CCW'idTIONS", da .,. a$ (.  ;

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siged:-

7'  ;, , ' John G. Reed -

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UNITED STATEC OF A}StICA-NUCLEAR REGULAT(RY COMMISSION '

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BEFCRE THE ATOl'IC SAFETY AND LICE?! SING BOARD

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In the Matter of )

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UNION ELECTRIC 'COIPANY -) Docket No. Sn50 483

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"C_ERTIFICATE OF SERVICE Y

I hereby certify that' the docum'ent ' attached, hereto was'serYed' this -

31st May ' S 196 by deposit 'in the U.S.: mail, first' day of .

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class postage prepaid,;upon the'following:- - -

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James P. Gleason, Esq'uire , Mr. Glenn O. Bright. .j..  ;,

Chairman,, Atomic : safety agtd '.y.j , Atomic Safety 'and 'Licessing Board

. Licensing Ecard. Panel, "'

Panel . ..

513 Gilmoure Drive;, ,

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. U.S. Nuclear . Regulatory-Colmmission Silver Spring, Maryland;20901~  ; Washington, D.C. 20555 , O ,

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Dr. Jerry R. Kline' , Docketing and Service Section Atomic Safety. and: Licensing ; Office of the Secretary Board Panel .

,U.S. Nuclear Regulatory Commission .

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 e

. Washington, D.C. 20555 ,

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, Itobert G.- Perlis, Esquire?

Kenneth M. Chackes[ Esquire . Office of the Executive Legal Director Chackes and Hoare,

&- ;U.S!, Nuclear Regulatory Commission 314 N. Broadway Washington,'D.C. 20555 ,

St. Louis, MO. 63102: >:9, Thomas A. Baxter, Esquire . :.-<

Shaw, Pittman, Potts & Trowbridge.'

1800 M. Street, N.W.

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Washington, D.C. 20036 -

Atomic Safety and Licensing - '

Appeal Board .

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 - '

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• hand delivered

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/ John G. Reed ..

Citizen of the United States-of America -

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