ML20028B210

Response to Interrogatory 26 & Revised Interrogatory 47. Certificate of Svc Encl

ML20028B210
Person / Time
Site:	Callaway
Issue date:	11/26/1982
From:	Jeffrey Reed REED, J.G.
To:	UNION ELECTRIC CO.
References
NUDOCS 8211300170
Download: ML20028B210 (3)

Text

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UNITED STATE!) OF AMERICA NUCLEAR REGULATORY COMMISSION gg .

BEFmE 'lHE ATOMIC SAFETY AtO LICENSING BOARD In the Matter of ) '82 tCl 29 A10:08

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UNION ELEC'IRIC COWANY ) Docket No. STN 50-483 ,.

) fa + u lElivv (Callaway Plant, Unit 1) ) RANCH REED'S RESPONSE TO APPLICANT'S REVISED INTERROGATCRT 47 On 19 November 1982, Counsel for the Applicant telephoned the 4

undersigned and requested oral response to certain questions which were posed in an attegt to expand responses by the undersigned to previously submitted interrogatories. Mr. Reed agreed to clarify his response to Applicant's Interrogatory 26 and permit Applicant to rephrase its question nusber 47.

The following answers are submitted in accordance with the telephode agreement:

Interrogaroty 26. I have not performed a study on the subject.

A tertiary response capability is considered a minissas for an emergency M

respcose capability and the use of three people to perform said duties is a conservative estimate of what is required.

Intarrogatory 47 (Revised). I have identified no aquipment in ,

response to Applicant's Interrogatory 45. Designation of protective devices and defensive measures is part of the planning process and the undersigned was formally removed from that process after Applicant mot, in secret, with the Callaway County Court on 22 February 1982 All questions regarding equipment or protective measures should be directed to the men who are preparing the proposed emergency plans, they are employees of U.E.

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~8 4 I have developped no opinion relating to equipment versus K.I. in the proposed emergency plan since the function of an intervenor is to identify issues and prove their existance. The proposed plan presents a situation in which public health and safety are protected for a period of about one hour, if a period of protracted shelter is required. In a sustained defensive mode, this equates ' to no protection of the public health and safety. Any resolution to this unsatisfactory condition is a function of the planners, or in the event they are unable to do such, it becomes a matter for the Commission (via the A.S.L.B.) to resolve.

END OF ANSWERS Respectfully submitted; Dated this 26th day JOHN G. REED of November 1982, at Citizen of the United States Kingdom City, M). of America RFD #1 Kingdom City, M0. 65262 tel: (314) 642-2769

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!;L' CLEAR ELGULA;OhY CO!O'.IS." ION BEFCRE THF, ATOMIC SAFETY At:D Llus:SI!!G BOARD In the Matter of )

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UNIQI ELECTRIC COMPANY ) Docket No. STN 50-483

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(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that the document attached hereto was served this

/$- day of Nev . ,1982 by deposit in the U.S. mail, first class posta6e prepaid upon the following:

James P. Gleason, Esquire Mr. Glenn O. Bright Chairman, Atomic Safety and Atomic Safety and Licensing Boani Licensing Board Panel Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory Co. mission U.S. Nuclear Regulatory Cormission Washington, D.C. 20555 Washington, D.C. 20555 '

Robert 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, MD. 63102 Thomas A. Baxter, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.

! Washington, D.C. 20036 Atorde Safety and Licensing Appeal Board U.S. Nuclear Regulatory Co:.r.ission Washington, D.C. 20555

• hand delivered /J hn R Citizen of the United States of America 1