ML20031C640

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Motion for Summary Disposition of Joint Intervenors Contention Ib Re Concrete Cracks.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20031C640
Person / Time
Site: Callaway Ameren icon.png
Issue date: 10/02/1981
From: Galen R
SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20031C639 List:
References
ISSUANCES-OL, NUDOCS 8110070375
Download: ML20031C640 (2)


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i Octobur 2, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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UNICN ELECTRIC COMPANY

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Docket No. STN 50-483 OL

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(Callaway Plant, Unit 1)

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APPLICANT' S MOTIO'T FOR

SUMMARY

DISPOSITION OF JOINT INTERVENORS' CONTENTION NO. IB (CONCRETE CRACKS)

Union Electric Company

(" Applicant") hereby moves the Ato:aic Safety and Licensing Board pursuant to section 2.749 of the Commission's Rules of Practice, 10 C.F.R.

S 2.749, for summary disposition in Applicant's favor of Joint Intervenors' Centention No. IB which alleges that there are cracks in concrete structures at the Callaway Plant which will affect its safe operation.

As grounds for this motion, Applicant states that there is no genuine issue as to any fact material to Contention No. IB and that Applicant is entitled to a decision in its favor on Contention No. IB as a matter of law.

This motion is based upon Applicant's Brief in Support, Applicant's Statament of Material Facts As To

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8110070375 810100 PDR ADOCK 05000483 G

PDR

Which There Is No Genuine Issue To Be Heard, the Affidavit of Eug6ne W. T.'omas, and the Affidavit of R. David Neal, all submit 4;nd herewith, and upon all pleadings and other papers oa file in this proceeding.

SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street N. W.

Washington, D. C.

20036 Telephone:

202-822-1000 By

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Thomas A.

Baxter Richard E.

Galen Attorneys for Applicant Union Electric Company Dated:

October 2, 1981 0

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