ML20031C646

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Motion for Summary Disposition of Joint Intervenors Contention I.D Re Concrete Cover.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision
ML20031C646
Person / Time
Site: Callaway 
Issue date: 10/02/1981
From: Baxter T
SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20031C639 List:
References
ISSUANCES-OL, NUDOCS 8110070389
Download: ML20031C646 (1)


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

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UNION ELECTRIC COMPANY

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Docket No. STN 50-483 OL

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(Callaway 'lant, Unit 1)

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APPLICANT'S MOTION FOR

SUMMARY

DISPOSITION OF JOINT INTERVENORS' CONTENTION NO-I.D (CONCRETE COVER)

Union Electric Company

(" Applicant") hereby moves the Atomic Safety and Licensing Board, pursuant to 10 C.F.R.

S 2.749, for summary disposition in Applicant's favo'r of part I.D.,

entitled " Concrete Cover," of Joint Intervenors' Conten-tion No. 1.

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

This motion is based upon Applicant's Brief in Sup-port, Applicant's Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard, the Affidavit of Subir K. Sen, and the Affidavit of R. David Neal, all submitted herewith.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Thomas A.

Baxter Richard E. Galen Counsel for Applicant 1800 M Street, N.W.

Washington, D.C.

20036 (202) 822-1000 8110070389 811062' PDR ADOCK 05000403 G

PDR