ML20032D908
| ML20032D908 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/09/1981 |
| From: | Chackes K CHACKES & HOARE, JOINT INTERVENORS - CALLAWAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8111180281 | |
| Download: ML20032D908 (3) | |
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s DXKETED USNRC UNITED STATES OF AMEIUCA NUCLEAR REGULATORY COMMISSION
'81 HSV I2 P5.52 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~ 1F $!'CRETARY a NG & SERVICE In the Matter of
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UNION ELECTRIC COMPANY f
Docket No. STN 9-48 3-O L'
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(Callaway Plant, Unit 1)
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JOINT INTERVENORS' AMENDMENT ta$.d@'C" 7 TO CONTENTION TWO rf Pursuant to the opportunity provided by the Atomic Safety and [li v
(see Memorandum and Order on Prehearing Conference, October 29, 1981) Joint Intervenors hereby amend Contention Two parts D and I by providing the bases for those parts of the contention.
Contention Two, Part D, as revised March 24, 1981, states:
The Applicant has not adequately assessed and cannot accurately predict the amourit or discharge rate of the rr.dioactive pollutants to be released from Callaway Plant, Unit 1, into the atmosphere Furthermore, due to meteorological considerations, U.E. is unable to predict accurately the dispersion of radiosetive materials or their fallout rate.
The bases for taese allegations are contained in Joint Intervenors' Response to Applicant's Interrogatories... (Set No. 1) to Joint Intervenors on Their Contention 2, nos. A-2 through A-4 (pp.10-21), and D-1 through D-15 (pp. 35-39); in Response to Applicant's Interrogatories... (Set lio. 2)... Contention 2, no. 2D-1 (pp.10-11); and in Response to NRC Staff Interrogatories, no. Q-1 (pp. 3-6 and Exhibit A).
Said interrogatory responses are hereby incorporated into part D of Contention Two as the bases therefor.
ConteMion Two, Part I, as revised March 24, 1981, states:
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U.E.'s estimates of radiation dose from the Callaway Plant emissions do not adequately reflect new data on the health effects of low-level radiation, and of tritium in particular.
The ' oases for these allegations are contained in Joint Intervenors' Response to Apnlicant's Interrogatories... (Set No.1)... Contention 2, nos.1-1 through I-3 (pp. 52-68), as supplemented.
Said interrogatory answers are hereby incorporated into part I of Contention Two as the bases therefor.
Respectfully submitted, CIIACKES AND HOARE A
Kenneth M. Chackes Attorneys for Joint Intervenors 314 North Broadway St. Louis, Missoari 63102 314/241-7961 O
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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 Plant, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of Joint Intervenors' Amendment to Contention Two have been served on the following by deposit in the United States mail this 9th day of November,1981.
James P. Gleason, Esq., Chairman Atomic Safety and Licensing Board 513 Gilmoure Drive Silver Spring, MD 20901 Mr. Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Jerry R. Kline Atomic Safety and Licen. sing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Roy P. Lessy, Jr., Esq.
Office of the Executive Legni Director U.S. Nuclear Regulatory Commission Washington, D.C.
20535 isenneth M. f'hackes-M-
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