ML20058D588
| ML20058D588 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/23/1982 |
| From: | Schukai R UNION ELECTRIC CO. |
| To: | REED, J.G. |
| References | |
| ISSUANCES-OL, NUDOCS 8207270221 | |
| Download: ML20058D588 (44) | |
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UNITED STATES OF AMERICA 1 '. I i.
NUCLEAR REGULATORY COMMISSIONI
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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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APPLICANT'S RESPONSES TO SPECIFIED REED INTERROGATORIES SERVED ON THE CALLAWAY COURT ADMINISTRATIVE JUDGES AND EMERGENCY MANAGEMENT COORDINATOR on June 16, 1982, intervenor John G.
Reed filed interrogatories and requests for the production of documents on the Callaway County Court Administrative Judges and on the Callaway County Emergency Management Coordinator.
While Judge Wright of the Callaway County Court is a 5 2.715(c) special participant to this proceeding, none of the three Callaway County Court judges nor the Callaway County Emergency Management Coordinator is a party to the operating license proceeding.
In these circumstances, and in view of the fact that a number of Mr. Reed's interrogatories seek information which Applicant Union Electric Company is in a position to
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provide, Applicant herein submits responses to most of Mr.
Reed's interrogatories.
Specifically, Applicant has provided answers to all but the following interrogatories (or document production requests) proffered by Mr. Reed to Callaway County officials:
Interrogatories 1, 7, 8(b), and 21.
INTERROGATORY NO.
2.
Answer the following questions as relate to radiological protection for emergency workers and the general population within and without the plume exposure pathway EPZ:
a.
What respiratory protection will be provided, if any, for emergency workers who are required to perform duties in a radioactive environment or potential radioactive environment?
b.
What thyroid protection will be provided to emergency workers and the general population in the event they are exposed to radioactive iodines emitted from Callaway 1 during an accident?
c.
What respiratory protection will be provided for citizens who are exposed to radioactive nuclides emitted during an accident?
d.
What protection will be provided to ambulance and hospital employees during transport and treatment of radioactively contaminated injured persons?
e.
Will high effeciency particulate air (HEPA) filters be installed in ambulance treatment areas or the j
radiation emergency area of the Callaway Memorial l
Hospital or its successor?
f.
If installed, to what levels will the HEPA filters reduce particulate levels outside the radiation emergency area?
g.
How are levels determined inside and outside of the radiation emergency area?
Where will the sensors be located in and outside of said radiation emergency I
area?
h.
Will these levels be monitored from a remote area?
l If so, where, exactly, will this area be located?
4 1.
Will there be a decontamination room adjacent to the radiation emergency area?
If so, where?
If not, why not?
j.
How will radioactive water and waste be disposed of once the decontamination of an individual or equip-ment is completed?
k.
Where will ambulances and other vehicles be deconta-minated?
1.
How will radio-contaminated water be collected?
How and where disposed?
m.
If contaminated water and waste is to be transported to Callaway 1 for disposal or elsewhere, describe how the material (liquid and solid) will be transported and what safeguards will be taken to ensure safe transport of such material?
n.
What special provisions will be taken to assure that ambulance and hospital employees and others have not been exposed to biologically dangerous levels of radiation or have ingested biologically dangerous levels of radioactive nuclides?
o.
How will such exposures be validated, recorded, and such records be stored for future reference by said individuals?
p.
How and where will such ambulance / hospital employees be treated to mitigate the effects of such radiolog-ical exposure?
q.
Who will pay for all costs involved in all of the activities relating to each of the above interroga-tories?
ANSWER:
a.
Respirators with charcoal filters will be provided for emergency workers who desire to use such devices, and will be stored at the Emergency Operations Center.
b.
None, other than the respirators provided emergency workers specified in response to Interrogatory 2(a).
Recent l i
studies by the Nuclear Safety Analysis Center and the Electrical Power Research Institute show that only a very small fraction of iodine would escape into the environment following a nuclear accident.
This is supported by data from the accident at Three Mile Island, Unit 2.
c.
None.
Protective actions such as sheltering or evacuation will be used if required to reduce the exposure to radioactive nuclides emitted during an accident.
These actions preclude the need for specific respiratory protection equip-ment.
d.
Protective clothing and respirators will be available for use by personnel from Callaway Memorial Hospital and Callaway County Ambulance District.
e.
No.
See also response to Interrogatory 2(h).
f.
Not Applicable, g.
Radiation levels inside and outside of the radiation emergency area at Callaway Memorial Hospital will be determined using portable detection instrumentation available at the hospital.
h.
A radiation emergency area in a hospital does not mean that significant exposure levels exist in that area, as exposure levels are defined as being present in a radiation or high radiation area in Chapter 10, Part 20 of the Code of Federal Regulations.
A radiation emergency area in a hospital implies an area of controlled access in which contaminated L
injured persons who have received an overexposure are treated.
The distinction between radiation and contamination is imperative.
Contamination levels which are considered signifi-cant (10,000-100,000dpm/100 cmr), emit relatively insignificant radiation levels (0.1 - 0.5 mr/hr).
Although the contamination poses no direct threat as an external radiation hazard, it must be controlled to prevent its spread and possible ingestion through deposition on food and hospital equipment.
This control is achieved by isolating, i.e.,
not allowing public access through, an area of the hospital and constructing control points at exits and entrances to the area.
People exiting the area would remove their protective clothing (hospital gowns, surgical gloves, shoe covers, mask and cap) and be monitored for any contaminatiom before exiting the area.
A person entering the area may be required to dress in protec-tive clothing.
Periodically, entrances and exits would be surveyed to check for the spread of contamination outside of the area.
Specific decontamination procedure and policy development is at the discretion of hospital staff.
Union Electric will provide assistance in this development as requested.
l i.
No.
If patient decontamination is required, it will take place in the radiation emergency area.
A separate decontamination room is not necessary because the decontamina-tion can be effectively carried out in the radiation emergency area.
I l !
j.
Radioactive water at Callaway Memorial Hospital will be collected in 30 gallon collection containers.
Other contaminated wastes will be collected on the protective floor coverings.
All contaminated material will be sent to Callaway Plant for disposal.
k.
The internal areas of the ambulance will be deconta-minated at the ambulance home station by the ambulance attend-ants and plant health physics personnel.
All other vehicles will be decontaminated by hand cleaning at preselected loca-tions.
1.
Contaminated water will be retained in the area where it was applied to the vehicles.
It will be collected through the use of pumps, mops or brushes as may be appropriate with the water and particulate matter transported to Callaway Plant for disposal in accordance with established plant procedures.
m.
It is anticipated that all such contaminated water and waste will be low-level waste and thus will be transported by Union Electric in accordance with NRC and State of Missouri criteria for dealing with such material.
n.
Because of the location of Callaway Memorial Hospital approximately 11 miles from the Callaway Plant, it is anticipa-ted that ambulance and hospital employees could be seriously contaminated only if they went on site, in which case they would be monitored, and provided with necessary protective equipment.
Less significant exposure would be minimized as stated in the response to Interrogatory 2(d).
o.
Personnel from Callaway Memorial Hospital and Callaway County Ambulance District will be issued personal dosimeters for exposure determination.
It is anticipated that records will be maintained by the hospital and ambulance district.
p.
It is not anticipated that exposure of ambu-lance / hospital employees sufficient to require medical treatment will occur; nevertheless, it it were to occur, these individuals would be treated as would any other individuals subject to radiation exposure.
See SS 10.0 and 11.0 of Draft Callaway Offsite Emergency Response Plan (April 1982).
q.
Applicant objects to Interrogatory 2(g).
The issue of who will pay for specific emergency planning functions is outside the scope of this proceeding.
Applicant need only demonstrate to the NRC that the state of onsite and offsite emergency preparedness for the Callaway Plant is adequate and capable of being implemented.
See 10 C.F.R. 5 50.47(a).
INTERROGATORY NO.
3.
Will special provisions or consider-ation be made for area evacuees who have pets, e.g.,
kennel facilities, special mass care centers, pet food supplies, etc ?
Will people be permitted to take pets with them when they etracuate?
If not, what is to be done with the animals?
ANSWER:
Pets and animals are addressed in the reception and care procedures for each Reception and Care Center.
The public will be informed that evacuees should not bring pets with them.
Provisions are made in the reception and care procedures to _ _ _ _
request assistance from the local Humane Society to care for animals that are brought to the center.
Alternatively, evacuees can leave their pets at home, indoors, with enough food and water for a several day period.
This policy is necessary to protect the health and well-being of the evacuees.
The reasons in support of this policy are (i) the detrimental impact animals can have on maintenamce of sanitary conditions; (ii) the allergic reactions of some evacuees to specific animals; (iii) the potential for animal fights; and (iv) the potential for human injury resulting from uncontrolled animals (dog bites, etc.).
Guide dogs are not considered pets and would be admitted to a care center.
INTERROGATORY NO.
4.
What provisions or considerations will be made for live-stock which area evacuees must leave behind?
How will non-radioactively contaminated feed and water be supplied to such live-stock during the evacuation period?
Where is such feed located until needed?
How delivered to stock feeding areas?
Who pays for such feed and water and the actual service of delivering such feed to said live-stock?
ANSWER AND OBJECTION:
This activity is a responsibility of the State of Missouri, and not within the authority of the County Court.
Insofar as Mr. Reed seeks information about who would pay for livestock feed, etc., Applicant objects for the reason l
stated in Applicant's response to Interrogatory 2(q).
l INTERROGATORY NO.
5.
How do live-stock owners determine whether or not genetic damage has been done to said livestock?
Who is responsible for liability for biological or genetic i
(
damage?
How are damages for such injury collected?
! 1 i
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ANSWER and OBJECTION:
Provisions have not been made for livestock owners to determine whether their livestock have been genetically damaged.
However, contamination of meat and milk products will be determined from samples taken by the Missouri Department of Agriculture.
Applicant objects to that portion of Interrogatory 5 concerning liability for genetic or biologi-cal damage, for the reason articulated in Applicant's response to Interrogatory 2(q).
INTERROGATORY NO.
6.
Explain how the plume exposure pathway EPZ depicted in Callaway Offsite Emergency Response Plan, Revision 3, April 1982, figure 9-1, page 9-7 (or future revised versions) was derived.
Explain precisely how each and every one of the following factors was considered in the determination of the extent of the plume exposure pathway EPZ:
demography, including permanent and seasonal residents and transients; topography, land use characteristics; access routes; meterology; local jurisdictional boundaries; release time and energy characteristics; release height; radionuclide content of releases considered, including release fractions; plume dispersions, including plume rise; deposition velocity; breathing rates, sheltering and shielding, dose-effects; radiation treatment and time of year of release.
ANSWER:
The boundaries of the plume exposure pathway EPZ were determined on the basis of the criteria of NUREG-0654, NUREG-0396, and the study of Preliminary Evacuation Time Estimates prepared by the PRC Voorhees Company, on behalf of Union Electric Company.
The NRC/ EPA Task Force on Emergency Planning (NUREG-0396, EPA 520/1-78-016) selected an area encompassed by a radius of about 10 miles for the plume exposure pathway (PEP) emergency planning zone (EPZ).
The Commission has endorsed this selection in its regulations.
See 9
10 C.F.R. 5 50.47(c)(2).
Although this radius implies a circular area, the actual shape and size of the PEP EPZ is dependent upon the characteristics of each site.
The bases of boundary determination in these documents are as follows:
(1)
Projected doses from traditional design basis accidents would not exceed Protective Action Guide levels outside the zone.
(2)
Projected doses from most core melt sequences would not exceed Protective Action Guide levels outside the zone.
(3)
For worst case core melt sequences, immediate life threatening doses would generally not occur outside the zone.
(4)
Expansion of efforts, beyond 10 miles (if required) would have a substantial base for implementation with the procedures prepared for the 10 mile EPZ.
(5)
The PEP EPZ must be easily identifiable.
Rather than adhering strictly to an intangible radius, the EPZ boundary should follow natural features (shorelines, streams), man-made features (roads, railroads), or political boundaries.
The Callaway County EPZ boundary is defined as follows:
l The northerly limit is defined by 1
Interstate I-70 from the interchange with Highway Z in Calwood Township easterly to the Callaway County / Montgomery County Line.
1 i t
The easterly boundary consists of the Callaway/ Montgomery County line southerly to the Missouri River.
The southerly boundary is the Missouri River.
The westerly boundary follows the St.
Aubert/ Cote Sans Dessein Township line, north to the St. Aubert/Caldweel Township Line, north to Highway NN at the St.
Aubert/ West Fulton Township line, north on Highway NN to Route 54 north to and including the City of Fulton.
From Fulton, the boundary continues north on Highway Z through East Fulton and Calwood Townships to I-70.
(6)
The PEP EPZ should either include or exclude major population concentrations in their entirety.
Hence the inclusion of all of the City of Fulton.
(7)
The designation of the full circumference of the PEP EPZ boundary should reflect consistent criteria, with reasons for inclusion apparent and supportable.
With respect to the specific " factors" referred to in this interrogatory, these considerations should be divided into two groups to be addressed in the proper context.
These groups are as follows: -
A.
Sub-area Designation / Evacuation Time Estimates The factors applicable to this heading are:
(1)
Demography - the permanent and transient population distribution of the area was consid-ered in the designation of sub-area boundaries.
In particular, it is desirable that sub-ar,eas not divide contiguous concentrations of pop-ulation.
In addition, demography, with respect to sub-area boundaries and highway capacity, is a major consideration in evacuation route designation and time estimates.
Also considered were the population in special facilities, i.e.,
schools, colleges, institutions, hospitals, and nursing homes.
Please refer to the attached demography tables.
(2)
Topography - the physical features of the PEP EPZ are considered in boundary designation.
Significant topographic irregularities may have an effect on plume / ground interface and upon deposition.
Such irregularities should be acknowledged in PEP EPZ boundaries and/or dose projection procedures.
However, there are no such irregularities in the Callaway Plant PEP EPZ to be considered.
Features such as access routes (see discussion below) and jurisdictional boundaries were considered in defining the EPZ.
(3)
Land Characteristics - the interrogatory states
" land use characteristics."
" Land characteris-tics" are referred to as a consideration in PEP EPZ boundary determination in both NUREG-0654 4
and NUREG-0396.
Except for the demographic implications of industrial versus agricultural versus residential usage, the use of land in the PEP EPZ is not consequential in PEP EPZ boundary designation.
The land characteristics of an j
area, such as susceptibility to drifting snow or flooding, are taken into account in evacuation studies.
However, these considerations do not dictate the boundaries of the PEP EPZ.
(4)
Access Routes - limited accessibility, low population, and a lack of primary roads are considered as exclusion criteria.
No areas in the Callaway County EPZ have been identified for exclusion on the basis of these criteria.
(5)
Seasonal Residents / Transients - the transient population of an area has no impact on PEP EPZ boundary determination.
The transient pop-ulation was accounted for in the evacuation time estimates and evacuation route selections.
I.-_
B.
Dose Projection Factors The remaining factors specified in the interrogatory relate to dose projection methodology.
These factors are:
Meteorology Time of year (meteorological impact)
Release time (duration)
Release height Radionuclide content (release fractions)
Radiation energies Plume dispersion Breathing rates The designation of the 10 mile PEP EPZ by federal agencies is based, primarily, on " projected dose" as previously described.
The dose projections which support the 10 mile EPZ assume " worst case conditions" and incorporate a high degree of technical conservatism.
The factors of sheltering and dose-effects are addressed by the Environmental Protection Agency (EPA) in the designation of Protective Action Guides.
Therefore these factors are considered in the adoption of the 10 mile EPZ and Protective Action Guides.
INTERROGATORY NO.
8.
In the County Court's opinion, is it possible to safely evacuate the total permanent, seasonal, and transient populations within each of the following areas at any time of day or any time of year?
Describe in detail any assumptions made and indicate how your response would differ if that assumption were changed.
Disclose any assumptions made I
with respect to an acceptable level of risk to the evacuating population:
I l l l
{
a.
The area designated as the plume exposure pathway EPZ in the Callaway Offsite Emergency Response Plan.
c.
The circular zone surrounding Callaway 1 having a 20 mile radius.
d.
The entire City of Fulton.
ANSWER:
a & d.
It is possible to safely evacuate the total population within the plume exposure pathway EPZ as defined in the Callaway Plant Off-Site Emergency Plan.
This EPZ includes the entire City of Fulton.
4 The assumptions made for this evacuation are described in detail in Appendix I of Chapter 13.3A of the Callaway Plant FSAR.
This document is available for inspection at the Callaway County Library in Fulton, Missouri.
In general, the evacuation of the EPZ population was examined assuming a " worst case" situation (i.e.,
a winter time week day, day-time period).
If any assumptions were revised, the evacuation time estimates and the entire evacuation scenario would most likely be improved.
c.
Applicant objects to Interrogatory 8(c), which concerns the evacuation of all individuals in the 20 mile circular zone surrounding the Callaway Plant.
This inter-1 rogatory requests information which is beyond the scope of this proceeding, and liliplicitly challer.ge-the 10 mile plume exposure pathway (PEP) EPZ set forth in the regulations.
See 10 C.F.R. 6 50.47(c)(2).
Part 50 of the regulations requires 1 -.
adequate provisions to be made to notify and evacuate individuals within the PEP EPZ.
Specifically, the Applicant must perform a time evacuation study for the evacuation of transient and permanent populations within the PEP EPZ, which consists of an area about 10 miles in radius.
See 10 C.F.R. Part 50, Appendix E,Section IV and 10 C.F.R. 5 50.47(c)(2).
Additionally, the regulations require Applicant to demonstrate that initial notification of individuals within the PEP EPZ can be completed within about 15 minutes.
10 C.F.R. Part 50, App.
E at IV(D).
No requirement exists to assess or provide for the notification or evacuation of individuals in a 20 mile radius of the Callaway Plant.
See also NUREG-0654, Rev.
1,Section I.D.
INTERROGATORY NO.
9.
In the County Court's opinion, will there ever be a need to order protective actions in any area outside of the PEP EPZ outlined in the Callaway Offsite Emergency Response Plan (Callaway RERP) referenced above?
If so, describe the circumstances necessary for such order, the areas so affected, and the nature of any such protective actions.
ANSWER:
It is anticipated that the only protective actions taken outside the PEP EPZ would concern the ingestion pathway.
Actions such as a ban on the sale or distribution of contami-nated foodstuffs could be taken based on recommendations from the Missouri Department of Agriculture.
Areas affected would depend on conditions at the time of the accident, and the resultant plants and animals affected.
INTERROGATORY NO. 10.
In the County Court's opinion, are there adequate facilities available to shelter the total permanent and peak seasonal and transient populations in each of the areas indicated in question 8, above, if evacuation is deemed impossible or impractical?
If the Court's answer is in the affirmative, indicate the numbers of each type of shelter available, the shielding factors of each type, the nature and location of shelters to be used by transients, and disclose any assumptions made as to acceptable levels of risk to the public.
ANSWER:
The EPZ population, permanent, transient, and those in special institutions, can be sheltered in structures and even in vehicles.
Please refer to the attached tables, taken from "Public Protection Strategies for Potential Nuclear Reactor Accidents, Sheltering Concepts with Existing Public and Private Structures" (SAND 77-1725), Sandia Laboratory, listing shielding factors for various structures and locations.
The approximate number of housing units located within the EPZ (per the 1980 census) is 6,370.
The number of private and public non-housing structures within the EPZ is not readily available.
The shielding factors for each of these structures is not available.
However, the following assumptions can be readily and reasonably made:
1.
Permanent residents will be either in their own
(
homes, at their places of employment, in a public or private location (school or shopping area), or in a vehicle in transit.
Therefore, they will be in or near a shelter.
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2.
The population in special institutions, i.e.,
schools, colleges, hospitals, nursing homes, jails, etc., are in or near a shelter.
3.
The transient population will be in vehicles, or in public or private locations (shopping areas or motels), and therefore will be in or near a shelter.
A study was not undertaken to assess acceptable levels of risk to the general public in the event sheltering is recom-mended.
INTERROGATORY NO. 11.
In the County Court's opinion, what constitutes an acceptable level of risk to the public in the event of an accident involving offsite radiological releases.
Specifically, what is the uppermost number of each of the following health effects which is acceptable:
early fatalities, delayed fatalities, early biological injury (thyroid damage or loss, etc.), delayed injuries, abnormal infant developmental defects or genetic birth defects?
If an answer depends on a specific type of accident, specify that type of accident in the response.
OBJECTION:
Applicant objects to Interrogatory 11 because it is outside of the scope of this proceeding.
What constitutes "an acceptable level of risk to the public" is not at issue in this proceeding.
Rather, if Mr. Reed proffers offsite emergency planning contentions which are deemed acceptable by the Board, the Board will consider the adequacy of offsite planning for the Callaway Plant, using the criteria set forth in 10 C.F.R.
Part 50, and the guidance provided in NUREG-0654, Rev.
- 1. ___ _
INTERROGATORY NO. 12.
In the County Court's opinion, what percentage of the permanent population within the proposed PEP EPZ will be working at locations outside said EPZ if an accident occurs during working hours on a weekday?
How many family members will be left without immediate transportation (privately owned automobiles, trucks, etc.)?
ANSWER:
Information is not readily available on the percent-age of the permanent population within the EPZ who will be working at locations outside of the EPZ when an accident at the plant occurs.
It is anticipated that workers will be able to return home and pick up families.
If it is not possible to do so, a special phone number will be specified in the emergency information literature which people without transportation can call to arrange for transportation.
INTERROGATORY NO. 13.
In the radiological emergency response plan for Callaway 1, the utility proposes to provide potassium iodide to emergency workers.
In the EPA manual EPA-520/1-75-001 (manual for protective action guidelines) the administration of radioprotective drugs is included.
The Federal Food and Drug Administration has found that potassium iodide is safe and effective as a thyroid blocking agent to prevent absorption of radioactive iodine by the thyroid gland.
The State of Missouri has refused to provide potassium iodide for use by emergency workers or the general public; suggesting that evacuation is a more effective protective measure.
What is the County Court's opinion in this matter?
If the Court agrees with the State of Missouri that potassium iodide (KI) is not needed, explain in detail how effective prevention of inhalation / ingestion of radiciodines will be affected by emergency workers and the general populations in the event they are located in a fallout area in which radio-iodines are present?
Identify all documents or other sources upon which the Court relies to support its decisions.
If the Court disagrees with the State of Missouri, to what distance from the plant site will disemination [ sic) of KI be necessary?
What quantity of KI will be needed?
How will it be diseminated
[ sic] to those who are to make use of this drug?
Will such disemination [ sic] be prior to or after an actual release or radionuclides at the plant site?
What is the shelf-life of, _.
this drug?
Will it be replaced at repositories on a timely basis?
If not, why not?
Who will pay for this protective measure, if it is to be approved?
ANSWER: Applicant agrees with the position of the State of Missouri on this issue for the following reasons:
1.
There is a growing body of technical data (see Applicant's response to Interrogatory 2(b)), in addition to the TMI-2 experience, that the quantity of radiciodine released during a nuclear accident would be considerably smaller than the estimates now used in calculating doses under hypothetical accident situations.
A smaller release magnitude would result in virtually no members of the public being exposed to the 25 rem crossover point for KI benefit endorsed by FDA.
Also, preliminary data indicate that a release would be delayed by reactor internal chemical mechanisms and containment structural capability.
2.
Even though its use has been approved by FDA, there are expressed concerns on the part of members of the medical community regarding the possible adverse impact on individuals from the general and uncontrolled distribution of KI, especially when compared to the mimimal potential benefit of its use as a thyroid protective agent at levels below 25 rem.
For example, the potential exists for individuals to.
take large quantities of KI when it is not appropriate or necessary to do so.
3.
There may be a false sense of security given to the recipients of KI from a perception that its use would also reduce the radiation dose to other critical body
- organs, e.g.,
bone marrow, lung, etc.
4.
The pre-distribution of KI and the maintenance of an adequate supply among individual members of the population have numerous administrative and logistic problems.
These problems include possible utiliza-tion at the wrong time, loss of the KI by individuals, and overuse of KI in the belief that larger doses are beneficial.
5.
Protective actions are available which can mitigate the effects of radioiodine.
These include milk and milk product control, sheltering and evacuation.
It is anticipated that Union Electric will utilize KI only if exposure to in-plant radioiodine makes its use necessary, and then it will be issued only under proper medical super-vision.
Applicant does not intend to provide KI to emergency workers in the plant prior to its need.
INTERROGATORY NO. 14.
Explain in detail how each of the following difficulties was accounted for and overcome in the preparation of evacuation time estimates for Callaway 1:
a.
Vehicle breakdown during evacuation (out of gas, abandoned, wrecked, etc.)
l b.
Notification of deaf persons within the PEP EPZ.
c.
Attempted or actual ingress into the evacuation area by family members who are attempting to rescue their families.
d.
Road blocks created by wrecks involving evacuating vehicles.
e.
Communications with school bus drivers intransit
[ sic) to or from schools with students aboard.
f.
Identification of invalid or injured residents within the PEP EPZ who require special transportation to evacuate.
g.
Verification that all residents within the evacuation zone have actually departed the area.
h.
Verification that adequate vehicles are available to effect actual evacuation of areas specified in the Callaway RERP, 9.OB Evacuation Areas, on page 9-1.
i.
Verification that drivers are available to drive initial and follow-up trips into a radiological fallout area or potential fallout area.
List names of drivers who have volunteered to drive ambulances, buses, trucks, wreckers, etc.
Indicate the number of trips estimated necessary for these drivers to assure complete evacuation of the areas identified in "h,"
above.
ANSWER:
a & d.
Vehicle breakdown and road blocks created by damaged vehicles were not considered in the preparation of the Callaway evacuation time estimates.
It can, however, be reasonably assumed that these vehicles will be few and will not noticeably impede the flow of traffic around them.
During the evacuation, normal traffic operations will generally prevail.
Specifically, roads will continue in two-way operation, traffic signals will continue to function, etc.
At key locations, such ___
.~
as major intersections, traffic control will be under the direction of police personnel or other personnel as designated by the Off-site Emergency Plan and procedures.
On most roads, the traffic will flow freely, although at reduced speeds, However, at certain locations in or near the City of Fulton, traffic congestion is expected and police personnel will direct traffic to maintain an orderly flow.
If a vehicle were to stop traffic due to mechanical problems, being out of gas, or some other predicament, the most time-saving response would be for the people impeded by the vehicle to move it off the road.
This could be performed by hand pushing the vehicle or pushing the vehicle with an operating private vehicle.
Assuming that this type of action could not t ake place, the plan has an alternative.
In the Traffic Control procedure, (procedure
- 11), local towing services are identified in Attachment 11.3.
In the event their services are required, it is anticipated that these firms will provide the equipment necessary to remove vehicles which are impeding traffic.
b & f.
The evacuation time study assumed the beginning of notification of handicapped persons would occur in 15 minutes.
See FSAR S 13.3A (the RERP), Appendix I, Ch. 5, regarding non-auto owning population.
The Transportation procedure (procedure #9) provides for an emergency Registration Card system and guidance in the use of this card system by the county emergency organization.
The Registration Card will be a j -
part of the emergency information literature which will be distributed to all residents in the PEP EPZ.
The purpose of i
this Card is the identification of persons who are visually impaired, hard of hearing, physically h3rdicapped or in need of transportation assistance for any reason.
The Cards are preaddressed for their return mailing to the Callaway/Fulton Emergency Management Agency (EMA).
It is the responsibility of I
each affected individual to fill out the Card and return it to the EMA.
The Cards will be screened; special problems identified; permanently filed for future reference; and regularly updated.
Individuals identified by the process will be contacted as necessary and actions will be determined on a case-by-case basis.
c.
Work-to-home travel time of employees, to pick up 4
families, has been incorporated in evacuation time estimates.
l This is addressed in the Preliminary Evacuation Time Estimates study on pages 50 and 51.
The time estimates account for a 20 to 30 minute time phase, during which people will be allowed to enter the EPZ to pick-up families and/or secure their household.
This is one reason why two-way traffic is maintained on all roads.
However, employees who work at some l
distance outside the EPZ will not be allowed to enter if barricades are in place and actual evacuation has commenced.
The families of these individuals will be evacuated using buses l
l as per procedure #9, Transportation.
A special phone number (
[
r will be specified in the emergency information literature,,
whichpeoplewithouttransportationcancallduringanact$al r
emergency.
This action is addressed in steps 5.2 and 5.3 of
/
Callaway/Fulton procedure #9, Transporation.
j e.
The capability to individually communicate with school
/
/
bus drivers in transit does'not exist.
The activation of the mi
/ j alert-warning sirens *would alert the driver.
It is anticipated
(
that school authorities will giye explicit and detailed g
instructions to bus drivers at to what actions to tale if/
t I
-k notification sirens go off while!they are in transit.
i
- ii
\\
g.
The evacuation tino estimate does not consider s
^'
i' i
,?
F
~.'
verification of evacuation.
/
h.
The evacuation time estimate does not consider
'/
verification of vehicle availability, although it did assume i
i i
the availability of the#aveEage number of private vehicles per r
A i t household in the EPZ i's approximately 1.06 (based on the number.,
3 t; i I
of households and vehicles in 1980).
This is adequate for
/
evacuation of the resident vehicle-owning population.
It can be reasonably assumed that the transient population will.'have/
- +
- l their own vehicles.
For the non-vehicle owning population, arid
/
,1.,
other population segnents that will require special transporta -
.g
' tion, public and private vehic1c.? will be used.
Buses and other vehicles will need.to make multiple trips out of the EPZ g
in order to evacuate this segment of the population.,yarlous,/
r e s.
.s
" l~L'e-I i resources have been called upon [.o supply the Callaway ulton
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- 7 (s, '
7
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EMA with the vehicles necessary to evacuate the area.
These resources, their capacities, and the institutions for which these resources will be utilized are specified in procedure #9 of the Callavay/Fulton Standard Operating Procedures, entitled
/
Transportation.
This procedure provides the methodology for determining the number of vehicles required based on estimated and/or actual population of a given institution or facility.
Specifically, vehicle resources and distribution are addressed
'in the following portions of procedure #9:
(i) Step 5.4.8.2; (ii) Attachment 9.1; (iii) Attachment 9.2; and (iv) Attachment 9. 3 '.
i.
Ne verification of the availability of emergency
. drivers was made in the preparation of the evacuation time estimates.
The owners of the bus companies involved have made verbal assurances that the buses and drivers will be available during an emergency.
The number of follow-up trips necessary J
by the buses to evacuate the population requiring special transportation cannot be estimated until after the public
~
information program census determines the number and location c
of this population segment, which will be conducted prior to plant operation.
The names of the drivers of these vehicles l
1 are not relevant.
w INTERROGATORY NO. 15.
What provisions have been made to
[ ensure the cooperation of the public during a radiation l-emergency?
Specifically, what authority do State and local governments have to force people to evacuate their residences, j
to prevent spontaneous evacuation in areas outside the l
- - a l
e
evacuation zone (and in areas in the immediate vicinity of reception and care centers), to control panic or uncooperative behavior in evacuees, or to compel emergency workers to endanger their health or safety in evacuation operations or other necessary tasks to be performed in actual or potential radiation areas?
ANSWER:
State and local governments have general police power authority to force people to evacuate their residences during an emergency.
From a practical standpoint, however, there is no way to " force" public cooperation during a radiation emergency.
Cooperation of the public has generally been favorable during natural disasters, such as hurricanes.
See Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), LBP-81-59, 14 N.R.C.
1211, 1566 n.191 (1981).
The public education process which is part of the planning process facilitates this cooperation.
It is therefore assumed that the response would be similar during an accident at Callaway Plant.
With respect to emergency workers, experience during disasters indicates that workers generally respond professionally to the public's need for their services.
Id. at 1562, 1633.
INTERROGATORY NO. 16.
Is there a system for precedence in evacuation?
E.g.,
who will be evacuated first, school chil-dren, pre-school children, pregnant women, or the elderly or l
infirm?
' ANSWER:
If an evacuation is ordered during school hours, l
school buses would be used to evacuate students prior to their l
use for others.
There is no other precedence in evacuation.
l l l l
INTERROGATORY NO. 17.
Are any non-English speaking persons residing inside the PEP EPZ?
If so, what provisions have been made to provide them instructions or notification of protective actions tm be taken in the event of a radiological accident at Callaway 1?
ANSWER:
Applicant does not know.
INTERROGATORY NO. 18.
Answer the following questions relating to school evacuations.
a.
What provisions have been or will be made to evacuate nursery schools, pre-schools, day care centers, and other similar facilities, both private and public?
b.
What provisions have been or will be made to evacuate private schools, public schools (including colleges and the Missouri School for the Deaf) within the PEP EPZ?
Include in your answer the notification procedures amd a count of buses (indicating total seating capacity) and a count of students, teachers and school employees who may be required to use buses in an evacuation.
c.
What disposition will be made of students who attend school outside the PEP EPZ, but reside within said EPZ?
d.
What disposition is made of students who are enroute to school when an accident occurs requiring evac-uation?
Be specific as to how instructions are relayed to the drivers and what becomes of students in the fallout area awaiting pick-up.
I e.
Are schools suitable for sheltering students?
For what length of time (indicate each school by name and i
include sheltering factors for the buildings, availability of food, medical supplies, bedding, etc.)?
l f.
How will bus drivers be notified to report to work in a nuclear emergency?
What notification system exists for those who may be away from their homes?
If they are outside the PEP EPZ, how will they get to their bus if it is inside the EPZ and roadblocks have been established to prevent entry into the PEP EPZ?
g.
Indicate what effective methods of respiratory and thyroid protection will be provided to students while in school buses or in shelter in schools awaiting evacuation during an accident at Callaway 1 involving a significant release of radionuclides.
Identify the basis for such determination and indicate where in 10 CFR, Part 20, NRC Regulatory Guide 8.15 or other Federal guidance that the protective methods or devices are considered " effective" (list document, chapter, section, paragraph and page number of such references).
ANSWER:
a.
Given the escalation of events on which the emergency plan is based, as contemplated by NUREG-0654, sufficient time is available for the notification of such facilities.
The Callaway County /Fulton Transportation proce-dure, Step 5.4.8, provides the option to close schools at the Site Emergency level if escalation to a General Emergency is envisioned.
This action may appear premature as a protective action decision, but it will increase the margin of safety for the children.
Private day care centers, nursery schools, and pre-schools will have to arrange the transportation of their pupils.
Since these children are expected to be under five (5) years of age, and parents normally drive their children to such facilities, the parents would be expected to pick up their children.
With the implementation of early notification, this operation should pose no problem.
b.
The actual evacuation procedure for a given school is the responsibility of the cognizant Board of Education, Superintendent of Schools and the school principal.
The local e
emergency plan ensures the timely notification of the school and transportation of the students.
The transportation of students is addressed in Callaway County /Fulton Standard Operating Procedure #9, Transportation.
Specifically, this topic is addressed throughout section 5.0 and in the following attachments to Procedure #9:
(i).1 - Transportation Resources:
57 buses identified with an average capacity of 60 persons.
(ii).3 - Vehicle Requirement Worksheets, Worksheet #1 - Schools.
The following schools are identified:
Public Schools McIntire Elementary Center Elementary Bush Elementary Bartley Elementary Fulton Junior High So. Callaway Elementary So. Callaway Junior High School So. Callaway High School Private Schools St. Peters Catholic School Ank. Christian Elementary Special Schools Mo. School for the Deaf.
The most recent, obtainable enrollment figures indicate a total of 3,502 students for all of these schools.
Teachers and other school employees are not included in these figures.
Sufficient numbers of private vehicles should be available for school staff.
The school principal may assign a teacher (s) to each bus for student control. I t-
Westminster and William Woods College have agreed orally
- that they will transport their students independently, using college-owned vehicles and private vehicles.
Once all schools are evacuated and buses are available, buses will be made available to these institutions, if necessary.
c.
If schools are closed at the Site Emergency level, as described in the response to Interrogatory 18(a), entering the EPZ would be of no consequence since no offsite release would have occurred.
If children are in school and an evacuation is ordered, schools outside the EPZ would be unaffected.
By the time these schools were dismissed the EPZ will be isolated and traffic control in effect.
Parents with children in this situation could retrieve their children.
d.
See Applicant's response to Interrogatory 14(e).
e.
In this interrogatory, Mr. Reed appears to have misinterpreted the meaning of sheltering as it applies to nuclear reactor accidents.
The interrogatory implies sheltering in the true " civil defense" sense (long period of time, sheltering factor, food and bedding).
Sheltering in a nuclear reactor emergency is defined in the Callaway County /Fulton Standard Operating Procedure #8, entitled
" Protective Actions."
With this definition in mind, it is unnecessary to address sheltering factors, food supply, medical supplies and bedding facilities for a sheltering period of several hours.
Sheltering is considered appropriate for a.
" puff release" with no minimum preparation time for evacuation.
A " puff release" refers to a release of short duration result-ing in a finite plume, or cloud, of radioactive gases and particulates.
f.
Notification of bus drivers would be achieved by commercial telephone in the event their services are required.
i If the driver is not at home at the time of notification, other drivers will be notified and then effort will be made to notify those that could not be reached.
Bus drivers will not be prevented from entering the EPZ if an evacuation order has been issued.
g.
Protective actions will be taken to protect school children; however, no protective devices will be provided.
The predistribution and use of respiratory protection equipment by school age children is not practical, nor logistically pos-sible.
The interrogatory references the criteria of 10 CFR 20 l
and Regulatory Guide 8.15 in determining the effectiveness of respiratory protection equipment.
Regulatory Guide 8.15 has been deleted as a regulatory guide.
See 47 Fed. Reg. 16162 (April 15, 1982).
All regulatory criteria for such equipment are now stated in 10 CFR 20.103(c).
However, that regulation applies to the exposure to ionizing radiation in restricted areas (i.e.,
occupational exposure); therefore, the regulation does not apply to the general public.
Should the regulation be i
applied to the general public, it would require individual
' l
facepiece fittings and fitting tests for each person, periodic fitting tests and respirator maintenance to ensure a proper fit, and formal instruction in the use of respirators to all individuals prior to allowing such use.
Continual fitting and refitting during a child's rapid growth years would be extre-mely difficult to monitor.
Morever, children could not be expected to understand how to use the equipment.
The methods to be used for protection of students in this situation are sheltering and/or evacuation.
In accordance with the policy of the Missouri State Emergency Management Agency, potassium iodide (KI) will not be administered to the general public.
See response to Interrogatory 13.
INTERROGATORY NO. 19.
Describe in detail any independent monitoring for radiation that will be made within the PEP EPZ?
(Independent monitoring means radiological survey and moni-toring by a governmental or private entity other than an agent of the Applicant, Union Electric.)
Indicate types of moni-toring equipment to be used, mobile or fixed, type of emissions detected (gamma, beta, alpha, or iodine /other nuclides), manner and frequency of readings, the availability of instantaneous data, type of data link with the responsible agent or entity, l
type meteorological monitors, and means of calculating projec-ted doses of radiation /nuclides measured or detected.
ANSWER:
Independent monitoring will be performed by the State of Missouri as a joint operation of the State Emergency Management Agency 1/ and the Bureau of Radiological Health.
The capabilities and procedures for this operation are given in the l
l 1/
This is the future name of the Disaster Planning l
Operations Office.
f :
l t
o State of Missouri Nuclear Accident Plan, Annex - D,
" Radiological Monitoring and Decontamination Support" and in Annex - A,
" Bureau of Radiological Health Nuclear Facility Accident Emergency Plan and Procedure," Attachment - A2B.
Dose projection will also be performed by the Bureau of Radiological Health.
The methodology for this dose projection is presented in the Missouri Nuclear Accident Plan, Annex - B, pages B-12 to B-16.
This methodology is substantiated by the Environmental Protection Agency Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, (EPA-320/1-75-OO1),
sections 5.4.2 and 5.4.3, revised 6/79.
INTERROGATORY NO. 20.
If no systems, as indicated in 19 above, exist or are planned; indicate how verification of radiological releases are made and how local government /public can verify that rumo ad releases did or did not occur.
ANSWER:
Not Applicable.
INTERROGATORY NO. 22.
Provide a list of protective equipment to be used by each individual in the County Sheriff's i
Department if and when they are to respond to an incident or accident at the Callaway Plant No.
1.
If no equipment is provided by the County Court, explain how the equipment is to l
be obtained, what, if any special funds are made available for l
these missions, and what alternate means are available to provide personal and radiological protective equipment for this
[
department.
l l
l ANSWER and OBJECTION:
Respirators are being supplied by Union Electric and will be available in the Callaway County EPZ.
l l
Normal rain gear will serve more than adequately as protective i
I l,
l
clothing.
Applicant objects to the funding issue raised in this interrogatory, for the reasons stated in Applicant's i
response to Interrogatory 2(g).
INTERROGATORY NO. 23.
What radiological emergency response plans exist for the Village of Mokane?
If none, what agreement exists between the Village of Mokane and the County Court that permits the C,ounty Court to plan for radiological emergencies that may affect that populace?
What authority exists in law for such planning in lieu of such agreement?
Who is or will pay for such planning, drills, exercises and implementation of such plan by the Village of Mokane?
What County monies or other funds and how much has been allocated for the activities cited above?
ANSWER and OBJECTION:
A separate radiological emergency response plan does not exist for the City of Mokane, which is located in Callaway County and, accordingly, whose residents will be notified along with other members of the public within the PEP EPZ.
No Mokane resources are expected to be relied upon during emergencies to carry out the Callaway County emergency plan.
Nevertheless, in order to assure there is no misunderstanding about the arrangement, Applicant understands that an agreement is being sought between the city and the county.
Applicant objects to the issue of funding raised in this interrogatory, since it is outside the scope of the NRC proceeding.
See Applicant's response to Interrogatory 2(q).
INTERROGATORY NO. 24.
Mokane is located within approxi-mately 8 miles of the Callaway Plant No.
1.
What respiratory and thyroid protection is planned for in the event sheltering is ordered instead of evacuation for the following residents: -.
a.
Citizens of the Village of Mokane.
b.
Residents of the River-view Nursing Home c.
South Callaway R-II elementary and high schools What respiratory / thyroid protection is provided for citizens in the areas of Portland, Steedman, Readsville, Harmony Hill Youth Camp, Yucatan, Leisure Lake, Glover Springs Lake, Lost Canyon Lake, and other similar population concen-trations?
ANSWER:
The " areas" specified in this interrogatory are within Callaway County, and therefore are addressed in the Callaway County /Fulton Emergency Response Plan and supporting Standard Operating Procedures.
i 1. -.
CALLAWAY COUNTY INTERROGATORY NO. 6 TABLE 1.
1980 CENSUS POPULATION WITH IN EPZ Population Jurisdiction Callaway County 15,349 Auxvasse 941 Calwood 536 East Fulton (without Fulton) 784 Nine Mile Prairie 379 St. Aubert (without Mokane) 1,141 West fulton (without Fulton) 229 Fulton 11,046 Mokane 293 Montgomery County 116 Danville 18 Loutre 98 Osage County 1,412 Benton (without Chamois) 866 Chamois) 546 Gasconade County 217 Richland (without Morrison) 48 Morrison 169 Total 17,094 m-ii..
CALLAWAY COUNTY INTERROGATORY NO. 6 TABLE 2.
TRANSIENT POPULATION IN EPZ Distance From Plant Location Population 3 NNW Canyon Lake 48
- 3. 5 WNW Harmony Hill Youth Camp 40 5 NNW Thunderbird Lake 32 4.5-6 NNE Lake Lochaweeno 213 6 SE Paradise Lake 150 7 NNE Yucatan area 12 7.5 E Along County Line 3
10 NE Route YY 9
10 NW Glover' Spring Lake 39 10 NNW Leisure Lake 54 0
Reform wildlife management area 85 685 l
e 1
CALLAWAY COUNTY INTERROGATORY NO. 6 TABLE 3.
1980 SPECIAL FACILITY POPULATION IN EPZ COLLEGE 2,100 West minster 850 Dormitory 200 William Woods 1,250 Dormitory 850 SCHOOL 4,000 Fulton Public Schools 2,250 Fulton High School Fulton Junior High School Fulton Elementaries Bartley Bush Carver Center McIntire R-I (Chamois) 313 R-II (Mokane) 725 St. Peter's Catholic (Fulton) 100 Ark. Christian Elementary (Fulton) 100 Missouri School for the Deaf 500 INSTITUTION Patients Staff Total 3,150 State Hospital Number 1 1,200 1,500 2,700 State Program for Retarded Children 250 200 450 MEDICAL Patients Staff Total 350 l
l Callaway Memorial Hospital 24 18 42 Kingdom Nursing Home 44 29 73 Fulton Manor Nursing 50 38 88 Presbyterian Home Life 62 40 102 Riverside Nursing Home 25 29 45 TOTAL 9,600
CALLAWAY COUNTY INTERROGATORY NO. 10 TABLE 1 REPRESENTATIVE SHEILDING FACTORS FOR SURFACE DEPOSITED RADIONUCLIDES Representative Representative Stru6ture or Location Shielding Factor (a)
Range 1 m above an infinite smooth 1.00 sur face 1 m above ordinary ground 0.70 0.47-0.85 1 m above center of 50-ft roadways, 0.55 0.4-0.6 50% decontaminated Cars on 50-ft road:
Road fully contaminated 0.5 0.4-0.7 Road 50% decontaminated 0.5 0.4-0.6 Road fully decontaminated 0.25 0.2-0.5 Trains O.40 0.3-0.5 One and two-story wood-frame house 0.4 (b) 0.2-0.5 (no basement)
One and two-story block and brick O.2 (b) 0.04-0.40 house (no basement)
House basement, one or two walls 0.1 (b) 0.03-0.15 fully exposed:
One story, less than 2 f t of 0.05 (b) 0.03-0.07 basement, walls exposed l
Two stories, less than 2 ft 0.03 (b) 0.02-0.05 of basement, walls exposed Three-of four-story structures, 5000 to 10,000 sq. ft. per floor:
First and second floors:
0.05 (b) 0.01-0.08 t
l Basement 0.01 (b) 0.001-0.07 Multistory structures, >10,000 sq. ft. per floor:
Upper floors 0.01 (b) 0.001-0.02 i
Basement 0.005 (b) 0.001-0.015 1
(a)
The ratio of dose received inside the structure to the dose that would be recived outside the structure.
(b)
Away from doors and windows.
i t
t
P CALLAWAY COUNTY INTERROGATORY NO. 10 TABLE 2 REPRESENTATIVE SHEILDING FACTORS FROM GAMMA CLOUD SOURCE Sheilding Representative Structure or Location Factor (a)
Range Outside
- 1. 0 Vehicles
- 1. 0 Wood-frame house (b) 0.9 (no basement)
Basement of wood house 0.7
- 0. l' to 0. 7 (c)
Masonry House (no basement) 0.6
- 0. 4 to 0. 7 (c)
Basement of masonry house 0.4
- 01. to 0.5 (c)
Large office or industrial O.2 0.1 to 0. 3 (c,d) building (a)
The ratio of the dose received inside the structure to the dose that would be. received outside the structure.
(b)
A wood frame house with brick or stone veneer is approximately equivalent to a masonry house for shielding purposes.
(c)
This range is mainly due to different wall materials and diff-erent geometries.
(d)
The shielding factor depends on where the personnel are located within the building; (e.g., the basement or an inside room).
e 4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
UNION ELECTRIC COMPANY
)
Docket No. STN 50-483 OL
)
(Callaway Plant, Unit 1)
)
AFFIDAVIT OF ROBERT J.
SCHUKAI City of St. Louis
)
)
)
Robert J.
Schukai, being duly sworn according to law, deposes and says that he is General Manager-Engineering of Union Electric Company; that the answers contained in " Applicant's Responses to Specified Reed Interrogatories Served on the Callaway Court Administrative Judges and Emergency Management Coordinator" are true and correct to the best of his information, knowledge and belief; and that the sources of his information are the officers, l
employees, agents and contractors of Union Electric Company.
I 9
f
&kj Ro.
.{5chukai l
l Sworn to and subscribed before i
me this 22nd day of July 1982 M
Notarf Publi/d # //
My commissions expires 4/22/85 BARBARA J. PFAFF NOTARY PUBUC, STATE OF MISSOURI l
MY COMMISSION EXPIRES APRIL 22, 1985 ST. LOUIS COUNTY
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
UNION ELECTRIC COMPANY
)
Docket No. STN 50-483 OL
)
(Callaway Plant, Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Responses to Specified Reed Interrogatories Served on the Callaway Court Administrative Judges and Emergency Management Coordinator" and " Affidavit of Robert J. Schukai" were served this 23rd day of July, 1982, by deposit in the U.S. mail, first class, l
postage prepaid, to the parties on the attached Service List.
k, J' A AA Deborah B.
Bauser l
t l
l
/
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
UNION ELECTRIC COMPANY
)
Docket No. STN 50-483 OL
)
(Callaway Plant, Unit 1)
)
SERVICE LIST James P. Gleason, Esquire Kenneth M. diackes, Esquire CW man Chackes and Hoare Atomic Safety and Licensing Board 314 N. Broadway 513 Gilmoure Drive St. Icuis, Missouri 63102 Silver Spring, Maryland 20901 Mr. John G. Reed Mr. Glenn O. Bright Route 1 Atcmic Safety and Licensing King & m City, Missouri 65262 Board Panel U.S. Nuclear Regulatory Comission Mr. Faaard Steffen Washington, D.C.
20555 Charris, Missouri 65024 Dr. Jerry R. Kline Mr. Harold Icttmann Atomic Safety and Licensing Poute 1 Board Panel Owensville, Missouri 65066 U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Mr. Earl Brown P.O. Box 146 Roy P. Lessy, Jr., Esquire Auxvasse, Missouri 65231 r
Office of the Executive Legal Director I
U.S. Nuclear Regulatory Ccm ission Mr. Fred Luekey Washington, D.C.
20555 Rural Boute Phineland, Missouri 65069 Docketing and Service Section Office of the Secretary Mr. Samuel J. Birk.
U.S. Nuclear Regulatory Omnission P.O. Box 243 Washington, D.C.
20555 bbrrison, Missouri 65061
, Joseph E. Birk, Esquire Mr. Bcbert G. Wright Assistant to the Geneual Counsel Ibute 1 Union Electric Co::pany Fulton, Missouri 65251 P.O. Box 149 St. Icuis, Missouri 63166 Eric A. Eisen, EsquLe Birch, Horton, Bittner & btnroe A. Scott Cauger, Esquire 1140 Cbnnecticut Avenue, N.W., #1100 Assistant General Counsel Washingtcn, D.C.
20036 Missouri Public Sen* ice Comission P.O. Box 360 Jefferson City, Missouri 65102