ML20064N990
| ML20064N990 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/07/1982 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8209130065 | |
| Download: ML20064N990 (4) | |
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September 7, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 000KETED USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.
12 SP -8 N1 :22 In the Matter of
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0FFICE OF SECdETAIP' UNION ELECTRIC COMPANY
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Docket No. $b h
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(Callaway Plant, Unit 1)
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APPLICANT'S AMENDFENT TO ITS RESPONSE TO FINAL PARTICULARIZATION OF REED'S CONTENTIONS 1, 2, AND 3 On July 14, 1982, Applicant Union Electric Company submitted its Response to intervenor John G.
Reed's " Final Particularization of Reed's Contentions 1, 2, and 3."
In reviewing its Response, Applicant has determined that it inadvertently responded twice to one of Mr. Reed's contentions, proposed contention 1(d),
thereby omitting any response to proposed contention 1(c), which has two subparts, (1) and (2).
See Applicant's Response to Final Particularization of Reed's Contentions 1, 2,
and 3, dated July 14, 1982, at 12-13.
Applicant therefore asks the Board to accept the following addition to its Response, which addresses Mr. Reed's proposed contentions 1(c) (1) and 1(c) (2).
Proposed contention 1(c) (1) is entirely duplicative of proposed contention 1(f) (1), concerning the adequacy of communi-cations facilities, proposed contention 1(h) (2), concerning radia-tion protection and communications equipment, proposed contention 1(i) (2), concerning protective equipment for emergency workers, proposed contention 1(o), concerning radiological training, and 8209130065 820907 PDR ADOCK 05000483 G
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1 f proposed contention 2, concerning funding.
Accordingly, proposed contention 1(c) (1) should be rejected.
Proposed contention 1(c) (2) asserts that dedicated communica-tions facilities for each local government agent at the EOF must exist for that agent's use in contacting his local EOC.
Applicant does not object to this contention.
Respectfully submitted, j
SHAW, PITTMAN, POTTS & TROWBRIDGE h
Thomas A.
- Baxter, P.C.
Deborah B.
Bauser Counsel for Applicant 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1090
l $$
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
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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4 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicant's Amendment to Its Response to Final Particularization of Reed's 4
Contentions 1, 2,
and 3" were served this 7th day of September, 1982, by deposit in the U.S. mail, first class, postage prepaid, to the parties identified on the attached Service List.
i
/1
__ /L 4 Thomas A.
- Baxter, P.C.
i t
I
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMM.ISSION 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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SERVICE LIST James P. Gleason, Esquht Kenneth M. Chackes, Escuire Chaiman Chackes and Hoare Ate:aic Safety and Licensing Boad 314 N. Broadway 513 Gilncure Drive St. Icuis, Missouri 63102 Silver Spring, Maryland 20901 Mr. John G. Reed Mr. Glenn O. Bright Ecute 1 Atcrric safety and Licensing Kingccm City, Missouri 65262 Board Panel U.S. Nuclear Pegulatory Comrission Mr. Bcward Steffen Washington, D.C.
20555 Chanois, Missouri 65024 Dr. Jerry R. Kline Mr. Earold Icttmann Ato:ric Safety and Iicensing R o ut.e 1 Board Panel Owensville, Missouri 65066 U.S. Nuclear Regulatory Comrission Washington, D.C.
20555 Mr. Fred Luekey i
Rural Ibute Robert G. Perlis, Esquire Rhinaland, Fissouri 65069 Office of the Executive Iagal Director U.S. Nmlaa" Regulatory Comnission Mr. Samuel J. Birk,
Washington, D.C.
20555 P.O. Box 243 bbrrison, Missouri 65061 Docketing ard Service Section Office of the Secretary Mr. Icbert G. Wright U.S. Nuclear Regulatory Comrission Route 1
- .shington, D.C.
20555 Fulton, Missouri 65251
, Joseph E. Birk, Escuire Eric A. W en, Esqui_m Assistant to the General Counsel Bi.%, Horten, Bittner & btnroe Unicn Electric Co m ny 1140 Ccnnecticut Avenue, N.W., #1100 P.O. Box 149 Washingten, D.C.
20036 St. Iouis, Missouri 63166 A. Scott Cauger, Esquire Assistant General Counsel Missouri Public Service C o.ission P.O. Scx 360 Jefferson City, Missouri 65102 1
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