ML20070M046

Response to ASLB 821207 Order Re Applicability of 10CFR20 Stds to re-entry/recovery Activities.Permitting re-entry/ Recovery at Levels Exceeding Part 20 Contradicts NRC Regulation & Policy.Certificate of Svc Encl

ML20070M046
Person / Time
Site:	Callaway
Issue date:	01/06/1983
From:	Jeffrey Reed REED, J.G.
To:
References
NUDOCS 8301120241
Download: ML20070M046 (3)

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V UNITED STATES & AE:RICA NUCLEAR REGULAKRY COMMISSION DOLKETED

.nsr BEFmE THE ATOMIC SAFETY AND LICENSING B0 FLU In the Matter of '83 JAM 11 N0 54 UNION ELECTRIC COMPANY Docket No. STN 50-483 cnk pccy,LTm MGt4tlmG & SEP\ !

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(Callaway Plant, Unit 1) )

U REED'S RESPONSE TO BOARD EDER DATED 07 DECEMBER 1982 The Board, by order dated 07 December 1982, requested a response from all parties on the applicability of Part 20 standards to reentry / recovery activities (see paragraph 4, or said order). In coupliance therewith, the following is submitted:

1. Radiological emergency response plans for State and local governments provide for control of radiological exposures in areas which are not under the control of the licensee, and include areas used for residential quarters.

2. By definition, such areas are " UNRESTRICTED AREAS",, and are provided for in 10 CFR, Part 20 (see Sectica 20 3, a, (17)). Protective standards for unrestricted areas are set in Sections 20.105 and 20.106 along with exposure standards for any foetus, infant, child, minor, female of child-bearing age, etc. elsewhere in Part 20.

3. Recognizing the argument that the above referenced standards are intended to apply to routine operations and their resulting nuclide releases; it must, none the'less, be acknowledged that these standards are set and apply to minimum exposure levels for individuals in unrestricted areas if radio-contamination is present. As such, how or why an unrestricted

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8301120241 830106 PDR ADOCK 05000483 0 PDR O

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A area becomes contaminated by nuclides previously in the possession of

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a licensee becomes moot. Under the provisions of the Act, the Corsaission must insure that population exposures are kept within safe limits, and such limits are specified in 10 CFR, Part 20. -

4. Topermitreentry/recoverytooccuratleveisinexcessof those set by Part 20 is a contradiction to NRC regulation and policy, s even if such is authorized by State or local governments in ignorance of ,

Commission regulation.

'5 Inclusion of clear, concise instructions, suitable for lay-interpretation, in State and local radiological emergency response plans .

will provide all officials of the govemments involved with a basis for determiningreentry/recoveryactions. Also, it provides the Consnission with a means by which it can most easily meet its regulatory r.equirement to protect the public health and safety. To refuse to include such.in all plans presents a situation in which it is possible that radiological exposure in excess of Part 20 standards will. occur after a plant accident has taken place.

Res'pectfully sub te -

Dated this 06th '

John G. Reed day of January 1983 Citizen of the United States at Kingdom City, 10. of America RFD #1

! Kingdom City, Missouri 65262 tel: (314) 642-2769 i

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k UNITED STATE 3 C? AV.:.53CA

.6 NUCLEAR RLGULA10RY COMMISfICN BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of -)

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UNION ELECTRIC COWANY ) Docket No. S7W 50-483

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(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE .

I hereby certify that the document attached hereto was served this 06D day of Yanvar , 1962 by deposit in the U.S. mail, first class postage prepaid upon the following:

James P. Gleason, Esquire Mr. Glenn O. Bright Chairman, Atomic Safety and Atomic Safety and Licensing Board Licensing Board Panel . Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Commission -

Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline Socketing and Service Section

! Atomic SafetyJand Licensing Office of the Secretary:ev Board Panel U.S. Nuclear Regulatory Com :ission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Robert G. Perlis, Esquire Kenneth M. Chackes, Esquire Office of the Executive Legal Director Chackes and Hoare U.S. Nuclear Regulatory Commission 314 N. Broadway Washington, D.C. 20555 St. Louis, MO. 63102 Thomas A. Baxter, Esquire ' -

Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.

Washington, D.C. 20036 '

Atomic Safety and Licensing .

Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 -

• hand delivered /Jo G. Reed

! Citizen of the United States of America 1

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