ML20071H425

Statement of Matl Facts as to Which There Is No Genuine Issue Re Reed Contention 1 Staffing of Montgomery County Sheriff Ofc

ML20071H425
Person / Time
Site:	Callaway
Issue date:	05/20/1983
From:	Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO.
To:	Atomic Safety and Licensing Board Panel
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References
ISSUANCES-OL, NUDOCS 8305250300
Download: ML20071H425 (2)

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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 STATEMENT OF MATERIAL FACTS ON REED CONTENTION 1 AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (STAFFING - SHERIFF'S OFFICE)

Pursuant to 10 C.F.R. 5 2.749(a), Applicant states, in support of its motion for summary disposition of intervenor Reed's Contention 1 in this proceeding, that-there is no genuine issue to be heard with respect to the_following material facts:

1.

During an emergency, it is a common and acceptable practice for emergency workers,- such as individuals performing law enforcement functions, to work a twelve hour shift.

8305250300 830520 PDR ADOCK 05000483 9

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2.

During an emergency, routine law enforcement activities need not be performed because relative to emergency-related functions, normal functions became-unimportant and can even hinder necessary emergency activities.

3.

The Missouri State Highway Patrol and the State National Guard have committed to respond and satisfy needed law enforcement functions in the'four counties'in the Callaway Plant plume exposure emergency planning zone ("EPZ").

4.

Because of-the availability of local law enforcement-officers and personnel from other local organizations assigned law enforcement-related functions in the county plans, supple-mented as needed by members of the Highway Patrol and the National Guard, there are more than an adequate number of personnel to fulfill county law enforcement-related functions in the event of an emergency at the Callaway Plant.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE

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Thomas A.

Baxter, P.C.

r Deborah B. Bauser 1800 M Street, N.W.

L Washington, D.C.

20036 (202) 822-1000 May 20, 1983 J

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