ML20071H815

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Statement of Matl Fact as to Which There Is No Genuine Issue Re Reed Contention 11 on Recovery & Reentry Radiation Stds
ML20071H815
Person / Time
Site: Callaway Ameren icon.png
Issue date: 05/20/1983
From: Baxter T
SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20071H409 List: ... further results
References
ISSUANCES-OL, NUDOCS 8305250490
Download: ML20071H815 (2)


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O UNITED STATES OF AMERI MJ'Pgy

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A s4 BEFORE THE ATOMIC SAFETY AND LICENS ,- , ,/

In the Matter of )

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UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL

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(Callaway Plant, Unit.1) )

i APPLICANT'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (CONTENTION 11)

Pursuant to 10 C.F.R. 6 2.749(a), Applicant states, in support of its motion for summary disposition of intervenor Reed's' Contention.11, that there is no genuine issue to be heard with respect to the following material facts:

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[ ' 1. The off-site plans' provide.that the designated local i

l decision-makers on recovery and reeatry will utilize recom-j mendations and information from the (Missouri) Bureau of Radiological Health and the.Callaway Plant. .

2. Standards need not be written to a level of detail which would permit' local decision-makers-to implement reentry i and recovery operations independently of Applicant, State and Federal agencies.

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3. Only general plans for recovery and reentry are required. , ,
4. Radiation levels alone constitute an incomplete and inadequate basis for recovery and reentry decisions.
5. Utilization of a number of criteria, some of which are judgmental, calls for a degree of flexibility in the decision process.
6. The decision criteria specified in the off-site plans,.for recovery and reentry, include radiation standards in the form of State Protective Action Guides, which are a part of the State plan, and which are recognized, endorsed and utilized in the local plans.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE 1 A '

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Thomas A. Baxter, P.C.

Deborah B. Bauser Counsel for Applicant 1800 M Street N.W.

Washington, D.C. 20036 (202) 822-1000 May 20, 1983 l

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