ML20071H952
| ML20071H952 | |
| 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 |
| Shared Package | |
| ML20071H409 | List:
|
| References | |
| ISSUANCES-OL, NUDOCS 8305250542 | |
| Download: ML20071H952 (3) | |
Text
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May 20, 1983 id l y h
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIOR et e.,
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BEFORE THE ATOMIC SAFETY AND LICENSI G\\BOARDfQ
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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 AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (CONTENTION 17)
Pursuant to 10 C.F.R.
$ 2.749(a), Applicant states, in support of its motion for summary disposition of intervenor Reed's Contention 17 (Radiological Monitoring), that there is no genuine issue to be heard with respect to the following material facts:
1.
The local radiological emergency response plans (i.e.,
Callaway/Fulton, Osage, Gasconade and Montgomery) state that 8305250542 830520 PDR ADOCK 05000483 G
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~l those government response organizations do not have the capability to perform field radiological monitoring and sampling or assessment cf radiological data, and that these functions will be performed by Callaway Plant, State and Federal agencies.
l 2.
There is no legal or valid planning basis for requiring that local offsite governments have offsite radiolog-ical monitoring and accident assessment capabilities redundant to the State of Missouri and Applicant.
3.
The State of Missouri, through its Bureau of Radiological Health (with logistical support from the State Emergency Management Agency) has resources in trained personnel and equipment to place at least two radiological monitoring teams (each composed of two persons) in the field within one.
hour of' initial notification, and to deploy two different teams in each subsequent 12-hour shift.
4.
The State Plan describes the means for notifying the State field monitoring team members, transporting them, the communications and monitoring equipment to be used, as well as the actual Field Monitoring and Plume Verification procedure.
5.
The Bureau of Radiological Health will have the
-7 capability to measure radioiodine levels as' low.as 10 uCi/cc under field conditions.
6.
The State Plan provides reasonable assurance that adequate methods,. systems and equipment for assessing and.
monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
See 10 C.F.R. 6 SO.47(b)(9).
7.
The State's radiological monitoring and accident assessment capability is redundant to, and supplemented by, Union Electric Company's extensive radiological monitoring and accident assessment capabilities both on site and in the field offsite.
8.
The Callaway Plant, State and local plans provide for use of Union Electric's radiological assessment information by local, State and Federal officials, and for close coordination in the off-site radiological monitoring efforts of Union Electric and the Bureau of Radiological Health.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE
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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 I