ML20076G907
| ML20076G907 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/13/1983 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20076G909 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8306160314 | |
| Download: ML20076G907 (4) | |
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Juno 13, 1983 cWP
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UNITED STATES OF AMERICA g 36 NUCLEAR REGULATORY COMMISSION 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 ANSWER TO INTERVENOR'S MOTION AND RESPONSE TO APPLICANT'S MOTION FOR
SUMMARY
DISPOSITION OF MR. REED'S CONTENTIONS On May 31, 1983, intervenor John G. Reed filed "Intervenor's Motion and Response to Applicant's Motion for Summary Disposition of Mr. Reed's Contentions."
The Commission's Rules of Practice do not contemplate the filing of a reply by the movant for summary disposition.
Nevertheless, Applicant Union Electric Company must reply to one aspect of Mr. Reed's pleading -- his accusation, in response to the motions on Contentions 1 and 2, that Applicant's counsel and Mr. Gerald W. Stanfill, Radiological
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Emergency Planner with the Missouri State Emergency Management Agency ("SEMA"), misrepresented facts and attempted to mislead the Licensing Board.-1/
I Mr. Reed asserts that Mr. Stanfill is an employee of Union Electric Company merely working at SEMA, and that Mr. Stanfill is biased because he could lose his job if he did not endorse l
the views of Union Electric Company.
The enclosed Affidavit of l
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This narrow reply should not be read as acquiescence by Applicant to the veracity of the remainder of the statements in Mr. Reed's pleading.
8306160314 830613 h
PDR ADDCK 05000483 D
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eor
William R.
Beaty, the Director of SEMA, demonstrates that Mr.
Reed's reckless charges are false.
Mr. Beaty explains that while Union Electric has temporarily funded ~a SEMA position through a third-party contract, the Company's arrangement with that third party (in the form of a purchase order) provides that the employee will be selected by SEMA to work for, at the direction of, and under the complete control of SEMA.
Mr. Beaty states that Mr. Stanff.ll was selected by SEMA, that he is not an employee of Union Electric Company, and that ll 4
Mr. Stanfill cannot be discharged, or the subject of any retaliatory action by, Union Electric.. Consequently, the
. temporary funding of Mr. Stanfill's position is irrelevant to this proceeding and need not have been disclosed by Mr.
Stanfill or Applicant's counsel.
Further, the arrangement clearly guarantees Mr. Stanfill's objectivity as a SEMA staff member.
The accusation of bias, based upon Mr. Reed's apparent misunderstanding of the facts, is therefore without foundation.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE l
Thomas A.
Baxter, p.C.
Counsel for Applicant 1800 M Street, N.W.
l Washington, D.C.
20036 (202) 822-1090 i
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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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CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Answer to Intervenor's Motion and Response to Applicant's Motion for Summary Disposition of Mr. Reed's Contentions" and " Affidavit of William R. Beaty" were served this 13th day of June, 1983, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.
n Thomas A.
Baxter, P.C.
1 I
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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, Esquire K-uni:t.h M. Chsckes, Esquire maivman Chsckes and Hoare Atomic Safety and Licensing Board 314 N. Broadway 513 Gih oure Drive St. Iouis, Missouri 63102 Silver Spring, Maryland 20901 Mr. John G. Reed Mr. Glenn O. Bright Route 1 Atmic Safety and Licensing Kingdcm City, Missouri 65262 Board U.S. Nuclear Regulatory Cenmi=sion Mr. Howard Steffen Wa=hington, D.C.
20555 Chmois, Missouri 65024 Dr. Jerry R. IOine Mr. Harold LDLL aut Atcznic Safety and M=aing amt.e 1 Board Owensville, Missouri 65066 U.S. Nuclear Regulatory Cenminaion Wa=hington, D.C.
20555 Mr. Fred Luekey Rural Route Robert G. Perlis, Esquire Rhineland, Missouri 65069 Office of the E='#1ve Iagal Director U.S. Nela=" Regulatory Nirnicn Mr. Samuel J. Birk,
Wa=hingtcm, D.C.
20555 i P.O. Box 243 Morrison, Missouri 65061 l
Docketing and Service Section l
Office of the S w i.ary Mr. Ibbert G. Wright U.S. Nuclear Regulatory Cemmiasion Ibute 1 W ahingtcm, D.C.
20555 Fulton, Missouri 65251
, Joseph E. Birk, Esquire Eric A. Eisen, Esquire Assistant to the h val Counsel Birch, Horton, Bittner & Monroe Union Electric re==ny 1140 Cbnnecticut Avenue, N.W., #1100 P.O. Box 149 Washingtcn, D.C.
20036 St. Iouis, Missouri 63166 Steve Ferris A. Scott Cauger, Esg s e FEMA, Region VII l
Assistant General Counsel 911 Walnut Missouri Pnh1ic Service Ccmnission Focm 300 P.O. Box 360 Kansas City, Missouri 64106 Jefferson City, Missouri 65102 i
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