ML20079M218
| ML20079M218 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/18/1983 |
| From: | Jeffrey Reed REED, J.G. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8302230607 | |
| Download: ML20079M218 (3) | |
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UNITED STATES T A} ERICA
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NUCLEAR REGULATQ1Y C0! MISSION BEFCRE THE ATOMIC SAFETY AND LICENSING BOARD b
In the Matter of
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'83 FEB 22 P2:51
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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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i3bN REbD'S REBUTTAL TO STAFF VIEWS RELATING 70 PART 20 STANDARDS, DATED 14 FEBRUARY 1983 Staff Counsel, in its views, identified above, acknowledged that 10 CFR, Part 20 establishes standards for protection against radiation (see Staff Views, II. DISCUSSION, first sentance). Section 20.1 (a) of said Part 20 specifically states:
"The regulations in this part, establish standards for protection against radiation hazards arising out of activities under licenses issued by the Nuclear Regulatory Commission.."
If these regulations, indeed, establish standards for protection against radiological dangers, and there is no other standard within the framework the U.S. N.R.C. Rules and Regulations, Title 10 - Chapter 1, Code of Federal Regulations, then these standards must be applied, regardless of the date they were formulated, to protect the public health and safety from hazards arising out of activities under licenses issued by the KRC.
Staff states that the framers of the emergency planning regulations did not mean to apply Part 20 guidelines to recovery / reentry phase (see Staff Views, page two last two lines on th'e page), but Staff fails to provide an identification of other standards of protection against radiation hazards. Further, Staff comments (see Staff Views, page three, lines 3 & 4) are incorrect; Part 20 plcces a limit upon individual radiological exposures, 8302230607 830218 PDR ADOCK 05000483 O
PDR 3
in r=nricted and unrestricted areac. The purpose of Part 20, is to set inflexible standards whereby public health and safety are reascnably assured within all areas identified within the regulation. To assume, as does Staff that safety standards that apply to routine operations of a nuclear power plant do not apply to extraordinary conditions (see Staff Views, page 2, lines 9,10, & 11) are without foundation in regulatico and can be viewed as a violaticn of Part 20, Section 20.6 Interpretations.
The standards set forth in Part 20 clearly identify acceptable dose or exposure levels for a complete cross-section of the population within and without the licensed facility. No other standards exist establishing protection of the public health and safety in the N.R.C. Rules and Regulations.
No other Federal agency has authority to set such standards; therefore, it matters little whether or not Staff Counsel has applied these standards in its past activities; in this matter, no other alternative exists.
The establishment of an inflexible standard for radiological exposure of returning evacuees to an area is merely the basis by which general plans are fornulated, and as such are the foundation or corner-stone for such a plan.
For the above reasons, the undersigned finds Staff views, identified above, to be without merit, and requests the Board to rule appropriately.
pectfully submitted, Dated this 18th day JOHN G. REED of February 1983 at Citizen of the United Statea Kingdom City, }0.
of America RFD #1 Kingdom City, 10. 65262 tel: (314) 642-2769
U:.:TED STA'~t.3 CF AK_5ICA NUCLEAR hEGULIGORY coa 3SSION BEFO?.E THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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UNICN ELECTRIC COMPANY
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Docket No. STN 50-483
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(Callaway Plant, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that the document attached hereto was served this I
j6 day or Famq,1983 by deposit in the U.S. mail, first class posta6e prepaid upon the fellcwing:
t Ja:nes P. Gleason, Esquire Fr. Glenn O. Bright l
Chairc.an, Atomic Safety and Atomic Safety and Licensing Board Licensing Board Panel Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Comission Silver Spring, Maryland 20901 Fashington, D.C. 20555 Dr. Jerry R. Klins Docketing and Service Settion Ate r.ic Safety ano Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory Co=ission U.S. Nuclear Regulatory Commir,cion 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
/ John G. Reed Citizen of the United States of America
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