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l- | May 2N | ||
/p I | |||
O UNITED STATES OF AMERI MJ'Pgy | l-4 | ||
~ | |||
i | O h | ||
UNITED STATES OF AMERI MJ'Pgy 7 | |||
A s4 BEFORE THE ATOMIC SAFETY AND LICENS | i | ||
In the Matter of | - NUCLEAR REGULATORY COMMI SION7 t | ||
4 %, | |||
UNION ELECTRIC COMPANY | A '6 t | ||
Lic.) | |||
(Callaway Plant, Unit.1) | ~ | ||
A s4 BEFORE THE ATOMIC SAFETY AND LICENS | |||
,-,,/ | |||
In the Matter of | |||
) | |||
) | |||
UNION ELECTRIC COMPANY | |||
) | |||
Docket No. STN 50-483 OL | |||
) | |||
(Callaway Plant, Unit.1) | |||
) | |||
i APPLICANT'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (CONTENTION 11) | 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: | 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: | |||
l | l | ||
[ | [ | ||
l | ' 1. | ||
The off-site plans' provide.that the designated local i | |||
l | l decision-makers on recovery and reeatry will utilize recom-mendations and information from the (Missouri) Bureau of j | ||
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. | |||
l | |||
.18305250490 830520 P,DRADOCK05000g8 - | |||
.. a 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. | |||
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE 1 | Utilization of a number of criteria, some of which are judgmental, calls for a degree of flexibility in the decision process. | ||
6. | |||
Thomas A. Baxter, P.C. | 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. | ||
Deborah B. Bauser Counsel for Applicant 1800 M Street N.W. | Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE 1 | ||
Washington, D.C. 20036 (202) 822-1000 May 20, 1983 | A | ||
/kM. | |||
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 | |||
...i}} | |||
Latest revision as of 06:28, 15 December 2024
| ML20071H815 | |
| 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 8305250490 | |
| Download: ML20071H815 (2) | |
Text
.
May 2N
/p I
l-4
~
O h
UNITED STATES OF AMERI MJ'Pgy 7
i
- NUCLEAR REGULATORY COMMI SION7 t
4 %,
A '6 t
Lic.)
~
A s4 BEFORE THE ATOMIC SAFETY AND LICENS
,-,,/
In the Matter of
)
)
UNION ELECTRIC COMPANY
)
Docket No. STN 50-483 OL
)
(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:
l
[
' 1.
The off-site plans' provide.that the designated local i
l decision-makers on recovery and reeatry will utilize recom-mendations and information from the (Missouri) Bureau of j
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.
l
.18305250490 830520 P,DRADOCK05000g8 -
.. a 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
/kM.
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
...i