ML20071H614

Statement of Matl Facts as to Which There Is No Genuine Issue Re Reed Contentions 6 & 16 on Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering

ML20071H614
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: ML20071H404 ML20071H415 ML20071H425 ML20071H436 ML20071H490 ML20071H496 ML20071H504 ML20071H509 ML20071H513 ML20071H518 ML20071H522 ML20071H527 ML20071H531 ML20071H541 ML20071H553 ML20071H563 ML20071H570 ML20071H577 ML20071H582 ML20071H596 ML20071H604 ML20071H614 ML20071H625 ML20071H636 ML20071H647 ML20071H655 ML20071H671 ML20071H687 ML20071H708 ML20071H718 ML20071H740 ML20071H750 ML20071H753 ML20071H761 ML20071H773 ML20071H783 ML20071H790 ML20071H801 ML20071H815 ML20071H832 ML20071H852 ML20071H864 ML20071H883 ML20071H888 ML20071H904 ML20071H906 ML20071H927 ML20071H937 ML20071H945 ML20071H952 ... further results
References
ISSUANCES-OL, NUDOCS 8305250419
Download: ML20071H614 (3)

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BEFORE THE ATOMIC SAFETY AND LICENSIN

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

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(Callaway Plant, Unit 1) )

APPLICANT'S STATEMENT OF MATERIAL FACTS ON REED CONTENTIONS 6 AND 16 AS TO WHICH THERE IS NO GENUINE ISSUE TO'BE HEARD (PROTECTIVE ACTIONS AGAINST RADIOIODINES &

MESSAGES WITH INSTRUCTIONS FOR LONG-TERM SHELTERING)

Pursuant to 10 C.F.R. 5 2.749(a), Applicant states, in support of its motion for summary disposition.of intervenor-Reed's Contentions 6 and 16 in this proceeding, that there is no genuine issue to be heard with respect.to the following material facts:

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1. The administration _of potassium-iodine ("KI") to emergency workers and institutionalized persons whose immediate

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-evacuation from the planning zone.("EPZ") may be-infeasible or-

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very difficult in.the-event of a radiological emergency is recommended by the variuos federal agencies charged with evaluating and making recommendations to State agencies about the administration of KI.

2. To date, ru) federal agency has recommended the administration of KI to the general public located within the ten mile plume exposure pathway EPZ.-

3. The State of Missouri policy on the administration of KI is fully consistent with current federal guidance and is

-soundly based on the factors that must be balanced in making this public health policy decision.

4. Neither sheltering nor ad hoc respiratory protection is intended to be a protective action that is equivalent in its appropriateness or-its effect as the ingestion of KI.

5. The use of sheltering as a viable protective action is-supported by data on the ability of structures to shield individuals from exposure to radiation.

6. The use of ad hoc respiratory protection as a viable protective action is supported by data on the effectiveness of  !

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using common household materials as inhalation filtering devices to minimize internal exposure to radioactive material.

Respectfully submitted, SH.iW, 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

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