-. . _ . -. -- . . . . _ . _ . - ,_ - _ -_

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.

UNITED STATES OF AbhRICA DOCgETED

p}OCT 27195)>

8

geMRCNUCLEAR Rt.GULATCRY COMMISSIC4'

-

r__

{ osaerassanturBEFORE THE ATOMIC SAFETY AND LICiNSING BOARD

NIn the Matter of ) !

UNION ELECTRIC COFPANY ) Docket Nos. STN 50-483) STN 50-486

(Callaway Plant, Units 1 and 2) )

APENDED PETITION FOR LEAVE TO INTERVENE ANDREQUEST FOR A HEARING |

Under the provisions of 10 CFR - 2.714(a)(3), the undersigned amends~~

his petition for leave to intervene in the proceedings called under the

docket numbers indicated above and requests a hearing in this matter.

!

Petitioner is a citizen of the United States of America, a resident of

Callaway County, Missouri, a prope.ty owner in said county, and the

parent of school-aged children. Th family residence, other owned

property, and the high school (where one child attends school) are

located sixteen miles (more or less) from the Callaway Plant in Plume

Exposure Pathway "R"; the elementary school (where the other child

attends school) is about nineteen miles from said plant in Plume;

Exposure Pathway "Q". Health and safety of petitioner's family

(identified hereafter as public health and safety) 'and the value of

all property owned by the undersigned can be adversly affected by a

Class 9 radiological accident (see NUREG 0396/ EPA 520/1-78-016 and

44 FR 6H23) at the Callaway Plant. While petitioner's residence is .

'80102,9.0#5 6 - - . - - - . , -.

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technically outsido a 10 mile radius of the plant,; the actual chape of

this EPZ depends upon the characteristics of a particular cite (NUREG

| 0654 FEMA-REP-1, Section I, D, 2) and it is possible that the residenceI

and other property will be located inside the actual fallout pattern

established by the deposition of particulate matter in a radiocative

plume emanating from the plant. Residence is wC hin the Ingestion EPZ.

Petitioner interest is limited to radiation safety matters inside the

low population zone (LPZ) and in the emergency planning zones (EPZ).

Interest is directed to the emrgency planning requirements established

in UUREG 0654 FEl%-REP-1; 10 Cnt, Part 50; Appendix E to Part 50; and

data in Part 100.

10 CFR, Part 50 - PROPOSED RULE MidING - 43 FR 37473; APPENDIX E -

EERGECY PLANS FOR PRODUCTIGI ANb UTILIZATICN FACILITIES, Supplementary

Information, Section 4, Procedures, paragraph 3, is accepted as

authority to refer to pending revisions, amendments and new rules in

the Federal Register,r

Specifically, interest is directed to the' general information required

by 10 CFR, Part 100, Sections 100 3 and 100.11; 10 CFR, Part 50,

Sections 50 33, 50.47 and Appendix E, thereto. Included are the

revisions, 'amendients and new rules identified as " interim guidance"

in 43 FR 37473 cited above. Also, the practical aspects of in:plementing

procedures necessary to transform " emergency plans" into effective

_ __ -

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radiological protection of public health cnd safety as contained in

the provisions of NUREG 0654 FEW-REP-1 and 10 CFR, Part 50 and

Appendix E, thereto. Petitioner seeks reasonable assurances that the

activities to be authorized by the operating license can be conducted

without endangering the health and safety of the public, and that such

activities will be conducted in compliance with pertinent rules and

regulations of the NRC.

Interest of the petitioner can be affected by these proceedings ini

that issuance of the operating license constitutes the removal of'

the last legal control on the utility, permitting "on-line" operation

of the facility licensed. The next control action available to NRC

is dependent upon failure of the utility to comply with establiched i

NRC rules (21 FR 355 and 44 FR 75167). Such failure to comply may be

the result of utility actions or inactions which initiate a serious

nuclear accident. Not to address the practical aspects of providing

for the radiological health and safety of the public impacted by the

operation of the Callaway Plant and solving such problems as may arise

in the discussion thereof can result in an unnecessary hazard to said

public health and safety and cause needless damage to property in the

event of a Class 9 accident (NUREG 0396, Appendix I, D, 2).

Petitioner should be permitted to intervene for the following reasons:

1. Petitioner is authorized to appear under provisions of 10 CFR,

Section 2.713 (a):

" Representation. A person may appear in an adjudication onhis or her own behalf - - ."

~ _

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2. Possibic (probable) injury to petitioner's family (public

health and safety) and possible (probable) damage to property owned

by petitioner should satisfy " injury in fact test" and should be

" arguably within the zone of interest" protected by the statute

(Sierra Club v. Morton, 405 US 727 (1972); Warth v. Soldin, 422 US

490 (1975).

3. This is the proper time in the licensing process for discussion

of plant operating safety matters (45 FR 10492) and emergency planning*

(!3 FR 37473):,

"- - the emergency plans will be reviewed at the operatinglicense stage in accordance with interim guidance - ."

| 4. Section 189a of the Act provides that upon 30 days noticeI

! published in the Federal Register, the Commission may issue an

operating license or amendment to an operating licenso - - without a

public hearing if no hearing is requeeted by any interested person.

The request by petitioner, contentions and supporting documentation

provide a basis for a hearing.

5. Contentions of petitioner provide a basis for exercise of the

Commission's ability to implement policy statermnts contained in 43 FR

28058, 6/28/78 and 43 FR 49082,10/20/78 quoted in part, below:

43 FR 28058 "As a general matter, the Commission and stafftry to involve concerned citizens in any Commission activityin which they have expressed an interest. - - ."

43 FR 49082 " Recommendation 6 - - It is the intent of theCommission to provide increased opportunity for the publicto observe and participate in the licensing process - - ."

6. Interest of petitioner can be best served by pro se intervention

because of first hand knowledge of local governmental capabilities as

. . -

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regards radiological response in support of the Callaway Plant, and

personal knowledge of any and all coordinating efforts between the

applicant, the State government and local governments and agencies.

Such information available to the ASLB through testimony and examination

of witnessen by petitioner.

l

Contentions of petitioner and discussions are specified below. All|

substantiating dccumentation is contained in attachments as indicated. '

Contention 1,

Applicant has not made sufficient arrangements with local governments,

nor local agencies and organizations to cert the requirements of 10 CFR

Part 50, Section 50.47(b). Issuance of an operating license is

prohibited by 10 CFR, Part 50, Section 50.47(c)(1).

Discussion

The Callaway Plant impacts eight governnental jurisdictions with respect

to the 10 mile EPZ. To this date, neither aid nor funding has been

provided by Union Electric Company for the development and impletentation

of adequate emergency response plans; these governmental entitica do not

have sufficient funds to support planning and recessary administrative

or operational requirements to meet NRC requirements. Therefore; no

authorized local planning has been initiated (see Attachments la thru

lh and 2a thru 2h). Operation of the plant without adequate loen1 plans

and response capability will result in danger to public health and

safety (45 FR 55402, pub. 8/19/do, eff.11/3/s0 Rationale for the Final

Rules, paragraph 3).

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Contention 2

As of 02 June 1980, no funding for planning purposes or acquisition

of equipment and other related materials required in NUREG 0654 FEMA

-REP-1 have been roccived by the State of Missouri and Stato " Interim

Nuclear Accident Plan" will not be completed until August 1981 (see

Attachment J). (Letter obtained from LPDR, Fulton, EO.) Applicant

cannot meet the requirements of 10 CFR, Part 50, Section 50.33(g).

Discussion

Baced upon the details in paragraph 2, lines 4, 5 and 6 of referenced'

letter, applicant is unable to present plans for state 'ove rnr.cnt

with current application. Also, baced upon affidavits frt a Presiding

Judges and Mayors of irpacted jurisdictions; applicant cannot submit

local governn.cnts' plans as required in 10 CFR, Part 50, Section 50.33

( g) . Witnout cuch plans, HRC cannot evaluate provisions for protecting~

public health and safety in the LPZ or either EPZ. Operations of the

plant is prohibited by 10 CFR, Part 50, Section 50.47(c)(1).

Contentien 3

Applicant's SNUPPS - FSAR, Volume 5, Appendix 13 3A (13 3A.5.4) and

Missouri State Emerguacy Operations Plan, Part 3, Section B, " Nuclear

Emergency Ansictance Plan", prepared by the Department of Public

Safety, DP00, dated 23 May 1979, do not adequately provide for the

protection of public health and safety in the event of a radiological

emergency at the Callaway Plant. See 45 FR 55402, pub. 8/19/80; cff.

11/3/80, quoted in part below:

- - . No new operating license will be granted unless the NRC"

can make a favorible finding that ,the integration of onsite andoffsite emergency planning providQ3 reasonable ascurance that

ka

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adequate protective measures can and will be taken in the eventof a radiological emergency. - - - - - - - ."

Discussion

Applicant's SNUPPS - FSAR, Volume 5, Appendix 13.3A (13 3A.5 4) puts

lead responsibility for radiological defense of the public health and

safety on the Departn.cnt of Public Safety, Disaster Planning and

Operations Office:

SNUPPS - FSAR (13 3A.5 4.1)

" The Governor of the State of Missouri has delegated theauthority for protecting the health and safety of the generalpublic in the event of a radiological emergency to the

'

Department of Public Safety, Disaster Planning and OperationsOffice (DPOO). Iais office has prepared a draft State ofMissouri Radiological Emergency Response Plan. - - - d. Toprovide for coordination among State, local and Federal agencies

Assistance available to Union Electric Company from DP00- - .

in the event of an accident would include, but not necessarilybe limited to:

a. Notification and alert of agencies and the generalpopulace.

b. Off-site monitoring, evaluation, and reporting.c. Respense decision by the Governor.d. Traffic control and evacuation of affected areas.e. Medical surveillance of personnel to determine exposure

desage,fc' Establishment of Radiation Protective Act10n Guides,g, Emergency welfare services,h. Supnort by the Missouri National Guard.i. Monitoring of agriculture contamination.j. Supervision of off-site re-entry survey and decon-

tamination efforts.k. Centrol of public information releases.

Various agencies and organizations within the fran.ework of thegovernment of the State of Missouri .rovide expertise - - .Unicn Electric's primary responsibility is to notify the DP00in the event of an Emergency Alert, Unit, Site or GeneralEmergency. - - - ."

At no point in the DP00 Nuclear Emergency Assistance Plan does DP00.

accept " lead responsibility" to perform the functions listed in SNUPPS

FSAR, above, but abrogates those duties and acts as a technical

-8.

.

advisory council to local government:

NUCLEAR EFiRGB'CY ASSISTANCE PLANSection I - Basic Plan

" I. MISSTgl This document describes the procedures to be followedwhen the Missouri Nuclear Emergency Team (McNET) is requested bylocal authority - - . The primary objective of MoNET shall be toprovide immediate technical assistance to local authorities at thescene of a radiological emergency - - .

II SITUATION AND AS3Ul?TIONS A radiolor. cal incident is anoccurance which results in the loss of control of radioactivematericle - - . An incident may occur at a hospitol - - or anuclear power plant - - . In the event such an incident occurs,it is expected that local authorities - - - would be capable oftaking the action described in Section IV Emergency Procedures ForLocal Authorities. - - - Qualified technical experts are expectedto give assistance and advice to local authorities. - - Aseistance-

provided shall not in any way usurp or circumvent Federal or localauthority - - ."

All practical responsibility for public health and safety is deposited

at the local level of governnent which is not included in the utility's

FSAR. This repudiation of " lead reepensibility" by DPCO and the failure

of the Ltility to include local governments into its FSAR in a

meaningful role presents a situation devoid of practichi emergency

response needed to protect the public health and safety and prevent

damage to pre erty (live stock and crops). Applicant's FSAR does not

meet the criteria of 44 FR 75167,12/19/79,10 CFR, Part 50, Appendix

E, III - The Final Safety Analysis Report:

" The Final Safety Analysis Report shall contain the emergency plansplans - . - - The plans shall incorporate information about theemergency response roles of supporting organizations and off-siteagencies. That information shall be sufficient to provideassur;nce of coordination among the supporting groups and betweenthem and the licensee. - - ."

Informaticn to provide response roles and assurance of coordination is

absent from the FSAR (see Attachment 4). This haphazard approach to

planning is the result of failure of Union Electric Company, and the&

..n.

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State of Missouri to initially inc]ude local gcVernnents in the

planning process. A hearing by the ASLB would assist in clarifying

the facts as presen #4 and clininate petitioner's and public concern

in this natter.

Contention 4

Funding of local government to meet radiological safety response

capability has not been adequately addressed by NRC, FEMA, or other

Federal Agency. Failure to resolve the problem of funding for emergency

planning and response capability at the local level of government will,

result in o placing of responsibility for supporting commercial nuclear

power plante uper governmental jurisdictions which do not have the

financial ability to meet established URC criteria for the protectioa

of public health and safety. This is a contradiction of Commission

policy and intent (PS-31, 44 FR 61123,10/23/79). To defer action on

this matter until after the Callaway Plant is in operation can adversly

affect the health and safety of the public as regards any radiological

incident due to operati on of this facility.,

Discussion

The study done by Dr. Stephen N. Salomon, Office of State Programs, US

NRC; NUREG 0553, Beyond Defense-In-Depth, October 1979, clearly

identifies the urgency of and need to resolve the question of funding

at the local level. See NUREG 0553, Chapter 7, exerpts quoted:

" Local goveranents are recognized by the States as having thefirst line of official public responsibility to prepare for andrespond to most emergencies. - - - a discussion of funding atthe local level is essential. - - - There are basically threecentral iesnes:

- 1C -.

.

The assurance of adequate funds at the local - - jurisdictionthat is hosting the nuclear power station - - .

The assurance of adequate funds to local - - jurisdictionsneighboring the host juricdiction - - .

The assurance of continuity over time of adequate funds- - - of all impacted jurisdictions. - - ."

While Dr. Salomon's PP2FERRED APPROACH (Part III. A, N'JRhG 0553)

provides a satisfactory bas'- "'r assuring the financial capability

1

of local governments to meet the NRC planning guidelines, the subject

was not addressed in NUREG 0654 FE}%-REP-1, except on page number 21

as follows:-

" C. FUNDING AND TECHNICAL ASSISTANCE While funding and technicalassistance are not addressed in this doeur.cnt, it is a subject whichmust be discussed in any large effort to culckly improve planningand resources. - - - FEl% and NRC expect tfiat the nuclear facilityoperator will have an interest in providing certain manpower andcapital expenditures needed by the State and local governments tomeet the criteria in this document."

A reasonable man must conclude that the " key-stone" to the solution of

the problems surrounding adequate radiation protection for the public

in the LPZ and Emergency Planning Zones is adequate funding at the

local level of government for planning, administration, training,

tactical operations, equipment and maintenance for the LO years

anticipated life of the Callaw Ly Plant (ULNBC 326,19 October 1979,

an amendment to Union Electric Company's application of 30 April 1974).

Since utility opcration of a nuclear power plant is the basis for the

| need for such safeguards; it must follow that it is their responsibility

j to fund the entire administrative and operational phases of the safety

program. Such contention was supported by FEPA in their Renort to the

President (June 1980), State Radiological Emergency Planning and-

- 11 -.

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Preparedness in Support of Commercial Nuclear Power Plants and in t!UREG

0553 The inability of local governments to meet NRC cmergency response'

criteria is authority to prohibit reactor operation. (see 45 FR 55402,

exerpt quoted below:

" The Commission recognizes there is a possibility that theoperation of some reactors may be affected by this rule throughinaction of State and local governments or an inability to complywith these rules. The Commission beleives that the potentialrestriction of plant operation by State and local officials is notsignificantly different in kind or effect from the means alreadyavailable under existing law to prohibit reactor operation, - ."

End of Contentions and Discussion.

The foregoing information, stipulations, contentions and conclusions

are submitted for consideration to the Atomic Safety and Licensing

Board. Petitioner respectfully requests that the ASLB grant him leave

to intervene as a matter of right; such intervention should not unduly

delay the conduct of these proceedings and will be conducive to the

ends of justice; or

IN 1EE ALTERNATIVE

permit the undersigned intervention as a matter of discretion (CLI-

76-27; or ALAB-292, 2 NRC 631, 655 (1975); or 441 F.2d 962, 976-77

(1969); or

IN THE ALTERNATIVE

permit the u. dersigned to participate in this matter under the

provisions of 10 CFR, Part 2, Section 2.715 (c). Petitioner is

the Director of the Callaway County Emergency Management Agency, a

leEally constituted agency of the government of Callaway Coanty,

Missouri (see Attachment 5).

. . _ ..__ _ _ _ _

. _ _ _ _ _ _ _ _ _ _

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Rea.cetfully submitted,

A-'Dated at Kingdom City, JOHN G. REED

Piscouri this 2.2."k Citizen of the United Statesdry at OeMw of America1980. RFD dl

Kingdom City, MO. 65262

-

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--

(,.ttach::iint 1-a).

.

U:!IT1.!) STiiib i n:'hhICn'

tiUC1.hnit I1GUlan. ; ; C0!7'l!'31Ch'

fihFORh 'Jiii, AT0!' C SAFETY A::D LICFJ|SII;G BDahDJ

In the Patter of ))

UI;IO!! ELECTP,1C CO: PANI ) Docket : sos. 3'O 50-483) S'I?: 50-486

(Cal]away Plant, Units 1 and 2) )

AFFIDAVIT

The undersigned, being duly sworn, says that the County /EXINXofs

Callnway 133::ouri is located within a radius of ten,

r.iles fro:u the Callaway Plant ownca by Union Electric Company nnd

that no funding or assistance has been received from this private

utility for planning purpoces or acquisition of equipment and other

related rr.aterials required to satisfy the requirements of !;UI LG C65L/

FEl%-REP-1.~

/And further affiant saith not. ,6

PAUL PURPHY

,

Presiding Judge / IX$XXX.

. Sw rry to before r,c/yiT/ rjjbsgribed in my presence thism

,' _ day of{ M/qf'u v, 1980.! /- -

, f3! ! /

JQ c'

(aunt). ignatute Gi~;nia u / g;,;< y

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(Attachtunt 1-b) |.

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3 ;lT M S'r.'..t,D t. ,d'hillC A

IlUCLbdt REGUleTO.tY CGIO'IESIC-N

I!EF0!I.E ' hie ATOMIC SAFbTY A!;U I.ICiliS!!!G ID,d:D

ln the Matter of ))

U!!IO:; ELECTi!1C CO 'PnNY ) Docket : ns. Sil; 50-l.83

) S'iti 50-486(Callaway Plant, Unita 1 and 2) )

AFFIDAVIT

'I'ne undersigned, being duly sworn, says that the Qu/,;ity ofe

pin ,nn Missouri is located within a radius of ten,

. miles frem the Callaway Plant owned by Union Electric Cocpany and

that no funding or assistance has been received fro.m this ;)rivate2

utility for planning purposes or acquisition of equipment and other

related materials required to satisfy the requirecents of NUi1G 0654/

FEl%-REP-1. ~s

f;'\

'

/.

i * i'~And further affiant saith not. '

Q . .' '( J \' A.0 A -( -( O1_ E 2r,i i. re;' RETCH

w / Mnyor' '

| Sworn to before cc and subscribed in rcr presence thisi 9 zt day of rf.*.i' , 1980.

|i

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(SEAL) 6 v. < A / .r f .,.

E. Cir,nathre of.;f otary/ o::nty Chrk* .p---

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stmp d e m-9 6 4. -A= si * * '"#~ "'

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(Attachment.1-c)<.

.

U: lit 3.D STATE:, i' . I'}.h 1C,,

MUCLhAR h:liULN!c:U COB:1331L::

.

!!hFORE 'DiF, AT0!!IC SAFETY aND LICENSI?:G ihhi>

In the Patter of ))

UNION M,hCTRIC CU:.P,JJ ) Docket Nos. S'Ifi 50-!,83) S'i?J 50-1.86

(Callaway Plant, Units 1 and 2) ) '

AFFIDAVIT ~

The undersigned, being duly sworn, says that the County /h::p of.~

l'ontgomery , Kiscouri is located within a radius of ten

miles from the Callaway Plant owned by Unicn Electric Company and

that no funding or accistance has been received from this private

utility for plar.ning purposes or acquisit, ion of equipment and ot.her

related materials required to satisfy the requirements of NUILG 0654/

FEl%-REP-1.

And further affiar.t saith not. f3 of'Dsn'U4h-FitF.D =LUNKi r

'gn.,<a'r

; ihrsue Presiding Judge / %.

Sworn to before me and ti:bscribed in my presence this20' day of c0 r /e-hu , 1960.~

!

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(SEAL) ,dJ' ./l Auf . OeM 40Signature of N'tary/ County Clerk

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(Attachncnt 1-d).

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U :1ThD STAlt: i. n:9,I:ICA

!iUCLEAR iiEGULATO:1? Ce 0:1.93ICR

.

w

!!h? ORE TiiF ATOIUC SAFETY ::.ND LichNSIt:G EOahD

In the 1htter of ))

U?!ICli ELECTitIC Col?ANY ) Docket Nos. ST!! 50-!.83) STii 50-486

(Callt.way Plant, Unita 1 and 2) )

AFFIDAVIT

Tne undersigned, being duly sworn, says that the County % of,

Osage , Eiscouri is located within a radius of ten

miles from the Callaway Plant mned by Union Electric Corrpany and

that no funding or assistance has been received from. this private

utility for planning purposes or acquisition of equipn.ent and other

relsted rr.aterials required to satisfy the requiretents of NUFEG 0654/

FE!%-TEP-1.

'

And further affiant saith not. ,j .g . , f < q,u,_

4 e r ne r['TO:3Y'REllAGi!!'

Presiding Judge / -_

Sworn to before me and >upscribed in y presence this,J/#U day of M .sj , 1980.

(SEAL) e ga/D- o.g'

Sig ture of Tiotarg/Gour ifrk

-

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(At, tac bent 1-c).

.

U:!IlhD STATES t - !ShlCnNUCLE /d! REGULxTC:ii CCD:ITSIO:

.

EEFORE Tlih AT0!:IC SAFhTY AND LIChNSl?:G B0idtD

In the Matter of ))

UNICf! ELECTPIC COI?ANY ) Docket Nos. STN 50-493) SW 50-486

(Callaway Plant, Units 1 and 2) )

AFFIDAVIT

The undersigned, being duly sworn, says that the %/ City of.-

Ch nmM n F.iscouri is located within a radius of ten,

miles from the Callaway Plant owned by Union Electric Co:r.pany and

that no funding or assistance has been received from this private

utility for planning purposes or acquisition of equipment and other

related materials required to satisfy the requirer.cnts of NU:~LG 0654/

FE!'.A-REP-1. {}

VI-

ru]mc[] 'U;'jAnd further affiant saith not.

HGdARD STFFFE3 /, --

L - W / Mayor'

Sworn to before me and -ubycribed in my presence this2 /af ~. day of /f e Ai >140 , 1980.

-

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(SEnL) !Mf(,|Nf b tt(1Phig7F(. '

Si .nat.urp' of *Nythry/)Cdyi ist::ty C1erk

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,

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:

.- - . . . . . _ . - - . . - . .- -- _.-.- -. . . - - . - . _ , .

.

(Attachnent 1-f),

.

U:!J'i hD STA':h. , ' . 6 4. I C,,i

!!UCliidt ilhGUIATUid C0! Ell:31G

fihFOPS "SS ATui:IC SAFhTY id:D LICENSR'G Baahl)

In the I?.tter of ))

UNIGN C,CTi!IC COMPANY ) Docket Nos. SIN 50-483) SW 50-L86

(Callaway Plant, Unita 1 and 2) )

AFFIDAVIT

The undersigned, being duly sworn, says that the County / % of,

! Gasconade , I?issouri in locat cd within a radius of ten

miles from the Callaway Plant owned by Union Electric Cortpary and

that no funding or assistance has been received from this private

utility for planning purposen or acquisition of equipna.nt and other

related rr.aterials required to satisfy the requirerent,s of MUI EG 0654/

FEP.A-pip-1.

, And further affiant saith not. yY~/ Hit bl. ' ci$Martw

PAROI D IrfrTim!'/Presiding Judge / ~

Sworn g before tr.e and subscribed .in gr presence thisAb - day of M M , 1980.'

,,_

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(SEAL) hSignature of ?%/ County Clerk

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( Attach; tent 1-g)

U:ll'i LD STh'Ih:3 r . n!'hF.lCn"UCliidt RhCUlasTU : COD'l ."S ICN

>

EhFGPS 1EE ATO!!IC SAFETY id:D LIC113IEG BolihD

In the Matter of ))

UNICN ELEC1EIC CCIh NY ) Docket Nos. S1N 50-1.83) STN 50-486

(Callaway Plant, Units 1 and 2) )

AFFIDAVIT

Tne undersigned, being duly sworn, says that the M j/ City of,

l'orri son , Missouri is located within a radius of ten

miles from the Callaway Plant owned by Unicn Electric Company and

that no funding or assistance has been received frot this private

utility for planning purposes or acquisition of equipmcnt and other

related materials required to satisfy the requirements of MUELG 0654/

Fil'A-F1P-1.

And further affiant saith not.Y

Rnn RTnv X sDu o? JE ,

/ Mayo:M'

x

Sworn to before me and *ubscribed in my presence this.3/ day of Ot 3 M_ _ L , 1980.

.

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[C-[~~_, - (CEl.L) __/ o- ct. _ > (, O h JL 4i ,

_ Signature of Notary /Gounty Clerki[ [ - _ (T i 4

,

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*d.as 'g

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(Attachment 1-h).

. '

UNITED STATES 0:< A!' MICA!iUCLhAlt P1GULaTCitY CO!7.1SSION

, .

,

.

EhEGRE TiiE ATOMIC SAFETY AND LICENSING BOAhD

In the Patter of ))

UNION ELECTRIC CCEPANY ) Docket Nos. STil 50-4831) Sm 50-486(Callaway Plant, Units 1 and 2) )

l-AFFIDAVIT ~ "

The undersigned, being duly sworn, says that the w w/ City of,-

Mokane ,, Missouri is located within a radius of ten

miles from the Callaway Plant owned by Union Electric Company and.

that no funding or assistance has been received from thic privatei

utility for planning purposes or acquisition of equipment and other

related materials required to satisfy the requirements of NUliG 0654/

FE!'.A-PIP-1.

And further affiant saith not,f'' ,

CLARDJCE LAUGHLIN__

. / Mayor' ',

m

Sworn to before me ard sub g ibed in my presence thisgeR 1 _ dar of (r) c-r . , 1980.

.

.

3(j, 'f b;" ' +'"f Nf "'t 2'""f/ County ClerY+ -

g,

,

r.s

"

,

.

m--w ms mn e m no *" "

. - -

t (Attachment 2-a)

|

I.

UNIThD STATLS ( F n!'hRICAfiUCLEAR REGULATURY col'. MISSION

.

BEFCliE Tl!E ATOMIC SAFETY AfJD LICENSING BOARD,

,

In the Matter of ))

UNION ELECTRIC COMPANY ) Docket Nos. S'lii 50-4C3) SIN 50-486

(Callaway Plant, Units 1 and 2) )

AFFIDAVIT

The undersigned, being duly sworn, says that the County 6 of

Callaway , Missouri is located within a radius of ten

. miles from the Callaway Plant owned by Union Electric Company and

that emer6ency planning required by IJUEEG 0654/Fblk-REP-1 by this

local governn.cnt has not begun, ner has authority to corar.cnce such

planning been delegated to any agency of State government.

And further affiant saith not. Q MPAUL !11RPHY

Presiding Judge /

Sworn to before rr.c and et ocribed in my presence this

day of M e3 2 , 1980.i /

,..

//. .

. 7 ''

.. - -

5; h ' ' b <<c L (0 C,{s 7g

a1

. _ _ _ . . _ _._. . _.

i

(Attacim.cnt 2-b).

.

U:;ITED Sles'1ES UF es:'s,li!CA i

NUCLEAli F1GULATORY C0!'.MISSIO::

DEFCRE Tl!E ATO 'IC SAFETY AND LICE? SI;;G HOARD

In the Mattec of ))

UNION ELECTRIC CO:.A!;Y ) Docket !!os. STf; 50-l.83) S'hi 50-486

(Callaway P1mit, Units 1 and 2) )

AFFIDAVIT<

'Tne undersigned, being duly cworn, says that the jiggq(y/ City of'

,

Fult c'n , ;liscouri is located within a radius of ten

miles from the Callaway Plant owned by Union Electrle Co:r.pany and

that emergency planning required by NUF1G 0654/FsFn-HEP-1 by this

local government has not begun, nor has authority to cor.:ence such

planning been delegated to any agency of State goverr. ment.-

s.Qhhi s., C 'x'! k d k A 94 -iAnd further affiant saith not, t --

<w.

dET"0E L _ 02''O!EIC!!I2CCCiDiffli)3k? / Payor

Sworn to before rc.c r'd subscribed in my presence this

/R day of [t , 1980.

.

'.

~f -

(Si:AL) Z - I.. /[,/s,

P.ipditure of' I?otary/Ceunty Clerk,

1, a f,e.

'a\

't |.

y . .h*M*

(attachment 2-c)-,

,

UNITED STATES OF AERICANUCLEAR REGULATORY CODIISSIGil

'~ '..

.4BEFORE TiiE AT0l'IC SAFETY Af:D LICEI; SING DonRD

,

In the Matter of ))

UNION ELECTRIC C0!'PA!!Y ) Docket Nos. STN 50-483) STN 50-486

(Callaway Plant, Units 1 and 2) )

.

AFFIDAVIT

The undersigned, being duly sworn, says that he/ain is the Presiding

Judge /Egypr of the County /CEy of Montgom rv , Missouri and that

said governmental jurisdiction is located within a radius of ten (10)

r:iles from the Callaway Plant. Further, that said government lacks

sufficient revenue base to support, an added burden of planning and

operations necessary to meet NRC criteria established in NUREG 0654

FEMA-REP-1 and 10 CFR, Part. 50 and Appendix "E", theret.o. Emergency

planning has not begun at this level of govern =cnt, nor has aut.hority

been delegated to any agency of State government to act in our behalf

( in this matter.|

| And further affiant, saith not. gg; y,jy 7,

Ujnt2sj if .kJ a <.cdFRED:LUEKkY

W-:mro Presiding Judge / nh

Sworn to before n.c and subscribed in ry presence this

7J o f- day of /C c [--4h ,1980/' '

3 ',- .

%'

N. % ~

~ (SEAL) M W f (c t d . A rc't t e l(:I..:j,

+

,

3 -'. 3 County Clerk /*% tary'7 .,

"-t ., c. .*

. o',,

a

(Attachment 2-d)

.

UNITED STnTES ei- MERICA#

1 UCUak RFTUUsTORY C0FMISSICH

,, q'

BEFORE THE ATGICC SAFICY A!;D LICENSII;G B0nRD

In the Matter of ))

> UllION ELECTRIC CO:PldlY ) Docket I!os. STI' 50-483'

) STN 50-486.

(Callaway Plant, Units 1 and 2) ).

. ' 4; AFFIDAVIT

- , -,

| The undersigned, being duly sworn, says that he/she is the Presidings., ,

Judge /KTvrm of the County / Gift of Osane , Missouri and that' said governmental jurisdiction is located within a radius of ten (10)

miles from the Callaway Plant. Further, that said t;overnment lacks

sufficient revenue base to support an added burden of planning and

operations necessary to meet PRC criteria established in NUREG 0654

FEMi-REP-1 and 10 CFR, Part 50 cnd Appendix "E", thereto. Emergency

planning has not begun at this level of government, nor has authority

been delegated to any agency of state government to act in our behalf

in this matter.

And further affiant saith not.

'n a r n"J ' ONY'REHAGEN l<

~~

Presiding Judge / EEyIIr

Sworn to before me and subscribed in r/ presence this

__ $O ay af Sl'h(.s1980/.

,-m

, c. ?> i, '. ,g; , s i <;

'',

e' ;(stat) ' naw A /% a-

--f ,-

' ~

y .CoYty Clerk / fota+f-

'

,

e,. ',L' y ,

, t*i

_

- . .- - -.- . - . _- - --

'(Attachment 2-e)

.

i

,

.. ,

UNITED STATES L+' A!' ERICA.

NUCLEAR REGULATORY CODilSSIONya

|*

, .

.v .jY/d .BEFORE THE AT01EC SAFATY AND LICENSING DoaRD

, .m

#bk 'In'the Matter of- ),

! )UNION ELEtTRIC PC.TPANY ) Docket Nos. STN 50-483

'

L t )' Snl 50-486 +

I '" (Callaway Plant, Units 1 and 2) ):

- m,

AFFIDAVITi f

s

- - The undersigned, being duly sworn, says that he/she is the l'---- = g

!.,+

dk2p/Payor of the ^%/ City of hamois , Missouri and thatC

said governmental jurisdiction is located within a radius of ten (10),

; ./-.miles from the Callaway Plant. Further, that said government lacks

'-

!'i_i sufficient revenue base to support an added burden of planning and

'

1; operations necessary to meet NRC criteria established in NUREG 0654'

:

1 FEMA-REP-1 and 10 CFR, Part 50 and Appendix "E", thereto. Emerdency

. planning has not begun at this level of government, nor has authorityi,,

i been delegated to any agency of State government to act in our behalf

in this matter.|

' And'further affiant saith not. Oj 'D 7' 4"~[d/EB ,

T/

; 7c., F N Gn "?FFFFM '

,_J. . F =1u= J= = / Mayor ' ',y 4

4

j. L. . .. '' ~-*

, Sworn'to before .pe and subscribed in ray presence thisse.

C h f day of A?h/A [/o ,1980/'

2 n .

. i *!.

-

.-

.;,z , e 8 ~.1 ,

Q||(SEAL)e..; )pgk/ 0,7/,pfsfjt '~.

/;

T .P.s;. .... ,o. County Qferk /4 ct.rfN '

<

,

m., o g,./)' .- .

.

|

[

|'

.

> e

Y egge +We M- M4 -@* 'Y ""

" Y

_, . ._ _ _ _ . . _ ._ . _ _

(At.tacht:.cnt, 2-f)zj

:.

UNITED STnTES LY AP3RICA,.

NUCLEAR REGULATORY C0FJilSSION

4

. &a4

! ,,; ; j ..

13.:: BEFORE THE ATOMIC SAFETY /d:D LICENSING DGARD, , ' ,

In the Matter of )'

'

)UNION ELECTRIC COMPANY ) Docket Nos. STN 50 ' ';.

) STN 50 .m6(Callaway Plant, Unita 1 and 2) )

-

AFFIDAVIT!

I r

The undersigned, being duly sworn, says that he/she is the Presiding- ,

Judge /Mssaar of the County /G1$y of cayennnae lussouri and that,

said governmental jurisdiction is located within a radius of ten (10) t

miles from the Callaway Plant. Further, that said government lacks

sufficient revenue base to support an added burden of planning and,!

operations necessary to meet NRC criteria established in NUREG 0654

FE.% REP-1 and 10 CFR, Part 50 and Appendix "E", thereto. Emergencya-

planning has not begun at this level of govern:r.cnt, nur has authority;

been delegated to any agency of Stato government to act in our behalf

in this matter. *

And further affiant saith not. -

tt&hMet4 tu aMAROT.D TRLTL'A}{}L

Presiding Judge /h,.

Sworn to before me and subscribed in try presence thia*

,.-a

Md - ' day of b 1 M , 1980/ -

_,, s

i..

*

5,.1 : ;,.1 : W/ ,o,"

2 y

I ,- ;;(SEAL) M,

4 E ' ,if .J

..' County Clerk / JMaury

'

[. Jj , fj , ,.g / . *.

--

5

.

, ---s1 -, - .m. . , 2-,. r, _ v*- -c.. , .e- .c % p. - , _.-.-2 ,y . , r

*,,-

-

( At.tachr.cnt . -g).

!l

.

UNITED STATES C. A!:r.RIGA!!UCLEAR RNiULATCF.Y COFallSSIOil

.

REFORE TiiS ATOMId SAFhTY A :D LIChh'SII;G B0allD

'

In the P.atter of ))

UNION ELECTRIC COMPANY ) Docket Nos. STN 50-483) S"JJ 50-486

(Callaway Plant, Units 1 and 2) )

AFFIDAVIT

The undersigned, being duly sworn, says that he/she is the P -,e " . . ,~~

A W /Maror of t'ae Gu+y/ City of yn ,.,.u nn , Missouri and that_

said governmental jurisdiction is located within a radius of ten (10)

miles from the Callaway Plant. Further, that said government lacks

sufficient revenue base to support an added burden of planning and

operations necessary to meet NRC criteria established in NUREG 0654

FEMA-REP-1 and 10 CFR, Part 50 and Appendix "E", thereto. Emergency

planning has nat begun at this lwel of government, nor has authority

been delegated to any agency of State governtxnt. to act in our behalf

in this matter.

And further affiant saith not.,

RAV RTRY A!'f|]n- Le rQB e m k i;u g 4 # | Vayor f

~

Sworn to before r.c and subscribed in nur presence this

2_ / dayofbc1>db,' ,1930/--

, ..

' '/ . S @) _ t$ e O. tf r 1.- U-

6 :/ ~ "..' .. - Gountry-Clerk / Notaryu ,. g..-

,

- d '- E i*

t[/'

: .

', /;;.- ._,,.A". .,

e ,-,g.... ..

+.,;,; . : n. . -

. . ,

.ew-, *-% = = . . - - - , - . , e--.- ~% , . - ---- . .--

( Attachtent 2-h)

.

UNITED STATES Ci' A! ERICANUCLEAR REGULATORY C0!G11SSION

.

'

BEFORE THE ATOICC SAFETY A!!D LICENSING B0aRD4

In the Matter of .)' )

UNION ELECTRIC COM'ANY ) Docket Nos. STN 50-483) SUJ 50-486

(Callaway Plant, Units 1 and 2) ),

* gQ AFFIDAVIT "

.

The undersigned, being duly sworn, says that he/she is the A he

39/ Mayor of the e- 9 / City of Mokane , Missouri and that

said governmental jurisdiction is located within a radius of ten (10)

j! miles from the Callaway Plant. Further, that said government lacks-,

^' sufficient revenue base to support an added burden of planning and

operationo necessary to meet NRC criteria established in NUREG 0654

FEMA-REP-1 and 10 CFR, Part 50 and Appendix "E", thereto. Emergency

planning has not begun at this level of government, nor has authority,

been delegated to any agency of State governraent to act in our behalf

in this matter.

And further affiant saith not. gCLARENCE LAUGd' L,IN

2*===*= vin *m / Payor

Sworn to before me and subscribed in ry presence this

M 1 d r of ,1930/;t$ ,,

4 (SEAL)- M. .# County Cle'rk / ''^'-f-

-

,

: aun a.-~/g ~ .

* -y,

n __ . _ - n..- - - _ . . .. .. . - - . _ _ . - - - - . . - ...

. &.m . ~ : .n:. . ..- .:a . . n - -.~.a uz;a. .. .- .

(Attachment 3)Page 1 of 2 pages

..:: ...,:;:...

y w .s* .t 45 \

Joacph P. Teasdale U,$, f L!y,i j Adsutant 6*n+r41 of W ouri) thneson of Hghway SafetyCorerflor* E-

I Y Q) )*8?/.

gg4 thvigion of taqunr Cetrol

y, M Wilson Ihmum of Water Safety

Director STATl; OF MISSOUlt! m oun coanut aa cumia u='tice

' ' " " " " ' ' ' ' " ' * " " ' ' " 'DEPARTMENT OF PUBLIC SAFETYItobert E. Itucchler State Fire Marshal

The Adjutant General OFFICE OF TiiE ADJUTANT GENEliA1,

DISASTEli PLANNING & GPEliATIONSGeorge M. Atch son, Director1717 Induatrial - P. O, llox 116

Jefferson City. Minuouri 65102

June 2, 1980

Mr. Francis X. TobinRegional Director

',

Federal Emergency !!anagement AgencyRegion VII911 Walnut Street, Room 4 3

| Kansas City, Missouri 64106

I

| Dear Mr. Tobin:

Following is our reply to liarold Pickering's memo dated May 22, 1980,subject: Radiological Emergency Preparedness Plans.

Regarding questions la & b, Missouri does not now have within itsborders an operating cormnercial power reactor nor will we have withinthe 12/31/81 date. The first power plant is scheduled to go on linein October 1982. Ilowever, our of fice timetable for radiological

emergency preparedness is to have an Interim !;uclear Accident Planccmpleted by August 1981.

Regarding questions Ic & d, there is a commercial power reactor ina contiguous state; Cooper Nucicar Station at Brownville, Nebraska.Again, our office timetabic calls for Missouri's INAP, with theappropriate county plan, to be completed by August 1981.

Regarding question 2, which addresses costs of developing and maintainingstate and local plans, including exercises, we estimate the following:

State Plan (includes 45 man-days state staf f for local Cooper plan);

Development 273 man-days 0 $100 $27,500

Maintenance 105 man-days 0 $100 $10,500

Local Plan (Cooper);

Development 30 man-days 0 S75 $ 2,250

Maintenance 50 man-days 0 $75 S 3,750

Ax50

,

(Attachr..ent 3)Page 2 of 2 pages-

.

Mr. Francis X. TobinJune 2, 1980

{ Page'2

|.

ILocal Plan (Callaway);,

3 Development:! State Staff 150 man-days 0 $100 $15,000

Local 200 man-days @ S 75 $15,000.

Maintenance:State Staff 90 man-days @ $100 $ 9,000

Local 75 man-days @ $ 75 $ 5,625

',.

TOTAL $88,625,

. ,,

t' -' These figures are conservative in that they primarily reflect salaries

| of persons involved and only partial per diem expenses during exercises.T;tal costs, which we are unable to estimate at this time, should include'

actual food, lodging and travel expenses of all persons involved in anexercise; secretarial costs; printing and xeroxing expense; telephone

; calls, etc., for each agency involved. This could easily add to theabove total approximately $100,000 for initial purchases, and $5,000to $10,000 for annual maintenance and exercises.

Regarding question 3, neither state nor local governments have receivedany funding f rom private utilities for planning purposes or acquisitionof equipment and other related materials required to satisfy therequirements as set out in NUREG 0654 /FDIA-REP-1.

Sin <.e r e l y ,

s

W f// w tkw-

George M. AtchisonDirector

GMA:nd

Ax51

Qfi7 i.EniELMssdJMJEMiJ?4 ;*J * N TJCd'<3i W'U5f6fiii h i/AM M OYU0ie M N i T 5 M.Fia5

- .. - .. .. . . - . - -

4 - ( At.t.acht:.ent 4)-

1 Page 1 of 2 pagesC,.,,

|6(

1-

i?O U:!ITLD STATiS M AMi.P.1 CA

l' NU.r NUCLEAll REGu1EICid COMMISSIONen, q ?; ~ ~

q Q. .;c . ::1 c

. . . yr

$ I( fdb- W .. BZF0!lE 'IllE ATOMC SAFETY At:D LICE!! SING BCA.9D

; $7 In the Matter of ). .u q 4 )

< Mk[U LION ELEC*1RIC C0FPANY ) Docket nos STN 50-493

j [b ||' } STN 50-l.86J7 (Callaway Plant, Units 1 and 2) )1

p:,.~:',

-

'

AFFIDAVIT-

; , .

ywt

The undersigned, being duly sworn, says that having read the provisions3 ,,

'mf ;,

j, of Union Electric Company Standardized Nuclear Unit Power Plant System

i- (SNUPPS) Final Safety Analysis Report (FSAR), Volume 5, Appendix 13.3A.v: .p- . Specific attention being directed to "Coonlination with Participating

,

h

i Governmental Agencies (13 3A.5.4); he found that responsibility for all/(-

operational assistance and authority for local public safeguards for "off-

. [' site" locations was vested ic the Missouri Department of "ublic Safety;

Disaster Planning and Operations Office (DP00). The only local support-v.

A is identified as the Callaway Sheriff's Office (SNUPPS-C, page 13 3A-26),;Y+

.

j - ,the ,Callaway County Ambulance Service and the Callaway County Memorialy

* 26 7 Hospital (SNUPPS-C, page 13.3A-24).. Two other assisting organizations -' i.EL ,'

. p.rg,7, are: the U.S. Coast Guard, St. Louis, M0.'(SNUPPS-C, page 13.3A-26) and4 b; r, .-t

WT an agency that has no legal authority to operate in the ca eas impacted by'

;-

; ,._ ,

i Tr the 10 mile c.PZ: the Civil Defense Office, Columbia, (Boone County) MO.! |D.. %,,

'S.. .(SNUPPS-C,'page 13 3A-27). Additionally, having read the Missouri StatoMW,:$yftf Emergency Operations Plan, Part 3,- Section B, " Nuclear Emergency Assistancegy

2 $' h;'[i Plan", prepared by the D'epartment of Public Safety, D.P.O.0., dated 2; May, y.o q

t .

e2i r?fQ_L

bh ;Qi T. .e

_ .. - - - *- o nwa, ,- +- q e q - -m, + + -- >,. E * W's+ ,,,.

T

.,

, . 1979 and sif;ned by Joseph P. Teacdale, Governor of the State of Missouri;

recalling with particular attention the provisions contained in the FSAR,

Volume 5, identified above, affiant found that State does not fulfill the.

responsibilities delineated in SNUPPS-C, 13 3A.5.4.1. State will act in

an advisory capacity only and assistance will not be provided unless local

authority requests such aid. Section II, of the State plan cited above

states that " Assistance provided shall not in any way usurp or circumvent

Federal or local authority, - - ." Since DP00 can not take the lead in

providing radiological protection as outlined in the FSAR, it in effect

repudiates the responsibilities designated as accepted by the DPCO inc

Appendix 13 3A, Volume 5, FSAR identified above. Reason would indicate

that with such a conflict, and/or repudiation; the provisions of the Union

Electric Company SNUPPS FSAR, Volume 5, can not meet the requirements of

45 FR 55402; Appendix E,10 CFR, Part 50. The above statements are true

and correct to the best of my information and belief.

And further affiant saith not. g

/ , -

/ DirectorCallaway CountyEmergency Fanagement. Agency

Swcrn to before me and subscribed in my presence this

cf/ h day'of M b 1980.,

Y, s y : v',r .~

, I| , ''

:+ .. c, s (s, s

.... ,

M M dYd M* - '*

, |? Ccunty Clepfc (/_g,

484/g! .g ,\ 's.,

,g - , ' . . . g,-,,*

X' I '

.,

K Q . @. $'

,1,T,.

,-

W M

. . _ . . ..- -- - =~

.~ ~ - - -

(Attachn.ent 5).

'

UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION

BEFORE THE A'IDIGC SAFETY AND LICENSING BOARD

In the Patter of ))

UNION ELECTRIC COMPANY ) Docket Nos STN 50-493) STN 50-486

(Callaway Plant, Units 1 and 2) )

AFFIDAVIT

The undersigned, being duly sworn, says that he is the Presidinge

Judge of Callaway County, Missouri and that Mr. John G. Reed is

the Director of the Callaway County Emergency Management Agency.

Further, that the Callaway County Emergency Fcnagement Agency is

a legally constituted agency of the government of Callaway County,

Missouri.

And further affiant saith not. '

Presidirig Judge,/Callrr Coun ,,

Sworn to before me and subscribed in ny presence this

da; he [vm ,1980./4 #<

/

..' mCounty Clerk //NotaryD I/'

Y) L s - *

'c U

%

4

. . . _ _ _ _ . . _ _ _ . . _ _ _ _ _ .

,

*

,.

|i.

..

UNITED STATES OF AMERICANUCLEAR REGULATORY CO}2:ISSION

.

BEFORE THE ATOPIC SAFETY AMD LICENSING B0/dtD.

. ;

In the Matter of ). )

UNION ELEC'IRIC COFPANY -) Docket Nos STN 50-483) STN 50-486

(Callaway Plant, Units 1 and 2) )

,

AFFIDAVIT

,,-

The undersigned, being duly sworn, says that the details contained

'in his " AMENDED PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR A

HEARING", signed the 2 2. " day of Octo ber , 1980 are true

and correct to his best knowledge and belief, and that all attached

documentation was justly and legally obtained.

And further affiant saith not.

Je-.

'itizen of the United Stal.c::,

of America

Sworn to before me-and subscribed in my presence this

M M '' ' day o Lf 2 &2 1980., ,

9| { , ' ' ,

, (SEAL) ( /M( 4~ a.

'h Notary / County Ipfk

Y d C* '

, ,

4/

. sgW '"' ww w i.e% sm -4

_ , _ .

..e

.

.

UNITED STATES OF AKcRICANUCLEAR REGULATORY COMMISSION

.

BEFORE 'IBE AT0FIC SAFETY AND LICENSING UOARD,

In the Matter of ))

UNION ELEC'IIllC COFPANY ) Docket Hos STN 50-483) STN 50-486

(Callaway Plant, Units 1 and 2) ).

CERTIFICATE OF SERVICE

'I hereby certify that copies of the foregoing " AMENDED PETITION FORLEAVE TO INTERVENE AND RMUEST FOR A HEARING" in the above-captionedproceeding have been served on the following by deposit in the United:

! States mail, first class postage prepaid this 2 3d day of October,j 1980:

James P. Gleason, Esq., Chairman Treva J. HearneAtomic Safety and Licensing Board Asst. Gen. Counsel513 Gilmoure Drive Missouri Public Service CommissionSilver Spring, MD. 20901 P.O. Box 360

Jefferson City, Mo. 65101Gerald Charnoff, Esq.Thomas A. Baxter, Esq. Barbara ShullShaw, Pittman, Potts & Trowbridge Lenore Loeb1800 M Street, N.W. League of Women Voters of M0.Washington, DC 20036 2138 Woodson Road

# 'Atomic Safety and Licensing

Board Panel. Marjorie Reillyi

U.S. Nuclear Regulatory Commission Energy Chairman-

Washington, D.C. 20555i

League of Women Voters of UniversityUniversity City, MO.Docketing and Service Section 7065 Pershing Avenue

'

Office of the Secretary University City, 10. 63130U.S. Nuclear Regulatory Commission,

Washington, DC 20555 Donald Bollinger, MemberMissourians for Safe Energy

i Roy P. Lessy, Jr. Esquire 6267 Dolmar BoulevardOffice of the Executive Legal Director University City, M0. 63130U.S. Nuclear Regulatory CommissionWashington, DC 20555

i

,

_ _ __

.

_ _ _ _

..

,

2 .-.,

't'

Atomic Safety and Licensing - Rose Levering, MemberAppeal Board Crawdad Alliance

U.S. Nuclear Regulatory Commission 7370a Dale Avenue,

Washington, DC 20555 St. Louis,.MD 63117

Dan I. Boler- Kay DreyPresident, Board of Directors 515 West Point AvenueCoalition for the Environment University City, 10. 63130

St. Louis Region-'6267 Delmar BoulevardUniversity City, NO 63130

.

j'# ' John G. Reed

Citizen of the United Statesof America

.

-s , n- + 4- , . m w n. - a