ML20101S877
| ML20101S877 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/01/1985 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20101S865 | List: |
| References | |
| OL, NUDOCS 8502050690 | |
| Download: ML20101S877 (4) | |
Text
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' February Igg U% C UNITED STATES OF AMERICA
'53 R9 ~5 A9 :50 NUCLEAR' REGULATORY COMMISSION BEFORE-THE ATOMIC SAFETY AND LICENSING BOARD _,,_____CRFn:'
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.d.. "i ? y; In'the_ Matter of
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THE CLEVELAND ELECTRIC
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Docket Nos. 50-440
-ILLUMINATING COMPANY
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50-441
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(Perry Nuclear Power. Plant,
)
Units 1 and 2)
)
APPLICANTS' STATEMENT O MATERIAL FACTS AS TO WHICH THERE IS No GENUINE ISSUE TO BE HEARD ON CONTENTION A Pursuant to.lO C.F.R.
5 2.749(a), Applicants state, in support of their Motion For Summary Disposition of Contention A,
that there is no genuine issue to be heard with respect to the following material facts:
1.
The evacuation. time estimate study ("ETE") for the Perry plume exposure pathway Emergency Planning Zone ("EPZ")
was prepared by HMM Associates, Inc.
McCandless Affidavit, V 1.
2.
HMM Associates has prepared more than 20 evacuation
. time estimate analyses in connection with emergency planning for nuclear. power plants.
Most of the analyses already have been found acceptable by the NRC; the' remaining analyses are currently'under review.
McCandless Affidavit, 1 1.
8502050690 850201 PDR ADOCK 05000440 0
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3.
.The Perry ETE was developed ucilizing a
~
state-of-the-art computer simulation that has been used at nu-clear sites throughout-the country,:and that has been previous-
- ly-approved by the NRC.
McCandless Affidavit, 12.
4.
Offsite emergency planning / response officials have
. played an important role in the development of the ETE -- far beyond a mere " review" of-the ETE.
McCandless Affidavit, 13.
-5.
The ETE itself reflects that county emergency pre-paredness officials'(officials-of.the Lake, Ashtabula and Geauga County' Disaster Services Agencies and the county Sher-iffs' Departments) participated in,;e.g.,
the determination of L
preparation and mobilization times and vehicle occupancy rates.
McCandless Affidavit, V 3.
6.
Before beginning work'on.the Perry.ETE (in early October 1983), HMM personnel. met individually with.representa-t tives of each of the three counties (including the three DSA f
Directors).
The meetings covered the basic ETE methodology, and.the general input data and assumptions for the computer l
simulation model for the ETE, as well as the model_ output and the time / weather condition scenarios'to be modeled..All meet-ing participants were in agreement with the information prese'nted.
McCandless Affidavit, 5.4.
.7.
In'mid-October, HMM personnel.again. met with the of-ficials.(including the DSA Directors) of the three counties, to
. review.the area-specific-data and' assumptions for use in'the,,
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JP ETE. ' All those in attendance at the meetings concurred in the results to date, as well as the proposed plans and procedures
'for continued work on the ETE.
McCandless Affidavit, 5 5.
8.
Copies of the March 1984 draft of the ETE were pro-vided to the-DSA Directors of each of the three counties, and to'the Ohio Disaster Services Agency.
The agencies' comments will be reflected in the next revision of the ETE.
The com-ments will.be submitted to the NRC with the next revision of the ETE.
McCandless Affidavit,.1 6.
9.
HMM considered two adverse weather scenarios in the preparation of the ETE.
HMM considered capacity and travel speed reductions of 20% (to represent sudden summer thunder-storm conditions) as well-as capacity and travel speed reduc-z I
tions of 30% (to represent winter snowstorm conditions).
McCandless Affidavit, 1 7.
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'10.
The adverse weather scenario assumptions for the
-Perry ETE:were selected based upon discussions with local offi-cials (including the three County DSA Directors).
These as-sumptions are' consistent with those used in NRC-approved analy-
~ ses conducted by HMM for other sites with comparable
~
meteorology.
McCandless Affidavit, 1 8.
Respectfully submitted,-
(L.
/
Jay'f,PISi berg, 7.C.
g-SHAH MAN, POTTS & TROE RIDGE 180C M S reet, N.W.
Washington, D.C. 20036 (202) 822-1000 counsel for Applicants Dated:
February 1, 1985.