ML20101S892
| ML20101S892 | |
| 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 | |
| ML20101S871 | List: |
| References | |
| OL, NUDOCS 8502050697 | |
| Download: ML20101S892 (3) | |
Text
.I February 1, 1985
-.Q DCL?ETED UNITED STATES OF AMERICA L%FC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 85 F8 -5 A9 :48 LFfiCE 0 5ECRiiAh' GCCKETriG & SE9'uf f 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,
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Units 1.and 2)
)
APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE. HEARD ON CONTENTION M Pursuant to 10 C.F.R. 5 2.749(a), Applicants state, in support of their Motion for Summary Disposition of Contention M in this proceeding, that there is no genuine issue to be heard with respect to the following material facts:
1.
There is no regulatory requirement'that each jurisdiction with the plume exposure pathway emergency planning zone (EPZ) have its own independent radiation monitoring system or that such systems be fixed._ NUREG-0654, Criterion H.7; Affidavit of Ronald W. Smith on Contention M (" Smith Affidavit"), 1 3; Affidavit of Richard R. Bowers on Contention M (" Bowers Affidavit"), 11 2, 7.
.2.
The State of Ohio.has independent radiological assessment capability, including off-site radiological monitoring teams.. Smith Affidavit, 1 4.
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3.
-The State.has three fully-equipped off-site radiological teams capable of high, mid and low range gamma radiation readings, alpha and beta radiation detection, radioiodine and particulate air sampling.
Smith Affidavit, 11~-4, 7.
4..
The State has a radio communication system for the
.immediate and simultaneous data transmission from the field
'-teams'to the State and County Emergency Operation Centers and the Perry Emergency Operations Facility.
Smith Affidavit, E
11 4,.6.
5.
The State radiation monitoring teams are sufficient in number, equipment and communications capability to track a radiation plume independently of the Applicants' radiation monitoring teams.
Smith Affidavit, 1 8.
6.
The Department of Energy,-EPA and NRC have field radiation monitoring teams with comparable. capability.as the State's teams.
Smigh Affidavit, 1 9.
7.
A fixed radiation monitoring system would require approximately 103 locations to be sure that a radiation plume would be tracked.
Bowers Affidavit,1[ 2.
8.
The Federal Emergency Management Agency has studied and rejected the concept of a fixed monitoring system based on consideration of maintenance, repair and calibration.
Bowers Affidavit, 1 2.
9.
Mobile survey teams are more effective in evaluating accidential releases than are fixed monitoring locations.
Bowers Affidavit, if 3-5.
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-10.
Reliance on mobile survey teams isLconsistent with
-. e
- regulatory guidance.
Bowers Affidavit, 1 4.
11.
Both NRC and the State have fixed independent radiation monitoring systems in place in the plume exposure pathway EPZ.
Respectfully submitted, f
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- Salberg, P.C.
SH PI"TMAN, POTTS & TR BRIDGE 18 Sj;reet, N.W.
Wa ngton, D.C.
20036 (202) 822-1000 Counsel for Applicants DATED:-February 1,-1985 I
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