ML20101S892

Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention M

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: ML20101S869 ML20101S892 ML20101S904 ML20101S921
References
OL, NUDOCS 8502050697
Download: ML20101S892 (3)

Text

.I February 1, 1985

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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 ) sAh;g

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THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING. COMPANY ) 50-441

)

(Perry Nuclear Power Plant, )

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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I -. e -10. Reliance on mobile survey teams isLconsistent with

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

J Y *

(./

Ja 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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