ML20101S915
| ML20101S915 | |
| 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 | |
| ML20101S903 | List: |
| References | |
| OL, NUDOCS 8502050710 | |
| Download: ML20101S915 (2) | |
Text
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1 February 1, 1985
- [0, CCD:F7ED UNITED STATES OF AMERICA U bi.C NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING $dARSE -5 AO :51 (TfjCE C.: SEc,::g7;j y tv A iv;G L SEe w !
In the Matter of
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ca A.GH
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THE CLEVELAND ELECTRIC
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Docket Nos. 50-440 ILLUMINATING COMPANY
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50-441 1
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(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 C 1-Pursuant to 10 C.F.R. S 2.749(a), Applicants state, in support of their Motion For Summary Disposition of Contention C, that there is no genuine issue to be heard'with respect to the following material facts:
1.
The cited provisions of the radiological emergency response plans clearly and consistently define the role of the County Commissioners as including overall responsibility for local emergency operations.
Baer Affidavit, 13.
2.
Although the emergency organizations among the three counties may differ, the responsibilities and roles of the County Commissioners in the three counties are parallel, as es-tablished by the emergency plans.
Baer Affidavit, 13.
4 3.-
The County Commissioners in each of the three counties are charged with direction and control of local 8502050710 850201
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Q emergency operations; receiving recommendations from the Perry plant, the State, and other sources; making protective action decisions for the public within their respective counties; ap-proving activation of the public alert / notification system within their respective counties; and coordinating with appro-pripte state agencies to authorize relaxation of protective
' measures.
Baer Affidavit, 14.
4.
The State of Ohio, under Ohio law, vests the County Commissioners with the authority and responsibility to act as the officials in charge of emergency response.
The plans es-tablish the legal authority of the County Commissioners to take-J the actions under the plan.
Baer Affidavit, 115, 6.
Respectfully submitted,
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Jay /Ef Silberg, P.C.
,f SHAW,f P TMAN, POTTS &'TljoWBRIDGE 1800'M treet, N.W.
Washing on, D.C.
20036 (202) 822-1000 Counsel for Applicants Dated:
February 1, 1985 y
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