ML20101T057

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

ML20101T057
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
ML20101T051	List: ML20101T049 ML20101T057 ML20101T080
References
OL, NUDOCS 8502050789
Download: ML20101T057 (3)

Text

I' t

February 1, 1985

((

UNITED STATES OF AMERICA 15 FE9 -5 NUCLEAR REGULATORY COMMISSION AO Id7 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD CFf}ree-Sj{pW-C0c{n;yg V.TJ BaAggg In the Matter of. )

)

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 U Pursuant to 10 C.F.R. S 2.749(a), Applicants state, in support of their Motion for Summary Disposition of Contention U in this proceeding, that there is no genuine issue to be heard with respect to the following material facts:

1. The emergency plans and procedures of Lake, Ashtabula and Geauga Counties provide for monitoring, decontamination, and isolation of vehicles and property at reception centers.

Affidavit of John Baer on Contention U ("Daer Affidavit"), 1 3.

2. The three counties have established standard action levels for decontamination of property and vehicles. Baer Affidavit, 1 3.

3. County emergency procedures provide directions for monitoring and decontamination of vehicles, and provide for 8502050789 850201 "

PDR ADOCK O M 440 0 PDR

'k impounding vehicles that cannot be-decontaminated. Baer Affidavit, 1 4.

4.- Personal property found to be contaminated will be sealed in plastic bags for disposal by licensed commercial radioactive waste disposal firms. Baer Affidavit, 1 4.

5. Fire department personnel, who are responsible for handling contaminated property at reception centers, will have been trained for handling contaminated property and vehicles at reception centers. Baer Affidavit, 11 4, 5.

6. Prior to fuel load, about 630 fire department

~

personnel will have been trained on contamination procedures.

This is more than enough to conduct monitoring and decontamination activities at all reception centers. Baer Affidavit, 1 5.

7. Prior to fuel load, all reception centers will have emergency kits with equipment and supplies for handling contaminated property and vehicles. Baer Affidavit, 1 6.

8. Emergency. kits will include specific instructions directing where contaminated vehicles will be impounded and contaminated property temporarily stored. Baer Affidavit, 1 6.

9. Each. reception center is a public educational institution and has adequate facilities (i.e., parking lots and recreational fields) for isolating contaminated vehicles. Baer Affidavit, 1 6.

10. - Plans and procedures are in place for handling contaminated property at reception centers and the means, facilities and trained emergency workers to handle contaminated property will be in place before fuel load. -Baer Affidavit, a

1 7.

Respectfully submitted, J

n V

Tilberg, P .'C .

laa SH PKTTMAN, POTTS & TR WBRIDGE 18 M Street, N.W.

Wa ington, D.C. 20036 (202) 822-1000 Counsel for Applicants

, DATED: February 1, 1985 1

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