ML20102C250

Statement of Matl Facts as to Which There Is Genuine Issue on Contention Q.Parents of Children Attending School in Emergency Planning Zone Would Very Likely Attempt to Pick Up Children During Evacuation

ML20102C250
Person / Time
Site:	Perry
Issue date:	03/02/1985
From:	Lodge T LODGE, T.J., SUNFLOWER ALLIANCE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20102C140	List: ML20102C139 ML20102C153 ML20102C163 ML20102C190 ML20102C248 ML20102C250 ML20102C252 ML20102C255 ML20102C257 ML20102C261 ML20102C269 ML20102C292 ML20102C303 ML20102C308 ML20102C311 ML20102C314 ML20102C315
References
OL, NUDOCS 8503050417
Download: ML20102C250 (1)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION" ,

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Before the Atomic Safety and Licensing Board In the Matter of- )

THE CLEVELAND ELECTRIC ) Docket Nos. 50 450 1 Jarid,-30-441n '

ILLUMINATING COMPANY ) '"#jd(["M

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

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SUNFLOWER'S STATEMENT OF MATERIAL FACTS (CONTENTION Q)

Now comes Sunflower Alliance and sets forth the following facts concerning which there is a genuine issue on Contention Q:

1. Parents of children attending school in the EPZ would very likely attempt to pick them up during an evacuation. The experience of one Ashtabula County bus driver is that parents call the schools if a bus is 10 minutes late in delivering a child home. Affidavit of Barbara Niznik.

2. The expertise of Applicant's affiant, Gary Winters, shows ex-perience solely in natural disasters, not man-made radiological disasters.

Winters Affidavit.

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3. Bus drivers to this point have not had evacuation training which warrants a conclusion that they would show "prosocial" behavior during an emergency. Niznik Affidavit.

4. The Ashtabula County Radiological Emergency Response Plan contains no letters or contracts committing buses for use in an emergency at Perry.

Respectfully submitted, h40 By l l & /

%y D } PDR (

) Ah1A f Lodge

/lTrty[MichiganStreet g 6 8 N.

Suite 105 Toledo, Ohio 43624 Phone: (419) 255-7552 Counsel for Sunflower Alliance