ML20102C255

Memorandum in Opposition to Summary Disposition of Contention U.Provisions for Decontamination of Vehicles & Use of Saybrook Fire Station for Decontamination Activities Proven Deficient During Nov 1984 Test of Emergency Plans

ML20102C255
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 8503050421
Download: ML20102C255 (2)

Text

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 ::C#.ETED UNITED STATES OF- AMERICA l.h i C NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Boa'rd cr SE;R .~' '

In the Matter of ) 'iT 9-

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

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(Perry Nuclear Power Plant, ) , _ . , _ , , _ _ _ _ _ _ . . , _ ._

Units 1 and 2) )

)

SUNFLOWER'S MEMORANDUM IN OPPOSITION TO

SUMMARY

DISPOSITION OF CONTENTION U By 10 CFR Section 2.749 (d), Applicant must show that there is no genuine issue as to any material fact and that it is entitled to a decision C as a matter of law. The record is to be viewed in the light most favorable to the party opposing the motion. Poller v. Columbia Broadcasting System, Inc., 368 U.S. 464, 473 (1962); Pennsylvania Power & Light Co. and Allegheny Electric Cooperative. Inc. (Susquehanna Steam Electric Station, Unit: 1 cr.d 2), LBP-81-8, 13 NRC 335, 337 (1981).

Applicant again seeks on this contention to fill the gaps in plan-ningby Affidavit assurances that certain events will occur prior to fuel loading at Perry, such as training of fire department personnel, and the placement of emergency kits at reception centers.

Provisions for decontamination of vehicles were a sore point of deficiency in the November, 1984 test of emergency plans at PNPP. The Saybrook Fire Station in Ashtabula County was strongly criticized, with the recommendation that it not be designated for decontamination activity because of certain physical

' facility limitations.

8503050421 850302 PDR ADOCK 05000440 -

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These are hard, and as yet unresolved, fact issues. Based upon them, Sunflower " prays that summary disposition of Contention U be denied.

Respectfully submitted, By I

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Perry Jf I,odge

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/ 518 N. U!ichigan Street suite 105 iroledo, Ohio 43624 Phone: (419) 255-7552 Counsel for Sunflower Alliance