ML20102C269
| ML20102C269 | |
| 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: |
| References | |
| OL, NUDOCS 8503050438 | |
| Download: ML20102C269 (1) | |
Text
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')SISD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Befere the Atomic Safety and Licensing Board
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fit In the Matter of
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_,,j' THE CLEVELAND ELECTRIC
) Docket Nos. 50-440 and 50-441 ILLUMINATING COMPANY
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(Perry Nuclear Power Plant,
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Units 1 and 2)
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SUNFLOWER'S STATEMENT OF MATERIAL FACTS (CONTENTION Z)
Now comes Sunflower Alliance and sets forth the following as mater-ial facts in opposition to the granting of summary disposition on Contention Z:
1.
The only evacuation training for bus drivers was given in 1984, and was attended by fewer than half of all drivers. Affidavit of Barbara Niznik accompanying Sunflower response to motion for summary disposition of Contention Q-2.
At least one bus driver in the EPZ has had no explanation of dosimetry use, an overview of the offsite emergency plans, or instruction on an individual driver's duties. Niznik Aff., Id.
3.
Present emergency plans do not contemplate evacuation "before any significant radiation release," as claimed by Applicant, but rather only after Emergency Action Levels measure 1 rem whole body /5 rem thyroid. PNPP Emergency Plan, p. 4-32.
Respectfully submitted, r
By Af
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3OgO438850302 DOCK 0500g
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fierrfJ. Lodge y
A. 018 U Michigan Street g
duite 105 Toledo, Ohio 43624 Phone: (419) 255-7552 Counsel for Sunflower h