ML20102C269

Statement of Matl Facts in Opposition to Granting of Summary Disposition on Contention Z.Evacuation Training for Bus Drivers Given in 1984 Attended by Fewer than 1/2 of All Drivers & Training Inadequate

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: ML20102C139 ML20102C153 ML20102C163 ML20102C190 ML20102C248 ML20102C250 ML20102C252 ML20102C255 ML20102C257 ML20102C261 ML20102C269 ML20102C292 ML20102C303 ML20102C308 ML20102C311 ML20102C314 ML20102C315
References
OL, NUDOCS 8503050438
Download: ML20102C269 (1)

Text

W UNITED STATES OF AMERICA ')SISD NUCLEAR REGULATORY COMMISSION Befere the Atomic Safety and Licensing Board _,, . , ., e

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In the Matter of )  ;, , g(~ ;

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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 / -

f ierrfJ. y Lodge 3OgO438850302 DOCK 0500g /

A. 018 U Michigan Street g

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