ML20102C303

Statement of Matl Facts in Opposition to Summary Disposition of Contention Bb.Applicant States That Previously Noted Deficiencies Identified by FEMA Being Resolved But Applicant Does Not Indicate Resolution

ML20102C303
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 8503050471
Download: ML20102C303 (1)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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Before the Atomic Safety and Licensing Board ,#1 '4 c;i 33

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In the Matter of ) '"*^~ y g - j.,S ;., nct

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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) )

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SUNFLOWER'S STATEMENT OF MATERIAL FACTS (CONTENTION BB)

Now comes Sunflower Alliance and sets forth the following facts in opposition to summary disposition of Contention BB:

1. Applicant states that previously-existing deficiencies identi-fled by FEMA "are being" resolved, but does not state that they are resolved.

Applicant's " Statement of Material Facts," para. 5.

2. FEMA identified as problems in its review of the November 28, 1984 drill at Perry-that staff at Ashtabula County Medical Center "had to-improvise the means to attempt to decontaminate the patient." FEMA "Execcise Report," January 18, 1985 at 12. This has been confirmed as an outstanding-deficiency by the more recent Affidavit of Dr. Robert L. McTrusty, Disaster Planning Liaison at the Medical Center, which accompanies Sunflower's responses to summary disposition.of Contention P.

3. FEMA also considers deficient the adequacy of field monitoring of radiation levels. " Exercise Report," p. 24.

Respectfully submitted.

8503050471 850302 /

PDR ADOCK 05000440 BY A ' '

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[ TfryJ[.' Lodge

( 8 N.'Wichigan Street ice 105 Toledo, Ohio 43624

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