ML20104A265

Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard on Contention J

ML20104A265
Person / Time
Site:	Perry
Issue date:	01/30/1985
From:	Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20104A253	List: ML20104A249 ML20104A265 ML20104A276
References
OL, NUDOCS 8502010185
Download: ML20104A265 (2)

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January 30, 1985 f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BC HEARD ON CONTENTION J Pursuant to 10 C.F.R. 5 2.749(a), Applicants state, in support of their Motion for Summary Disposition of Contention J in this proceeding, that there is no genuine issue to be heard with respect to the following material facts: -

1. Emergency Action Levels ("EAL's") describe specific plant conditions at which one of the four Emergency Classifications is to be declared. Affidavit of Daniel D.

Hulbert on Contention J ("Hulbert Affidavit"), 1 3.

2. Table 4-1 of the Perry Emergency Plan, Rev. 3 sets forth.more than 200 individual EAL's. Hulbert Affidavit, 14.

3. In Revision 3 of the Perry Emergency Plan, 13 EAL's were " incomplete" because the information to be included was 8502010185 850130 PDR ADOCK 05000440 O PDR

.9 k I not available at the time that Revision 3 was issued. Hulbert Affidavit, 14. ,

4. For each of the 13 EAL's in which a value was to be added later, a comparable value was specified. Hulbert Affidavit, 1 5.

5. In each of the 13 cases where the EAL's were

" incomplete" in Revision 3 of the Plan, the values have now been developed based on additional detailed information which became available after Revision 3 was issued. Hulbert Affidavit, 16.

6. .The values missing from the 13 EAL's will be included in' Revision 4 of the Plan. Hulbert Affidavit, 1 6.

Respectfully submitted, M I . b tr Jag f. pilberg, P.C~. /

S W , KITTMAN, POTTS &JROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Counsel for Applicants DATED: ' January 30, 1985

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