ML20104A265
| 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: |
| References | |
| OL, NUDOCS 8502010185 | |
| Download: ML20104A265 (2) | |
Text
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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
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Docket Nos. 50-440 ILLUMINATING COMPANY
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50-441
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(Perry Nuclear Power Plant,
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Units 1 and 2)
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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
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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, I
b tr M
Jag f. pilberg, P.C~.
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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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