ML20104A634
| ML20104A634 | |
| 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 | |
| ML20104A615 | List: |
| References | |
| OL, NUDOCS 8502010419 | |
| Download: ML20104A634 (2) | |
Text
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January 30, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY
)
50-441
)
(Perry Nuclear Power Plant,
)
-Units 1 and 2)
)
APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON CONTENTION DD Pursuant to.10 C.F.R.
S 2;749(a), Applicants state, in support of their Motion for Summary Disposition on Contention DD~in this. proceeding, that-there is no genuine issue to be
' heard with. respect to the following material facts:
l 1.
.The. Emergency Operations Facility
(" EOF") for the Perry Nuclear Power Plant ("PNPP") is' located approximately 1,970 feet from the Unit 1 reactor building and about 1,800 l
' feet from the Unit 2 reactor building.
Affidavit of Daniel D.
Hulbert on Contention DD ("Fulbert Affidavit"), 1 3.
2.
The PNPP EOF.'is located about 1,500 feet beyond the security boundary for Unit 1 and 1,200 feet from where the-security boundary for Unit 2 will be after construction of Unit 2 is completed.
Hulbert Affidavit, 1. 4.
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3.
The only NRC guidance on the minimum distance that an
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EOF should be from a nuclear power plant is contained in Generic Letter No. 82-33, Supp. 1 to NUREG-0737 (December 17, 1982), which states that an EOF should be beyond the plant security boundary.
Hulbert Affidavit, 1 4.
4.
NRC documents NUREG-0814 and NUREG-0696 do not recommend that an EOF be located off-site, but provide criteria for EOF locations within 10 miles from the plant and beyond 10 miles-from the plant.
Hulbert Affidavit, 1 5.
5.
Specific Commission approval of an EOF location is only required if the EOF is beyond 20 miles from the plant.
--Hulbert Affidavit, 1 5.
.6.
~ County decision-makers do not come to the EOF in the event of an accident at PNPP, but convene in their respective county emergency operation centers.
Hulbert Affidavit, 1 6.
7.
The PNPP EOF is located consistent with NRC criteria and guidance..Hulbert Affidavit, 1 7.
Respectfully submitted, t
4%
~
Jay E/
1 erg,.P.C.
I SHAW P T MAN, POTTS &
ROWBRIDGE 1800 St eet, N.W.
Washingt n, D.C.
20036 (202) 822-1000 Counsel for Applicants 1 DATED:
January 130, 1985