ML20104A885

Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention Z

ML20104A885
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
ML20104A848	List: ML20104A845 ML20104A885 ML20104A899
References
OL, NUDOCS 8502010557
Download: ML20104A885 (3)

Text

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5 January 30, 1985 "[y[{ED

'85 #N 31 R2:01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION . < 7 H Lfiti ARV

• JH WU i SERvic!.

3 RANCH 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 Z Pursuant to 10 C.F.R. 5 2.749(a), Applicants state, in

support of their-Motion for Summary Disposition of Contention Z in this proceeding,'that there is no. genuine issue'to be heard with respect to the following material facts

1. There is no regulatory requirement or guidance that.

calls for bus drivers to.be provided with protective gear such as' respirators and goggles.- Affidavit of John Baer on

< ~ Contention Z ("Baer Affidavit"), S 3.

2.-  : County emergency-plans call for bus drivers who will be serving-as emergency workers to receive personnel dosimetry, both self-reading and' permanent record types,,and associated

recordkeeping material. Baer Affidavit, 1 4.

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3. Bus drivers have been receiving, and will continue to receive, training in the use of and recordkeeping for personnel dosimetry. Baer Affidavit, 1 5.

4. Bus drivers will wear personnel dosimetry at all times. Procedures require that bus drivers read their dosimeters and record the readings at least once an hour. If the-bus driver's self-reading dosimeter shows any radiation

. exposure, the procedures call for him to report for m$nitoring and, if needed, decontamination. . This monitoring would show any. differing exposure levels to different parts of the body.

Baer Affidavit, 1. 5.

5. -Each school district emergency procedure includes

- information of.the distribution and use of personnel dosimetry and the availability of monitoring and decontamination services. Baer Affidavit, 1 6.

U6 . - Other factors reducing the chaace that bus drivers

. will;be exposed to any radiation hazard include the facts that emergency' plans contemplate evacuation before any significant radiation ~ release, bus drivers would spend less time in the

- plume exposure pathway EPZ than most other emergency workers, each-bus has radio communication for prompt receipt and transmission of radiological information, and State and CEI radiation monitoring teams'can, if needed, relay' radiation information to bus drivers. Baer Affidavit, 1 7.

7. . Bus drivers do not need'p{otective. equipment such as

. goggles, respirators or protective clothing because they are

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.9 well protected against radiation hazards by the dosimetry i provided to each driver,'the radiation monitoring and ccmmunication-available, and the plan to evacuate before significant radiation' releases occur. Baer Affidavit, 11 6-7.

Respectfully submitted,

/

JayJ . Si lberg, P.C. g SHAW PI7TMAN, POTTS & TR N RIDGE 18C M St reet, N.W.

Washingtc n , D.C. 20036 (202) 822-1000 Counsel for Applicants DATED: January 30, 1985 p-i

. . . .