ML20104A885
| 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: |
| References | |
| OL, NUDOCS 8502010557 | |
| Download: ML20104A885 (3) | |
Text
-
5
"[y[{ED January 30, 1985
'85 #N 31 R2:01 UNITED STATES OF AMERICA
. < 7 H Lfiti ARV NUCLEAR REGULATORY COMMISSION
- 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.
~ 8502O 57 850130:
- y Agn no"#1 mz
j '
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
_2_
4.
L 4
t
-ep
+'y*
g
' 97s-.-
3
--m?->
r>
--+47-g
-*,,e--
r yv-9
--*-=1--
6gw-9m-ee-wvw w w
e' e=w#
J e-
.9 i
well protected against radiation hazards by the dosimetry 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....