ML20104A956

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

ML20104A956
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
ML20104A913	List: ML20104A909 ML20104A956 ML20104A963
References
OL, NUDOCS 8502010591
Download: ML20104A956 (2)

Text

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January 30, 1985 33 iMc {

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,

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a uu. # A n BEFORETHE'ATOMICSAFETYANDLICENSINGBdNRdf(thlERVICI I'n 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 JL and 2) )

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON CONTENTION CC Pursuant to 10 C.F.R. 5 2.749(a), Applicants state, in

. support of.their Motion.for Summary Disposition of contention

'CC in this proceeding, that there is no genuine issue to be heard with respect to the following material facts:

'l. Supplement 4 to the NRC Safety Evaluation Report, NUREG-0887 (February 1984) reviewed Revision 2 to the Perry Emergency Plan. Affidavit of Daniel D. Hulbert on Contention CC ("Udlbert Affidavit"), 1 2.

2. Supplement 4 identified 35 items in Revision 2 of the Perry Emergency Plan which required resolution.

.3. By letter dated April 28, 1984, Applicants transmitted to.the NRC Staff Revision 3 the Perry Emergency

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Plan. On August 20, 1984 and October 29, 1984, Applicants transmitted to the NRC Staff additional clarification of changes to the Plan, to be incorporated in Revision 4 to the Plan (scheduled for submission on February 28, 1985). Hulbert Affidavit, 1 3.

4. The information contained in Revision 3 and in the subsequent correspondence addresses each of the 35 resolution items identified in Supplement 4. Hulbert Affidavit, 11 3-4.

5. Applicants' response to each item provided the information requested by the Staff, identified where that information had been previously presented, or demonstrated why the information was not needed or appropriate. Hulbert Affidavit, 11 4(a)-(ii).

6. The resolution items identified in Supplement 4 are not uncorrected deficiencies in the Perry Emergency Plan as that Plan has been revised.

Respectfully submitted, N , _

Jay'f. SJ.lberg, P.C.

SHAW, PITTMAN, POTTS &q/'OWBRIDGE fR 1800 M Street, N.W.

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