ML20104B000
| ML20104B000 | |
| 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 | |
| ML20104A935 | List: |
| References | |
| OL, NUDOCS 8502010621 | |
| Download: ML20104B000 (4) | |
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,
)
LUnits 1 and 2);
)
APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON CONTENTION BB Pursuant to 10:C.F.R. S'2.749(a), Applicants state, in
~ support'of.their Motion for Summary Disposition of-Contention BB in this proceeding, that'there is no genuine issue to be
~
heard with respect'to the following material facts:
1.
The Interim Report on Off-Site Radiological Emergency
- Planning lfor the Perry NuclearfPower Station, dated-January 10, s
1984 (" FEMA" Interim Report")Lreviewed' draft emergency plans for.
~ Lake, Ashtabula and'Geauga Counties submitted ~for review by the
-Stateiof Ohio in March 1983 and'a' schedule of corrections re-ceived1by FEMA'in August'1983. ' Affidavit ofEJohn Baer on Con-
'tention BB:'("Baer'Aff."),,1'4.
- 2. '
.The FEMA' Interim Report concluded that "there'.is rea--
Esonable assuranceLthat.the plans are adequate and-capable of?
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being implemented in1the' event'of an accident at the' site."'
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, BaerLAff.,21 3.
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More than half of the planning deficiencies identi-fled in the FEMA Interim Report were corrected and the correc-tive action accepted by FEMA in the Interim Report itself.
Baer Aff., 1 4.
4.
Each of the plans was revised in response to the FEMA Interim Report and reflects-corrective actions to the planning deficiencies.
Baer Aff., 1'5.
5.
An independent review of all the planning deficiencies in the FEMA Interim Report shows that all have
-been corrected or are being resolved.
The few remaining items still being addressed involve emergency information material to
-be distributed prior to fuel load.
Baer Aff., 11 6-7 and At-tachment B.
Respectfully submitted, Ja S lberg, P.C.
SH PI TMAN, POTTS ROWBRIDGE 18 ME treet, N.W.
Washington, D.C.
20036 (202) 822-1000 Counsel for Applicants DATED:- January 30, 1985'.
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD LIn the Matter of
)
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440
- ' ILLUMINATING COMPANY
)
50-441
)
(Perry Nuclear. Power Plant,
)
Units _1;and--2)
)
~ CERTIFICATE OF SERVICE I hereby-certify that copies of " Applicants' Motion For
- Summary Disposition of. Contention BB,"
" Applicants' Statement
- of-Material Facts As To Which There Is No Genuine Issue To Be Heard on Contention BB" and " Affidavit of John Baer on Contention BB," were served this 30th day of January,- 1985, by deposit in the U.S. mail, first-class, postage prepaid, upon
. the parties listed on.the attach Service L t.
)
E.
Silberg
- DATED:
January 30, 1985 4
L m _,
t 4
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 ILLUMINATINGJCOMPANY, ET AL.
)
50-441
)
(Perry Nuclear: Power Plant,
)
Units 1 and 2)
)
SERVICE LIST
' Janes P. Gleason, Chairman Atomic Safety and Licensing
'513 Gilmoure Drive Appeal Board Panel
" Silver Spring,' Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
-Mr.rJerry R..Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary _
<U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
-Washington, D.C.
20555 Washington, D.C.
20555 Mr. Glenn.O. Bright Colleen P. Woodhead, Esquire-
- Atomic Safety' and Licensing. Board Office of the Executive Legal U.S.. Nuclear Regulatory Commission Director
. Washington, D.C.
20555 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555'
- Alan S. Rosenthal, Chairman Atomic Safety and Licensing Terry Lodge, Esquire Appeal Board?
Suite 105 U.S. Nuclear Regulatory Commission-618 N. Michigan Street 1 Washington, D.C.
20555
' Toledo,~ Ohio '43624 Dr. W._ Reed Johnson Donald T.
Ezzone, Esquire Atomic Safety.and' Licensing
' Assistant Prosecuting Attorney
. Appeal Board ~
Lake County Administration
- U.S. Nuclear'Re'gulatory Commission Center Washington, D.C.~
20555-105 Center Street-Painesville, Ohio 44077
' Gary J.;Edles, Esquire Atomic! Safety and Licensing:
Atomic Safety.and Licensing KAppeal Board Board'Paneli U.S. Nuclear Regulatory Commission U.S., Nuclear Regulatory' Commission
> Washington, D.C..
20555-
-Washington, D.C..
.20555 s
~ John G. Cardinal,LEsquire Ms.' Sue Hiatt s
2 Prosecuting' Attorney Mentor, Ohio 44060 8275 Munson Avenue Ashtabula County Courthouse _
Jefferson,f0hio 44047
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