ML20106A142

From kanterella
Jump to navigation Jump to search
Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention H
ML20106A142
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 02/05/1985
From: Silberg J
CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20106A129 List:
References
OL, NUDOCS 8502110053
Download: ML20106A142 (3)


Text

r:-

3

%=

February 5, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION jp):57 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 H Pursuant to 10 C.F.R.

S 2.749(a), Applicants state, in support of'their Motion For Summary Disposition of Contention H, that there is no genuine issue to be heard with respect to the following material. facts:

1.-

All of the local emergency response plans establish radiation exposure' limits for emergency workers that conform to EPA guidance.

The exposure limits for emergency workers are:

t

.a.

-For other than lifesaving missions:

Projected Wholas Body. Gamma Dose. - 25 rem Projected Thyroid Dose - 125 rem s

1-8502110053 850205 PDR ADOCK 05000440 0

PDR

'!I

.-.4 b. --

For lifesaving missions:

Projected whole Body Gamma Dose - 75 rem O

Projected Thyroid Dose - No limit Winters Affidavit, 1 3.

2.

A decision chain for authorization of an emergency work'er to exceed the exposure limits established in the local

- emergency plans is provided in each of the plans.

The decision chain provides that the emergency worker's department head will discuss the need with direction and control personnel of local emergency operations (i.e.,' the County Commissioners) who, in

-consultation with the Ohio Department of Health, will concur with', or disapprove, : the in~ creased exposure.

Winters Affidavit,.1

<4.

3.

There is.no NUREG-0654 criterion providing for respirators for o'ffsite emergency workers.

Winters Affidavit,-

.1;5.

4.

In:any' event,urespirasors are available for use by emergency workers.

The table below represents a partial i:

~

inventory of self-contained breathing apparatus ("SCBA")

, - available to.the three counties through municipal ~ fire departments in the counties.-

5 -

L n

.a t

r Self-Contained Breathing' Apparatus Partial Listing:~ Fire Departments within the Three Counties County

~SCBA Extra Cascade Refill Compressors Tanks Systems

. Lake-353 345 17 3

Ashtabula 132 125 8

1 Geauga 165 186 8

1 Additional' respiratory protection equipment (beyond that identified above) is locally available to the counties.

Winters Affidavit, 1 6.

Respectfully submitted,

(')

i A% $

/ l i -

\\

Jay [E/

lberg, P.C.

S H A W,/ P TMAN, POTTS & #ROWBRIDGE 1809/M treet, N.W.

Washington, D.C.

20036 (202) 822-1000 Counsel for' Applicants Dated:

February 5, 1985

~ b