ML20107G337
| ML20107G337 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/23/1985 |
| From: | Lodge T LODGE, T.J., SUNFLOWER ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20107G302 | List: |
| References | |
| OL, NUDOCS 8502260386 | |
| Download: ML20107G337 (2) | |
Text
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00CKETED UNITED STATES OF AMERICA U%RO NUCLEAR REGULATORY CO.T!ISSION Before the Atomic Safety and Licensing Board FEB 25 Pi65 In the Matter of
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FflCE Gr StcpgAf.
hyEM THE CLEVELAND ELECTRIC
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Docket Nos. 50-440 a ILLUMINATING COMPANY
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(Perry Nuclear Power Plant,
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Units 1 and 2)
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SUNFLOWER'S STATEMENT OF MATERIAL FACTS (CONTENTION B)
Now comes Sunflower Alliance and sets forth the following in support of its position that there are genuine issues of' material fact on Contention B:
1.
Eyewitness evidence of extremely adverse recent weather conditions affecting the vicinity of PNPP includes snow and ' ice flees. Leuth Affidavitj-_Brotzman Al idavit, para. 2, 3, 4; Boyd Affidavit, para. 2, 6.
2.
Snow removal resources can be strained even by an unexception-al winter. Boyd Affidavit, para. 5.
3.
Snow removal is adversly affected by traffic congestion.
Boyd Affidavit,_ para. 3.
- 4. -Mentor, Ohio officials have never been contacted by Applicant, concerning weather-related' evacuation problems. Boyd Affidavit, para. 4.
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' 5. - Mentor's snow removal resources are the' subject of no agree-
.t ment with any other unit of government'to be made'available'for'use outside Mentor during a PNPP-induced evacuation..Boyd. Affidavit, para. 6.
- 6. -No' letters of agreement appt.ar in Applicant's,St' ate, or county-
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plans from any tow truck operators.
7.
No intergovernmental agreements for sharing of commitments of road-clearing equipment appear in Applicant's State or county plans.
8.
The Evacuation Time Estimate study nowhere assumes extra-ordinary snow removal requirements.
9.
Applicant's, State, and county plans reveal no input from county engineers of Lake, Geauga, or Ashtabula counties-yet these elected officials are responsible for snow removal from county highways.
10.
Bootstrapping a conclusion into fact, as is attempted by Applicant's Winter's Affidavit, para. 4, does not give substantive evidence to Applicant's belief that road clearance will be easy during a blizzard, 11.
Applicant's witnesses include a bachelor of science in law enforcement with 3 years background in emergency consulting work andfan
" expert" with only a bachelor of science degree in chemistry, neither of whom displays meterorlogical expertise.
Respectfully submitted,-
By
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_ Tefry J. Lodge.
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L615 N.' Michigan 1 Street Suite-105 Toledo, Ohio.-43624 Phone: (419) 255-7552:
Counsel'for Sunflower Alliance s '*
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