ML20107G337

Statement of Matl Facts as to Which There Is No Genuine Issue on Contention B

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: ML20107G299 ML20107G306 ML20107G312 ML20107G322 ML20107G337 ML20107G350 ML20107G353 ML20107G359 ML20107G367 ML20107G373 ML20107G385 ML20107G392 ML20107G424 ML20107G441 ML20107G451 ML20107G463 ML20107G477 ML20107G489 ML20107G502 ML20107G516
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 FflCE Gr StcpgAf.

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THE CLEVELAND ELECTRIC ILLUMINATING COMPANY

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Docket Nos. 50-440 a hyEM

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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.

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6. -No' letters of agreement appt.ar in Applicant's ,St' ate, or county-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 . .

J L615 N.' Michigan 1 Street Suite-105 Toledo, Ohio.-43624 Phone: (419) 255-7552:

Counsel'for Sunflower Alliance s '* _

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