ML20107G441
| ML20107G441 | |
| 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 8502260420 | |
| Download: ML20107G441 (1) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0FDfISSION Before the Atomic Safety and Licensing Board g gg pj g In the Matter of
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THE CLEVELAND ELECTRIC
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Docket Nos. 50-440 _-fgEPVICL ILLUMINATING COMPANY
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(Perry Nuclear Power Plant, Units 1 and 2)
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- .z:.. a SUNFLOWER'S STATEMENT OF MATERIAL FACTS (CONTENTION H)
Now comes Sunflower Alliance and sets forth the following in support of its position that there are genuine issues of material fact and law on Contention H:
1.
10 CFR 50.47 (10) requires Applicant to demonstrate a'" range" of protective actions for emergency workers and the public.
2.
Applicant provides a wholly incomplete inventory of res-pirator equipment as evidence in support of its motion.
3.
Applicant's witness (see Mauro affidavit at 9) minimizes radioiodine exposures. suggesting that protective actions should be taken'to protect offsite radiaciiin workers.
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4.
The Environmental Protection Agency references respiratory protection for emergency workers immediately upon evidence of a'r'adiation' release.
EPA-520/1-75-001 at 1.29, 2.5, 5.34.
Respectfully submitted, By
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Adge 8502260420 850223 61Eh N.
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Phone: (419) 255-7552'
' Counsel.ior Sunflower Alliance
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