ML20107G489

Statement of Matl Facts as to Which There Is No Genuine Issue for Contention M.Applicant Fails to Mention Cost Consideration to Support Opposition to Independent Monitoring Sys in Affected Counties

ML20107G489
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 8502260438
Download: ML20107G489 (2)

Text

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00CMETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY 00MMISSION Board I 15 Rd 25 P1:36

• Before the Atomic Safety and Licensing

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In the Matter of

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) Docket Nos. 50-440 and 50-h BRANCH

)

THE CLEVELAND ELECTRIC '

ILLUMINATING COMPANY ','

(Perry Nuclear Power Plant, - . .

Units 1 and 2) }

SUNFLOWER'S (CONTENTION M)

STATEMENT OF MATERIAL FAC h the following as Now comes Sunflower Alliance, and sets fort ition to summary disposition of material facts in support of its oppos Contention M: to ensure:

1.

10 CFR 950.47(b)(9) requires an emergency plan for assessing and Adequate methods, systems and equipment nsequences of a monitoring actual or potential offsite coradiolo

2. By its own statement of facts and supporsideration in s Applicant has failed to mention any cost conystems in all a opposition to independent monitoring s ill contains the 1980

3. The current revision of the State Plan st Chief of Ohio Department of Public Health letter from Charles Croft, h, Jr., Deputy Director of the Ohio laboratories to Curtis Griffit f-the stating that,the Radiochemistry Unit o Adjutant's Department, handle t have various necessary equipment to-

. ODH laboratories does no and analyze " hot" samples. h November, 1984 emergency.

4.

At p. l35 of the FEMA Exercise Report from t e h d ific finding that emergency officials s owe drill at PNPP, there was;a spec d res,for. testing irradiated materfals.

a lack of familiarity with sampling proce u 04g C~

5. NUREG-0654 identifies as a local responsibility that there be methods of rapidly assessing actual or potential magnitude and locations of radiological hazards through liqued or gaseous release pathways. Id.

l at 58. The Ashtabula County Radiological Emergency Response Plan at p.

I-l indicates only that local officials will " support" the state "as requested."

6. Contrary to Applicant's allegation at para. 11 of its " Statement of Material Fact," the State of Ohio does not have fixed independent radia-tion monitoring systems in place, but uses three mobile vehicles. FEMA Exercise Report at 33. These vehicles are apparently heqdquarted at the Ohio DSA offices in Worthington, Ohio, and require 3 or more hours

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of driving time to get to PNPP. Id.

Respectfully submitted,

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l em ' d1L. -

m., TERRY J. L01 CE . [ .

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Counsel o r Sunftower Alliance.

618 N. M c .gan St.,-Suite 105 Toledo, Oh ) 43624-(419) 255-7552 ' (.

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