ML20111A465

Informs That Paragraph 3 of RR Bowers Affidavit Included W/ 850205 Motion for Summary Disposition of Contention B Contained Erroneous Statement Re Blizzard Conditions. Correction to Affidavit Does Not Change Conclusions

ML20111A465
Person / Time
Site:	Perry
Issue date:	03/07/1985
From:	Silberg J SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Bright G, Gleason J, Kline J Atomic Safety and Licensing Board Panel
References
CON-#185-974 OL, NUDOCS 8503120514
Download: ML20111A465 (2)

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SHAw, PITTMAN, POTTS &JROWBRIDGE ,

A PAmfMER$Mep OF pmOFES$40NAtt flONS 1800 M STREET. N. W.

WASHINGTON O. C. 20036 TELEcopiEn i

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i James P. Gleason, Chairman Atomic Safety and Licensing Board 513 Gilmoure Drive

Silver Spring, Maryland 20901 Dr. Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

Mr. Glenn O. Bright 1

Atomic Safety and Licensing Board

{ U.S. Nuclear Regulatory Commission

Washington, D.C. 20555 i The Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Units 1 and 2)

Docket Nos. 50-440 and 50-441 0 L j Gentlemen:

Included with Applicants' Motion for Summary Disposition of Contention B, dated February 5, 1985 was an Affidavit of Richard R. Bowers. Mr. Bowers has just informed me that  ;

j paragraph 3 of the Affidavit included an erroneous statement.

The Affidavit stated that blizzard conditions would be l characterized as Pasquill-type A or B meteorological

conditions, which would result in a dose reduction ranging from

, factors of 45 to several hundred as compared to doses

calculated using standard NRC design basis licensing

! methodology. Mr. Bowers has informed me that despite the high l winds accompanying blizzard conditions, it should be categorized as a Pasquill-type D condition. The dose reduction using Pasquill-type D as compared to standard NRC design basis j methodology would be anywhere from factors of about 20 to 50

! (instead of 45 to several hundred).

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'- SHAw, PITTMAN, PoTTs & TROWBRIDGE A PAAfNERSMep OF PaoFEsssONAL CCRoonArtoms Atomic Safety and Licensing Board March 7, 1985 Page Two The correction to paragraph 3 of Mr. Bowers' Affidavit would not change any other of his statements or conclusions.

Nor would it change the statement in Applicants' Motion (at 9) that "the meteorological conditions which would accompany the inclement weather conditions postulated by Sunflower would in themselves sharply reduce the doses to the public, because of the substantial dispersion." The Statement of Material Facts, 1 16, should be modified to reflect the fact that while blizzard conditions are not "the most faverable conditions for rapid dispersion of a radioactive plume," they still result in rapid dispersion of a radioactive plume.

Very truly yours, r,

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i SILBERG tkliv C unhel for Applicants) cc: Service List  !'~/

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