ML20112J913
| ML20112J913 | |
| Person / Time | |
|---|---|
| Site: | Harris |
| Issue date: | 01/14/1985 |
| From: | Gaukler P CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20112J843 | List:
|
| References | |
| OL, NUDOCS 8501180421 | |
| Download: ML20112J913 (2) | |
Text
g r
o o
C. 5En
- iM L JangyjM,7 p95 7 1
5 LTTiCE : w.,u C CO KEilG 4 5E-\\' fe UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
CAROLINA POWER E LIGHT COMPANY
)
and NORTH CAROLINA EASTERN
)
Dccket No. 50-400 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant)
)
APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON EDDLEMAN 213-a Pursuant to 10 C.F.R. section 2.749(a), Applicants state, in support of their Motion for Summary Disposition of Eddleman 213-a, that there is no genuine issue to be heard with respect to the following material facts:
1.
The Emergency Response Plan ("ERP") for the Shearon Harris facility is divided into five parts, Parts 1-5.
Part'l sets forth the State's responsibility and involvement in emer-gency planning and response for Shearon Harris.
Parts 2 through 5 set forth the responsibility and involvement for emergency planning and response for Chatham, Harnett, Lee and Wake counties respectively.
Pugh Aff.
1 4.
2.
-Attachment 2 for each Part of the ERP lists by title
.the standard operating procedures used in the implementation of the ERP by the State and each of the four counties located O!h4oo PDR
m u
within the Shearon Harris EPZ.
The titles of the procedures indicate the section(s) of the ERP to be implemented by the procedures.
Pugh Aff. 11 4-5.
3.
The State and counties are presently developing addi-tional standard operating procedures to aid in the imple-mentation of the ERP for the Shearon Harris facility.
The ERP for the Shearon Harris facility will be amended to include these new procedures as part of the implementing procedures currently identified and set forth in Attachment 2 of the re-spective parts of the ERP.
Additionally, the Attachments, as amended, will identify the various section(s) of the Plan that each procedure (both those presently listed and those being added) are intended to implement.
Pugh Aff. 11 7-8.
Respectfully submitted, OLL L
Thomas A.
Baxter, P.C.
Paul A. Gaukler SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 and Richard E. Jones Dale E. Hollar CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated:
January 14, 1985 I -
.