ML20101S846

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

ML20101S846
Person / Time
Site:	Perry
Issue date:	02/01/1985
From:	Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20101S836	List: ML20101S834 ML20101S846 ML20101S857 ML20101S873
References
OL, NUDOCS 8502050671
Download: ML20101S846 (6)

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hl'C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'[3 EP -5 A9 :53 BEFORE THE ATOMIC SAFETY AND LICENSIN7 BOARD cCC:.M ip,(;

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tAACH In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' STATEMENT OF MATERIAL PACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON CONTENTION GG Pursuant to 10 C.F.R. S 2.749(a), Applicants state, in support of their Motion For Summary Disposition of Contention GG, that there is no genuine issue to be heard with respect to the following material facts:

1. In 1984, CEI conducted a study to determine the loca-tion of the Amish in northeastern Ohio, as a part of the Perry-Hanna transmission line proceedings. This study indi-cated that there is no Amish population within the Perry plume EPZ. Dugan Affidavit, 1 3.

2. The representatives of the planning commissions of Lake, Ashtabula, and Geauga Counties agencies are aware of no information indicating that there are any population groups within the plume EPZ which do not use radio and TV. In addi-tion, local Councils of Churches as well as parish priests and k Oh

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< 4 91-various other ministers throughout the EPZ were contacted. l

'None of these persons was aware of any people within the EPZ whose' religious beliefs would preclude use of radio or TV.

Dugan-Affidavit, 11 4, 5.

3.- In the event of an evacuation of the Perry EPZ, any persons without radio or TV would learn of the need for protec-

f tive action. The public information brochure will include a  !

I special needs information card to be completed and returned to the respective County Disaster Services Agency by anyone who might need special assistance in an emergency.. The special

, help categories on the card include persons without radio and

persons without TV. In the event of an evacuation, special i

personal notification would be provided to those individuals --

ll j if any.-- who have indicated that they.have no radio or TV.

j Dugan Affidavit, 1 6.

4. Public response to emergency information and warnings 1

l of impending disasters has been a topic of investigation by so-

{ cial scientists for almost three decades. Many studies have I been performed on the subject in a variety of emergencies i

stemming from geological, climatological, and technological j phenomena, and have been documented in a vast body of emergency

, literature. Mileti Affidavit, 1 2.

5. A clear conclusion of the decades of research is that f people generally seek out additional information upon receipt c of an initial warning, before acting on that warning. The end i

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sb 3 result is that, historically, many people in emergencies have first received emergency information from other members of the ,

public. There are two reasons why this is the case. First, emergency warning /public response is an evolving process; and,-

second, people generally do not respond to emergency warnings as individuals -- rather, emergency response is largely a group activity. Mileti Affidavit, 1 3.

6. The initial response of most people to a warning of an impending. emergency is to seek out more information, and/or engage in additional communication with others.in order to con-firm the warning and information. Confirmation of warning in-formation occurs in a variety of ways; people may turn to dif-ferent radio or TV stations to hear the warning several times, check with friends and neighbors to ask if they heard the same message, and talk the situation over with others. As a result of this behavior, people become part of the warning dissemination effort, albeit informally, through social net-i working. Mileti Affidavit, 11 4, 5.

7. In the event of an emergency at the Perry plant, the seeking of confirmation would lead people to contact others who might or might not as yet have learned of the emergency. Simi-larly, people hearing sirens can naturally be expected to take e

steps to determine the reason for the use of the sirens, by turning to radio and TV and/or checking with friends or neigh-bors. Mileti Affidavit, 1 5.

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8. In addition'to the confirmation process carried out by the public,.the public information brochure (and other-media) will educate the public to tune to an Emergency Broad-cast System ("EBS") radio or TV station when the sirens within.

, the plume EPZ are sounded, to receive a message. Therefore, even if a household does'not have a radio or TV, it will be.

aware of the need to seek additional information about the EBS message from friends or neighbors with TV or radio. Dugan Af-fidavit, 1 7. t l

9. Because emergency response is largely group behavior, emergencies transform the order of a community into one'in {

which people act in more altruistic and caring ways than the-j day-to-day patterns of community life. In an emergency, neighbors, friends and family -- and even total strangers --

! check on one another and offer assistance if it is needed. As j a result, people will be in communication with other members of I the public who might not as yet have learned of the emergency.

Thus, people who have received notification of an emergency at l

l Perry generally can be expected to notify those whom they have

reason to believe may not have been informed of the nature of 1

the emergency. Members of the public would be particularly i

likely to provide such notification to any discrete segments of 4

the population known not to have access to emergency informa- i l

' tion on radio or TV (e.g., the Amish). Mileti Affidavit, 1 6.

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-10. The high level of activity which would be associated with an emergency at Perry would have a strong " ripple effect,"

generally alerting members of the public to seek additional in-

. formation.about the events taking place, even if they had not been directly warned by the official alert and notification system or another member of the public. In other words, the activities of other residents who have already received notifi-cation (turning on the lights in their homes, perhaps preparing to evacuate, or even the stream of traffic driving out of the l 10-mile EPZ) would alert most members of the public who may not yet have been warned, and cause them to seek additional infor-mation about what is going on (for example, by talking to neighbors). Mileti Affidavit,.1 7.

j 11. Each of the offsite plans for the Perry EPZ includes a means for verifying that persons within the plume EPZ have received notification. Prior to fuel load, each household will

, be provided with a card stating "WE HAVE BEEN NOTIFIED." In the event of an emergency, members of the public would display the card, or tie a towel to the doorknob or mailbox, to indi-cate that they are aware of the need to take specific protec-tion action. Any household not displaying the card or a towel 1s 4

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would be individually checked,-and.given the EBS message.

Dugan Affidavit, 1 8. ,

Respectfully submitted,

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JayA Silberg, P.C.

SH7W, P] TTMAN, POTTS & T WBRIDGE s ng n C bO36 (202) 822-1000 Counsel for Applicants Dated February-1, 1985 4

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