ML20100C542

Direct Testimony of DD Hulbert on Issue 1,Contention J Re Emergency Action Level Indicators.Related Correspondence

ML20100C542
Person / Time
Site:	Perry
Issue date:	03/25/1985
From:	Hulbert D CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20100C521	List: ML20100C517 ML20100C537 ML20100C542 ML20100C547 ML20100C557 ML20100C569 ML20100C574 ML20100C583 ML20100C600 ML20100C612 ML20100C625 ML20100C640 ML20100C650 ML20100C665
References
OL, NUDOCS 8503290143
Download: ML20100C542 (3)

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) . . . , . . - . , - . . . . . . ~ . . -

)

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

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' DIRECT TESTIMONY OF DANIEL D. HULBERT ON ISSUE NO. 1 - CONTENTION J

1. I am presently Emergency Planning Coordinator, Perry Plant Technical Department, The Cleveland Electric Illuminating Company. My business address is 10 Center Road, Perry, Ohio 44081. In my position, I am responsible for developing, e

maintaining, and evaluating the Perry Nuclear Power Plant (PNPP) Emergency Plan, including coordinating emergency preparedness among various PNPP departments and developing emergency planning documents and specification of response i

requirements. These responsibilities include the development of Emergency Action Level ("EAL") indications.

2. Contention J states:

Emergency Action Level indicators are incomplete in the Applicants' emergency plan.

The contention was based on Sunflower's reading of Table 4-1 of the Perry Emergency Plan, Rev. 3, in which according to Sunflower critical measurements or standards are left 8503290143 850325 PDR ADOCK 05000440 R PDR

1 incomplete. Sunflower Alliance's Particularized Objections to Proposed Emergency. Plans in Support of Issue No. 1, dated August 20, 1984, page 16.

3. Emergency Action Levels (EALs) describe specific plant conditions at which one of the four Emergency Classifications (Unusual Event, Alert, Site Area Emergency, General Emergency) are to be declared. Table 4-1 of the Perry Emergency Plan, Rev. 3, sets forth more than 200 individual EAL indications.

4. Of the 200 individual EAL indications, only 13 were

" incomplete" in Revision 3 of the Perry Emergency Plan. Table 4-1, EAL 55 I.3.a.(1) and (2), II.l.a(1), III.ll.a, b and c; IV.6.a(2), b. In each case, the value to be included later was not available at the time Revision 3 of the Plan was issued, because the value could only be determined after the detailed technical data became available.

5. In each of the 13 cases where a value was to be added later, a comparable value was specified. For example, Table 4.1, EAL 5 I.3.a(1) states:

Off-gas pretreatment process radiation monitor high alarm with indication of (1) increase of (later) mrem /hr in 30 min.

(equiv. to 100,000 uCi/sec).

6. In each of the 13 cases in Revision 3, either the

" missing" values have now been developed based upon additional l detailed information which became available after Revision 3 was issued, or alternate indications have been selected. In all cases, these have been included in Revision 4 to the Perry i

t Emergency Plan, which was issued in February 1985. There are no incomplete EALs.