ML20102A836

Affidavit of G Winters Re Contention Q.Prof Qualifications Encl

ML20102A836
Person / Time
Site:	Perry
Issue date:	02/05/1985
From:	Winters G CLEVELAND ELECTRIC ILLUMINATING CO., EMERGENCY MANAGEMENT SERVICES, INC.
To:
Shared Package
ML20102A826	List: ML20102A822 ML20102A830 ML20102A836 ML20102A846
References
OL, NUDOCS 8502080588
Download: ML20102A836 (9)

Text

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8 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING DORRD In the Matter of )

'85 EP -8 A11 :00

)

THE CLEVELAND ELECTRIC ) Socket" Nosi- 50-440 ILLUMINATING COMPANY ) "' T! ~ ' 50-4 41

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF GARY WINTERS ON CONTENTION Q County of Dauphin )

) ss.

Commonwealth of Pennsylvania )

GARY-WINTERS, being duly sworn, deposes and says:

1. I am presently a Project Coordinator and Emergency Planning Specialist for the Emergency Management Services l Department of Energy Consultants. My business address is 2101 I North Front Street, Harrisburg, Pennsylvania 17110. My i

responsibilities include coordination of offsite resource inventory and assessment efforts involving Lake, Ashtabula and Geauga Counties with respect to the Perry Nuclear Power Plant.

l Project activities have included the interview of response agency / facility administrators for resource information, preparation of county resource documents and analysis of l

l -offsite resource capability to respond to an accident at the l-Perry Plant. A current statement of my professional qualifications and experience is attached hereto. I have L 18N8889h

personal knowledge of the matters stated herein and believe them to be true and correct. I make this affidavit in support of Applicants' Motion For Summary Disposition of Contention Q.

2. The purpose of this affidavit is to demonstrate the availability of sufficient resources to evacuate all schools (grades K-12) within the plume exposure pathway emergency planning zone ("EPZ") in a single trip, to jdentify the specific measures being taken to assure that parents of children in schools within the EPZ will cooperate with plans for the evacuation of the schools, and to explain that -- even if some parents did attempt to pick up their children at school

-- the evacuation of schools would not be impeded.

I. School Buses

3. A recent survey of the superintendents of all school districts within the Perry EPZ indicates that current total enrollment in EPZ schools is approximately 19,802 students.

4. The licensed capacity for EPZ and support school busesl / is an average of 59.3 students per bus; the actual evacuation capacity is an average of 55.0 students per bus.2/

I 1/ Support school buses are school buses from schools within the three county area (but outside the EPZ) which'are

, available to assist with the evacuation of EPZ schools in the event of an emergency at Perry.

2/

The average licensed capacity of EPZ and support school I

buses was determined by averaging the licensed capacity of

, these buses. The average actual evacuation capacity of these buses was determined by matching licensed capacity (Continued next page)

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, Thus, the actual number of buses needed to evacuate EPZ schools in a single trip -- based on actual evacuation capacity -- is 384 buses.3/ A county-by-county breakdown is shown in Table A below.

TABLE A SCHOOL BUSES County Support Buses Total Buses Surplus Buses Within Needed For Buses EPZ School Evacuation Lake 246 120 303 63 Ashtabula 182 34 64 152 ,

Geauga 65 14 17 62 TOTALS 493 168 384 277 s

5. As Table A indicates, the schools within the EPZ do not have sufficient bus capacity to evacuate their students in a single trip without assistance. However, Standard Operating Procedures developed with school distriots in the three (Continued) to grade level for all schools within the EPZ, and assigning two or three students per seat (based on three per seat for grades K-9, and two per seat for grades 10-12). The total number of buses needed was then determined, and an average per bus capacity calculated.

3/ The actual number of buses needed to evacuate EPZ schools in a single trip was determined by matching actual evacuation seat capacity to individual school enrollment and calculating the number of buses needed to evacuate each school in a single trip.

P I

counties provide for the use of resources (school buses and drivers) from outside the EPZ to evacuate schools within the EPZ in an emergency. See also Lake County Plan,i/ SS J-06, J-ll, and Attachment A-1; Ashtabula County Plan,5/ Appendices 6 and 9, and 5 J.4.1; Geauga County Plan,5/ Appendices 4 and 24.

Letters of agreement are being obtained for the use of these resources. Table A clearly demonstrates the availability of adequate numbers of buses to evacuate all school students from the EPZ in a single trip. Indeed, Table A indicates a surplus j

of 277 buses available within the three counties, over and above the buses needed to evacuate the schools in the EPZ.

II. Bus Drivers 4

6. Table B below shows the pool of licensed school bus drivers (both regular and substitute drivers) available within the three counties to support evacuation in the event of an emergency at the Perry Plant. As Table B indicates, there are many more than enough schcol bus drivers available to drive the 384 buses needed to evacuate the schools within the EPZ in a single trip.

4/ Lake County Emergency Response Plan For The Perry Nuclear Power Plant (Rev. 3, October 1984).

5/ Ashtabula County Radiological Emergency Preparedness Plan (May 10, 1984). -

1/' Geauga County Radiological Emergency Response Plan (December 1983) (including Change No. 2 dated July 1984).

TABLE B SCHOOL BUS DRIVERS County Regular Substitute Totals Lake 314 78 392 Ashtabula 174 68 242 Geauga 65 19 84 718

7. Each of the three county plans provides for the training of emergency workers, including bus drivers. Lake County Plan, Attachment 0-1; Ashtabula County Plan, Appendix 34; Geauga County Plan, Appendix 36. The training being provided to each bus driver prior to fuel load includes (at a minimum):

a. An explanation of basic radiation concepts (including the use of dosimetry).

b. An overview of the offsite emergency plans.

c. Instruction on each driver's specific duties. ,

In addition, the training includes making the bus drivers aware-of'the advantages-of informal pre-emergency family contingency

. planning.

8. All school bus drivers assisting with the evacuation-of schools within the plume EPZ in the event of an emergency _at Perryfwould-be provided-with personnel dosimetry,-both

-self-reading and permanent' record types.

III. Parents' Response

9. The EBS announcements for broadcast in the event of an evacuation will advise parents of the evacuation of the schools and of the location to which each school's students are being evacuated. The EBS announcements also will emphasize that parents should pick up their children at the appropriate receiving school outside the EPZ. The emergency public information brochure (for distribution throughout the EPZ prior to fuel lead, and annually thereafter) will provide this same information about school evacuation, and will also instruct parents not to go to the schools to pick up their children.

Lake County Plan, SS G-01, G-02, G-03; Ashtabula County Plan, 55 E.4, G.2; Geauga County Plan, 55 E-6, G-3.

10. The offsite plans for the Perry EPZ are designed to facilitate the expeditious evacuation of school children,

- directly from their schools within the EPZ to. predesignated receiving schools (reception centers) outside the EPZ. In the event of an emergency at Perry, evacuation of approximately half the schools within the EPZ would begin within 15 minutes of.the order to evacuate. Therefore, many school children would already be.enroute to receiving schools by the time parents could receive and react to notification of an

- evacuation and travel to the schools.

11. Nevertheless,'even if some parents ignored the information provided in the brochure and in the EBS brohdcasts and did go to the schools to pick up their children in an d

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emergency, school evacuation would not be seriously impeded. Normal school dismissal p would be followed, including the stationing of school personnel to dfMt buses out of the loading areas, and to prevent extran-eous traffic from entering the loading area, if necessary.

12. In summary, ample resources (school buses and drivers) are

! available to evacuate all schools within the EPZ in a single trip.

Provisions for the dissemination of information about school evacuation in an emergency provide assurance that parents of children in schools within the EPZ will cooperate with plans for the direct evacuation of q

their children to receiving schools outside the EPZ. Nevertheless, even if some parents did attempt to pick up their children at school, the evacuation of schools would not be impeded. j j J _.

'~

A Gary in ers

,. sworn to before day of February, 1985.

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' ENERGY CONSULTAMS RMunde Omco Center 3 2101 N. Fvont St. . Hertuourg, PA 17110 (717) 2 4 0031 Resume Current 01-11-85 GARY A. WINTERS Education 1975 Bachelor of Science - Law Enforcement Pennsylvania State University University Park, Pennsylvania Experience 9-81 to Present Energy Consultants Harrisburg, Pennsylvania Planner / Trainer, Emergency Management Services. Re-sponsible for provision of direct consultant services to assist s tate and local governments and industry in emergency management planning, procedure preparation and program accrtditation/ licensing. Recent project as-sigreent has included coordinating and performing a detailed audit of the offsite emergency preparedness program in support of the Perry Muclear Power Plant Atomic Safety and Licensing Board hearings. Assignment as )roject coordinator involved responsibility for l deve l opment of audit. criteria; plan / procedure review; i doceentation of program weaknesses; and resource l verification. Prior project assigreents have included:

l l - Development of four county radiological emergency l responte plans in support of the Callaway Plant; l

, - Development of local emergency response agency implementing procedures in support of the Water-ford 3 Steam Electric Station; and

- Revision of a county radiological emergency re-sponse plan in support of the Beaver Valley Power Station.

capone omem 13mwamqpon pee . erusede. e 15017 . (at2) 257-13s0

Gary A. Winters Pagt 2 4 76 to 9-81 Dauphin County Harrisburg, Pennsylvania Juvenile Court Prvbation Officer. Managed caseloads, investigated cases of delinquency, prepared legal doceents, and testified in court hearings; coordinated the delivery of haan services to delinquent youth among various public and private institutions.

Assistant Supervisor of Predispositional Advanced to Services .

9 67 to 10-70 U.S. Amy 12th U.S. Arwy Security Agency Field Station Chitose, Japan Non-Morse Intercept Operator for the U.S. Arg Security Agency.

Advanced to search operator, Specialist 5, quality controller, and shift leader. Received a " top secret

• security clearance.

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