ML20104A276

Affidavit of DD Hulbert on Contention J Re Emergency Action Levels.Prof Qualifications & Certificate of Svc Encl

ML20104A276
Person / Time
Site:	Perry
Issue date:	01/30/1985
From:	Hulbert D CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20104A253	List: ML20104A249 ML20104A265 ML20104A276
References
OL, NUDOCS 8502010192
Download: ML20104A276 (6)

Text

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UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l-In the Matter of )

)

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

)

(Perry Nuclear Power Plant, )

Units l'and 2) )

AFFIDAVIT OF DANIEL D. HULBERT ON CONTENTION J County of Lake )

) ss State of Ohio )

Daniel D. Hulbert, being duly sworn, deposes and says:

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, maintaining, and evaluating the Perry Nuclear Power Plant (PNPP) Emergency Plan, including coordinating emergency preparedness:among variousHPNPP departments and developing

• emergency planning-documents and specification of response

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

~ statement of my professional and' technical qualifications is attached hereto. I have personal knowledge of the matters stated'herein~and believe them to be true and correct. I make 8502010192 850130 PDR ADOCK 05000440

. .Q LQ PDR

7 4

thisLa'ffidavit in support of Applicants' Motion for Summary

-Disposition of Contention J.

2. Contention J states that the Emergency Action Level

-indications in the Perry Emergency Plan are incouplete. 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 incomplete.

Sunflower Alliance's Particularized Objections to Proposed Emergency Plans in Support of Issue No. 1, dated August 20, 984, page 16.

~3. Emergency Action Levels (EAL's) 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 F7rry

. 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,IEAL, 55 1.3.1.e(l) 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, alcomparable value was specified. For. example,_ Table (4.1, EAL 5 1.3.a.l' states:

CT

• Off-gas pretroatment process rcdiation monitor high alarm with indication of (1) increase of (later) mrem /hr in 30 min. (equiv. to 100,000 uC1/sec).

6. In each of the 13 cases,'the " missing" values have been developed based upon additional detailed information which  !

l became available after Revision 3 was issued and will be included in Revision 4 to the Perry Emergency Plan.

7. In summary, the few EAL's with " missing" values already have comparable values specified and the " missing" values will be included in the PNPP Emergency Plan prior to fuel load.

s/ _

s,  ;. /M42 -

~ DANIEL D. HULBERT Subscribed and sworn f day to beJ re me this 30, f

of J AN'UAA / 1985.

b . L

~

ta:iy Public p{

JOSEPH C. 5ZWCXCW5K!

Netat P.bce, s*st, et ces ens. r, My Commission-Expires: my cenm. len g,pi ;e, g, ton 9

~

i '

Name: Daniel D. Hulbert, Emergency Planning Coordinator, Perry Plant Technical Department Formal Education and Training:

Electrician's Mate School, U. S. Navy , 197 3-1974

. Nuclear Power Training, U. S. . Navy, 1974-1975 Engineering Laboratory Technician School, U. S. Navy ,1975 One-Week Basic BWR Systems (PDP), 1980 Fif teen-Week Davis-Besse Nuclear Power Station (Emergency Planning), 1980 Eight *4cek Davis-Besse Nuclear Power Station (Evacuation Time Estimates),

1981 One-Week' Electrical Fundamentals II, 1981 One-W' e ek Planning for Nuclear Emergencies Course, Harvard School of Public Health,-1982 Experience:

1979 - Present: The Cleveland Electric Illuminating Company Joined CEI as an Engineering Technician and assigned to development of the PNPP Emergency Plan. Assisted in the preparation of the Davis-Besse Nuclear Power Station Emergency Plan, implementating procedures, and the Davis-Besse education time estimates. Partici-pated in several Emergency Plan exercises at other Nuclear Power Plants as an of ficial Exercise Observer. In 1982 promoted to present

. position of Emergency Planning Coordinator. Reports directly to the Technical. Superintendent, Perry Plant Technical Department.

1973 - 1979: U. S. Navy

~

Electrician's Mate - Qualified as Engineering Laboratory Technician, Electrical Operator and Shutdown Reactor Operator on a S5W Class Submarine. Duties included operation and maintenance of electrical systems, chemistry ' controls for both primary and secondary plant,-

ape routine and emergency health physics coverage. As signments

- ' included one tour on an S5W Submarine.and one tour assigned to the Radiological Controls Division of a Submarine Tender.

A L

4 s

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

)

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

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion For Summary Disposition of Contention J," " Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard on Contention J" and " Affidavit of Daniel D. Hulbert on Contention J," were served this 30th day of January, 1985, by deposit in the U.S. mail, first class, postage prepaid, upon the-parties listed on the attached Service List.

kM .

EG Jay . ilberg J

Dated: January 30, 1985 i

M

-t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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) )

SERVICE LIST James P. Gleason, Chairman Atomic Safety and Licensing 513 Gilmoure Drive Appeal Board Panel Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Glenn O. Bright Colleen P. Woodhead, Esquire Atomic Safety and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Alan S. Rosenthal, Chairman Atomic Safety and Licensing Terry Lodge, Esquire Appeal Board Suite 105 U.S. Nuclear Regulatory Commission 618 N. Michigan Street Washington, D.C. 20555 Toledo, Ohio 43624 Dr. W. Reed Johnson Donald T. Ezzone, Esquire Atomic Safety and Licensing Assistant Prosecuting Attorney Appeal Board Lake County Administration U.S. Nuclear Re'gulatory Commission Center Washington, D.C. 20555 105 Center Street Painesville, Ohio 44077 Gary J. Edles, Esquire Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission

' Washington, D.C. 20555 Washington, D.C. 20555 John G. Cardinal, Esquire Ms. Sue Hiatt Prosecuting Attorney 8275 Munson Avenue Ashtabula County Courthouse Mentor, Ohio 44060 Jefferson, Ohio 44047