ML20104A642

Affidavit of DD Hulbert Re Contention Dd.Emergency Operations Facility Located at Distance from Plant Consistent W/Nrc Criteria & Guidance.Certificate of Svc Encl

ML20104A642
Person / Time
Site:	Perry
Issue date:	01/29/1985
From:	Hulbert D CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20104A615	List: ML20104A611 ML20104A634 ML20104A642
References
OL, NUDOCS 8502010428
Download: ML20104A642 (7)

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ITED 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) )

AFFIDAVIT OF DANIEL D. HULBERT ON CONTENTION DD 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 various PNPP departments and developing emergency planning documents and specification of response requirements. These responsibilities' include identifying facility and. support equipment requirements for radiological emergency response, including.those for the Emergency e 8502010428 850130 PDR ADOCK 05000440 A. G. ,

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'4 h ~ Operations Facility (EOF). 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 this affidavit in support of Applicants' Motion for Summary Disposition of Contention DD.

2. Contention DD states that the EOF for the_ Perry Nuclear Power Plant "is located contrary to the criteria and guidance provided by the NRC." Sunflower Alliance's objections are' based on the claim that the location of the EOF is contrary to the recommendations of NUREG-0814 and NUREG-0696-and would require county " decision-making officials to come to the nuisance in the event of a severe accident." Sunflower Alliance's Particularized Objections to Proposed Emergency Plans in Support.of Issue No. 1, dated August 20, 1984, p. 25.

3. The EOF for Perry is siteo approximately 1970 feet southwest of the Unit 1 reactor building and about 1800 feet from the. Unit 2 reactor building. This location is consistent

'with NRC regulatory guidance.- Its location has been reviewed by the NRC Staff in Supp. 4 to NUREG-0887, Safety Evaluation Report for the Perry Nuclear Power Plant, S 13.3.2.8.

4 .- .The only NRC guidance on the minimum distance that an EOF should be from the plant is contained in Generic Letter No.

82-33, Supplement 1 to NUREG-0737, Requirements for Emergency Response Capability, dated December.17, 1982. That document o

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ib states that the EOF should be " located outside [the] security boundary." Generic Letter No. 82-33, p. 26, Table 1. The Perry EOF complies with this criterion in that it is located approximately 1500 feet beyond the security boundary for Unit 1 and 1200 feet from where the security boundary for Unit 2 will be after construction of Unit 2 is completed.

5. Contrary to Sunflower's unsupported claim, NUREG-0696 and NUREG-0814 do not recommend that the EOF be located

~ off-site. NUREG-0696, " Functional Criteria for Emergency Response Facilities" (February 1981), provides criteria for EOF's located "within 10 miles of the TSC [ Technical Support

^

Center]" and for EOFs located "at or beyond 10 miles of the TSC." Id. at 18. For " EOF locations beyond 20 miles of the

-TSC," specific Commission approval is required. Id. No similar Commission approval is required for other locations, including locations on-site or close to the plant. Similarly, NUREG-0814, ." Methodology for Evaluation of Emergency Response

~

Facilities" (August 1981), does not recommend an off-site EOF, although it does identify different ventilation requirements for EOF's within 10 miles of the TSC that differ from those for EOF's beyond 10 miles of~the TSC.

.6. . Sunflower is also incorrect in claiming that the EOF location would force decision-making officials to jeopardize themselves by coming to PNPP'in an accident. At no time do the decision-making' officials come to the EOF. The plans provide that each county's decision-makers will convene in that

i county's own emergency operation center ("EOC"), each of which is located in the respective county, and beyond the plume exposure pathway EP2. Ashtabula Plan, SS A.3, B.3; Geauga Plan, SS A-5, B-3; Lake Plan, SS 5.1, H-01 and Attachments 5.1 and H-3. The three county ECCs and the EOF are linked by dedicated communications systems. Ashtabula Plan, 5 F.2.1 and App. 20; Geauga Plan, 5 F-2; Lake Plan, SS F-05, H-02. Thus there is no basis to support the argument that the EOF location will harm decision-making by county officials.

7. In summary, the EOF for Perry is located consistent with NRC criteria and guidance. Sunflower's claims that the EOF location is inconsistent with NRC criteria and guidance, and that the EOF location would harm decision-making by county officials, are incorrect.

~

DANIEL D. HULBERT Subscribed to before meand sworg9 this 6 gday

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of INeJt)AAN , 1985.

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fetapj.Public M M593 C. SIWBCWEKI Ncq P@c SMe et Gbc Cm. %

Ny Commission Expires: My Ammisalon upres my 14,1su

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4 Name: Daniel D. Hulbert, Emergency Planning Coordinator, Perry Plant

... Technic al . Depar tment Formal Education and Training:

Electrician's Mate School, U. S. Navy, 1973-1974 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 ~.,*cek Davis-Besse Nuclear Power Station (Evacuation Time Estimates),

1981-One-Week Electrical Fundamentals II, 1981 One-Week Planning for Nuciaar Emergencies Course, Harvard School of Public Health, 1982 Experience:

s: 1979 - Present: :The Cleveland Electric Illuminating Company L

E LJ oined CEI as an Engineering Technician and assigned to development

-h" of the1PNPP Emergency . Plan. Assisted in-the preparation of the Davis-Besse -Nuclear Power Station Emergency Plan, implementating 7 )j +f '

~

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.

I!. _ l 31973 1979: U. S. Navy Electrician's Mate - Qualified as Engineering Laboratory Technician, Electrical- Operator and -Shutdown Reactor Operator on a S5W Class ,

01 ,

Submarine. Duties included operation and maintenance of' electrical X systems, chemistry controls for both primary and secondary plant, apd routine and emergency health physics coverage. Assignments

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

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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 DD," " Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard on Contention DD," and " Affidavit of Daniel D. Hulbert on Contention DD" 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 J .

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DATED: January.30, 1985 t

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Y UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING nOARD 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. Eline 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 s 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 Regulatory Commission Center Washington,' D.C.. 20555 105 Center Street

-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 n