ML20104A951

Affidavit of J Baer Re Contention Bb

ML20104A951
Person / Time
Site:	Perry
Issue date:	01/30/1985
From:	Baer J CLEVELAND ELECTRIC ILLUMINATING CO., ENERGY CONSULTANTS, INC.
To:
Shared Package
ML20104A935	List: ML20104A932 ML20104A951 ML20104B000
References
OL, NUDOCS 8502010588
Download: ML20104A951 (18)

Text

C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION B_E'/ ORE 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) )

AFFIDAV1T OF JOHN BAER ON CONTENTION BB County of Dauphin )

) ss State of Pennsylvania )

John Baer, being duly sworn, deposes and says:

1. I am presently Project Manager for Emergency Management Services, Energy Consultants, Inc. My business address is 2101 North Front Street, Harrisburg, Pennsylvania 17110. In my position, I am project manager for off-site radiological emergency response planning being provided to

' Lake, Ashtabula and Geauga Counties with respect to the Perry Nuclear Power Plant. A current statement of my professional tand technica1' qualifications is attached hereto as Attachment "A". -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'BB.

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2.- Contention BB claims that the off-site emergency plans for_the-Perry facility are inadequate due to the planning deficiencies set forth in the Interim Report on off-site

-Radiological Emergency Planning for the Perry Nuclear Power Station, dated January 10, 1984 (" FEMA Interim Report").

3.: The conclusion of the Interim Report was that "there

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-is-reasonable assurance that the plans are adequate and capable of being implemented in the' event of an accident at the site."

4. The FEMA Interim Report reflects the review by the FEMA Regional Assistance Committee ("RAC") of draft Ashtabula, Geauga and Lake County Emergency Plans submitted for review by the' State of Ohio on March 17, 1983, and the schedule of corrections to the RAC review received by FEMA from the State on August 30, 1983. As reflected in the FEMA Interim Report, more than half of the planning deficiencies identified by the RAC were corrected and the corrective action accepted by FEMA in the Interim Report itself. A subsequent submittal of corrections to be made to the county plans was made by the State to FEMA on March 29, 1984.

5.. Each of the county plans was revised in response to the FEMA Interim Report. The Ashtabula County Plan was revised

?in'May 1984. The Geauga County Plan was revised in March 1984 and in July 1984.' The Lake County Plan was revised in June and October 1984. The-plan revisions reflect corrective actions made in direct response'to the planning' deficiencies noted in' the FEMA Interim Report.

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6. My independent review of the Lake, Ashtabula, and Geauga County

. Plans shows that, of the total of 145 planning deficiencies listed in the Interim Report, all have been corrected or are being addressed.

Attachment "B" hereto shows the planning deficiencies noted in the FEMA Interim Report, those deficiencies acknowledged by FEMA to have been corrected by the August 30, 1983 State submission, those remaining

, deficiencies corrected by the plan revisions made subsequent to the Interim Report and where in revised plans the remaini.ng deficiencies were corrected. The few items still being addressed invoiv'e' emergency information material which will be distributed prior to fuel load.

7. Attachment "B" hereto shows that each of the planning deficien-cies has been, or is being, resolved. These resolutions further support FEMA's conclusion that the county plans are adequate. It is therefore incorrect to claim that the planning deficiencies noted in the FEMA Interim Report indicate that the county plans are inadequate.

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J f(n' Baer e i Subscr'ibed and sworn before I me thi,s .3d" day of _ e Lau W , 1985.

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( Notary Public My Coasntssion Expires: 'i$[igQQjg'mc NT C04!sigicg gyg,g g g y E8:46f. Patsyfteda Anadah ,4 actsfis-

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ENERGY CONSULTANTS Rrversde Omce Centw 3 2101 N. Ffont St. . Hamstxsg.PA 17110 l (717) 23M031 Resume current 01-11-85 JOHN W. BAER Education 1970 Post Graduate Study - Political Science American University Washington, D.C.

1966 Bachelor of Arts - Political Science Western Maryland College Westminster, Maryland Experience 1981 to Present Energy Consultants Harrisburg, Pennsylvania Project Manager, Emergency Management Services. Re-sponsible for providing supervision and technical assistance to project staff. Assigned responsibility for emergency management planning, procedure prepara-tion, personnel training, drill / exercise preparation, licensing support, and scheduling and coordinating project work with the client. Recent project assign-ments have included:

managing the offsite radiological emergency pre-paredness programs for the Counties of Ashtabula, Geauga and Lake (Ohio) to support response to incidents at the Perry Nuclear Power Plant includ-ing establishing operational readiness of county emergency operations centers , offsite drill and .

exercise preparation and ASLB hearing support; managing the offsite radiological emergency pre-paredness re-training program to support response to incidents at the Waterford 3 Steam Electric Station; coordinating the offsite radiological emergency preparedness program to support response to inci-dents at the Callaway Plant including direct responsibility for revision of the Missouri State "dpopo8e Cace 1370 Wouhrgbn Pke . Bridopte Penne r$ces 15017 . (412) 257-1350

John W. Baer '

Page 2 Nuclear Accident Plan and associated local radio-logical emergency response plans, preparation of affidavits to support motions for stannary dispo-sition of licensing contentions, development of local RERP implementing procedures, establishing operational readiness of local emergency operations centers, development of emergency response training programs for local E0C staff officers and emergency workers , and development / conduct of the offsite drill and exercise program; '

- evaluating and preparing revisions to the station and offsite radiological emergency preparedness plans in support of the Palo Verde Nuclear Gener-ating Station;

- development o'f the Louisiana Office of Emergency Preparedness implementing procedures and lesson plans for training of state , parish and local emergency response personnel in support of the Waterford 3 Steam Electric Station; and

- preparation of lesson plans and conduct of training programs for state, county and local emergency response personnel in support of the R. E. Ginna Nuclear Station.

1 1973 to 1980 Southcentral Regional Planning Council Harrisburg, Pennsylvania i

Director. Responsible for administration of an eight-county planning and evaluation program for the Cosson-wealth of Pennsylvania. Assisted local goverments in l planning and development of criminal justice / emergency response communications and automated inforsation l: systems. Developed and revised training courses in data analysis for use by planning and operational personnel at the state and local government level. Assisted with delivery of six 35-hour training sessions for criminal l- justice personnel within a ten-state region. Developed

• and conducted practical ~ group exercises for course

i. participant *.

Planner (1973 to 1978). Assisted local governments in

. planning and development of a range of criminal

• tice l- pmgrams, criminal justice system casuunicati .. and l automated information systems.

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J:hn W. Baer Page 3 Lord Fairfax Planning District Commission 1971 to 1973 Front Royal Virginia Planner. Performed general planning tasks, including criminal justice and emergency response planning for a five-county region of Northern Virginia.

1966 to 1968 U.S. Department of Defense Fort Meade, Maryland Security Specialist. Evaluated security measures for a federal security agency. Provided recessendations for security requirements. Top secret / crypto security clearance.

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ATTACHMENT B

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RESPONSES TO FEMA INTERIM REPORT Lake County 0654 Planning Corrected Per Corrected By Reference In Deficiency Interim Report Plan Revision County Plan Subsequent to Interim Report A. Assignment of Responsibility

-A.1.b. X Att. 6-1

.A.1.e X

-A.2.a X Att. A-7 A.3 - X A.4~ X

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C. Emergency Response Support and Resources C.4 X D. Emergency Classification System D.4 X E. Notification Methods

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. E.6 X E.7 X F. Emergency Communications F.1.d -X

. F.2 X G. Public Education and Information G.1' (Will be addressed in PNPP emergency brochure.and telephone directory.

o inserts)

G.2' (Will be addressed in PNPP emergency brochure and telephone directory inserts)

G.3.a 'X 5 G-03 G.4.b X Q G-03 G.4.c' X

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e Lake County 0654 Planning Corrected Per Corrected By Reference In Deficiency Interim Report Plan Revision County Plan

- H. Emergency Facilities and Equipment-H.3- X H.7 X-H.10- X H.11- X H.12 X 6 H-08 I.- Accident Assessment I.7 X I.8 X J. Protective Response J.9 X

. J.10.a X J.10.b X

.J.10.c X 5 E-07

. J.10.d X

- J.10.e- & f X J.10 g X Att. 6-1 J.12 X

- K. Radiological Exposure Control

- K.3.a X Att. K-2 K.3.b X

'K.4 X 6 K-03 K.S.a X

- L. Medical.and Public Health Support.

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L'.1 ' -X -6 L-03 L.4. X App._4 i M. Recovery and Reentry M.1, X- 6 M-02

' N. Exercises-and Drills N.I.a X 6 N-01

. N.1.b~ X 6 N-01 N.2.a- X 6 N-02 N.2.d X 6 N-02 u'

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4 Lake County 0654-Planning Corrected Per Corrected By Reference In L Deficiency': Interim Report Plan Revision County Plan N.3.a X $ N-03

'N.3.cf. X 9 N-03

' N.3.d X Q N-03

'N.3.e X Q N-03 N.4- X 9 N-04 N. 5 ' X Q N-05

-0. Radiological Emergency Response Training 0.4.b.- X Att.0-2 0.4.c X Att.0-2

.0.4.d. X Att.0-1, Att.0-2 e.5 X 6 0-02 P. Responsiblity for Planning P.7 X App. 4 4

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RESPONSES TO FEMA INTERIM REPORT Ashtabula County 0654 Planning Corrected Per Corrected By Reference In Deficiency Interim Report Plan Revision County Plan Subsequent to Interim Report

.& ~A. Assignment of Responsiblity

'A..1 a X A.1.b X

' A.1.c- X

- A.2.a X

- A .~ 3 X A.4 X E. - Notification Methods E.5 (Will be addressed in'the PNPP emergency brochure and telephere directory inserts)

~ E.7 X

- F. Emergency Communications

' F.1'. c . X

' G. Public Education and Information G.1' -X G.2= '(Will be addressed in PNPP emergency brochure and telephone

' directory inserts)

G.3.a' .X

- G.4.b .X 9 G.3 H. Emergency. Facilities H.10 X H.11 X H.12 X 9 H.4 J.- Protective Response

- a,10.a' X

.- J.10.c' .X-

' J.10.d X

J.10.e & f x 'l J.5, App. 31' 4

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2 Ashtabula County 0654 Planning Corrected Per Corrected By Reference In

' Deficiency-Interim Report Plan Revision County Plan J.10.g- X

J.12 X K. Radiological Exposure Controls K.3.a X 6 K.2 K.3.b X

'K.4- X

.K.5.a X K.5.b X 9 K.6

' L '. Medical and Public Health Support

-L.1 X L.4 X App. 8 N. Exercises and Drills N.1.b X $ N.2

-N.2.a X 6 N.5 N.2.c ~ X 9 N.3 N.3.a X l N.4

N.3.b X Q N.4 N.3.c X' 5 N.4

.N.3.d. .X ' 6 N.4 N.3.e X' i N.4

'N.5 X 9 N.6 0.' . Radiological Emergency Response Training

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0.5 X-

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P. Responsibility for Planning P.7 X P.10 X e

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1 RESPONSES TO FEMA INTERIM REPORT Geauga County 0654-

-Planning Corrected Per Corrected By Reference In

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- Deficiency Interim Report Plan Revision County Plan Subsequent to Interim Report A. Assignment of Responsibility A.1.a X A.I.b X App. 24

- A.I.c X

- A .' 1. e . X

, A.2.a. X A.3 ~ X A.4--

C. Emergency _ Response Support and Resources C.4 X App. 24 D. Emergency Classification System D.4- X E. Notification Methods and Procedures E.5: X E.7 , .X

. F. Emergency Communications.

- F.1.c ' X G. Public Education and.Information G.1- X

, G.2' X

. G.3.a X Q G-4 G.4.b X Q G-4 G.4.c . X G. 5' :X-

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H .~ Emergency. Facilities and Equipment

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- H-11 -X H-12 X  % H-5 6

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Geauga County 0654i

. -Planning. Corrected Per Corrected By Reference In

Deficiency.- Interim ~ Report Plan Revision County Plan

.J. 1 Protective. Response J.10.a- X 9 J-3, App. 21 6 J-6, App. 27

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'J.10.d . X i ._ .J.10.e &:f .'

X 5 J-8 LJ.10.g. -

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-J.12 X 6 J-4(d)

K .L. Radiological Exposure Controls K.3.a X 9 K-2 1K.3.b X K.4 X K.S.a X K.5.b: -X L.--Medical and Public Health Support

L.1 -

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. L.4 ' X App.:7

.. .N. Exercises and Drills

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N.I.b- .X- .6 N-2

'N.2.a X 9.N-3:

N.3.a1 X 9 N-4

-N.3.c7 >

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N.3.e' X l N-4' N.5' ,

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.0.  : Radiological Emergency;Respon'se Training-

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' P. ' Responsibility for Plann'ing Effort.

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hs ENERGY CONSULTAM1S Rrvernde Omcs Cantor 3 (717) 236 0031 2101 N. Ffont St. . Hansbi.rg, PA 17110 Resume current 01-11-85 JOHN W. BAER Education 1970 Post Graduate Study - Political Science American University Washington 0.C.

1966 Bachelor of Arts - Political Science Western Maryland College .

Westminster, Maryland Experience 1981 to Present Energy Consultants liarrisburg, Pennsylvania Project Manager, Emergency Management Services. Re-sponsible for providing supervision and technical assistance to project staff. Assigned responsibility for emergency management planning, procedure prepara-tion, personnel training, drill / exercise preparation, licensing support, and scheduling and coordinating project work with the client. Recent project assign-ments have included:

i managing the offsite radiological emergency pre-paredness programs for .the Counties of Ashtabula, Geauga and Lake (Ohio) to support response to incidents at the Perry Nuclear Power Plant includ-ing estabitshing operational' readiness of county emergency operations centers, offsite drill and exercise prepara tion and ASLB hearing support; managing the offsite radiological emergency pre-paredness re-training program to support response to - incidents ' at the Waterford 3 Steam Electric Station;

- coordinating the offsite radiological emergency preparedness Sprogram to support response to inci-dents at the Callaway Plant including direct l responsibility for revision of the Missouri State 1

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( e Cmke 1370 Wodhhpon Pte . Brd@>Go W 15017 . (412) 257-1350

...3- , . , ,,. . .

John W. Baer

.: Page^2 Muclear Accident Plan and associated local radio-logical emergency response plans, preparation of affidavits to support motions for stannary dispo-sition of licensing contentions, development of local RERP implementing procedures, establishing operational readiness of local emergency operations centers, development of emergency response training programs for local EOC staff officers and emergency workers, and development / conduct of the offsite drill and exercise program;

- evaluating and preparing revisions to the station and offsite radiological emergency preparedness plans in support of the Palo Verde Nuclear Gener-ating Station;

- - development of the Louisiana Office of Emergency Preparedness implementing procedures and lesson plans for training of sta te , parish and local

, emergency response personnel in support of the Waterford 3 Steam Electric Station; and

- preparation of lesson plans and conduct of training

-f -,-

programs for state, county and local emergency

'N response personnel in support of the R. E. Ginna l- Nuclear Station.

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[ ' 1973 to 1980 Southcentral Regional Planning Council

,s Harrisburg, Pennsylvania i

Director. Responsible for administration of an eight-county planning and evaluation program for the Cosmon-wealth of. Pennsylvania. Assisted local governments in planning and development of criminal justice / emergency response connunications and automated information -

9 y systems. Developed and revised training courses in data analysis for use by planning and operational personnel l-

,t '3 at the state and local government level. Assisted with-

,. delivery of six 35-hour training sessions for criminal

,- i

.= , justice personnel within a ten-state region. Developed

'Fl and conducted practical group exercises for course l

L. E participants.

i L Planner (1973 to 1978). Assisted local governments in

! planning and development of a range of criminal justice programs, criminal justice system communications 'and automated inforsation systems.

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John W. Baer Page 3 1971 to 1973 Lord Fairfax Planning District Commission Front Royal. Virginia Planner. Performed general planning tasks, including criminal justice and emergency response planning for a five-county region of Northern Virginia, 1966 to 1968 U.S. Department of Defense Fort Meade, Maryland Security Specialist. Evaluated security measures for a federal security agency. Provided recommendations for security requirements. Top secret / crypto security clearance.

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