ML20106A147

Affidavit of G Winters Re Contention H.Certificate of Svc Encl

ML20106A147
Person / Time
Site:	Perry
Issue date:	02/04/1985
From:	Winters G CLEVELAND ELECTRIC ILLUMINATING CO., EMERGENCY MANAGEMENT SERVICES, INC.
To:
Shared Package
ML20106A129	List: ML20106A127 ML20106A142 ML20106A147
References
OL, NUDOCS 8502110055
Download: ML20106A147 (8)

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r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION  ;

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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"n 37 In the Matter of )

) _

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

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF GARY WINTERS ON CONTENTION H County of Dauphin )

) ss.

JCommonwealth 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 Department of Energy Consultants. My business address is 2101 North Front Street,.Harrisburg, Pennsylvania 17110. .My responsibilities include coordination of offsite resource inventory and assessment efforts involving Lake, Ashtabula and Geauga Counties with respect to the Perry Nuclear Power Plant.

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^ Project activities have included the interview of response agency / facility administrators for resource information, preparation of county resource documents and analysis of d' offsite resource capability to respond to an accident at the Perry Plant. A' current statement of my professional

' qualifications and experience is attached hereto. I have v

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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 H.

'2. The purpose of this affidavit is to note tho

. consistency of local emergency response plans with regulatory guidance on_ radiation exposure levels for emergency workers, s

and the availability of respirators for emergency workers.

I. Regulatory Guidance on Radiation Exposure Levels

3. All of the local emergency response plans establish radiation exposure limits for emergency workers that conform to EPA guidance.1/ See Lake County Plan,2/ Attachment K-3;

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Ashtabula_ County Plan,3/ Appendix 32; Geauga County Plan,4/

Appendix 34. In each case, the exposure limits for emergency

.s- workers are:-

1/~ EPA-520/1-75-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (September 1975, i rev. June 1980) Tables 2.1 and 2.2.

'2/ Lake' County Emergency Response Plan for the Perry Nuclear Power Plant, (Rev. 3, October 1984).

3/c Ashtabula County Radiological Emergency Preparedness Plan

-(May 10, 1984).

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

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a. For other than lifesaving missions:

Projected Whole Body Gamma Dose - 25 ren Projected Thyroid Dose - 125 rem

b. For lifesaving missions:

Projected Whole Body Gamma Dose - 75 rem Projected Thyroid Dose - No limit

-4. A decision chain for authorization of an emergency workerLto exceed the exposure' limits established in the local emergency plans is provided in each of the plans. Lake County

-Plan, 5 K-03; Ashtabula County Plan, S K.4; Geauga County Plan, 5 K-4. In'each local plan, the decision chain provides that the, emergency worker's department head will discuss the need with direction'and control personnel of local emergency

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operations (i.e., the County Commissioners) who, in consultation with the Ohio Department of Health, will concur with,;or disapprove, the increased exposure.

II. Respirators

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5. While NUREG-0654 Evaluation Criterion J.6.a expressly

.provides for the. availability of " individual respiratory protection",for onsite emergency workers, there is no comparable NUREG-0654 criterion providing for respirators for offsite emergency workers.

'6. In any event, respirators are available for use by

. emergency workers.- .The' table-below represents a partial LinventoryS / og:self-contained breathing apparatus ("SCBA")

p .jb/L The inventory of respiratory equipment did not include all fire' departments within the three counties -- only those (Continued next page)

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e is; available to tW counties through municipal fire departments in the counties.

Self-Contained Breathing Apparatus Partial Listing: Fire Departments s' thin the Three Counties County, SCBA Extra Cascade Refill Compressors Tanks Systems Lake 353 345 17 3 Ashtabula 132 125 8 1 ,

Geauga 165 186 8 1

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7. In summary, the local emergency response plans establish

, radiation exposure limits for emergency workers in conformance with applicable regulatory guidance. Further, respirators are av<tilable for use by emergency workers. A Sar N ters ribed and sworn to before day of Fe6 mary,1985.

t .Y- h enexpi Q j Whw (Continued) serving municipalities with a response role specified in the county plans. Therefore, additional res that identified in the inventory)piratory is locally protection available toequipment the counties. (beyond 4

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• Hansourg,PA 17110 Resume Current 01-11-85 GARY A. WINTERS Education 1975 Bachelor of Science - Law Enforcement y Pennsylvania State University University Park, Pennsylvania Experience 9-81 to Present Energy Consultants Harrisburg, Pennsylvania i

Planner / Trainer, Energency Management Services. Re-sponsible for provision of direct consultant services to assist state and local goverreents and industry in caergency managenent planning, procedure preparation and program accreditation / licensing. Recent project as-signment has included coordinating and perfonsing a detailed audit of the offsite emergency preparedness program in support of the Perry Nuclear Power Plant Atomic Safety and Licensing Board hearings. Assignment as project coordinator involved responsibility for development of audit criteria; plan / procedure review; documentation of program weaknesses; and resource verification. Prior project assigreents have included:

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- Development of four county radiological emergency i

response plans in support of the Callaway Plant; i

. - Develo; ment 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-l sponse plan in support of the Beaver Valley Power Station.

Corpose oncet ismwatecpan Pte . IMdgmes. W 15017 . (at2) 2571360 yo -

Gary A. Winters

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-4 76 to 9-81 Dauphin County Harrisburg, Pennsylvania Juvenile Court Probation Officer. knaged caseloads, investigated . cases of delinquency, prepared legal decanents, and testified in court hearings; coordinated the delivery of haun services to delinquent youth among various public and private institutions. Advanced to Assistant Supervisor of Predispositional ,

Services.

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

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

• security clearance.

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i 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

)

f(Perry Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I:hereby certify that copies of " Applicants' Motion For Summary Disposition of Contention H," " Applicants' Statement of Material' Facts As To which There Is No Genuine Issue To Be Heard on Contention H" and " Affidavit of Gary Winters on Contention H,".were served this 5th day of February, 1985, by

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deposit in the U.S. mail, first class, postage prepaid, upon ,

.the-parties listed on the attached Service List, except for

.those parties identified by asterisk who were served by hand.

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' Dated: February 5, 1985.

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y kN 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 LJtmes 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 LMr.: 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.-GlennLO. Bright it Colleen P. Woodhead, Esquire Atomic Safety and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission- Director Washington, EF.C. 20555 U.S. Nuclear Regulatory Commission Washington-, D.C. 20555 Alan S.:Rosenthal, Chairman

, Atomic: Safety and-Licensing 4tTerry Lodge, Esquire Appeal Board _ Suite.105

- U.'S... Nuclear Regulatory Commission 618 N. Michigan Street

'Wnshington,-D.C.L 20555 Toledo,-Ohio. 43624

Dr 1W. Reed Johnson.

. Donald T. Ezzone, Esquire Atomic Safety and Licensing ~ Assistant Prosecuting Attorney.

AppealJBoard Lake County Administration

>U.S.: Nuclear Regulatory Commission Center

.W shington,-D.C.- 20555- 105 Center Street Painesville, Ohio 44077

G ryl'J. Edles, Esquire

. Atomic SafetyLLad-Licensing. . Atomic Safety and Licensing Appeal Board: Board Panel LU.S. Nuclear Regulatory _ Commission U.S. Nuclear Regulatory Commission LWashington, D.C. -20555 ,

Washington, D.C. 20555 TJdhn G. Cardinal,_ Esquire. & Ms. Sue.Hiatt Prosecuting Attorney- 8275 Munson-Avenue Achtabula. county. courthouse Mentor, Ohio '44060

'JGfferson, Onio- 44047-

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