ML20207Q334
| ML20207Q334 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/20/1987 |
| From: | Hulbert D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | |
| Shared Package | |
| ML20207Q326 | List: |
| References | |
| 2.206, NUDOCS 8701270177 | |
| Download: ML20207Q334 (8) | |
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DO( KE TEP Ui$ikC UNITED STATES OF AMERICA
,87 JAN 23 All :34 NUCLEAR REGULATORY COMMISSION Before The Director, Office of Inspection And. Enforcement Docet In the Matter of
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CLEVELAND ELECTRIC
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Docket No. 50-440 ILLUMINATING CO.,
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(10 C.F.R. $ 2.206)
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(Perry Nuclear Power Plant,
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Unit 1)
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AFFIDAVIT OF DANIEL D. HULBERT IN OPPOSITION TO SUNFLOWER 6 2.206 PETITION County of Lake
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ss.
State of Ohio
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Daniel D. Hulbert, being duly sworn, deposes and says:
1.
I am the Emergency Planning Supervisor, Perry Services Department, The Cleveland Electric Illuminating Company ("CEI").
My business address is 10 Center Road, Perry, Ohio 44081.
In my l
position, I am responsible for developing, maintaining, and l
evaluating the Emergency Preparedness Program for the Perry Nuclear Power Plant (" Perry"), including coordination with local, State, and Federal agencies to assure an effective Emergency Pre-paredness Program.
I have been involved in emergency planning for Perry since 1980, and have been responsible for coordination of the exercises conducted at Perry.
I have completed numerous 12]Q [3$
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O courses in radiological emergency management, including the Advanced Course on Nuclear Emergency Planning offered at the
-Harvard School of Public Health.
2.
I have reviewed "Intervenor Sunflower Alliance's Motion To Reopen,the Record and To Submit New Contentions or Alterna-tively For Applicant To Show Cause Why Its Licenses Should Not Be Modified or Denied," including the attached " Affidavit of Theresr.
M. Burling" and the July 14, 1986 letter from the Superintendent of the Jefferson Area Local School District.
I have prepared this Affidavit in opposition to Sunflower's Motion.
I have per-sonal knowledge of the matters set forth in this Affidavit and believe the information set forth herein to be true and correct.
As discussed more fully below, the allegations of the Motion are lacking in basis, and cast no doubt on the adequacy of the emer-gency plans for the Perry plant.
3.
There is no merit to Sunflower's challenge to the read-iness of reception / congregate care centers in Geauga County.
The survey referenced by Ms. Burling -- who is not identified as-holding any official position in either the Geauga County school system or the Geauga County government -- reflects a fundamental misconception about the concept of operations for recep-
-tion / congregate care centers in an emergency.
There are ten re-ception/ congregate care centers in Geauga County.
Four of these are designated " primary" centers, and would be opened in the event of an evacuation of any part of the EPZ; the others are
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" secondary" centers, and would be opened -- as needed -- if pri-J mary centers were full.
The ten reception / congregate centers in Geauga County have a combined capacity of 12,891 evacuees.
How-ever, those centers are not expected to accommodate that number of people in an actual emergency.
Of the approximately 90,000 persons in the Perry EPZ, only about 2,000 live in Geauga County.
Thus, there is excess capacity in the Geauga County centers, as
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there is in the centers in Ashtabula and Lake Counties as well.
For planning purposes, it has been assumed that up to 18,000 per-sons (20% of 90,000) may use a care center.
The ten primary cen-ters and the 23 secondary centers in Lake, Ashtabula and Geauga 1
Counties have a combined capacity of 36,272 persons -- more than double FEMA's conservatively projected need.
4.
Sufficient supplies (such as food, clothing, cots and bedding) would be available for evacuees in Geauga County.
By agreement with the County and with the State, the American Red Cross would provide cots, blankets and other items at the care centers.
The school food supply in addition to local purchases
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would be used to feed evacuees.
These provisions are reflected in the Standard Operating Procedure (" SOP") developed by the Red Cross for use in operation of Geauga County reception / congregate care centers.
Moreover, the emergency public information bro-chure disseminated annually throughout the EPZ reminds residents j
to pack extra clothing and bedding if they are asked to evacuate.
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These provisions are comparable to measures taken for other i..
plants across the country, and demonstrate full compliance with the Commission's regulations.
5.
Arrangements have been made for the use of the desig-nated schools as Geauga County reception / congregate care centers in the event of a radiological emergency at Perry.
All desig-nated schools have SOPS for operation-as emergency recep-tion / congregate care centers.
The SOP for Kent State University-Geauga Campus is signed by the Administrator of that institution, and letters of agreement have been obtained for the use of Geauga County school facilities and equipment.
This docu-mentation is included in the Geauga County Plan.
In addition, the Superintendent of the Geauga County Schools serves as a mem-ber of the County EOC staff, to direct school district operations in the event of a Perry emergency.
These measures provide rea-sonable assurance that the designated schools would be available for use as reception / congregate care centers in Geauga County in an emergency.
6.
Contrary to Sunflower's assertions, the July 1986 let-ter from the Superintendent of the Jefferson Area Local School District does not rescind its May 1986 letter of agreement.
Rather, as indicated in a July 18, 1986 letter of clarification from the Superintendent to CEI, the July 14, 1986 letter simply reiterated the Superintendent's understanding that the May 1986 letter was not intended to be a legally enforceable " contract or agreement."
There is no indication whatsoever that the school,
s district would refuse to provide resources in the event of a ra-diological emergency.
Indeed, in a discussion with Perry emer-gency planning personnel the week of November 18, 1986, the school district at issue reaffirmed its willingness to assist in an emergency.
7.
In an attempt to support its argument that school bus drivers may not respond in a radiological emergency, Sunflower inappropriately relies on an October 13, 1986 non-binding resolu-tion of the Ohio Association of Public School Employees
("OAPSE").
However, the local bus drivers' participation in the ongoing radiological emergency preparedness training program dem-onstrates their continued support for Perry emergency planning.
This program includes lesson plans, student hand-outs, and audio-visual aids, and covers topics such as plan overview, bus drivers' role in emergency response, basic radiation principles (including the use of dosimetry), and radiation health effects.
The program compares favorably with those offered to bus drivers at other plants across the country.
8.
Training for those bus drivers in Lake, Ashtabula and l
Geauga Counties with roles in emergency response commenced in 1984.
Initial training of personnel from all school districts with emergency response roles in the three counties was completed j
in 1985.
The training program has been expanded to address the specific concerns raised recently by the bus drivers' union, to l
include a discussion of radioprotective drugs, and to allow more l
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3 question and answer interaction.
As of January 20, 1987, 332 persons have completed annual bus driver training (including 30 bus driver aides assigned to buses for special education chil-dren).
Training for the remaining school districts will be com-pleted in the near future.
In addition, a separate course for school district transportation offices has been designed.
That course emphasizes the role of the transportation office in coordinating with the superintendent's office, bus drivers, and the county Emergency Operations Center.
The course also addresses specific duties such as notification, dosimeter charg-ing, and recordkeeping and reporting responsibilities.
Both the bus driver training program and the transportation effice training program are expected to be completed in the first quar-ter of 1987.
These are annual training programs which are sub-ject to modification and improvements each time they are con-ducted.
9.
Sunflower also implies that Ashtabula County Medical Centers ("ACMC") is not capable of treating victims of a ra-diological accident.
But, contrary to Sunflower's implication, ACMC continues to be accredited by the Joint Commission on Ac-creditation of Hospitals ("JCAH"), which has standards for facil-ities and requires procedures for the emergency management of ra-diological accident victims.
JCAH accreditation has been accepted by the NRC and FEMA as assurance of adequate medical treatment capability.
A February 21, 1986 letter from the JCAH, _.
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based on its September 1985 onsite inspection, reaffirmed ACMC's accreditation for three years.
The JCAH's approval of provisions for treatment of contaminated injured persons was without " con-tingency" (i.e.,
an unconditional approval).
Comprehensive ra-diological emergency training has been provided to ACMC staff by the State of Ohio and by Radiation Management Consultants
("RMC").
In addition, ACMC is presently developing an inhouse radiological emergency medical training program, based on a pro-gram developed by the Emergency Management Institute of the Na-tional Emergency Training Center.
To facilitate the development of ACMC's inhouse training capability, CEI sponsored the atten-dance of an ACMC Emergency Room physician at a four day course on medical management of radiological emergencies held by the De-partment of Radiation Therapy of the Hospital of the University of Pennsylvania in August 1986.
Additional training for ACMC emergency room personnel, to be conducted by RMC, is scheduled for February 19 and 20, 1987.
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4 10.
Perry emergency planning meets or exceeds all applicable regulations, and is adequate to protect public healta and safety. Sunflower's allegations are merttless, and provide no evidence of even one violation of the Commission's regulations. Certainly they do not demonstrate the potential for a substantial health or safety issue.
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Cake'I~U. Tiulbert Sworn and subscribed to before me this doff day Of January,1987.
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