ML20104A963

Affidavit of DD Hulbert Re Contention Cc.Certificate of Svc Encl

ML20104A963
Person / Time
Site:	Perry
Issue date:	01/30/1985
From:	Hulbert D CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20104A913	List: ML20104A909 ML20104A956 ML20104A963
References
OL, NUDOCS 8502010599
Download: ML20104A963 (11)

Text

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- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Dcr ;ETED m,:c BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'85 JM 31 p;; gg In the Matter of ) .-

) ' to s SEe/.r;r THE CLEVELAND ELECTRIC ) Docket Nos. 50-440  ? 29 ILLUMINATING COMPANY ) 50-441

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF DANIEL D.

HULBERT ON CONTENTION CC 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 (CEI).- 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 plan-ning documents and specification of response requirements.

These responsibilities include responding to resolution items identified by.the NRC Staff on its review of the PNPP Emergency Plan. A current statement of my professional and technical qualifications is attached hereto. I have personal knowledge h

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of the matters stated herein and believe them to be true and I correct. I make this affidavit in support of Applicants' Mo-i tion for Summary Disposition of Contention CC.

2.- Contention CC states that the resolution items set forth by the NRC Staff in Supplement 4 (February 1984) to the Safety Evaluation Report, NUREG-0887 (SSER 4), pages 13-1 to 13-22, are uncorrected deficiencies in the emergency plan. The referenced pages in SSER 4 set forth the NRC Staff's evaluation of the'PNPP Emergency Plan (through Revision 2) and identified 35 items which required resolution.

3. By letter dated April-28, 1984 (PY-CEI/NRR-0105 L),

CEI transmitted to the NRC Staff Revision 3 to the PNPP Emer-gency Plan, as well as a cross-reference between the resolution item in SSER 4 and where in Revision 3 those items had been re-solved. By letters dated August 20, 1984 (PY-CEI/NRR-0135 L) and October 29, 1984 (PY-CEI/NRR--149 L), CEI provided to the NRC Staff additional clarification of changes to the PNPP Emer-gency Plan which relate to resolution items in SSER 4 and which will be incorporated in Revision 4 to the PNPP Emergency Plan, scheduled for submission on February 28, 1985. The information contained in Revision 3 and the subsequent correspondence dem-onstrates that all the resolution items in SSER 4 have been ad-dressed and that they_are not uncorrected deficiencies in the PNPP emergency plan.

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4. The-tallowing paragraphs summarize each resolution item and CEI's' response.

a. Item 13.3.2.2(1) requested that augumented shift staffing be made consistent with Table 2 to NUREG-0737, Supp. 1. This consistency was achieved

.in the October 29, 1984 CEI letter (55 5.2.2.2, 5.2.2.4,'5.2.3 and Table 5-1 of the PNPP Emergency Plan)..

- b. -Item 13.3.2.2(2) requested additional de- ,

tail on the process of transferring responsibilities

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to the Emergency Coordinator. This information was provided in SS 5.2.2.4 and 6.1.3 of the Plan (Rev.

3).

c. Item 13.3.2.2(3) requested clarification that the Emergency Coordinator could not delegate the duties of notifying and making protective action rec-

-ommendations'to offsite authorities. This was done

, in SS 5.2.2.1, 5.2.2.3 and 5.2.2.4 of the Plan (Rev.

!3).

d.. Item 13.3.2.2(4) requested clarification that.the Emergency Coordinator maintains unilateral control of the overall emergency response. This was

-accomplished in Rev. 3 of the Plan, SS 5.2.1, 5.2.2.1,.5.2.2.3, 5.2.2.4 and 6.1.2.

e. Item 13.3.2.3(1) requested that the expect-

- - ed arrival times of federal assistance be indicated.

~ This information was. incorporated in 5'5.4.4 of the Plan (Rev. 3).

f. Item 13.3.2.3(2) requested clarification of the: radiation detection capabilities of the Post Ac-cident~ Monitoring System (PASS)<and the capabilities ofiTechnical Support Center (TSC)-and Emergency Oper-ator Facility (EOF) laboratory equipment. This in -

formation"Was'provided in Plan (Rev. 3), S 7. 3. 9, -

with clarification.in the. August'20, 1984 letter, and further~ revision toi$ 7.3.9 in'the 0ctober- 29, 1984 CEI-letter.

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'. ;g. Item 13.3.2.3(31- requested that provisions forLbackup laboratory fac.lities be made consistent with NUREG-0737. This'was added in Rev. 3 of the Plan,'S 7.3.9Jand further clarified in the August'20,

. 1984 letter.

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h. Item 13.3.2.4(1) asked that the Plan incor-porate into the emergency classification scheme com-ments contained in NRC Staff's January 11, 1984 let-ter. This was done in Rev. 3, Table 4-1, except for the comment on low water level, which CEI showed to be inapplicable to Perry in the April 28, 1984 let-ter. Further clarification was provided by the August 20, 1984 letter.

i. Item 13.3.2.4(2) called for the Plan to in-dicate that Emergency Action Levels are agreed upon by state / local authorities and are reviewed annually.

This was. included in S 8.2 of the Plan (Rev. 3) and further updated by the August 20, 1984 letter.

j. Item 13.3.2.4(3)(a), which called for the Plan to discuss nonradiological means of core status determination, was withdrawn by the NRC Staff by let-ter dated February 29, 1984.

Item 13.3.2.4(3)(b) requested a discussion of the relationship between gap activity and failed fuel percentage as it relates to protective action recommendations. This was provided in Rev. 3, SS 4.1.4 and 6.4.3, with minor changes to the Tables in these sections added by the October 29, 1984 let-ter.

Item 13.3.2.4(3)(c) requested that the Plan 41scuss how the core status graph (Fig. 4-1) will be used in the emergency action level scheme. This was provided in Rev. 3, SS 4.1.4 and 6.4.3, with minor changes to the Tables in these sections added by the October 29, 1984 letter.

k. Item 13.'.2.5(1) requested that the Picn describe the methods for prompt notification of the, public in a rapidly escalating emergency. This was addressed in 5 6.4.2 of the Plan (Rev. 3), and fur-

ther clarified in the August 20, 1984 letter.

1. Item 13.3.2.5(2) called for-the Plan to ad-dress periodic testing of the sirens. This was done in Rev. 3, S 7. 2. 5. -

m. Item 13.3.2.6(1) requested Applicants to provide for backup communications capabilities be-tween the site and all state / local authorities with primary response responsibilities. Backup communica-tions capabilities are provided, as described in

'S 7.2.2 and Fig. 7-6 of the Plan (Rev. 3), as further clarified by the August 20 and October 29, 1984 let-ters.

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n. Item 13.3.2.6(2) requested a coordinated

, icommunications link for fixed and mobile medical sup-sport 1 facilities. Information on this link was pro-

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vided in Rev. 3,.S 7.2.2.8, and by the August 20, 1984 letter.

N o. Item 13.3.2.7(1) requested that Applicants provide finalized emergency information brochures and other_ emergency information materials to the public before fuel load. This committment was added in Rev.

'3, S 8.4.1.1.

p. Item 13.3.2.7(2) called for the Plan to

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-specify the location of the Joint Public Information Center. .Rev. 3~of the Plan added this in S 7.1.4.

q. Item 13.3.2.8(1) requested that the Plan specify the time: required to bring the TSC and EOF to functional readiness. This information was added in Rev. 3 of the Plan, 5 5.2.3.

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r. Item 13.3.2.8(2) requested that the Plan

' indicate that emergency equipment and supplies will be available in the control room. The Plan should also specify;the calibration frequency for emergency instrumentsLand that instrument's removed from service will'be replaced'by comparable instruments. NRC withdrew the' request to specify calibration frequency

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by letter dated February 29, 1984. The remaining in-formation was provided in Rev. 3, S' 8.3 and Appendix' C.and in the August 20, 1984- letter.

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-s.' Item 13.3!2.8(3)' called for the' Plan to de-scribeLthe capability.to.obtain 24' hour /dayJregional weather information, consistent with~NUREG-0737, Supp._1. This-information'was provided,in the August 20, 1984, letter;(5 7.3.7)Dand in a' letter off

- agreementito be added to Appendix'B.

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t.. Item 13.3.2.8(4). requested a commitment ~

that permanent: emergency response facilities-and-

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equipment be operational before fuel loading or that adequate interim 1 facilities and capabilities be in place.- Asf noted :in ithe April .28,1984 :letterf this

, commitment had;previously been made by letter'from-M.R.=Edelman to B.J.'Youngblood dated April 15, 1983

-(PY-CEI/NRR-0032).

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.u. Item 13.3.2.9(1) called _for, additional in-

-formation in the Plan on radiation monitoring-teams, s ' including staffing' levels consistent with NUREG-0737,

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-Supp.ul, and. transportation availability. This in-

~ -formation was provided in the August 20 and .

l October- 29,:1984 letters (55 5.2.2.2, 5.2.2.4, 5.2.3, j

~ . Table 5-1). '

.. v. Item 13.3.2.10(1) requested more details in the Plan on evacuating visitor and/or contractor per-sonnel. .This information was incorporated in Rev. 3, 5 6.4.1 and Figure.6-7, and further addressed in the

. October 29, 1984? letter.

w. Item 13.3.2.10(2) called for the Plan to describe personnel monitoring methods and decontamination supplies, and to indicate.that per-sonnel accountability will.be accomplished within 30 minutes. This was done in Rev. 3 in 5 6.4.1, 6.5.3 and Appendix C.

x.. Item 13.3.2.10(3) called for the evacuation

. time. estimate study to address the effects of adverse iweather (i.e. thunderstorm).on a summer Sunday evacu--

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tation and to indicate that the evacuation time esti--

mates have been reviewed-by appropriate state / local individuals. The April 28, 1984 letter stated-that

- - the evacuation. time estimate study was being reviewed by State andflocal officials and that adverse weather effects were addressed in the. time estimate study in-corporated in Rev. 3 of the. Plan.

y. Item 13.3.2.11(1) stated that the Plan-should indicate that each emergency worker will re-

.ceive a self-reading and;a permanent record dosimeter

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and.the' emergency. personnel dosimetry program has-the capability of.24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day dose determination. This

'was'done in Rev. 3, 5'6.5.1.

z.- -Item 13.3.2.11(2) requested the Plan to

-_specify contamination action levels. and . to : indicate that decontamination supplies include materials capa-

ble:of radioiodine' skin decontamination. .This was yaddedJinLRev.. 3, 5 6.4.4.1, 6.5.3 and-Appendix C.

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aa. Item'13.3.2.12(1) called-for the Plan to

?? includefa letter of agreement'with. Northwestern Memo-si 1- rial' Hospital. As' stated in'the April. 28, 1984,'let-

ter,'and in Rev. 3, 5 5.3.3.2,' the arrangements with

- b -Northwestern Memorial Hospital were made through r e CEI's medical consultant,' Radiation Management.Corpo-ration (RMC). ;CEI has a letter of agreement with RMC d

94@ which is included in the Plan, App. B.

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'S bb. Item 13.3.2.12(2) requested a more detailed Y afi 4^ discussion in the Plan on first aid personnel, 4 ' including training at least equivalent to Red Cross

' Multi-Medic training and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day availability.

This-information was provided in Rev. 3, SS 6.5.3, 8.1.3.

O cc.. Item 13.3.2.14(1) called for the Plan to

' reflect the regulatory requirements on the frequency of emergency exercises and drills. This was done in Rev.13, S 8.5.4.2, and in the August 20 and October 29, 1984 letters ($ 8.5.4.1).

f dd. Item 13.3.2.14(2) requerted that the Plan

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indicate that the exercice scenario will be varied over a 5-year period to ensure testing of all major portions of~the Plan, that the exercise will include public notification system testing, and that the ex-ercise will be conducted under various weather condi-tions. This' commitment was provided in Rev. 3, N

5 8.5.4.1.

ee . ' Item 13.3.2.14(3) called for the-Plan to

-indicate that part of each communication drill will involve evaluating message understandability. This information was provided in Rev. 3, S 8.5.4.3, as

[ supplemented by the August 20, 1984 letter.

, 'ff.- Item 13.3.2.15(1) requested the Plan to in-dicate that initial and annual retraining of emergen-s .cy personnel will be provided. This information was fprovided.in Rev. 3, S 8.1.3.

g- gg.. ' Item'13.3.2.16(1)' called for the Plan to specify that the Nuclear Safety Review Committee has c no direct responsibility for emergency preparedness planning,;to' describe in~more detail the. Committee's scope of review,:and'to indicate that there are ad-ministrative means for correction of deficiencies.

ThisLwas.done in Rev. 3,.S 8.2,-as supplemented-by

.the-October 29, 1984 letter.

. hh. Item'13.3.2.16(2) requested more descrip-

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. tion'of.the administrative. procedures for revising the Plan.and implementing procedures, including-an

," indication;that revised pages are dated and marked tx). .

'show the changes. This information was provided in Rev. 3,'518.2.

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. iii. Item 13.3.2.16(3) requests that Appendix F

~ ;of the Plan be updated. Revision 3 of-the Plan

' updated Appendix F.-

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5. In suremary, CE: has responded to and has recolvcd (or  ;

is resolving) all the resolution items set forth by the NRC Staff in Supplement 4 to the Safety Evaluation Report, pages I

13-1 to 13-22. These items are not uncorrected deficiencies in the PNPP Emergency Plan.

f A-d Daniel D. Hulbert j Y

Subscribed to and sworn by me this 1 day of January, 1985.

A VNotary PulbPi{

10$9H C. 5!WIK0W5KI neecy we, swe et oe.m em. cw ley Castrussen lapim Jufy 14, 1986 My Co..

T mission expires:

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

Electrician's }kte 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,198 L One-Week 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 tne 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 SSW Class Submarine. Duties included operation and maintenance of electrical systems, chemistry .ontrols for both primary and secondary plant, apd routine and emergency health physics coverage. As signments

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

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UNITED STATES OF AMERICA 'ME D NUCLEAR REGULATORY COMMISSION ~ FC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD vs wu. ;

AM:59 In the Matter of ) b bshe$E.t

) MANCH 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 CC," " Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard on Contention CC" and " Affidavit of Daniel Hulbert on-Contention CC," were served this 30th day of January, 1985, by

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

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' '. Silbe'rg DATED:

January 30, 1985 m -- . -

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.6 UNITED STATES OF AMERICA i 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 l

)

(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 LWashington, 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 LAtomic 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 Proseculing Attorney 8275 Munson Avenue

'Ashtabula County Courthouse Mentor, Ohio 44060 Jefferson, Ohio 44047

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