ML20102A818

Affidavit of G Winters Supporting Motion for Summary Disposition of Contention B Re Potential Evacuation Route Impediments

ML20102A818
Person / Time
Site:	Perry
Issue date:	02/07/1985
From:	Winters G CLEVELAND ELECTRIC ILLUMINATING CO., ENERGY CONSULTANTS, INC.
To:
Shared Package
ML20102A776	List: ML20102A774 ML20102A784 ML20102A809 ML20102A818 ML20102A832 ML20102A841 ML20102A858
References
OL, NUDOCS 8502080579
Download: ML20102A818 (9)

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~8 70:15 UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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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 B County of Dauphin )

) ss.

Commonwealth 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

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Geauga Counties ~with respect to the Perry Nuclear Power Plant.

Project activities have included the interview of response

' agency / facility administrators for resource information, preparation of county resource documents and analys*s of 8502080579 850205-PDR ADOCK 05000440 g .PDR.

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l Y offsite resource capability to respond to an accident at the Perry Plant. A current statement of my professional l

qualifications and experience is attached hereto. I have i personal knowledge of the matters stated herein and believe  ;

them to be true and correct. I make this affidavit in support of Applicant's Motion For Summary Disposition of Contention B.

2. The purpose of this affidavit is to explain the consideration of potential evacuation route impediments (such as snow and disabled vehicles) in offsite plans for the Perry plume exposure pathway Emergency Planning Zone ("EPZ") as well as the ability of the counties in the EPZ to handle extreme conditions of inclement weather. As indicated in the plans and procedures, resources such as tow trucks and snowplows are utilized to keep evacuation routes clear. See, e.g., Lake County. Plan,l/ S J-08; Ashtabula County Plan,2[ S J.4.2; Geauga County, Ohio Radiological Emergency Response Plan Standard Operating Procedure.

3. .The; jurisdictions within the EPZ are particularly well prepared to handle snow. Because the agencies charged

-with responsibility for snow removal within the'EPZ are

equipped.and staffed to keep the roads passable in a normal

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

2/ Ashtabula County Radiological Emergency Preparedness Plan (May 10, 1984).

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3' " snowbelt" snowfall, normal snow conditions require no special consideration in emergency planning for the Perry EPZ. l

4. Of the 22 road departments within the EPZ, most could keep roads passable with no assistance even during a blizzard.

During an emergency, the county governments have the authority to coordinate the response of the various political subdivisions within a county. Lake County Plan, 5 A-08;

-Ashtabula Codnty Plan, S B.5; Geauga County Plan,3/ 5 B-4. .

Municipal road departments are included in the group of local I

departments subject to county-level coordination. The County Engineers are charged with maintaining roads within the EPZ in

! usable condition, and will coordinate impediment removal efforts. Lake County Plan, 5 J-08; Ashtabula County Plan, Appendix 6; Geauga County Plan, Appendix 4. Thus, in the unlikely event of an emergency at Perry during a blizzard, the.

resources of all road departments throughout Lake, Ashtabula, and Geauga Counties would be made available to augment the

. resources of any road departments within the EPZ which might need assistance in keeping roads passable.4/ With the 3/ Geauga County Radiological Emergency Response Plan (including Change No.:2 dated' July-1984).

4/- Indeed, under particularly inclement-weather conditions (i.e., snow accompanied by high winds), only~the downwind sector of the' plume EPZ'is likely to be affected by an

, emergency at Perry. Therefore,-~should evacuation ~be.

indicated in such conditions, the snow removal resources

-of the three counties could be concentrated on the~ sector-ofLthe'EPZ-to be evacuated.,

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assistance of these road departments from outside the EPZ, the few road departments within the EPZ which may need assistance will have sufficient snow removal resources to keep the roads clear in a blizzard.

5. A partial surveyE/ of road departments within the three counties revealed an impressive inventory of snow removal equipment. The 23 road departments surveyed in Lake County have a combined total of 139 large trucks with snow plows, 117 salt / cinder spreaders, 32 front-end loaders, and 13 graders.

The 12 road departments surveyed in Ashtabula County have a combined total of 88 large trucks with. snow plows, 58 salt / cinder spreaders, 22 front-end loaders, and 15 graders.

The 11 road departments surveyed in Geauga County have a combined total of 64 large trucks with snow plows, 58 salt / cinder spreaders, 16 front-end loaders, and 11 graders.

Additional snow removal equipment is available locally, from the other road departments within the three counties.

6. Still more snow removal equipment (if needed) would be provided from Ohio Department of Transportation resources outside the three counties, upon-the request of one of the three County Engineers. State Plan,l/'SS II.A.4.b(5)(d),

. 5/- The survey did not canvass all. road. departments within the-three counties -- only those serving municipalities with a response role specified in the county plans. Therefore, additional snow removal equipment (beyond that identified in the survey)'is-locally.available to the counties.-

6/ State of Ohio Plan For Response to Radiological Emergencies at Licensed Nuclear Facilities (1984 ed.).

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II.A.4.b(5)(e)3, V.2.e(4).

7. Sunflower's further argument that the Perry facility should be required to go to low power or no power operation during extreme conditionr. of inclement weat'..er is also inconsistent with the snow removal capabilities within the three counties and the frequency of major snowstorms in this area. According to Miller & Weaver, Research Bulletin 1044:

Snow in Ohio (Ohio Agricultural Research and Development Center, 1971), base'd on 29 years of data, the frequency of snow fall in excess of eight inches for the locations within the plume EPZ is 0.92 mean days per season (Painesville) and 0.85 mean-days per season (Geneva). The frequency of snow fall in excess of twelve inches is 0.21 mean days per season (Painesville) and 0.20 mean days per season (Geneva). The frequency of snow falls in excess of 12 inches together with high winds is undoubtedly even less frequent.-

8. Interviews with the County and State road departments

' indicate that with snowfalls of eight inches or less, the roads can be kept passable with existing resources. The road departments also indicated that under " worst case" weather-conditions (i.e., 12 or more inches of snow in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with high wiads), all evacuation routes could be kept open without resources from outside the three counties by marshalling the available resources within the counties in the EPZ area. This' does not consider resources from outside the three counties a

which would be available through the Ohio Department of Transportation.

9. This information demonstrates that even extreme conditions of inclement weather would not make evacuation impossible for any substantial periods of time. Although there have been instances (for example the " Blizzard of '78") when some roads in the area near the plant remained snowed in for a few days, in these few cases there was no attempt to marshall available resources to clear a particular area. Our review of the available resources and interviews with County and State road departments indicate that even in the " Blizzard of '78,"

all evacuation routes could have been kept open by focusing the available resources on these routes. -

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In sumary, the offsite emergency plans for Perry reflect adequate consideration o#patential evacuation route spediments A lu@ ng snow.

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and sworn to before day of February, 1986.

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Resume Current 01-11-85 GARY A. WINTERS Education 9

1975 Bachelor of Science - Law Enforcement Pennsylvania State University University Park, Pennsylvania Experience 9-81 to Present Energy Consultants Harrisburg, Pennsylvania Planner / Trainer, Emergency Management Services. Re-sponsible for provision of direct consultant services to assist s tate and local goverreents and industry in emergency management planning, procedure preparation and program accreditation / licensing. Recent project as-sigreent has included coordinating and performing a detailed audit of the offsite emergency preparedness program in support of the Perry Muclear 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 assigmnents have included:

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- Development of four county radiological emergency response plans in support of the callaway Plant; l . - Development of local emergency response agency l implementing procedures in support of the Water-i ford 3 Steam Electric Station; and

- Revision of a county radiological emergency re-sponse plan in support of the Beaver Valley Power Station.

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Capampe omos 1370 WouNngeon Pte . arksomes PenrwrMmia 15017 . (a12) 257-132io l

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Gary A. Winters

Page 2 4 76 to 9-81 Dauphin County Harrisburg, Pennsylvania Juvenile Court Probation Officer. Managed caseloads, investigated cases of delinquency, prepared legal doceents, and testified in court hearings; coordinated the delivery of haan services to delinquent youth among various public and private institutions.

Assis tant Supervisor of Predispositional Advanced to Services.

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

quality controller, and shift leader. Received a " top secret

• security clearance.

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