ML20101S926

Affidavit of J Baer Re Contention C.Certificate of Svc Encl

ML20101S926
Person / Time
Site:	Perry
Issue date:	02/01/1985
From:	Baer J AFFILIATION NOT ASSIGNED, CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20101S903	List: ML20101S901 ML20101S915 ML20101S926
References
OL, NUDOCS 8502050717
Download: ML20101S926 (9)

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UNITED STATES OF AMERICA @

NUCLEAR REGULATORY COMMISSION " {'fD -

BEFORE THE ATOMIC SAFETY AND LICENSING BOARU5 R3 -5 Ao s;

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In the' Matter of )

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bbff}.dd@.%7Ar hUf THE CLEVELAND E7ECTRIC ) Docket Nos. 50-440

-ILLUMINATING COMPANY ) 50-441

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(Perry Nuclear Power Plant,- )

Units 1 and 2) ).

AFFIDAVIT OF JOHN-BAER ON CONTENTION C County of Dauphin )

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Commonwealth of Pennsylvania )

JOHN BAER, being duly sworn, deposes and says:

1. I am presently Project Manager for Emergency Manage-ment Services, Energf Consultants, Inc. ("ECI"). My business address is 2101 North Front Street, Harrisburg, Pennsylvania 17110. In my position, I am project manager for offsite ra-dialogical 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 qualifica-tions and experience is attached hereto. I have personal knowledge of the matters stated herein and believe them to be true and correct. I make this affidavit in support of Appli-cants' Motion For Summary Disposition of Contention C.

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~6: 5 B-2,-p. B-1; 5 B-3, p. B-5; 5 B-6, p. B-7; Ap-pendix 6.

b. Receiving recommendations from the Perry plant, the. State, and other sources. See L Lake County Plan at 5 A-05, pp. 24-25; 5 J-01, 1

p. 118; Ashtabula. County Plan at 5 A.3, p. A-3; .

1 5 J.3, p. J-2; and Geauga County Plan at 5 A-5, I

p. A-3;-S A-5, p. A-4.

'c. Making protective action decisions for

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the public within their respective counties.

'See Lake County Plan at S A-05, pp. 24-25; At- .

tachment A-7, p.~47-A; Ashtabula County Plan at S A.3, p. A-3; 5 B.3, p. B-2; 5 J.3, p. J-2; Ap-pendices 6 and 7; and Geauga County Plan:at S B-2, p. B-1; Appendix 4; Appendix 6.

d. Approving activation of the public alert / notification system within their respec-I ~t ive counties.- See Lake County Plan at S E-07,

p. 61; Ashtabula County Plan at S E.4, p. E-2;

and Geauga County Plan at S E-5, p. E-3.

e. Coordinating with appropriate state

agencies to authorize relaxation of protective i measures. See Lake County Plan at S M-02, p.

1 151; Ashtabula County Plan at S M-3, p. M-2; and Geauga County Plan at S M-3, p. M-2.

1 II. Legal Basis For Plans

5. The State of Ohio, under Ohio law, vests the County j Commissioners with the authority and responsibility to act as the officials in charge of emergency response. See State Plan,1/ at S II.A.3.b(3)-(5), pp. II-A-04-05; Lake County Plan at S 1, p. 1; SS A-07, A-08, pp. 27-28; Ashtabula County Plan

, at S B.5, p. B-4; and Geauga County Plan at S B-4, p. B-6.

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i 4/ The State of Ohio-Plan for Response to Radiological Emergencies at Licensed Nuclear Facilities (1984 ed.).

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2. The purpose of this affidavit is to describe :the l clearly defined and consistent responsibilities and roles of the'. Lake, Ashtabula.and Geauga County' Commissioners when re-sponding to an emergency at the Perry Nuclear Power Plant, and

to' note that their; legal authority to act is set forth in the 3

respective' plans.

T I. The Role of County Commissioners

, 3. The cited provisions of the radiological emergency response plans clearly and consistently define the role ~of the County Commissioners as including overall responsibility for local emergency operations. Although the emergency organiza-

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l tions among the three counties may differ, the responsibilities

'and roles of the County Commissioners in the three counties are parallel, as established by the emergency plans.

4. The County Commissioners in each of the three counties are charged with the following five responsibilities in radiological emergency response:

a. Direction and control of local emer-i gency operations. See Lake County Plan,1/ at 5 5.1, p. 12; 5 A-05, p. 24-25; p.47-A;AshtabulaCountyPlan,2_pttachmentA-7, . at'S A.3, pp.

A-2 to A-3; 5 B.3, p. B-2;. Appendices 6 and 7; and Geauga County Plan,3/ at S A-5, p. A-3; j 1/ Lake County' Emergency Response Plan for the Perry Nuclear 4 Power Plant (Rev. 3, October 1984).

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

3/ Geauga County Radiological Emergency Response Plan (Change No.-2 dated July 1984).

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6. In' summary, the emergency plans clearly establish the consistent roles and responsibil ties of the County Commissioners. Furthermore, they establish the_ legal authority of the County Commissioners to take the actions under the plan in the event of an'emergenc SY ~

OHN BAER Subscribed'and sworn before me this 5'/ ' a of_ January, 1985.

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Nctary Public My commission _ expires: Ylgill,]g.j]>Rr 4

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ENERG'bCONSULTANTS RMwede OMce Center 3 2101 N. Font St. . Mamotrg,PA 17110 (717) 2360031 Resume current 01-11 85 4

JOHN W. BAER Education 1970 Post Graduate Study - Political Science American University Washington, D.C.

!?66 Bachelor of Arts - Political Science Western Maryland College Westminster, Maryland Experience 1981 to Present Energy Consultants harrisburg, Pennsylvanta Project Manager. Emergency Management Services. Re-sponsible for providing supervision and technical assistance to project staf f. 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 p re-paredness programs for the Counties of Ashtarula, 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 prepara tion and ASLB hearing support; i -

mnaging 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 i preparedness program to support response to inci-dents at the Callaway Plant including direct responsibility for revision of the Missouri State apcsoso omer tam wahryson ate . W nwrr,m 13017 . (412) 257 1300

s John W. Baer a

Page 2 Maclear Accident Plan and associated local radio-logical emergency response plans, preparation of affidavits to support motions for summary 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 detil and exercise progras;

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

- development of the Louisiana Office of Emergency Preparedne:s 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.

1973 to 1980 Southcentral Regional Plarning Council Harrisburg, Pennsylvania Director. Responsible for administration of an eight-county planning and evaluation program for the Cosmon-wealth of Pennsylvania. Assisted local goverreents in planning and development of criminal justice / emergency response communications and automated information 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 36-hour training sessions for criminal justice personnel within a ten-state region. Developed and conducted practical group exercises for course participants.

Planner (1973 to 1978). Assisted local governments in planning and development of a range of criminal justice pmgrams, criminal justice system casounications and automated inforsation systems.

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' John W. Beer Page 3 1971 to 1973 t.ord 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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t' UNITED STATES OF AMERICA

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NL' CLEAR REGULATORY COMMISSION -

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av.C BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'55 Prf -5 A9 :51 In the Matter of ) c c. . ,. : ,, ,

) CCCn;i'iG a SEg yJrJ THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 6RAhCH 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 C," " Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard on Contention C," and " Affidavit of John Baer on Contention C," were served this 1st day of February, 1985, by 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 express mail.

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si m i 1 ., V-L i .f-E. Silberg i Jay /

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s Dated: February 1, 1985

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

In the Matter of )

') 1 nTHE CLEVELAND ELECTRIC ) Docket Nos. 50-440 '

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--ILLUMINATING COMPANY, ET AL. ) 50-441-

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(Perry Nuclear Power Plant, )  !

j_ . Units l 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 h

Mr. Jerry R. Kline . Docketing and Service Section Atomic Safety and Licensing Board Office ofsthe. Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission

. Washington, D.C. 20555 Washington, D.C. 20555 Mr. Glenn O. Bright Colleen P. Woodhead, Esquire j 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 i U.S. Nuclear Regulatory Commission 618 N. Michigan Street Washington, D.C. 20555

• Toledo, Ohio 43624 i.

Dr. W. Reed Johnson Donald T. Ezzone, Esquire Atomic Safety and Licensing Assistant Prosecuting Attorney Appeal Board Lake County Administr'ation 2 -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' l

John G. Cardinal, Esquire

• Ms. Sue Hiatt

. Prosecuting Attorney 8275 Munson Avenue Ashtabula CountyfCourthouse Mentor, Ohio 44060 Jefferson, Ohio 44047 h

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