ML20101S904

Affidavit of RW Smith on Contention M.Independent Radiation Monitoring Sys for Plume Exposure Pathway Emergency Planning Zone Capable of Detecting & Measuring Release from Nuclear Power Plant & Meets Regulatory Guidance

ML20101S904
Person / Time
Site:	Perry
Issue date:	01/30/1985
From:	Rich Smith CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20101S871	List: ML20101S869 ML20101S892 ML20101S904 ML20101S921
References
OL, NUDOCS 8502050705
Download: ML20101S904 (10)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g [.h 50 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD,-~ -

CJ In the Matter of FF'-5 gj *.;p

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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) ,

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AFFIDAVIT OF RONALD W. SMITH OF CONTENTION M County of Lake )

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State of Ohio )

Ronald W. Smith, being duly sworn, deposes and says:

1. I am presently Government Affairs Representative, Community Relations Section, The Cleveland Electric Illuminating Company ("CEI"). My business address is 10 Center Road, Perry, Ohio 44081. In my position, my duties include assisting State and county governments with their emergency planning and preparedness and coordinating those efforts with each other and with CEI. Included in these efforts is the coordination of the State of Ohio's off-site radiological monitoring capability. A current statement of my professional and technical qualifications 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 Applicants' Motion for Summary Disposition of Contention M.

2. . Contention M states that I,ndependent Radiation Data Monitoring Systems should be installed within the 10-m11e 8502050705 850201 PDR ADOCK 05000440 0 PDR

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,_ Emergency. Planning Zone (EPZ). Sunflower's argument is that

.each of the three counties within the plume exposure pathway EPZ should have fixed radiation monitors, meteorological equipment'and telemetering equipment. Sunflower Alliance's Particularized Objections to Proposed Emergency Plans in Support of Issue No. 1, dated August 20, 1984, pages 17-18.

3. There is no regulatory requirement that each jurisdiction within the plume exposure pathway EPZ have independent radiation monitoring systems or that such systems be fixed. The NRC/ FEMA guidance says that Each organization, where appropriate, shall provide for off-site radiological monitoring equipment in the vicinity of the nuclear facility.

NUREG-0654', Criterion H.7 (p. 54) (emphasis added). This equipment need not be stationary; it can be portable.

NUREG-0654, Criterion I.7 states that Each organization shall describe the capability and resources for field monitoring within the plume exposure pathway Emergency Planning Zone which are an intrinsic part of the concept of operations of the facility.

This criterion does not require that each organization have its own capability, but rather that each organization describe the monitoring capability on which it will rely.

4. In the case of the Perry facility, the State of Ohio has extensive independent radiological assessment capability, including off-site radiological monitoring equipment.1/ The 4

1/ Each of the three plume exposure pathway EPZ counties relies on the State's field radiation monitoring (Continued next page)

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4 . State's1 system consists of.three key elements: (1) a centralized' command and control facility in the State emergency

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operations center-(EOC) in Columbus which includes a dedicated computer system for analysis and evaluation of radiological data and.related..doseirates for_the key. isotopes and for converting parameters for.these isotopes (State Plan S II-Part

-I 2a(3) and 3g:(3)); (2) three fully equipped field radiological monitoring teams capable of high, mid and low range gamma radiation readings, alpha and beta radiation detection, air sampling for radioiodine and particulates (State Plan, Figure II-H-1); environmental sampling (State Plan S II, Part H Sa), and aerial survey of a radioactive plume (State Plan'S II, Part I 2d (2)); (3) a radio communication system for the immediate and simultaneous transmission of. data from-the field teams to the State EOC~in Columbus, the PNPP emergency 1

operations facility (EOF), the Lake County EOC, the Ashtabula

, County EOC, and the Geauga County EOC.

5. The three field monitoring teams take-radiological readings and environmental samples such.as water, soil, and j-4 i

, (Continued) capability to demonstrate compliance with NUREG-0654 Criterion I.7. Lake Plan, S I-02; Ashtabula Plan, S I.2; Geauga Plan,.5 I-2. -FEMA has found, in its Interim Report, that each of the three plans has complied.with

. this criterion.

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• vegetation at preselected monitoring points (State Plan, Figure II-J-36). By moving from point to point in areas where the plume is projected to be, the teams' measurements, when assembled at the State EOC, form a " picture" of a radiation plume. The preselected monitoring points are located systematically throughout the entire plume exposure pathway EPZ which al, lows.for systematic monitoring in any area deemed appropriate. Also, monitoring teams conduct aerial surveys by flying over the areas of the-projected path of the plume. In this way the teams' data is compiled to define the actual midpoint and boundaries of the plume as well as the intensity of radiation present.

6. Each monitoring team carries portable (hand-carried) and mobile (in-vehicle) radios which operate on the Disaster Service Agency Direction and Control frequencies (transmitting at 150.10 MHz and receiving at 150.70 MHz). Field data is relayed directly to the county EOCs and the EOF instantaneously through a repeater system in the communications van. Data is also relayed to the State EOC through the communications van.

(State Plan, Figure II-E-9).

7. Each radiological monitoring team has the following equipment (State Plan, Figure II-H-1):

CDV-715- Survey meter; range-05 R/hr to 500 R/hr (high and mid level gamma radiation measurement) 4_

CDV-700 Survey meter;-range-0 mR/hr to 50 mR/hr (low level gross gamma radiation measurement and beta radiation detection)

PRM-7 Scintillator detector; range .005.mR/hr=to 5 mR/hr (very low level gamma radiation measurement)

PRS-lP Base rate meter and scaler used with the following four probes:

SPA-3 Scintillator probe; range-O to 999,999 CPM (detects radiciodine and'is used to monitor the silver zeolite cartridge used'in air sampling)

HP-210 Geiger-Mueller Tube; range-0 to 200 mR/hr (low level gross. gamma radiation and beta radiation detector)

AC-3-7 Scintillator; range-0 to 999,999 CPM (alpha radiation detector)

RAS-1 -Regulated Air Sampler with silver zeolite-cartidges.

The. equipment used by State radiological monitoring teams affords fully effective field monitoring for detection and measurement of any release from a nuclear power plant.

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t*- 8. .The State RadiologicalLResponse teams are sufficient in number,' suitably equipped with radiological equipment, and.

ihave'the communications capability to provide effective

-radiation' plume tracking thatols independent of the PNPP field

radiation 1 monitoring teams. .The-State teams are notified on

-declaration of an Unusual-Event (the lowest level.of emergency -

L classification)'and'are activated and dispatched.on declaration

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of-an' Alert. .The State teams were fully exercised during the

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emergency _. exercise held on November.28, 1984.

. 9. Additionally, the Federal Government. responds to nuclear power plant: incidents.with a full cadre of field

. monitoring teams. The Department of Energy (DOE), the

. Environmental Protection Agency, and the Nuclear Regulatory' Commission each have field radiological monitoring capability that matches that described here for the State of Ohio. DOE-coordinates field data (collected via radio transmission from i

the FederalsGovernment response teams) at a' central point

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called the Federal Radiological' Monitoring and-Assessment ,

Center and in turn relays it's consglidated information and recommendations to the State and county EOCs and'the EOF. ,

.10. The. independent radiological monitoring capability'of the-State'of Ohio ~is more_than adequate'to meet the

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requirements of Criterion H.7 of NUREG-0654. ThereLis no reason why it is appropriate for the three plume exposure

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pathway EPZ counties to be: required to have their own off-site radiological monitoring. equipment.

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4. j 11. - Sunflower's_ August 20, 1984 objections also cite'to H

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page~ 58l of-

NUREG-0654 aus a basis for- contention. The.only ~

possible source-on that.page for Sunflower's reference is Lcriterion I.10 which states i

Each' organization, where a'opropriate, shall-(' provide methods, equipment:and expertiseLto make1 rapid assessments of the actual or potential magnitude and;1gcations of any l .

' radiological hazards through liquid or

gaseous release pathways.

NUREG-0654,'page 58J(emphasis added). 'With the capabilities-

' described above, there is no reasonswhy it is appropriate to require-the three counties to have independent radiological -

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, monitoring-systems.

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.12. Sunflower also suggests that a resolution by the i{ - trustees of Jefferson Township provides a basis-for:this contention. That resolution states the Township's resolution to-s t

! [R]equest and support the installation and

maintenance of independent monitoring- ,

! facilities and procedures at and'around the-Perry Nuclear Power facility.

i Sunflower August 20, 1984 Objections, page 18. Jefferson 1

l Township,_although located in Ashtabula= County, is well outside f

i- the plume exposure pathway EPZ. .And the radiation monitoring

capabilities described above would meet the requirements of the

Township's resolution.

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13. In suecar/' , there are independent radiatien tenitoring systers for the plu::e expcsure pathway EPZ, Tnese systs:s are capable of detect.

Ing and measuring the release fecm a nuclear ;cwer plant and meet all re6ulatory ,3uidance.

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.7Iu ./. i M/* 0 RWJALD W. Si1TH Subscribed and sworn before me this g day of January, 1995

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NotaryPublf(

, My Cocnission Expires:

B(TNA W L M ESE Notary Puhuc.3 TATE OF OHl0 My Commissies eg6m 3/11/88

' Recorded in Lake Counts

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RESUME Name: Ronald W. Smith

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Position: Government Affairs Pepresentative, Community Relations Sectica Perry Nuclear Power Plant, Perry, Ohio 144081 EDUCATIONS. The Wharton Schnol, University of Pennsylvania, Philadelphia, PA.

Master of Governmental Administration 1976 The Pennsylvania < State University, University Park, PA Master of Science 1964~ .

Indians University of Pennsylvania, Indiana, .iNi Bachelor of Science 1963 EXPERIENCE:

April 1984 to present: Clevelsed Electric Illuminating Ccmpany Perry nuclear Power Plant Head of the Emergency. Planning Unit in the Ccesunity Relations Sectien. Provide consulting services ano direct assistance to off-site emergency response agencies, especially state and_ county disaster services agencies. Duties includes facilitation of coordination of plans (on-site to eff-site and among off-site plans) and development-of plans and procedures that adhere to Federal Covernment reguistions and guidance and will also work in practices coordination of training efforts-among state, county, utility, and consultant persennel who provide training to eff-si'.e agencies;' liaison with Chio Disaster Services Agency and FEMA on planning and preparedness matters, trainin6 effcrts, and exercise arrangements; supervise ccmpany empicyed consultants who provide emergency planning and preparedness assistance to counties.

4 1990-to April 1984: Planner and Emergency Management Specialist

-with the Pennsylvania Emergency Management-Agency, Harrisburg. PA Developed.a new state level plan for off-site emer-gency response to_ accidents at'Three Mile Island Nuclear Station and other. nuclear pgwer plants in Pennsylvania.

Wrote najor: portions of eleven county piens that surrcund nuclear power plants. Dev)1cped policies and precedures related to nuclear power plant accidents-for the state -

F Anil PEPPY COttt1 PEL '02/01/85 09:13; LP. 2 j

0 risk counties, risk municipalities, and risk institutiens. ,

Organized, participated in, and evaluated several large scale exercises designed to test the effectiveness or the radic1cgical emerger.cy response plans and. to train the hundreds of participants. Assisted numerous state agencies in develeping disaster response plans. Initiated, developed and conducted training sessions related to response to nuclear power plant accidents for state employees, county and municipal emer6ency personnel.

1974 - 1980: Prcgram Analyst with the Legis3ative Budget and Finance Committee, Harrisburg, PA Researched and evaluated prc6 rams funded by the General Assembly. Gathered descriptive informatien with appropriate statistical data and organized and analyzed this informatien to ascertain stren6ths and weaknesses of administrative procedures as well as adherence to legisla-tive intent. Wrote forr.a1 in-depth reports on such studies which included jescriptjve information and data, findings, and reccmmendations. Duties included follow through acticn to help 1=plement the study recommendations.

1974 - Prior: Educattor, specialist in the Staff Development and Improvement section of.the Fennsylvania Bureau of Correction, Camp Hill Fa. Special Educati:n teacher with Harrisbur6 City School 3 and Dauphin County Schools, Harrisbur6, Pa.

MILITARY: United States Army active duty 1964-1966 with 48th Medical Battalion, 2AD, Fort Hood, Texas Commander of a field hospital that provided energency and short term medical care. Company and Battalien Chemical-Radiological-51ological k'arfare Orricer.

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