ML20154B967

Third Affidavit of DD Hulbert.* Discusses Issues Raised by Concerned Citizens Ltrs Re Emergency Planning.W/Certificate of Svc

ML20154B967
Person / Time
Site:	Perry
Issue date:	08/31/1988
From:	Hulbert D CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20154B946	List: ML20154B940 ML20154B967
References
2.206, NUDOCS 8809140202
Download: ML20154B967 (8)

Text

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6 August 31, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE DIRECTOR, OFFICE OF NUCLEAR REACTOR REGULATION l

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! In the Matter of ) ,

)

THE CLEVELAND ELECTRIC )

ILLUMINATING COMPANY, ) Docket Nos. 50-440 l

et al., ) 50-441

) (10 C.F.R. 5 2.206)

(Perry Nuclear Power )

Plant, Units 1 and 2) )

3 THIRD AFFIDAVIT OF DANIEL D. HULBERT County of Lake )

) ss.

State of Ohio )

DANIEL D. HULBERT, being duly sworn, deposes and says:

1. I am presently 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 position, I am responsible for developing, main-taining, and evaluating the emergency preparedness program for the Perry Nuclear Power Plant ("Perry"), including coordination with local, state and federal agencies to ensure the effective-ness of that program. I have been involved in emergency planning for Perry since 1980, and have been responsible for coordination of the exercises conducted at Perry.

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2. I have reviewed the Concerned citizens' July 25, 1988 letter to the NRC, as well as the FEMA and EPA documents refer-enced in that letter. I have prepared this affidavit in response to the Concerned Citizens' letter, supplementing my affidavits of March 8, 1988 and August 2, 1988. I have personal knowledge of the matters stated herein and believe them to be true and cor-rect.

3. FEMA expressed concerns about the use of receiving schools in a February 26, 1988 memorandum to the NRC, which was supplemented by a second memorandum to the NRC dated April 19, 1988. In subsequent discussions with the NRC and with counsel for Licensees, FEMA clarified that its concern is not with either the concept of receiving schools or with the location of those schools. Rather, FEMA is concerned that existing emergency plans do not expressly provide for the monitoring and decontamination of evacuating school children who may have been exposed to a passing plume and therefore may be contaminated. To resolve this concern, the county plans will be revised to clearly indicate that any evacuating school children who have been potentially ex-posed (and therefore potentially contaminated) vill be promptly monitored, and decontaminated if necessary. In some cases, these students vould be re-routed to a Care Center for monitoring and decontamination. In other cases, available moni-toring/ decontamination teams would be deployed to the appropriate receiving school (s) to accomplish the task there. In addition,

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the EBS Standard Operating Procedure ("SOP") vill be revised to ensure that parents vould be promptly advised at the time of an emergency if any school children vere being routed to a care Cen-ter rather than to their designated receiving school. The changes to the plans and to the EBS SOP vill be completed by the end of September 1988, with any related changes to other proce-dures completed during the fall /vinter season. FEMA officials have advised counsel for Licensees that these actions resolve FEMA's concern.

4. The present system for provision of emergency in-formation to transients in the Perry area includes the posting of signs in recreation areas frequented by transients. FEMA recog-nized that the signs already had been posted in Geauga County, but expressed concern that Lake County and Ashtabula County had planned to post their signs at the time of an emergency. In re-sponse to FEMA's concern, the posting of the signs in state, county and municipal parks, at public campgrounds, at scout and church camps, and at public beaches and marinas was completed in the Spring of 1988. Through spot checks in early June, FEMA Re-gion V representatives have confirmed that the emergency in-formation signs have been posted.

5. To enhance existing public education efforts, the Ohio Emergency Management Agency is hiring an additional Public In-formation Officer ("PIO"). As recommended by the State's 3_

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s Emergency Evacuation Review Team, this new PIO will develop addi-tional methods of increasing the awareness of emergency in-formation among those with disabilities.

5. The development of the 1989 Calendar will include con-sideration of other FEMA recommendations, specifically those on the subjects of:

(a) The identification of Perry as a nuclear plant; (b) The inclusion of the names, addresses and phone numbers of the emergency management agencies in the introductory let-ter; (c) The typography and graphic design of the list of 24-hour radio and TV stations; (d) The degree of emphasis on the utility of portable radios in an emergency; (e) The inclusion of additional text describing the characteris-tics of radioactive material in the plant and the potential health effects of a large release; (f) The clarification of the text on page 6 of the 1988 Calen-dar, to indicate that evacuees may stay with friends or fam-ily outside the EPZ, or at a Care Center; 1

(g) The inclusion of a statement explaining how persons can learn the location of evacuated hospital and nursing home patients; (h) The wording of the disc' . ion of care for livestock i.n an emergency; and (i) The format of the map of the Emergency Planning Zone.

6. In the spirit of accommodation, the last paragraph of the section of the 1988 Calendar entitled "Sources of Radiation"

( vill be deleted in the 1989 Calendar, and will be replaced with the following text:

Radiation levels at nuclear plants are checked constantly. The law limits levels released from a plant. If.you would like more information on radiation, write to The Illuminating Company, Perry Plant, Community Relations Section, P.O. Box 97, Perry, Ohio 44081.

7. The Special Needs Information Card for inclusion with the 1989 Calendar vill be revised to clarify that responses are necessary only from those whose physical or mental disabilities vould necessitate special assistance in an emergency.

8. Licensees historically have made all reasonable good faith efforts to provide pre-emergency public information to area businesses and to encourage them in turn to make that information available to transients. For example, Licensees distributed sup-plies of the 1988 Calendar to motels throughout the EPZ (for placement in guest rooms), and supplied motel operators with copies of emergene.y information telephone directory insert (for j posting in directories in guest rooms). While the proprietors

! of private businesses cannot be forced to make such information i available to transients, Licensees and local officials will con-1 i tinue their efforts in this area.

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9. CEI's internal procedures have been formalized to en-sure coordination between the utility and the various telephone companies so that emergency public information is not omitted from future editions of the phone directories. Indeed, the 1988-89 Ohio Bell directory for the Painesville area has been distributed, and it includes tha two pages of emergency in-formation.

10. None of the issues raised in the Concerned Citizens' '

letter raises a substantial health and safety issue or calls into question the adequacy of emergency planning for the Perry area.

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Daniel D. Hulbert sworn to and subscribed before me this [ day of August, 1988.

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Notary Public IEVRY A CARUIO, NOTARY Ngtm My commission expires STAit W M io W C00MS$2 DMt3 ff8.11,lHO 6-

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- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'26 SU) -1 P2 :14 BEFORE THE DIRECTOR, OFFICE OF NUCLEAR REACTOR REGULATION Ontci n Si. r w <

DUC6L im & 'i .:vsu' In the Matter of ) BRANc9

)

THE CLEVELAND ELECTRIC )

ILLUMINATING COMPANY, ) Docket Nos. 50-440 et al., ) 50-441

) (10 C.F.R. 5 2.206)

(Perry Nuclear Power )

Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of "Licensees' Answer To Con-cerned Citizens' Letter Regarding FEMA Memoranda on S 2.206 Peti-tion" were served this 31st day of August, 1988, by deposit in the U.S. mail, first class, postage prepaid, to the following persons:

Mr. Lee Dewey Office of The General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Robert A. Meck Emergency Preparedness Branch Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Timothy Colburn Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. William G. Snell U.S. Nuclear Regulatory Commission Region !!!

799 Roosevelt Road Glen Ellyn, Illinois 60137

4 Ms. Margaret Lawless Federal Emergency Management Agency 500 C Street, S.W.

Washington, D.C. 20472 Mr. Dan Bement Federal Emergency Management Agency Region V 175 West Jackson, 4th Floor Chicago, Illinois 60604 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Connie Kline 38531 Dodds Landing Drive Willoughby Hills, Ohio 44094 Ms. Theresa Burling 11701 Colburn Road Chardon, Ohio 44024 Mr. Russ Bimber 10471 Prouty Road Painesville, Ohio 44077 Mr. Ron O'Connell 315 Garfield Street Geneva, Ohio 44041

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