ML20106E340

Affidavit of G Winters on Contention Q Re Evacuation of Schools within Emergency Planning Zone in Single Trip.Ample Resources (School Buses & Drivers) Available to Evacuate Schools within Emergency Planning Zone in Single Trip

ML20106E340
Person / Time
Site:	Perry
Issue date:	02/04/1985
From:	Winters G CLEVELAND ELECTRIC ILLUMINATING CO., EMERGENCY MANAGEMENT SERVICES, INC.
To:
Shared Package
ML20106D844	List: ML20106D839 ML20106E181 ML20106E340
References
OL, NUDOCS 8502130284
Download: ML20106E340 (9)

Text

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

L In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF GARY WINTERS ON CONTENTION Q 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 L

inventory and assessment efforts involving Lake, Ashtabula and I

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

Project activities have included the interview of response i

agency / facility administrators for resource information, preparation of county resource documents and analysis of i offsite resource capability to respond to an accident at the A current statement of my professional

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_ Perry Plant.

qualifications and experience is attached hereto. I have L-l-

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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 Q.

2. The purpose of this affidavit is to demonstrate the availability of sufficient resources to evacuate all schools (grades K-12) within the plume exposure pathway emergency ,

planning zone ("EPZ") in a single trip, to identify the specific measures being taken to assure that parents of children in schools within the EPZ will cooperate with plans for the evacuation of the schools, and to explain that -- even if some parents did attempt to pick up their children at school

-- the evacuation of schools would not be impeded.

I. School Buses

3. A recent survey of the superintendents of all school districts within the Perry EPZ indicates that current total enrollment in EPZ schools is approximately 19,802 students.

4. The licensed capacity for EPZ and support school i

buses 1/ is an average of 59.3 students per bus; the actual evacuation capacity is an average of 55.0 students per bus.2/

1/ Support school buses are school buses from schools within the three county area (but outside the EPZ) which are available to assist with the evacuation of EPZ schools in the event of an emergency at Perry.

, 1/ The average licensed capacito c. EPZ and support school buses was determined by aver .ng the licensed capacity of r

these buses. The average act evacuation capacity of these buses was determined by a Ning licensed capacity (Continued next page) 9

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Thus, the actual number of buses needed to evacuate EPZ schools in a single trip -- based on actual evacuation capacity -- is 384 buses.3/ A county-by-county breakdown is shown in Table A below.

TABLE A SCHOOL BUSES County Support Buses Total Buses Surplus Buses Within Needed For Buses EPZ School Evacuation Lake 246 120 303 63 Ashtabula 182 34 64 152 Geauga 65 14 17 62 TOTALS 493 168 384 277

5. As Table A indicates, the schools within the EPZ do not have sufficient bus capacity to evacuate their students in a single trip without assistance. However, Standard Operating Procedures developed with school districts in the three (Continued) to grade level for all schools within the EPZ, and assigning two or three students per seat (based on three per seat for grades K-9, and two per seat for grades 10-12). The total number of buses needed was then determined, and an average per bus capacity calculated.

3/ The actual number of buses needed to evacuate EPZ schools in a single trip was determined by matching actual evacuation seat capacity to individual school enrollment and calculating the number of buses needed to evacuate each school in a single trip.

i counties provide for the use of resources (school buses and drivers) from outside the EPZ to evacuate schools within the EPZ in an emergency. See also Lake County Plan,1/ SS J-06, J-ll, and Attachment A-1; Ashtabula County Plan,1/ Appendices 6 and 9, and S J.4.1; Geauga County Plan,5/ Appendices 4 and 24.

Letters of agreement are being obtained for the use of these resources. Table A clearly demonstrates the availability of adequate numbers of buses to evacuate all school students from the EPZ in a single trip. Indeed, Table A indicates a surplus of 277 buses available within the three counties, over and above the buses needed to evacuate the schools in the EPZ.

II. Bus Drivers

6. Table B below shows the pool of licensed school bus drivers (both regular and substitute drivers) available within the three counties to support evacuation in the event of an emergency at the Perry Plant. As Table B indicates, there are many more than enough school bus drivers available to drive the 384 buses needed to evacuate the schools within the EPZ in a single trip.

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4/ Lake County Emergency Response Plan For The Perry Nuclear Power Plant (Rev. 3, October 1984).

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

1/ Geauga County Radiological Emergency Response Plan (December 1983) (including Change No. 2 dated July 1984).

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i TABLE B SCHOOL BUS DRIVERS

' County Regular Substitute Totals Lake 314 78 392 Ashtabula 174 68 242 Geauga 65 19 84 718

7. Each of the three county plans provides for the training of emergency workers, including bus drivers. Lake County Plan, Attachment 0-1; Ashtabula County Plan, Appendix 34; Geauga County Plan, Appendix 36. The training being Lprovided to each bus driver prior to fuel load includes (at a minimum):

a. An explanation of basic radiation concepts (including the use of dosimetry).

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b. An overview of the offsite emergency plans.

c. Instruction on each driver's specific duties.

In addition, the training includes making the bus drivers aware of the advantages of informal pre-emergency family contingency planning.

8. All school bus drivers assisting with the evacuation of schools within the plume EPZ in the event of an emergency at Perry would be provided with personnel dosimetry, both self-reading and permanent record types..

1 III. Parents' Response 9.- The EBS announcements for broadcast in the event of an evacuation will advisa parents of the evacuation of the schools and of the location to which each school's students are being evacuated. The EBS announcements also will emphasize that parents should pick up their children at the appropriate receiving school outside the EPZ. The emergency public information brochure (for distribution throughout the EPZ prior to fuel load, and annually thereafter) will provide this same information about school evacuation, and will also instruct

-parents not to go to the schools to pick up their children.

-Lake County Plan, SS G-01, G-02, G-03; Ashtabula County Plan, SS E.4, G.2; Geauga County Plan, $$ E-6, G-3.

10. The offsite plans for the Perry EPZ are designed to facilitate the expeditious evacuation of school children, directly from.their schools within the EPZ to predesignated receiving schools'(reception centers) outside the EPZ. In the 4

'eventiof an emergency at Perry, evacuation of approximately half the schools wAthin the EPZ would.begin within 15 minutes i.

of the order to evacuate. Therefore, many school children

l. would already be enroute to. receiving schools by the time

l. parents could receive and react to notification of an evacuation and travel to the schools.

If 11. Nevertheless, even if some parents ignored the

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' information provided in the brochure and in the EBS broadcasts and did go to the schools to pick up their children in an

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1 emergency, school evacuation would not be seriously impeded. Normal school I dismissal procedures would be followed, including the stationing of school personnel to direct buses out of the loading areas, and to prevent extran-eous traffic from entering the loading area, if necessary.

12. In summary, ample resources (school buses and drivers) are available to evacuate all schools within the EPZ in a single trip.

Provisions for the dissemination of information about school evacuation in an emergency provide assurance that parents of children in schools i

within the EPZ will cooperate with plans for the direct evacuation of

-their children to receiving schools outside the EPZ. Nevertheless, even if some parents did attempt to pick up their children at school, the evacuation of schools would not be impeded. j W

Gary in ers Subscribed and sworn to before me this (4'4 day of February, 1985.

'l Mai N Notary -Public ' \

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JENINE N. RANNEls. NOTARY PUBUC HARRISBURG, DAUPHIN COUNTY My Commiss10n eXpife$

• NYCONNISSION EXPtRES DEC.12.1988 W,.nu, Penn$yt.a A$$0Chtion t$

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ENERGY CONSULTANIS Rhernde Omco Cenhar 3 2101 N. hont St.

• Heucug, PA 17110 (717) 2bO131 Rasume Current 01 11 85 l

l GARY A. WINTERS Education 1976 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 state and local gover ments and industry in emergency management planning, procedure preparation and

' program accreditation / licensing. Recent project as-signment has included coordinating and performing a detailed audit of the offsite emergency preparedness program in support of the Perry Muclear Power Plant

l. Atomic Safety and Licensing Board hearings. Assigreent project coordinator involved responsibility for as development of audit criteria; plan / procedure review; l documentation of program weaknesses; and resource

verification. Prior project assigments have included

- Development of four county radiological emergency response plans in support of the Callaway Plant;

. - Development of local emergency response agency implementing procedures in support of the Water-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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- Gary A. Winter s Page 2 i 4 76 to 9-81 Dauphin County i

Harrisburg, Pennsylvenia Juven 11e Court Probation Officer. Managed caseloads, investigated cases of delinquency, prepa red legal deciments, and testified in court hearings; coordinated the delivery of haan semices to delinquent youth among )

various public and private institutions. Advanced to Asststant Supervisor of Predispositional .

Services.  ;

9 67 to 10-70 U.S. Amy l 12*.h U.S. Arwy Security Agency Field Station Chitose, Japan

, Non-Morse Intercept Operator for the U.S. Amy Security Agency.

Advanced to search operator, Specialist S.

quality co-%11er, and shift leader. Received a " top secret

• sec .'ity clearance.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

- THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF JOHN BAER ON CONTENTION Z County of Dauphin )

g ) ss

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. State of Pennsylvania )

John Baer, being duly sworn, deposes and says:

l.. I am presently Project Manager for Emergency Management Services, Energy Consultants, Inc. My business address is 2101' North Front Street, Harrisburg, Pennsylvania 17110. In my position, I am project manager for.off-site radiological 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 and technical' qualifications is attached hereto. I have

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personal knowledge of the matters stated herein and-believe i

+

them to be true and correct. I make this affidavit in support

- of Applicants' Motion for Summary Disposition of Contention Z.

2. Contention Z claims that the emergency plans do not

- provide " decontamination protection for bus' drivers during an

_. emergency." Sunflower believes that bus drivers, in addition ,

to the. dosimeters they will have, should also be provided with-protective gear such as respirators and goggles.

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3. There is no regulatory requirement and no regulatory guidance that calls for bus drivers to be provided with protective gear such as' respirators and goggles. The NRC regulations require that there be means for controlling radiation exposures to emergency workers. 10 C.F.R.

S 50.47(b)(11). Further guidance on this topic is contained in NUREG-0654, Criterion K.3, which describes provision for

' supplying dosimetry to emergency workers. Neither NRC regulations nor NUREG-0654 nor other guidance documents suggest that respiratory devices or goggles should be provided for emergency workers such as bus drivers.

4. The county emergency plans provide for the distribution of personnel dosimetry, both self-reading and permanent record types, and associated recordkeeping materials to those bus drivers who will be serving as emergency workers.

5. Bus drivers have access to dosimetry at assembly areas from which they will be deployed. Each bus driver will wear desimetry equipment at all times. Training in the use of and associated recordkeeping of dosimetry has been, and will continue to be provided to bus drivers. This includes

" reading" dosimeters regularly while performing emergency duties. Procedures require that bus drivers, as well as other

-emergency workers, read their dosimeters and record their readings at least once an hour. If the bus driver's self-reading dosimeter indicates any radiation exposure, the procedures call for him to report to a monitoring and

[ - . _ -

5 decontamination station (all of which are outside the plume exposure pathway EPZ) for monitoring and, if needed, '

decontamination. This monitoring would show any differing exposure levels to different parts of the body. Upon completion of a mission or shift, each bus driver is required to turn in his or her dosimetry to be checked and recorded.

Dosimetry records are forwarded to the county EOC and retained.

6. In each school district emergency procedure there is i

a section that details radiological exposure control procedures i for. bus drivers. Information contained in this section includes:

The distribution and use of dosimeters; Associated exposure control recordkeeping; and Availability of monitoring and decontamination

^ services at specified worker decontamination stations.

7. There are several other factors that reduce the chance of bus drivers being exposed to any. radiation hazard.

a. Emergency response plans have been written so that an evacuation can be completed before.the release of significant radioactivity occurs.

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b. The nature of bus drivers' duties will have them spending less time inside the plume exposure pathway emergency planning zone than most other emergency workers, i.e., bus drivers leave the risk area-as soon as their buses are loaded.

c. Every bus driver will have a radio in his bus which will ensure prompt receipt or transmission of pertinent information, including radiological information. . ,

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d. State and CEI radiological monitoring teams will be reading radiation levels and can provide radiological data through emergency management channels that can be relayed to bus drivers. Each of the three county plans provides for the dissemination of information originating with the state radiological monitoring teams. Lake Plan, Annex H, p. 100; Ashtabula Plan, Section H, p. 3; Geauga Plan, Section H, p. 3. The dissemination of radiological or other information is yet another way to protect bus drivers.

8. In light of the information and procedures in the emergency response plans relevant to the proper dosimetry, exposure control recordkeeping and monitoring services, bus drivers are well protected.

There is no need for bus drivers to have goggles, protective clothing or respirators.

Joh' Baer Subscribed and sworn before me this.46{[sday of Sa umu - ,1985 u

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CYNT!i!A T. LUITZ, fl0TARY PUBUO My Cerem ss:m Expires Anust 8. U87 My Commission Expires: liart:stur2, PA Da;;h.a County

ENERGY CONSULTAhni Rnerade Omca Center 3 2101 N. Fent St. . Hameug PA 17110 (717) 2360031 Resume Current 01-11-85 JOHN W. BAER Education l

1970 Post Graduate Study - Political Science l American University l Washington. 0.C.

1966 Bachelor of Arts - Political Science Western Maryland College l Westminster, Maryland Experience 1981 to Present Energy Consultants Harrisburg, Pennsylvania Project Manager. Emergency Management Services. Re-sponsible for prostding supervision and technical assistance to project staff. 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 pre-paredness programs for the Counties of Ashtabula, 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 preparatton and ASLB hearing support; managing 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 preparedness program to support response to inci-dents at the Callaway Plant including direct responsibility for revision of the Missouri State apaase once 13Mwaewgeon me Mdomme Pomm+ eda 15017 . (412) 267 1380

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t John W. Beer Page 2 Muclear Accident Plan and associated local radio-logical mergency 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 mergency operations centers, development of mergency response training programs for local E0C staff officers and emergency workers , and development / conduct of the offsite drill and exercise program;

- evaluating and preparing mvisions to the station and offsite radiological emergency preparedness i plans in support of the Palo Verde Nuclear Gener-ating Station;

- development of the Louisiana Office of Emergency Preparedness 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 Planning Council Harrisburg, Pennsylvania Director. Responsible for administration of an eight-county planning and evaluation program for the Cosmon-wealth of Pennsylvania. Assisted local governments in planning and development of criminal justice / emergency response consunications and automated information systems. Developed and revised training courses in data i

< analysis for use by planning and operational personnel

at the state and local government level. Assisted with delivery of six 35-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 programs, criminal justice system communications and automated information systems.

~- ... .

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John W. Baer t

Page 3 1971 to 1973 Lord 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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. h* _ ____.____i____._______.____.___.-_____ -- - -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF JOHN BAER ON CONTENTION BB County of Dauphin )

) ss State of Pennsylvania )

John Baer, being duly sworn, deposes and says:

1. I am presently Project Manager for Emergency Management Services, Energy Consultants, Inc. My business address is 2101 North Front Street, Harrisburg, Pennsylvania 17110. ~ In my position, I am project manager for off-site radiological 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 and technical qualifications is attached hereto.as Attachment "A". I have personal knowledge of the matters stated herein

-and believe them to be true and correct. I make this affidavit Lin support of Applicants' Motion for Summary Disposition of

' Contention BB.

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~2. Contention BB claims that the off-site emergency

~

plans for the Perry facility are' inadequate due to the planning deficiencies set forth in the Interim Repo;.t on Off-site Radiological Emergency Planning for the Perry Nuclear Power Station, dated January 10, 1984 (" FEMA Interim Report").

3. The conclusion of the Interim Report was that "there is reasonable assurance that the plans are adequate and capable of being implemented in the event of an accident at the site."

4. .The FEMA Interim Report reflects the review by the FEMA Regional Assistance Committee ("RAC") of draft Ashtabula, Geauga and Lake County Emergency Plans submitted for review by the State-of Ohio on. March 17, 1983', and the schedule of corrections to_the RAC review received by FEMA from the State on August 30,11983. As reflected in the FEMA Interim Report,

.more than half of-the planning deficiencies identified-by the RAC were corrected and the corrective action accepted by FEMA Lin..the Interim Report itself. A subsequent submittal of corrections to be made to-the county' plans was made by the

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StateLto' FEMA on March 29,'1984.

5. Each:of the county plans was revised in response to

~the FEMA' Interim Report. The_Ashtabula County Plan was. revised in May 1984. .The Geauga County-Plan was revised in March 1984 -

and in July.1984. The Iake County Plan was revised in' June and 10ctober 1984..-The plan revisions ~ reflect corrective actions-made in direct response to the planning deficiencies noted in the FEMA Interim [ Report.

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6. My independent review of the Lake, Ashtabula, and Geauga County Plans shows that, of the total of 145 planning deficiencies listed in the Interim Report, all have been corrected or are being addressed.

Attachment "B" hereto shows the planning deficiencies noted in the FEMA Interim Report, those deficiencies acknowledged by FEMA to have been corrected by the August 30, 1983 State submission, those remaining deficiencies corrected by the plan revisions made subsequent to the Interim Report and where in revised plans the remaining deficiencies were -

corrected. The few items still being addressed involve emergency information material which will be distributed prior to fuel load.

7. Attachment "B" hereto shows that each of the planning deficien-cies has been, or is being, resolved. These resolutions further support FEMA's conclusion that the county plans are adequate. It is therefore incorrect to claim that the planning deficiencies noted in the FEMA Interim Report indicata that the county plans are inadequate.

J n Baer

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Subscribed and sworn before me this ,$d" day of t/ANvW , 1985.

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[NotaryPublic My Comission Expires: otute a new:rr netm Pueuc M E E*AG.DAUP m C m n M CGHl531GN EXP!P[$ NAY 5,1937 hfe:Mr. Fennslunia Anociation af Mctaries ATTACHMENT A

ENERGY CONSULTAN13 Prwrmde Omce Center 3 2101 N. Fvont St. . Hcrnaug.PA 17110 (717) 236{ 031 Resume Current 01-11-85 JOHN W. BAER Education 1970 Post Graduate Study - Political Science American University Washington. 0.C.

1966 Bachelor of Arts - Political Science Western Maryland College Westminster, Maryland Experience 1981 to Present Energy Consultants Harrisburg, Pennsylvania Project Manager, Emergency Management Services. Re-sponsible for providing supervision and technical assistare to project staff. 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 pre-paredness programs for the Counties of Ashtabula, 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 preparation and ASLB hearing support; managing 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 preparedness program to support response to inci-dents at the Callaway Plant including direct responsibility for revision of the Missouri State

'oposase Omce 1370Washrglon Pke . Brt$gwte PemsAmio t$D17 e (412) 257-1350 3 .

John W. Beer Page 2 Nuclear Accihnt Plan and associated local radio-logical emergency msponse plans, preparation of affidavits to support motions for stamary dispo-sition of licensing contentions, development of local RERP laplementing procedures, establishing operational readiness of local emergency operations centers, development of emergency response training programs for local E0C staff officers and emergency workers, and development / conduct of the offsite drill and exercise progras;

- evaluating and preparing mvisions to the station and offsite radiological emergency preparedness plans in support of the Palo Verde Nuclear Gener-ating Station;

- development of the 1.ouisiana Office of Emergency Preparedness implementing procedures and lesson

plans for training of state, parish and local caergency response personnel in support of the Waterford 3 Steam Electric Station; and

- preparation of lesson plans and cenduct 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 Planning Council Harrisburg, Pennsylvania 4

Director. Responsible for administration of an eight-county planning and evaluation program for the Cosmon-wealth of Pennsylvania. Assisted local gos arreents 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 35-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 1- planning and development of a range of cristnal justice pr$ grams, cristnal justice systes consunications and 4

automated information systems.

4 11 . . . , . . .

John W. Baer Page 3 1971 to 1973 Lord 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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I ATTACHMENT S

L RESPONSES TO FEMA INTERIM REPORT i Lake County 0654 Planning Corrected Per Corrected By Reference In Deficiency Interim Report Plan Revision County Plan Subsequent to Interim Report A. Assignment of Responsibility A.1.b. X Att. 6-1 A.1.e - X A.2.a X Att. A-7 A.3 X A.4. X C. _ Emergency Response Support and Resources C.4 X D. Emergency Classification System D.4 X E. Notification Methods E.6 X E.7 X F .- Emergency Comunications F.1.d .X F.2 X G. Public Education and Information G.1 (Will'be addressed in PNPP emergency brochure and telephone directory inserts)

.G.2 -(Will be addressed in PNPP emergency brochure and telephone directory inserts)

G.3.a X  % G-03

.G.4.b X i G-03 G.4.c X G.5 X 1

_m______.__.__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

- Lake County 0654 Planning Corrected Per Corrected By Reference In Deficiency Interim Report Plan Revision County Plan

-H. Emergency Facilities and Equipment H.3 X H.7 X H.10 X H.11 X H.12~ X Q P-08 I. Accident Assessment I.7 X I.8 X J. Protective Response J.9 X J.10.a X J.10.b X J.10.c '

X Q E-07 J.10.d X J.10.e'& f X J.10 g .

X Att. 6-1 J.12 X K. Radiological Exposure Control K.3.a X Att. K-2 K.3.b X K.4 X  % K-03 K.5.a X L. Medical and Public Health Support L.1 X l L-03 L.4- X App. 4 M. Recovery and Reentry M.1 X l M-02

'N. Exercises and Drills N .1. a . X l N-01 N.1.b X' i N-01 N.2.a X~ 'l N-02 N.2.d X i N-02 2

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Lake County

-0654 Corrected By Reference In

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Planning Corrected Per Deficiency Interim Report Plan Revision County Plan N.3.a X Q N-03 N.3.c X Q N-03

~N.3.d X  % N-03 N.3.e~ X Q N-03 N.4 -

X $ N-04 N.5 j X @ N-05

^

-0. . R'adiological Emergency Response Training 0.4.b. X Att.0-2 0.4.c X Att.0-2

0. 4.'d . X Att.0-1, Att.0-2 0.5' , X 6 0-02

-P. Responsiblity for Planning.

P.7 X App. 4 r.?

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RESPONSES TO FEMA INTERIM REPORT Ashtabula County 0654 Planning Corrected Per Corrected By Reference In Deficiency Interim Report Plan Revision County Plan Subsequent to Interim Report A. Assignment of Responsiblity A.1.a X A.I.b X

._.A.1.c X A.2.a- X A.3. -X A.4 X E. Notification Methods E.5 (Will be addressed in the PNPP emergency brochure and telephere directory inserts)

E.7- X F. Emergency Communications

.F.1.c X

<G. Public Education and Information

- G.1 X G.2- (Will be addressed in PNPP emergency brochure and telephene directory inserts)

G.3.a X G.4.b - X 9 G.3 H. Emergency Facilities-

-H.10- X H.11 X H.12 X i H.4 J. Protective Response-J.10.a X J.10.c X J.10.d X J.10.e & f x 6 J.5, App. 31 4

i i

I Ashtabula County 0654 Planning Corrected Per Corrected By Reference In Deficiency Interim Report Plan Revision County Plan J.10.g X J.12 X K. Radiological Exposure Controls K.3.a X 6 K.2 K.3.b X K.4 X K.S.a X K.5.b X  % K.6 L. Medical and Public Health Support L.1 X-L.4 X App. 8 s

N. Exercises and Drills N.1.b X $ N.2 N.2.a X 9 N.3 N.2.c. X  % N.3 N.3.a X 6 N.4 N.3.b -

'X -5 N.4 N.3.c- X  % N.4 N.3.d. X' 6 N.4 N.3.e X 6 N.4 N.5 X- 9 N.6

0. Radiological Emergency Response Training 0.4.h X 0.5 X P. _ Responsibility for. Planning P.7 X P.10 X t.

i-5

~

l RESPONSES TO FEMA INTERIM REPORT Geauga County 0654 Planning Corrected Per Corrected By Reference In Deficiency Interim Report Plan Revision County Plan Subsecuent to Interim Report A. Assignment of Responsibility A.1.a X A.1.b X App. 24 A.1.c X A.1.e. X A.2.a X A.3 X A.4 C. Emergency Response Support and Resources C.4 X App. 24 D. Emergency Classification System D.4- X E. Notification Methods and Procedures E.5 X E.7 X F. Emergency Communications F.1.c X G. Public Education and Information G.1 X G.2 X G.3.a- X $ G-4 G.4.L X l G-4

-G.4.c X G.5: X H. Emergency Facilities and Equipment H-10 X H X H-12 X 9 H-5 6

c. .-

Geauga County 0654 Planning Corrected Per Corrected By Reference In Deficiency Interim Report Plan Revision County Plan J. Protective Response J.10.a X Q J-3, App. 21 1 J-6, App. 27 8 28 J.10.c X J.10.d X J.10.e & f X Q J-8 J.10.g X J.12 X  % J-4(d)

K. Radiological Exposure Controls K.3.a X  % K-2 K.3.b X K.4 X K.5.a X K.5.b ,

X L. Medical and Public Health Support L.1 X L.4 X _ App. 7 N. Exercises and Drills N.1.b X Q N-2 N 2.a X N-3 N.3.a X Q N-4 N.3.c X 5 N-4 N.3.d X 6 N-4

' N.3.e X l N-4 N.5 X  % N-6

0. Radiological Emergency Response Training

. 0.4.h' X l 0-3, App. 36 0.5' X P. Responsibility-for Planning Effort

-P.4. X P.7 X l P-5, App. 37 P.10 X 7

y- -.

x ENERGY CONSULTAhni RMrsde Omce Center 3 2101 N. Fvont St. . Hermeug PA 17110 (717) 236 0031 Resume current 01-11-85 JOHN W. BAER Education 1970 Post Graduate Study - Political Science American University Washington, D.C.

1966 Bachelor of Arts - Political Science Western Maryland College Westminster, Maryland Experience 1981 to Present Energy Consultants Harrisburg, Pennsylvania Project Manager, Emergency Management Services. Re-sponsible for providing supervision and technical assistance to project staff. Assigned responsibility for emergency managanent planning, procedure prepara-tion, personnel training, drill / exercise prepara tion, licensing support, and scheduling and coordinating project work with the client. Recent project assign-ments have included:

managing the offsite radiological energency pre-paredness programs for the Counties of Ashtabula, 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 preparation and ASLB hearing support; managing the offsite radiological emergency pre-paredness re-training program to support response to incidents at the Waterford 3 Steam Electric Station;

- coordinitting the offsite radiological emergency preparedness program to support response to inci-dents at the Callaway Plant including direct l responsibility for revision of the Missouri State

'e cace 1370Wotmpon Pke . MdQwte W 15017 . (412) 257 1350

John W. Baer Page 2 Nuclear Accident Plan and associated Ic<:al radio-logical energency response plans, preparation of affidavits to support motions for susmary dispo-sition of licensing contentions, development of local RERP tuplementing 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 drill and exercise program;

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

- development of the Louisiana Office of Emergency Preparedness implementing procedures and lesson plans for training of sta te , parish and local emergency response personnel in support of the Waterford 3 Steam Electric Station; and

- preparation of lesson plans and conduct of training prograars for state, county and local emergency response personnel in support of the R. E. Ginna Nuclear Station.

1973 to 1980 Southcentral Regional Planning Council Harrisburg, Pennsylvania Director. Responsible for achinistration of an eight-county planning and evaluation program for the Cosmon-wealth of Pennsylvania. Assisted local governments 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 35-hour training sessions for criminal justice personnel within a ten-state region. Developed 1

' and conducted practical group exercises for course participants.

Planner (1973 to 1978). Assisted local goverfments in planning and development of a range of criminal justice i

programs, criminal justice system cosuunications and l

automated inforsation systems.

I l

l

, - , . - . , ,_ ..- -_ . . ~ , _ - . . _ . _ ,

John W. Baer Page 3 1971 to '1973 Lord Fairfax Planning District Canaission 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 recossendations for security requirements. Top secret / crypto security clearance.

A d g 9e

1'._. -* . ._ . _ . _ _ _ _ . _ - . - -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY ) 50-441

)

(Perry Nuclear Power Plant, )

Units l'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-l .-

ning documents and specification of response requirements.

These, responsibilities-include responding to resolution items identified by th: 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

- 0 N

aof the matters stated herein and believe them to be true and correct. I make this affidavit in support of Applicants' Mo-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 it. 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.

i

d

4. The following paragraphs summarize each resolution 7

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).

s~

b. Item 13.3.2.2(2) requested additional de-tail on the process of transferring responsibilities to the Emergency Coordinator. This information was provided in 55 5.2.2.4 and 6.1.3 of the Plan (Rev.

3).

c.. 7. tem 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 55 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, 55 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 of Technical Support Center'(TSC) and Emergency Oper-ator' Facility (EOF) laboratory equipment. This'in-formation was provided in Plan _(Rev. 3), 5 7.3.9, with clarification-in the August:20, 1984 letter, and further revision to 5 7.3.9 in the October 29, 1984 CEI letter.

m g. Item 13.~3.2.3(3)' requested that provisions for backup laboratory facilities be made consistent with NUREG-0737. This was added in Rev. 3 of the Plan,~517.3.9'and-further clarified in the August 20, 1984 letter.

m

h. - Ite.n 13. 3. 2. 4 ( 1 ) asked that the Plan incor-2 porate into the emergency classification scheme com-ments contained in NRC Staff's January 11, 1984 let- g ter. This was done in.Rev. 3, Table 4-1, except for ,

the cogment on low water level, which CEI showed to &

be inapplicable to Perry in the April 28, 1984 let- i 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 tre agreed upon by-state / local authorities and are reviewed annually.

This was included in 5 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, ,

55 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 y discuss how the core. status graph (Fig. 4-1) will be f

used in the emergency action level scheme. This was provided in Rev. 3, 55 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 13.3.2.5(1) requested that the Plan describe the methods for prompt notification 1of;the public:in a rapidly escalating emergency. This was addressed in 5 6.4.2Lof 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-La . dress periodic-testing of.the sirens. This was'done in-Rev. 3, 5'7.2.5.

m. ' Item 13.3.2.6(1) requested Applicants to a provide for--backup communications capabilities be -

. tween the site and = all state /loca l ' authorities with primary.responseLresponsibilities.- Backup communica-tions capabilities lare-provided, as described in' 5: 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.

- - , - . _ . . = . _ _-.;.-- - - . -

n. Item 13.3.2.6(2) requested a coordinated communications link for fixed and mobile medical sup-port facilities. Information on this link was pro-vided in Rev. 3, 5 7.2.2.8, and by the August 20, 1984 letter.

s

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, 5 8.4.1.1.

p. Item 13.3.2.7(2) called for the Plan to specify the location of the Joint Public Information Center. Rev. 3 of the Plan added this in 5 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.

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 instruments and that instruments removed from service will be replaced by comparable instruments. NRC withdrew the request to specify. calibration frequency by letter dated February 29,'1984. The remaining in-formation was provided in Rev. 3, 5 8.3 and Appendix C and in the August 20, 1984 letter.

s. Item 13.3.2.8(3) called for the Plan to de-scribe the capability to_obtain 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day regional weather information, consistent with NUREG-0737, Supp. 1. This information was provided in the August 20, 1984 letter (5 7.3.7) and in a letter of agreement to be added to Appendix B.

t. Item 13.3.2.8(4) requested a commitment that permanent emergency response facilities and equipment be operational before fuel loading or that adequate interim facilities and capabilities be in place. As noted in the April 28, 1984 letter, this commitment had previously been made by letter from M.R. Edelman to B.J. Youngblood dated April 15, 1983 (PY-CEI/NRR-0032).

u. Item 13.3.2.9(1) called for additional in .

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

i Supp. 1, and transportation availability. This in- ,

formation was provided in the August 20 and October 29, 1984 letters (55 5.2.2.2, 5.2.2.4, 5.2.3, ,

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 Ficure 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 iacuation time estimate study to address the effects of adverse weather (i.e. thunderstorm) on a summer Sunday evacu-ation 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 and local 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 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 radiciodine skin decontamination. This was added in Rev. 3, 5 6.4.4.1, 6.5.3 and Appendix C.

aa. Item 13.3.2.12(1) called for the Plan to include a letter of agreement with Northwestern Memo-rial Hospital. As stated in the April 28, 1984, let-ter, and in Rev. 3, 5 5.3.3.2, the arrangements with Northwestern Memorial Hospital were made through CEI's medical consultant, Radiation Management Corpo-ration (RMC). CEI has a letter of agreement with RMC which is included in the Plan, App. B.

c bb. Item 13.3.2.12(2) requested a more detailed discussion in the Plan on first aid personnel, 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, 55 6.5.3, 8.1.3.

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. 3, 5 8.5.4.2, and in the August 20 and October 29, 1984 letters (5 8.5.4.1).

dd. Item 13.3.2.14(2) requested that the Plan indicate that the exercise 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, 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, 5 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-cy personnel will be provided. This information was provided in Rev. 3, 5 8.1.3.

gg. Item 13.3.2.16(1) called for the Plan to specify that the Nuclear Safety Review Committee has 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.

This was done in Rev. 3, 5 8.2, as supplemented by the October 29, 1984 letter.

hh. Item 13.3.2.16(2) requested more descrip-tion of the administrative procedures for revising the Plan and implementing procedures, including an indication that revised pages are dated and marked to show the changes. This information was provided in Rev. 3, 5 8.2.

ii. Item 13.3.2.16(3) requests that Appendix F of the Plan be updated. Revision 3 of the Plan updated Appendix F.

5. In summary, CEI has responded to and has resolved (or is resolving) all the resolution items set forth by the NRC Staff in Supplement 4 to the Safety Evaluation Report, pages 13-1 to 13-22. These items are not uncorrected deficiencies in the PNPP Emergency Plan.

' ^

, f

- ,, . M- ~

vn Daniel D. Hulbert d

Subscribed 'to and sworn by me this M ~ day of January, 1985.

M VNotary PulnPi{

JOSEPH C. SZWEJK0WSKI Notary Public, State cf Ohio Cuya. Ctv My Commission expires:

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

Electrician's Mate 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 (Emargency Planning), 1980 Eignt-40ek Davis-Besse Nuclear Power Station (Evacuation Time Estimates),

~

1981 One-Week Electrical Fundamentals II, 1981 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 the 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-paced in several Emergency Plan exercises at other Nuclear Power Plants as an official 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 Raactor operator on a $5W Class Submarine. Duties included operation and maintenance of electrical systems, chemistry controls for both primary and secondary plant, apd routine and emergency health physics coverage. As signments included one tour on an S5W Submarine and one tour assigned to the Radiological Controls Division of' a Submarine Tender.

E 4

3m E

2 5 -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) __

}

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 5=

ILLUMINATING COMPANY ) 50-441 -

) =

(Perry Nuclear Power Plant, )

Units 1 and 2) ) {_

A AFFIDAVIT OF JANET E. DUGAN =]

ON CONTENTION GG q a -

County of Lake ) E_

) ss. 5 State of Ohio )  ; .

h 4

JANET E. DUGAN, being duly sworn, deposes and says: j

1. A I have been employed by CEI since March 1982 at the 7 i

Perry Nuclear Power Plant. Since April 1983, I have held the =

=

position of Associate Governmental Affairs Representative as- 9 d

signed to the Emergency Planning Unit of the Community Relation 2 Section of CEI. My responsibilites in my current position have included coordination and support of the Evacuation Time Esti- b mate Study prepared by HMM Associates, Inc., the offsite emer- -

3 4

gency response training, and the development of the prompt alert and notification system for the Perry plume EPZ. A cur- .

]

rent statement of my professional qualifications and experience @

5 is attached hereto. My business address is 10 North Center j 5-g i 99e675 A

Street, Perry, Ohio 44081. 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 Sum-mary Disposition of Contention GG.

2. The purpose of this affidavit is to explain the basis for confidence that there are no identifiable population groups within the EPZ which do not use radios and TV (such as the Amish), and to explain the basis for confidence that -- in any case -- in the event of an evacuation of the Perry EPZ, any in-dividuals without radio or TV would learn of the need for pro-tective action.

3. In 1984, CEI conducted a study to determine the loca-tion of the Amish in northeastern Ohio, as a part of the Perry-Hanna transmission line proceedings. The results of that study indicate that there is no Amish population within the Perry-plume EPZ.

4. The planning commissions of Lake, Ashtabula, and Geauga Counties have also been contacted. The representatives of these-agencies were aware of no information ind!cating that there are any population groups within the plume EPZ which do not use radio and TV.

5. In addition, local Councils of Churches as well as parish priests and various other ministers throughout the EPZ were contacted. None of these persons was aware of any people within the EPZ whose religious beliefs would preclude use of radio or TV.

L

6. In any case, in the event of an evacuation of the Perry RPZ, any persons without radio or TV would learn of the

need for protective action. The public information brochure to be mailed to all residents of the plume EPZ prior to fuel load i

and annually thereafter will include a special needs informa-tion' card to be completed and returned to the respective County

Disaster Services Agency by anyone who might need special as-sistance in an emergency. The special help categories on the card include persons without radio and persons without TV. In the event of an evacuation of the Perry EPZ, the appropriate County Disaster Services Agency would provide special personal notification to those individuals -- if any -- who have indi-cated that~they have no radio or TV.

7. The public information brochure (and other media)

, will educate the public to tune to an Emergency Broadcast Sys-tem ("EBS") radio or TV station when the sirens within the plume EPZ are sounded, to receive a message. Therefore, even if a household does not have a radio or TV, it will be aware of the needfto seek additional information about the EBS message from friends or neighbors with TV or radio.

8. Finally, each of the offsite plans for the Perry EPZ includes a means for verifying that persons within the plume

-EPZ have received notification in an emergency. Prior'to fuel

loid, each household will be provided with a green card stating "WE HAVE BEEN NOTIFIED." In the event of an emergency, members of the public would ute the card to indicate that they are aware of the need to take specific protective action. The brochure instructs the public:

To show that you know about the emergency and you know what to do, put your green card in a window. Be sure it can be seen from the road. Or tie a towel to your front door or mailbox or to anything that can be seen from the road.

This same message will be repeated in the EBS announcement broadcast at the time of the emergency. Any household not displaying the card or a towel would be individually checked,-and given the EBS message.

9 In summary, there is no identifiable population group within the Perry plume EPZ which does not use radio or TV. In any case, in the event of an evacuation of the EPZ, any individuals without radio or TV would learn of the need for protective action, vi/* k.L 1sm- )

'/ Janet E. Dugan /

Subscribed and sworn to before me this / day of February, 1985.

OmJL p ptary Publiq// /

0.bM V M5EPH C. SZWEJK0W5KI hotary Public, State of Ohm Cuya Cty My Commission expires: 4 r- " f.nowa July 14. Isas

Janet E. CuEan Ass:c;a:e Coverr.nen:a1 Aff air.t er rer en t: 01.M Ene.gency Planning L'ai:

Cc-nunity Relat.cns Sec t:c Tne M'. inatirg Ocmpany; Perry *u: lear :-c'.Tr

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Sne ;s a ::ve in cc:n .ne cr:ress;0.2. ar acire: : ,r. r.ity :: ere. 3r.e nas ceen en;1cyed at : e Ferry L: lear f:wer ?ian. s;nce i;5: ::stn as a ::nste;: ..

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9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY ) 50-441

)

(Perry Nuclear Power Plant, )

Units.1 and 2) )

AFFIDAVIT OF DAVID R. GREEN ON CONTENTION JJ County of Lake )

) ss

-State of Ohio )

David R. Green, being duly sworn, deposes and says:

1. I am a Senior Project Engineer, Nuclear Engineering Department of The Cleveland Electric Illuminating Company. My business address is 10 Center Road, Perry, Ohio 44081. I am the head of Systems and Equipment Design in the Nuclear Design and Analysis Section and am responsible for all the electrical systems and the electrical technical support for the plant. 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 JJ.

bJ F0162 [63

2. Contention JJ states that the emergency plans do not provide for back-up power so that evacuation procedures and activities can be carried out. Sunflower Alliance's explanation of this contention argues that the emergency plans should addrcas the availability of electrical power "to compensate for the loss of power from PNPP that would accompany an accident." Sunflower Alliance's Particularized Objections to Proposed Emergency Plans in Support of Issue No. 1, dated August 20, 1984, p. 17.

3. Sunflower's argument incorrectly assumes that an accident at Perry would cause a loss of power in the area surrounding the plant. The Final Safety Analysis Report, Section 8.2.2.2, addresses the availability of electrical power from the transmission system under the conditions that would accompany an accident, i.e., the loss of power from PNPP. As shown in the FSAR, load flow and stability studies show that a full load trip of both units or the tripping of one unit with the other online or offline will not impair the ability of the preferred source to provide power to the Class IE System. FSAR S 8.2.2.2. The " preferred source" mentioned in the FSAR is the i offsite power from the transmission grid system. This power is available from generating stations other than PNPP through the transmission grid and distribution system. Therefore, sufficient power would be available in the area to " operate sirens, emergency-set traffic lights, independent radiation l

monitoring equipment, gasoline pumps and the like" even if the Perry facility were to shut down because of an accident.

- i 4%

David R. Green ,

Subscribgandswornbefore this / day of 632RU T , 1985 cm d~

taryGNblic n b /JO h k H C. SZWEJK0WSKI Not:7 u lic. State of Ohio Cuya. Cty.

My Comission Expires: my comnusson Expro July 14, 1808

E

+ _

DAVID R. GREEN PROFESSIONAL QUALIFICATIONS -

L My name is David R. Green. I ata employed as a Senior Project I l

Engineer in the Nuclear Engineering Department of The Cleveland i I have extensive and intensive 1 Electric Illuminating Company.

l experience in design, construction, startup, operations, '-

3 l maintenance, and electrical equipment failure diagnosis and i repair engineering for both nuclear and fossil-fueled power j t plants. I also act as CEI's Rotating Electrical Machinery

[ Specialist.

EXPERIENCE - The Cleveland Electric Illuminating Company i since 1955

1983-Present Senior Project Engineer; Electrical, Instrumentation and Control, Chemical, r Environmental and Equipment Qualification, l Nuclear Design and Analysis Section of the Nuclear Engineering Department.

[

f 1981-83 Senior Project Engineer, Engineering Unit, ud

[

Nuclear Design Section of Nuclear Engineering Department - responsible for construction and {

. startup support engineering (electrical and

mechanical) for Perry Nuclear Power Plant. Also

responsible to serve as CEI's Rotating

} Electrical Machinery Specialist.

t l 1979-81 Senior Project Engineer, Electrical and Instrumentation and Control - responsible for i

electrical, instrumentation and control design

! for Perry Nuclear Power Plant.

B l 1975-79 Senior Electrical Engineer - responsible for all

- electrical design for Perry Nuclear Power Plant. _

1973-75 Project Electrical Engineer - responsible for electrical design construction and startup for Avon 10 and Eastlake 6 plants, both 35-MW gas 5 turbine projects.

i 1968-72 Project Electrical Engineer - responsible for electrical engineering on all phases of Eastlake a Plant, a 650-MW coal-fueled unit, including the direction of the electrical check, test and

[ startup.

g s

1969-71 Project Engineer - responsible for design, _

construction, startup on the world's first 345 _

KV SF6 Gas-Insulated Bus, installed at the 1l r

Eastlake Plant.

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-1965-68 Projsct Electrical Engineer - participated in various engineering positions on the following projects: Avon 9 (a 650-MW fossil plant),

Lakeshore 18, Avon 8, Ashtabula 5, and Eastlake 4 (all 250-MW coal-fueled plants).

Served as Plant Electrical Operator during two company strikes for periods totaling six months (1968 and 1973).

EDUCATION: B.S. Electrical Engineering, Case Institute of Technology, 1955.

Power Systems Engineering Course (9 months),

General Electric, 1966-67.

Numerous seminars and short courses including General Electric BWR training.

-REGISTRATION: Professional Engineer, Ohio, 1958.

SOCIETIES: IEEE Memberships include:

Rotating Machinery Committee, 1967-present..

Synchronous Machinery Subcommittee, 1967-present.

Working Group Chairman - Turbine Generator Shaft Stress, 1972 present.

Excitation Systems and Equipment - 1967-present.

Nuclear Power Engineering - Qualification Subcommittee, 1975-present.

Working Group Member, IEEE 649 Qualification of Motor Control' Centers for Nuclear Plant Use, 1977-present.

Working Group Member, IEEE 323 Electrical Equipment Qualification for Nuclear Plants, 1975-78.

Liaison IEEE 387 Diesel-Generators for Nuclear

' Plant Use, 1980-present.

ANSI Memberships include:

Rotating Synchronous Machinery (C50.10-14).

Power Plant Motors (C50.19).

PUBLICATIONS: IEEE 62-970.- Proper Motor Application and Engineering Can Reduce Costs and Improve Reliability.

' IEEE 70 CP 217 - Electrical Features of Avon Unit 9.

Electrical World - 1973, World's First 345 KV SF6 Bus.

i 4