ML20100C542
| ML20100C542 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/25/1985 |
| From: | Hulbert D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | |
| Shared Package | |
| ML20100C521 | List: |
| References | |
| OL, NUDOCS 8503290143 | |
| Download: ML20100C542 (3) | |
Text
.
T WTED CORRESPONDENC8L
' ~
cow ETE:
USMC
'E3 /M 28 A10:41 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION GFFICE :3 EECREDJW CCCKEir 3 & SEPVICf.
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) . . . , . . - . , - . . . . . . ~ . . -
)
THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
APPLICANTS' DIRECT TESTIMONY OF DANIEL D. HULBERT ON ISSUE NO. 1 - CONTENTION J
- 1. I am presently Emergency Planning Coordinator, Perry Plant Technical Department, The Cleveland Electric Illuminating Company. My business address is 10 Center Road, Perry, Ohio 44081. In my position, I am responsible for developing, e
maintaining, and evaluating the Perry Nuclear Power Plant (PNPP) Emergency Plan, including coordinating emergency preparedness among various PNPP departments and developing emergency planning documents and specification of response i
requirements. These responsibilities include the development of Emergency Action Level ("EAL") indications.
- 2. Contention J states:
Emergency Action Level indicators are incomplete in the Applicants' emergency plan.
The contention was based on Sunflower's reading of Table 4-1 of the Perry Emergency Plan, Rev. 3, in which according to Sunflower critical measurements or standards are left 8503290143 850325 PDR ADOCK 05000440 R PDR
1 incomplete. Sunflower Alliance's Particularized Objections to Proposed Emergency. Plans in Support of Issue No. 1, dated August 20, 1984, page 16.
- 3. Emergency Action Levels (EALs) describe specific plant conditions at which one of the four Emergency Classifications (Unusual Event, Alert, Site Area Emergency, General Emergency) are to be declared. Table 4-1 of the Perry Emergency Plan, Rev. 3, sets forth more than 200 individual EAL indications.
- 4. Of the 200 individual EAL indications, only 13 were
" incomplete" in Revision 3 of the Perry Emergency Plan. Table 4-1, EAL 55 I.3.a.(1) and (2), II.l.a(1), III.ll.a, b and c; IV.6.a(2), b. In each case, the value to be included later was not available at the time Revision 3 of the Plan was issued, because the value could only be determined after the detailed technical data became available.
- 5. In each of the 13 cases where a value was to be added later, a comparable value was specified. For example, Table 4.1, EAL 5 I.3.a(1) states:
Off-gas pretreatment process radiation monitor high alarm with indication of (1) increase of (later) mrem /hr in 30 min.
(equiv. to 100,000 uCi/sec).
- 6. In each of the 13 cases in Revision 3, either the
" missing" values have now been developed based upon additional l detailed information which became available after Revision 3 was issued, or alternate indications have been selected. In all cases, these have been included in Revision 4 to the Perry i
t Emergency Plan, which was issued in February 1985. There are no incomplete EALs.