ML20101P475

Affidavit of Jt Pugh Re Eddleman Contention 57-C-7

ML20101P475
Person / Time
Site:	Harris
Issue date:	01/02/1985
From:	Pugh J CAROLINA POWER & LIGHT CO., NORTH CAROLINA, STATE OF
To:
Shared Package
ML20101P355	List: ML20101P352 ML20101P372 ML20101P395 ML20101P411 ML20101P475
References
OL, NUDOCS 8501070141
Download: ML20101P475 (4)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Power Plant) )

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AFFIDAVIT OF JESSE T. PUGH, III ON EDDLEMAN 57-C-7 County of Wake )

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State of North Carolina

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JESSE T. PUGH, III, being duly sworn, deposes and says:

1. I am the Director of the Division of Emergency Management of the North Carolina Department of Crime Control and Public Safety. In my position, I am responsible for the State's planning for and response to all emergencies, including accidents at any of the four nuclear plants that affect North Carolina. My business address is 116 West-Jones Street, Raleigh, North Carolina 27611. I have personal knowledge of the matters stated herein and believe them to be true and correct. I make this ' Affidasit in response ' to Eddleman Contention 57-C-7. I have reviewed this

- contention and am familiar with the substance of the allegations contained therein.

2. Through the Division of Emergency Management, I have directed the State's response to mcre than 650 emergency cases in the last year alone, including the tornadoes in March and Hurricane Diana in September. In my professional capacity, I

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have been involved in the development of the off-site emergency response capability for the Shearon Harris Nuclear Power Plant as well as the Catawba, McGuire and Brunswick nuclear plants. A current statement of my professional qualifications and experience is _

attached hereto as Attachment 1.

3. One of the primary responsibilities of the Division of Emergency Management as set forth in the state Emergency Response Plan (ERP) for the Harris Plant is the preparation and maintenance of that plan. Part 1,Section V.B.3. of the ERP lists the hospitals which will support the plant and surrounding communities'in the event of radiological emergencies. Of those hospitals, Duke University Medical Center and North Carolina Memorial Hospital may be considered regional facilities from the standpoint that they provide medical treatment for patients from across North Carolina and the southeastern United States.

4. I have reviewed the affidavits of Dr. Fred A. Mettler, Jr. and Dayne H. Brown as to the capabilities both of the hospitals listed in the ERP and of the Oak Ridge REAC/TS unit to treat cases of severe radiation exposure per se. The Division of Emergency Management will proceed to include that information in the NC ERP.

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Jesse"I'. Pugh, Ill i Subscribed and sworn to before me i

thisiday of January,1985.

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Notary'Public l

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~ .1' Attachm:nt 1 JESSE THOMAS PUGH, III '

l Professional Qualifications EDUCATION Graduated Asheboro High School, Asheboro, North Carolina, 1965 North Carolina State University, Raleigh, North Carolina, 1969, B.S., Textile Technology Compucer Application Certificate Program, NCSU, Spring 1982 Enrolled in Master of Public Administration Program, NCSU Graduate, Government Executives Institute, University of North Carolina, Chapel Hill,1980 EMPLOYMENT Area Coordinator, Division of Civil Preparedness, Asheboro, North Carolina, July 1978 - May 1979. Responsible for 15-county area working with local coordinators and governmental officials in, preparing plans to prevent and/or respond to disasters, both natural and man-made. Also responsible for arranging specialized training for local volunteers and governmental employees. -

Assistant Director, Division of Emergency Management, May 1979 -

May 1980, promoted to Deputy Director May 1980. Responsible for daily operations of the Division. Supervise 53 employees, administer budget of approximately $2 million, managed grant program to local governments, represent the State in business transactions and in meetings with local and federal government.

Division Director, Division of Emergency Management, .May 1982 to present. Responsible for the State of North Carolina emergency response and planning. This includes the coordination of all emergency response activities of the 17 State agencies. Serve as State Coordinating Officer and Gove rno r's Authorized Representative in all disaster related matters. In emergencies '

serve as leader of the State Emergency Response Team.

MILITARY United States Marine Corps, June 1969 - April 1982, highest rank: -

First Lieutenant

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TRAINING Radiological Monitoring Instructor Course, August 1978 Basic Seminar for Civil Preparedness Personnel, September 1978 Civil Preparedness Career Development, Phase I, September 1978 Basic Radiological Defense Officer Course, September 1979 United State Coast Guard National Search and Rescue School,-

Governor's Island, New York, March 1984.

PROFESSIONAL ORGANIZATIONS North Carolina Emergency Management Association National Coordinating Council on Emergency Management National Association for Search and Rescue National Emergency Management Association Association of State Dam Safety Officials 9

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