ML20101S967

Affidavit of Ti Hawkins in Support of Applicant Motion for Summary Disposition of Contention 57-C-7.Certificate of Svc Encl

ML20101S967
Person / Time
Site:	Harris
Issue date:	01/29/1985
From:	Hawkins T Federal Emergency Management Agency
To:
Shared Package
ML20101S963	List: ML20101S961 ML20101S967
References
OL, NUDOCS 8502050742
Download: ML20101S967 (5)

Text

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UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION

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

)

CAROLINA POWER & LIGHT COMPANY )

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

)

(Shearon Hr.rris Nuclear Power )

Plant) )

AFFIDAVIT OF THOMAS I. HAWKINS IN SUPPORT

-OF APPLICANTS' MOTION FOR SUMMAP.Y DISPOSITION OF CONTENTION 57-C-7 County of Fulton )

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) ss.

State of Georgia )

Thomas I. Haukins, baing duly sworn, deposes and says:

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1. My present position is Emergency Management Program Specialist for the Federal Emergency Management Agency. Included among my responsibilities is the radiological emergency planning liaison function between FEMA Region IV and the States of North and South Carolina. In this position, I am responsible for the review of radiological plans and preparedness for the State of North Carolina and the State of South Carolina and for the local governments within those States.

I have held this position since December 1981. .I'have been employed by FEMA since July 1978. A current statement of my

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professional qualifications is attached hereto. My business address is 1371 Peachtree Street, NE;- Suite 736 - Atlanta, Georgia, 30309.

'I h' ave personal knowledge of the matters discussed herein and believe them to-be-true and correct. I make this affidavit in response'to Eddleman Contention 57-C-7.

2. Eddleman 57-C-7 contends:

Neither the State ERP nor the county ones make clear whether the hospitals listed in Section V.B.3. of the State ERP are prepared to treat severe radiation exposure-per se. Plans should include lists of local and regional hospitals with the.necessary capa5ITitles to provide medical services for those seriously injured by. radiation alone.

FEMA guidance requires that "Each organization shall arrange for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals." (NUREG-0654, criterion L.l . )

FEMA guidance also-requires that "Each State shall develop lists indicating the location of public, private and military hospitals and other emergency medical services facilities within the State or contiguous States considered capable of providing medical support for any contaminated individual. The listing shall include the name, location, type of facility and capacity and any special radiological capabilities. These emergency medical services should be able to radiologically monitor contamination personnel, and have facilities and trained personnel able to care for contaminated

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injured persons." (NUREG-0654, criterion L. 3. )

Section V.B.3. of the State ERP-is in accord with NUREG-0654, criteria L.l. and L.3.-

FEMA staff understands,lafter reviewing the " Affidavit of Jesse T.

Pugh, III on Eddleman 57-C-7" that the North Carolina Division of Emergency Management will include, in their ERP, the information contained in the affidavits of Dr. Fred A. Mettler, Jr. and Dayne H.

Brown regarding the capabilities of the hospitals listed in the ERP and of the Oak Ridge REAC/TS unit to treat cases of severe radiation per se. This action would go beyond the NUREG-0654 3

requirements of FEMA and would clearly supply the information asked for in Contention 57-C-7.

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Thomas I. Hawkins Sworn to and subscribed before me this S Q day of January, 1985

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NOTAR? PUBLIC FOR STATE OF GEORGIA My Comnission ExP i res . . .Notary

_ c,mmPublic Georgia.

u.cn c,.3,,cs State at Large n,v 12.19m.

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

'In the Matter of CAROLINA POWER AND LIGHT COMPANY AND p Docket Nos. 50-400-OL 50-401-OL NORTH CAROLINA EASTERN MUNICIPAL POWER AGENCY ')I

)

(Shearon Harris Nuclear Power Plant, Units 1 and 2) ))

CERTIFICATE OF SERVICE 4

I hereby certify that copies of " FEMA STAFF RESPONSE TO APPLICANTS' MO

SUMMARY

DISPOSITION OF EDDLEMAN 57-C-7" in th or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Comission's internal mail system, this 1st day of February,1985:

1 James L. Kelley, Chairman

• Richard D. Wilson, M.D.

Administrative Judge 729 Hunter Street Atomic Safety and Licensing Board Apex, NC 27502 U.S. Nuclear Regulatory Comission Travis Payne, Esq.

Washington, DC 20555 723 W. Johnson Street Mr. Glenn 0. Bright

• P. O. Box 12643 Administrative Judge Raleigh, NC 27605 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Dr. Linda Little Governor's Waste Management Building Washington, DC 20555 513 Albermarle Building Dr. James H. Carpenter

• 325 North Salisbury Street Administrative Judge Raleigh, NC 27611 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Dr. Harry Foreman, Alternate

• Washington,:DC 20555 . Administrative Judge P.O. Box 395 Mayo '

Daniel F. Read University of Minnesota -

Minneapolis, MN 5545'S CHANGE P. O. Box 2151 .

.Raleigh, NC 27602

't Robert P. Gruber John Runkle, Executive Coordinator Executive Director Conservation Counsel of North .Public Staff - NCUC Carolina P.O. Box 991 307 Granville Rd. Raleigh, NC ~27602 i Chapel' Hill, NC 27514 l George Trowbridge, Esq.

Bradley W. Jones, Esq. Thomas A. Baxter, Esq.

Regional Counsel John H. O'Neill, Jr., Esq. i USNRC, Region II Shaw, Pittman, Potts & Trowbridge 101 Marietta St., N.W. 1800 M Street, N.W.

Suite 2900 Washington, DC 20036 Atlanta, GA 30323 Atomic Safety and Licensing Board Wells Eddleman Panel

• 718-A Iredell Street U.S. Nuclear Regulatory Commission Durham, NC 27701 Washington, DC 20555 Richard E. Jones, Esq. Steven Rochlis Associate General Counsel Regional Counsel Carolina Power & Light Company FEMA 1371 Peachtree Street, N.E.

P. O. Box 1551 Atlanta, GA 30309 Raleigh, NC 27602 Spence W. Perry, Esq.

Atomic Safety and Licensing Appeal Associate General Counsel Board Panel

• Office of General Counsel U.S. Nuclear Regulatory Commission FEMA 500 C Street, S.W., Room 840 Washington, DC 20555 Washington, DJ 20472 Docketing and Service Section*

Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 I

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Elair.e I. Chan Counsel for NRC Staff i

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