ML20112G955

Affidavit of Jt Pugh Supporting Applicant Motions for Summary Disposition of Conservation Council of North Carolina Contention 2 & Eddleman Contention 57-C-10

ML20112G955
Person / Time
Site:	Harris
Issue date:	01/14/1985
From:	Pugh J CAROLINA POWER & LIGHT CO., NORTH CAROLINA, STATE OF
To:
Shared Package
ML20112G899	List: ML20112G897 ML20112G929 ML20112G947 ML20112G955 ML20112G967 ML20112G975
References
OL, NUDOCS 8501160580
Download: ML20112G955 (6)

Text

_ _ _ - _ - _ _ _ _ - _ _ _ _ _ - _ ___

r IJanuary 14,1985 -

UNITED STATES OF AMERICA y .-

NUCLEAR REGULATORY COMMISSION "m 'O N BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ':. t1 s

' ';;yjl.'

In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

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

)

.(Shearon Harris Nuclear Power Plant) )

AFFIDAVIT OF JESSE T. PUGH, III IN SUPPORT OF APPLICANTS' MOTIONS FOR

SUMMARY

DISPOSITION OF CCNC CONTENTION 2 AND EDDLEMAN CONTENTION 57-C-10 County of Wake )

) SS:

State of North Carolina )

~

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

1. I am the Director of the Division of Emergency Management (JEM) 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. In that professional capacity, I 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. Through the Division of Emergency Management, I have directed the State's response to more than 650 cases'in the last year alone, including the tornadoes in March and Hurricane Diana in September. As a result of both these disasters, several thousand persons had to be sheltered in evacuation centers for various lengths of time. In addition to these practical experiences with sheltering,I have 0

0 PDR

_ - _ - _ _ _ - _ _ - _ - _ - _ - - _ _ - _ _ - _ _ . - _ _ 1

completed the Shelter Manager Course and Radiological Defense Officer Course -

conducted by DEM. A current statement of my professional qualifications and -

experience is attached hereto. 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 Affidavit in response to CCNC Contention 2 and Eddleman Contention 57-C-10. I have reviewed both of these contentions and am familiar with the substance of the allegations contained therein.

2. I have reviewed the results of the housing survey commissioned by Applicants and summarized in the Affidavit of Robert G. Black, Jr. In Support of Applicants' Motion for Summary Disposition of CCNC Contention 2 and Eddleman Contention 57-C-10. I believe that the results of this survey accurately reflect the cc dition of the housing stock in the Harris plume EPZ with respect to those characteristics that have the greatest effect on the sheltering effectiveness of a structure, that is, the presence or absence of a basement, number of stories and type of exterior wall. I also believe that the estimates of the protection factor of typical structures in the IIarris EPZ presented in Mr. Black's Affidavit are based on standard Environmental Protection Agency guidance and accurately represent the level of protection afforded by typical structures with the characteristics identified.

3. The Division of Emergency Management accordingly accepts the results of this housing survey and the protection factor estimates for typical housing in the EPZ. The North Carolina Emergency Response Plan in Support of the Shearon llarris Nuclear Power Plant ("the EIU") will be amended to reflect the results of the housing survey and to include an analysis of the level of protection from radiation releases afforded by typical residential structures in the Ilarris EPZ. Based upon the information reflected in Mr. Black's Affidavit, the estimated protection factors of typical residential structures will be listed in the ERP. With the addition of this information, the ERP will comply

with criterion J.10.m. of NUREG-0654 which calls for inclusion of information on the

" expected local protection afforded in residential units or other shelter for dirce'. and -

inhalation exposure" in off-site emergency plans. The information will be available tc officials who will decide what protective action (that is, evacuating or sheltering the populace) to take in the event of an accident at the Harris Plant.

4. It should be emphasized that the sheltering option will be utilized only if the State is *horoughly convinced that it would result in a lessening of radiation dose exposure to the public compared to other available options for protective action. We do not intend to use in-place sheltering for the general population on a long-term basis, that is, more than a period of several hours. Unless conditions make evacuation infeasible (e.g., the highways are temporarily impassable due to a heavy snowfall), evacuation of the affected population would be preferred if long-term protective action is needed. In-place sheltering provides adequate protection in the short term during some situations.

Even if sheltering is the initial recommended protective action and circumstances subsequently change, emergency planners could later order additional protective actions (including evacuation) as the situation develops. Thus, the availability of a sheltering option in no way detracts from the ability of emergency planners to protect the public.

Indeed, it is preferable that the sheltering option be available since planners need to have a " range of actions" available, as provided in the NRC's emergency planning rule, to respond to different situations.

5. Given the characteristics of housing in the Harris EP7, sheltering is an appropriate protective action in the circumstances where it may be used. Based on the results of the survey of housing in the liarris plume EPZ and my general knowledge of housing near other nuclear plants,I find no basis for the statement in CCNC Contention 2 that sheltering "is not adequate to protect the public health" in any circumstances.

The housing stock in the liarris EPZ is adequate to provide protection from some types of

radiatim release on a short-term basis. The characteristis of the hotsing in the Harrfs EPZ are similar to bcusing in the EPZs of the Brtmswick, Catawba and McGuire plants, -

for which the Div!sfon of 3mergency Management has planning responsibilities and about whleh I am familiar. Under the North Carolina off-tite amargency plans for cach of these plants, sheltering is one of the protective actions that !a available. Thdre la no basis for treating the Harris Plant differently. Emergsney planners should also have the flexibility to use the sheltering option In the event of an accident at the Harris Plant if the circumstances warrant.

M _

e' -

JESSE T. PUGI, III Subscribed and sworn to before ma this / day of January 1985,

.s _ >

p.m.y a:' o*e -N uu\.O  :$ otary Publia

~

""* tuton exptrej / E9 O

e 4-

JESSE THOMAS PUGH, III Professional Qualifications -.

EDUCATION Graduated Asheboro High School, Asheboro, North Carolina, 1965 North Carolina State University, Raleigh, North Carolina, 1969, B.S., Textile Technology Computer 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 Governor'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

~ ' ~

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 e

u