ML20112J928

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Affidavit of Jt Pugh Re Applicant Motion for Summary Disposition of Eddleman Contention 213-A.Emergency Response Plan Conforms to Criterion II.P.7 of NUREG-0654.Plan Will Be Amended to Include List of New Procedures
ML20112J928
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 01/11/1985
From: Pugh J
CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, NORTH CAROLINA, STATE OF
To:
Shared Package
ML20112J843 List:
References
RTR-NUREG-0654, RTR-NUREG-654 OL, NUDOCS 8501180424
Download: ML20112J928 (8)
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E?! ETE3 UNITED STATES OF AMERICA - >kC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA V 17 Pl :57 W:Ci v e,,.

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In the Matter of ) - ' l{!

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))

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

SUMMARY

DISPOSITION OF EDDLEMAN 213-A 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 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 offsite emergency capability for the Shearon Harris plant as well as the Catawba, McGuire and

.[ Brunswick nuclear plants. Through the Division of Emergency O Management, I have directed the State's response to more than L

,o yt 650 cases in the last year alone, including the tornadoes in 34$ March and Hurricane Diana in September. A current statement of

$ 'my professional qualifications and experience is attach-d sto.

hereto as Attachment A. My business address is 116 West Jones Street, Raleigh, North Carolina 27611.

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2. I make this affidavit in response to Eddleman Contention 213-a. I have read this contention and am familiar with the substance of the allegations contained therein. I have personal knowledge of the matters stated in this Affidavit and believe them to be true and correct.
3. Eddleman Contention 213-a contends that "each offsite ERP should contain an appendix which conforms to evaluation criterion II.P.7 of NUREG-0654 or it should be demonstrated that such an appendix is unnecessary because its functions are performed in some other way by the present form of the Plans."

It is the State's position that the Emergency Response Plan

("ERP") as currently constituted conforms to evaluation criterion II.P.7 of NUREG-0654.

4. The Emergency Response Plan ("ERP") for the Shearon

, Harris facility is divided into five parts, Parts 1-5. Part 1 sets forth the State's responsibillity and involvement in emergency planning and response for Shearon Harris. Parts 2 through 5 set forth the responsibility and involvement for emergency planning and re sponse for Chatham, Harnett, Lee and Wake counties respectively. Attachment 2 for each Part of the ERP lists by title the standard operating procedures to be used in the implementation of the Plan for the State and each of the four counties respectively. For example, Attachment 2 to

'Part 1 lists the plans and standard operating procedures supporting the State's involvement in the Shearon Harris ERP as set forth in Part 1. Likewise Attachment 2 for Parts 2 through 5 sets forth the respective county procedures and plans supporting the ERP.

5. The titles of the procedures listed in Attachment 2 to the various Parts indicate the section(s) of the Plan to be implemented. For example, the standard operating procedure labelled Emergency Operations Center indicates that this procedure is used to implement those sections of the Plan that discuss the respective county emergency operations centers.

See Part 2, III.C, Part 3, III.C, Part 4, III.C and Part 5, III.C of the ERP. In regard to the " State Emergency Response Team Standing Operating Procedures," Part I, Attachment 2 and the " Standard Operating Procedures (SOP)" for Chatham, Lee and Wake counties, Parts 2, 4 & 5, Attachment 2,.these procedures consist of a single document for each organization which sets forth generally applicable procedures to be used by that organization in emergencies generally. As such, these procedures provide additional detail for implementating the ERP as a whole.

6. Additionally,Section IV, paragraphs B, C, D, E, F and G of each Part of the ERP, Parts 1 through 5, identify a host of specific procedures that are to be undertaken by the State and the various counties in the implementation of the various i sections of the ERP. For example,Section IV.G of Part 1 and l Sections IV.F of Parts 2 through 5 identify numerous actions and procedures to be undertaken by the State and counties with respect to radiological exposure control. Among the procedures set forth in these provisions are procedures governing who is to receive dosimeters and the procedures to be followed in the l

l assignment of dosimeters. See, e.g.,Section IV.G.3 of Part 1.

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! Similarly, Sections IV.E.4 & 5 of Part 1 and Sections IV.E.7 of Parts 2 through 5 set forth procedures with respect to providing and monitoring evacuation transportation. The other paragraphs of Section IV referred to above likewise provide and identify specific procedures that will be undertaken by the State and the counties in implementing the Emergency Response Plan. In certain instances these procedures are supplemented and set forth in greater detail in Annexes C, E, G and J to the Plan. It is my opinion that Attachment 2 to Parts 1 through 5 combined with the specific procedures set forth in the Plan comply with criterion II.P.7 of NUREG-0654 or, alternatively, perform the function intended thereby in that they identify the procedures to be used in implementing the Plan and the section(s) which they implement.

7. Beyond those procedures currently identified in the Plan set forth in Paragraphs 4 and 6 above, the State and counties are presently developing additional standard operating procedures to aid in_the implementation of the ERP for the Shearon Harris Facility. A list of additional procedures currently under development is set forth in Attachment B to this Affidavit. As is apparent from this list, the procedures under development are detailed and extensive. The State intends to amend the Emergency Response Plan to include new procedures as part of the implementing procedures currently identified and set forth in Attachment 2 of the various Parts of the Emergency Response Plan. This is scheduled to be done prior to the required drills and exercises for the Shearon Harris facility. Additionally, the Attachments, as amended, will identify the various section(s) of the Plan that each L-

r procedure (both those presently listed and those being added) are intended to implement.

8. In summary, the Emergency Response Plan as presently constituted conforms to criterion II.P.7. of NUREG-0654. The Plan currently lists in Attachment 2 for each Part the various standard operating procedures to be used in its implementation and the Plan itself identifies and sets fort.h numerous other procedures that are to be used in the implementation of the various section(s) of the Plan. Additionally, the State and the counties are in the process of developing numerous additional standard operating procedures to aid in the implementation of the Shearon Harris Emergency Response Plan.

The Plan will be amended to include a list of new procedures as well as the various section(s) of the Plan that both the new and previously identified standard operating procedures implement.

aame l aw er esse T. Pudh, III Sworn to and subscribed before me this //' day of January, 1985.

Yl/L S$ bu _

Notary Puplic My Commission expires:

/ 7 2 7- 79

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. I Attachment A l 1

JESSE THOMAS PUGH, III Professional Qualifications 1

EDUCATION Graduated Asheboro High School, Asheboro, North Carolina, 1965 North Carclina 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 EMPI4YMENT 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 em plo ye e s ,

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 j serve as leader of the State Emergency Response Team.

I l MILITARY

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

l First Lieutenant l

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l A-1 l

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G Attachment A TRAINING Radiological Monitoring Instructor Course, August 1978 Basic Seminar fot 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 i

A-2

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Attachment B County Standard Operating Frocedures (SOPS)inSupportofNuclearPowerPlants

1. Emergency Operating Center (E0C)
2. Shelter Management
a. Radiologi:al Monitoring / Decontamination A part of this SOP (people and vehicle) which will include other operating
b. Shelter Communications procedures
3. Warning and Notification (public)
4. Special Transportation
a. Schools d. Day Care Centers
b. Hospitals e. Homebound Handicapped
c. Nursing Homes f. Persons Without Transportation
5. Radiological
a. Radiological Monitoring c. Exposure Control e. Records
b. Decontamination d. Communications
6. St1ging Areas
a. Medical Resources
b. Rescue Resources
7. Traffic and Roadblocks Control
a. People Monitoring /0econtamination A part of this S0P which should include other
b. Vehicle Monitoring / Decontamination operating procedures
8. Training S0P
a. Shelter Management
b. Radiological
c. Exercises (1) Table Tops (2) Functional Exercises (3) EOSs 8-1
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