ML20113E358

Affidavit of Ti Hawkins Supporting Applicant Motion for Summary Disposition of Conservation Council of North Carolina Contention 8.Prof Qualifications & Certificate of Svc Encl

ML20113E358
Person / Time
Site:	Harris
Issue date:	01/08/1985
From:	Hawkins T Federal Emergency Management Agency
To:
Shared Package
ML20113E307	List: ML20113E312 ML20113E321 ML20113E333 ML20113E358 ML20113E368 ML20113E375
References
OL, NUDOCS 8501230430
Download: ML20113E358 (8)

Text

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UNITED STATES OF AMERICA NUCLEAR PIGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In tt,e 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 THOMAS-I. HAWKINS IN SUPPORT OF APPLICANTS MOTION FOR

SUMMARY

DISPOSITION OF CCNC CONTENTION 8 County of Fulton )

) ss.

State of Georgia )

Thomas I. Hawkins, being duly sworn, deposes and says:

1. M:r present position is Emergency Management' Program Specialist for the Federal Emergency Fbnagement' 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 8501230430 850116 PDR ADOCK 05000400 PM g .

L..

professional qualifications is attached hereto. My business address is 1371 Peachtree Street, NE, Suite 736, Atlanta, Georgia, 30309. I have personal knowledge of the matters discussed herein and believe them to be true and correct. I make this affidavit in response to CCNC Contention 8.

2. CCNC contends:

10 C.F.R. 50. 47 (b) (1) mandates that "each principal response organization has staff to respond and to augment its initial response on a continuous basis" (emphasis added) while (b) (15) requires that "(e)mergency response training is provided to those who may be called on to assist in an emergency." The Radiation Protection Section (RPS) of the North Carolina Department of Natural Resources, one of the principal State agencies, does not have adequate staff and does not have adequately trained staff.

3. FEMA staff response asserts that:

During the last full-participation exercise at Plant Catawba in February 1984, FEMA evaluators found no NUREG 0654 deficiencies involving the Radiation Protection Section (RPS). In the two full-participation exercises before Catawba, Brunswick in May 1983 and McGuire in December 1982, FEMA evaluators found no significant deficiencies involving RPS and their accident assess-ment activities. FEMA evaluators; however, did find minor train-ing deficiencies involving RPS staff during the 1982 and 1983 exercises.

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Thomas I. Plaw)c.n)

Sworn to-and subscribed before me this 2 ( day of January,-1985 O

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NOTAT'l }UBLIC FOR STATE OF GEORGIA Notary Public. Georgia, State at targe I!y Commission Expires: My Commisson Emra fiev 12,1935 4

L' -

Thomas I. Hawkins Professional Qualifications My present position is Emergency Management Program Specialist for the, Federal Emergency Management Agency. I am assigned to the Radiological Emergency Planning liaison position between FEMA Region IV and the States of North and South Carolina. In this position, I am responsible for the review of radiological emergency plans and preparedness for the State of North Carolina and the State of South Carolina and for the local governments within these States.

I hav,e held the position of Emergency Management Program Specialist (or its equivalent) since December 1981. I have been employed by FEMA since July 1978.

From April 1964 to January 1977 I was employed as Planning Director of Clayton County, Georgia.

My formal education is as follows:

- AB Degree, Emory University, Atlanta, GA, 1958

- Master of City Planning Degree, Georgia Tech., Atlanta, GA, 1963

- Completed Radiological Emergency Response Course at the U.S.

Department of Energy's Nevada Test Site, April 1982

- Completed Radiological Defense Officer and Radiological Defense Instructor Course, Georgia Emergency Management Agency, Atlanta, GA, March 1982

- Completed Basic Management Seminar for Emergency Management Personnel, Valdosta State College, Thomasville, GA, Winter Quarter, 1980

- Completed Radiological Emergency Planning Seminar, National Emergency Training Center, Emmitsburg, Maryland, October 1982

- Completed Radiological Accident Assessment Course, National' Emergency Training Center, Emmitsburg, Maryland, August 1984 e

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CAROLINA POWER AND LIGHT COMPANY AND )

NORTH CAROLINA EASTERN MUNICIPAL ) Docket Nos. 50-400 OL POWEP AGENCY ) 50-401 OL

)

(Shearon Harris Nuclear Power Plant, )

Units I and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " FEMA STAFF RESPONSE TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF CCNC CONTENTION 8" in the above-captioned proceeding have been served by the Staff on the following by deposit in the United States mail, first class, or deposit in the Nuclear Regulatory Commission's internal mail system (*), this 16th day of January,1985.

James L. Kelley, Chairman

• Pichard D. Wilson, M.D.

Administrative Judge 729 Hunter Street Atomic Safety and Licensing Board Apex, NC 27502 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Glenn 0. Bright

• Travis Payne, Esq.

Administrative Judge 723 W. Johnson Street Atomic Safety and Licensing Board P.O. Box 12643 U.S. Nuclear Regulatory Commission Raleigh, NC 27605 Washington, DC 20555

.Dr. James H. Carpenter

• Dr. Linda Little Administrative Judge Governor's Waste Management Puilding Atomic Safety and Licensing Board 513 Albermarle Puilding 325 North Salisbury Street l

H.S. Nuclear Regulatory Commission Washington, DC 20555 Raleigh, NC 27611 Daniel F. Read John Runkle, Esq. Executive Coordinator **

CHANGE. Conservation Counsel of North Carolina

[ P.O. Box 2151 307 Granville Rd.

I Raleigh, NC 27602 . Chapel Hill, NC 27514 i

Steven Rochlis Spence W. Perry, Esq.

Regional Counsel Associate General Counsel FEMA Office of General Counsel 1371 Peachtree Street, N.E. FEMA Atlanta, GA 30309 500 C Street, SW Rm 840 Washington, DC 20472 Atomic Safety and Licensing Appeal- Bradley W. Jones, Esq.

Board Panel Regional Counsel, USNRC, Region II U.S. Nuclear Regulatory Commission 101 Marietta St., N.W. Suite 2900 Washington, DC 20555 Atlanta, GA 30323 Robert P. Gruber George Trowbridge, Esq.

Executive Director Thomas A. Baxter, Esq.

Public Staff - NCUC John H. O'Neill, Jr., Esq.

P.O. Box 991 Shaw, Pittman, Potts & Trowbridge Raleigh, NC 27602 ,

1800 M Street, N.W.

Washington, DC 20036 Vells Eddleman Atomic Safety and Licensing Board 718-A Iredell Street Panel

• Durham, NC 27701 U.S. Nuclear Regulatory Commission Washington, DC 20555 Richard E. Jones, Esq. Dr. Harry Foreman, Alternate Associate General Counsel Administrative Judge Carolina Power & Light Company P.O. Box 395 Mayo P.O. Box 1551 University of Minnesota Raleigh, NC 27602 Minneapolis, MN 55455 C [. h d M Janice E. Moore Counsel for NRC Staff

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