Affidavit of Ah Joyner Re Contention EPX-2.Corrective Actions Being Taken to Resolve Communications Problems Experienced During 850517-18 Exercise.Resolutions Expected Prior to Full Power Licensing of PlantML20137F616 |
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Harris |
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01/13/1986 |
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Joyner A NORTH CAROLINA, STATE OF |
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ML20137F380 |
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OL, NUDOCS 8601170559 |
Download: ML20137F616 (10) |
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Category:AFFIDAVITS
MONTHYEARML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc ML18016A8191999-02-12012 February 1999 Affidavit of G Thompson Re Application by CP&L for Amend to FOL NPF-63 & NRC Review of Application & Proposes to Determine That Amend Request Involves No Significant Hazards Consideration ML20209A9071987-01-28028 January 1987 Affidavit of JW Mckay.* Provides Minor Corrections to 861017 Affidavit.Corrections Should Be Made to Allegation on Undercut Tolerances for Holes Drilled to Receive maxi-bolt Anchors.Certificate of Svc Encl ML20214S1051986-09-25025 September 1986 Affidavit of SA Brown Re 860728 Affidavit of Ps Miriello Concerning Radiation Exposure,Filed in Support of Motion to Reopen Record.Allegations Re Exposure to High Levels of Radiation Unsupported ML20214S1271986-09-25025 September 1986 Affidavit of Tw Brombach Re Allegations Raised in Ps Miriello 860728 Affidavit Concerning QA Filed in Support of 860915 Motion to Reopen Record.Allegations W/O Factual Basis.Util s to Jn Grace Re Insp Encl ML20210B6471986-09-13013 September 1986 Affidavit of Ps Miriello Re safety-related Welds That Never Received Preservice Insp ML20205F3771986-08-0606 August 1986 Affidavit of Tw Brombach Re Issues Raised in 860702 Request for Institution of Proceeding Per 10CFR2.206,specifically Allegations on Inservice Insp of Piping Welds.Insp Rept 50-400/85-48 Encl ML20210B6961986-07-28028 July 1986 Affidavit of Ps Miriello Stating That QA Quality Check Program Not Used as Intended at Facility ML20210E0171986-07-28028 July 1986 Affidavit of Ps Miriello Re False Dose & Const Records Constituting Threat to Public Health & Safety ML20210U7691986-05-16016 May 1986 Affidavit of Ps Miriello Re Failure to Act on Issues of False Dose Records,Intimidation & Unsafe Radiation Practices Until After Contention W-4 Produced ML20210U7751986-05-15015 May 1986 Affidavit of Ps Miriello Re Health Physics Supervisors Ordering Author to Agree W/False Radiation Rept & to File NRC Form 4 in Agreement W/False Radiation Rept ML20204A4921986-05-0606 May 1986 Affidavit of SA Browne Re Results of Review of Ps Miriello 860403 Affidavit in Support of Conservation Council of North Carolina & W Eddleman Request for Admission of New Contention WB-4 ML20210K7041986-04-0303 April 1986 Affidavit of Ps Miriello Re Falsification of Exposure Records.Related Info Encl.W/Certificate of Svc ML20154N2091986-03-10010 March 1986 Suppl to HR Goodwin Affidavit on Timing of Weather Alerts, Per ASLB Request.Info on Precise Times That Weather Alerts Transmitted Unavailable.Certificate of Svc Encl ML20205K6031986-02-24024 February 1986 Affidavit of RW Fell,Supporting NRC Response to Aslab Question Re Conservation Council of North Carolina Contentions 16,17 & 18.Certificate of Svc Encl ML20137P5991986-01-30030 January 1986 Affidavit of Ti Hawkins,Supporting Nrc/Fema Response to Applicant Motions for Disposition of Eddleman Contentions EPX-2 & EPX-8.Certificate of Svc Encl ML20137J0731986-01-13013 January 1986 Affidavit of Ah Joyner in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys.Certificate of Svc Encl ML20137F6491986-01-13013 January 1986 Affidavit of M Scott Re Contention EPX-2.Chatham County Responded Appropriately & Effectively to Experience Gained During 850517-18 Exercise.Addl Dispatchers Will Assure Response to Radio Traffic Levels.W/Certificate of Svc ML20137F6161986-01-13013 January 1986 Affidavit of Ah Joyner Re Contention EPX-2.Corrective Actions Being Taken to Resolve Communications Problems Experienced During 850517-18 Exercise.Resolutions Expected Prior to Full Power Licensing of Plant ML20137F4171986-01-13013 January 1986 Affidavit of W Ethridge Re Contention EPX-2.Minor Highway Patrol Radio & Telephone Communications Delays During 850517-18 Exercise Were Due to Priority Assigned to Messages & Emergency Operations Ctr.Difficulties Being Resolved ML20137F4101986-01-13013 January 1986 Affidavit of Dh Brown Re Contention EPX-2.Relay Procedure Is Normal Operating Procedure for Radiation Protection Section Communications & Causes No Significant Delays or Addl Inaccuracies ML20137J0591986-01-10010 January 1986 Affidavit of R Capps in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys ML20136F6401985-12-31031 December 1985 Affidavit of Dn Keast Re Correction to 851104 & 05 Oral Testimony on Eddleman Contention 57-C-3.Certification of Svc & Notice of Withdrawal Encl ML20137L7951985-11-26026 November 1985 Affidavit of Wj Hindman Re Info on Age Distribution & Gender of Daniel Intl Corp Employees & First Line QA Inspectors at Facility.Certificate of Svc Encl ML20135H8321985-09-23023 September 1985 Affidavit of SL Burch Re Undercover Drug Operation at Facility.Related Correspondence ML20135H8371985-09-19019 September 1985 Second Affidavit of SL Burch Re Drug Investigation at Facility.Related Correspondence ML20137L6741985-09-0606 September 1985 Affidavit of P Miriello Re Drug Abuse Observed at Facility Const Site.Certificate of Svc Encl ML20134H4261985-08-23023 August 1985 Affidavit of Wp Haass Re ASLB Questions Concerning Whether Public Disclosure of Info Voluntarily Submitted to NRC Would Impair NRC Future Ability to Obtain Similar Info.Notice of Appearance of Ga Berry & Certificate of Svc Encl ML20135C0421985-08-23023 August 1985 Affidavit of Wp Haass Addressing Series of Questions Propounded by ASLB Re Whether Public Disclosure of Info Contained in Certain Applicant Documents in ASLB Possession Would Impair Staff Ability to Obtain Info ML20134E7891985-08-14014 August 1985 Affidavit of Wj Hindman Responding to SL Burch 850731 Affidavit Re Undercover Drug Investigation During Fall 1984 ML20134E7761985-08-14014 August 1985 Affidavit of MW King Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7661985-08-14014 August 1985 Affidavit of DG Joyner Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7831985-08-0909 August 1985 Affidavit of ML Plueddemann Re Fall 1984 Undercover Drug Investigation at Site ML20133A1111985-07-31031 July 1985 Affidavit of SL Burch Re Assertions in King Affidavit & Undercover Operation of Facility Concerning Drug Abuse. Intelligence Indicated Drug Dealings & Abuse Widespread. Certificate of Svc Encl ML20129H1061985-07-11011 July 1985 Affidavit of Nj Chiangi Re Allegation in Conservation Council of North Carolina Contention WB-3.QA Program Provides Necessary Steps to Ensure Safe & Reliable Power Plant.Certificate of Svc Encl ML20129H0941985-07-10010 July 1985 Affidavit of Wj Hindman Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const ML20129H0821985-07-10010 July 1985 Affidavit of Pb Bensinger Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const.Biography Encl ML20129H0991985-07-0909 July 1985 Affidavit of AR Pannill & Gw Flowers Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Employees Subjected to Preemployment Background Verification ML20129H0911985-07-0909 July 1985 Affidavit of Jd Ferguson Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Cp&L Adopted Drug & Alcohol Interdepartmental Procedure.Resume & Procedure Encl ML20129H0871985-07-0909 July 1985 Affidavit of MW King Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Use Widespread & That Mgt Failed to Control Drug Use During Const.Resume Encl ML20128M0401985-07-0808 July 1985 Affidavit of TS Elleman Supporting Util 850709 Application for Withholding Final Rept Shnp QA/QC-Const Inspector Review Panel, Per 10CFR2.790.Certificate of Svc Encl. Related Correspondence ML20128M0331985-07-0808 July 1985 Affidavit of HR Banks Supporting Util 850709 Application for Withholding Documents,Including Quality Check Rept,Concern/ Allegation Followup & Quality Check Procedure Investigation Rept,Per 10CFR2.790.Related Correspondence ML20116N7771985-05-0202 May 1985 Affidavit of Ti Hawkins in Support of Applicant Suppl to Motion for Summary Disposition of Eddleman Contention 213 Re Emergency Planning.Certificate of Svc Encl ML20116D0091985-04-25025 April 1985 Affidavit of Jf Myers Describing Recent Change to Provisions for Official Transportation Assistance for Persons in Emergency Planning Zone Needing Assistance in Event of Plant Emergency.Related Correspondence ML20112K0061985-04-0505 April 1985 Supplemental Affidavit of RG Black on Eddleman Contention 213.Provisions for Alert & Notification of Persons on Harris Lake Obviate Measures Suggested by Contention ML20112K0131985-04-0505 April 1985 Supplemental Affidavit of MR Bassiouni on Eddleman Contention 213.Rept of Proposed Siren Configuration & One Oversize Map Encl.Aperture Card Available in PDR ML20100B1011985-03-22022 March 1985 Supplemental Affidavit of Eh Harris Re Rev of School Evaluation Procedure Which Would Reduce Number of Students Riding Buses & Use of Buses Kept on Property During School Hours.Certificate of Svc Encl.Related Correspondence ML20107M5111985-02-27027 February 1985 Affidavit of Ti Hawkins in Support of Motion for Summary Disposition of Eddleman Contention 30.Emergency Response Plan Provisions Fully Comply w/NUREG-0654 ML20107K0411985-02-26026 February 1985 Affidavit of Ti Hawkins in Support of Applicant Motion for Summary Disposition of Contention EPJ-4(c).Prof Qualifications Encl.Certificate of Svc Encl 1999-04-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] |
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UNITED STATES OF AMERICA 0 JAN 76 A9 :59 NUCLEAR REGULATORY COMMISSION GTF;ct .w e BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ' JC U.Tjgj!( 3h.l['!
00 NCH ,
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 ALVIN H. JOYNER ON CONTENTION EPX-2 COUNTY OF WAKE )
) ss:
STATE OF NORTH CAROLINA )
Alvin H. Joyner being duly sworn, deposes and says:
'1. I am the Lead Planner for Fixed Nuclear Facilities for the North Carolina Department of Crime Control and Public Safety, Division of Emergency Management (DEM). The basic responsibilities of DEM include fulfilling the State's role in emergency planning for natural and manmade disasters, in responding to and recovering from disasters, and in mitigation of their effects. As a primary planner for fixed nuclear facilities, I have been directly involved in the development of the offsite emergency capability for the Shearon Harris Nuclear Power Plant, as well as the Catawba, McGuire, and Brunswick nuclear plants. Since April 1985, I have had overall responsibility for emergency planning activities concerning the Harris plant. Prior to April, I was the coordinator for the September revision and Change 2 to the North Carolina Emergency O PM .
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a Response Plan (ERP) in Support of the Shearon Harris Nuclear Power Plant, and had extensive contactYlt the surrounding counties in developing their portions of the plan.
I was also responsibl5 for overall coordination with the affected counties and the utility in the development of the May 1985 exercise for Shearon Harris. A complete statement of my professional qualifications is ' appended to this affidavit. My current business address.is 116 W. Jones St., Raleigh, N.C. 27601. I make this affidavit in response to Contention EPX-2. I have personal knowledge of the matters stated herein and believc them to be true and correct.
- 2. A full-scale exercise of the off-site emergency response capabilities for a potential accident was held on May 17 and 18,1985. This was the first full scale exercise held for the Harris Plant, and it was intended to evaluate the state, county, and local agencies' response capabilities within the plume exposure Emergency Planning Zone (EPZ) ,
- 3. Contention EPX-2 directs itself to several issues invc,1ving ec.nmunications difficulties, which were pointed out by exercise evaluators representing state agencies.
In this affidavit, I will address three issues which are of special concern to D'EM because they involve several different public safety agencies, procedures within the state Emergency Operations Center (EOC), or involve DEM directly in their resolution. The first is the concern of the state evaluator regarding the " overcrowding" of the radio frequency 155.280 mHz. The second addresses the delay in the receipt of messages by the representatives of the North Carolina Office of Emergency Medical Services within the state EOC. Finally, a third issue involved inadequacies found in the telephone communications capabilities of the Harnett County EOC.
- 4. Within the State of North Carolina, many public safety agencies conduct their normal and emergency radio communications on many different frequencies. During the
. exercise on May 17 and 18, many of these frequencies were being used not only for their normal, day-to-day purposes, but also for radio traffic directly related to the exercise.
One is the "Special Emergency" frequency of 155.280 mHz VHF, which is used in North Carolina by rescue squads. This frequency is referred to in Contention EPX-2 as the
" emergency inter-system mutual aid frequency." This frequency is widely available in the radios used in most communities and is also available to some state agencies.
. 5. ' During the period of the exercise, as is the case on other days, the frequency was utilized by many parties for dispatching and routine communications. It is recognized in North Carolina that 155.280 mHz is a widely and heavily-utilized frequency. However, with the benefit of radios equipped with tone encoding, and the characteristics inherent with VHF transmissions, particular agency users are able to successfully conduct their own communications operations. VHF transmissions are limited to "line-of-sight", so the more elevation that is gained over the surrounding area, the greater the range for transmission and reception. Tone-encoded radio equipment prevents interference from unwanted signals by blocking those from radios other than those used by a particular response agency. I am aware that the state evaluators for communications on the exercise were monitoring this frequency from a helicopter and
- also using it for their own, evaluator-to-evaluator communications. It is my understanding that this frequency was selected by the evaluators for their own use because the vehicles they used for the exercise had radios equipped with this frequency, although I am not aware of any provision of the exercise scenario which designated this frequency for this purpose. The state evaluators evidently found that the frequency was congested and that they could not contact a county EOC on 155.280 mHz.
- 6. As I noted, I am aware that the evaluators were monitoring 155.280 mHz
- from a helicopter in flight over the EPZ, and I also understand that they were not using Lm
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' tone-encoded radios. For this reason, the evaluators flying above the EPZ received not ,
I only the local transmissions directly below them, but most likely stations many miles beyond the local area around Harris. These distant transmissions would not have been received on the ground and therefore would not have interfered with emergency communications. The evaluators in the helicopter also were not monitsing any specific
- units or communications on this frequency (155.280 mHz), but were mo- .oring every unit being received due to t'he fact that the receiver wr.s not tone encod d. Emergency 9
. personnel were using tone enecded equipment that prevented interference from
. extraneous signals. b
- 7. I recognize from the evaluator comments that 155.280 mHz is a highly utilized frequency and it would have limitations, as any single frequency would, as a coordinating channel for a response of the magnitude represented by this exercise. In the four counties comprising the EPZ, all of their public safety organizations operate on 7
multiple frequencies which are dedicated to specific services (fire, police). Some of these counties have multiple frequencies for just one type of service. None of these counties rely on 155.280 mHz as their sole primary frequency to respond to any emergency situation. If under extenuating circumstances, this frequency or the other frequeneles being utilized were needed on a priority basis, it could be done. This would be accomplished by having a powerful base station from either the state or one of the counties, come on frequency and order the radio traffic to move off frequency. For those individual agencies with tone-encoded radio systems, their dispatch center would be informed of this need. I;am confident that 155.280 mHz and the many other frequencies available to the responding agencies would be able to handle all of the traffic during an emergency at the Harris Plant.
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- 8. In addressing the second problem noted in Paragraph 3 above, I have reviewed the comments by the evaluator for the Office of Emergency Medical Services (OEMS) regarding the delay in the receipt of messages within the state EOC, and have been infermed by the evaluator that this comment was primarily the result of a delay in a single, key message. In particular, the OEMS representatives were not made aware of a briefing in the EOC that was to be held, and it was at this briefing that the announcement of a release from the plant was simulated. Under conditions of a real accident, this would be important information for OEMS. I concur with the evaluator's comments that the OEMS personnelin the EOC probably missed the announcement of the briefing because of shortcomings with the method used to deliver messages within the rooms that are used as the state EOC.
- 9. A large central room at the state EOC is designed to accommodate key representatives of each agency making up the State Emergency Response Team (SERT).
The response of SERT is directed and coordinated from this room, and, accordingly, SERT briefings are held in it. A ring of offices surrounds and is immediately adjacent to the central room; these offices are used for other representatives of each state agency.
A public address system has speakers in the hallway, which is used to make general announcements, such as the scheduling of a briefing. In addition, individuals are on the EOC staff to function as " message runners"; they carry special or important messages to representatives on the SERT, whether in the central room or in an adjacent office. It is very likely that OEMS staff, who were located in an office, were unaware of the briefing because they did not hear the public address system used in the state EOC, or because of a failure on the part of the message runners to properly notify them.
I
- 10. I am confident that increaced emphasis on briefing message runners as to their responsibilities will improve their effectiveness and assure that their messages have n
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the direct attention of the recipients. New procedures will require that the EOC runners receive a direct acknowldgement, such as a signature or initials, from,the recipients, thus eliminating the possibility of missed messages. Acknowledgments will be reviewed by the message control office for completeness of notification and receipt of message traffic. DEM plans to develop and implement these procedures immediately. These new procedures will provide additional assurance that representatives of state agencies will receive all important. messages.
- 11. I am aware'of the communication difficulties that arose due to the temporary nature of the facilities Harnett County used for an EOC on the two days of the exercise. The location of the temporary EOC was selected because it was adjacent to the Harnett County Sheriff's Office communications center. This location only had three telephone lines coming into it with only a few additional telephones in adjacent offices. I am in complete agreement with county officials and the evaluators of the Federal Emergency Management Agency that this was an inadequate facility with an insufficient number of telephones to properly support EOC operations.
- 12. Harnett County is now developing a permanent EOC, with the cooperation and consultation of DEM. The permanent EOC will be located in the County Administration Building, in a room suitable to the efficient operation of an EOC. DEM is currently studying the needs of the new EOC and will advise the county on the number of telephones and other resources which will be needed. This study will determine the communication needs required to correct the type of problems which arose during the exercise. After full evaluation of Harnett County's needs, DEM .will request Carolina Power & Light Company to financially support the necessary communications requirement and additional telephone lines will be added. Current thinking envisions at least 11 telephone lines in the permanent EOC. Completion of the permanent EOC will
, be prior to full power licensing of the Harris Plant.
- 13. I believe that DEM clearly understands the basis of the actual communication problems that arose during the exercise and that are addressed by Contention EPX-2. I
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also believe that the corrective actions be!ag taken by the state and county agencies, and
- the cooperation being extended by Carolina Power & Light Company, will effectively resolve these problems prior to full power licensing of the Harris Plant.
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ALVIN H. JOYKER '
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'*esu nipio*' Notary Public My commission expires: Or4% Z /7I
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STATDTE OF PROFESSIONAL QUALIFICATICNS ALVIN H. JOYNER DIVISION OF EERGEiCY PANAGD5r
" NC DEPARD.ENI 0F CP,1.'E CCMOL & PUBLIC SAEEIY PPGESSICML EXPERIDX2 E=ergency Manaaement Planner I.
Pu=ite Safety. Octccer 1953 - Fresent. North Carolina Decartment of Crime Centrol and
- Principle planner for emergency rescense to nuclear accidents within the State of North Carolina. Specific responsibilities involve developing State policy and plans ccacerning emergency respense to nuclear power plant cmergencies, previding guidance tp state and local government officials and other public anad private agencies in the preparation of emergency response plans to ensure accuracy and ec=patibility with State and Federal plans, provide censultatica and guidance to nuclear utility management to ensure full availability of resources and cchesiveness of emergency response plans. Support the State E=ergency Response Team -(SERT) when a disaster er threat of a disaster is present.
Plans. 0:eraticns. and Militari Sun:cr: Cfficer. '&,e Adiutant General's Office.
Sta:e cf Goren Carciina. Jr.uary 1953 - Occc:er 1953. ..
Princi Guard.ple staff officer for emergency planning within the North Carolina Natienal Specific responsibilities involved developing, evaluating, and putting into oceratica a variety of centingency plans for such emergencies as natural disasters.
civil disturbances, land special security missions, nuclear attack, or alert and mobilizatica of National Guard units for ' State or Federal emergencies. Functioned as physical, of the State Director of Security, responsible for the direction and i=ple=entation co==unications, informacien and automatic data processing security p:cgrams. ,
Administrative Officer. North Carolina National Guard. Septe=her 1978 , January T983.
Fullti=a executive assistr.t to the Cc=mander of a General Officer Ccm=and o
- Artillery population Brigade, of 3,677.oneCecrdinated Support Group of four separate battalions with a troop the day-to-da matters, logistics, maintenance, military law,y military administratien, and technician fiscal and budget personnel, pay, public and community relations, recruiting managerial functicas. Supervised 130 epployees,including plans andsupervisors programs, training in civiland service (GS) grades 4 through 11 engaged in personnel, training, supply maintenance, and administracien. Coordinated the preoaraticn of dc=estic emergency, and military support for centingency and operational' plans for the cc= mand.
Administrative Septemcer 1978.
Officer, North Carolina Ar=v National Cuard. December 1972 -
Fulltime executive assistant to the Cc==ander of a North Carolina Army National Guard separate a representing Support troopGrouppopulation of four attached of 2,685. battaliens and one separate company Coordinated the day-to-day ad=f nistraticn, fiscal, and budget matters, legistics, maintenance, military law.
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l L*> . l military and technician perso=al, pay, public and cc===ity relati=s, recrui:ing ;
plans and programs, training, and managerial functions. Coordinated the ,
preparation of domestic emergency and military support for contingency and operational plans for the command.
Ad=inistrative Officer. North Carolina Ar=v Nati nal Guard. March 1961 -
Dece=oer 1972. -
Fulltime executive assistant to the Cc==ander of a Divisienal Medical Battalien.
Coordinated the day-to-day administracion, training, supply, and maintenance activities within the com=and. Recruiting plans and programs for the professicnal co= ole =ent. Exercised supervisica over one (1) operati ns and trainirs specialist GS-09, one (1) staff supply assistant GS-07, ene (1) ad=inistrative specialist GS-07, four (4) administrative and supply technicians GS-07, one (1) organizational maintenance shop chief W-12 and three (3) general mechanics.
Power Plant 0:erator. E.I. DuPont De Nemours Cc=canv. January 1953 - March 1961.
Power Plant auxiliary cperator within an industrial plant utilizing fossil fuel.
Specific responsibilities included operation of turbine condensers for planc electric generators, primary refrigeratien =achines for the e . tire plant, operaticn of power plant production of co=oressed air and analysis and creat=ent of all cendi:icned water for both hunan ab.d industrial purpcscs. -
'IRAINEC E CCtC L . CCURSE SCECCL 1961 Medical Service Corps Officer Medical Field Service School Orientatica 1967 A =y Medical Depart =ent Officer Medical Field Service School Advance 1971 Ccccand & General Staff Officer Cc=z:and & General Staff (Hcnor Grad) College 1973 Introductica to Supervision US Civil Service Cceraisaien 1974 Engineer Officer Orienta:icn Erzineer School 1974 National Guard Perscnnel US Civil Service Cc::r:ission Management 1976 legistics Management Orientation US A=y kgistics Management Center 1977 Ordance Officer Advance US Ar=y Ordcnce School 1978 National Security Managecent Naticnal Defense University 1978 Role of the Manager in EID US Civil Se:vice Cceraission 1978 Manage =ent Awareness Officer NC State Persennel 1979 Installation Manage =en: US Ar=y kgistics Management Cmter 1979 Middle Management US Office of Persennel Manage =ent 1980 Netotiating Labor Agreements US Office of Perso=el Msnagement g 1980 Administrative Officer NG Profession Education Cen.
1982 Labor Relacions Supervision US Office of Personnel
{L for Managers -
Management 2
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1982 Industrial Facilitics Protection US Defense Indust. Security Inst.
1982 Basic Disaster Operations Course Emergency Management Inst.
(FD'A) 1982 Assoc. Legistics Executive US Ar=y Legistics Mr,asecent Develeg:ent Center 1983 Classification Management for Naticnal Guard _cureau Managers 1983 Search and Rescue Management US Air Force Rescue Seminar Coordinatien Center 1984 Managing the Search n:.ctica Naticnal Assoc. for Search
& Instructor Workshop and Rescue 1984 Basic Nuclear Power Concept Tennessee Valley Authority Course 1985 Federal Radiological F.cergency Dmrgency M.tnage ent Respense Plan Workshop Institute (TiFA)
SlWARY My professional career has been al= cat entirely in the military. I retired frett fSilti=e duty with the North Carclina National Guard as a Lieutenant Colcnel (GS-
- 12) in October 1983. During that career my responsibilities have been almost entirely devoted to planning ansd training to support the National Guard in its military role both to the Nation and the State. I am an honor graduate of the Ar:y's coveted Cc==and and Staff College and ce=pleted nu=ercus other military courses directly related to plans and cperaticas.
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