ML20107K041

Affidavit of Ti Hawkins in Support of Applicant Motion for Summary Disposition of Contention EPJ-4(c).Prof Qualifications Encl.Certificate of Svc Encl

ML20107K041
Person / Time
Site:	Harris
Issue date:	02/26/1985
From:	Hawkins T CAROLINA POWER & LIGHT CO., Federal Emergency Management Agency
To:
Shared Package
ML20107K026	List: ML20107K041
References
OL, NUDOCS 8502280125
Download: ML20107K041 (5)

Text

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l 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 Harris Nuclear Power )

Plant) )

AFFIDAVIT OF THOMAS I. HAWKINS IN SUPPORT OF APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF CONTENTION EPJ-4 (c)

County of Fulton )

) ss.

State of' Georgia )

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

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 8502290125 850226 PDR ADOCK 05000400 C PDR =

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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 Contention EPJ-4(c).

2. Contention EPJ-4 (c) contends:

Section E4d of State Procedures (p. 47) is deficient because --

In normal operation, each bus makes two runs each day. Thus, two round trips to the shelter sites would be required. (This factor was not considered in traffic control plans or evac-uation time estimates.) Students who do not normally ride buses will be an extra burden, requiring even more round trips.

NUREG-0654, criterion J.10.g., requires that:

The organization's plans to implement protec-tive measures for the plume exposure pathway shall include:

g. means of relocation;

- The State Plan, Part I, E.4.a., E.4.b. (p. 46) does indeed include 3

"means of relocation" and, therefore, complies with NUREG-0654.

Also, according to the affidavit of Jesse T. Pugh, III on EPJ-4(c) the evacuation of the schools within the Plant Harris EPZ would be accomplished in a single bus trip to the school evacuation shelters.

FEMA staff has no reason to discount Mr. Pugh's statements regard-l ing this contention.

/ . W Thomas I. Hawkins Sworn to and subscribed before me this \tb day of February, 1985 h.

NOfARf'PUBLIC FOR STATE OF GEORGIA

. . Notary Public. Georgia. State at Large My Commission Expires: uo en,n, is. rn runires Nov 11 1985

1 Thomas I. Hawkins i

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 Stateseof 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 land for the local governments within these States.

I have. 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.

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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 i$ - 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 l

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.ju' 00CgETE9 UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION W FEB 27 N0:22 '

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.

8 In the Matter of ) '

)  :- -

CAROLINA POWER AND LIGHT COMPANY AND ) M.T ' *CwSi '

NORTH CAROLINA EASTERN MUNICIPAL ) Docket Nos. 50-400iOL ...

POWER AGENCY ) 50-40140L--- - '"

)

(Shearon Harris Nuclear Power Plant, )

Units 1 and 2) )

I hereby certify that copies of "NRC STAFF / FEMA RESPONSE IN SUPPORT OF APPLICANTS' . MOTION FOR

SUMMARY

DISPOSITION OF CONTENTION EPJ-4(c)"

in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or deposit in the Nuclear Regulatory Commission's internal mail system (*), this 26th day of February,1985:

i

~ James L. Kelley, Chaiman* Richard D. Wilson, M.D.

Administrative Judge 729 Hunter Street Atomic Safety and Licensing Board Apex, NC 27502 U.S. Nuclear Regulatory Commission 4 Washington, DC 20555 I

i 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 i Washington, DC 20555

( Dr. James H. Carpenter *- Dr. Linda Little

! Administrative Judge Governor's Waste Management Building l ' Atomic Safety and Licensing Board 513 Albemarle Building U.S. Nuclear Regulatory Commission 325 North Salisbury Street Washington, DC- 20555 Raleigh, NC 27611

Daniel F. Read John Runkle, Esq. Executive Coordinator l CHANGE. Conservation Counsel of North Carolina

P.O. Box 2151 307 Granville Rd.

Raleigh, NC 27602 Chapel Hill, NC 27514 Steven Rochlis Spence W. Perry, Esq.

i Regional Counsel Associate General Counsel

FEMA Office of General Counsel i

1371 Peachtree Street, N.E. ' FEMA Atlanta, GA 30309 500 C Street, SW Rm 840 i, ,

Washington, DC 20472 1

.. ~ _ ,. - - . _ _

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 - NCilC 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 Wells 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

& O L. - Q Q -tj l

Marjdrie Ulman Rothschild 4 Counsel for NRC Staff 4

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