ML20113E375

Affidavit of Ti Hawkins Supporting Applicant Motion for Summary Disposition of Eddleman Contention 57-C-13.Prof Qualifications & Certificate of Svc Encl

ML20113E375
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 8501230438
Download: ML20113E375 (6)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1: BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In'.the' Matter of )-

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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 THOMAS I. HAWKINS IN. SUPPORT OF  ;

APPLICANTS MOTION FOR

SUMMARY

DISPOSITION OF EDDLEMAN CONTENTION-57-C-13 County of Fulton. )

) ss.

' State'of. Georgia )

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 i

liaison-function between~ FEMA Region IV and the States of-North and South' Carolina.; -In this position, I amLresponsible-for the reviewLofEradiological plans and preparedness-for the-StateLof

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.-North Carolina and-the State-of' South Carolina and-for the~1ocal-governments-within those States.

I have held this: position.since December 1981. .I have:been-employed byDFEMA since-July _1978. A current statement of my-

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'P professional qualificiations is attached hereto. My business address is 1371 Peachtree Street, NE, Suite 736, Atlanta, Georgia, 30309. I have personal knouledge of the matters discussed herein and believe them to be true and correct. I make this affidavit in response to Eddleman Contention 57-C-13.

2. Eddleman 57-C-13 contends:

The plan, in discussing protective actions, repeatedly refers to "the best Protection Factor (PF) for sheltering." Yet it nowhere sets up criteria for identifying such protection factors or the

, highest PF_in hospitals and nursing homes. The highest PF areas need to be determined in advance (before the emergency prepared-ness exercise) to comply with 10 CFR 50.47 (a) (1) 's requirement for assurance of appropriate protective action. If seeking the highest PF is appropriate action (as the plan states, pt .- 2, pp. 29-30, pt. 3, p. 26, pt. 4, pp. 28-29, pt. 5, p. 31), then that action must be assured.

3. FEMA staff response asserts that:

FEMA guidelines do not require that PF's r& hospitals and nursing homes be determined. However, we understand, from reading.the

" Affidavit of Jesse'T. Pugh, III in Support of Applicants' Motion

- for Summary Disposition of Eddleman Contention 57-C-13," that a survey of-hospitals and nursing homes, similar to that referred to in Contention 57-C-13, has been conducted, and as a result, the areas of these facilities which would provide the greatest' protection from a radiation release-are nou known.

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Thomas I. Ifhwkins Sworn to.and subscribed before me this' N day of January, 1985 u.h a NOTARf PUBLfC FOR STATE OF GEORGIA Notary Public. Georgia. State at Large

. My Commission Expires : sy commission Empires Nov. 12,1985 1

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e 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 Ur.S.

Department of Energy's Nevada Test Site, April 1982 1

- 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 Emergendy Training Center, Emmitsburg, Maryland, October 1982

-- Completed Radiological Accident Assessment Course, National Emergency Training Center, Emmitsburg,. Maryland, August 1984 4

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

)

CAPOLINA POWER AND LIGHT COMPANY AND )

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

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(Shearon Harris Nuclear Power Plant, Units 1 and 2)

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

SUMMARY

DISPOSITION OF EDDLEMAN CONTENTION 57-C-13" 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

• Richard D. Wilson, M.D.

Administrative Judge 729 Hunter Street Atomic Safety and Licensing Brard 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 Building Atomic Safety and Licensing Board 513 Albermarle Building U.S. -Nuclear Regulatory Ccmmission 325 North Salisbury Street 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.

Raleigh, NC 27607 Chapel Hill, NC 27514 i

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'O 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 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 liniversity of Minnesota Raleigh, NC 27602 Minneapolis, MN 55455 u (UtED AN Janice E. Moore Counsel for NRC Staff i

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