ML20112K042

Affidavit of Jt Pugh Re Contention EPJ-4(c).Sufficient Transportation Resources Available to Evacuate Schools in Single Trip in Event of Emergency at Facility

ML20112K042
Person / Time
Site:	Harris
Issue date:	01/14/1985
From:	Pugh J CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, NORTH CAROLINA, STATE OF
To:
Shared Package
ML20112J843	List: ML20112J839 ML20112J852 ML20112J864 ML20112J867 ML20112J876 ML20112J883 ML20112J890 ML20112J898 ML20112J904 ML20112J913 ML20112J928 ML20112J936 ML20112J952 ML20112J959 ML20112J966 ML20112J976 ML20112J980 ML20112J999 ML20112K015 ML20112K038 ML20112K042 ML20112K046 ML20112K054 ML20112K067 ML20112K077 ML20112K080 ML20112K082 ML20112K094 ML20112K100 ML20112K105 ML20112K116 ML20112K118
References
OL, NUDOCS 8501180455
Download: ML20112K042 (8)

Text

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January 14 g l}8{

t.R; UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '85 e'W 17 P1 :58 BEFORE THE ATOMIC SAFETY AND LICENSING B 5RD",' 'E W :;-

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io 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 JESSE T. PUGH, III ON EPJ-4(c)

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 l

accidents at any of the four nuclear plants that affect North j Carolina. In that professional capacity, I have been involved l

l 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 i

Management, I have directed the State's response to more than i 650 cases in the last year alone, including the tornadoes in

[ March and Hurricane Diana in September. A current statement of l e i

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PDR ADOCK 05000400 0 PDR

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my professional qualifications and experience is attached hereto. My business address is 116 West Jones Street, Raleigh, North Carolina 27611. I have personal knowledge of the matters stated herein and believe them to be true and correct. I make this affidavit in response to EPJ Contention 4(c).

2. The purpose of this affidavit is to explain the State's high degree of confidence (based on contacts with authorities at all schools within the EPZ, and with appropriate Chatham and Wake County school officials) that -- in an emergency -- evacuation of the schools within the EPZ would be accomplished in a single trip to the school evacuation shelters.

3. In the Waka County public school system, the Apex Attendance Area has a total of 48 buses available.1/ Of these, only thirty would be used for school evacuation in the event of an emergency at the Harris plant. The enrolled student population (490 students) at Apex Elementary School would be evacuated using sevea buses (with a combined capacity of 504 students.) The 537 students enrolled at A.V. Baucom Elementary School would be evacuated using eight buses (with a combined capacity of 576 students). At Apex Middle School, eleven buses (with a combined capacity of 682 students) would evacuate the 1/ These large buses can each accommodate 72 elementary school students (in addition to two teachers), with no standees, or 62 middle or high school students (in addi-tion to two teachers), with no standees.

O l '- enrolled student population of 679 students. And, at Apex High r .

School', four buses (with a combined capacity of 248 students) would be used to evacuate the approximately 190 students who do not provide their own transportation.2/

k., The Fuquay-Varina Attendance Area has a total of 8 small buses and 30 large buses available.3/ Of these, all the small buses and 29 of the large buses would be used for school evacuation in the event of an , emergency at the Harris plant.

The enrollpd, student population (387 students) at Fuquay-Varina Elementary; School would be evacuated using six large buses (with a combined capacity of 432 students). The 510 students i

enrolled at Lincoln Heights ElemSntary School would be evacuated using one small bus and seven large buses (with a combined capacity of 534 students). At Fuquay-Varina Middle School,-7even small buses and seven large, buses (with a

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combined)capacityof644 students)wouldevacuatetheenrolled student population of 624 students. And, at Fuquay-Varina High School, nine large buses (with a combined capacity of 558 1 ,

2/ According to school officials, at Apex,High School approx-imately 85% of the engolled student body of 1219 students either drive their own cars to school or ride with other

students who drive their own cars. Pursuant to school policy, in the event of an evacuation, these students would be released -- with the prior wri$ ten permission of

their parents -- to take advantage of their available means of private transportation. All other students would be evacuated in school buses.

3/ The small buses can each accommodate 30 students (in addi-

, tion to two teachers), with no standees. The capacity of

,the large buses is stated in note 1, above.

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students) would be used to evacuate the approximately 500 students who do not provide their own transportation.4/

5. At Wake Chapel School, a K-8 private school in Fuquay-Varina, one small bus (with a capacity of 20 students plus one teach'er), two larger school buses (with a combined capacity of 85 students, plus 1 teacher per bus), and the personal vehicles of seven school staff personnel (each carrying 1 adult staff person plus 3 students) are available to evacuate the enrolled student population of 125 students, in the event of an emergency at Harris.

6. At Moncure Elementary School, in Chatham County, five buses (with a combined capacity of 330 students, plus 2 teachers.per bus, with no standees) are available to evacuate the enrolled student population of 280 students, in the event of an emergency at Harris.

7. The figures stated above reflect several conservatisms which may in fact reduce the number of buses actually needed for school evacuation. First, school officials indicate that daily student absenteeism averages 5% to 10% of enrollment (depending upon, e.g., the season). Second, the 4/ According to school officials, at Fuquay-Varina High School, approximately one-third of the enrollment of 752 students either drive their own cars to school or ride with other students who drive their own cars. Pursuant to school policy, in the event of an evacuation, these stu-dents would be released -- with the prior written permis-sion of their parents -- to take advantage of their avail-able means of private transportation. All other students would be evacuated in school buses.

R inclusion of standees in the calculation of bus capacity would increase the capacity of each large bus by approximately 10 students.

8. Ample bus capacity exists to accommodate contingencies such as, e.g., a day when fewer students than usual drive to school.5/ As discussed above, the schools in the. Apex Attendance Area have a reserve of 18 buses (with a combined capacity of 1116 students); and the Fuquay-Varina Attendance Area has an additional large bus, with a capacity of 62 students. Further, if standees are taken into account, the combined capacity of the Apex Attendance Area buses increases by approximately 220 students, and that of th'e Fuquay-Varina buses, by approximately 100 students.

9. In summary, based on contacts with appropriate school authorities, I am confident that sufficient transportation 5/ To accommodate such contingencies, it would likely be nec-essary to shift buses among the schools within the Apex Attendance Area and within the Fuquay-Varina Attendance Area, although it would not be necessary to shift buses between the two areas. ~Such shifts would involve only a few minutes of delay, as the schools in each area are quite close together. In the Apex Attendance Area, none of the schools are more than 3 miles apart, and in the Fuquay-Varina area, they are less than 2 1/2 miles apart.

a resources are available to evacuate the schools in the EPZ in a single trip, in the event of an emergency at Harris.

Therefore, EPJ Contention 4(c) has no basis in fact.

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\ l JESSE THOMAS PUGH, III '

Professional Qualifications EDUCATIORI Graduated Asheboro High School, Asheboro, North Carolina, 1965 North Carolina 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 employees, administer budget of approximately S2 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. Responstole for the State of North Carolina emergency response anc planning. This includes the coordination of alt emergency response activities of the 17 State agencies. Serve as

, State Coordinating Officer and Gove rno r's Authorized l Representative in all disaster related matters. In emergencies l serve as leacer of the State Emergency Response Team.

MILITARY I

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

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TRAINING Radiological Monitoring Instructor Course, August 1978 Basic Seminar for 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

.