ML20102C357

Affidavit of Ti Hawkins in Support of Applicant Motion for Summary Disposition of Conservation Council of North Carolina Contention 2 Re Sheltering as Protective Action. Certificate of Svc Encl

ML20102C357
Person / Time
Site:	Harris
Issue date:	02/22/1985
From:	Hawkins T Federal Emergency Management Agency
To:
Shared Package
ML20102C354	List: ML20102C355 ML20102C357
References
OL, NUDOCS 8503050552
Download: ML20102C357 (6)

Text

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DOCS,ETEC UNITED STATES OF AMERICA UB'O NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY ' AND LICENSING BOARg $R -5 M1 :15 trt:EOfSECPifM'.'

C ,n .ip.} QE - J v In the Matter of ) ~~

)

CAROLINA POWER & LIGHT COMPANY ) ..

and NORTH CAROLINA EASTERN ) Docket No. 50-400 LL MUNICIPAL POWER AGENCY ) ,, . . .

) .

l (Shearon Harris Nuclear Power )

Plant) )

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

SUMMARY

DISPOSITION OF CONTENTION CCNC-2 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 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 I

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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 j believe them to be true and correct. I make this affidavit in response to Contention CCNC-2.

2. Contention CCNC-2 contends:

Sheltering as the recommended response to the release of radiation is not adequate to protect the public health. The typical rural house found around the plant site is not well-insulated 1 and air in it is exchanged several times each I hour.

NUREG-0654, Criterion J.10.m. , states that "The organization's plans to implement protective measures for the plume exposure pathway shall include: The bases for the choice of recommended protective actions from the plume exposure pathway during emergency conditions.

This shall include local protection afforded in residential units or other shelter for direct and inhalation exposure, as well as evacuation time estimates.." (Footnote excluded.) FEMA staff and the RAC are of the opinion that the ERP meets this requirement on page 49, Part 1; pages 29-30, Part 2; page 26, Part 3; page 28, Part 4; and page 31, Part 5.  !

FEMA guidelines do not suggest in any way that in place sheltering be excluded from consideration as a protective measure because of  !

" inadequate" housing or because of housing which is not well-insulated.

Further, sheltering is not "the recommended response to the release of radiation?' as indicated in Contention CCNC-2. Neither the ERP nor the FEMA guidelines imply that sheltering is the " recommended response." They do indicate that sheltering is one available option under certain conditions.

f

-According to the Applicants' Affidavit in response to CCNC-2 and Eddleman 57-C-10, applicants have performed a survey of housing in the EPZ and determined the protection factors for that housing using the information contained in EPA 520, a standard reference referred to in NUREG-0654, for the determination of protective factors.

FEMA knows of no reason why the above information would not be appropriate for the Plant liarris EPZ.

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Thomas I. !!awkins Sworn to and subscribed before me this A_ Q day of February, 1985.

Mm. ROL2 - .

NOTA Y PdiBI,1C FOR SThYE'OF GEORGIA N.

My Commission Expires e,'Itary Pubbc.Geerra commm.on Do.res NovState at Larre 12.1985

(

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 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 employ'ed 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

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OcuETE:

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

, w. 0: SEC.: 2 In the Matter of If($['[L CAROLINA POWER AND LIGHT C0f1PANY AND NORTH CAROLINA EASTERN MUNICIPAL Docket Nos.750-400 OL P0HER AGENCY ) 50-401 OL

) . _ . . . , _ . . .

(Shearon Harris Nuclear Power Plant, )

Units 1 and 2) )

I hereby certify that copies of "f:RC STAFF /FEffA RESPONSE TO APPLICANTS' 110TIONS FOR SUf!MAPY DISPOSITION OF CCNC CONTENTION 2 AND EDDLEMAN CONTErl-TION 57-C-10" 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 Comission's internal mail system (*), this 27th day of February,1985:

James L. Kelley, Chairman

• Richard 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

• Travfr. 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. Janes H. Carpenter

• Dr. Linda Little Administrative Judge Governor's Waste Management Building Atomic Safety and Licensing Board 513 Albermarle Buf1 ding U.S. Nuclear Regulatory Commission 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. Rox 2151 307 Granville Pd.

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

Regional Counsel Associate General Counsel FEffA Office of General Counsel i 1371 Peachtree Street, P.E. FEftA c Atlanta, GA 30309 500 C Street, SW Rm 840 Pashington, DC 20472 l

I

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Atomic Safety and Licensing Appeal Bradley W. Jones, Esq.

Board Pane 1* Regional Counsel, USP'PC, 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 Fle11s Eddleman Atomic Safety and Licensing Board 718-A Iredell Street Panel

• Durhan, NC 27701 U.S. Nuclear Regulatory Comission Washington, DC 20555 Richard E. Jones, Esq. Dr. Harry Foremar, Alternate Associate General Counsel Adninistrative Judge Carolina Power & Light Company P.O. Box 395 Mayo P.O. Box 1551 University of f!innesota Raleigh, NC 27602 flinneapolis, MN 55455 5 $$Mk Janice E. f1oore Counsel for l'RC Staff l

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