ML20107M511

Affidavit of Ti Hawkins in Support of Motion for Summary Disposition of Eddleman Contention 30.Emergency Response Plan Provisions Fully Comply w/NUREG-0654

ML20107M511
Person / Time
Site:	Harris
Issue date:	02/27/1985
From:	Hawkins T CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20107M505	List: ML20107M511
References
RTR-NUREG-0654, RTR-NUREG-654 OL, NUDOCS 8503010316
Download: ML20107M511 (6)

Text

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-9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CARCLINA POWER & LIGHT COMPANY )

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

)

(Shearon Harris z Nuclear Power )

' Plant) )

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

SUMMARY

DISPOSITION OF EDDLEMAN CONTENTION 30 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 Carclina 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 t

employed by FEMA since July 1978. A current statement of my l

l 8503010316 850227 PDR ADOCK 05000400 0 PDR

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 Eddlemin Contention 30.

2. Eddleman Contention 30 states:

The plan's provisions (Part 1 pp. 49-50) for Potassium Iodide do not comply with the re-quirements of NUREG-0654 II.J.10.e. (pg. 63) that the plans must include " quantities" for persons whose " evacuation may be infeasible or very difficult" who are in the plume EPZ.

NU REG-06 54 , criterion J.10.e., requires that the ERP shall include:

" Provisions for the use of radioprotective drucs, particularly for emergency workers and institutionalized persons within the plune exposure EPZ whose immediate evacuation may be infeasible or very difficult, including quantities, storage, and means of distribution."

(Emphasis added.)

NUREG-0654 does not require that specific quantities of KI be listed in the plan but that provisions for the use, quantities and distri-bution be included in the plan. This is done on pages 48, 49, Part 1 of the ERP where the plan states that DHS will establish a

" program to insure that a suf ficient number of potassium iodide units are conveniently and strategically located in the vicinity of the Shearon Harris Plant." Succeeding paragraphs of the plan discuss the distribution of KI.

DHS's program will include a running inventory of quantities of KI on-hand and on-order and where those quantities are located. Since the quantities fluctuate, it would be misleading and/or cumbersome (because of necessary updating) to include those figures in the North Carolina Emergency Response Plan document per se.

l

FEMA and the RAC have determined that the ERP provisions fully comply with NUREG-0654.

T C' f ,.

/ Ltd A i

__~ ~5'homas I . Hawkins Sworn to and subscribed before me this \ d , day of February, 1985

__ _ t _h_o _O * --

NOTARY P'BLIC FOR STATE OF GEORGIA Notary Public, Georgia. State at Large My Commission Expires: My Commission Expires Nov 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 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 U.S.

Department of Energy's Nevada Test Site, April 1982

- Completed Radiological Defense Of ficer 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

r:

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

)

CAROLINA POWER AND LIGHT COPPANY AND )

N0PTH CAROLINA EASTERN MUNICIPAL ) Docket Nos. 50-400 OL POWER AGENCY ) 50-401 OL

)

(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 EDDLEMAN CONTENTION 30" 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 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 y Washington, DC 20555 Mr. Glenn 0. Bright

• Travis Payne, Esq.

Administrative Judge 723 W. Johnson Street Atonic Safety end Licensing Board P.O. Box 12643 U.S. Nuclear Regulatory Commission Raleigh, NC 27605 Washington, DC 20555 Dr. James H. Carpenter

• Er. Linda Little Administrative Judge Governor's Waste Management Building Atomic Safety and Licensing Board 513 Albermarle Building U.S. Nuclear Regulatory Commission 325 North Salisbury Street Washington, DC 20555 Paleigh, NC 27611 Daniel F. Read John Punkle, Esq. Executive Coordinator CHAN3E 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.

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

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

Board Panel

• Regional Counsel, USNRC, Region II ti.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 Vells Eddleman Atomic Safety and Licensing Board 718-A Iredell Street Panel

• Durham, NC 27701 U.S. Nuclear Regulatory Comission 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

& (4 As*% M Y MarjoFie U. Rothschild Counsel for NRC Staff -