ML20107M704

Affidavit of Ti Hawkins in Support of NRC Response to Applicant Motions for Summary Disposition of Wilson Contention 12(b)(3) & EPJ-2.Certificate of Svc Encl

ML20107M704
Person / Time
Site:	Harris
Issue date:	02/22/1985
From:	Hawkins T CAROLINA POWER & LIGHT CO., Federal Emergency Management Agency
To:
Shared Package
ML20107M700	List: ML20107M704
References
OL, NUDOCS 8503010397
Download: ML20107M704 (6)

Text

._ . __. _

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 WILSON CONTENTION 12 (b) (3) AND EPJ-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 may 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 4

0

. 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 Wilson Contention 12 (b) (3) and EPJ-2.

2. Wilson Contention 12 (b) (3) states:

The evacuation time study itself is deficient because: The 240 family (sic) without trans-portation is too low -- there are more without cars and many whose only car would be out of the EPZ at work. Many 1. ave cars that are not in working order.

Wilson Contention EPJ-2 states:

Section IV.E.4.e. of the State Plan (at 47) is deficient because it provides no estimate of the number of people without transportation (Applicants' estimate of 240 families in evac-uation time study (p. 3-2) seems far too low),

no suggestion as to how people without trans-portation would get to pickup points, and no criteria for determining when and where they would be " established as required."

In response to Wilson Contention 12 (b) (3) : FEMA staff and the RAC have no basis for questioning the validity of the ETE Study data or assumption made in that study.

In response to Wilson Contention EPJ-2: FEMA guidance does not require estimates of the number of households without transportation, details of how this population segment will get to pickup points, or criteria for determining when and where pickup points will be established, to be included in the plan document itself. This infor-mation concerning detailed plans for the transit-dependent population is better placed in Standard Operating Procedures.

. Further, FEMA staff understands, from a review of the " Applicants' Motion for Summary Disposition cf Wilson 12 (b) (3) and EPJ-2" that a more precise estimate of people without transportation has been developed, derived from more recent data since the preparation of the ETE. {EMA staff also understands from that affidavit that detailed plans for official transportation assistance are being developed, thus satisfying the implied requests of Wilson Contention 12 (b) ( 3) and EPJ-2.

\ I s

.W/-

Thomas I. Hawkins Sworn to and subscribed before me this 13_ B day of February, 1985.

&_ hihb ->

NOTARY' PUBLIC FOR' STATE OF GEORGIA Notary Pubhc, Georgia. State at Large My Commission Expires: My commiss.on Eeres 40s 1.' mn

0 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 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 Semir.ar, National Emergency Training Center, Emmitsburg, Maryland, October 1982

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

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

)

CAROLINA POWER AND LIGHT COMPANY AND )

NORTH CAROLINA EASTERN PUNICIPAL ) 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' MOTIONS FOR

SUMMARY

DISPOSITION OF EDDLEMAN CONTENTION 215(3)

WILSON CONTENTIONS 12(b)(2), AND 12(b)(3) AND EPJ CONTENTION 2" 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 Regu-latory 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

Deard 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 Comission 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 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

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 University of Minnesota Raleigh, NC 27602 Minneapolis, MN 55455 D N N 'l ] N [ / S 5 Janice E. Moore Counsel for NRC Staff

.