Affidavit of M Scott Re Contention EPX-2.Chatham County Responded Appropriately & Effectively to Experience Gained During 850517-18 Exercise.Addl Dispatchers Will Assure Response to Radio Traffic Levels.W/Certificate of SvcML20137F649 |
Person / Time |
---|
Site: |
Harris |
---|
Issue date: |
01/13/1986 |
---|
From: |
Michael Scott CHATHAM, NC |
---|
To: |
|
---|
Shared Package |
---|
ML20137F380 |
List: |
---|
References |
---|
OL, NUDOCS 8601170563 |
Download: ML20137F649 (7) |
|
|
---|
Category:AFFIDAVITS
MONTHYEARML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc ML18016A8191999-02-12012 February 1999 Affidavit of G Thompson Re Application by CP&L for Amend to FOL NPF-63 & NRC Review of Application & Proposes to Determine That Amend Request Involves No Significant Hazards Consideration ML20209A9071987-01-28028 January 1987 Affidavit of JW Mckay.* Provides Minor Corrections to 861017 Affidavit.Corrections Should Be Made to Allegation on Undercut Tolerances for Holes Drilled to Receive maxi-bolt Anchors.Certificate of Svc Encl ML20214S1271986-09-25025 September 1986 Affidavit of Tw Brombach Re Allegations Raised in Ps Miriello 860728 Affidavit Concerning QA Filed in Support of 860915 Motion to Reopen Record.Allegations W/O Factual Basis.Util s to Jn Grace Re Insp Encl ML20214S1051986-09-25025 September 1986 Affidavit of SA Brown Re 860728 Affidavit of Ps Miriello Concerning Radiation Exposure,Filed in Support of Motion to Reopen Record.Allegations Re Exposure to High Levels of Radiation Unsupported ML20210B6471986-09-13013 September 1986 Affidavit of Ps Miriello Re safety-related Welds That Never Received Preservice Insp ML20205F3771986-08-0606 August 1986 Affidavit of Tw Brombach Re Issues Raised in 860702 Request for Institution of Proceeding Per 10CFR2.206,specifically Allegations on Inservice Insp of Piping Welds.Insp Rept 50-400/85-48 Encl ML20210E0171986-07-28028 July 1986 Affidavit of Ps Miriello Re False Dose & Const Records Constituting Threat to Public Health & Safety ML20210B6961986-07-28028 July 1986 Affidavit of Ps Miriello Stating That QA Quality Check Program Not Used as Intended at Facility ML20210U7691986-05-16016 May 1986 Affidavit of Ps Miriello Re Failure to Act on Issues of False Dose Records,Intimidation & Unsafe Radiation Practices Until After Contention W-4 Produced ML20210U7751986-05-15015 May 1986 Affidavit of Ps Miriello Re Health Physics Supervisors Ordering Author to Agree W/False Radiation Rept & to File NRC Form 4 in Agreement W/False Radiation Rept ML20204A4921986-05-0606 May 1986 Affidavit of SA Browne Re Results of Review of Ps Miriello 860403 Affidavit in Support of Conservation Council of North Carolina & W Eddleman Request for Admission of New Contention WB-4 ML20210K7041986-04-0303 April 1986 Affidavit of Ps Miriello Re Falsification of Exposure Records.Related Info Encl.W/Certificate of Svc ML20154N2091986-03-10010 March 1986 Suppl to HR Goodwin Affidavit on Timing of Weather Alerts, Per ASLB Request.Info on Precise Times That Weather Alerts Transmitted Unavailable.Certificate of Svc Encl ML20205K6031986-02-24024 February 1986 Affidavit of RW Fell,Supporting NRC Response to Aslab Question Re Conservation Council of North Carolina Contentions 16,17 & 18.Certificate of Svc Encl ML20137P5991986-01-30030 January 1986 Affidavit of Ti Hawkins,Supporting Nrc/Fema Response to Applicant Motions for Disposition of Eddleman Contentions EPX-2 & EPX-8.Certificate of Svc Encl ML20137F4171986-01-13013 January 1986 Affidavit of W Ethridge Re Contention EPX-2.Minor Highway Patrol Radio & Telephone Communications Delays During 850517-18 Exercise Were Due to Priority Assigned to Messages & Emergency Operations Ctr.Difficulties Being Resolved ML20137J0731986-01-13013 January 1986 Affidavit of Ah Joyner in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys.Certificate of Svc Encl ML20137F4101986-01-13013 January 1986 Affidavit of Dh Brown Re Contention EPX-2.Relay Procedure Is Normal Operating Procedure for Radiation Protection Section Communications & Causes No Significant Delays or Addl Inaccuracies ML20137F6491986-01-13013 January 1986 Affidavit of M Scott Re Contention EPX-2.Chatham County Responded Appropriately & Effectively to Experience Gained During 850517-18 Exercise.Addl Dispatchers Will Assure Response to Radio Traffic Levels.W/Certificate of Svc ML20137F6161986-01-13013 January 1986 Affidavit of Ah Joyner Re Contention EPX-2.Corrective Actions Being Taken to Resolve Communications Problems Experienced During 850517-18 Exercise.Resolutions Expected Prior to Full Power Licensing of Plant ML20137J0591986-01-10010 January 1986 Affidavit of R Capps in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys ML20136F6401985-12-31031 December 1985 Affidavit of Dn Keast Re Correction to 851104 & 05 Oral Testimony on Eddleman Contention 57-C-3.Certification of Svc & Notice of Withdrawal Encl ML20137L7951985-11-26026 November 1985 Affidavit of Wj Hindman Re Info on Age Distribution & Gender of Daniel Intl Corp Employees & First Line QA Inspectors at Facility.Certificate of Svc Encl ML20135H8321985-09-23023 September 1985 Affidavit of SL Burch Re Undercover Drug Operation at Facility.Related Correspondence ML20135H8371985-09-19019 September 1985 Second Affidavit of SL Burch Re Drug Investigation at Facility.Related Correspondence ML20137L6741985-09-0606 September 1985 Affidavit of P Miriello Re Drug Abuse Observed at Facility Const Site.Certificate of Svc Encl ML20134H4261985-08-23023 August 1985 Affidavit of Wp Haass Re ASLB Questions Concerning Whether Public Disclosure of Info Voluntarily Submitted to NRC Would Impair NRC Future Ability to Obtain Similar Info.Notice of Appearance of Ga Berry & Certificate of Svc Encl ML20135C0421985-08-23023 August 1985 Affidavit of Wp Haass Addressing Series of Questions Propounded by ASLB Re Whether Public Disclosure of Info Contained in Certain Applicant Documents in ASLB Possession Would Impair Staff Ability to Obtain Info ML20134E7891985-08-14014 August 1985 Affidavit of Wj Hindman Responding to SL Burch 850731 Affidavit Re Undercover Drug Investigation During Fall 1984 ML20134E7761985-08-14014 August 1985 Affidavit of MW King Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7661985-08-14014 August 1985 Affidavit of DG Joyner Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7831985-08-0909 August 1985 Affidavit of ML Plueddemann Re Fall 1984 Undercover Drug Investigation at Site ML20133A1111985-07-31031 July 1985 Affidavit of SL Burch Re Assertions in King Affidavit & Undercover Operation of Facility Concerning Drug Abuse. Intelligence Indicated Drug Dealings & Abuse Widespread. Certificate of Svc Encl ML20129H1061985-07-11011 July 1985 Affidavit of Nj Chiangi Re Allegation in Conservation Council of North Carolina Contention WB-3.QA Program Provides Necessary Steps to Ensure Safe & Reliable Power Plant.Certificate of Svc Encl ML20129H0941985-07-10010 July 1985 Affidavit of Wj Hindman Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const ML20129H0821985-07-10010 July 1985 Affidavit of Pb Bensinger Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const.Biography Encl ML20129H0911985-07-0909 July 1985 Affidavit of Jd Ferguson Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Cp&L Adopted Drug & Alcohol Interdepartmental Procedure.Resume & Procedure Encl ML20129H0991985-07-0909 July 1985 Affidavit of AR Pannill & Gw Flowers Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Employees Subjected to Preemployment Background Verification ML20129H0871985-07-0909 July 1985 Affidavit of MW King Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Use Widespread & That Mgt Failed to Control Drug Use During Const.Resume Encl ML20128M0401985-07-0808 July 1985 Affidavit of TS Elleman Supporting Util 850709 Application for Withholding Final Rept Shnp QA/QC-Const Inspector Review Panel, Per 10CFR2.790.Certificate of Svc Encl. Related Correspondence ML20128M0331985-07-0808 July 1985 Affidavit of HR Banks Supporting Util 850709 Application for Withholding Documents,Including Quality Check Rept,Concern/ Allegation Followup & Quality Check Procedure Investigation Rept,Per 10CFR2.790.Related Correspondence ML20116N7771985-05-0202 May 1985 Affidavit of Ti Hawkins in Support of Applicant Suppl to Motion for Summary Disposition of Eddleman Contention 213 Re Emergency Planning.Certificate of Svc Encl ML20116D0091985-04-25025 April 1985 Affidavit of Jf Myers Describing Recent Change to Provisions for Official Transportation Assistance for Persons in Emergency Planning Zone Needing Assistance in Event of Plant Emergency.Related Correspondence ML20112K0061985-04-0505 April 1985 Supplemental Affidavit of RG Black on Eddleman Contention 213.Provisions for Alert & Notification of Persons on Harris Lake Obviate Measures Suggested by Contention ML20112K0131985-04-0505 April 1985 Supplemental Affidavit of MR Bassiouni on Eddleman Contention 213.Rept of Proposed Siren Configuration & One Oversize Map Encl.Aperture Card Available in PDR ML20100B1011985-03-22022 March 1985 Supplemental Affidavit of Eh Harris Re Rev of School Evaluation Procedure Which Would Reduce Number of Students Riding Buses & Use of Buses Kept on Property During School Hours.Certificate of Svc Encl.Related Correspondence ML20107M5111985-02-27027 February 1985 Affidavit of Ti Hawkins in Support of Motion for Summary Disposition of Eddleman Contention 30.Emergency Response Plan Provisions Fully Comply w/NUREG-0654 ML20107K0411985-02-26026 February 1985 Affidavit of Ti Hawkins in Support of Applicant Motion for Summary Disposition of Contention EPJ-4(c).Prof Qualifications Encl.Certificate of Svc Encl 1999-04-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] |
Text
.
p%
00CKETED usuc
'86 JAN 16 A9 :59 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION (/F;CE 6 SECRETAc' CCCMETihG & SE?v!U l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD BitANCH 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 MARK SCOTT ON CONTENTION EPX-2 COUNTY OF CHATHAM )
) ss:
STATE OF NORTH CAROLINA )
MARK SCOTT, being duly sworn, deposes and says:
- 1. I am the Coordinator of Emergency Management in the Chatham County Office of Emergency Services. In this capacity, I am responsible for the development, review, modification, and cocedination of emergency response procedures for Chatham County. I also serve as liaison - between Chatham County emergency service organizations (i.e., fire, rescue and law enforcement organizations) and the State of North Carolina. A current statement of my professional qualifications and capabilities is attached to this affidavit. My business address is P. O. Box 428, Pittsboro, North Carolina 27312. I make this affidavit in response to Contention EPX-2. I have personal knowledge of the matters stated herein and believe them to be true and correct.
- 2. Several Chatham County emergency response organizations participated in the full-scale exercise held on May 17 and .18,1985 for a simulated accident at the t
8601170563 860113
. PDR ADOCM 05000400 0 PDR
y l .
Shearon Harris Nuclear Power Plant. It was my role to direct the Chatham County Emergency Operations Center (EOC), which coordinated the response within the County by providing overall direction to its fire, - rescue and law enforcement agencies participating in the exercise. Included in the responsibilities of the EOC tisff was the control of radio communications for these agencies.
- 3. This e'xercise was Chatham County's first test of its capability for off-site response to a potential accident at the plant. I believe the exercise both demonstrated that.Chatham County's overall emergency response capabilities are good, and provided the opportunity to identify areas that could be improved. Following the exercise, within Chatham County and in coordination with the Division of Emergency Management of the State of North Carolina, we have evaluated the results of the exercise and are making improvements in our emergency response procedures and capabilities. Improvements needed in the area of concern addressed by Contention EPX-2 have been completed.
- 4. At the start of the exercise on May 17, 1985, Chatham County had one dispatcher on duty, which was the normal staffing level for that time. Upon notification of the simulated emergency at the plant, the dispatcher correctly followed a " call-in" procedure to obtain assistance, and the called-in personnel arrived approximately ten minutes after being notified. Their arrival provided the EOC with two radio dispatchers and two additional dispatchers to handle the telephone communications. During the very brief pericd when only one dispatcher was on duty, radio traffic was heavy. I believe, however, that after this initial period of approximately ten minutes, the additional
, dispatchers adequately handled all of the traffic that took place in Chatham County throughout the remainder of the exercise.
S. It is worthwhile to point' out that throughout the exercise, radio traffic regarding a simulated emergency was added to our normal, routine radio traffic over the two day period. Had an actual emergency been occurring at the plant, the radio traffic regarding the County's response would have received an appropriate priority.
l i
, i
- 6. As a result of. Chatham County's assessment of the exercise, we have improved our communications staff by adding additional personnel. Chatham County now has two full-time radio dispatchers that work in the communications center during the hours'of the week that the greatest communications traffic occurs. This provides the ability to effectively handle increased radio communications which might suddenly develop from a major emergency without the immediate call-in of additional personnel-even if this happens at a time of normally higher radio traffic. Such an emergency might be an~ accident at the plant. Of course, the County still maintains a call-in list of additional dispatchers in case they are needed to respond to an emergency as it progresses and radio traffic increases beyond initial levels. Chatham County has also taken steps to remove some traffic from the airwaves by installing a repeater station which is used for our county fire di; patch. This repeater allows all of our units on this frequency in the county to hear each other without the need to relay through our central communications center.
- 7. I believe that Chatham County has responded appropriately and effectively to the experience gained during the exercise. I am confident that the additional dispatchers employed by the County will assure the capability to respond to initial and continuing radio traffic levels which would be experienced in the event of an accident at the Shearon Harris Nuclear Power Plant.
k Ch MARK SCOTT Sworn to and subscribed before me this /0 A of January,1986.
q/ 4pW &. Public L "t,'p, Notary ,
h .' ....ge...' 9't 7, n expires: b '/ /f M y ion v ju.; _,_
\ki% Avi
%,'>,,ilmst f
MARK SCOTT Chatham County Office of Emergency Services Post Office Box 428 401 West Street Pittsboro, N. C. 27312 PROFESSIONAL EXPERIENCE Emergency Management Coordinator, Emergency Services Director and Fire Marshal of Chatham County As Emergency Management Coordinator, my duties include acting as liaison between Chatham County emergency service organizations (fire, rescue and law enforcement organizations) and the State of North Carolina. I am on call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day for emergencies in Chatham County, either in a response or advisory capacity.
procedures for emergency serv, ices and am directly responsible services. I advise the County Manager and Board of Commissioners on procedures and activities of rescue squads and ambulance services.
As Fire Marshal, I investigate suspicious fires, enforce fire codes and inspect domiciliary care agencies. I also advise the County Manager and Board of Commissioners on procedures and activities of fire agencies.
Member Bonlee Fire and Rescue Department,1970 - Present; Captain, 1971-73; Chief, 1973-1983; Assistant Chief, May 1983 - Present.
TRAINING North Carolina Fire College sponsored by North Carolina Firemen's Association, North Carolina Association of Fire Chiefs and North Carolina Department of Insurance, 1973-74.
Hazardous 1983-84. Materials, Leak and Spill Controls School sponsored by Safety Systems, Inc.,
North Carolina Sanford, Basic Law Enforcement Course, Central Carolina Technical College, N. C.,1983. .
Emergency Services, Medical Technician Course sponsored by North Carolina Office of Emergency 1973-74.
l
~
J
Fire Pump Operator Instruction sponsored by North Carolina Department of Insurance, 1974.
Propane Leak and Fire ControlInstruction sponsored by North Carolina Fire Instructor's Association,1975.
Basic Radiation Emergency Preparedness Course sponsored by North Carolina Division of Emergency Management,1984.
Continuing Education Courses in Emergency Medicine sponsored by North Carolina Office of Emergency MedicalServices, 1976-84.
Police Informaton Network (PIN) Operator Training sponsored by North Carolina Justice Academy,1983.
Rural Water Supply Instruction sponsored by Cumberland County Firemen's Association, 1976.
Received certification from the Professional Association of Diving Instructors as a certified diver,1982.
e
=
b .
l
U l 0 0.'EL: J L5N <u UNITED STATES OF AMERICA '86 JAN 16 A9 :59 NUCLEAR REGULATORY COMMISSION LFFig: Er SEcstie BEFORE THE ATOMIC SAFETY AND LICENSINGMAgG ANCH & SE8viU In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN ) D teket No. 50-400 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power Plant) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motlo . for Summary Disposition of Eddleman Contention EPX-2," " Applicants' Statement of Material Facts as to Which There Is No Genuine Issue to be Heard on Eddleman Contention EPX-2," " Affidavit of Dayne H. Brown on Contention EPX-2," " Affidavit of William Ethridge on Contention EPX-2," " Affidavit of Alvin H. Joyner on Contention EPX-2," and " Affidavit of Mark Scott on Contention EPX-2" were served this 13th day of January,1986 by deposit in the United States mall, first-class, postage prepald, to the parties on the attached Service List, except for the copy for Steven Rochlis, which was sent Federal Express.
l a
Dale E. liollar Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 ,
Dated: January 13,1986 4
\s
l
[
[ SERVICE LIST J:mes L. Kelley, Esquire M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U. S. Nuclear Regulatory Commission Post Office Box 12643
~ Washington, D. C. 20555 Raleigh, North Carolina 27605
-Mr. Glenn O. Bright Dr. Richard D. Wilson At:mic Safety and Licensing Board 729 Hunter Street U. S. Nuclear Regulatory Commission Apex, North Carolina 27502
. Washington, D. C. 20555 Mr. Wells Eddleman Dr. James H. Carpenter 806 Parker Street
' Atomic Safety and Licensing Board Durham, North Carolina 27701 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Thomas A. Baxter, Esquire Delissa A. Ridgway, Esquire
? - Charles A. Barth, Esquire Shaw, Pittman, Potts & Trowbridge Myron Karman, Esquire 1800 M Street, NW Office of Executive Legal Director Washington, D.C. 20036 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Bradley W. Jones, Esquire U. S. Nuclear Regulatory Commission Docketing and Service Section Region 11 Office of the Secretary 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555 Robert P. Gruber Mr. Daniel F. Read, President Executive Director Chapel Hill Anti-Nuclear Public Staff Group Effort North Carolina Utilities Commission Post Office Box 2151 Post Office Box 991 Raleigh, North Carolina 27602 Raleigh, North Carolina 27602 Dr. Linda Little Mr. Joe Flynn Governor'r Waste Management Board Associate General Counsel
' 513 Albemarle Building Federal Emergency Management Agency 325 Salisbury Street 500 C Street, S.W.
Rdelgh, North Carolina 27611 Room 480
/p Washington, D. C. 20740 J:hn D. Runkle, Esquire C:nservation Council of North Carolina 307 Granville Road Steven Rochlis Chapel Hill, North Carolina 27515 Federal Emergency Management Agency l
1371 Peachtree Street, N.E.
L J) Anne Sanford, Esquire Atlanta, Georgia 30309 Special Deputy Attorney General Post Office Box 629 Raleigh, North Carolina 27602
.