ML18019A486
| ML18019A486 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/19/1985 |
| From: | Bright G, Carpenter J, Kelley J Atomic Safety and Licensing Board Panel |
| To: | Asselstine J, Palladino N, Roberts T NRC COMMISSION (OCM) |
| References | |
| CON-#485-228 OL, NUDOCS 8511210412 | |
| Download: ML18019A486 (12) | |
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UNITEDSTATES NUCLEAR REGULATORYCOMMISSION ATOMICSAFETY AND LICENSING BOARD PANEL WASHINGTON,OA'0555 November 19, 1985 ENCLOSURE 1 Chairman Nunzio J. Palladino Comissioner Thomas M. Roberts ComIissioner James K. Asselstine Commissioner Frederick M. Bernthal Comissioner Lando W. Zeck Dear Mr. Chairman and Comissioners:
We are writing this letter to bring to your attention evidence of possible generic safety problems involving nighttime emergency notification of residents in the plume emergency planning zones surrouncfing nuclear power plants.
It appears that under the acceptance criteria being generally applied by the Federal Emergency Management Agency to nuclear plant siren systems criteria which are based on daytime, conditions substantial numbers of EPZ residents would not be aroused from sleep should an emergency siren notification be necessary between.
say, midnight and 6:00 a.m., particularly if bedroom.windows were closed.
We are members of the Atomic Safety and Licensing Board presiding over the application of Carolina Power and Light Co., et al. for an operating license for the Shearon Harris faci1ity.
Me rece~nt y conducted an evidentiary hearing in that case on an Intervenor's contention that the Applicants'irens would not awaken sleeping residents in the EPZ between midnight and 6:00 a.m., particularly those who have closed their..
windows and turned on their air conditioners.
Both the Applicants and the Federal Emergency Management Agency presented extensive testimony and responded to cross-examination on the contention, as reflected in the Shearon Harris transcript.
Tr. 9356-9976.
The parties will be submitting proposed findings of fact on the siren and another contention during December, and the Board expects to decide those contentions in early 1986.
In these circumstances, we as a Licensing Board have not drawn any conclusions about the particular siren contention before us in the Shearon Harris case.
In any event, we would have no occasion to write to you about Shearon Harris at this time in advance of the normal review process because Harris is not, of course, an operating facility.
Furthermore, should any deficiencies in nighttime notification emerge from the Shearon Harris record, we could fashion effective measures to deal with them on a site-specific basis.
- Rather, this letter is prompted by the possible eneric implications of certain of the evidence in the Shearon Harris recor
, and our belief that such evidence should be called to your attention now.
Most significantly, you should be aware of the following matters:
1.
The FEN design criteria provide for siren sound coverage of 10 dB(a) above ambient noise levels or a minimum of 60 dB(c).
2.
The "FEMA 43" reviews of siren system designs for operating nuclear facilities are based on summer daytime conditions.
Such reviews give no consideration to factors only applicable at night i.e., almost everyone is indoors and asleep, many with the windows closed.
These factors are not offset by greater sound propagation at night.
3.
The testimony is that, for a house with the windows closed (central air conditioning) and an outdoor siren sound level of 60 dB, the probability of arousal from sleep is essentially zero.
With the windows open, the probability is 7-8X.
(Tr. 9650).
4.
The sound levels necessary for high probability of arousal are substaotially above the FENA minimum guidance.
For example, a
50%
probabihity of arousal of an individual in a house with the windows closed requires outdoor sound levels of 90-99 decibels (Tr. 9927).
The wide range in this estimate reflects the imperfect knowledge of siren arousal capability, since direct tests have not been conducted, at least in the United States.
5..
For the Harris assumed summer scenario including 36K of the houses in the EPZ with no air conditioning (windows open) arousal is estimated as approximately 70%.
Assuming the accuracy and acceptability of that estimate, lower probable arousal rates in other climatic areas
... of the United States nevertheless suggest possible generic safety
---concerns-particularly in the winter season.
when more of the population may sleep with the windows closed.
6.
We further note that overall arousal percentages for an EPZ can mask the fact that, in areas of moderate housing density but with a fair number of houses more than one mile from a siren, a substantial percentage of the houses would have an arousal probability of less than 50K.
For example, at siren 70 in the Harris EPZ, about 100 houses of about 160 in that area, or 63K, are in the 70-80 dB area.
The probability of arousing an individual in those houses with the windows closed is approximately 30K, and is 55% for household arousal with two residents.
If these houses correspond to,U.S. averages, 18K would have one resident, 30$ would have two residents, and the average probability of arousing the household would be 43K.
Thus, although the risk of not being aroused, averaged over the
- EPZ, may be roughly 30K, in some areas approximately 50K of the houses may have a risk of non-arousal of roughly 575.
NRC regulations require "early notification" to EPZ residents (10 C.F.R.
. 50.47(b)(5)),
and this has been further defined to mean that the design objective of "the prompt public notification system shall be to have the capability to essentially complete the initial notification of the
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public within the plume exposure pathway EPZ within about 15 minutes."
10 C.F.R. Part 50, Appendix E, IV D.3.
The evidence we have cited indicates that in EPZs which rely primarily on siren notification (it is our impression that that 'is the case for most commercial reactors),
such notification would not be "essentially complete" under some:typical nighttime conditions within 15 minutes.
To be sure, emergency notification typically includes "back-up" notification by police, fire and other emergency vehicles driving prearranged routes with sirens.
sounding.
However, as was testified to in the Shearon Harris case, this back-up notification probably would not be accomplished in the 15-minute period.
Testimony of Alvin H. Joyner at 42. ff. Tr. 9374. It seems doubtful that such back-up notification could be completed expeditiously if emergency workers had to first be reached and activated between midnight and 6:00 a.m.
We also are aware that persons who are aroused from sleep might not only arouse:%heir household.
but that.they, would also tend to contact some neighbors, friends and relatives in the EPZ.
This process of "informal notification" was testified to at some length in the Shearon Harris
- hearing, and the Board does not doubt that such informal notification would occur to some tfegree.
However, the phenomenon cannot be controlled like a siren level or a police car route, and its likely effects are difficultto quantify.
Therefore, we question whether informal notification should be viewed as a substitute for planned notification.
According to testimony in the Shearon Harris case, the siren systems
-.-.-around operating nuclear plants have not been field-tested to determine what percentage of EPZ residents would actually be aroused by their activation. between midnight and six a.m.
Tr. 9935-40.
We believe that some such testing would be prudent and merits Commission consideration.,
Respectfully submitted,/~
s e
ey ames arp ter G enn rig t cc:
H. Plaine, General Counsel S. Chilk, Secretary Shearon Harris Service List
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ENCLOSURE 2 Federal Emergency Management Agency Washington, D.C. 20472 0
0 DEC 6 l985 rt erson Chief Technological Hazards Division MEHORANDlJ1 FOR:
Dave Matthews Chief Emergency Preparedness Branch US atory Ccaanission FKN:
SVNECT:
Nighttime Emergency Notification This memorandum transmits (see attachnent)
FEMA's response to the Atanic Safety and Licensing Board's (ASLB) November 19, 1985 mamrandan notifying the Commission of possible generic safety problens involving nighttime emergency notification.
HlRKSE:
The remembers of the AKB presiding over the application of Carolina Power and Light Co. et al. for an operating license for the Shearon Harris facility informed the Commissioners, in a letter dated November 19, 1985, of "evidence of possible generic safety problems involving nighttime emergency notification of residents in the plume energency planning zones surrcunding nuclear power plants."
This discussion presents the Federal Emergency Manageient Agency's (FBQ.'s) evaluation of the evidence presented in this letter and its conclusions concerning the existence of a possible generic safety problen.
BACKGfQUND The Federal Emergency Management Agency (FIRMA), as the lead Federal agency in a Memoranda of Understanding (NN) with the Nuclear Regulatory Canmission (NRC), is resgensible for evaluating and approving prompt alert and notifi-cation systems that are installed around cannercial nuclear power plants throughout the United States.
These systans have been, or are being, installed within the te~e Emergency Planning Zone (EPZ) of each nuclear power plant by cocperative agreements between NRC licensees and State and local goveranents to provide a mechanism for rapidly alerting the public in the event of an anergency at the rlclear power plant.
NRC licensees were mandated by the NRC to have alert and notification systems installed for all cperating nuclear power plants by February 1, 1982, (originally July 1, 1981) < or face enforcenent actions.
All nuclear power plants scheduled to go on line after February 1, 1982, must have an alert and notification system in place prior to operation.
10 CFR $ 50.47(b) (5) and 44 CFR Part 350 require that. "means to provide early notification and clear instruction to the populace within the plune exposute pathway Emergency Planning Zone have been established."
10 CFR Part 50 Appendix E S D.3 requires in addition that "The design objective of the pranpt public notification systen shall be to have the capability to essentially canplete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes.
The use of this notification capability will range fran immediate notification of the public (within 15 minutes of the time that State and local officials are notified that a situation exists requiring urgent action) to the rrore likely events where there is substantial time available for the State and local goverrInental officials to make a judgment whether or not to activate the public notification system."
In 1980, NRC and FIRMA published final guidance in NUREG-0654/FIRMA-REP-1 Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency
Response
Plans and Preparedness in Support of Nuclear Power Plants" which defined in technical terms, how the regulatory requirenents in 10 CFR 50 where to be met.
In 1983, FIRMA published interim guidance in FBIA-43 "Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" which organized the acceptance criteria of NUREG-0654/FB4A-REP-l, Rev.
1 into a format that could be used by the utilities to docunent their alert
and notification systems installations for review and approval under PENA's 44 CFR 350 process..
PENA-43 did not change the design criteria established in RREG-0654/FEMA-REP-l, Rev. l.
To date, over 60 plants have submitted their prcapt alert and notification system design plans, as prescribed in FEMA-43, for review by FENA.
F&1A expects to canplete its review of these'sites, including findings to the NRC urder the K)U, by the end of calendar 1986.
ISSUES:
'Jhe AS'embers, in their letter, cited the following evidence as the basis of their concern:
2) 3)
The FERA design criteria provide for siren sound coverage of 10dB(a) above anbient noise levels or a minimun of 60dB(c).
The 'FB4A-43'eviews of siren system designs foor cperating nuclear facilities are based on saner daytirre conditions.
Such reviews give no consideration to factors only applicable at nighti.e. < almost everyone is indoors and asleep, many with the windows closed.
'Ihese factors are not offset by greater sound propagation at night.
The testimorp is that, for a house with the windows closed (central air conditioning) ard an outdoor siren sound level of 60dB, the probability of arousal fran sleep is essentially zero.
With the windows open, the probability is 7-8%.
(Tr. 9650).
4)
The sound levels necessary for high probability of arousal are substantially above the FEMA minimun guidance.
For
- example, a
50% probability of arousal of an individual in a house with the wirdows closed requires outdoor sound levels of 90-99 decibels (Tr. 9927).
'Ihe wide range in this estimate reflects the imperfect knowledge of siren arousal capability, since direct tests have not been conducted, at least in the United States.
5)
For the Harris assumed sumner scenario including 36% of the houses in the EPZ with no air conditioning (windows open) arousal is estimated as approximately 70%.
Assuming the accuracy and acceptability of that estimate, lower probable arousal rates in other climatic areas of the United States nevertheless suggest possible generic safety concerns~r-ticularly in the winter season, when rrore of the population may sleep with the windows closed.
6)
M further note that overall arousal percentages for an EPZ can mask the fact that, in areas of moderate housing density but with a fair number of houses mere than one-mile fran a siren, a s&stantial percentage of the houses would have an arousal probability of less than 50%.
For example, at siren 70 in the Harris EPZ, about 100 housel'f about 160 in that area, or 63%, are in the 70-80dB area.
'Ihe probability of are@sing an individual in those houses with the windows closed is appmximately 30%, and is 55% for household arousal with two residents.
If these houses correspond to U.S. coverages, 18% would have one
- resident, 30% would have two residents, and the average probability of arousing the household would be 43%.
- Thus, although the risk of not being amused, averaged over the EPZ, may be roughly 30%< in scae areas approximately 50% of the houses may have a risk of non-arousal of roughly 57%.
- 7) & also are aware that persons who are aroused frcm sleep might not only arouse their household< but that they would also tend to contact scae neighbors, friends and relatives in the EPZ.
This process of "informal notification" was testified to at scae length in the Shearon Harris hearing, and the Board does not daubt that smh informal notification would occur to scae degree.
However, the phencaenon cannot be contmlled like a siren level or a police car ate, and its likely effects are difficult to quantify.
Therefore, we question whether informal notification should be viewed as a substitute for planned notification."
FEI% EVALUATION Issue Nl.
For acceptance of the licensee's or applicant's siren system, FBQ;43 requires that the design report demonstrate that either "(a) the expected siren sound level generally exceeds 70dBC where the population density exceeds 2,000 persons per square mile and 60dBC in other inhabited areas or (b) the expected siren sound level generally ex~ the average measured daytime anbient sourd levels by 10dB." It should be noted that these are minimum requiranents and, in fact, cost effective siren system
- design, which locates sirens within population centers, results in many households being exposed siren sound levels that significantly exceed these minimums.
For example, the Shearon Harris siren system, which is not atypical, provides sound levels in excess of 80dBC to alnost 60% of the residence in the EPZ, under typical suaner nighttine conditions.
Issue 02.
The FBI&3 reviews are based upon sumner daytime conditions only to the extent that sunaer daytime conditions are used to ncdel sound propa-gation.
'Ihis approach is taken because siren sound propagation is least effective during these conditions.
Therefore an analysis that deacnstrates
that the FBI&3 and NURHG-0654/PRIA~1, Rev. 1 requirenents are m t under average sumner daytime corditions pmvides reasonable assurance that they willbe met in the event of an actual emergency at any time af year.
The attenuation of structures, whether windows are open or closed and the need to provide a signal laud enough to alert people was considered in establishing the minimum acceptable sound pressure levels.
In particular< as KB~0654/
FEME~-l, Rev.
1 states:
"The 10dB differential above daytime anbient is intended to
...proyide a distinguishable signal inside of average residential construction under average conditions>...research has shown that a person is capable of being alerted by such a differen-tial above or belov the backgrzmnd asbient in the case of a predcndnantly narrow band 300 to 800 Hz esdtted by large sirens."
Issue 03.
The cited testimony is not in agreement with FBCA expert witness testimony which indicates that the probability of arousing an individual from sleep under the circumstances cited with wia9cws closed, is approximately 20%
and with windows open is approximately 30%.
Using the mix of one and two resident households cited as representative of the U.S. by the board aanbers, this corresponds to an average household probability of direct (iee., by siren) arcusal of 33% for houses with windcam closed and 47% for houses with windcws open.> It should be noted that these direct arousal pmbabilities are for hcusetalds at the minimum acceptable sound levels and, under actual circum-
- stances, would be supplemented by informal notification by other alerted residents
[see evaluation of issue 07].
Issue 44.
Again the cited testimony is not in agreertent with FB4h, expert
.., witness.testimony that indicates that abcut 85dB would provide a 50%
probability of direct arousal of a sleeping individual.
Using the mix of one and two resident households cited as representative by the board members, this 85dB sound level would be expected to arouse about 70% of all households.
As noted in the discussion of issue 3, this direct arousal wouid be supplemented by informal notification by other alerted residents.
Issue <<5.
The arcvsal estimated cited is for direct arcusal only.
Both FENA and applicant expert witnesses testified that the inclusion of informal arcusal m chanisms
[see response to issue 47] auld increase the percentage at the population aroused to approximately 90%.
Issue 06.
FIRMA agrees with the observation that, if the overall direct amusal percentage for an EPZ is 70% then there will be households for which the direct arousal rate is less than 50%.
However, it should be noted that the letter's treatment of multi-resident households is improper since it Daytime anbient is used because it is higher than nighttime ambient.
ignores the 52% of the'households nationwide with three or aare residents.
If these are treated
[conservatively]
as two resident households, the correct average prcbability of arousing the household auld be 50.5%.
Thus, although FB4A agrees with the general observation that there will be households with direct arousal probabilities lower than 50%,
we note that the cited figures do not provide a supportirg example.
Issue 07.
In disregarding informal alerting mchanisms, the board nembers are failing to consider a phenarenon which is known to occur and for which quantitative date have been obtained on analogcus occasions.
The NRC makes predictive findings, often on the basis of engineering judgarent, for other pherxmena that are known to happen but are not strictly controllable (e.g.,
accidents)
~ It is FEMA8s judgment that consideration of informal alerting mechanisms, based upon quantification of actual experience by disaster sociologists, is appropriate so'long as such consideration incorporates suitable conservatism.
In addition, FBI'notes that infoxmal notification nechanisms have been recognized by NRC boards in other hearings.
See eecCe Duke Power (Catawba Nuclear Station, Units l anc 2), ISP-84-37, 20 N.R.C.
1): H>>k Nuclear Generating Station, Units 2 and 3), LBP-82-46, 15 N.R.C. 1531, 1534-35 (1982).
CONCLUSION:
Evaluation of the evidence.presented in the November 19, 1985, letter to the Camissioners fran the medSers of the ASLB presiding over the application of Camlina Power and Light Co. et al. for an cperating license for the Sheamn Harris facility does not irdicate that there are possible generic safety problems involving nighttime emergency notification of residents in the plume emergency planning zones surrounding nuclear power plants.
The evaluation criteria in NURE'&654/PHD-REP-l, Rev.
1 and the acceptance criteria in FBK-43 are intended to ensure that alert and notification systems that are designed and evaluated in accordance with these criteria meet NRC's 10 CFR 50 Apperdix E design objective "to have the capability to essentially canplete the initial notification of the public within the plume exposure pathway within about 15 minutes."
The siren system for the Shearon Harris Nuclear Power Plant, which is not atypical of the siren systans at other nuclear pwer
- plants, was designed, evaluated, and found to be acceptable under these criteria.
The conclusion reached in FB4A s study, in response to the hearing contention, that this siren systan can be expected to arouse and alert approximately 90% of the EPZ residents during a nighttime emergency serves to confirm FBIs judgarent that siren systems designed and evaluated in accordance with NUREG-0654/FIRMA~-l, Rev.
1 and FBI&3 meet the NRC requirements for both daytine and nighttim alerting.
ENCLOSURE 3 RE UIREMENTS AND GUIDANCE RELATING TO U
L The requirement for a public alert and notification system is set forth in 10 C.F.R. 550.47(b)(5) of the Commission's regulations.
This regulation requires that: "... means to provide early not'ification and clear instruc-tion to the populace within the plume exposure pathway Emergency"Planning Zone have been established."
Appendix E to 10 C. F. R. Part 50 establishes the mini-mum requirements for emergency plans in order to attain an acceptable state of emergency preparedness.
10 C. F. R. Part 50, Appendix E 5IV.
In addition, the Commission has established a design objective for the prompt public notification system; this design objective is that the system "... shall. have the capa-bility to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes."
10 C. F. R. Part 50, Appendix E SIV.D.3.
The responsjbility for determining the adequacy of offsite emergency plans, including the adequacy of the prompt public notification system, rests with the Federal Emergency Management Agency (FEMA).
- See, Memorandum of Understanding between NRC and FEMA, 50 Fed.
~Re
. 15485 (Apr~118, 1985).
FEMA makes its determination of the adequacy of offsite emergency plans by evaluating their compliance with the standards and criteria of NUREG-0654/FEMA-REP-l, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency
Response
Plans and Preparedness in Support of Nuclear Power Plants" (November 1980).
NUREG-0654 contains acceptance criteria for a prompt public notification system.
NUREG-0654 Appendix 3, 58.
The minimum acceptable design objectives for coverage by a prompt public notification system are:
ga)
Capability for providing both an alert signal and an informational or instructional message to the population on an area wide basis throughout the 10-mile EPZ, within 15 minutes.
(b)
The initial notification system will assure direct coverage of essentially 100K of the population within 5 miles of the site.
(c)
Special arrangements will be made to assure 100K coverage within 45 minutes of the popu-lation who may not have received the initial notification within the entire plume exposure EPZ.
NUREG-0654, Appendix 3 at 3-3. 1/
The acceptance criteria of NUREG-0654 have been further clarified by FEMA-43, "Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants."
1/ Appendix 3 also contains specific acceptance criteria relating to sirens and siren systems.
These criteria are discussed further in the enclosed FEMA response.
-2" NVREG"0654 notes, however, that it is a design objective to meet the criteria of SB of Appendix 3, and that this does not mean that there is a "..
. guarantee that early notification can be provided for everyone with 100K assurance or that the system when tested under actual field conditions will meet the design objec-tive in all cases."
NUREG-0654 at 3-1.
This statement is consistent with the Commission's view of the effect of the actual operation of such a system.
As the Commission stated, "The Commission recognizes that not every.individual would necessarily be reached by the actual operation of such a system under all conditions of system use."
45 Fed.
~Re
. 55402 (August 19, 1980).
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