ML20006C427
| ML20006C427 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/01/1990 |
| From: | Greer L MASSACHUSETTS, COMMONWEALTH OF |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20006C428 | List: |
| References | |
| CON-#190-9785 LBP-89-17, OL, NUDOCS 9002080026 | |
| Download: ML20006C427 (272) | |
Text
. . . - - - .
o @ 12
- /
a -
UNITED STATES OF AMERICA *
$30 1 O NUCLEAR REGULATORY COMMISSION 7 i9 ~ ~-
ATOMIC SAFETY AND LICENSING APPEAL BOAR sR ya
< s Before Administrative Judgest g g O G. Paul Bollwerk III, Chairman Alan S. Rosenthal Howard A. Wilber
)
O In the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL PUBLIC SERVICE COMPANY )
OF NEW HAMPSHIRE, ET M,. )
)
(Seabrook Station, Units 1 and 2) )
O >
O MASS AG'S MOTION TO REOPEN THE RECORD O
l 0
COMMONWEALTH OF MASSACHUSETTS JAMES M. SHANNON ATTORNEY GENERAL
.O Leslie B. Greer Assistant Attorney General Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108
.C- (617) 727-2200 l
DATED: February 1, 1990 O 900200002b 900201 PDR ADOCK 05000443 PDR 15"A J
G ,
J
1
'O I
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-ATOMIC SAFETY AND LICENSING APPEAL BOARD Before the Administrative Judgest O G. Paul Bollwerk III, Chairman Alan S. Rosenthal Howard A. Wilber O
)
In the Matter of ) Docket Hos.
PUBLIC SERVICE COMPANY ) 50-443-OL OF NEW HAMPSHIRE, EI &L. ) 50-444-OL g (Seabrook Station, Units 1 and 2) )
)
)
MASS AG'S MOTION TO REOPEN THE RECORD 1/
g The Massachusetts Attorney General (" Mass AG") moves this Board to reopen the record in that portion of the Seabrook proceeding dealing with the adequacy of the utility's alert and g notification system as that system is set out and relied upon in both the Seabrook Station Radiological Emergency Response Plan
("SSRERP" or "onsite plan") and the Seabrook Plan for S
1/ The Mass AG states that this filing as well as all other efforr.s made after November 18, 1989 to seek additional' intra-agency relief in the Seabrook licensing action reflects no intention or purpose to elect to continue such intra-acency review in deroaation of his rights to have " final agency licensing action" (which the November 9 license authorization under Commission regulations, federal statutes, and case law constitutes) reviewed by the cognizant Court of Appeals.
Instead the Mass AG files all such pleadings only to protect his rights to such agency relief in the event that Court review is stayed or denied.
1 0 ;
i i
1 Massachusetts Communities ("SPMC"). This motion is filed pursuant to $189(a) of the Atomic Energy Act and is based upon
~
the grounds set forth below.
INTRODUCTION 3 A separate Atomic Safety and Licensing Board (the "Bloch l J
Board") was assigned to hear matters pertaining to the utility's alert and notification system. In Public Service Comoan" of New Hamnshire, et al. (Seabrook Station, Units 1 and 2) , LBP-89-17,
~
j ;
29 NRC 519(1989), (hereafter "LBP-89-17") that Board found the 1 system to be adequate. One of the factual underpinnings of that finding was the Board's assumption that the Applicants would use 3
the Massachusetts Emergency Broadcast System ("EBS") as the i primary means of providing notification to the general populace within the Massachusetts EPZ. That the Bloch Board relied upon 1
l this assumption is established by review of the five separate -
instances in its decision on the alert and notification system
) in which it referenced EBS.
In its Memorandum and C; der ruling on the Applicants' motion for summary disposition,.the Bloch Board twice stated that the
) Applicants were relying on the operation of the EBS to provide notification in the EPZ. First, in connection with its ruling on Basis A.1, the Board said: 7 "The following are material facts that we find are not in
) dispute:
... A.1-b. The Energency Broadcast System (EBS) radio broadcasts are relied upon to provide the notification function (i.e., providing information and instructions) to y the public."
L L
Public Service connany of New Mannahire, et al., (Seabrook Station, Units 1 and 2) , LBP-89-9, 29 NRC 271, 278 (1989)
]
(hereinaf ter "LBP-89-9") .
Further on in the same decision the Board stated D Applicants' conclusion that they can complete initial notification in the non-winter months in 14 minutes and 50 seconds does not permit any accommodation for EBS or other instructional messages. See Applicants' Brief at 27. (The Applicants rely on th EBS radio network for providing information and instruction messages. Desmarais Aff: davit, g Attach. D at 3 of 23.)
Id. at 285-286. Attachment D of the Desmarais Affidavit is section 3.2.5 of the SPMC and is attached hereto as Exhibit 1.
It is noteworthy that in both passages cited the Board D
describes thc Applicants as reivina on the EBS and characterizes that as a matprial fact. 14. at 278.
g In its Final Initial Decision the Bloch Board again reiterated its understanding that notification would be provided by means of the EBS. LBP-89-17, supra. First, at g Footnote 4 the Board stated, " emergency messages would be broadcast over the emergency broadcast system (EBS)". Id. at 521. In describing its interpretation of the requirements of g NUREG-0654 the Board said:
"We interpret this (NUREG-0654) to require sequential alerting and notification since people will not know to receive the EBS notification until after they have heard the siren alerting signal." (emphasis added.)
)
Id. at 529. Finally, in making its calculation as to how long it will take the public to receive notification, the Board allocated a relatively short amount of time to the process of
' finding and tuning a radio. As justification for this the i
Board stated:
.) .
1 l
m . - - .-____. _ - _ _ ._ _ _ .. - ..
L We are adding an additional 12 seconds of time because
- there could be a delay in finding and tuning in a radio, j We have no direct evidence-on how much time to allot; however, we assume that the public has had an opportunity to learn tiie EBS orocedura and that 15 seconds- is adequate r
time to find and tune a radio.- We add only 12 seconds L because only those who are actually alerted at the very end l
of the siren sounding are affected and there is a 3 second.
y delay before the alert tone and message will start - a
/ message that begins with a tone that does not contain l essential information.
Id. at 533. (Emphasis added.)
This motion to reopen the record on alert and' notification-
)
is being filed because one of the factual foundations for-the ,
Bloch Board's decision in LBP-89-17 is'no longer t):ue. The j SPMC's primary means for notifying the public in un emergency (the EBS) became unavailable as o# October'20, 1989 when John Bassett, manager of WCCM/WCGY ' - ;Y " ) , repudiated WCGY's letter of agreement with New ,
shire Yankee ("NHY"). As explained in Exhibit 2 and .tachments D-and F, without the cooperation of WCGY, the App ucants can not activate-the EBS -
, for the area containing the Massachusatts EPZ.
).
A similar motion to reopen (Exhibit 2) as well as a motion to add an additional basis (Exhibit 3) (the "EBS motions") were previously filed with the Atomic Safety,and Licensing Board i L
(the " Smith Board") that had jurisdiction over the SPMC. Those-notions were denied in an order dated January 8, 1990 (LBP-90-1). An appeal of that decision is currently pending before this Appeal Board with appellant briefs due to be filed on February 16, 1990. As this Board is aware, the appeal of ,
l l LBP-89-17, supra, is also currently pending. This motion is being filed to preserve procedural rights in connection with
~4-
. . _. , . _ _ . . - a
. _ . _ _ _ . . _ . . _ _ _ _ - . _ _ ~ _ _ _ . . _ _ _ .
l o-l LBP-89-17 should it be determined that the appropriate way to ,
address the absence ~of the-EBS in terms of the vitality of that
' O' .
decision is not through its appeal or the appeal of LBP-90-1 1
but rather through a motion to reopen the record'on alert and
() notification to admit evidence not available until after l LBP-89-17 issued.
JURISDICTION lg since the appeal of LBP-89-17, is currently before this Board, this Board has jurisdiction over this motion. The L
- filing of the notice of appeal on LBP-89-17 removed O jurisdiction over matters connected with that decision from the Bloch Board.
THE CRITERIA TO REOPEN A CLOSED RECORD i
,g The criteria for reopening a closed-record are set forth in 10 CFR 52.734. Under those criteria such a motion must be timely, must address a significant safety or environmental y issue, and must demonstrate that'a materially different result would have been likely had the new evidence been considered a
j initially. Furthermore, a motion to reopen must be accompanied by one or more affidavits pursuant te 10 CFR 52.734 (b) . In.
)
this instance only copies of the original affidavits are accompanying the motion since the originals of the affidavits
) are already before this Board as part of the record on the appeal of.LBP-90-1.
TIMELINESS The Mass AG and two other Intervenors, the Seacoast j Anti-Pollution League and the New England Coalition on Nuclear Pollution ("the Intervenors"), initially brought the withdrawal D-of the Massachusetts EBS and WCGY to the attention of the Smith a
] Board by means of a motion to file a late contention on the SPMC and reopen the record on October 30,-1989, within ten days "
of the withdrawal of WCGY. That motion was accompanied by the 3 affidavit of Royce Sawyer, the communications / Warning Officer-of the Massachusetts Civil Defense Agency. After the Mass AG learned that the Intervenors would not be able to sponsor Mr.
3 Sawyer as an expert witness as had been represented in the #
motion of October 30, 1989, the Intervenors withdrew the ,
October 30th motion on November-8, 1989. One day after withdrawing that motion, the Intervenors filed a virtually- ;
- identical motion. (Exhibit 2.) That motion was accompanied by the affidavit of Robert Boulay, the Director of the Massachusetts Civil Defense Agency and Mr. Sawyer's superior. '
)
L See pages 3-7 of Exhibit 2.
Subsequently, when the Intervenors obtained the affidavit of another expert, A. Anthony Kelsey, they filed an additional motion on November 22, 1989. (Exhibit 3.) That additional motion was timely for the reasons set forth at pages 4-6 of i
j Exhibit 3.
In response to both motions the Applicants-took the position that they were untimely'because the SPMC never relied' h upon the the Massachusetts EBS as the primary means of providing notification, and the Intervenors had been on notice of that fact for ever a year. Egg pages 1-9 of Exhibit 4'and i
pages 5-9 of Exhibit 5.
p The Applicants were successful in their opposition to the motions and the Smith Board denied the motions in an order' L
I dated January 8, 1990, LBP-90-1, that was served upon the Mass AG on January 9, 1990. On January 17, 1990 the Intervanors filed a notice of appeal of that decision lodging appellate
! jurisdiction over the Smith Board's decision with this Board, l
Prior to this Appeal Board having plenary jurisdiction'over both LBP-89-17 and the appeal of LBP-90-1, any. motion to
- - . reopen the alert and notification proceeding based on the same grounds as argued in support of reopening the record on the SPMC would have been inappropriate for two reasons. First, had the Mass AG filed a motion to reopen the alert and notification proceeding with this Appeal Board on essentially the same i
grounds as were being argued to the Smith Board that motion would have been opposed on the grounds that to have two separate panels (one licensing board and one appeal board) considering the same issues invites the possibility of inconsistent findings on the issues. For example, the Smith Board found the EBS motions-to be untimely. LBP-90-1, slip op.
j at 14. It is certainly conceivable that another panel could have come to a different conclusion on the matter. (Indeed, on appeal of LBP-90-1 the Mass AG will argue that the Smith Board erred in this regard.)
Second, the Mass AG believed the Intervenors had met their l burden (in their EBS motions) for reopening the record on the l'
SPMC. Had the Smith Board granted those motions, the EBS issue
! would have been aired and had deficiencies in public notification procedures in the SPMC been established they would
() i have had to have been corrected before licensing and operation. These corrective steps, in turn, would have mooted l()
the bases on which the Mass AG is now moving to reopen the alert and notification proceeding. In short, a hearing before l
the Smith Board would have mooted the need for any reopened -
()
hearing before the Bioch Board. The Mass AG only learned on January 8, 1990 that the Smith Board'had denied his motions for such a hearing. In these circumstances, the Mass AG is acting
()
in a timely fashion by filing a motion to reopen the alert and.
notification proceeding within 23 days of learning of that [
j) denial.
Even if this Board were to find this motion to be untimely, '
the issue presented by the lack of an adequate means to provide g timely public notification is sufficiently grave that this-Board should consider the matter in its own discretion. ,
A SIGNIFICANT SAFETY ISSUE IS PRESENTED O.
. Pages 14-18-of Exhibit 2 and pages 11-15 of Exhibit 3.
l address why a significant safety issue is presented by the withdrawal of the Massachusetts EBS and WCGY. Those reasons
.g. are adopted and incorporated here by reference. Those. reasons are particularly compelling when considered in-connection with
. Basis A.5 and the Bloch Board's discussion of the factors to be o considered under that basis.
The Bloch Board held that the relevant regulations and regulatory guidance call for both alerting and notification to cur within the 15 minute design objective. LBP-89-17, supra O
at 527-529. The Bloch Board found that while the use of the i words " essentially complete" and "about" indicates some ;
f
- , . - . . - , r.- ve , . _ , ,
Y !
flexibility in interpretation of the regulations, the FEMA-guidance in NUREG-0654, Appendix 3, specifies: "The initial -i notification system will assure direct coverage of essentially {
100% of the population within 5 miles of the plant." (emphasis The withdrawal of WCGY and the EBS directly undermines
) added.)
any assurance that 100% of the population within 5 miles of the ;
plant will be notified in fifteen minutes.
First, without the participation of WCGY there is no hardware in place to assure activation of the EBS within
! fifteen minutes. There is no~ dedicated phone line or other i direct communication link to assure.that WCGY--can be contacted and provided with a message. The affidavits of Robert Boulay -
l
! and John Bassett attest to the facts that the Massachusetts
) Civil Defense Agency has no direct link with WCGY and that-the phones lines at WCGY are at times all busy. Exhibit 2, Attachments D and F. Furthermore, the affidavit of~ Robert
) Boulay indicates that even if the entire statewide EBS was-activated through WROR (the statewide primary EBS station)-
I there is no assurance that notification would reach'the
- population of the Massachusetts EPZ within 15 minutes.
The SPMC' contemplates the use of pre-recorded emergency messages being present at.the activating EBS station as a
)
mechanism to speed the notification process. See page 7 of SPMC Implementing Procedure 2.13. Under the SPMC neither the. l Massachusetts Civil Defense Agency, nor WROR nor WCGY have been provided.with copies of the pre-recorded emergency information messages. As the Bloch Board observed, the SPMC messages require a considerable amount of time to read. LBP-89-9, at l
} i 286. Before the Massachusetts Civil Defense Agency could put
]
out an SPMC emergency message on the statewide EBS, it would #
have to receive and record the message, and then transmit that message to WROR. The Bloch Board's own estimation of the time 3
that it takes to convey one such message is 2 minutes'and.38 seconds.- LBP-89-17, supra at 532. Without adding in additional necessary steps such as rewinding the message after it is received from NHY, simply the receipt of the message and i j
retransmission would add roughly 5 minutes to the notification process. In addition to that increase of time, it would also
, take more time for WROR to transmit the messages to the
" downstream" EBS stations. The only available estimate of time-for that process is found in the Massachusetts EBS Operational 3 Plan attached to Robert Boulay's affidavit. Exhibit 2, Attachment P. According to the Operational Plan " downstream" l
l-transmittal to local EBS stations tekes approximately 8 h minutes. Page 2 of the Operational Plan. Central to the lack of assurance of timely notification by the statewide.EBS is the ;
fact that the mechanism has never been exercised or tested for i l
) the Massachusetts EPZ.
The second factor that is affected by the withdrawal of WCGY and the EBS is the amount of time that it will take to
)
find a radio station carrying an SPMC emergency message.- As is explained at page 15 of Exhibit 2, the way in which the EBS operates ensures that-a listener trying to locate'an EBS' I
station will find one fairly promptly. That same mechanism is not present when only one AM (WHAV) and one FM (WLYT) station '
are carrying the emergency messages.
q
) i The third factor that must be' considered in light of WCGY's f
withdrawal is how many people will actually hear _ messages i transmitted solely on WHAV/WLYT. The affidavit of A. Anthony i I
i Kelsey, Attachment E of Exhibit 3, makes clear that a tiny fraction of the population are likely to hear such an amargency message when they first turn on their radios because so few people listen to those stations. One is then left to speculate ;
about how long it will take a listener to find the right channel.
In Public Service Comnany of New Hamnshire. et al.,
1 (Seabrook Station, Units 1 and 2) , ALAB-883, 27.NRC 43, it was l stated that compliance with the regulations designed to_ ensure The
( prompt notification is safety significant. Id at 50.
compliance that the Bloch Board found in LBP-89-17 is directly l undercut by the withdrawal of WCGY and the. Massachusetts EBS.
h A MATERIALLY DIFFERENT~ RESULT WOULD'HAVE BEEN LIKELY l
In finding that the utility's alert and notification system
[
is adequate, the Bloch Board relied on the SPMC's use of the EBS. This is evidenced in three ways. First, in LBP-89-9 the
)
Bloch Board characterized the utility's reliance on the EBS to make notification as a " material" fact not in dispute. (
LBP-89-9, supra at 278. The Bloch Board's own characterization ~
as to the significance of this fact should obviously be given i deference in evaluating whether that fact played a principal role in its decision making.
Second, in making its finding that prompt notification was I \
assured the Bloch Board was clearly relying on the fact that the emergency messages would be carried on several stations. I I
The Bloch Board referred to the messages as being carried."on the EBS radio network." (emphasis added.) LBP-89-9, suora at l 286. Obviously, the Board contemplated that the emergency.
messages would be transmitted on more than just one AM~and'one I
- p. FM station.
Finally, in making its calculation as to how long it would take to complete notification.the Board allocated a very small amount of time (15 seconds) to find and tune a radio to the ,
l appropriate station. LBP-89-17, ggpr.g at 533'. Aa underlying assumption of the Soard was the cooperation of the EBS to ensure that the emergency messages would be on the air to be ;
heard by the listener as soon as a radio could be tuned. As i explained above that assumption is undermined by the lack of a .
h proven means to get a message on the EBS within the appropriate i time period. The finding of the Bloch Board alsotassumes the i appropriate station can be found very quickly by a listener.
1 j That assumption is also unlikely if there are only two stations carrying the messages. .
In order to find that the absence of the EBS Network would not have materially affected the. result reached by the Bloch Board, one would have to postulate that the Board did not know ,
f how the EBS works. -That is extremely unlikely given that:the l I
Board assumed that the public would learn the EBS procedure.
)
LBP-89-17, 1.d. at 533. Given.the several' references that the Board makes to EBS, and the EBS Network, it must be assumed 1
that the Board was not ignrrant of the way the EBS works. The l
l
) I Bloch Board would have in all likelihood reached a materially different finding'in connection with Basis A.5 had the Board
~
y known of the withdrawal of the EBS.
CONCLUSION -
For the reasons provided above, the motion to reopen
}.
standard has been met in this instance, and the motion should i be granted. .;
Respectfully submitted, COMMONWEALTH OF MASSACHUSETTS >
JAMES M. SHANNON ATTORNEY GENERAL
)
daa A Cm Leslie Greer Assistant Attorney-General
} Nuclear Safety Unit ,
Department of-the Attorney General -l One Ashburton Place Boston, MA 02108-1698
. (617)^' 727-2200 i 1
) .
February 1, 1990 l DATED:
1796n 1-
) I 1
L Y
'I' f
S Amenoment $ i 1
3.2.5 kublic Notification
)
i-Upon the determination that a Site Area Emergency or General Emergency is in progress, the NHY Offsite Response Organization J
will-implement procecures to provide a recommendation to officials L of the Commonwealth of Massachusetts that notification anc clear instructions (including periodic status updates) should be given to the general public. The NHY.0ffsite Response Organization maintains the capacility to activate any of the available public notification' means when authorized by the Commonwealth of Massachusetts as described below and detailed in Implementing Procedure (IP) 2.13, Public' Alert and Notification System Including EBS Activation, IP 2.15, Airborne Alert Activation and IP 2.16, Vehicular Alert and Notification System.
l- High-powered sirens are the primary _means of providing puolic alerting to the resident and transient population within the Plume ;
Exposure EPZ within the required 15-minute time criteria. The stren system is comprised of fixed sirens installed througnout the '
New Hampshire portion of the' Plume' Exposure EPZ, and the Vehicular Alert and Notification System'(VANS) for the Massachusetts cortion-
.g -of the Plume Exposure EPZ. The VANS is a mobile fixed siren con-cept providing puelic alerting within 15 minutes. .
The VANS is a truck with a notification cargo package consisting of a lifting device and a'Whelen siren. VANS vehicles are located throughout or near the Massachusetts portion of the Plume Exposure i
?
EPZ at the VANS Staging Areas on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (continuous)=Dasis, I
~
with VANS operators. l I
3.2-13 Revision 0 l8 L
. ~. _ .. _ . ..
h Amenoment 5 upon dispatch of the VANS.in an emergency, the vehicles will travel to specific scoustic locations pre-established in order to provide for acceptable coverage of the Flute Exposure EPZ in Massachusetts. .
VANS sirens can be remotely activated--(normal-eethod) from the NHY l
Offsite Response EOC, or manually activated, if required, by VANS operators upon direction.
In the event that a VANS siren failure occurs, additional backup- l VANS vehicles are maintained (continuously) at the Backup VANS l Staging Area to provide independent coverage for specific acoustic-locations.
In addition, an Airborne Alert System consisting of a helicopter l mounted siren system is maintained in a state of readiness, con- I-tinuously, at Seabrook Station. Upon direction, the helicopter may be dispatched to accomplish backup public notifications.
l Table 3.2-3 summarizes the number, sound ratings, end-locations, by municipality, of the sirens in-the Plume Exposure EPZ. Siren locations are illustrated on oops of the Plume. Exposure EPZ found in Appendix A. -k Transients in the Parker River National Wildlife Refuge on Plus Island will be provided supplemental notification through'the U.S.
g Department of the Interior. Notification of.the EPZ waterways, under U.S. Coast Guard jurisdiction, will he carried out by the .
U.S. Coast Guard. Through the State of Nees Hampshire RERP, the U.S. Coast Guard is initially notified at a NOTIF.! CATION'0P UNUSUAL EVENT to allow for preliminary inventory of available l
g l
resources so that, if it becomes necessary, protective actions for l waterways may be instituted. Inland waterways are covered by the i siren system.
I 3.2-14 Revision 0 9
8
i O l 4
4
' Amendment,5 i i
f Through an extensive public education program (Section 3.7 and-Q- 7.5),
the public will-be instructed that, upon hearing the sirens, ,
they should listen to local radio stations for information and -l
! instructional messages broadcast over the EBS radio network.
J g
i To supplement the public alerting functions provided by the siren
-l system, tone-elert radio receivers will be offered to be distri-buted to schools, day care centers, nursing homes, hospitals, medical facilities, campgrounds, businesses with 50 or'more- ~
employees at one location, and other selected facilities, prior to l 1 full. power operation of Seabrook Station.
i l v
_The designated EBS radio station. tests its EBS signal generation-once a week. The weekly test will enable special facilities to- k determine whether their receivers are functioning properly.
l The operations) 4 authority for public notification' rests with the State and Local Emergency Response Directors.. The NHY Offsite 3 !
Response Organization maintains the capability to initiate the public n'otification process.. Ecth'the NHY Offsite Respor.se EOC and the Seabrook Station Control Room are equipped with a siren l activation encoder.
D In cases where the NHY Offsite Response EOC'is manned by the NHY. ,
Offsite Response Director and the Public Notification Coordinator, l i
the following actions will be-taken to make public notifications.
I. ,
l l
l 3.2-15 Revision 0
)
f
. . . _ . .=
[ ,
'O Amenoment 5 9
The NHY Offsite Response Director, upon authorization from offi-cials of the Commonwealth of Massachusetts, as described in Implementing Procedure 2.14,. Emergency Response Assessment, will direct public notif*ications to be made using the'Public Alert and- l- g Notification System, including EBS. . The Public Notification Coordinator will communicate with-the State of New Hampshire and the Commonwealth of Massachusetts to coordinate EBS messages and timing of the Massachusetts siren system-with that of New Hampshire, as feasible. The lead EBS radio station will be pro--
vided with 'the approved ESS message (s) and instructed to commence broadcast. Concurrent with activation of the ESS, the Communica-tion Coordinator will activate the siren system which consists of a Vehicular Alert ano Notification System, using the siren active - g,;
i tion encoder in- the NHY Of fsite Response EOC. Additional backup methods are available for public alerting, including manual acti-vation of VANS sirens, dispatch of Backup VANS vehicles and an
( ,
airborne alert system which consists of a helicopter mounted siren 'l O system.
. I Various supplemental notification methods will also be implemented l by the NHY Offsite Response Organization and suoport'organiza-tions.
i $
The NHY Offsite Response Director will verify the State of l New Hampshire's initial notification to the U.S. Coast Guard and }
the Federal Aviation Administration. The U.S. Coast Guard is I responsible for notification of transients in waters under their gj
, jurisdiction, and the FAA is responsible for notifying and '
restricting air traffic in the area. Transients at the Parker River National Wildlife Refuge en Plum Island will receive supple- l
~
mental notification by the U.S. Department of the Interior. The
-l NHY=0ffsite Response Organization also maintains the capability to notify public and private schools, day care centers, nursing
]j homes, hospitals, medical facilities, and other special facili- t 3.2-16 Revision 0 e
0 a
Amenoment 5 0-- 14es.
In addition,-suppiementai notification of sne near,ng- ; '
impaired population with door-to-door notification by Route Guices will be implemented, as necessary. NHY Offsite Response.
I Organization supplemental notification activities will be coor-Q l dinated by the Special_ Population Coordinator, and the School l
Coordinator as described in Implementing Procedure 1.9, School Coordinator / School Liaisons, Implencnting Procedure 1.10,'Special Population Coordinator /Special-Population Liaisons, Implementing O "" ***""' 2 "**4'i*i " ' '**""*Y )
Support Org'anizations, and Implementing Procedure 2.7, Special !
Population Protective Actions.
O In the event that Seabrook Station declares an immediate Site Area-g r,,ney or g,n.c.) g r,,ney ,3,n ,r e no,,3,n ,,,
sheltering or evacuation, the following &ctions will be taken.
The NHY Offsite Response EOC Contact will direct the dispatch of O
VANS vehicles by VANS operators through communication with each
_l.
VANS' Staging-Area.
A.
The Seabrook Statica Short-Term E4nergency Director'(STED) will O establish contact with officials of the Commonwealth of Massachusetts through the Massachusetts State Police imme-diately, with the recommendation and-request for authorization i
to activate the public alert and notification system.
.O Upon receiving this authorization, the STED will activate the Massachusetts portion of the Public Alert and Notification l
[ i System through communication with and direction to the_NHY l Offsite Response EOC Contact. ,
0 1.
The NHY Offsite Response EOC Contact will contact the i EBS radio station and provide the authentication coce.
l He will explain that there is an immediate Site Area Emergency (or General Emergency) and. instruct the 3.2-17 Revision 0 O- {
_ _ o
O j -
Amendment E radio station operator on the appropriate EBS message to .9 commence broadcast based on direction provided by the Seabrook Station Short Term Emergency Director.
2.
The NHY'Offsite Response E0C Contact will remotely g activate the VANS concurrent with the ESS; activation.
Upon activation at the NNY Offsite Response EOC, the NNY-Offsite Response Director will notify the Seabrook Station g
Emergency Coordinator-(Seabrook Station Short-Term Emergency Director, Sito Emergency Director or_ EOF Coordinator'that the NHY Offsite Response Director is assuming Public Alert and Notification System including EBS activation responsibility..
O Additional information regarding public notification-is pro-
~
vided in Section 3.7 Implementing Procedure 2.1, Notification
{
of Emergency Response. Personnel:and Support Organizations: l Implementing Procedure:2.12 Public Information - News O Releases and Rumor Controls Implementing-Procedure 2.13, Public Alert and Notification System including E8S Activation:
Implementing Procedure 2.14. Emergency Response Assessment; Implementing Procedure 2.15, Airborne Alert Activation Implementing Procedure 2.16, Vehicular Alert and Notification System in addition to the Seabrook Station Radiological Emergency Plan.
O O
3.2-18 Revision 0
.8 ei i '
TABLE 3.2-1 Amendment 5 MOSILI7ATION SCHENE PERSONS / GROUPS / ORGANIZATIONS NOTIFIED - NOTIFICATION OF UNUSUAL EVENT Emergency Responsible Class Notifier NHY Offsite Response Organization Personnel Other Organizations Notification of. NHY Offsite NHY Offsite Response Director unusual Event Response EOC Contact Assistant Offsite Response Directors (NHY Offsite Emergency Preparedness Advisor j Response Organization Radiological Health Advisor Pager. System) Pub 1ic Notification Coordinator -
Pub 1ic Information Advisor Nassachusetts State Liaisons Local EOC Liaison Coordinator i Communication Coordinator -
Reception Center Coordinator l Evacuation Support Coordinator ,
Support Services Coordinator
' Technical Advisor ,
Accident Assessment Coordinator Exposure Control Coordinator '
Monitoring /Decontanination Leaders Public Information Coordinator Assistant Reception Center Coordinator !
NAS Communicator Staging Area Leader . l Special Population Coordinator School Coordinator Bus Company Liaison Evacuation Support Dispatchers NHY Offsite Response VANS Operators .I EOC Contact (VANS Alace System)
Seabrook Station Backup VANS Operators !
Security Helicopter Pilot
^
Note: NHY Offsite Response Organization personnel will remain on stand-by status. i 1 of 9 Revision 0 i 'l
_ ._ ._. , ~- _ _
TABLE 3.2-1 Amendment 5' (continued)
PERSONS / GROUPS / ORGANIZATIONS NOTIFIED - ALERT Emergency Responsible Class Notifier NHY Offsite Respose Organization Personnel Other Organizations Alert NHY Offsite- *NHY Offsite Response Director -
Response EOC Contact
- Assistant Offsite ; ,~..x Directors (MNY Offsite
- Emergency Preparedness Advisor Response Organization
- Radiological Health Advisor Pager Systesj *Public Notification Coordinator
- Public Information Advisor
- Massachusetts State Liaisons
- Local EOC Liaison Coordinator
- Communication Coordinator . l ~.
- Reception Center Coordinator
- Evacuation Support Coordinator .
- Support Services Coordinator
- Technical Advisor
- Accident Assessment Coordinator
- Exposure Control coordinator
- Monitoring / Decontamination Leaders
- Public Information Coordinator
- Assistant Reception Center Coordinator
- NAS Communicator
- Staging Area Leader
- Special Population Coordinator.
- School Coordinator
- Sus Company Liaison
- Evacuation Support Dispatchers NHY Offsite Response VANS Operators
'EOC Contact (VANS Alarm System)
Seabrook Station Backup VANS Operators Security Helicopter Pilot
~
Note: NHY Offsite Response Organization personnel marked with an asterisk (*) report to their preassigne<f duty stations when notified. All other personnel remain on stand-by status.
2 of 9 Revisiewi o s
- ~
.___c__.m =...==. -
A8tE 3.2-1 (continued) "
t Emergency Responsible PERSONS / GROUPS / ORGANIZATIONS NOTIFIED - ALERT Class Notifler NHY Of fsite Response Organizetion Personnel Other Organizations Alert (cont.)
9#1Y Offsite *rield Team Dispatcher
( Response EOC Contact .Public Service of New Hampshire i
!
- Dose Assessment Technician Utility Dispatcher (METS)/ Utility *Public Information Staff l Dispatchers
- Media Relations / Rumor Control Liaison Massachusetts Electric Company Utility Dispatcher !
- Media Relations / Rumor Control Supervisor
- Rumor Control. Assistants Yankee Atomic Electric Company Utility Dispatcher
- Media Relations Assistants ,
- Public Information Administrative Staff !
- Media Center Administrative Staff
- Joint Telephone Information Center Administrative Staff j
- Local EOC Liaisons
- Telephone Operator
- Massachusetts Governmental Interface -
Communicators
- Telephone Technician
- Radio Repair Technician
- Radio Operators
- Transfer Point Dispatchers
'*Special vehicle Dispatchers
- Special Population Liaisons ,
~
- School Liaisons
- Bus Dispatchers
- Field Monitoring Teams
- Trailer Drivers
- Dosimetry Recordkeepers I
- Administrative Staff
- Staging Area Administrative Staff
- Security 'I
- Staging Area Security Reception Center Leaders
. Reception Center Staff EWF Monitoring / Decontamination Personnel Reception Center Monitoring / Decontamination-
- Personnel Note:
NHY Offsite Response Organization personnel marked with an asterisk (*) report to their preassigned duty stations when notified. All other personnel remain on stand-by status.
l 3 of 9 i Revision 0
_ _ . . . _ . . . . , _ _ -. . _- - . , . , , , - - ..:-.,~,, ,_ . . . ~ , ~ . .- ,_ . . . - , . . , . . - - - . . . , . . .
TA8tE 3.2-1 Amendment 3 (continued)
PERSONS / GROUPS / ORGANIZATIONS NDTIFIED - ALERT Emergency Responsible Class Notifier NHY Offsite Response Greanization Personnel Other Oreanizations Alert (cont.) NHY Offsite Response Traffic Guides EOC Contact (NETS)/ Route Guides Utility Dispatchers Sample Collection Teams l
NHY Offsite Response + Amesbury Dispatcher EDC Contoct -
+ Nerrteac Dispatcher
+ Newbury Dispatcher
+ Newburyport Dispatcher
+ Salisbury Dispatcher
+ West Newbury Dispatcher U.S. Department of the Interior' Fish and Wildlife Services at l Parker River Notional Wild 11fe Refuge on Plus Island Pub 1ic Notiffeetion X EBS Nadio Statson Coordinator Staging Area Leader X Snow Removal Companies School Liaisons
.X Private and Public Schools Special Population X Nursing Homes Liaisons X Day Care Centers X Special Facilities X Nospitals Notes: 1. NHY Offsite % g x Organization personnel marked with an asterisk (*) report to their preassigned duty sta-tions when notified. All other personnel remain on stand-by status.
- 2. + Local Notification / Verification
- 3. X Notifications will be made upon arrival'at emergency response facilities.
4 of 9 Revision 9 O __
- . - . *I * - . ..
- - ~~
~ ' ' ' ' ~ ~
TABLE 3.2-1 (continued) Amendment 5 PERSONS / GROUPS / ORGANIZATIONS NOTIFIED - SITE AREA ENERGENCY AND GENERAL EN Emergency Responsible
_ Class' Notifier f#fY Ofisite Response Organization Personnel Other_Organi_zations Alert (cont.) - Special Population Coor- '
dinator X Ambulance Companies .
X Host Hospitals, Host Nursing Homes X MS-1 Hospitals Bus Company Liaison .,
X Bus Companies Reception Center Coordinator X Reception Centers, Congregate X Care Centers X American Red Cross Evacuation Support Coordinator X Helicopter Company
~
Transfer Point Dispatcher X Road Crew Yard. l Site Area Emer- NHY Offsite- .*MHY 0ffsite Response Director gency and Response EOC Contact
- Assistant offsite Response Directors General Emergency or NAS Communi-
- Emergency Preparedness Advisor ]
cator (NHY Offsite .
- Radiological Health Advisor '
Response Organiratloei *PubIic Notification Coordinator Pager System)'
- Pub 1ic Infornation Advisor
.
- Massachusetts State Liaisons
'
- Local EOC Liaison Coordinator
- Communication Coordinator
- Reception Center Coordinator l
- Evacuatton Support Coordinator
- Support ~ Services Coordinator
- Tecimical Advisor Notes: -1.
NHY Offsite Response Organization personnel marked with an asterisk (*) report to their preassigned duty sta-
' tions when notified. All other personnel remain on stand-by status.
- 2. X Notifications will be made upon arrival at emergency response facilities.
5 of 9, Revision o 1
p m. . -.-~,i ,< ~ ~
v . . <cg g.. y ,
,v. -.
%w.. ,. _. _m_ _ _ _ _ _ _ ___________m.., _ . _ . . _ . , , . ,
TABLE 3.2-1 Amendment 5 (continued)
PERSONS / GROUPS / ORGANIZATIONS NOTIFIED - SITE AREA EMERGENCY AND GEleERAL EMERGENCY-Emergency Responsible Class Notifler NHY Offsite Response Organiration Personne1 Other Cius irations Site Area NHY Offsite
- Accident-Assessment Coordinator Emergency and Response EOC Contact
- Exposure. Control Coordinator General Emergency or NAS Communicator
- Monitoring / Decontamination Leaders (cont.) (NHY Offsite Response *Public Information Coordinator Organization Pager
- Assistant Reception Center coordinator System) *NAS Communicator
- Staging Area Leader
- Special Population Coordinator-
- School Coordinator
- Bus Ceepeny Llaison
- Evacuation Support Dispatchers
- NHY Offsite Response VA80S Operators EOC Contact (VA80S Alarm System) ~
Seabrook Station Backup VANS Operators Security Helicopter Pilot NHY Offsite Response
- Field Team Dispatcher Public Service of New Hampshire EOC Contact or NAS. *00se Assessment Technician Utility Dispatchers
~
Communicator (METS)/ *Public Information Staff Masachusetts Electric Company.
Utility Dispatchers
- Media' Relations / Rumor Control Liaison ~ Utility Dispatchers
,
- Media Relations / Rumor Control Supervisor' Yankee Atomic Electric Company
- Rumor Control Assistants Utility Dispatchers
- Media Relations Assistants
- Public Information Administrative Staff
- Media Center Administrative Staff
- Joint Telephone.Infornation Center Administrative Staff
- Local EOC Liaisons
- Telephone Operator
- Massachusetts Governmental-Interface.
Communicators-
- Telephone Technician Note: NHV Offsite Response Organization personnel marked with an asterisk (*) report to their preassigned duty stations
~
when notified. A11'other personnel remain on stand-by status.
, 6 of 9 Revision 0 O __ _? - - -
- - ~~ ^ ~ ~ ^ ~~~
s TA8tE 3.2-1 (continued)
PER_S_0NS/ GROUPS / ORGANIZATIONS N0ilFIED - SITE AREA ENERGENCY AND Emergency Responsible Class No t_ i f ier_ _
NHY Offsite Response Organization Personnel Other Organizations Site Area Emer- NHY Offsite Response
- Radio Repair Technician gency and General EOC Contact or NAS
- Radio Operators Emergency (cont.) Communicator (METS)/
- Transfer Point Dispatchers l
-Utility Dispatchers *Special Vehicle Dispatchers
- Special Population Liaisons
- School Liaisons
- Bus Dispatchers
- Field Monitoring Teams
- Trailer Dsivers
- Dosimetry Recordkeepers -
L
- Administrative Staff
- Staging Area Administrative Staff
- Security
- Staging Area Security
- Reception Center Leaders
- Reception Center Staff
- EWF Monitoring / Decontamination Personnel.
- Reception Center Monitoirng/ Decontamination Personnel
- 1raffic Guides
- Route Guides
'* Sample Collection Teams :
NHY Offsite Response
- EOC Contact.or NAS Amesbury Dispatcher ,
Communicator
+ Merrimac Dispatcher
+ Newbury Dispatcher
+ Newburyport Dispatcher i + Salisbury Dispatcher i
+ West Newtusry Dispatcher Notes: 1.
- NHY Of fsite Response Organization personnel marked with an asterisk (*) report to their preassigned duty sta-tions when notified. All other personnel remain on stand-by status.
- 2. +
1.oca l Not i f icat ion /Ver i f icat ion 7 of g
. Rev i*;itwo O
....,m. .s, -~~ ~ -m .- + .r - -
- w. sw a ~- ~~r s ~m-- ~e . . ~ .-- , w .e u s- . , _ _ . . w s_n
l TABLE 3.2-1 Amendment 3-(continued)
PERSONS / GROUPS / ORGANIZATIONS NOTIFIED - SITE AREA ENERGENCY KfD GENERAL ENERGENCY Emergency Responsible Class. -Notifier _ NHY Offsite Response Og anization Personnel Other Organizations NHY Offsite Response U.S. Department of the Interior EOC Contact or NAS Fish and Wildlife Services at Communicator Parker River National Wildlife Refuge on Plum Island Site Area Emer- Public Notification X EBS Radio Station i
{
gency and General Coordinator Emergency (cont.)
Accident Assessment X Yankee Atomic Electric Company Coordinator _
Assistant Offsite S Yankee Atomic Electric Company Response Director, Support tlaison l
Staging Area Leader X Snow Removal Companies School Liaisons ++ Private and Public Schools Special Population ++ Nursing Homes Liaisons ++ Day Care Centers
++ Special Facilities
++ Hospitals Special Population Route Guides X Hearing-Impaired Individuals Notes: 1. NHY Offsite Response Organization personnel marked with an asterisk (*) report to their preassigned duty sta-tions when notified. All other personnel remain on stand-by status.
- 2. X Notifications will be made upon arrival at emergency response facilities.
- 3. S Notification will be made several hours subsequent to activation of'IfHY Offsite Response Organization to ;
request manpower support through the Yankee Nutual Assistance Plan.
- 4. ++ This denotes facilities at which tone-alert radios provide initial notification at Site Area Emergency and General Emergency. Add i t iona l con t ac t s w i l l be made t o con f irm no t i f ica t ion.
8 of 9 Revision 0 Ol #_ # - -
8 -- =
O' - - -- - - -
l.
1 TABLE 3.2-1 (continued) Amendment's i
PERSONS / GROUPS / ORGANIZATIONS NOTIFIED - SITE AREA EMERGENCY AND GENER l_ Emergency Responsible s
,, Class. Notifier NHY Offsite Response Organization Personnel Other Organizations Site Area Emer- Special Population gency and General Coordinator X Ambulance Companies Emergency (cont.) X MS-1 Hospitals X Host Hospitals X Host Nursing Homes i Bus Company L iaison X Bus Companies Reception Center Coordinator X Reception Centers, Congregate l Care Centers X American Red Cross t Evacuation Support Coordinator X Helicopter Company Transfer Point Dispatcher X Road Crew Yards l Bus company. Managers
- Bus Drivers Ambulance Company Managers
- Ambulance Drivers Special Vehicle Drivers Road Crew Managers
- Road Crews I
~
Notes: 1.
NHY Offsite Response Organization personnel marked with an asterisk (*) report to their preassigned duty sta-tions when notified. All other personnel remain on stand-by status.
- 2. X Notifications will be made upon arrival at emergency response facilities.
9 of 9 nevision n i
- _ _ . . - ,- ,~, . - -
.. - . - , , . , . - - - . .. a .. ,
e 2
t n
en e e
m A y l c r
an ege nr 0 O O O O O O O ee Gm .
o E d n
u o
r r
y a ac e y
en r e i s e Ag e e r 0 O O O O O O O s a
_ t b r
Sm i
u E o h-4 Y 2 C
N E
a e G t r n R
E S l e 0 O O O O d o
N E E I A e f
T f 2 R I a 2
- O L t s
F I l C at s 3 S A un i E
L B
A L
E V
E F
E S
se uv 0 nE t
i P
n o e_
T L N O U t N P c O S a I E t T R A
n V
o O I
y C
T C f i
C A l.i O c -
E a t i
n e F o s P n e t o
s c n
o t
a n
)
F W
p s e p o E e C ( R s C C y e O O it l t e
R E E ic a
i s
y e F 2 f s O F f c
n m E r s r e s O _
p n + r e r e
e g
r R s
e i t
o a Fr a r e
l i
a r
kr o
Wy t
n e
Y H o e e t
S e e t T
g C N t
t i r n e n c n :
se m i s k s A i n o f o f f g C r o e it eh E f O
o r O n ia i t g r
p e
t oT t
Y ig d n e c Y a e H a e o m e N _
H S N t
S M M E R N
e_
e_
Amenoment 5 TABLE 3.2-3
SUMMARY
OF SIREN LOCATIONS
. Numbers of Sirens Community g Massachusetts Amesbury >l Merrimac (Details of acoustic locations are {
Nowoury provided within FEMA REP-10 report) !
i Newburyport
- Salisbury West NewDury Other .
MA Totals
- T - - 4 O' 16 16 I
New HamD$ hire ~
Brentwood 5 East Kingston 4 5 Exeter 8 Greenland '2 %
3 3 HamDton g 4 Hampton Falls )
3 10 3
Kensington 3 4
3 Kingston , 6-New Castle 3 4
Newfields 2 1
Newton 5 2 i North Hampton -6 $
Portsmouth 8 0
Rye 7 8
Seabrook 7 7- ;
3 South Hampton 3 8 ;
3 Stratham 4 d
- 2
- J NH Totals 82 12 .._
9,
~
~ _
GRAND TOTALS 333 3g 16 110
NOTE:
^
.l
- Mobile sirens will be deployed for public alerting. '
I Of I Revision 0
O c: :::::::: : : :: :::: ,
o n: :: o o
' o as o o e 5 e o o s e o e o e .e
- o o g >
1 o ng- wgs . a. g g 9 o ,y 35g I "
0 e v
ig $5 If
- r
~ER g g. "gr I r
$w,$lQ - l
- - - f 8 - .E : 8 _ . .-_. E $
- .~....
av i
- g ,
e
~ '
E! ::: i :
- f. t.f++l_. .
t) ! : e I rl I I o tw i i e g e
~
- ,3 gg ;:........... a g l I3
- ..............;.- [ !a n a
=l e
- :: o e = rE a
- g s EB v ..
5 g r a . 1 -
e
-+
- I e 3s,g g
w 5 -
e sI.-
l ag -
- w. , . . _ ,
-- -- 1ea 4 - I l vg ! ese e I
___- ,,-, , -+ v ---+
W 3 >3 3 , ,.
l e e I a es ?> c
>c l E e I ! e I! !
3
- >c
- x e.
x l l e 4
I,
! l I sl!
t;iIl
= I
[I a
. : ::: * ... i t ,s. . - -
f i =m l
a : :
________.s ig,E,==-
e - l - ,
- a , +----___., i -[ I r, r m = y gg
- g. ;r y e l e IIllgi
- e I i e e*BE e
4 a. l i -.
e
~ "Halli gggi y r l ,
e f----- g2 jll5g IE l
S' l L.._ i t B* 8 l
l 11 E I -*
h
- Illill ajrriiajgi,
-m erm lI=uisill W
mg
'...........__ e !i!gglgg,g.*
a _
- .am,IE.,I-ti. l l .8 . r .E, E, f S 5 .L u o ,L a e o i l
u o oa u o l
.. u ou a e o n
-- u o o a e o l 9
o'
'O !
l
. 1 Amenoment 5 F10uRE 3.2-2 l[) i STATE NOT!PICATION FACT SHEET '
1 BLOCK 1. "TH!$ IS:
(NAME)
(TITLE) t O *** '" 8I "' ' "' "'" **""'"*"" i i TIME DECLARED TIME TERMINATED _
)' SLOCA 2.
WE MAYE DECLARED A(N):
- O O UNUSUAL.EvtNT O SITE AREA EMERGENCY ALERT GENERAL EMERGENCY SLOCK 3.
WE RECOMMEND THE FOLLOWING:
.Q t U NO PROTECTIVE ACTIONS RECOMMENDED (G0 *0 BLOCK 4).
NEW HAMPSHIRE SHELTER EVACUATE MASSACHUSETTS SHELTER EVACUATE
( ) (
) SEABROOK ( ) (
( ) (
) AMESBURY
) HAMPTON FALLS ( ) ( )
( ) ( SALISBURY
) HAMPTON ( ) ( t
( ) ( ) MERRIMAC
) KENSINGTON ( ) ( ) [
( ) ( y,WSURY
) SOUTH MAMPTON ( ) ( )
( ) ( ef
) NORTH HANPTON (
( ) ( )
) ( ) N.WSURYPORT NEWBURY lO ( > (
BRENT @ D 1
) East KINGSTON
( ) ( ) EXETER sEACHES (setween May is eno September is> .;
-( ) ( ) KINGSTON
( ) EVACUATE -
( _,1 NEWFIELUS
( ) ( ) Seabrook Secch
( ) NEWTON ( ) Hampton Beach l
( ) ( ) STRATHAM Q ( ) ( ) OREENLAND l- ( ) ( ) NEW CASTLE M '
L (
( ) ( ) PORTSMOUTH (
) Parker River Nationet Wildlife Refuge
( ) ( ) RYE ) Plum Island teach
( ) Salisbury Secch .
SLOCK 4. THE EMERGENCY O HAS BEEN TERMINATED I IS CONTINUING BLOCK 6.
A RELEASE OF RADI0 ACTIVITY l lNAS NOT OCCURRED R HAS BEEN TERMINATED C IS CONTINUING 1 of 2 Revision 0
.O j
l 0
l I
. Amenoment 3 FIGURE 3.2 2 %
STATE NOTIFICATION FACT SHEET (continued) l BLOCK 6. AUTHORIZED BY: _
e i STED/ SED /RM OATE/ TIME !
i BLOCK 7.
PLEASE ACKNOWLEDGE RECE!PT OF TH18 MESSAGE NITH YOUR NAME.
NEW HAMPSHIRE (NAME OF DISPATCHER) (TIME) O i
MASSACHUSETTS (NAME OF DISPATCHER) (TIME)
G-(NAME OF O!SPATCHER) 9 VERIFY THAT PARTY TO READ SACK ALL THEORGAN!ZATIONS INFORMATION. HAVE RECE!VED CORRECT INFORMA t
Oi l
t 9:
i 2 of 2 Revision 0 Ol i
- .. . . . . ~ . - -. ______________._____l
i O ,
j Amenement 2 !
FIGURE 3.2-3 f j POLLOW-UP !NPORMATION FORM ;
O T* "' ***'Id "Y 87'8 'h' ****"* i""***i'" i' k"'""' 0"'Y *** ' ""'
necessary when issuing a termination update.
- 1. Name of Communicator: l l
- 2. Location: Seabrook Station Seabrook New Hemeshire
- 3. Classification Level: [ Unusual Event Alert
_ General Emergency "The Emergency has l
_ __ 7
- _, Site Area Emergency teen Terminated" 4 Declaration Date
- Declaration Time !
.O ter.ination oate Termination Times i
- 5. Srief Description of Event l
Sa. Brief Description of reason (s) for termination ,
i
- Meteorolooiemi Information l 1
Mggge. Lower
! 6. Windspeed sph (C0784) (C0783)
O i 7. Wind Direction FROM (degrees) (C0786) (C0785)
! 8. Stability Class (Circle)
Upper Delta- T -1.74 -1.55 -1.37 -0.46 1.36 3.64 o (C0788) A Is 1 Cl o I e rI o Lower Delta-T A l8 l Cl 0 l E F lG +
(C0747) -1.12 -1.0 -0.89 -0.30 0.88 2.34
- 9. Precipitation [ ] Yes [ ] No ,
} Wadioactive Release Rate (NA if none, or not available)
- 10. Radioactivity ( ) Has ( ) Has not been released
- 11. Noble Gas Release Ratet uCi/sec (RDMS) g 12. Zodine Release Pates uCi/sec
- 13. Particulate Release Rates uCi/sec 1 of 3 Revision 0 0 !
O Amendment 2 ,
F10URE 3.2-3 %
POLLOW-UP INFORMATION FORM (continued) i e
- 14. Time release started:
- 15. Release Terminated ( ) Yes [ ] No ( ) N/A
- 16. Time release terminated: 9
- 17. Estimated total release durations hours.
Offsite Excesure Data g Site Soundary 2 mi. 5 mi. 10 mi.
- 18. Whole-body dose rate (mR/hr) g--
. 19. Thyroid dose rate (mR/hr)
- 20. Whole-body dose (ares)
(Step 817 x 818)
- 21. Thyroid dose (mrom)
(Step 817 x #19)
- 22. Surface Spill Information: Volume liters Concontration: __ uCi/m1 6 Location:
- 23. Surface Contamination: a. Onsite: dps/100cm2 Location: I
- b. Offsite dpe/100cm2 Location:
1 2 of 3 Revision 0 9:
- - . . . .- . - .. - . . - - . . --.-- _.. ~ .. - . - - - ._. -_-_._ _ _ .
'O !
I Amenoment 3
, l i FIGURE 3.2-3 '
O
, POLLOW-UP INFORMATION FORM i (continued) .
4
- 24. Prognosis for Worsening or Termination ,
t i
lO '
t
- 25. Authorized by:
STED/ SED /RM DATE/ TIME
.:O
- 26. Contacts i
~
NEW HAMPSHIRE NAME ORGANIZATION TIME PHONE NO.
.O i MASSACHUSETTS NAME ORGANIZATION TIME PHONE NO.
1 O NHy ORO g j NAME ORGANIZATION TIME PHONE NO.
O .
t O
- O
9 3 of 3 Revision 0 O '
, v , ,- n ,- , e.,.
i I) Qq
,0 UNITED STATES OF AMERICA [
NUCLEAR REGULATORY CoxxISSIoN ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judgest
() Ivan W. Smith, Chairman '
Dr. Richard F. Cole !
Kenneth A. McCollom l
- O
)
In the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL t PUBLIC SEAVICE COMPANY )
OF NEW HAMPSHIRE, EI AL. )
O )
(Seabrook Station, Units 1 and 2) ) November 9, 1989 '
)
C) INTERVENORS' MOTION TO ADMIT A LATE FILED CONTENTION AND REOPEN THE RECORD ON THE SPMC BASED UPON
.THE WITHDRAWAL OF THE MASSACHUSETTS E.B.S. NETWORK AND WCGY !
The Massachusetts Attorney General (" Mass AG"), Seacoast O Anti-Pollution League ("SAPL"), and New England Coalition on Nuclecr Pollution ("NECNP"), (hereinafter "Intervenors") , move this Board to admit for litigation in the above-captioned
- () proceedings the contention filed herewith as Attachment A and i
reopen the record in the proceeding on the Seabrook Plan for i
Massachusetts communities ("SPMC"). This motion is filed '
,.C) pursuant to $189(a) of the Atomic' Energy Act and is founded upon the grounds set forth below. The Intervenors also request that this Board permit them to have a hearing on all issues raised by
,0 this contention and engage in any discovery necessary to prepare
- for such a hearing.
Oj l
j ,
l i
INTRODUCTION 9 The SPMC contemplates the use of the Emergency Broadcast )
l System ("EBS") as the primary means for notifying the public in )
the event of a radiological emergency at Seabrook Station. In a Gi letter dated october 20, 1989 John F. Bassett, manager of WCCM(AM)/WCGY(FM) ("WCGY"), repudiated ~WCGY's prior agreement to j participate with New Hampshire Yankee- ("NHY") in emergency 9 planning and to activate the EBS in the event of a emergency at I Seabrook Station. Without the cooperation of WCGY, the !
i Applicants will not be able to activate the EBS servicing the gj l Seabrook Emergency Planning Zone ("EPZ") in Massachusetts. '
Without the activation of the EBS, the Applicants will not be able to provide notification to the public in the event of an gl emergency in accordance with the SPMC and as required -by applicable law and regulations. TheinabilityofNHYto activate the EBS poses a significant safety issue that warrants gp admission of the attached late-filed contention and reopening the record under the applicable standards.
THE CRITERIA FOR THE ADMISSION OF A LATE-FILED CONTENTION ARE MET The criteria for the admission of' late-filed contentions i are set forth in 10 CFR 52.714 (a) (1) . In ruling on a motion to admit a late-filed contention, a licensing board must balance #
the factors set forth in the above cited provision.
Commonwealth Edison Co. (Braidwood Nuclear Power Station, Unite.
4) i 1
3l L
- l. - -
l0 l .
0 1 and 2), CLI-86-8, 23 NRC 241 (1986); Duke Power Co. (Catawba-Nuclear Station, Units 1 and 2), CLI-83-19, 17 NRC 1041 (1983);
Public Service of New Hamenhire Co. (Seabrook Station, Units 1 g and 2), ALAB 918, NRC (1989). Those factors aret (i) good cause for failure to file on time; the availability of other means by which the (ii) petitioners interest will be. protected; -
- (iii) the extent to which the petitioners participation may reasonably be expected to assist in the development ~
of sound record; (iv) the extent to which the petitxoners interest will'be represented by other partier.;
(v) the extent to which the petitioners participation will broaden the issues or delay the proceeding.
A considered balancing of those five factors clearly !
establishes that the attached contention should be admitted in this proceeding.
TIMELINESS
'S At the time that the contentions on the SPMC were initially required to be filed in this proceeding (April, 1988) WCGY and !
the Massachusetts EBS were cooperating with NHY in emergency D planning.O Both WCGY and EBS had letters of agreement with NHY to provide services to NHY in the event of a radiological j emergency at Seabrook.
(Attachments B and C.) Those letters D
1/ WCGY (FM) and WCCM (AM) are sister stations that are I located at 33 Franklin Street, Lawrence, Massachusetts and are currently owned and managed by Curt Gowdy Broadcasting.
3_
a.
of agreement were incorporated into the SPMC in Appendix C. g.
Under the terms of those letters of agreement, WCGY agreed to j activate the EBS for the Merrimac Valley operational area that includes Massachusettp when requested to do so by NHY. When gi contentions on the SPMC were initially due, a review-or the j SPMC's provision did not reveal any difficulty in activating ,
the EBS as a means of notifying the public. The SPMC at 53.2 !
9; and I.P. 2.13 contained provisions and procedures for activating the EBS. On its face the SPMC contained the documents indicating it had a means to actually activate the- !
0; EBS through the letter of agreement with WCGY contained in !
Appendix C. Not until October 20, 1989 when WCGY withdrew did i the SPMC lose that means of activating the EBS.A/
On October 20, 1989, when WCGY repudiated its letter of *:
agreement with NHY the provisions of the SPMC for notifying the !
public became unworkable. This motion to admit a late-filed 9.
contention and reopen the record is being filed within 15 working days of that repudiation, and as quickly as practicable under the circumstances. Good cause is established for failure O
to file on time because the event that triggered the filing did .
not occur until October 20, 1989.
l
- l 2/ Douglas Rowe's withdrawal of the Massachusetts EBS occurred a few days earlier on October 13, 1989, however, until WCGY's withdrawal, the SPMC still contained a legally enforceable means to activate the EBS through WCGY's letter of agreement. 0:
(See Attachment G) >
t 9:
O
() As soon as the Intervenors knew of WCGY's withdrawal and could put together the appropriate documentation including the affidavits of Douglas Rowe and John Bassett, the Intervenors
() brought the issue to the attention of this Board by' filing a motion identical in title to this one on October 30, 1989.
Accompanying that motion was an unsigned affidavit of Royce
(-) sawyer, the communications / Warning officer for the Massachusetts Civil Defense Agency. Although the affidavit had been reviewed and approved, it was filed without a signature
() because Royce Sawyer was on medical leave from October 23, 1989 until November 6, 1989. A statement of Sawyer's professional qualifications was also unavailable at that time for the same O #*** "**
Royce Sawyer's affidavit was predicated in part :(section 4, page 5) on the affidavit of John Bassett that was signed on i q) October 27, 1989.
With the corrections noted, Royce Sawyer signed the affidavit on November 3, 1989 (Attachment H) and provided the Mass AG with a detailed statement of his g) professional qualifications. On November 6, 1989, Sawyer's first day back at work, that statement of professional !
qualifications was reduced to writing and faxed to sawyer for
() his review and approval. Late on the afternoon of November 7, 1989, the Mass AG became aware for the first time that the Intervenors would be unable to sponsor Sawyer as an expert g witness in this proceeding. In light of that development the 4
C) ~5' 4
I
'( i i
Intervenors withdrew the motion dated october 30, 1989 on et l l November 8, 1989. I l
The Intervenors then promptly undertook to locate another i
expert on the issues raised in the attached contention. on OH November 9, 1989, Robert Boulay, the Director of the i
Massachusetts Civil Defense. Agency, af ter having reviewed the ' :
issues and relevant documents agreed to serve as an expert IN i
witness and signed the attached afffidavit (Attachment D).1E ;
l This motion is being filed on the same day that Mr. Boulay e
provided his opinion. The Intervenors have acted as II expeditiously as possible in putting the issue in the attached -
i contention before the Board. In substance, this motion is identical to the one initially' filed on october 30, 1989 with O the exception of this section on timeliness, changes in the affiant's name and the deletion of three words that have been simply crossed out in this text to highlight the alteration in II the affidavit regarding actions by non-EBS stations during an 4:
19 Apart from section 1 the affidavit of Robert Bculay is _
substantially the same as the corrected affidavit of Royce Sawyer (Attachment H) with certain minor changes that are found 4 at: page 2, lines 20-21; page 4, line 20 and 27; page 5, line :
- 12. . The only change of substance is the addition of one II sentence on page 4, lines 2-5. That one change in substance simply states that non-EBS stations in the Merrimac Valley operational area go off air as a matter of operational practice regardless of the level at which EBS is activated. That one )
change has no impact on the instant motion, since although the reason stated for EBS stations going off- air was originally in I error, the not result is that they do go off air. The reason that non-EBS stations go off air in the Merrimac Valley is of .
no importance to the manner-in which EBS functionally operates.
importance'to the' motion.
It is the functional operation of the EBS that-is of 0
1
___ _- - ~ , _ . _ _ _ _ . . . _ _ .. _ _ __ _ _ - - -
I S) i i
emergency. SJut supra at 15 _ . 2/ ;
d,)
PROTECTION OF THE INTERVENORE' INTEREST ;
i other than litigation of the attached contention there is
(
a no other means to ensure that Seabrook Station operation will '
f
() conform to regulatory requirements and ensure public safety. l The NRC Staff cannot be relied upon to protect the public interest and interests of the Intervanors. Throughout the C) course of this proceeding, the NRC Staff has consistently and '
without exception rubberstamped the actions taken by the j
4
{.
l Applicants. There is no reason to believe.that the NRC Staff !
70 at this point will adopt a more reasoned and impartial L
i position. The only way to ensure that the regulatory l
t requirements cited in the attached contention are met and that 3 public safety is provided for is through the admission and j ,
litigation of the attached contention.
3 i
2/ .The first indication that there might be a problem with the SPMC's notification procedures using the EBS was received by &
the Mass AG's office on October 16, 1989. On that date, Douglas Rowe contacted a paralegal in the Mass AG's office to ,
[) learn the address of the Nuclear Regulatory Commission. He '
indicated that he wanted the NRC's address so that he could -
forward to the NRC a copy of his letter to NNY. Mr. Rowe sent to the Mass AG's office a copy of his letter to NHY, and indicated that WCGY had been informed of his actions. In turn, WCGY was contacted by the Mass AG's office to ascertain what 3 its status was in respect to EBS' repudiation of its letter of '
agreement with NHY. John F. Bassett, manager of WCGY, stated that he knew about Rowe's action, and was. contemplating sending l a similar letter but had not yet done so. In a follow-up -
conversation on October 19, 1989 Mr. Bassett stated that he was still considering sending a similar letter and would provide
) the Mass AG's office with'a copy of the letter.
I
)
l l Oi l -
l l r DEVELOPMENT OF A SOUND RECORD gj 1
The Intervenors will contribute to the development of a f sound record through the litigation of the attached l contention. The contention and basis sufficently identify the gf l issues to be decided. In support of the contention, the ;
Intervenors will offer the testimony of Robert Boulay whose ;
affidavit is attached to this motion as Attachment D. He will ,
testify as to how the Massachusetts EBS operates and why the non- participation of WCGY precludes operation of the EBS in the Massachusetts EPZ. :
0; Notification to the public of the status of an emergency at i Seabrook Station and any protective action recommendations that are made in response to such an emergency is predicated on the operation of the EBS. Section 3.2.5, Public Notification, of the SPMC specifies that that public notification will take place through the EBS. Section 3.2.5 at p. 3.2-13 states:
9-
"The NHY Offsite Response Organization maintains the capability to activate any of the available public notification means when authorized by the Commonwealth of Massachusetts as described below and detailed in
- Implementing Procedure ("IP") 2.13, Public Alert and Notification System Includina Ens Activation; IP 2.15, O!
Airborne Alert Activation, and IP 2.16, Vehicular t l Alert and Notification System." (Emphasis added.) ;
I That same section also provides at 3.2-15 that: "Through an extensive public education program (553.7 and 7.5), the public #I
\
l will be instructed that, upon hearing the sirens, they.should listen to local radio stations for information and 9:
g l !
O
) instructional messages broadcast over the ras radio network.a (Emphasis added.) The plan specifies that the NHY Offsite Response Director will direct public notification by using the public alert and notification system including EBS. The SPMC O
states that the EBS will be activated concurrently with the activation of the siren system, $3.2.5 at 3.2-16, and provides O that through the EBS the public will be informed of the import of the sirens.
Implementing Procedure 2.13 outlines the procedural steps that will be taken to activate the EBS. Section 5.1.5 of IP O
2.13, at p. 5, states that contact with the EBS radio station is to take place on a dedicated ring down circuit. Section 5.1.11 of IP 2.13, at p. 7, directs that activation of the O
public alert and notification system is to take place by contacting the lead EBS station on the dedicated ring down circuit, and advising it of the pre-recorded message that is to O
be broadcast or that an authorized prescripted EBS will be telecopied to it for broadcast. The implementing procedures as well as the plan itself clearly contemplate that under the SPMC O
information is to be disseminated to the public through the EBS. In making its finding of adequacy in respect to the SPMC, FEMA reviewed those provisions of the plan calling for the use 9
of EBS as the primary means for notifying the-public. Those provisions are a predicate to FEMA's finding. FEMA's Review Of The SPMC, App. Exh. 43C, Page 24.
9 i
9 9
. - . - . . - . _ . . - _. -. ~- -- _ _ . - - - - . ..
l O
l -
l l Robert Boulay will testify as to how the EBS network in l
G l
. Massachusetts works and why the lack of participation by WCGY means that the EBS network cannot be activated. As Mr.
Boulay's affidavit makes clear, the EBS network functions in e much the same way as a telephone pyramid. The primary relay EBS station in Massachusetts, WROR in Boston, by transmission of its activating tone, trips the tone alert radios at the EBS gh operational area gateway stations. WCGY is the gateway station in the Merrimac Valley where the Massachusetts EPZ is located.
WCGY picks up the EBS message transmitted by WROR and, through 3:
activation of its activating tone, trips the tone alert radios !
located in the other Merrimac Valley EBS stations. Those j stations in turn pick up the EBS message and transmit it out on gp their own frequencies to the public. The activation of the EBS 9
stations in the Merrimac Valley can be implemented directly through contacting WCGY and having WCGY send out its activating g=.
signal. However, the activation of the EBS cannot take place t
through contacting WLYT, the only other station with whom NHY [
has a letter of-agreement, because WLYT is not a gateway or a g:
lead EBS station. The tone alert radios in the other Merrimac Valley EBS stations are not tuned to receive WLYT's signal; they are only tuned to receive WCGY's signal. gp Mr. Boulay's testimony will show that the import of WCGY's !
non-cooperation is that NHY will not be able to contact and activate the EBS within the 15 minute window required by ef 9.
5
. . . . . _ . . ~ . . _ . , . . . _ . . . _ . , _ _ , , _ _ - . _ _ __
. _ - - . - - . - . .- . -~ - -- --. _ ___ --- _
) ,
() regulation.S/ NUREG 0654, FEMA-Rep-1, Rev. .1, Appendix 3. t The identification of Mr. Boulay as a witness who possesses t
'i l special expertise on the topic of the EBS in Massachusetts and l() the above statement as to what he will testify to clearly !
I establishes that the admission of the contention will j i
contribute to the development of a sound record. The Appeal ;
I()
! Board has holdt i , 't A late petitioner can establish that its '
participation may reasonably be expected to 2
assist in developing a sound record by "(1) ;
1 identify [ing) specifically at least one witness
!O
' it intends to present: and (2) provid[ing) sufficient detail respecting that witness' ;
proposed testimony to permit the Board to reach a !
i reasoned conclusion on the likely worth of that I testimony on one or more of [its) contentions." 4 Washinaten Public Power Sumelv System (WPPSS
'O Nuclear Project No. 3), ALAB-767, 19 NRC 964 l (1984), 985 (1984) quoting Washinaten Public Power Suceiv System at al. (WPPSS Nuclear Project i No. 3), A LAB-7 4 7 , 18 NRC 1167, 1181 (1983). ;
j The Intervenors in this instance have clearly met the test
'O for establishing that their participation will assist in the development of a sound record. That. factor thus weighs heavily
- in favor in the admission of the attached contention.
O A/ An additional factor in WCGY's non-cooperation is that as '
Attachment E indicates, WCGY's activation of the Merrimac Valley EBS would immediately reach approximately 6-times the O listening public in Essex County as opposed to just WLYT i transmitting an informational message. It is contemplated that this result will ultimately be offered as another basis to the attached contention. However, given the haste with which this motion is being filed, there has been insufficient time to obtain an affidavit from an expert on this issue. It is O contemplated that when such an affidavit from an expert is obtained, a motion to amend the basis to the attached contention will be filed. ,
O ~11~
. _ _ . _ . __ _ _ . _ ._ _ ._~ _ __ ._ __ _ . . _ _ . _ . . ._ _ _ _ .
Si l
i I
i THE PETITIONERS' INTEREST REPRESENTED BY EXISTING PARTIES S In this proceeding, no other party has to date raised, or j is known to be raising, the issues set forth in the attached '
contention. $!
AREENCE OF DELAY obviously the admission of the attached contention will broaden the issues to be decided in this proceeding, and may gl delay a final resolution of the proceeding. However, the same 2
would be true with the admission of almost any new contention. k Therefore, what must be considered by this Board in assessing g!
~
this factor is the degree to which the issues before the Board will'be broadened and the degree of the delay that will be occasioned by the admission of the contention. gr In this case the contention that is proposed focuses narrowly on one aspect of the SPMC. It is anticipated that any ,
discovery on the issue can be kept.to a minimum and that any g.
hearings will not be lengthy. Through the prior proceedings that have occurred in this licensing matter, the parties and the Board are already generally familiar with the parameters of g 1
the issue, l
l l While this factor does by its nature' militate somewhat in
\
l favor of the Applicants, the narrowness of the issue raised in gl the contention and minimal amount of delay that is likely to ensue by admission of the contention do not weigh heavily in l
l g;
i O i
. l i ,
g the Applicants' favor. When the slight weight to be accorded [
to this factor is balanced against the other four factors that strongly favor admission of the contention, the not result-is j that n balance the contention should be admitted.
lO Therefore, ;
the Board should allow the motion to admit the late-filed contention.
O * * " " " * ** * * *
[
The criteria that must be met'to reopen a closed record are t i
set forth in 10 CTR $2.734. Those criteria are all met in this instance. The motion is timely for the reasons set forth above. The event that triggered the motion to reopen the record was the letter of October 20, that was sent by WCGY to O
NHY. Prior to the transmission of that letter voiding the '
, letter of agreement that had previously existed between NHY and WCGY, the elements of the SPMC that called for the activation O
f the EBS uld still have been implemented. Even though prior to the issuance of the letter the equipment that NHY ;
undertook to provide to WCGY had not actually been provided, NHY had a contractual commitment to provide that equipment. In return, WCGY had a commitment to activate the EBS upon request by NHY. The voiding of the letter of agreement on October 20, 1989 negated those commitments.
Given the requirement that a motion to reopen the record be accompanied by one or more affidavits setting forth the basis of the motion, this motion is being filed as quickly as is l
O l i
l
i O
p'racticable. Not only was there the necessity of obtaining ,
affidavits as to the factual basis for the motion, i.e., the i 4 i non-participation of WCGY and EBS, but, there was also the necessity of obtaining an affidavit from an expert who could ;
l I opine on the import of that non-cooperation. This motion is 1 being filed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the authorization and i approval of that affidavit. t 9;
THE MOTION ADDRESSES A SIGNIFICANT SAFETY ISSUE 1
Both NUREG 0654, FEMA Rep-1, Rev. 1, Supp. 1 and NUREG !
0654, Rep-1, Rev. I require that means be established to i 0;
i provide early notification and clear instruction to the populace within the EPZ. Under Planning Standard E, ;
Notifications Methods and Procedures, an emergency response 9
, organization has a responsibilty to demonstrate that means exist to notify and provide prompt instructions to the public.
The specifications for providing such prompt notification is 9;
set forth in NUREG 0654, FEMA Rep-1, Rev. 1, Appendix 3. Under the criteria for acceptance in Appendix 3, the minimal acceptable design objectives for an alert _and notification system require the capability of providing both an alert signal and an informational, or instructional, message to the population on an area wide basis throughout the 10-mile EPZ 0;
within 15 minutes. Appendix 3, at 3-3. Under this minimally acceptable criterion for a notification system, NHY must make !
provision not only for alerting the population in the EPt by 91 O
- .- . _ _ -. __._____ ___-__A
O O
means of a siren, or other signal, within 15 minutes, but must O *** **** P' "l'i " ' ' P" Vidi"' "" i"# ""*ti "*1' '
instructional, message to the population within that same time period.
O The withdrawal f WCGY and the Massachusetts EBS pose two separate and distinct significant safety risks under Planning Standard E. First, the withdrawal of WCGY means that the EBS O cann t be activated f r the Merrimac Valley area. As the affidavit of Robert Boulay makes clear, WCGY as the Common Program Control Station (CPCS-1) for the Merrimac Valley is the gateway f r the activati n f the EBS system in that area.
O All other.EBS stations within that operational area are tuned to WCGY's tone alert frequency to trigger their activation and g participation in the EBS. Without WCGY's activation of those stations, they will not pick up the EBS-messages that are designed to carry information to the public in the event of an
, emergency at Seabrook Station. The manner in which the EBS operates ensures that when the EBS is activated, an-individual turning on a radio to find out the significance of the alerting sirens will come fairly shortly to an EBS station. When the EBS is activated, all non-EBS stations ###/t#4g/t#d/t# go off the air. That means in tuning to find out the significance
, of the sirens, an individual will quickly encounter an EBS station carrying the authorized EBS messages.
H
, l l
v.
0;
. i a
While NHY apparently still has an existing contract with 9 j one radio station, WHAV (AM)/WLYT (FM)/ ("WLYT") that station is not a CPCS-1 station that can activate the EBS. While WLYT 7 does participate as a station in the EBS, it cannot activate g 1
any other station in the EBS, or pass on EBS messages to any l but its own immediate listening public. In making its finding i
as to the adequacy of the SPMC, TEMA did not find that a letter gj of agreement with WLYT was enough to satisfy notification r requirements. The SPMC does not call for the activation of ,
WLYT alone, rather it calls for the activation of the EBS. M g In making its finding of adequacy FEMA stated !
The Plan states that the primary system for d!sseminating information to the public is EBS. In event of an emergency, the NHY ORO offsite Response g';
Director will request authority from the Commonwealth l' of Massachusetts to utilize EBS to broadcast' emergency information and instructions to the public. Each instructional message broadcast over EBS will also be released as a news release by the Media Center.
FEMA's Review of the SPMC, App. Exh. 43C, Page 24.
Totally apart from the coverage problem that is posed by the withdrawal of WCGY, the withdrawal also poses a significant O'
y As is indicated in Attachment E. the activation of the EBS through WCGY reaches six times the listening population than that reeched by WLYT and its sister station. The activation of the EBS by WCGY results in twelve radio stations carrying the g~
EBS messagas rather than-simply two. It further results in all other non-EBS stations going off the air, making access to the critical EBS stations more likely. None of that happens when WLYT on its own sends out an information message. Further i more, given the-fact that WLYT's letter of agreement with NHY is premised on its " ongoing committment" to the EBS, it is g1 unclear that that committment-will continue since the EBS no longer recognizes the NHY ORO as a responsible local j organization authorized to request activation of the EBS.
l I
0)
O O safety issue with respect to the ability of NHY to notify any portion of the public within the 15 minute minimum requirement.
One of the reasons that EBS and WCGY apparently O withdrew fr m participation with NHY was because NHY refused to live up to its committment to install a dedicated phone line or radio link to the radio station. The existence of those O * """"i**** " 11"** *"*"#** th' **ili'Y # ""* * * """"I****
the EBs messages to WCGY within the 15 minute regulatory requirement. Without that dedicated phone line, there is no O assuran e that the e mmunicati n f the EBs messages and notification of the public can be made within the 15 minute window. As John Bassett's affidavit (Attachment F) indicates, g WCGY periodically experiences occasions during which all of its i phone lines are busy at the same time.
It is true that if the Governor of Massachusetts was to
""*h #i** th' * *i"*ti "
O # 'h* *** "*** ** # # *h* **##i"*
Valley, given enough time activation of the EBS through WCGY could ultimately be accomplished. It could be made either
- h" "'h * * "" *i'#*
O * *i"**i "' "i" ""
- i" * ** "' # *h" "9h a commercial line telephone call to WCGY. However, without a '
dedicated phone line or radio link between the activating O agencies and W GY, there is n assurance that the activation could take place within 15 minutes. There has been no i assessment made as to how long it would take to activate the EBS through WROR and then transmit that activation to WCGY.
l 0 ~17'
i Ol
)
, i Nor is there any assurance that a phone call would reach WCGY g i within the regulatory 15 minutes. During the normal course of f
business, WCGY's commercial phone lines are all occasionally busy. (See Attachment T at Page 2.) Only the existence of a g.
dedicated phone line, or some other means of direct access from i
the activating agency or entity to the radio station ensures the ability to make notification within 15 minutes.U S:
Without WCGY's participation and the existence of that direct ,
access linkage, this mandatory regulatory requirement is not '
t met.
O' Thus, the withdrawal of WCGY poses two separate significant ;
safety issues. It precludes the ability to activate the EBS as the SPMC calls for, and to notify all the public in the EPZ as :
g required by 50.47 (b) (5) and NUREG 0654's Planning Standard E.
Its withdrawal also precludes the ability to notify the public ,
within the time required by Appendix 3. In holding the ability G..
to make prompt notification to the public to be a significant safety issue, the Appeal Board has stated:
" Extended discussion should not be necessary with' regard to the obvious safety significance that attends upon 8,,
compliance with the commission's regulation designed to I provide the members of the public located inside the EPZ with "early notification and clear instructions" in the event of a radiological emergency." (Footnote omitted.) ,
Public Service comeany of New Hamnahlre, et al. (Seabrook 0l 1 Station Units 1 and 21, ALAB-883, 27 NRC 43, 50 (1988).
k/ No Massachusetts agency or entity has prescripted EBS Ol messages for the Seabrook EPZ. If any EBS messages for the-Seabrook EPZ were to be transmitted by means of a state agency !
activating WROR, the EBS messages would first have to be transmitted from NHY ORO to the state agency, then from the l state agency to WROR. l 0-i
O
) Without the ability to make notification to the public, the public will not be aware of the significance of the sirens; there will not be a uniform dissemination of the information in the EBS messages; and protective action' recommendations cannot be transmitted to, or received by, the general public in accordance with the SPMC and regulatory requirements.
Therefore, the attached contention and supporting affidavits address a significant safety issue that warrant reopening the record.
() A MATERIALLY DIFFERENT RESULT IS LIKELY IF THE BOARD CONSIDERS THE ATTACHED CONTENTION AND NEWLY PROFFERED EVIDENCE IN MAKING ITS DETERMINATION ON THE SPMC First of all, it is inconceivable that FEMA would have
() found the SPMC to be adequate without a provision for notifying the public in accordance with Planning Standard E. Similarly, l l
it is inconceivable that FEMA would have approved the SPMC O without specific provision in the SPMC for activation of the EBS by means of a letter of agreement with: the CPCS-1 station, WCGY, Without that station there can be no activation of the EBS.
C)
HUREG 0654, FEMA REP-1, REV.1, Appendix 3, at Pages 3-15, l I
specifically requires the integration of an emergency plan's notification system with the state and local EBS.2/
O 2/ It is highly unlikely that FEMA would have ever approved a plan that provided only for notification of the public through O a contract with a small local radio station like WLYT that services less than half of one percent of the area's public. "
See Attachment E. ,
~19-8 i
l Ol 1
l el Had the Intervenors known of the non-participation of WCGY and the inability to activate the EBs, the Intervenors certainly would have put that issue before this Licensing Board g in the form of a contention at the inception of this proceeding. However, as long as a legally enforceable agreement existed between the NHY and WCGY, there existed the g!
legal obligation on one side to provide equipment that-would enable the activation of the EBS, and on the other side, there ;
existed the legal obligation to activate the EBS upon request gf by NHY ORO as a recognized responsible organization. The voiding of the letter of agreement leads to a substantially different result.
9:
Without WCGY and the EBS, there are no provisions for notifying all of the general public in the Massachusetts EPZ as i to the status of an emergency at Seabrook Station or as to g:
actions to be taken in response to that emergency. If the Board takes that fact into consideration, it will doubtlessly ,
come to a different conclusion as to the adequacy of the SPMC's ,
notification provisions. I CONCLUSION Therefore, the Intervenors have established that a balancing of the factors to be considered in admitting a- )
i late-flied contention weigh heavily in favor of the admission '
S g
1
- ()
1 l
O of that contention. The Intervenors have also established that i this motion to reopen meets the standards that such a motion must comply with, and the gravity of the issue warrants !
reopening the record for consideration of the issue.
'() J COMMONWEALTH OF MASSACHUSETTS O JAMES M. SHANNON J ATTORNEY GENERAL O Joh haficonte Chief, Nuclear Safety' Unit .l Leslie Greer 1 Assistant Attorney :eneral l Nuclear Safety Unit.
Department of the Attorney General
!O one Ashburton Place Boston, MA 02108-1698
, (617) 727-2200 '
DATED: November 9, 1989 O
.O ,
O O
-21 '
.O-
. , - . . . . . ,,--~.~,.___.u, , - _- s. . a - u .u_s .sna, -u_ a , + .- ._ .-. . s . _ , ._ . . , . .
O 3
d B
t I
O .
t i
I
] )
a
- )
I i O i 2 r I
f
. I I
h
- t t
\
A ATTACHMENT A .
3 .
I e
b D
5 i
D 4
L J
4 D
i
. __ _ _ _ _ _ _ _ _ . _ . _ . _ . _ _ _ _ . . _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ . _ _ - _ ~ . . . _ _ . __ _
l lO j l
ERE CONTENTION ;
I
'O :
i i The Applicants do not have the means.to provide early i notification and clear instruction to the populace within the I O plume exposure pathway Emergency Planning Zone ("EPZ") in l Massachusetts and therefore do not meet the planning standards of 10 CFR I50.47 (b) (5) , and 10 C.F.R. Part 50, App. E.IV.D.
l O namin A. The Applicants' primary method for providing I i
notification to the populace in the Massachusetts EPZ is by means of the activation of the Emergency arcadcast system ;
- O (" Essa) serving the geographic area containing the EPz. (Plan i 3.2.5, IP 2.13). The Applicants' utility plan for Massachusetts formally contained provisions for activating the O ras by means of a letter of agreement with WCCM (AM)/ WCGY (rM)
. ("WCGY"). That letter of agreement was incorporated in the SPMC in Appendix C. On October 20, 1989, WCGY repudiated that
- O letter of agrement rendering it void and ineffective.
- Therefore, the Applicants no longer have the means for implementing early notification and clear instruction to the O populace in the EPz.
lO i
1 .
ATTACHMENT A O
O-
_v. . ~ , . _ 7... _
,,,_,...-,,%,._. _ _ . , , . _ , . , . _ _ - , . _ , _ _ _, . , , . , _ - o,-._ , , , . ,,,.m., . _ . - . . - .
a ._ms__A4_4 .ra - - - m_w_..sm_--, 4 . e, s...a.. a ,e. e m a.m.A- wa,_a.u..4 w- 4a na a.s m,c 4 e_ .a,._,p.a.
4 9
e e
sh d
l
,4
( .
i - (*
$ h
-O a i
l O -
t l
l-O I
v O ATTACHMENT B >
D 1
o i
l l
l l
i
- ,- -. - ... . - , . .. ..,., ,...... -- . . -- , . . -.i
. - . - - ~ . - - . - .. - -- .. .
- O ~
l t
/
l
' QI .
A LETTER OF AGREEMENT BETWEEN RADIO STATION WCGY AND l NEW HAMPSHIRE YANKEE'S OFFSITE RESPONSE ORGANIZATION L
Purpose:
' (}
To activate Emergency' Broadcast System as Provided Title 47 U.S.C. 151, 154 (i) and (o), and 303 (r); Chapter 1, Part 73, Subpart G, Federal Communications Commission Rules and Regulations, Radio Broadcast System (EBS) as pertains to day-to-day emergency. operation and to-provide-for cooperation and coordination between New Hampshire Q Yankee's Offsite F.esponse Organization (NHY/ORO) and the management of radio station WCGY 93.7 FM, Lawrence, Massachusetts, in the event of an accident / incident at the.Seabrook Nuclear Power Station (SNPS) in Seabrook, New Hampshire.
Scope of Activity of WCGY:
O The management of WCGY, Lawrence, Massachusetts, (when requested) agrees to activate the Emergency Broadcast System for the Emergency Planning 2one located within the Commonwealth of Massachusetts which consists of the following six (6) communities:
Amesbury, Merrimac, Newbury, Newburyport, Salisbury, and West Newbury.
O The management of WCGY further agrees to activate (when requested) the tone-activated radios supplied as part of the puclic notification system and broadcast emergency _public information when notified to do so by the Offsite Response Director of the NHY/ORO, using a pre-arranged authentication system.
,O WCGY further agrees that they have and will maintain a recording capability to record the actual voice of the NHY/ORO~Offsite Response Director, and they will broadcast the message, acceptance
! of/or participation in this plan shall not be deemed as a relinquishment of program control and shall not be deemed to prohibit
'O the licensee from exercising its independent discretion and -
responsibility in any given situation.
WCGY further agrees that the'NHY/ORO Offsite Response Director is authorized (through a pre-arranged authentication procedure) to activate the Emergency Broadcast System servicing the 0 -
Seabrook Emergency Planning Zone area in the event that there is an accident and/or incident at the Seabrook Nuclear Power Station with off-site. consequences.
The NHY/ORO Offsite Response Director will notify the management of WCGY when to activate the tone-alert radios and when to O begin broadcasting Emergency Public Information messages. The context of these messages and the interval'at which the messages will be repeated will be supplied by NHY/ORO.
This agreement becomes valid when signed by the signatures indicated below. Once valid, it can be terminated by either NHY/ORO
.O- or the management of WCGY by written notificacion ninety (90) days
_ O! .
e i
i i.
prior to the date of termination. ei -
)
i George V. Thomas
/-A ,pnager dd KAn'2
- Vice President of Production 'WCGY 93.7 FM New Hampshire Yankee ,
l Division of Public Service Company of New Hampshire Agent for the Seabrook 9:
Joint Owners L Date f- n . ei fE/r /4, / P P7 .
cate gl O'
.6 r
s O
l
\
- 1 0 '
01 1
2 t ei t
)
i 4
\.
.O
0-O O.
-O i
O ATTACHMENT C .
O I n
O V
i O
4 0
6-0-
'OL -
- The Messachusetts Emergency Broadcast System is Comunitted to responding to eng emergency that msg effect residents lO / of Messochusetts.The Emergency treadcast System is a voluntary organizetten authertred by and created by the Federal Conununications Commission. Its primorg functlen is to elert the public in the opent of a Presidential Declaration of Emergeneg; most ;
specificly nuclear attack. But the authority to use the EBS has been )
- O delegated down to the individuel licenses which must use its
" independent discretion and responsibility ". :
The Massachusetts Emergency Broadcast System would recognize eng responsible local business or ergenization that meg O' he responsible for creating er reporting a local ' emergency. .
After review of New Hampshire Yankee's Offsite Response
~ Organization and determining that en incident et New Nampshire Yankee could effect Messachusutts residents and that actlpation of could gate effects caused bg en Mdent h New :
O Nampshire Yankee Offsite Response Orgentzetion is recogenized as a responsible Iscal ergenization within the meaning of the Rules and Regulations governing the ESS.
IDith regard to the planning and implementation of the -
O eierting system it is understeed that NIIV/0A0 will provide certain services and equipment et its supense and that this process of planning and !mplementation mill be en ongoing.ene.
The following equipment and services will be initleig O #II'##
- 1. Dedicated telephone line end answering depics with competable taping equipment.
- 2. Fan er similar desica for receiving hard copy of eng O message.
- 3. RPU er similar transmit / receive equipment to enable messages to be sent / receiped without reliance en telephone. Also,-
to enable EBS stetten to transmit from incident eres or from erees O
that the incident meg cause en effect.
George'S./ Thomas NS m Douglas J.-sowe
=-
Vice President of Production Co. Chairman-New Hampshire Yankee Massachusetts Emergency Q Division of.Public Service Broadcast System Company of New Eaapshire Agent for the Seabrook Joint Owners Q VW / ' VU . lYlW7 ' ~ ',
Date Date ' /
k O'
O 5
-O O
O i l
a i
ATTACHMENT D !
i i
i
.w E
i 4 1
m 8 M
E
^
m l
=
(
i Q-9 i
UNITED STATES OF AMERICA j
NUCLEAR REGULATORY COMMISSION 0
ATOMIC SAFETY AND LICENSING BOARD
.Before the Administrative Judges q) Ivan W. Smith, Chairman :
Dr. Richard F.. cole i Kenneth A. McCollom i
O )
In the MatterLof ) Docket Nos. 50-443-OL
) 50-444-OL ;
PUBLIC SERVICE COMPANY )
OF NEW HAMPSHIRE, EI AL. ) ,
(Seabrook Station,-Units 1 and 2) November 9, 1989
) ,
AFFIDAVIT OF ROBERT BOULAY REGARDING c) THE VOIDING OF THE EBS LETTERS OF AGREEMENT q
~I, Robert Boulay, being duly sworn, state as follows:.
j)- 1. I am the Director of the Massachusetts Civil Defense Agency. My office is located at the Massachusetts Civil ~ Defense. '
Headquarters, 400 Worcester Road, Framingham, Massachusetts. As g Director of the Massachusetts Civil Defense Agency-I am the ;
official who is ultimately responsible for the supervision and l oversight of the Massachusetts Emergency Broadcast System l
("EBS"), and am familiar with its purposes, configuration, and
.O i operation. The Communications / Warning Officer who is the of ficial who is primarily responsible for the oversight and hand 0; n maintenan e f the Massa husetts EmergencyfBroadcast System O-r -
- - - . . . . . _ , . . . . _ . . . _ _ _ _ _ , , , ~ . . . . . . , . . . . , .
C
("EBS") reports directly to me and I supervise his activities as part of my job responsibilities. I have been Director of the Massachusetts Civil Defense Agency for approximately seven (7) years and I have worked in the field of civil defense and O
emergency planning for approximately twenty-six (26) years. A copy of my professional qualifications is provided.
- 2. The EBS is created under Title 47, U.S.C. 151, 154(1) and (o), and 303(r); Chapter 1, Part 73, Subpart G of the Federal Communications Commission's Rules and Regulations. It is a national communications network that can be activated on the national level, statewide level, or local operational area O level. Activation of the EBS national system is by authority of the President of the United States through control points for O
radio and T.V. networks, AP and UPI new services and participating common carriers. Activation of the EBS within Massachusetts may be by request of the Governor, the Director of the Massachuetts Civil Defense Agency, the Massachusetts State O
Police or the National Weather Service. Statewide activation may be made by the request for activation going directly to the Originating Primary Relay Station, WROR (F.M.). Activation on a O
local operational area basis may be made by directly contacting the operational area's primary relay /CPCS-1 station. That station in turn cues in the remaining stations in the operational area.
In essence, activation of the EBS proceeds as a ripple effect. If it is activated on the national level, transmission 9
- -- -- - - . . . - -~ . . . . . . .-- . . - - .
CI !
of the EBS attention signal is made _from Washington.to the
- O states' originating Primary Relay Stations followed by an 2
- -informational message. In Massachusetts the originating Primary _
l- - l Relay Station, WROR, would then transmit the EBS attention-signal followed by the informational message to the operational j l areas primary relay /CPCS-1 stations. WROR's transmissions would be received by tone alert radios at the CPCS-1 stations that are f in the local operational areas and are tuned to WROR.- There'are-
- seven operational areas within Massachusetts. In the Merrimac Valley, WCCM (A.M.)/WCGY (F.M.) ("WCGY") is the CPCS-1 station.
WCGY functions as the primary relay station, or' lead EBS l t i station, in the Merrimac Valley operational area. It activates the EBS on the local operation level by transmitting the EBS S attention signal to the radio stations in the Merrimac Valley ,
operational area. Those local stations have tone' alert radios that are tuned to receive WCGY's tone activation signal. See b Exhibit 1.
-While the EBS is a voluntary association of radio and television stations, all broadcast stations that are licensed by
)
the FCC are required to install an EBS two tone receiver. When the EBS i.s activated all radio and television stations that participate in the EBS pick up and transmit the informational
) EBS message. When the EBS is activated at the national level, all stations that do not participate in the EBS at the national i level are required to go off the air by F.C.C. regulations.
) That results in any listener who turns on his radio tuning in to 3
, - . J - - . . _ . , . . -
n
- O only EBS activated stations-that are allicarrying the same 9
uniform EBS message. On information'and belief as a matter of practice, the two (2) currently operable non-EBS stations in the Merrimac Valley operational area go off the' air whenever the EBS S
is activated at any level. In theory, it means that a listener who-is tuning his-radio to find information about an alerting signal will rapidly come to an EBS station carrying the-9 appropriate information because all other local radio stations will be off the air. The EBS functions as a-radio'rabroadcast-information procedure so that all stations receive and j 0;
retransmit the same messages. ]
- 3. The import of WCGY voiding-its prior letter of agraement with NHY and withdrawing from participating in the e:
emergency planning means that the EBS for the-Merrimac Valley operational area cannot be activated by NHY as called for in the l
SPMC. WCGY is the gateway station that activates the tone. alert 1 radios in the other EBS stations in the Merrimac Valley j i
operational area which in turn insures'the uniform transmission of EBS messages. While there appears to still be an existing 0
letter of agre'ement with WLYT (F.M. )/WHAV(A.M.) ("WLYT") , WLYT cannot activate the EBS in the Merrimac Valley operational !
area. The tone alert radios located in the other radio stations ,
O in the Merrimac Valley operational area are not tuned to WLYT.
While WLYT may be able to transmit an informational message provided by NHY to its own listening public, that message will 4 k
not reach the rest of the public who do not happen to be !
listening to those two radio stations.
9
-- . . . - - - . . . . _ - - -~- . . _ - . . . . . - - . - -
s
.O - ,
l :
g 4. While-in theory in the event of a radiological emergency'at seabrook Station, the Governor could activate the-EBS on a statewide basis by activating it through WROR in Boston,.there does not appear to exist any provision for y
- insuring that notification is made to the public in the j I
Massachusetts emergency planning zone for'Seabrook Station ]
within the 15 minutes required by NUREG 0654, FEMA-REP-1, i Revision 1, Appendix 3. There does not. exist a dedicated phone line, or other direct access link from any activating agency in- ;
i the state' government.to WCGY. There is not any direct (g
, communication link with WCGY other.than through commercial -!
! phone. Commercial telephone may not provide the requisite
(
assurance of notification in 15 minutes because as noted in the l Affidavit of John F. Bassett, WCGY's telephone lines are at i times all busy. 1 The foregoing is true and correct to the best of my knowledge and belief. !
M e >L _ A !
V Robert Boul I
]
Subscribed and sworn to before me this 9 ^ LL.
day of ;kv 4.mb,<.1989.
r-- .
f a n // Wa i m ;
/
NotaffPubl[ic 4 My Commission Expires:
30 %R33 1
j l >!
u j . )
O ROBERT BOULAY STATEMENT OF PROFESSIONAL OUALTFICATIONS $
Position: Director of the Massachusetts Civil Defense Agency =
For approximately seven years I have been the-Director '
at the Massachusetts Civil Defense Agency. My job.
responsibilities and work experience during that period have g included supervision and oversight of_ communications personnel who have the following dutiest Providing-and supervising the capability'for alerting
~
g the public and escalating Civil Defense forces through the _ j state Civil Defense Warning-System and other emergency communications-systems, in event of disasters or enemy attack.
Supervising the daily operation of the state Civil e Defense Warning System, agency two-way. radio mobile-base l systems, microwave systems and repeater relays, by l conducting daily-circuit tests to ensure-that systems are 1 operational. J i
Prior to my employment with the Massachusetts Civil Defense g Agency, I worked extensively in. broadcasting: working primarily as a staff announcer and news. broadcaster,Lin special events and continuity writing. g l I am a graduate of the National-Academy of Broadcasting _in.
Washington, DC. I attended the Federal Emergency Management-Staff College in Michigan; the Federal Instructor Training -p ,
Center.in New York, and the Western Radiological Emergency Response Staff College in Nevada.. I also attended and completed a Senior Executive Program at Harvard University g]
Kennedy School of Government in 1985.
l el t
0L 1
MASSACHUSETTS EMERGENCY BROADCAST SYSTEM !
O l
O'PERATIONAL PLAN o
i gfENSg#
Q q*%
h 9, g f
- b MICH AEL S. DUK AKIS GOVERNOR
^
CH ARLES V. B ARRY PUB SA E ROBE J.BOULAY i O
Revised : May 1988 4^ ,
EXHIBIT 1
._._________z_:._______-____.__.______.
q M ASSACHUSETTS- EMERGENCY BROADCAST SYSTEM .
() , 1 TABLE OF CONTENTS 0; f.a,_g.e_
~
Record of Changes i i Distribution List 11 Preface 111 Definitions iv O
I Purpose 1 II Authority 1 III Introduction 1 ,
() IV General Consideration. 1 j A.
j I
Situation B. Physical Characteristics '
C. Assumptions V General Plan l A. Organization 3
() B. Concept of-Operations ;
VI Implementation 5 VII Tests 7 APPENDICES ~
Appendix 1 Massachusetts'0perational Areas Appendix 2 EBS Monitoring Assignments Appendix 3 National Weather Service Procedures Appendix 4 Attack Warning Script l Appendix 5 State Test Script _
() Appendix 6 Authorized Officials List .
Appendix 7 Authentication. Instructions 1 Appendix'8 State & Local' Emergency Communications-Committee Appointments Appendix 9 Cable IV (to.be developed)
() Appendix 10 Approval Sheet o
- O O
MASSACHUSETTS CIVIL DEFENSE AGENCY-EMERGENCY BROADCAST SYSTEM OPERATIONAL PLAN-RECORD OF CHANGES 8.
l 1
- ei t
8 I
1 i
j i
h O!
}
O i
D J
, DISTRIBUTION LIST
) .
STATE AGENCIES' NUMBER OF COPIES-Governor's Office 1 '
) Executive Office'of Public Safety 1' .
t e
Massachusetts State Police 2 Massachusetts Civil Defense Agency 10 J
FEDERAL AGENCIES Federal Emergency Management. Agency, Region I 2 <
3 National Weather Service (NWS-Boston) 2 Federal Communications Commission 2 (Emergency Communications Section)
PRIVATE ORGANIZATIONS Massachusetts State Emergency Communications Committee 2 (Chairman) f.
) Massachusetts Broadcasters Association (President) 2 Local Operational Area Emergency Communications 2 each Committee Chairman & Vice Chairman All Massachusetts Broadcast Stations 1 per station l
Cable T.V. 1 per station l l
l l I
11 l 1
I ,
! l l
)
O!
- f PREFACE O
The following is a revised Massachusetts Emergency Broadcast Plan which encompasses many of the memorandums, practices, and innovations 4
brought about by the tests and activations of the system since its inception. ,
i The plan was written to be understood by all who have the 9
( need to know about the plan. This plan is available to all agencies and organizations who have a role to play in informing the public during an emergency.
O It is hoped that you will read and comprehend this plan and use it effectively should the need for activating the Emergency Broadcast S) stem arise.
This plan was only possible due to the outstanding cooperation
- the Massachusetts broadcasters have given to the system.
I e i
1 4
1 111 I
1 0
2 i
l
- I
- O -
DEFINITIONS .
O .
EMERGENCY: A situation posing a threat to the safety of-C) life and property. Examples are, but not' limited to: :
tornados, hurricanes, floods, tidal waves, earthquakes, icing conditions, heavy snows, widespread power: failures,-
O industrial explosions, civil disorders, Land l nuclear 1
incidents or attack.
SEVERE WEATHER WATCH:- A severe weather WATOH: indicates O
that the probabilities of a particular severe weather storm are high, and is an alert to=the!public of such severe weather conditions.
C) j I
SEVERE WEATHER WARNING: A severe weather WARNING indicates.
that-a'particular severe weather storm hasfactually
() been sighted in the area or indicated by radar, and; serves notice to the public that-severe weather con- y ditions are almost certain to occur.
O AUTHORIZED GOVERNMENT OFFICIALS: The person or persons 1
designated by governments signatory to this procedure l that have the authority to request-activation of the-O' Emergency Broadcast System (EBS) and to make emergency announcements / broadcasts. ;
1 1
O l I l l
l l iv l lO
Q I PURPOSE ,-
j= The purpose for this document is to' provide methods and procedures agreed upon by the M osdcast industry, the state and the-local
($) governments which p&i-dit authorized government officials to issue emergency inf6rmation and instructions in threatened or actual.
emergencies.
II AUTHORITY D'
Title 47 U.S.C. 151, 154 (1) and (o), and 303 (r); Chapter 1,. Part 73, Subpart G, Federal Communications Commission Rules and Regulations, Radio Broadcast Services, Emergency Broadcast System (EBS) as pertains- to day-to-day emergency operation.
h) III INTRODUCTION These procedures were prepared by the Massachusetts Emergency Communications _ Committee in cooperation with the National Weather Service and'the Massachusetts Civil Defense Agency.
f) It provides background data and prescribes specific. procedures for the broadcast media to_ disseminate emergency information'and wa rning to the general public in Massachusetts, or any portion '
thereof within the station's' broadcast: coverage capability, I at the request of designated Federal, State or local government
- ) officials. Acceptance of/or participation in this plan shall not be deemed as a relinquishment of program' control and shall not be deemed _to prohibit a license from exercising his independent discretion and responsibility in any given situation.
3 IV GENERAL CONSIDERATION The listening and viewing habits of.the general public are inherent factors for consideration and are conducive to the positive effectiveness of the Massachusetts Emergency Broadcast System (EBS). It is the instinctive reaction of
[) the average person to turn on his radio or television set in time of emergency.
3
_1_
)
The foll'owing outlinas tho' basic situation,' physi' cal: charac- ' C) l- toristics and ossumptions'used in-the development of;this-plan. **
L A '. Situation Broadcast radio and T.V. stations'are mainly privately owned 8 corporations using the public " air waves" and-operating'in the public interest. One aspect of this public interest'is j to allow its facilities to be used bys responsible government j officials to .communi'cate with the public in . time of impending ;
or actual emergency. Such a system, as ' prescribed by y the -
Federal Communications Commission (FCC) is the Emergency $l' Broadcast System (EBS). (FCC Rules and Regulations Part 3.
Subpart G).
B. Physical Characteristics i The Commonwealth of Massachusetts has approximately 190 radio 9, and television stations in.the Massachusetts Emergency 1 Broadcast System. For EBS planning purposes, the state of i Massachusetts is-sub divided into seven local EBS operational ;
(geographical) areas. Each station in a local operational area !-
monitors the Primary Relay /CPCS Station for that area to :
receive Emergency Broadcast System messages. These Primary GP.
Relay /CPCS Stations receive the message directly by monitoring ,
either the state's Originating Primary Relay Station WROR(FM) or the' Primary Relay /CPCS Station in.an adjacent area. Using this procedure, the original Emergency Broadcasting System message is transmitted from WROR-FM in Boston and can be picked !
up and retransmitted-by every EBS station in. Massachusetts GP' within approximately eight minutes.
C. Assumptions All licensed Broadcast Stations are required by the FCC to install an EBS two tone Receiver. All Massachusetts stations 6 monitor either WROR-FM or the- Primary Relay /CPCS station in their local operational areas and contact with:WROR-FM or an 1 area's Primary Relay Station is sufficient to initiate entry into the system.
Since many broadcast stations become essentially "one man" $
operations during "non-business hours", the plan must take into consideration such problems as:
- 1. Duty operator doing news or otherwise "on mike". ,
- 2. Duty operator absent from " control room" for personal reasons. 9 Duty operator's specified actions, should such activation occur, during: commercials, dramas, music etc. must be clearly defined by station management so there will be no con-fusion or delay in activating the EBS on the part of such per-sonnel. As rebroadcast authority is automatic during EBS tests 9) and activations (under Sec. 73.935 (g) and 73 961 (g) FCC Rules and Regulations) there should be no hesitation to simulcast.
-2 l
- O <
~ ~
Precautions should be takin at all stations to automatically ,
tape all EBS messages, in case of failure to simulcast.
It is generally assumed that the Emergency Broadcast System would be O implemented in ,the following situations.
- 1. Nuclear Attack The EBS will be used to warn'the public of impending Nuclear O Attack and to augment existing outdoor public warning systems. The Massachusetts _ State Police, who constantly i monitor the National Warning System-(NAWAS) have been instructed to notify WROR should they receive an Actack Warning. A verified telephone call from the State _ Warning Point (State' Police Headquarters) is sufficient for WROR to -
O activate the EBS for. Attack Warning. Confirmation of an ,
attack may also come'over the AP/UPI wire service as' outlined by the FCC.. An appropriate warning' message to be read by WROR and carried simultaneously statewide is appended. (Appendix 4)
~
O 2. Other Emergency Situations The EBS will and has been activated for other situations FCC Rules which endanger'the. safety of life and property.
and Regulations Section 73 935 cites.aexamples of_ emergency situations which may_ warrant either'an immediate or delayed
-(3 response: tornados, hurricanes, floods, tidal waves, earth-quakes, icing conditions, heavy snows (blizzards),
widespread fires, discharge'of toxic gases, widespread power failures, industrial explosions, civil disorders, nuclear accidents (including _ power plant).
,0- 3 Testing To test the system and its interconnects V THE GENERAL PLAN
'O
= A. Organization National Level - Rules and regulations pertaining to the EBS are promulgated by the Federal Communications Commission.
Oversight for the Federal Government level is the respon-
.O - sibility of the Federal. Emergency Management Agency-(FEMA) with Natural Disaster planning and actual weather data input supplied by the' National Weather Service (NOAA). National EBS recommendations for changes in Rules and Regulations i stem from suggestions of the National Industry Advisory Committee (NIAC), composed of representatives of the M) - National Association of Broadcasters (NAB), the Common
' Carrier industry, cable television representatives (CATV),
and others representing the communications industry.
Stato'Levol=- Rulos ond. Regulations'for the Stoto EBS cro pro. I)
= aulgotod and onforcod by tha FCC with oversight- and progros implo-mentationthe responsibility of the Massachusetts Civil > Defense Agency-(MCDA), the National WeatherService, and the State
~ Emergency Communications Committee-(SECC) composed- of represer,-
tatives.of the Broadcast Industry. All FCC licensed broadcast g; fac!11 ties, AM -FM -TV , including public and educational facilities, may participate in the Massachusetts EBS. (See Appendix 1) 4 Local Level (Operational Area)
. Based on the recommendations of the local' operational' area' Emergency Communications Committee, local officials should. work O- '
out " local operational area activation procedures" with the local station management'. This plan will not attempt to address-itself to specific local activation procedures which may -differ from area to area. i B. Concepts of Operations 0
- 1. National Level Activation of the National System for Attack Warning or a national emergency is by authority of the. President of the ,
United States via control points for the radio and TV networks, AP and UPI News Services and particpating common carriers. In addition, a " wireless" system of interstate "off? air" monitoring exists with its origin at the White House via Washington, D.C.
radio station WTOP, ultimately reaching WROR (FM), Boston and the primary relay /CPCS-1 Stations in each of the operational ,
areas. The remainder of the Massachusetts stations monitor their operational area Primary Relay /CPCS Station'for "offLair'*
notification / programming. In addition, a method of combining the major national radio and TV networks exists to provide a common National Program to stations holding Emergency Broadcast System authorizations. National level instructions are con-tained in the FCC Publication, EBS Check' List. O.
- 2. State Level Activation of the Emergency Broadcast System (EBS) within the State may be by request of the Governor, the Director of the gp=
Massachusetts. Civil Defense Agency, the Massachusetts State Police or the National Weather Service. Such requests shall be made directly to the Originating Primary Station, WROR (FM)'or the Operational Area's Primary Relay /CPCS Station (See Appendix
- 1) who, after airing the-EBS Attention Signal, indicates the nature of the emergency and'" cues in" the remaining stations in g-the State EBS network. The State level concept of operations differs from the National level in that the State does not have access to the radio and TV networks. Thus the system is entirely a radio rebroadcast information procedure, so that.all stations receive and re-transmit the message or program supplied by the activating agency. g; 4-O
i Participation in the Massachusetts EBS is voluntaryfand?at'the discretion of station management. -Most Massachusetts stations -
O have carried,EBS programming or tests. This is. accomplished in several ways:
- a. Direct ' connection to the FCC required "off-the-air" signal monitor. This is the same receiver which decodes and is activated by the EBS Attention 1 Signal, A direct notification by telephone or Radio 1 Remote-
~
b.
Pickup Unit (RPU) to the Originating Primary Relay sta-tion or Primary _ Relay /CPCS-1. stations in the local operational areas.
9 Experience has shown that .the National Weather- Service- (NWS) may '
have the most requests for activation with weather warnings ~ , i while the Governor has used the system for public information j during the Blizzard of '78 when publishing was. at a -stand still. 1 Future uses are a practical reality. (See Appendix 3)-
D VI Implementation The following is an explanation of procedures-State 1 officials-and ,
the broadcast industry should use to implement the State EBS if t I necessary.
D A. Procedures for Activating Officials: l
- 1. Request activation of the EBS facilities through WROR Tel. No. (617) 236-6841. ,
D 2. Work out broadcast details (i.e., live or recorded, immediate
~
or delayed) with broadcast station personnel.
1
- 3. It is recommended that authorized' government officia'Is.use- -
the following format when delivering the emergency announ-cement. The format is deliberately general in nature to '
b allow for the uniqueness of each' emergency situation, yet' broad enough to insure completeness. )
D, D
l l
~
'O
.c.. "Thic is of
, Name7 Title .JuFTsdiction with a request to activate the Massachusetts Emergency
, Broadcast System. I authenticate as follows: -d
- 9 (State appropriate authenticator code)
- b. Situation summary (describe the nature of the emergency).
- c. Actions being taken by local government (s),
- d. Instructions or message to the public.
4 Keep line op'en if necessary Note. . ' . if the Greater Boston Metropolitan area and one or more g; other sectors are affected by the warning, activate the system through WROR (FM). If warning is to affect only one EBS- opera-tional area, activate that local EBS operational area by_ following the above procedures to the Common Program Control Station-1 (CPSC-1) in that area (Sce attached map for breakdown of state into Operational Areas - Appendix 1-1) g!
Telephone numbers: g Primary Relay Sta tions Back Up Merrimack Valley -
WC0Y - 729-9470 g.
Southeast Mass -
WPLM - 746-1390 WMYS -996-3371 Cape Cod and Islands -
WJFK - 775-7400 Central Mass -
WSRS - 757-6321 WTAG- 793-9400 4 Connecticut Valley -
WFCR - 545-0100-(413) WHYN 413-739-6338 i The Berkshires -
WBEC - 499-3333 (413)
e!
i B. Procedures for Broadcast Industry 'I
- 1. Upon receipt of a request to activate the Massachusetts EBS, the master control operator at WROR-(FM) will-begin- ;
recording omergency messages and proceed as follows:
$l
- a. Broadcast the following announcement:
1 "WE INTERRUPT THIS PROGRAM BECAUSE OF A STATE (OR LOCAL) EME RG EN CY . IMPORTANT INFORMATION WILL FOLLOW." g.
a 9
O
-l D) ' '
- b. ' Transmit the Enorgoney BroodcQot Syston- Two tons Attontion Signal: (FCC Regulations, Part-73, Subpart G, 73, 906). l 4
" c.2 Broadcast the following announ'coment:
O "WE INTERRUPT THIS PROGRAM TO ACTIVATE THE MASSACHUSETTS EMERGENCY BROADCAST SYSTEM AT THE. "
REQUEST OF AT
( time) .
- d. Make the emergency announcement. Repeat as necessary and r) include the source of informati.on and time received,
- e. Official.information statements during an actual " General ;
Emergency" at a nuclear power station should be given at no greater than 15 minute intervals.-
- 2. Each broadcast station, upon receipt of a State or Local-level-h) emergency notification will, at the discretion of station ,
management, perform the same procedures as outlined in B. 1. ;
- a. thru d. above including recording all the emergency
. messages.
3 To avoid unnecessary escalation and public confusion, all broadcast stations must be cautious in providing information l and news pertaining to the emergency. All messages'must be j based on definite and confirmed facts. The listener must not:
l be lef t to decide for himself what. is or is not factual.
4 Upon completion of.the above transmission procedures, resume I normal programming. Appropriate. notations should be made of I all significant events as they transpire. These1 records should be carefully preserved in he Engineering Log.in the event they are required at some later date. ,
) 5.
^
Upon receipt of termination notice from activating official, make the following announcement:
"THIS CONCLUDES OPERATIONS UNDER MASSACHUSETTS EMERGENCY BROADCAST SYSTEM, ALL BROADCAST STATIONS WILL.NOW-RESUME NORMAL BROADCAST OPERATIONS." (Repeat announcement) l VII. Tests L- .To ensure readiness, the Massachusetts Civil Defense Agency will initiate tests at random times. These tests will be conducted and evaluated by the the Massachusetts Civil Defense Agency with the N
voluntary particpation of the Massachusetts broadcasters.
-O Toassis$MassachusettsBroadcastersincomplyingwithFCCweekly EBS tests, State tests- will be generally conducted on either Mondays or Tuesdays. Should there be no State test, then the .
station should conduct its own EBS Attention Signal test 'S later in the' week (Wednesday, Thursday or Friday).- In this way, stations participating in the State test - are excused ' from having to conduct a-local test-for'that: week. (FCC Rules and
' Regulations Section 73 961 (d).). The Massachusetts Civil Defense Agency 'will coordinate with the SECC State Chairman in advance of a statewide test.- -0 If only one operational area is to be tested, the SECC Area Chairman shall be -notified in advance instead of the SECC State Cuairman if possible.
The conduct of a State EBS- test by the Massachusetts Civil- Defense- O Agency (MCDA) will be as follows:
- 1) M.C.D.A. will contact WROR (or for a test of -just one opera-tional area, that area's Primary Relay /CPCS-1 Station)
- 2) Identify yourself 9
- 3) Say the following, "I would like to conduct a test of the Massachusetts Emergency Broadcast System.-
- 4) Ask them to repeat the " State test message" on the air. (See Appendix 5). e WROR or the Primary Relay. Station in any operational area must issue a test of EBS and read the state test message.
This must be done at the next available program interruption, but for the test to be valid, within a half-nour's time. 9 all stations monitoring these primary relay stations ~shall repeat the test message "on air" at the next available : program interrup-tion but within a half-hour's time. Eventually the system will be refined to provide simulcasts of all emergency notification :qd tests. O Since State initiated tests contain appropriate wording, reading of the FCC supplied test script is waived. (FCC Rules and Regulations Section 73 961 (c))
O O
_d-O
10 LOCAL MASSACHUSETTS-EBS OPERATIONAL AREAS o .
O l MERRIM AC VALLEYI r
l BERKSHIRE ] l CENTR AL MASS.1 .
1
..e. .
O M.I F ra n klin
~
yMiddle.es l METRO BOSTDN l W orcester B....l.. , ,
Norf olk i
( H a sn p d e n u - --
g l CONNECTICUT, VALLEY l
> Bristol P ly sn o u t h I j ISOUTH EAST MASS.l '
/' Barnst _
l i
.. b
)
e .
[ CAPE & ISLANDS l 448 4 i
N o n1u c h e t i e
CPCS-1 PHI RELAY BERKSHIRE WBEC/WBEC (FM) WBEC.(FM)- !
g CONNECTICUT VALLEY WFCR (FM) WFCR (FM)
CENTRAL MASS WSRS (FM)- WSRS (FM)
MERRIMAC VALLEY W CCt'/W CGY (FM) WCGY (FM), i METRO BOSTON WROR (FM) WROR (FM)
SOUTH EAST MASS. WPLM AM/FM WPLM-(FM)
CAPE AND ISLANDS WOCB (FM) WOCB (SM)!
D -
1-1 -j Appendix 1
1
. . i MASS ACildSETTS },BS t HO itEi,AY Ni;TWOI1K i
- -9 1
l a
- e e n7.~
w e r. y
.y s
I' M 93.7- e];
T N, e'*= .
I P ie a s f t e l[ '
W it L C ', s T, M 105.5 *
- W ee t r e s t r e a '. I Il uTi n n i e' , W 's
- WHOH- I
- r s .H.. b. i ( , f u s aJ g)
' s, A mt.erss
~
~ ' ' ~
j "y ;
. WiCR ~
I
' l' M 413,3 ;
s, e
- a. _
- ; ,e v -
r i v m se u s ti W l' t. M ;
i
' l N 9 9. 4 ,e civil. Defense "' * * * " " ' 'I S' Agency h '
gg'Rz; Emergency Operating
~ center bM e
e:
- 1. The Massachusetts Civil Defense Agency, when activating the. Emergency Broadcast System (EBS), will contact the Originating Primary Relay radio station in Massachusetts, namely, WROR/WRKO, Boston.
- 2. WROR/WHKO will broadcast the emergency message or instructions.
L 3. WCGY in Lawrence and WPLM'in Plymouth will monitor WROR,. tape the mess 3Re and re-broadcast.
al . WJFK in West Yarmouth, will monitor WPLM, Plymouth, tape the message O l
and re-broadcast.
- 5. The chain-. continues from WROR to WSRS-in -Worcester, then to WFCR, Amherst and finally on to 'WBEC in Pittsfield.
- 6. All other radio and TV stat'lons in Massachusetts will monitor their 9:
Primary Relay station (the stations shown on the map) in their geographical area. Geographical areas are shown by the dotted lines.
O' 1-2
L)
' LOCAL MASSACHUSETTS 6BS OPEBATIONAL DETAILS (3
BERKSHIRE OPERATIONAL AREA - BERKSHIRE COUNTY -
AM STATIONS FM STATIONS (3 .
FREQUENCY STATION FREQUENCY '
STATION EBS DESIGNATION FACILITIES EBS DESIGN A TION FACILITIES WSDS Great Bharington 860 WJJW (FM) North Acams 89.5 !
PRIM A RY 0.01 kW PRIMARY g 0.25 kW D.
WMNb North Ac.f.a 1230 WMNB-FM North Ad:ams 100.1 .
1 kW U PRIMARY 1 kW 480 ft PRIMARY l
WBEC Pittsfield 1420 WKTQ-FM Pittsfleid 101.7 I~kE DA-N U PRI CPCS-1 3 kW 145 ft PRIMARY
.()
UERK Pittsfield 1340 WUPE-FM Pitts! 1 eld 95.9 1 kW U PRIMARY 1.0 kW 560 f t PRIMARY UUHN Pittsfie.d 1110 'W BEC-FM Pi tts f ield 105.5 '
5 kW DA-D PRIMARY UT53~fE 590 f t PHI RELAY 0 PRT 5PCS I j 89.7 WTBR-FM Pi tts f ie. d '
0.30 kW PRIMARY WBSL (FM) Shett'leid 91.7
!g 0.01 kW 50 ft PRIMARY ;
1 WRST (FM) Greenfiell 95.3 tv .? rt TIONS PRIMARY ,
STATION FREQUENCY WCWL (FM) Stockbridge 91.3 ,
(3 FACILITIES EBS DESIGN A TION 1 34 kW 4 ft. PRIMARY WCDC (TV) CH 19 WCFM (FM) Williamstown 91.9 0.44 kW - 750 ft PRIMARY 116 kW 2100 ft PRIMARY l
C) ,
' Stations CJrrently Participating in Broadesst Station.Pietection Progrhm ( B S P I' >
I
'O 1-3 i C) I
O LOCAL MASSACHUSETTS EBS OPERATIONAL AREA DETAILS :
CONtiCCTICUT VALLEY OPERATIONAL AREA - FRANKLIN. HAMPSj!RE & HetPPEN COUNTIES
, FM STATIONS ,
STATIui j M STATIONS FREQUENCY
- FACILITIES EBS DESIGNATION TV STATIONS O!
TATION FREQUENCY WAMH(Fh) Amherst 69 3 ACILITIES EBS DESIGNATION 0.15 kW 720 ft PRD4ARY STATION FREQUENCY !
FACILITIES EBS DESIGNATIOf' TTT Amherst 1830 WFCR (M4) Amharst 88.5 kW DA-D TRIMARY W kW 720 ft PHI RELAY WGBY W Springfield CH 57 i PRI CPCS-1 776 kW 1000 ft PRD4A4 ACE Chicopee 730 kW D PRIMARY WMUA(FM) Amherst 91.1 WOGB Springfield CH 40 1 kW 27 ft PRD4ARY 3630 kW 1000 ft NON EBS
'IXY East Longmeadow 1600 ,
.5/5 kW DA 10 PRD4ARY *WHAI-FM Greenfield 98.3 WWLP(TV) Springfield CH 22 1 kW 240 ft PRIMARY 4200 kW 750 ft dHAI Greenfield 1240 PRIM kW U PRIMARY WCCH(FM) Holyoke 89.5 !
0.01 kW PRIMARY POE Greenfield Primary 10KWD l RES Holyoke 930
- WHIP-FM Northampton 99.3 !
.5 kW D PRD4ARY 3 kW 300 ft PRD4ARY 9.
WR4F Northampton 1400 WMCH (FM) South Hadley 91.5 kW U PRIMARY 0.01 kW PRD4ARY ;
CAT Orange 700 WAIC(FM) Springfield 91.9 i kW D PRD4ARY 0.13 kW 66 ft PRDiARY 9 HYN Springfield 560 WAQY(FM) Springfield 102.1
/5 kW DA-2 U PRIMARY 17 kW 780 ft PRD1ARY i MAS Springfield 1450 WHYN-FM Springfield n31 kW U PRIMARY 10 kW 940 ft PRIliARY O' 1PR Springric1d 1270 WMAS-FM Springfield 'l4. 7
/5 kW U PRIMARY 50KW 170 ft PRD ARY ARE W re 1250 WSC8(FM) Sprirgrield 49.9 kW DA-N O PRIMARY 0.01 kW NON EBS 9:
LDM WCstfleid 1570 WTCC(FM) Sprirgrield 90.7
.5 kW D PRIMARY 4 kW 115 ft NON EBS QXQ West Springfield 1490 WTRZ(FM) Sprirgrield 89.1 kW DA-D U NON EBS 0.01 kW 80 ft PRDiARY #
91.5 WSKB(FN) Westileld O.01 kW 130 ft NON.EBS WNEK (FH) Springfield 97.5 PRIMARY 9:
Stations currently particpating in the Broadcast Station Protection Pmgram (BSPP) i-4 e!
) LOCAL MASSACHUSETTS EBS OPEHAT80NAL AREA DETAILS l CENTRAL MASS OPERATf0NAL AREA-WORCESTER AND P/0 M2DDLESEX & NORFOLK COUNTIES AM-STATIONS FM- ST A TION S g STATION FREQUENCY STATION FREQUENCY FACILITIES EBS DESIGNATION FACILITIES EBS DESIONATION __
WEIM Fitchburg 1280 WXLO(FM) Fitchburg 104.5 1/5 kW DA-2 U PRIMARY 37 kW 563 ft PRIMARY g WFOL Fitchburg 960 WOA0(FM) Franklin 88.3 1 kW DA-2 U PRIMARY 0.125 kW 95 ft PRIMARY WOAW Oardner 1340 WAYM(FM) Maynard 91.7 1 kW U PRIMARY 0.125 kW 43ft NON EBS -
WQVR(FM) Southbridge 100.1 p WLMS Leominster 1000 1 kW D PRIMARY 3 kW 295ft PRIMARY WSRO Marlboro 1470 WSRB(FM) Walpeie 91.5 5 kW PRIMARY 0.01 kW 83 ft PRIMARY WMRC Milford 1490 WAAF(FM) Worcester 107 3 I 1 kW PRIMARY 16.5 kW 780 ft PRIMARY- __
WESO Southbridge 970 WCUW(FM) Worcester 91.3 1 kW D PRIMARY 0.08 kW 37ft PRIMARY WFTQ Worcester 1440 WICN(FM) Worcester 90.5 5 kW DA-2 U PRIMARY 2 kW 370 ft PRIMARY WNEB Worcester 1230 W SRS( FM) Worcester 96.1 _
1 kW U 25 kW 640 ft PRI RELAY PRI CPCS T WORC Worcester 1310
' 1/5 kW DA-2 U PRIMARY WMWC (FM) Gardner PRIMARY
'WTAG Worcester 580 5 kW DA-2 U PRI CPCS-2 WBPV (FM) Charlton PRIMARY WOFP Worcester 940 I
1.0 KW PRIMARY WINQ (FM) Winchendon 97.7 1.27 kW 439 ft PRIMARY WCMX Leominster 1000 PRIMARY WNRC (FM) Dudley PRIMARY
' WCHC (FM) Worcester PRIMARY TV STATION FREQUENCY FACILITIES EBS DESIGNATION WHLL-TV Worcester CH 27 513 kW 1531 ft NON-EBS
- Stations Currently Participating in the Broadcast Station Protection-Programs (BSPP) 1-5
1 O!
. l LOCAL MASSACHUSETTS EB,S OPERATIONAL AREA-OPERATIONAL DETAILS :
DETAILED MASSACHUSE,TTS EBS OPERATIONAL PLAN - MERRIMAC V ALLEY OPERATION AL Ariel MERRIMAC VALLEY OPERATIONAL AREA-P/0 ESSEX & MIDDLESEX CO.
I AM STATIONS FM STATIONS i G'
STATION FREQUENCY STATION FREQUENCY FACILITIES EBS DESIGNATION FACILITIES EBS DESIGNATION WNSH Beverly 1570 WPAA(FM) Andover 91.7 ;
0.5 kW DA-D NON-EBS 0.01 kW NON EBS 9.
WHAV Haverhill 1490 WVCA-FM Gloucester 104.9 1 kW U PRIMARY 3 kW 50 f t NON EBS
'WCCM Lawrence 800 WLYT-FM Haverhill 92.5 1 kW D PRI CPCS-1 50 kW 350 ft PRIMARY WCAP Lowell 980 nWCGY(FM) Lawrence 93.7 5 kW D A-2 U PRIMARY W kW 430 ft PRI RELAY Plil CPC5~T
~ ~
WLLH Lowell 1400 >
1 kW U PRIMARY WJ UL ( FM) Lowell 91.5- -
- 1. 7 kW 39 f t PRIMARY e; WCEA Newburport 1450 0.5 kW D PRIMARY WSSH(FM) Lowell 99.5 39 kW 550 ft PRIMARY WQLI(FM) Newbury B B .' 7 <
0.01 kW 55 ft PRIMARY e' WMMC( FM) North Andover 90.5 0.01 kW 58 ft PRIMARY WBMT(FM) Topsfield 88.3 0.71 kW PRIMARY 3:
- Stations Currently Particpating in the Broadcast Station Protection Program (BSPP) - (WCCM/WCGY - currently scheduled to be included in program.) , e[
1 0
l 1-6 c:
b LOCAL MASSACHUSETTS EBS OPERATIONAL AREA-DETAILS METRO BOSTON OPERATIONAL AREA SUFFOLK CO AND P/0 ESSEX , MIDDLESEX AND NORFOLK CO.
D AM STATIONS STATION FREQUENCY FACILITIES EBS DESIONATION AM STATIONS (con't)
D WMEX Boston 1150 WLv0 Cambridge 740 5 kW DA-2 U PRIMARY 0.25 kW D PRIMARY oWBZ Boston 1030 WK0X Framingham 1206 50 kW DA-1 U PRIMARY 1 kW D PRIMARY WEEI Boston 590 WLYN Lynn 1360 5 kW DA-1 U PRIMARY 1 kW D PRIMARY WEZE Boston 1260 WXKS Medford 1430 5 kW DA-N U PRIMARY 5 kW D PRIMARY D
- WHDH Boston 850 WXLJ Sudbury 50 kW DA-2 U PRIMARY PRIMARY WILD Boston 1090 WTTP Natick 1060 1 kW D PRIMARY 2.5/25 kW DA-2 U PRIMARY WRKO Boston 680 WNTN Newton 1550 50 kW DA-2 U PRIMARY 10 kW D PRIMARY WMRE Boston 1510 WJDA Quincy 1300 50 kW DA-2 U PRIMARY 1 kW D PRIMARY WROL Boston 950 WESX Salem 1230 5 kW D PRIMARY 1 kW U PRIMARY WUNR Brookline 1600 WDLW Waltham 1330 5 kW DA-1 U PRIMARY 5 kW DA-2 U PRIMARY WJCC Norfolk 1170 PRIMARY
' Stations Curently Participating in the Broadcast Station Protection
> Program (BSPP)
(FM & TV - Next Page)-
1-7 i i
l O!
, L,0 CAL MASSACHUSETTS EBS OPERATIONAL AREA-DETAILS METRO BOSTON OPERATIONAL AREA (CON'il SUFFOLK CO. AND P/O ESSEX1_MIDDLESEX AND NORFOLK CO. j TV STATIONS STATION FREQUENCY l FACILITIES _E_B S__D E S IG N A T I ON FM STATIONS
~~~- WBZ-TV Boston CH 4 ,
60 3 kW 1160 f t PRIMARY glJ STATION FREQUENCY FACILITIES EBS DESIONATION
~~~~ WCVB-7Y Bos ton CH. 5 3 100 kW 988.6 f t PRIMARY ;
W BCN ( FM) Boston 104.1 i 19 kW 740 ft PRIMARY WOBH-TV Boston CH 2 i 50 kW 1040 ft PRIMARY g; WBUP(FM) Boston 90.9 ;
50 kW 260 ft PRIMARY WOBX-TV Boston CH 44 l
251 kW 1090~ PRIMARY WMJX(FM) Boston 106.7 21.0 kW 720 ft PRIMARY WNEV-TV Boston CH 7 l 316 kW 1000 ft PRIMARY gp WZOU(FM) Boston 94.5 i r 7.7 kw 1050 ft PRIMARY WQTV(TV) Boston CH 68 ;
1337 kW 870 ft PRIMARY WZLX-FM Boston 100.7
, 21.0 kW 720 ft PRIMARY WXNE-1V Bos ton CH 25 WMRQ-FM Boston 103 3
- 12 kW 890 ft PRIMARY WSBK-TV Boston CH 38 1170 kW 1180 f t PRIMARY -
WERS(FM) Boston 86.9 3.0 kW 727 ft PRIMARY WLVI-TV Cambridge CH 56 ;
2240 kW 1180 ft PRIMARY gp~
WOBH(FM) Boston 89.7 100 kW 670 ft
- PRIMARY FM STATIONS (con' t)
WDJM(FM) Framingham 91.3 WJIB(FM) Boston 96.9 0.01 kW- NON-EBS 12.5 kW 1010 f t PRIMARY g'-
WVBF(FM) Framingham 105.7 WRBB(FM) Boston 104.9 10. 5 kW 950' f t' ' PRIMARY 0.01 kW 106 ft PRIMARY -
W HH B( FM) Holliston 91.5 0.01 kW PRIMARY !
WFNX(FM) Lynn 101.7 3 kW 300 ft PRIMARY-WMF0(FM) Med ford 91.5
- Stations currently participating 0.01 kW 75 ft NON EBS in the Broadcast Station g 5
Protection. Program (BSPP) WXKS-FM Med ford - 107 9 21 kW 710 ft PRIMARY WMLN-FM Milton 91.5 0.01 kW 100 ft NON EBS 1-6
i METRO BOSTON 0PERAT!ONAL AREA (CONTINUED)
FM STATIONS (Con't) p FREQUENCY FREQUENCY --
RBS DESIONATION EBS DESIGNATION eWROR(FM) Boston . 93.5 WZBC(FM) Newton 90 3
==
5.5 kw 1190 ft ORIG PRI RELAY 1 kW 220 ft PRIMARY g PRI CPCS-1 .
WBRS(FM) Waltham 100.1 W BOS(FM) Brookline 92.9 0.01 kW NON-EBS -,
15.5 kW 880 ft PRIMARY WCRB(FM) Waltham 102.5 WHRB(FM) Cambridge 95.3 11 kW 920 ft PRIMARY p 3 kW 100 ft PRIMARY _-
WM BR( FM) Cambridge 88.1 0.01 kW 45 ft PRIMARY 0.01 kW NON-EBS '-
WUMB(FM) Boston 91.9 WIZH(FM) Concord 88.3 PRIMARY g 0.01 kW PRIMARY WZLY (FM) Wellesley WHAB(FM) Acton 88.7 PRIMARY g PRIMARY WMWM(FM) Salem 91.7
) PRIMARY =
) .
)
1-9
H LOCAL MASSACHUSETTS EBS OPERATIONAL AREA-DETAILS SOUTHEAST MASS OPERATIONAL AREA l BRISTOL AND PLYMOUTH CO l t
AM STATIONS . F_M STATIONS g STATION FREQUENCY !
STATION FREQUENCY FACILITIES EBS DESIONATION FACILITIES EBS DESIONATION WARA Attleboro 1320 WBIM-FM Bridgewater 91.5 :
I kW DA-2 U PRIMARY 0.01 kW 108 ft PRIMARY g!
WBET Brockton 1460 WBET-FM Brockton 97.7 i 1/5 kW DA-N U PRIMARY 3 kW 280 ft PRIMARY l
WATD Brockton 1410 WMCI-FM Brockton 1 kW DA-D PRIMARY PRIMARY g; WALE Fall River 1400 WSHL-FM 91.3 l 1 kW U PRIMARY 0.01 kW 74 ft PRIMARY
'WSAR Fall River '1080 WJFD(FM) New Bedford 97.3 .
5 kW DA-2 U PRIMARY 50 kW 285 ft NON-EBS gl WBSM New Bedford 1340 WMYS(FM) New Bedford 98.1 1/5 kW DA-2 U PRIMARY 28 kW 5,00 ft PRIMARY WJCC Norfolk 1170 W USM( FM) North Dartmouth 90.5 PRIMARY 0.01 kW 72 ft PRIMARY g WNBH New Bedford 1340 WPLM-FM Plymouth 99.1 0.25/1 kW U PRIMARY 50 kW 430 ft PRI RELAY PRI CPCS 1 WPLM Plymouth 1390 WRPS Rockland 91.5 g.
W DA-2 U PRI CPCS 1 0.01.kW 90 ft PRIMARY WPEP Taunton 1570 WCAV-FM Brockton ,
1 kW D PRIMARY PRIMARY WSRB Walpole WSNE (FM) Taunton 93.3 e.
PRIMARY 50 kW 340 ft PRIMARY WATD(FM) Marshfield 95.9 3 kW 220 f t PRIMARY
. e; TV STATIONS l STATION FREQUENCY FACILITIES EBS DESIONATION ;
WLNE (TV) New Bedford CH 6 80 kW 940 ft PRIMARY a Stations Currently Participating in the Broadcast Station Protection Program (BSPP) 0:
1-10 >
)
I LOCAL MASSACHUSETTS EBS OPERATIONAL AREA-DETA8LS
' [ APE & ISLANDS OPERATIONAL AREA BA R_ N ST A BLE , DUKES, AND NANTOCKET CO.
I .
FM STATIONS STATION FREQUENCY FACILITIES EBS DESIONATION t
AM STATIONS
~ WARC(FM) Barnstable 99.9 WEE TIO ft PRI CPCS-2 STATION FREQUENCY FACILITIES
~~
EBS DESIGNATION WCIB( FM) Falmouth 101.9 50 kW 240-ft PRIMARY a WKPE Orleans 1170 1 kW D P. TIM A RY WCOD-FM Hyannia 106.1 25 kW 125 ft PRIMARY WOCB West Y6rmouth 1240 T Ei U PRI :PCS-1 WKPE-FM Orleana 104.7 50 kW 300 ft PRIMARY WKKL(FM) West darnstable 91.1 0.01 kW 71 ft PRIMARY WJ FK f FM) West Yarmouth 94.9 5678 ft -
PRI RELAY PWT 5FCETT WSDH (FM) Sandwich 91.5 PRIMARY-WMVY (FM) Tisbury 92.7 PRIMARY WOMn Provincetown 91.9 1.0 kW 155 ft PRIMARY hXYJ Nantucket 96.3 50 kW PRIMARY 1-11
0;
,, EBS MONITORING ASSIGNMENTS ;
i j
Gh
- 1. The Originating Primary Relay Station WROR(FM) monitors an out of f state major networks (s), j er i
- 2. The Primary Relay Stations in the operational areas adjacent to the l Metro-Boston area will monitor WROR(FM). These are the Merrimac l Valley, Southeastern Massachusetts, and Central Massachusetts opera- 1 tional areas. g!
l
- 3. The Cape and Islands Primary Relay Station will monitor the Southeastern Massachus.stts area Primary Relay Stations. l o!
4 The Connecticut Valley Primary Relay Station will monitor the Central ,
Massachusetts Primary Relay Station.
' O
- 5. The Berkshire area Primary Relay Station will monitor-the Connecticut Valley Primary Relay Station.
.~
e.
I O
0;.
b 2-3 ;
e:
O t
0 ,
O I"*
O ,
MAStiACHUSETTS EMERGENCY BROADCAST SYSTEM O
AGREEMENT BETWEEN THE BROADCAST INDUSTRY OF MASSACHUSETTS AND THE O - NATIONAL WEATHER SERVICE 1979 O
O O
O 30 Appendix 3 0
-() (
PURPOSE i Thepurposeof(hisdocumentistoprovideproceduresagreeduponbythe broadcast industry of Massachusetts and the National Weather Service which l permit designated National Weather Service officials to issue emergency 1
() waather information and instructions in threatened or actual emergencies, t'
AUTHORITY L
Title 47 U.S.C. 151, 154 (1) and (o), and 303 (r)i-Chapter 1, Part 73, !
Subpart G, Federal Communications Commission Rules and Regulations, Radio !
C) Broadcast Services, Emergency Broadcast System (EBS) as pertains to day-to- ,
doy emergency operations.
t IETRODUCTION These procedures were prepared by the Emergency Committee'of the I
() Mossachusetts Broadcasters Association and the National Weather Service. i The Board of Directors of the Massachusetts Broadcasters Association has -
ondorsed this EBS weather operational plan.
This document provides ba:kground data and prescribes specific procedures for the broadcast media and the National Weather Service to disseminate ,
() Gmergency weather warnings and pertinent weather information to the general >
public in Massachusetts, or any portion thereof within a station's broad-cost coverage capability, at the request of designated National Weather SGrvice personnel. The plan also envisions involvement of the broadcast media as may be appropriate in areas contiguous or adjacent to the involved operational area and for other related mutual aid arrangements (Southern :
C) New Hampshire, Southern Vermont, Northern Connecticut and Northern Rhode Island).
Acceptance of, or participation in this plan shall not be deemed as a rolinquishment of program control and shall not prohibit a license from exercising his independent discretion and responsibility in any given
() situation, except for relay responsibilities for certain designated primary relay stations.
Stations originating emergency communications shall be deemed to have con-forced rebroadcast authority (Reference, FCC rules 73 93S (6)).
C) A system of FM radio stations has been set up to enable the state-wide dissemination of information regarding threats to the safety of life and property inclading weather warnings and severe weather information. These designated primary relay stations are shown on the map on figure 1. (Page 3-7)
Acceptance of this agreenent does not prevent formulation and acceptance of O agreements between the broadcast industry, the Massachusetts Civil Defense sgencies and local officials concerning EBS use during non-weather emergencies; le, nuclear accidents, toxic gas spillages, etc. This docu-ment pertains only to the various weather emergencies and procedures agreed to by the broadcast industry and the National Weatner Service, nor does it prevent or discourage participation in the EBS plans of other states in
.() areas wnere local radio coverage spans into the adjacent states; for example, radio station WHYN in Springfield should continue to monitor the Connecticut Primary EBS Station in addition to the Massachusetts Primary Relay Statin to provide its listeners in Northern Connecticut with cmergency weather information.
O 3-1
O.
GENERAL PROCEDURES FOR THE USE OF BROADCAST FACILITIES A. When a short-fuse weather warning is issued by the National Weather g Service (NWS), the NWS will notify the Massachusetts Emergency Broadest ;
(EBS) Primary Relay Station, radio station WROR-FM in Boston, or, at the options of the NWS, the operational Primary Relay Station / Common Programming Control Station (CPCS-1) in a more local area if the emergency warning applies to that area only. See Fig. 2.
- 2. Short-fuse weather warnings will .be defined as: O 4
- a. Severe thunderstorm warnings
- b. Tornado warnings .
Of
- c. Warnings of flash floods, or extensive small river, stream and street flooding ,
- d. Warnings of a raridly developing major severe winter storm, and
- e. Hurricane warnings (under certain conditions such as a rapid O; change in movement or direction).
B. Responsibility for the request of the emergency broadesst system acti-vation during weather events will rest with the Meteorologist-in-Charge (MIC) of the National Weather Service Forecast Office in Boston or the Official-in-Charge of the National Weather Service Office in Worcester or designee. O C. It is incumbent upon the primary relay stations to relay warning infor-mation whether or not said warning is relative to that station's listening area to ensure complete distribution of warnings. The National Weather Service, in turn, will make every attempt to activate only that portion of the state's EBS directly concerned with the warning area to minimize O;-
relaying responsibilities. (See Fig. 2 Page 3-8)
The EBS primary relay stations are: .
WROR(FM) Boston O WSRS(FM) Worcester WFCR(FM) Amherst WPLM(FM) Plymouth WCGY(FM) Lawrence WOCB(FM) West Yarmouth WBEC(FM) Pittsfield gy D. When severe weather watches and warnings are issued by the NWS, radio and television stations in Massachusetts can receive hard copy of the watch or warning over any of the following teletype networks:
NOAA Weather Wire (Massachusetts Weather Net) O Associated Press (AP)
United Press Internation (UPI) ,
3-2 9
)
l l
- l 4
g E. Communications between the WWS and the broadcast facilities include commercial telephone service both listed and a media-only unlisted telephone line.
3 4
I
{
i 4
3-3
C/
N ATION AL WE ATHER SERVICE PROCEDURES ,
Upon issuance of a short-fuse warning (as derind on page 2), activate the Massachusetts EBS using the following procedures:
- 1. Call the Primsry Relay or Common Program Control Station (CPCS-1): 8>
- a. If the warning is issued for a certain small portion of the state only (ie. The Berkshires, or the Merrimae Valley), activate the EBS ;
for tnat portion of the state through the CPCS-1 in that sector.
(See Fig. 2)
- b. If the warning af fects several continguous areas (ie, the l Conne:ticut Vallny and the Berkshires) activate the Primary Relay .
Station in the affected ar'ea which is closest to Boston (or Worcester). In the case in which both the Connecticut Valley and the Berkshires are af fected, activate the EBS through WFCR(FM) in Amherat or the backup station WHYN in Springfield) %.
- c. If the Greater Boston Metropolitan Area (GBMA), or GBMA and one or
~
or all of Massachusetts is within the weather I more warning, activate the E through WROR(FM).
contiguous areas, E3 If Worcester County or Worcester County and the Connecticut Valley is within the warning, GL activate through WSRS(FM) Worcester.
- 2. Give the authentication code which is the current month and da te.. . . . .
i le...... April 10th....May 22nd.....etc.)
"THIS IS JOHN DOE, METEOROLOGIST AT THE NATIONAL WE ATHER SERVICE IN BOSTON (WORCESTER) WITH A REQUEST TO ACTIVATE THE MASSACHUSETTS II EMERGENCY BROADCAST SYSTEM (OR PART THEREOF). I AUTHENTICATE AS FDLLOWS. . . . J UN E 10 TH" 3 Describe briefly the situation requiring EBS activation.
4 When given the go-shead, read the warning message and include safety II ;
actions which should be taken.
- 5. Follow through with frequent timely statements to keep the public fully informed of the site ion - each time activating the EBS system as in '
step 1 through 4 above.
- 6. Terminate as soon as conditions warrant.
Telephone numbers of the CPCS-1 Stations Primary CPCS-1 Stations 236-6841 8>
Greater Boston WROR(FM) Boston Merrimac Valley WCCM /W C0 Y (FM) Lawrence 683-7171 '
Southeast Massachusetts WPLM/WPLM(FM) Plymouth 746-1390 Cape Cod and Islands WOCB/WJ FK ( FM) West Yarmouth 775-0500 l Central Massachusetts WSRS Worcester 757-6321 Connecticut Valley WFCR Amherst 413-545-0100 l
l The Berkshires WBEC/W BEC( FM) Pittsfield 413-499-3333 8']
Ba c k up Stations Central Massachusetts WTAG Worcester 793-9400 l Connecticut Valley WHYN Spring fi el d 413-739-6338 l Cape Cod & the Islands WQRC Barnstable 771-1224 Southeast Massachusetts WMYS New Bedford 996-3371 8'],
na . . -.
l
O ;
BROADCASTPROCEDkES L 1
A. Upon rec 51pt of a request to activate the EBS, the control operator at the j
,O Primary Relay or C,PCS-1 station will proceed as follows: )
1 Activate the taping device
- 2. When ready, give the go-ahead to the Weather Service personnel and tape the warning message 3 While taping the message, transmit the Emergency Broadcast System atten-tion signal (FCC Regulation Part 73, Subpart G, 73, 906)...and...
4 Broadcast the following announcement:
l) "WE INTERRUPT THIS PROGRAM TO ACTIVATE THE MASSACHUSETTS EMERGENCY BROADCAST SYSTEM AT THE REQUEST OF THE NATIONAL WEATHER SERVICE. IMPORTANT WEATHER INFORMATION WILL FOLLOW."
- 5. As soon as the message taping is completed, broadcast it '
O 6. Repeat, if necessary, including the source and time of the message. .
B. Each Primary Relay station, as they receive the taped message, will follow the above procedures broadcasting the warning information to their listening area and to their respective stations and, at the same time, relaying the message to the next area. (In general, the Massachusetts EBS is set up to O relay messages from east to west across the state; le. a message from the NWS at Boston will be transmitted first to WROR(FM) in Boston, then to the relay station at Worcester - on to Amherst and finally to Pittsfield).
C. Local broadcast stations will, as soon as the message is received and taping completed, follow the procedures from A-1 through A-6 above to complete O the total distribution of the warning to all listeners within the state.
l 1. To avoid unnecessary public confusion, all broadcast stations I must be cautious in providing information and news pertaining i to the emergency. Do not broadcast rumors; make every effort I
to verify reports of severe weather before broadcasting. All O messages must be based on derinite and confirmed facts.
L. Frequent follow-up messages will be broadcasted by the NWS to keep the public fully informed of tne progress of the storm. The apove procedures should be used in all subsequent message distribution.
O E. Upon completion of the weather emergency, the NWS will activate the EBS for the all-clear announcement and stations snould then make the following announcement:
"THIS CONCLUDES OPERATIONS OF THE MASSACHUSETTS EMERGENCY BR ADCAST SYSTEM. WE NOW RESUME NORMAL BROADCAST OPERATIONS."
O 3-5 0
i f
Ol
[
v Fo Appropriate notations should be made of all significant events as they transpire. Tnese records should be carefully preserved in the event that are required at some later date.
Si Go Send a very brie'f summary to the FCC for informational purposes only, i f
f g+
9 Gi 9
9, P
h 5
9 l
\
i 9;
3-6 :
Gir
[
i k
h 9!t i
O MASSACHUSETTS STATE WETWORK (FM)
O .
O t.......
- WCGY \
s FM 93.7 i, '
g O w .i J ' *s .
au FM lt.l.5 .
7
- , WSRS
, -: ' " ' ' ' ( -
FM 98.8 Amhere. ,
WFCR . 'l w #
,e FM 8 8.8 V " s, '
O ! ,,'t ', f'
/.' <
- b. ' , a Plymouth '
s ,M ...
.w e 0
N, -
.. .. .. .m.. .s1 F 49 O
O O
O N r.1 0 37
O!
I MASSACHUSETTS OPERATIONAL AREAS l i
. ej r
~
IR MRIMAC VALLEY. '
f 1 CENTRIC' MAS $'~~l d Ql'RKSHIREl
? .....
Feenhiln l e t
- IMETRO BOSTOW ] O' Wattestet MiddI"
l it e m p shir e ISO f g g i
n e e n shir e .
. .3.>
, u.,i.in
{ li m, den ,i t
YNNECTICUTVII~EIb b s ele t*>l Pte .h i( '
q d
~
~'50VTH EAST MAkT C ' **
./ 1
' ', / ICAPE & ISLAN C '
/4$
Nentuck'l e
O!
CPCS-['"~~ PRI RELAY BERK SillitE WI)EC /W lir.C-t M WBEC-FM CONNECTICll'l V ALI.EY WFCH (FM) WFCR (FM) ,
i CENTRAL, MASS W SH:1 (FM) WSRS (FM) g3 '
MERRIMAC VALLEY WCCMiWC(iY (FM) WCGY-(FM)
METHO B0:iTON WllOlt - ( FM ) WHOR (FM) J SOUTH EAST MASS. WPl.M AM.'Fil WPLM-FM i l '
CAPE AND ISLANIO WOCB( AM) /WJFK FM) WRZE (FM) i no R . ::
l
.0; t
- 1. W :
. . . - . . . _ . _ _ . . . , . _ . _ . _ _ _ . _ . . . _ . . _______ _ _.____ _ _ _ ___.____ _ _ _ ____ _ _ .._______.____I
O MASSACHUSETTS EMERGENCY BROADCAST SYSTEM (EBS) ATTACK WARNING SCRIPT O ~
THIS SCRIPT TO BE RESERVED FOR USE IN THE EVENT OF ATTACK WARNING (OR ACCIDENTAL NUCLEAR MISSILE LAUNCH) -(EDIT AS NECESSARY).
() THE MASSACHUSETTS EMERGENCY BROADCAST SYSTEM (EBS) HAS BEEN ACTIVATED BY THE MASSACHUSETTS STATE WARNING POINT TO BROADCAST THE FOLLOVING WARNING INFORMATION. (PARAPHRASE OR SIMULCAST WROR's MESSAGE) THE
- 6) NORTH AMERICAN AIR DEFENSE COMMAND, (NORAD) HAS JUST DECLARED THAT THE UNITED STATES IS UNDER (ACCIDENTAL) ATTACK AND THAT CITIZENS SHOULD TAKE PROTECTIVE ACTION IMMEDIATELY! THIS MEANS THAT THE
() POSSIBILITY OF NUCLEAR WEAPONS STRIKING THIS COUNTRY IS IMMINENT AND RESIDENTS SHOULD SEEK SHELTER IMMEDIATELY!
SIRENS MAY BE SOUNDING IN YOUR COMMUNITY AT THIS TIME...IT IS NOT A O
FIRE...IT IS A WARNING THAT THIS COUNTRY IS UNDER (ACCIDENTAL)
ATTACK. YOU ARE TO SEEK SHELTER AS BEST YOU CAN, INCLUDING IMPROVISED BASEMENT SHELTER OR PUBLIC SHELTERS. THIS ANNOUNCEMENT HAS BEEN VERIFIED. THIS IS NOT A TEST... CITIZEN ACTION IS URGENT AND NECESSARY. IF YOU PLAN TO USE YOUR HOME AS A SHELTER, TAKE THE FOLLOWING ACTIONS IMMEDIATELY.... DRAW WATER RESERVES IN T"E BATHTUB, LOCATE FLASHLIGHTS AND BATTERIES FOR PORTABLE RADIOS, DRAW WINDOWS AND SHADES, RELOCATE FAMILY TO THE BASEMENT AND '.ISTEN FOR OTHER PROTECTIVE MEASURES TO BE BROADCAST BY THIS STATION.
O u-,
O' i
O
.- MASSACHUSETTS EMERGENCY BROADCAST SYSTEM SCRIPT SEQUENCE 9
STATE TESTS 9
SCRIPT FOR MASSACHUSETTS STATE LEVEL EBS TESTS THIS IS A TEST. THIS STATION WILL CONDUCT'A TEST OF THE MASSACHUSETTS EMERGENCY BROADCAST SYSTEM. THIS IS ONLY A TEST. 9 (25 SECONDS OF SILENCE FOR THE EBS TONES) 9 THE MASSACHUSETTS CIVIL DEFENSE AGENCY HAS REQUESTED THIG TEST OF THE MASSACHUSETTS EMERGENCY BROADCAST SYSTEM. THE BROADCASTERS OF YOUR AREA IN VOLUNTARY COOPERATION WITH THE MASSACHUSETTS CIVIL DEFENSE AGENCY AND OTHER AUTHORITIES, HAVE DEVELOPED THIS SYSTEM.TO KEEP YOU. INFORMED IN THE EVENT OF AN EMERGENCY. HAD THIS BEEN AN 9 ACTUAL EMERGENCY, THE ATTENTION SIGN AL YOU JUST HEt.RD WOULD HAVE BEEN FOLLOWED BY OFFICIAL INFORMATION, NEWS OR INSTRUCTIONS. THIS ,
l STATION SERVES THE (insert name of) OPERATIONAL AREA.
THIS CONCLUDES THIS TEST OF THE MASSACHUSETTS EMERGENCY BROADCAST SYSTEM. 9 9
9 5-1 8 9
l l
O dFFICI ALS AUTHORIZED TO ACTIVATE THE STATE EBS O .
The following is a list of officials authorized to activate the Massachusetts Emergency Broadcast System.
() JURISDICTION TITLE NAME g Massachusetts Governor Michael S. Dukakis Massachusetts State Civil Defense Director Robert J. Boulay Masachusetts (or Deputy Director) John L. Lovering O Massachusetts State Civil Defense Area Directors Area I - Northeastern Mass. Act Dir. Kevin Tully Area II- Southeastern Mass. Tom Rodger Area III-Cehtral Mass. Act Dir. Henry Gamache Area IV- Western Mass. John Pappas O Massachusetts State Police Commissioner Federal Nat.onal Weather Service Chief Duty Officer Q
Any questions concerning this plan should be directed to the Operational Area Co-Chairman. Area Co-Chairman will obtain guidance from either of the state level Co-Chairman, namely:
- Douglas J. Rowe 21 Cotting Street Marlboro, MA 01752 Telephone: (617) 485-5555
- James Bayley 403 Main Street Norwell, MA 02061 Telephone: (617) 659-2106 8
9 6-1
1 I
a i
AUTHENTICATION INSTRUCTIONS FOR THE i MASSACHUSETTS EMERGENCY BROADCAST SYSTEM GH j
j O
\
In the past, requests for activation of the Emergency Bros /, cast !
' GI System (EBS) would be accompanied by the authenticator code words as .
I distributed by the Federal Communications Commission (FCC) at six month ,
intervals to all radio and television stations. Recently, the FCC has l 9:
requested that we refrain from the use of these code words as they are j I for use at National level tests only. Therefore, should a radio or TV ;
station receive a phone call for EBS activation and the caller is ,
unknown, or'that the station may have reason to suspect it is a faudu-lent call, an immediate phone call to the calling organization (Civil ;
Defense, State Police, National Weather, etc.) and to the individual who .l placed the original call should be made and the emergency situation t
verified. For this reason an updated telephone-lis.t of the agencies .
r responsible for EBS activation abould be readily available.
9 e
l l
7-1 61 4
)
l l
l s MASSACHUSETTS STATE EMERGENCY COMMUNIC ATIONS COMMITTEE The State Emergency Comunications Committee (SECC) Co-Chairman are appointed by the Federal Communications Commission (FCC) and are as follows:
Douglas J. Rowe, Co-Chairman 21 Cotting St.
Marlboro, MA 01752 MASSACHUSETTS OPE!;ATIONAL AREA EMERGENCY COMMUNICATIONS COMMITTEE The Local Operational Area Emergency Communications Committee Co-Chairman are appointed by the Federal Communications Commission (FCC) and are as follows:
BERK 5 HINE OPERATIONAL AREA - Berkshire County Don a l .1 Coleman t Co-Chairman Paul Willey, Co-Chairman BBHK WMNB 8-1
f Ol
. CONNECTICUT VALLEY OPERATIONAL AREA-FRANKLIN, HAMPSHIRE ,
AND HAMPDEN COUNTIES
.i C,harles Ferguson Co-Chairman Paul Donovan Co-Chairman WFCR WHYN !
9; l
CENTRAL MASS OPERATIONAL AREA-WORCESTER AND St PART OF MIDDLESEX & WORCESTER COUNTIES ;
l 9 '
John Andrews Co-Chairman John Flynn Co-Chairman WTAG WSRS 9-MERRIMAC VALLEY OPERATIONAL AREA-PART OF ESSEX AND MIDDLESEX COUNTIES ,
1 Ike Cohen Co-Chairman Steve Boudreau Co-Chairman gj
~
WCAP WHAV I
l ?
Of i
i 8-2 0
p - .-,V, -
n - , - - , =.
()
l METRO BOSTON OPERATIONAL AREA-SUFFOLK COUNTY !
, i AND PART OF ESSEX, MIDDLESEX AND NORFOLK COUNTIES l
)
. l
_, __Co-Cnairman Paul Hurd _ _Co-Cnairman f
) _
WHDH v
0 SOUTHEAST __ MASS. OPERATIONAL AREA-BRISTOL AND PLYMOUTH [0 UNTIES ,
O Paul Doherty 00-Chairman Co-Cha i rinan i WPLM ,,,_,__ __ ,_
C C APE AND ISLANDS OPERATION AL AREA-BARNSTABLr;,
() DUK S AND NANTJCKET COUNTIES
$) Douglas M. Shackett Co-Cnairman Joseph Jarioura Co-Chairman I WKPE WCIB I
6-s g
.._% 4 2 . 4p br - w ,4---g- .a. u. .~. - - - a -- p o
, CABLE 7.V.
I hl I
l q
i 1
f 41 J
i i
i Si I TO BE DEVELOPED AT A LATER DATE
+
h E
9'..
e e
b t
t i
k 1
4 9-1 .
Oi
- s e n ----, av- ,- - - . - v - -- .- - --e
).
D APPROVAL SHEET
'D APPROVED:
b il 'd. N' 3 3 -//-f b Robert J. Boulay, State Director Date Massachusetts Civil Defense Agency se t ur = >
) James Bayley
'.-88
- 1. ,, * */// - t Co-Chairman, State Emergency S fgn'a tu re Date Communications Committee s
/ Douglas J. Rowe
/
-~w- " / 7 ='f. z, / /.
., Co-Chairman, State Emergency si Signature D'a tt Communications Committee I
10-1 )
y eit -w~.w. e.4-.a a.--.a.w - A ad---swiawew - -- am' A .das ,W c e--es-.g ,--45 e a 4-i+ep--ad 4- a w A sa N'sA-e4 4 3-as a4e.A-.u-We TJ 4 4
- M. ._maE. A f
O!
l e
- 6
'j l
e 4
.g.
el 1
a 1
mi 1
1
. l t
1
'l .
O' 1
. '1 S
l l
l
-' $l!
.1 t
9
A-O A'^'" - *== A-er 444a-' ='"%-"^ +J d F-&4 -~"^L*'96# l** 4 'KKd-"-7&^- e*A4. 3A-' e-WS-~ '-""A"vb---4a-^" *--" 44W a =
s ~~-== ~~
'ev'6a,a-,
f
?
o- 1 4
4 i
LO ' ,
s
?
a I
' \
' 0: -t 0
l' k
O b
ATTACHMENT E
~
lO-i a
t l'
O' l0 l
l O
Q-0 -
O County R@ port 1989 Edition Radio County Coverage Fieldwork Conducted 1988 t' t999 i% Artit+ea r.empey .
O MASSACHUSETTS COUNTY: HOME 44010 WETROS:
Elsta 90$t04 PO*VLAfl0N 12 +: lit 900 IN-TAS: i.530 TSLtvitt0N ADI:
90510N ETMNIC WGT: NONE 8800896 7 . Sefestav , esempa t . 8uesta t gg esad . effp taas . Few WTAttget SOWertv/St&TI SP Liettegt (gp ave avg seen Civ See f (De uTU *"W3R Ctt Sedh DOWTON O ween.e sver0LK m. ei2 te.. i.2 s.: i4.6 eie is.4 - i. ... 44 .
wl'et 848tr MA 111 2.0 ,1 .6 100.C 11J 2.C 1 6 100.0 w506.F NORf0LK MA 341 6.1* .4 2.3 11,3 326' t,$ .5 2.4 11.3 WO! .A Surr0LK W 1903 19.8 1 ? 9.0 ft 3 999 13.0 t.t t t- 16.0 WDCM.A 385t* Me 260 4.t 3 1,4 33 3 tif 46 .3 S.5 94 ?
w00Y.i ESSEX Ma 509 9.2 .t 2.0 24.5 463 8.3 f 2.8 It 0 18C89. t WIDDLElts Wa 192 3I .2 9.2 9I stl 3,t 2 -. .t y; WEE 1.A SUFrc;K MA 763 13.7 .? 3.8 94.2 696 13.5 8 3.7 13 ?
O wis>.A EssEx wt28.A SVFFOLK MA A 3r> ...
1.2
. 2. 3 - 'e0.0 3*3 6.1 .. 2.4 ice 0 69 . .2 12.5 St 1.0 . 2 16.8 wrNx.r gggtx eAA 167 3.0 .2 1.2 14.3 146 2.6 .2 1.' to 4 WWAve4 ESSEE HA 74 1.3 .i .3 SCC.0 70 $.3 .* .3 1C0 C WNDH.A SVfr0LK WA 535 9.f 6 2.6 9.? I 421 ?v S 24 68 wJ18 8 $Urr0LK Ma .593 10.7 '
i S9 15.2i l?9 to14* 1.4 t.3 16.6 weLN.a w!D0Lt$ty ua S9 t,1 .
3 800 0 55 2 1CC.C w6vi.F ESSEI Ma i 225 40 3 1.6 37 8 4 1.6 38.6 O wusa.r surr0LK ua -
esi e., e 2.e $2 3 - 215, 43 3, 9
+ : 4 it i w005.' turr0LK MA 021 14.0 t t) 53 10.7 *tt 14 0 11 55 '2 ?
wo kw.* #LynCUTH ha 131 2.4 1 8 E.7 103 19 2 8 2
tenKO. A SuvPOLK WA 954 15.4 1.2 6.t 14.1 797 14 2 9I ( t ta * ,
wa06.A susFCLK MA 13a' 2.5 t .? 19.4 138 25 *
.5- 19 4 i wuon.s .5uFFOLK MA $72 10.3 .6 3.4 13.5 . 646 9.6 36 's 1 i-wSSw.A SVPFDLK Ma 110 2.0 .$
.4 30 8 3 1C7 1.9 . ' t 32 3 l witw.B W1DOLISEX MA 1079 19 4 '
9.C 27.6 ' $C23 16,4 21 9.3 2' '
- O uve'.- uico.esEr wrus.A W100;t$ta
= 3ie 6.4 4 2.4 i3
- i 3si e. t : i 33 ;
- Ma 198 3.E 3 1.4 -t7.5 195 3f 3 5 *? t I wxKS.8 W100 LESER ut 846 15.2 $C 5.3 15 e. ?*l 14.3 1 ' t.1 5 j w2Lx.F Suf80LK ma 461 6.3 6 3.0 10 4 434 T.6 1 3C *t 4 l W200.F SV880LK w 960 17.3 1.1 5.8 13.4 895 18 1 12 14 12 E WETRO SHAmt 03NTRIBUT10N 98.1 , Bt 3 O uaNcNEem I .
wGla.F HILLS 80ROUGu W Set NN 75 1.3 . .2 2.t I 96 1.0 - 2 i7 w!!D.F HILL $90 ROUGET M SPT NN 69 I.2 1 .3 3.C ft 1.2 .t 3 3 '
WETRO SHARE CONTRIBUTION 5 .5 P0stfLANO, WE weecu.F 030$ WE 69 1.2 1 .3 2.2 66 1.2 . 2 10 I k l !
utTmc SNARE CONTR19UTION .3 g 2
pocr19MOUfW.00Vfm.aDCHESTER WHEB.F 90CKIN3 HAM REw Nw t 130 2.3 2 10 t$ 6 121 22 2 9 14 3 trwo.F sta stosto Nw 222 40 .3 1.' 11.9 , tic 38 4 7 '2 '
WETRO ENARE CONTRIBJTION 2.5 2.6 9 '
i AntBtTMON 9 a ATTACHMENT E
CSunty R pgrt .o!
1989 Editi3n Radia Csunty Cevcrago Fieldwo.r.k ,~AConducted C-, 1988 MASSACHUSETTS O! ^
COWTY: Wout atDIO Mtf#DS' .
Ettta ~305ftm 8'OPJLATION 1t
- a 665.900
. tw.fot: 1.030 T... 0 = r DOSTON tTWWic woT4 NONE t
e~
.e,.o 7' : l '"' "*ts' : 2. "' . -
statsom ' oowwevreeste er weswer O Rb eve ese iHi 596 It[k ett see
((I3N1INUED) ,
woncasten CAar.* sOnctsite we 39L!? eaa . 333 g.1 .3 1.3 4.9 270 4.3 .3 1. ! ' 4.1 g1 wxLC.F WORCESTtt Rtu naa to. 1.8 . .2 2.5 st 1,4' . .! 2.9 METRO shame CCMTRIBUTION 1.5 1.4 NO*WETao i WWOS.F MILLl50ROUOM Rtw asas 130 2.8 .2 i.0 19.9 113 3.0 ,7 .9 17.2 NQh. METRO $ Meet CONTRIBUTION 1.0 .9 'g f-CTNERS 6.0 C.3 COUNTY TOTALS CUWE (00) 53?1 OUWE 100 535' CUME 470 96.6 CUut RTO 96.3 AQH ( 00 ) 1036 Aod (001 Itti-1 .l
- e e
?
O' l
l MSSMO*d 9
ar c:
e 4
0--
O-O I
O '
i 1
-ATTACHMENT F 0
0 a ;
O ,
Q 0
4 0- .
O?
1
() UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judges:
C) -
Ivan W. Smith,-Chairman Dr, Richard F. Cole
'Kenneth A. McCollom O
)
In the Matter of ) Docket Nos. 50-443-OL
)- ' 5 0-4 4 4 -OL _- l PUBLIC SERVICE COMPANY )
(). OF NEW RAMPSHIRE, EI &L. -)
)
(Seabrook Station,-Units 1 and 2) ) October 27,~1989-
)
0 -
AFFIDAVIT OF JOHN F. BASSETT REGARDING THE VOIDING OF THE EBS LETTERS OF AGREEMENT I, John F. Bassett, being duly-sworn, state as'follows:
() -
- 1. I am the manager of WCCM'(A.M.)/WCGY (F.M.) ("WCGY") l located in Lawrence, Massachusetts. WCGY is the primary relay, l or lead-Emergency Broadcast System ("EBS") station, for the 0
Merrimac Valley operational area of the Massachusetts EBS. In ,
the operational plan for the Massachusetts EBS WCGY is designated as the CPCS-1 station that has responsibility for C)
- activating the EBS in the Merrimac Valley operational area. .!
That activation is implemented by WCGY transmitting the EBS I
attention signal followed by an informational message which is O
received by tone alert radios at the other Merrimac Valley EBS stations. WCGY takes its role as the CPCS-1 EBS station for the Merrimac Valley seriously and, in addition to regular O
ATThrHMENT F
O participation in the EBS testing program, has assumed I responsibility'for keeping itself operationally current by-investing-in additional equipment including EBS recording devices and a back-up power supply source. 4
=
- 2. It was pursuant to WCGY's serious commitment to the EBS that I signed a letter of agreement on September 14, 1987 with New Hampshire Yankee-(NHY). (Exhibit A).
The-Massachusetts EBS 9 had recognized the NHY Offaite-Responsa Organization ("ORO") as-a responsible local organization within the meaning of the rules and regulations governing the,EBS.- In light:of that- $
recognition, WCGY agreed to activate the EBS-serving _the Seabrook Emergency Planning Zone-in the event that there vas an emergency at Seabrook' Station'. In return, through its agreement 9 made with the Massachusetts EBS,.NHY committed to provide WCGY with certain-equipment including a dedicated phone line and radio link that could be used to communicate with NHY'in the 9 event of an emergency at Seabrook Station. While WCGY has eight outside telephone lines, in the normal course of' business on active news days those phone lines at times are all busy. 9
- 3. Despite the fact that NHY committed to providing that
, equipment to WCGY over two years ago, to date none of the equipment has.been forthcoming. While approximately_a year ago, #
WCGY engaged in discussions with a communications contractor sent by NHY, ALLCOMM, NHY never followed up in providing the promised equipment. 9
- 4. In late September 1989, I learned from Douglas J. Rowe, the Co-Chairman of the Massachusetts EBS, that NHY now took the position that they would not. provide any :of the promised 9 'l equipment to WCGY, or any of the other EBS stations in the
j a
'O,
.g - Merrimac Valley. I was informed by Mr. Rowe that EBS no longer recognized'the NHf ORO as a responsible local organization within tho'means of the rules and regul'ations governing the-EBS. I was also informed that the Massachusetts EBS was voiding the letter'of agreement'that it had entered into with NHY, and I.
received a copy of Douglas Rowe's letter withdrawing the
- O- Massachusetts EBS from participation. in NHY emergency planning. - !
l- (Exhibit B). -
- 5. In light of the Massachusetts'EBS withdrawal and NHY's .
- O failure to live up to its letter.of: commitments to WCGY, I sent NHY a letter dated' October 20,--1989 (Exhibit C) voiding the ;
letter of agreement'that I had signed on September 14, 1987 and withdrawing WCGY from participation-in emergency, planning with NHY. While I am aware of the'90 day termination clause in the letter of agreement, I consider the withdrawal and-cancellation ~
of that letter of agreement to be effective immediately because ,
of NHY's failure to live up to its commitments under the letter. In any event, under the-language of the letter of agreement, the termination is certainly effective 90 days from October 20, 1989.
The foregoing is true and correct to the best of my -
knowledge and belief.
/
% (cMfD John F. Bassett 9 >
( SubscriheJ and sworn to before me t a 27 day october, 1989..
J -
LL /m/ +
Notary Public,
-My Commission EWpires:
O 9
A LETTER OF AGREEMENT BETWEEN RADIO STATION WCGY AND NEW HAMPSHIRE YANKEE'S OFFSITE RESPONSE ORGANIZATION Purpose db r To activate Emergency Broadcast System as Provided Title 47 U.S.C.
G, 151, 154 (1) and (o), and 303 (r); Chapter 1, Part 73, Subpart Federal Communications Commission Rules and Regulations, Radio Broadcast System (EBS) as pertains to day-to-day emergency operation and to provide for cooperation and coordination between New Hampshire El Yankee's Offsite Response Organization (NHY/ORO) and the management of g radio station WCGY 93.7 FM, Lawrence, Massachusetts, in the event of
~
an accident / incident at the Seabrook Nuclear Power Station (SNPS) in Seabrook, New Hampshire.
Scope of Activity of WCGY: $
~
The management of WCGY, Lawrence, Massachusetts, (when requested) agrees to activate the Emergency Broadcast System for the
~
Emergency Planning Zone located within the Commonwealth of
_- Massachusetts which consists of the following six (6) communities:
Amesbury, Merrimac, Newbury, Newburyport, Salisbury, and West Newbury. Ib The management of WCGY further agrees to activate 'vhen requested) the tone-activated radios supplied as part of the puolt:
notification system and broadcast emergency public information wnen notified to do so by the Offsite Response Director of the NHY/ORO, using a pre-arranged authentication system. GP WCGY further agrees that they have and will maintain a recording capability to record the actual voice of the NHY/ORO Offsite Response Director, and they will broadcast the message, acceptance of/or participation in this plan shall not be deemed as a relinquishment of program control and shall not be deemed to prohibit GB the licensee from exercising its independent discretion and responsibility in any given situation.
WCGY further agrees that the'NHY/ORO Offsite Response Director is authorized (through a pre-arranged authentication procedure) to activate the Emergency Broadcast System servicing the GP
=
Seabrook Emergency Planning Zone area in the event that there is an i
accident and/or incident at the Seabrook Nuclear Power Station with off-site consequences.
, The NHY/ORO Offsite Response Director will notify the management of WCGY when to activate the tone-alert radios and when to 4>
! begin broadcasting Emergency Public Information messages. The context of these messages and the interval at which the messages will be repeated will be supplied by NHY/ORO.
This agreement becomes valid when signed by the signatures indicated below. Once valid, it can be terminated by either NHY/ORO II i or the management of WCGY by written notification ninety (90) days EXHTBTT A
.____ _.-__.._..,__ ___. .. - . _ ~ . . _ _ . . _ _ . . . . . -
- i i
O.
l r
.)
1
)
- O- +
prior to the date of termination, '
4 0 / (k ,
{hs-& '
George ps Thomas ' A nager Vice President of Production HCGY 93.7 FM New' Hampshire Yankee Division of Public Service- '
O Company-of New Hampshire agent.for the seabrook .
Joint owners b
$. .. . r .-
fD7"m,/p57 Date Date O.
O ,
S O:
h O '-
O ee Great Radio.. .
PO Bos $66 + 48 Fitchburg St Marlboro. Massachusetts 01752 e (508) 4B5-1470
%* October 13, 1989 g
an g 8 R. Boyd, Jr.
Mr.
888 I Performance Services Manager r Sql P. O. Box 300 pi Seabrook, NH 03874 S I
Dear Mr. Boyd:
i Your letter of September 20, 1 0 H ') , i:. not a ccu r.i t e' ' IL $
attempts to describe a meCting br'I. w r 7 st ut.. If you will recall, at the end of that meeting there was no spirit of cooperation.
I said to you that as Co-Chairman of the EBS Systems in Massachusetts. I was going to withdraw my letter of September GD 14, 1987. In fact, a copy of the letter I intended to send you was FAX'D to you on SepLcmber 20t h qivinq you thr furthrr opportunity to review the commitment made by Mr. Thomas.
After telephone calls and a request by N.il.Y. to delay the withdrawal, I agroed. It was understood that the reason 9 for the delay was N.H.Y. was to submit a revised commitment.
Your plan as submitted to NRC includos the EBS System.
You now say, and I quote, "IF the Morrimac Valley E.B.S.
Network is, utilized."
O I still remember the dayn of N.ll.Y. a s':ing Mr . Bassott of WCCY and myself to sign. " quick instant" drawn agreements with the intent of complying with FEMA requirements. My recollection was that the FEMA regulations recuire nuclear plants to cooperate with and be integrated with the E.B.S. System. As I tried to tell you at our meeting, there was an intent to put gp Massachusetts residents on equal rooting wi th New llampshire residents. Mr. Cat.ipano a :,:, o r e < l me t.h a t he w ou l ci install a system in t h t' Me r r i m.u - Valley < e in : . i :; t a n t. with t. h e .y:.Le m described latcr in the attached IcLter.
To my disappointment, the CPCS-1 station WCGY "the gateway" to g Massachusetts, has not received the committed eqmipment or services, not to mention the other stations of the Merrimac Valley. Your selection of WLYT as a source to activate specific receivers is well intentioned and commendable, but does not activate the E.B.S. System. l Ol
. SeMag the Affluent Suourbon Morket Between Bosten onc Worcester 24 Hours o Day
i i
1
[
' +
]
l
. 1 1
- l Your letter indicates.a total lack of understanding of the-E.B.S.
System. WLYT does NOT trigger a notification to the general
) public.-It triggers only YOUR system. The many radio stations serving the general public would receive NO notice. Your idea that the media:would decend.on your media. center is perhaps
-accurate, but FEMA and the E.B.S. System do not' work by press release. FEMA regulations involve agreements with_CPCS-1 stations .,
and coordination with state emergency E.B.S. chai rmen . I suggest.
you review the regulations. ;
My most disappointing thought about'your letter is that you say. ;
, that N.H.Y.'s commitment concerning Public Notification was ~
negotiated. Can you please tell me when, where and who negotiated away the ri'ghts of the general public ?
As you can read from the. attached copy, which'was previously FAX'D to you, I said that I had rev.iewed your plans.and determined that N.H.Y. was a " recognized responsible" ,
organization. In view of the apparent change in. attitude of-the operators of N.H.Y. , I now formally submit withdrawal 4
authorization, dated September 20, 1989, and I am sending a copy
- of this communication to the CPCS-1 station WCGY.
very truly yours, h--
Douglas J Rowe v1 ?
Co-Chairman '
Massachusetts Emergency i Broadcast System ATTACHMENTS; +
! A. Letter of withdrawal 9/20/89 l B. Co-Chairmans EBS letter 9/14/87 C. WCGY letter 9/14/87 D. All CommSystem Plan & Letter dated 11/14/88 E. N.H.Y. let ter' 9/29/8 9 l cc: WCGY l
l l
l l
l
i O!
7 .
. V Oc tober 20.-1989 '
Mr. B. Boyd, Jr.
Performance Services Manager ' )
I P.O. Box 300 Seabrook, New Hampshire 03874 .
4;
Dear Mr. Boyd:
r l I have received a copy of the letter of Octobar 13 1989, to New Hampshire Yankee from Douglas Rowe.
I am in agreement with the facts aw stated by Mr. Rowe, WCGY has not A
received the promised equipment or services as outlined in the letter of agreement response between radio station WCGY and New Hampshire Yankee's offsite organization.
There is NO pre-arranged authentification system. there_is NO dedicated telephone line and answering device, there is NO RPU or similar transmit / &
receive equipment to the incident area. _
The letter of September 14,,1987 equipment and services were rendered.was to become valid when signed'and the
! and services September 14, 1987 are not' forthcoming, I consider the CPCS-1/WCGY letter ofS void effective today. The management of WCGY does not g; intend to perpetuate an agreement that the public may rely'on',-when, in fact, to notifythere theisgeneral no agreement, public. or more importantly NO E.B.S. system in place
,Very truly yours, 0;
- i John F. Bassett
Attachment:
WCGY-NHY/ORO Letter 9/14/87 cc: Douglas J. Rowe, Esq.
Leslie,Greer Esq.
91 EX111 BIT C O'
WCCM & WCGY 3390pon/Lcworce, FRMMN STEEET. h',Jeetts LAWRENCE. MA 01840 VEAT & WEATW NN "(617)
"- " "~683 ~ 7171/ICSTON (617 ;
lO 14 4
4 o
O O
J 0-ATTACHMENT G O'. ,
O
-i O i i
i
'.I O
O y
- {
()
1
- 1 l
.O L
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
()' Before the Administrative Judges:
Ivan W. Smith, Chairman Dr. Richard F.. Cole.
Kenneth A. McCollom O
)- >
In the Matter of -) Docket Nos.~50-443-OL~
) 50-444-OL ',
C)' PUBLIC SERVICE COMPANY ) ;
OF NEW HAMPSHIRE, EI &L. '
)
)
(Seabrook Station,' Units 1 and 2)-
) October 27, 1989-
)
C) #
AFFIDAVIT OF DOUGLAS J. ROWE REGARDING THE' VOIDING OF THE~ERS LETTERS'OF AGREEMENT O I, Douglas J. Rowe, being1 duly sworn,. state:as follows:- '
- 1. I.am co-chairman of the Massachusetts' Emergency.
Broadcast. System. .The Massachusetts Emergency: Broadcast System (f ("EBS") is the association of radio and television, stations.in' Massachusetts that voluntarily agree to participate-in thel ;
+
EBS. I an also.the Federal-Communications Commission appointed O. c -chairman of the State Emergency Communications Committee; an owner and operator of WSRO (AM) located in Marlboro, ;
. Massachusetts; and a practicing attorney in the-Commonwealthiof gp Massachusetts with an office located at 21 Cotting' Avenue, Marlboro, Massachusetts.
iO '
ATTACHMENT G
-O 2.- on September 14,'1987' in my capacity as co-chairman of g the Massachusetts-EBS, I signed a letter of agreement that recognized the New Hampshire Yankee ("NHY") Offsite-Response organization'("ORO") as a responsible organization.within the O
meaning of the rules and regulations governing =the EBS.
(Exhibit A) In accordance with those rules and regulations,'
the Massachusetts EBS is authorized to recognize any 9
responsible local business or organization that may be responsible for creating or reporting a local emergency.
- 3. In return for the above-described recognition, NHY' O
committed to provide certain services and equipment at-1es own expense to the Massachusetts EBS stations in the Merrimac Valley operational _ area that includes the Seabrook Station
-9 Emergency Planning Zone. That equipment wasLto include a dedicated telephone line and answering device with compatible taping equipment, a radio link and other equipment as_needed 9
for the Merrimac Valley operational area. As recently.as November,.1988, NHY confirmed its-committment'to providing that equipment. This confirmation was evidenced by NHY sending out 9
a communications contracting firm, A11Comm,-to discuss the provision of-equipment to the EBS stations. That committment was further evidenced by the follow up letter sent by_ Gary J.
.9 Catapano, president of AllComm, as a follow up to those discussions. (Exhibit B)
- 4. On September:20, 1989, I met with-representatives of 9
NHY to discuss NHY's committments to the Massachusetts EBS.
During the course of that meeting, I learned that NHY would not live up to its. agreement with the Massachusetts EBS stations.
Ol j
l
'd
. . _ _ _ _ . _ _ _ . ~ _ _ . . _ . _ _ _ . _ _ _ . _ . _ _ . . _ _ _ _ _ . . _ _ _ _ _ _ _
, 1 Of i As a result of that meeting, I-drafted a letter dated September
~
20, 1989 that revoked.my previous letter of agreement dated September 14, 1987. (Exhibit'C) In response to a' request by NHY that time be afforded to_their management to discuss the
)
l matter, I withheld that letter of termination. i
- 5. In response to a letter dated September 29, 1989 from
']
R. Boyd,'Jr., Performance Service ~ Manager of NHY, (Exhibit D) I D :l sent a letter dated. october 13, 1989 that officially informed- l l NHY of and formally affirmed the revocation of the EBS letter of agreement with NHY. .(Exhibit E) $
- 6. Because of NHY's refusal'to live up to its i
committments to the Massachusetts EBS,'the Massachusetts;EBS will no longer continue to participate in emergency planning
~
) .
with NHY,'does not recognize the NHY ORO as'a responsible organization, and any and all former agreements between NHY and the Hassachusetts EBS are void. !
J The. foregoing is true and correct to the best of my knowledge and belief. I I
~~. l f+,4 !
- , p.y ./. /
Douglas J.. Rowe ./ :
i .l Subscribed and sworn to before this b day of October, 1989.
l \
1 Notary Public,
, MyCommissionExpires:-]; , ,,
1674n' I l ;
i
1
- n Tho' Massachusetts Emergency Broadcast $gstem is
- Connaitted to responding to eng emergency that meg effect residents
,- of Massachusetts. The Emergency Broadcast $gstem is_ e volunterg '#
organisetton eethertaed hg and created by the Federal Communicetions Commission._ita primary function is to alert the public in the event of a Presidential Becieration of Emergeneg; most -
specific 6g nocieer attack. But.the authority to use the EBS has been ,'
delegated down to the individual licenses which must use its
" Indepss&At discretion and responsibility ".
The Massachusetts Emergency Broadcast System would recognize eng responsible local business or orgentastion that meg he responsible for creating or reporting a local emergency. O Rfter review of New Hampshire Yankee's Offsite Response Organization and determining that en incident et New Nampshire' i Venkee could effect Massachusetts residents and that actlpation of the EBS could mitigate the effects caused by on incident the New _ g' Nampshire Venkee Offsite Response Organization is recogonized as s responsible local organization within the meaning of the Rules and '
Rogslations governing the E88.
IDith regard to the planning and implementation of the eierting system it is understood that NNV/088 mill provide certain 9:
services and equipment et its sapense and that this process of-planning and implementation will be en ongoing one.
The following equipment and services will be initialg supplied: ,.
- 1. Dedicated telephone line and answering device with !
competable taping equipment.
- 2. Fan er simRer device for receiving hard copy of eng message. .
ei
- 3. RPG or similar transmit / receive equipment to enable '
messages to be sont / receiped without reliance on telephone.'Riso, to enable EBS stetton to transmit from incident'orse or from etees that the incident acq cause en effect. ,
George S./ Thomas NS -,
Douglas J. Rowe
=" l i
Vice President of Production Co. Chairman New Hampshire Yankee Massachusetts Emergency g1 Division of Public Service Broadcast System Company of New Hampshire Agent for the Seabrook I Joint owners
~
Date h / /. n) Y Date '
/ Y (W7 . - e
/- ')
'O '
f MMMINIllllH 165 Mereell Cowt, Koew, NH 03431 603/357 0009 i:
r
.i (3
November 14, 1988 i.
Mr. Doug Rowe, Esq.
1
.O Morse Morte and Rowe P.O. Box 617 {
Marlborc, Massachusetts 01752
Dear Doug,
O Fer our discussions, attached is a description of the EBS equipment '
package AllComm, Inc. has developed for broadcast stations.
This' package was developed based upon research' relative to the EBS '
network's current configuration and its operational status. This research specifically examined these issues for the New England area.
I3 however, our research included discussions with Emergency Management Agencies in Florida, California, and Tennessee, broadcasters'from around the country and officials from FEMA and theLFCC.
The basic intent of these efforts was to determine the operational status of the EBS network. We needed to know what was broken and what could be done to fix it, if anything. These efforts were all O
encompassing and not limited to hardware issues. They included other-l important areas such as training ofLstation personnel, development of EBS procedures for each station, and the need for ongoing preventative maintenance and surveillance programs.for station EBS hardware packages.
g At the same time we were conducting our review, there were several other efforts underway at a federal. level which may.have appeared at -
first to be headed-towards'the same goal. These efforts, however. t were directed towards the further. development of EBS as a communications link from the-President to the public during a. time of g an emergency. This of course was the original purpose for:which EBS was conceived.
In contrast'to these efforts, the problems facing emergency management personnel and broadcasters on a daily basis are.quite different. These problems often require the-activation of EBS for
'O rapidly developing technological incidents that effect several f municipalities or a county-wide area. It is for these types of incidents and regional. weather advisories for which EBS is most often utilized. Therefore, it is logical to conclude that EBS must be fine-tuned on a station-by-station basis in order to be responsive to ,
s these types of incidents. -Our research and recommendations for
- Q creating a responsive functional EBS network are focused along these lines. EXHIBIT B-
O o
O In order to achieve .this goal, we have developed a basic generic equipment package to be installed at-each' station in the operational area. This equipment package is designed to *:fix" all of the hardware items that we identified during our research as being inadequate. The package is alse.dasigned to' facilitate the initial notification to. station personnel: wnd to assist personnel with EBS .g responsibilities once activiated. This " generic" package 11s then tailored to fit a particular station's needs and management' concerns. ;
Procedures for station personnel are reviewed, revised or developed, and a specially developed training program is initiated. Once.
installed, the EBS equipment itself is also placed under a A training review g-preventative maintenance and surveillance program.
is conducted on an annual basis and training is provided for new station personnel as required.
Collectively. these efforts combined with the willing participation gi i
of the broadcasters, state, and local authorities create.a. viable and responsive EBS network.
This program and hardware equipment packages-have been in place and operational in.the State of New Hampshire for the Seacoast Operational Area since March of 1987. -Several broadcast stations outside of New Hampshire also'have installed these equipment g.
packages. If you would like to visit one of these stations, or would
- prefer a demonstration of the hardware package at your location, please let me know.
Thank you again for your interest in our products,and services. !
Sincerely, Gary J. Catapano, g
President y
GJC/cer l Attachments :
Si 0
. : E2EIIITENf/##/
165 Menell Court, Keew, NH 03431 603/357 0009 b
OPERATION OF THE CATAPLUNKT EBS NOTIFICATION SYSTEM TheLsystem utilizes the CPCS-1 station as a " gateway" station allowing access and control of the operational area. The other p . stations in the operational area monitor the gateway station. These stations'are termed satellite stations. .l The equipment at the. satellite. stations monitors the CPCS-1 station =
continuously. The equipment package installed at each station consists of the following: the EBS Custom Control Unit, a TFT EBS b Receiver Encoder -Decoder. Unit and a specially modified Nakamichi MR-2 Cassette Deck.- High power strobe lights'are utilized as visual and silent means of notification to personnel in the air studio (s).
When the gateway station. transmits an EBS tone, the TFT Decoder decodes the signal and activates the EBS Control Unit which causes 3 the following events to occur simultaneously:
e 1. The strobe light (s) in the air studio (s) begin to flash. ,
- 2. The receiver on the TFT "unmutes" and the emergency message being-transmitted by the CPCS-1 becomes audible over the p speaker. A " mute" switch is provided to override this feature if the equipment'is installed in the air studio.
- 3. The cassette deck starts automatically and begins recording the emergency message being broadcast. ,
) 4. The broadcast audio from the'CPCS-1 station comes up on the console on the channel utilized.for EBS and the DJ can select it on " cue" channel in order to monitor it.
The strebe light remains " flashing" until reset by a remote reset
)
button installed on the audio console. However, the remote reset ;
) button-does not stop the tape recorder which continues to run for 10 !
minutes or until manually reset-via a switch on the EBS Control Unit.
When alerted by the flashing strobe light (s), station personnel are ,
trained to select the appropriate channel on the audio board and bring up the EBS audio on " cue" to determine if it is a test or an
> actual emergency EBS activiation.
4
O 9
If it is an actual emergency, the station can rebroadcast the message recorded from the CPCS-1.
The encoder portion of the TFT Unit is wired to the EBS activation button installed on the audio board to allow activation from the air 8 studio. Should an AM and FM station be co-located, the equipment can be remoted to both air studios. Special audio bridging can be added for simulcasting emergency information. Additional equipment wiring is performed at each station to allow operation of the features described above.
O An outdoor antenna is normally provided with each package. Where necessary, a notch filter or " trap' is also provided to ensure proper operation in the presence of strong R.F. fields.
When complete and installed, the system is placed under a monthly preventative maintenance and surveillance program. g In order to allow integration of the Operational Area with the state-wide EBS Network, the EBS equipment package at the CPCS-1 station is tuned to monitor the State Operational Primary Relay Station.
9 9
O O
9 0
).,
l_ .
l "Grbat Radio" RO. Box 566 48 Fitchburg St . Marlboro. Massachusetts 01752 e (508)485 1470 Seneq 20 September 1989
% Mr._ Michael. Lewis g/ Emersency Preparedness / Resource-Supervisor New Hampshire Yankee 8,, _
Post Office Box 300
- 4 Seabrook, New Hampshire 03874
- f f[l p ,
Dear Mr. Lewis:
Pursuant to our meeting today I. as Co-Chairman of-the Massachusetts Emergency.. Broadcast' System he'reby revoke my letter of 14 September 1987.
New Hampshire Yankee has, regretfully,: refused to honor the teras and conditions of that letter i of agreement. ;
~_
It has been two years-since-the ' letter was tendered and the E.B.S. stations of Merrimac! Valley._have_not received the promised cooperation. The limited -
equipment installed has not fulfilled commitments !
ande, oral or written. :
Sincerely,
[, . * , , ,
C - _ _
Douglas J. Rowe
-Co-Chairman Massachusetts Emeresency a Broadcast Systen j
Enc 1: Agreement 14 September 1987 3 l
EXHIBIT C c.~~ ... am n, s.,n.imn unrw., a.,w n Besten ene Worcester 24 Hours e Dov
t O SEP894479
, EP3.0.00.15 New Hampshire Yankee September 29, 1989 Douglas Rows Wass. Energency Broadcast System P.O. Box 566 Warlboro, MA 01752
Dear Mr. Rowe,
g Pursuant to our meeting of September 20, 1989, New Hampshire Yankee would like to outline its comattaents with regard to Public Notification and future Energency Planning participation by the State of Massachusetts.
NHY's commitment concerning Public Notification, as negotiated with federal officials, is to issue all residents, schools, businesses, public buildings, nursing homes, etc. public information asterial. This material outlines the responses the public should follow in the event emergency strens are sounded within the six towns of the Seabrook Emergency Planning Sone. In g addition, tone alert radios are being distributed to public &
private' schools, day care facilities, nursing homes, special needs facilities, botels, notels, inns, hospitals and businesses.
These radios will activate once an EBS tone is received from WLYT, and then monitor the station for emergency information.
9 The second issue is the future participation of Mass. in Energency Planning for Seabrook Station. Once the State begins to plan with NRY, we will re-evaluate our broadcasting capabilities and requirements, will formulate cost effective alternatives and laplement the selected alternative. If the Norrimact Valley EBS Network is utilised, due to prudency e considerations, federal and State assistance must be requested, documented and denied prior to a re-evaluation by NRY.
Ne hope our position in this matter is clear and appreciate the support you continue to provide on our behalf. NRY wishes to continue our relationship with you and the Mass. BBS. If you 9 have any questions or concerns please call as at (603) 474-9521 Ext. 2417. Thank you for your time and we look forward to your continued cooperation.
Sine oly,
. N .
R. Boyd, r.
Performance Services Manager O
EXHIBIT D jjg94$1
f l
i
" Great Radio" RO. Box 566 e 48 Fitchburg St e Marlboro. Massachusetts 01752
+ (508)485 1470 9*mmnq October 13, 1989 Al peg S
s/ Mr. R. Boyd, Jr.
88' ! Performance Services Manager Sq' P. O. Box 300 Seabrook, NH 03874 1
Dear Mr. Boyd:
i Your 1ctter of September 29, 1 911 9 , in not .a c c u r.i t. t' ! It attempts to describe a meetine; brl. enn un. !
If you will recall, at the end of that meeting there was no spirit of cooperation.
I said to you that as La-Chairman of the EDS Systems.in- I Massachusetts, 14, 1987. I was going to withdraw my letter of September In fact, a copy of the letter I intended to send you was FAX'D to you on September-20th qlvinq.you the further 4
opportunity to revicw the commitment made by Mr. Thomas.
After telephone calls and a request by N.ll.Y. to delay the withdrawal, I agreed. It was understood that the,rcason for the delay was N.H.Y. was to submit a-revised commitment. '{
-Your plan as submitted to NRC includas the EBS System.
You now say, and I quote, "IF the Morrimac. Valley E.B.S. i Network is, utilized." i I still remorber the dayn.of N.l!.Y. as::ing Mr. Bassett of WCGY and myself to sign, " quick instant" drawn agreements with the ;
intent of complying with FEMA requirements. - My recollection !
was that the FEMA regulations recuire nuclear plants to cooperate with and be integrated with the'E.B.S. System. As I tried to tell you at our meetinrj, there was an intent to put Massachusetts residents on ociual footing with New llampshire residentti. Mr . Ca t.ip.ino .i su u r ett mr t.h.i t he woulet install .i system in Lhn Morrim.ii' v.illiy i onn i n t..in t. with tin' ;yntem described later in the attached letter.
To my disappointment, the CPCS-1 station WCGY "the gateway" to Massachusetts, has not received the committed equipment or-services, not to mention the other stations of the Merrimac Valley. Your scicction of WLYT as a source to activate specific receivers is woll intentioned and commendable, but does not i activate the E.B.S. System.
EXHIBIT E
.. Serving the Amuent Sutueen Mortet Between Boston one Worcester 24 Hours o Dov
i O
.' i 1
g!
4 i
Your letter indicates a total lack of understanding of.the E.B.S.
System. WLYT does NOT trigger a notification to the general-' g public. It triggers only YOUR system.-The many radio stations 4 serving the general:public would receive NO notice'. Your idea that the media would decend on your media center is perhaps,,
accurate, but FEMA and the E.B.S.. System do not work'by press-release. FEMA regulations' involve agreements with CPCS-1 stations i and coordination with state emergency E.B.S. chairmen. I.suggest gy' you review the regulations.
My most disappointing thought about your letter is that you say that N.H.Y.'s commitment concerning Public Notification was.
negotiated..Can you pleaso.tell me when, where and~who negotiated '
away the rights of the general.public ?
g{
~
As you can read from the. attached copy, which was previously I FAX'D to you, I said that I had reviewed your plans and determined that N.H.Y. was a " recognized responsible" L
organization. In view of the apparent ~ change in attitude of the operators of N.H.Y.,-I.now formally submit withdrawal l authorization, dated September 20, 1989,' and I am sending a copy g.
of this communication to the CPCS-1 station WCGY. '
I very truly yours,
$~ f . f= =
Douglas J Rowe
?
O, Co-Chairman *
! Massachusetts Emergency Broadcast System ATTACHMENTS 9: :
l A. Letter of withdrawal 9/20/89 B. Co-Chairmans EBS letter 9/14/87 s C. WCGY letter.9/14/87' '
D. All CommSystem Plan & Letter dated 11/14/88 >
E. N.H.Y. letter'9/29/89 cc: WCGY e0 1
Ot
e J,.re, 43 kn3 a gr.. e - , - - - - -
Aa ma. a w e i
~
Q:
1
, , . I a
.1 O'
i i
l e
0 1
1 I
k O l 1
7
'O ATTACHMENT H ;
f O
L 5,
O ,
l 1 +
lO .;
,0-r +
t-O.
l l
l l
l l O --
lO
<=
UNITED STATES ~OF AMERICA Q_ NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before the Administrative-Judges:
cy Ivan W. Smith, Chairman Dr. Richard F. Cole Kenneth A. McCollom O
)
In'the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL PUBLIC SERVICE COMPANY )
O )
(Seabrook Station, Units 1 and 2) ) . October 30, 1989'
)
O AFFIDAVIT _OF ROYCE SAWYER REGARDING THE VOIDING OF- THE FBS LETTERS OF AGRERMENT i i
I, Royce Sawyer, being duly sworn,. state as follows:
.l C) 1. I.am the e mmunications officer for the Massachusetts Civil Defense Agency. My office is located.at the Massachusetts Civil Defense Headquarters, 400 Worcester' Road, Framingham, I O Massachusetts. As communications officer for the-Massachusetts Civil Defense Agency I am the official _who 13 primarily responsible for the oversight and maintenance of the
() Massachusetts Emergency' Broadcast Syst:L ("EBS"), and am familiar with its purposes, configuration, and operation. I have approximately ten. years experience as communications- 4 O officer as well as related experience in civil defense and 4
4
l o;
l i
emergency planning. A copy of my professional qualifications is y provided.
- 2. The EBS is created under Title 47, U.S.C. 151, 154(1) and (o), and 303 (r); Chapter 1, Part 73, Subpart G of the G,.
Federal Communications Commission's Rules and Regulations. It !
is a national communications network that can be activated on )
i the national level, statewide level, or local operational area I 91 level. Activation of the EBS national system is by authority of i
the President of the United States through control points for radio and T.V. networks, AP and UPI new services and i
participating common carriers. Activation of the EBS within ,
Massachusetts may be by request of the Governor, the Director of the Massachuetts Civil Defense Agency, the Massachusetts State Police or the National Weather Service. Statewide activation '
i may be made by the request for activation going directly to the l
l originating Primary Relay Station, WROR_(F.M.). Activation on a g local operational area basis may be made by contacting WROR (F.M.) or by directly contacting the operational area's primary i relay /CPCS-1 station. That station in turn cues in:the remaining stations in the operational area.
In essence, activation of the EBS proceeds as a ripple effect. If it is activated on the national level, transmission of the EBS attention signal is made from Washington to the states' originating Primary Relay Stations followed by an informational message. In Massachusetts the originating Primary 4{
Relay Station, WROR, would then transmit the EBS attention signal followed by the informational message to the operational
- c. -> v ~-3-.- , ,w. 7 r - - - - --g s , - - -_ _ _ _ +- ---_________--_______----------___-___---f-- ' - - - - - - - ---_a
~ . _ _ _ _ . . _ _ _ _ _ _ _ _ _ . _ . _ _ . _ . . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ .
I lO l
I g areas primary relay /cPCS-1 stations. WROR's transmissions would be received by tone alert radios at the CPCS-1 stations that are in the local operational areas and are tuned to WROR. There are j seven operational areas within Massachusetts. In the Merrimac O ,
Valley, WCCM (A.M.)/WCGY (F.M.) ("WCGY") is the CPCS-1 station. l WCGY functions as the primary relay station, or lead EBS station, in the Merrimac Valley operational area. It activates
{
the EBS on the local operation level by transmitting the EBS attention signal to the radio stationo in the Merrimac Valley ,
operational area. Those local stations have tone alert radios ;
that are tuned to receive WCGY's tone activation signal. See Exhibit 1.-
While the EBS i:. a voluntary association of radio and :
television stations, all broadcast stations that are licensed by l the FCC are required to install an EBS two tone receiver. When the EBS is activated all radio and television stations that ,
participate in the EBS pick up and transmit the informational 4 p c ,94n o w e., W .
EBS message. When the EBS is activatedpa call stations that do not participate in the EBS3 are required to go off the mira e i rec ** r,c u ,.r.,
y r4c, nw That results in any listener who-turns on his radio tuning in to only -
EBS activated stations that are all carrying the same uniform ,
EBS message. In theory, it means that a listener who is tuning his radio to find information about an alerting signal will rapidly come to an EBS station carrying the appropriate :
g information because all other local radio stations will be off the air. The EBS functions as a radio rebroadcast'information '
- 3-O i
O I procedure so that all stations receive and retransmit the same ,
messages.
- 3. The import of WCGY voiding its prior letter of agreement with NHY and withdrawing from participating in the g
emergency planning moans that the EBS for the Merrimac Valley
. CY MHY As Leuce fat ru ryc song, ,
operational area cannot be activatedg WCGY is the gateway ;
station that activates the tone alert radios in the other FBS ,
stations in the Merrimac Valley operational area which in turn ;
insures the uniform transmission of EBS messages. While there appears to still be an existing letter of agreement with WLYT (F.M.), WLYT cannot activate the EBS in the Merrimac Valley ,
operational area. The tone alert radios located in the other radio stations in the Merrimac Valley operational area are not i
tuned to WLYT. While WLYT may be able to transmit en l informational message provided by NHY to its own listening public, that message will not reach the rest of the public who do not happen to be listening to that one radio station. ;
i
- 4. While in theory in the event of a radiological emergency at Seabrook Station, the Governor could activate the EBS on a statewide basis by activating it through WROR in Boston, there does not exist any provision for insuring that notification is made to the public in the Massachusetts ,
emergency planning zone for Seabrook Station within the 15 )
minutes required by NUREG 0654, FEMA-REP-1, Revision 1, Appendix
- 3. There does not exist a dedicated phone line, or other direct access link from any activating agency in the state government to WCGY. There is not any direct communication link with WCGY t
g
. . - - - _ - , . . , , , , - . . . . ..,__.~,,..,,m~. ,w-., _ . . , , ..-_c- < s-.
O O other than through commercial phone. Commercial telephone does not provide the requisite assurance of notification in 15 minutes because as noted in the Affidavit of John F. Bassett, g WCGY's telephone lines are at times all busy.
The foregoing is true and correct to the best of my knowledge and belief.
Q. s 66.4.
Royce Sdityer 7 3 Subscri e and sworn t before me thi J day'of- , 1989.
j' Q ' - "pi
- u w u,v c
\:y=dommis s
on Expires. 'd 7 [f fh
- i
, ,e - -
, [
1 9 ,
9 9
9 b
i
.O '
UNITED STATES OF AMERICA
.O NUCLEAR REcuraTony ComuIssIoM ATOMIC SAFETY AND LICENSING BOARD Sofore the Administrative Judges:
,O Ivan W. Smith, Chairman Dr. Richard F. Cole ;
I:enneth A. McColloa '
O
)
In the Matter of ) Docket Nos. 50-443-oL j
) 50-444-OL !
PUBLIC SERVICE COMPANY )
lO (seabrook station, Units 1 and 2)
[ November 22, 1989 ;
.)
O INTERVENOR3' NOTION TO ADD AN ADDITIONAL BASIS '
To TNE LATE FItzD ATTACNED coNr.NTzon To TNE MOTION oF WOVEMBER 9, 1989 s
The Massachusetts Attorney General (" Mass AG"), Ceacoast i t
O Anti-Pollution League ("SAPL"), and New Engldnd Coalition on ;
Nuclear Pollution ("NECNP"), (hereinafter "Intervenors,"), move this Board to admit for litigation in the above-captioned g proceedings the additional basis filed herewith as Attachment A '
i and reopen the record in the proceeding on the Seabronk Plan for '
Nassachusetts communities ("sPMC"). This motion is. filed
- O P"****"* ** 'l(*) *' th* ***"i"
'"**'Y *** ""d i' ' ""d*d~"P""
the grounds set forth below. The Intervenors also request that 1
\
this Board permit them to have a hearing on all issues raised by IO this basis and engage in any discovery necessary to prepare for such a hearing.
O hf
j i
l i
l INTRODUCTIOM 9 On Neveabar 9, 1989, the Interver7rs filed a motion to admit a late filed contention and reopen the record on the SPMC. The !
l contention alleges that l g
The Applicants do not have the means to 1
provide early notification and clear instruction i to the populace within the plume exposure pathway Emergency Planning tone ("EP8") in Massachusetts and therefore do not meet the planning standards l g
of 10 C.F.R. $ 50.47 (b) (5) , and 10 C.F.R. Part . 50, i App. E.IV.D. (hereafter the "EBS Contention). l As a basis for that contention, the Intervenors submitted I that the SPMC contemplates the use' of the Emergency Broadcast g system ("Ess") as the primary means for notifying the public in the svent of a radiological emergency at Seabrook Station and-without the cooperation of WCGY, t.he gateway station for the g!
Merrimac Valley operational Area, the-Applicants will not be v able to activate the EBs servicing the Seabrook Emergency l Planning Zone ("EP2") in Massachusetts.
g In that notion, it was indicated that the.Intervenors i i
anticipated an additional basis would be filed-in support of ~
the contention when they were able.to obtain an opinion in g;
! support of this basis from an expert who would be available to testify at a hearing on the matter.M The Intervenors' having now located such an expert seek to supplement the basis g; U
Intervenors' Motion to Admit Late Filed Contention-and Reopen the Record on the SPMC Based Upon the Withdrawal of the Massachusetts EBS Network and WCGY (the "EBS Motion") page 11, g; note 4.
2- 0
)
i
{ ' supporting the RBs contention.
' The thrust of the supplemental .
basis (Attachment A) is that not only does the sPMC lack its primary means of notifying the public because of the loss of WCCM (A.M.)/WCGY (F.M.) and the EBS, but the remaining means it I
has for providing notification i.e. , WMAV (A.M.)/WLYT (F.M. )
(hereafter "WLYT*), is also inadequate.
]
b Tur enrTrarr yon err Agagggioup A tAen-pitun ec,.m-rrow Amr iu+
The criteria for the admission of late-filed contentions are set forth in 10 CPR 62.714(a) (1) . In ruling on a action to admit a late-filed contention, a licensing board must balance the factors set forth in the above cited provision, commenwealth Edimen co-(Braidwood Nuclear Power Station, Units 1 and 2), CLI-86-8, 23 NRC 241 (1986); Duk. power ca. (Catawba Nuclear Station, Units 1 and 2), CLI-83-19, 17 NRC 1041 (1983);
Public Service of New Ha==mhire ca. (Seabrook Station, Units 1 and 2) , ALAB 918, NRC (1989). Those factors are:
(1) good cause for failure to file on times (ii) the availability of other means by which the petitioners interest will be protectedt (iii) the extent to which the petitioners participation may -
reasonably be expected to assist in the development of sound records (iv) the extent to which the petitioners interest will be represented by other parties; ,
(v) the extent to which the petitioners participation will broaden the issues or delay the proceeding.
A considered balancing of those five factors clearly establishes that the attached contention should be admitted in this proceeding.
l !
1 :
l l l
TIMELINER$
The supplemental basis in Attachment A is timely for the I same reasons as the EBS Contention is as set.forth in the Ets
( Motion, and those reasons are adopted by reference in this #
motion. The SPMC's primary means for notifying the public in f
an energency became unavailable as of october 20, 1989 when !
John Bassett repudiated WCGY's letter of agreement with New 9 l !!ampshire Yankee ("NNY") . As evidenced by Attachments B, C, I
and D prior to that date the Applicants had represented they would be using the Ets to notify the populace in the O Massachusetts EPE. Furthermore, through the letter of agreement with WCGY, NNY had the means to implement that notification.M 9 1
U At best it seems disinegnuous of the Appli= ants to claim i
, that they had contemplated the use of WLYT as the sole means of providing notification to the public since the spring of 1988. O Attachments A, B, and C all post dated that time frame. The Applicants own witness Desmarais agreed with Assistant Attorney '
General Stephen Jonas as recently as May 2, 1989 that the use of WLYT and Egg 1 was contemplated for notifying the public.
Attachment D. The use of WC0Y since it is the gateway station for the Merrimac Valley operational Area under the terms of 9 l WCGY's then extant letter of agressent with NNY would have ,
triggered the activation of the EBS. -
It is of no consequence that in the FEMA-Graded Exercise 1 only WLYT was a player since participation in such an exercise '
by an outside entity that is not part of the response i organisation is limited by the negotiated scope of the 9; exercise. If one were to follow the perverted logic that the use of only one radio station during an exercise puts the world on notice that an emergency plan is going to be using only that radio station, then the same logic would be true for a limited demonstration of other contracting-entities in an exercise.
That would mean the June 1988 graded exercise should be viewed 9:
as a declaration by the Applicants that they plan to-rely on only one ambulance company and only forty-three buses since they were the only vehicles used in the exercise.
(footnote continued) 9-
)
l t
l In the_ original motion the Intervonors brought to the attention of the Licensing Board the facts that are at the heart of the now offered supplemental basis in Footnotes 4 and 7.
I At that time the Intervenors' did not have an expert witness to opine on those facts but was in good faith engaged 1
in the process of trying to find such an expert. on Friday, I october 27, 1989 the Mass. AG obtained a copy of one page of the 1989 Edition of Arbitron's Radio County Coverage Report for Essex County, Massachusetts (the "Arbitron Report") . The I
representative of Arbitron from whom the Mass. AG obtained that page was out of the office on that day and unavailable to answer questions on it.
1 The following week the Mass. AG
( contacted the Arbitron representative and sought to enlist I
Arbitron's aid in obtaining an expert who could opine on the contents of the Arbitron Report. The Arbitron representative D
indicated that she did not know whether Arbitron could be of (footnote continued) j a
The deposition of Gregory Howard also clearly cannot be regarded as offactive notice that the Applicants rely on only WLYT as the means of providing notification in the SPMC. No reasonable person wculd have given weight to the fact that Howard aantioned only one of the two radio stations identified in the SPNC during his deposition. Howard had consistently g
erred in his knowledge of and performance with respect to the SPMC.
Indeed, apparently NNY removed him from his offaite Response Organisation position because of his incompetence.- It was to be expected that Howard would refer to WLYT rather-than WCGY because WLYT was the station he had dealt with-during the June Graded Exercise. Similarly, Anthony callandrello's p
testimony on June 28, 1989 cannot be viewed as effective notice that the Applicants were relying on only WLYT since he did not name any radio station in that testimony. There is no way of knowing whether he was referring to WCGY or WLYT in his unresponsive answer at Tr. 27893-94.
_,..s -. . -
..=1 C
assistance but would inquire of her supervisors within the 9 l
company. on Wednesday, November 1, 1989 the Mass. AG received a call back from Arbitron's Vice President and General counsel, A. Anthony Reisey. Mr. Kelsey explained'that Arbitron did not i
gl usually provide expert witness services, but under the j l i
circumstances would be willing to consider doing, and certainly '
would be willing to furnish suppaenetary explanatory documents that permit assessment and interpretation of the information in the Arbitron Report. He went on to state that if after receipt of that information, the Intervenors believed that an Arbitron g1
) representative could be of service in the matter, he would be ,
willing to discuss the matter, review and consider furnishing i an affidavit.on the matter and provide testimony at any hearing g that resulted. On November 7 and 8, 1989 the Mass. AG received i the explanatory documents from Arbitron. After reviewing the '
materials the Mass. AG again spoke to Mr. Ralsey during the g week of November 13, 1989 and sent a draft affidavit to him for i
his review. On November 20, 1989 Mr. Welsey provided his comments and corrections to that draft affidavit. He signed g final version of the affidavit on November 21, 1989. This action is being filed within twenty-four hours.of the signing i of that affidavit and on the same day as the' Mass. AG received it. The supplemental basis is being filed only slightly over one month from the triggering event for the EBS-contention and
! as quickly as practicable under the circumstances, g
Ol I
.,<%.-- , , . . , - + , ,y pw.,, --wr.y . . - -, . .,y, ~,,, .. -
(.
~.
I pretaetlan of the Intervenere8 Intaraat.'And the htiti er**a Internat aaneamented hv existinct Dartian The Intervenors adopt, and by reference incorporate, the arguments on these two factors set forth in the EBs Nations.
=
nrvernmenmwT or A motmo namre The Intervanors will contribute to the development of a sound record through the litigation of the attached basis. The EBs contention and supplemental basis sufficiently-identify the issues to be decided. In support of the contention and supplemental basis, the Intervenors will offer the testimony of A. Anthony Kelsey whose affidavit is attached to this motion as Attachment E.
He will testify on the issue of how few people in the EPE are likely to hear any notification made solely over WLYT.
Mr. Kelsey is knowlegable on the methodology used to develop studies and analyses estimating the relative market share of commercial radio stations in a given listening area.
In particular, he is familiar with the study. conducted by the -
Arbitron company, the leading provider of audience estimate studies in the United states, that is reflected in the Arbitron Report. Attachment F.
Mr. Reisey will testify that the Arbitron Report shows that during an average quarter hour between 6 A.M. and Midnight on any day of the week, for all persons over the age of 12 years, the combined listernship of WLYT comprises.less than one half of one percent (0.5%) of the 121 persons population in that
~7-
...i i
l I
1 1 -
listening area. In contrast, the cashined estimated share of 9 listenership for WHAV, WCCN, WLYT, WCGY and WasN, which
~
comprise the Merrimac Valley operational Area Emergency I troadcast system ("ERS") stations that appear in that report, g I
is over.10 times as great.
He will also testify that it is his opinion that an
, emergency message transmitted on WHAV-AN and WLYT-FM alone g would have the potential for reaching a relatively small segment of the population in that radio coverage area at any point in time.
It is conceivable that relatively few people .g would tune their radios to WLYT in the. event that they heard j sirens or other audible warnings, and that at least ten times as many, and theoretically geometrically even more people would ,
I hear emergency messages if they were transmitted simultaneously l
over the combined facilities of the entire Merrimack Valley l Operational Area EBS network.
O The identification of Mr. Kelsey as a witness who possesses special expertise on the issue of the number of people in the Massachusetts EPE who are likely to hear any notification put ,
out over WLYT alone, and the above statement as to what he will testify to clearly establishes that the admission of the contention will contribute to the development of a sound g
record. The Appeal Board has held:
A late petitioner can establish that its participation may reasonably be expected to assist in developing a sound ~ record by "(1) ,
identify (ing) specifically at least one witness
-s- 8
lO l ,
\
l i
lg - it intends to presents and (2) provid(ing]
i sufficient detail respecting that witness' ,
l proposed testimony to permit the Board to reach a !
reasoned conclusion on the likely worth of that ;
i i
! testimony on one or more of (its) contentions."
um hin=+==
! publie Dewar su==1v avstan (WPP3s
' Nuclear Project No. 3) , AIAS-767, 19 NRC 964 ;
O (1984), 985 (1984 -
power so--1, sva+-) quoting wamhinstan publie
! .e al. (wppss Nuclear Project l
No. 3) , AIAS-747, 18 NRC 1167, 1181 (1933) .
l The Intervenors in this instance have clearly met the test i i
9 for establishing that their participation will assist in the development of a sound record.
4 l
i Since WLYT is the only {
! 1 remaining means the SPMC has for providing notification to the '
9 populace in Massachusetts, it is important for the Licensing l
Board to be aware of how few people are likely to actually
! receive notification by that means. As set forth above the l {
Intervenors are prepared to significantly contribute to the development of a sound record on this issue. That factor thus weighs heavily in favor in the~ admission of the attached contention.
AnsENCE OF DEIAY obviously the admission of the ESS contention and supplemental basis will broaden the issues to be decided-in this proceeding, and may delay a final resolution of the proceeding. However, the same would be true with the admission of almost,any new contention and basis. Therefore, what must.
l be considered by this Board in assessing this factor is the-degree to which the issues before the Board will be broadened and the degree of the delay that will be occasioned by the admission of the contention.
3 I
. i 9
In this case the contention and basis that are proposed ,~ 9l focus narrowly on one aspect of the sPMC. It is anticipated ;
l that any discovery on the issua can be kept to a minimum and 1 i
that any hearings will not be lengthy. Through the prior 4 !
l proceedings that have occurred in this licensing matter, the i {
parties and the Board are already generally familiar with the j parameters of the issue.
.g While this factor does by its nature militate somewhat in 6 favor of the Applicants, the narrowness of the issue raised in !
the contention and supplemental basis and minimal amount of .g!
delay that is likely to ensue by admission of the contention do not weigh heavily in the Applicants' favor. When the slight '
weight to be accorded.to this factor is balanced'against the gl other four factors that strongly favor admission of the [
contention, the not result is that on balance the~ contention
- . s should be anaitted. Therefore, the Board should allow the g; j action to add an additional basis to the late-filed EBS a
contention.
MOTION TO REOPEN TIM RECORD g The criteria that must be met to reopen-a closed record are '
j set forth in 10 CFR 62.734. Those criteria are all met in this instance. The motion is timely for the reasons set forth g-above.. The event that triggered the action to reopen the record was the letter of october 20, that was sont by WCGY to '
NNY. Prior to the transmission of that letter voiding the g; i
n 9: '
1
i l()
r
' i A3 letter of agreement that had previously existed between NHY and ,
McGY, the elements of the SPMC that called for the activation l of the EDS could still have been implemented. Without'the ESS 10 the Applicants can look to provide notification to the public only by means of WLYT.
Given the requirement that a motion to reopen the record be accompanied by one or more affidavits setting forth the bcsis !
- O of the motion, this action is being filed as quickly as is practicable.
There was the necessity of obtaining an affidavit IO from an expert who could opine on notifications made solely by means of WLYT. This action is being filed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> I l after the signature of that affidavit.
TME NOTION ADnmenEER A ETCMIFIFAWT Eliki-i IEiUi *
- 0 Both NUREG 0654, FEMA Rep-1, Rev. 1, Supp. 1 and NUREG i 0654, Rep-1, Rev. 1 require that means be established to previe,e early notification and' clear instruction to the O
populace within the EP3. Under Planning Standard E, '
Notifications Methods and Procedures, an emergency response organization has a responsibilty to demonstrate that means O .
exist to notify and provide prompt instructions to the public.
The specifications for providing such prompt notification is set forth in NUREG 0654, FEMA Rep-1, Rev. 1, Appendix 3. Under O ;
the criteria for acceptance in Appendix 3, the minimal acceptable design objectives for an alert and notification
!O system require the capability of providing both an alert signal O. ,
,.,--_y,.,..,_.,_.._.-,....y_.. . . , ~ . , , . _ . _ , _ . _ _ , , _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ , _ _ , _ _ _ _ _ _ . , _ _ _ _ , _ , , , . _ _ _ . _ _ , , _ , , _._m.,,,._ ,
i O!
I i I
i
'nd a an informational, or instructional, message to the gl .
j population on an area wide basis throughout the 10 baile EPE !
within 15 minutes. Appendix 3, at 3-3. Under this a$nimally acceptable criterion for a notification system, NNY aust make .
- gj provision not only for alerting the population in the~EP2 by I means of a siren, or other signal, within is minutes, but must I also make provision for providing an informational, or g;
instructional, message to the population within that same time -
~!
period.
The withdrawal of WCGY and the Massachusetts EBS poses a g
distinct significant safety risk under Planning Standard E. !
The withdrawal of WCGY means that the EBS cannot be activated i
- for the Merrimac Valley area. All other EBS stations within that operational area are tuned to WCGY's tone alert frequency '
to trigger their activation and participation in the EBS. '
Without WCGY's activation of those stations, they will not pick up the EBS messages that are designed to carry information to the public in the event of an energency at Seabrook Station.
The manner in which the EBS operates ensures that when the EBS 9:;
l is activated, an individual turning on a radio to find'out the \l significance of the alerting sirens will come fairly shortly to an EBS station. When the EBS is activated, all non-EBS 9:
stations go off the air. That means in tuning to find out the significance of the sirens, an individual will quickly encounter an EBS station-carrying the authorised EBS messages.
4.,
l
e 10 while NNY still has an existing contract with WLYT that station is not a CPCS-1 station that can activa'te the EBS.
While WLYT does participate as a station in the EBS, it cannot activate any other station in the ESS, or pass on ESS messages lO to any but its own immediate listening public.
- i. In making its j
finding as to the adequacy of the SPNC, FEMA did not find that I
a letter of agreement with WLYT was enough to satisfy !
1 0 notification requirements. The Sync does not call for the activation of WLYT alone, rather it calls for the activation of I the EBS. In making its finding of adequacy FEMA stated:
- O The Plan states that the primary system for disseminating information to the public is Ets. In I
event of an emergency, the NNY ORO offsite Response
- Director will request-authority from the commonwealth- <
i of Massachusetts to utilise EBS to broadcast emergency ;
information and instructions to the public. Each
- O 1
instructional message broadcast over Ea8 will also be ;
released as a news release by the Media Center. 1 i
FEMA's Review of the SPMC, App. .Exh. 43C, Pe.ge 24. I As indicated above and evidenced in the Affidavit of A.
Anthony Kelsey relatively few people in Essex County where the EPZ is located listen to WLYT. The means that when the populace of the EPS hears the sirens and turns on their radios
! to learn information, relatively few people will be tuned to WLYT and hear the emergency informational messages. For the g vast majority of people in the EPE who do not normally listen to WLYT it will be by chance if they happen to click on to WLYT when an emergency message is being aired as they tune up and down the dial. Notification to the public in a radiological 1
O ~12~
. - - - . . . - .- - - - - - - - - - - - ^'-~~ - - "~~~ ~ ~ ~ ~ ~ ~ 1
l
()
\
l l
emergency plan cannot in any right headed world be left to O
- ~
chance.
4 The Applicants cannot rely on pre-emergency information to accomplish for them what the notification provisions of the. 9 SPMC lack. Their own expert in this area, Dr. Dennis Mileti haw said:
It's not been empirically demonstrated that 9 pre-emergency education or information has an impact on what people do in response to emergencies. That doesn't make sense.. But it hasn't been empirically demonstrated yet.
That leads ne to conclude that we need an 8 emergency warning system during the emergency that will work independent of pre-emergency education to give.up and-information. -It doesn't make sense education. pre-emergency information It may accomplish and some good. For example, illustrate to residents of the Ep3 12 9 the live in the EPE. People who don't live in
,the EPE, that they don't, et cetera. And in general, help prime persons for an emergency, but it's not empirically demonstrated that it will have an effect on the actual emergency response a one way or the other, to the best of my 9 knowledge. Transcript (11/19/87) at 6371.
Based upon the opinion of the Applicant's own expert witness, pre-emergency information cannot be relied upon to assure that people in the EpE will know to turn to WLYT. Dr. Mileti has 9:
indicated in his testimony in this proceeding that reliance on pre-emergency information is particularly problematic with 3 9:
respect to transient populations such as those that visit the-Massachusetts beaches.A/
g:
1/ Transcript (11/19/87) at 6362-6365. Attachment G.
O
IO O 'Because the sirens in the Massachusetts beach areas do not function in a voice mode as they do in New Hampshire, the beach population cannot be expected to know to tune in WLYT.M O Thus, the withdrawal of WC0Y poses a significant safety issue. It precludes the ability to activate the nas as the SPMc calla for, and to notify all the public in the EPz as required by 50.47(b)(5) and NUREG 0654's Planning standard E.
O The loss of wcoY is not compensated for by the presence of WLYT. In holding the ability to make prompt notification to the public to be a significant safety issue, the Appeal Board O
has stated:
" Extended discussion should not be necessary with regard to the obvious safety significance that attends upon compliance with the commission's regulation designed to O provide the seabers of the public located inside the EPz with "early notificatio.. and clear instructions" in the event of a radiological emergency." (Footnote omitted.)
Publie service cannany of New Marnrhire, at al. fmembrook station. Unita i and 21, AIAB-883, 27 NRC 43, 50 (1988).
O Without the ability to make notification to the public, the public will not be aware of the significance of the sirens 0 th* "ill "** D* * ""if "" di'***i"****" *f "h* 1"f**"**i " i" the Eas nessages; and protective action recommendations cannot be transmitted to, or received by, the general public in g accordance with the SPMc and regtnatory requirements.
Therefore, the attached basis and supporting affidavit address a significant safety issue that warrant reopening the record.
O y Transcript (5/24/8s) at 22s54). <
l 3-D l '
l A NATERIALLY DIFFERENT RESULT IS LIKELY IF THE BOARD g CONSIDERS TNB ATTACHED CONTENTION AND NEWLY PROFFERED avinemace n m tua ITs L;;__.vuAtrou om si snee It is inoonceivable that FEMA would have found the SPNC to l
be adequate without a provision for notifying the public in accordance with Planning Standard E. Similarly, it is j
- inconceivable that FEMA would have approved the SPNC without specific provision in the SPNC for activation of the ESS by Or, l
means of a letter of agreement with the CPCS-1 station, WCGY. !
I l Without that station there can be no activation of the ESS.
NUREG 0654, FEMA REP-1, REY.1,. Appendix 3, at Pages 3-15, specifically requires the integration of an energency plan's 0:
l notification system with.the state and local EBS. Because emergency information messages disseminated through WLYT will G'
reach a reall segment of the population in the EPE, it cannot be relied upon to provide for adequate notification.
Without WCGY and the ESS, provisions for notifying the S'
general public in the Massachusetts EPE as to the status of an -
emergency at Seabrook Station or as to actions to be taken in response to that emergency are inadequate. If the Board takes 9!
that fact into consideration, it will doubtlessly come to a different conclusion as to whether the SPNC_ complies with i NUREG-0654 and other relevant planning standards. !
Si CONCLUSION Therefore, the Intervenors have established that a balancing of the factors to be considered in admitting a-ei O!
l
- l. .. ._ .~.. . _ _ - - . . _ _ . , . _ _ _ .
o j
' late-filed contention weigh heavily in favor of the admission O .,gn ..,,1 sel hasis. The Intervenors have also established that this motion to reopen meets the standards that i such a notion must comply with, and the gravity of the~ issue O
warrants reopening the record for consideration of the issue. .
O COMMONWEALTH OF MASSACNUSETTS JAMES M. SNANNON ATTORNEY GENERAL ,
O Aki b $&n John Traficonte
. Chief, Nuclear Safety Unit -
Imslie Greer Assistant Attorney General O Nuclear Safety-Unit ,
Department of.the Attorney General i One Ashburton Place Boston, MA 02108-1698 (617) 727-2200 O DATED: November 22, 1989 i O
O i
O L
O ,
.__ _ . . . _ . _ _ . . _ _ _ _ z _ _, _ _ _ _ . . . _ . . _ _ . _ _ . , _ _ _ . . _ _ _
O -
y O
'O 9
9 O
ATTActuanry A '
9 D
D .
4 :
8 D
\
D .. .
_ _ . - . _ _ . . _ . _ . . _ _ . . _ . _ _ . _ _ ~ _ . - . . _ _ . . . _ ._._ -- - ._ ___ _ _ __ _ _ _ _ _ . _ _ . _ . . - _ _ _ _ _ _ _ _
.O t .
O Attacheent A i
O ' " " " " ' ' '
- 3. The Applicants remaining means for providing j
notification to the Massachusetts EPE under the SPMC is by-g transmitting energency information messages over WHAV i
i (A.M. )/WLYT (F.M. ) . - A relatively small proportion of the j
i population in the EPE listen to those stations. Pre-emergency f information is not an effective means to arisure that people will tune to those stations in an energency. Therefore, the Applicants no longer have means for implementing notification '
g and instructions to the population in the EPE. i t
)
D l
l D
1 l
)
4
-, , - ~ . , . , , - - , , . . _ . , . . , , - , . , _ , , . , - - - , , . . - - . , , , . , , .- . . _ - ~ . - . _ . _ , ~ < - . - , , , . . . _m -- , ..w--...
-- ,in.
O .
e 1.
i' J
- O ,
i i -
I
.O I
I l ,
I i 4
i
! i
- O s
i i
- s l l i
ATTACIDEENT 5 l3 !
I i
i I
O 1
1
-l j
D .
sI y
I i
1 1
1 1
1
)
. .l D
3 .
l0 lO
~
SEABROOK STATION o
PUBLIC ALERT AND NOTIFICATIDW
- SYSTEM iO . i I .
FEMA-REP-10 DESIGN REPORT !
\o
- o
~
New Hampshire Vankee o
Oeir 1 i
- April 30,1988
O
' PLANN!NC STANDARD E - NOTIFICATION METM008 AND PROCEDUtt$
i EVALUATION CRITERTON E.$t S Notification Methods The primary means of disseelnating information and instructions to the public is through breedtest of messages ever the leergency treadcast 'g System (Ets), a network of teeeercial radio stations. New Maepthite and Massachusetts portions of the Ep! are severed by separate-El8 networks.
in the event that eteurtences at Seabrook Station lead to en energency 9 4
i classification of ALERT, the Ell stations la both states are put on standby.
The New Mespohire Ell stations may, at the ALERT Level, be estivated for issuance of instruction for precautionary sleeing of beach areas. At the $
i SITE AREA EMERCENCY er CtWtkAL EMERGENCY level, broadcasts over the Eb8 are activated for both Massachusetts and New Maapehire in conjunction with stree activations.
9 in addition to providing public information and instructional messages, the Els networks in both states are used in susslesentina the stren systes coverage for alerting of institutions. in the Ept. These institutions will be O of fered tene-elert radio receivers that will be activated by a two-tone signal over the Ett network. The use of institutional tene-elert radio receivers to suppleennt stres systes coverage is dieeussed more fully in Chapter 2, Section 9 E.6.2.4.2.
New Rameshire IS$ Network In New Mempshire, the Seacoast Operattenal Area Ceemen program Centrol Ste- b' tien (cpCS) is WOEQ. WOEQ, a 50,000-wett FM statica broadcasting at 97.5 MRs free Dover, NR, operates 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, seven days a week, and is ,
equipped with a backup power supply. As the CPCS, WOKQ is responsible 1
1-2 g
A
D f or notif ying, via the two-tone 185 signal, the other New Maspshire See-coast EBS stations in the network. Although not a CPCS station, WYF provides 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AM E85 broadcast capability for New Maapshire. WT F , a 5.000-watt AM station broadcasting at 1540 KMs f rom Exeter. WH, is oper-stional f rom 5 AM to midnight, seven days a week and is equipped with a backup power supply. lefYF has been specially equipped to provide 24-hour, seven any per week EBS coverage by remote activation from WOKQ during of f hours.
g Activation of the EBS covering the New Hampshire portion of the Seabrook 5 Station EPZ proceeds as follows:
g 1.
The New Maapshire State police Communications Center (NM5PCC) receives notice of an emergency free Seabrook Station.
2.
The NMSPCC notifies the New Hampshire Of fice of toergency
- Management (NH0EM) of the emergency.
I 3.
If the emergency reaches the ALERT level, the Director of the NMotM, or his designee, notifies the CPCS station, putting it on standby and preparing it for possible broad-east of public information or instructional messages.
(. .
) The CPCS is sonitored by the other New Hampshire 185 stations and broadcasts are staultaneously aired or recorded f or subsequent broadcast.
1 5. If beach precautionary actiona are recommended or if the
{ emergency reaches SITE AREA EMERCENCY or CENERAL EMERGENCY, the Director of the NH0EM, or his designee, notifies the CPCS to activate the broadcast over the EBS of specific inforestion er instructional messages.
Figure 1-1 depicts the activation communication sequence for the New Maap-shire ESS network. The activation of the New Hampshire 188 network is discussed in Volume 1. Section 2.1 of the State of New Hampshire Radiological toergency Response plan.
g Massachusetts E85 Netverk In Massachusetts, the contract El$ radio station is I station broadcasting at M f ree 6 Massachusetts. M is
) 1-3
. O operatiot.s126 hours0.00146 days <br />0.035 hours <br />2.083333e-4 weeks <br />4.7943e-5 months <br /> per day, seven days a week, and is equipped with a 9
backup power a pply. Provides 6 MA1. station broadcasting at M free M. M is operational 24-hours per day, seven days'per week and is equipped with a backup power supply. O Activation of the 188 covering the Massachusette portion of the Seabrook Station Ett proceeds as follows:
9
- 1. The NR offsite Response ROC Contact receives notice of an energency from the Seabrook Station Short-Ters Eastesacy Director (STED).
- 2. In an escalating energency, af ter the NW Of fsite Response Organisation is activated, the NNY Offsite Respor.se Stree= g ter (NNYORD) assumes responsibility for E88 activation f ree the Seabrook Station taergency Response Organisataan (ERO).
- 3. If the emergency reaches the ALERT level, the STED or NNYORD (depending on #2 above) notifies 6), putting the ctaties on standby and preparing it for possible broadcast of public g information or instructional sessages.
4 If the energency reaches SITE AREA EMEhCENCY or CtWERAL '
EMERGENCY the STED or NNYORD obtains autherisation from of ficials of the Commonwealth of Massachusetts to activate the Public Alert and Notification Systes and notifies W) to activate the broadcast over the Els of specific informa- O tion or instructional messages.
Figure 1-1 depicts the activation caemunication sequence for the Massa-chusette EBS network. The activation of the E88 network for the Masse-e chusetts communities in the EPE is described aste fully in Section 3.2 of the Seabrook Plan for Massachusetts Communities. ,
once the decision has been made by the Director of the WHOEM and the Massa- 'g chusetts Civil Defense Agency Director to activate the E88 networks, the system provides the capability of broadcasting informational and instructional sessages within 15 minutes. g 1-4 91 i
~.
O -
O O
o O
M s
J T
ATTActDERFf C T.'
i O
O l 2
4 o- !
L- j
- s. i i
-O-4 0 .
1 0- .
O s 1 0
21-12 (a) 0 Applicants' position on JZ-33 is that the asshanism for providing emergency information to the publis through-1 the EB8 is in place and san-be' activated'in asserdensa with the Massachusetts ESS operational Plan-er with -I' g
provisionsin_theSPNCand1tesupportingagreements.
The underlying facts supporting this position include:
Imtters of Agreement between the NNY ORO and the O
Eas radio stations relied on in the SPNe are-in place to facilitate ~ activation of the EBS systea q
delegation of the requisite authority from.
appropriate Massachusetts- governsental au*.hority to the ORD to activate the ESS.- A Letter of Agreement between NNY and the Massachusetts Emergency <
O Broadcast System.organisation has also been' !
executed.
The sample E88 messages relied on by the SPMC, 0 aucept Supplemental Message 1, 3 and-the Early School Dismissal message, clearly identify the l OcVernor of Massachusette er other-State officials O-as the seurse of the emergency information being_
eiseeminates. '
The- SPNC, IP 2.13 at 5.1.4 provides for transmittal of ES8 messages to the appropriate Commonwealth Q
officials hafare broadcast, allowing these 0:
l 4
'O! ;
. 1 i
.. g j etficials the ePpertunity fer. review'and/or .
l modification. I consistent with the Operational Plan, the SPNC
~
3 anticipates that the Governer of Massachusetts'will J authorise activation of the ESS.
l (b) The sources relied en for'the underlying facts include..
IP 2.13, Attachment 4.24, Letters of Agreement, IP 2.13-' #!
)
- at 5.1.6, Massachusette.ESS Operational Plan. NURES-
- i 0654/ FEMA-REP-1, Rev. 1. Supp. 1. (
(c) None selected. g; d
(d) None selected. 1 L
i (e) None. '
il f.
4 I, .
S'-
f P
I, - l e
i' '
, a
}
4 j
.0J 8
- - - . - - - ,, m.o . -- _,
d
.:.:t ; Hi -:: :: -
at:,. : it .;;
, ;;. . .,7,,3 - ,.
O' As'to Answers.
a f t' j h o w -
George 8. Thomas vise President, Musisar Production O
New-Maapshire Yankee Division of Publio Servise Ceapany of New-Naapshire Coteber 28, 1988 O
state er.New Naapshire Rookingham-County, es. .
i Then. appeared before me the above su. ..
1 O b s e r i b e d G e o r g e -..8. .
Thomas and made oath that ha'is the vlee Free &
, Nuclear.
e to i
execute the foregoing roeponaea to interroga, tories /on behalf the Applicants' that he made inquiry and believes that the .of
- teregoing available to answere aceurately' set'forth intosaation as-is.
the Applicanta, >
O i Before me, . ,
& i 'E MY.Caamassion Buyires agg As to ob3ectiones e i
O YA*) AYA0 k_'A la , 5 Tnesse e. Dignan, Jr. "
. George M. Leveld .
e* ,
Rathryn A. selleek .,
Jetfrey P.-Trout " ' ,.
Jay Bradford Smith ',' 4 O -
Ropes & Gray.
ans Franhain street Boston, MA 08110 (617) 433-6100 O
counsei een Ammitennes
s lo _
j s
O ..
1 l
o l O.
O "k' '
ATTACE1013PP D
@ (
i.
l l
1 0
,l o .
W %l- 4 i
D b -
i q .... . 4 I 1
9-O L
O stations I take in the it that area? that's not all of the' radio y
t A (Desmarais). That's right.
j Q i
For FM, that's WLYT; is that right? '
A -(Desmarais) If I could take a quick look at the REP-10 design report I would be able-te verify that..
h JUDGE B14CN ;
j-I. recall that in some of the doeunents
- those names giveni was that were not -- the station names were not correct? '
i r
MR. DIGNAN: That was part of the == ,
D. JUDGE SIACH: And it's now public.
- L j
(Document proffered to witness.)
THE WITNESS: (Desmarais) Thank you.
JUDGE SIDCH: While he's looki , is there a D stipulation you want about thi I
-MR. JONAS:
Well, there are two stations,-WLYT and WCGY on the FM dial; and one, WNAV on the AN dial.
JUDGE SIACH: Yes.
MR. JONAS: That's just what I want to establish.
THE WITNESS: (Desmarais).
but my copy of the rep-10 design report has theI believe that's accurate,
- stations blanked out as well. -
MR. DIGNAN: They don't trust the lawyers.
$ i THE WITNESS: (Desmarais) I believe it's' accurate.
MR. DIGNAN:
I'm not going to argue with you.If you represent that that's what'it'says, JUDGE SIACE: Is there.some point about that?
MR. JONAS: Well, the point.I'm raising only-is that there are two -- i l
SY MR. JONAS:
) Q Do you know how'many radio stations in the area?
l A (Desmarais) No, I don't.
)
' ~
S IO-i G
J OI i
l 4
i O
O i
O
'9
~k g ATTAcmetNT' E <
.1 0
I e 4
\'1
-4 t
'h 1
9 l
J D 1 1
- 1 e