ML20094A659

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Statement of Matl Facts as to Which There Is No Genuine Issue.Related Correspondence
ML20094A659
Person / Time
Site: Harris 
Issue date: 11/02/1984
From: Ridgway D
CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20094A658 List:
References
OL, NUDOCS 8411060492
Download: ML20094A659 (8)


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November 2, 1984

'84 my:-5 P2:03 UNITED STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION

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BEFORE THE-ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of

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CAROLINA POWER & LIGHT COMPANY

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and NORTH CAROLINA EASTERN

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Docket No. 50-400 OL MUNICIPAL POWER AGENCY

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(Shearon Harris Nuclear Power

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Plant)

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APPLICANTS' STATEMENT OF. MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON EDDLEMAN 57-C-3 Pursuant to 10 C.F.R.

5 2.749'a), Applicants state, in support of their Motion for Summary Disposition of Eddleman 57-C-3, that there is no genuine issue to be heard with re-spect to the following material facts:

1.

Carolina Power & Light Company contracted with Acoustic Technology, Inc. ("ATI") to analyse and evaluate

-the accustic coverage of the siren notification system de-signed to be installed within the Harris EPZ, and to prepare a report which documents the analysis of the warning system design to meet the guidance set forth in FEMA and NRC reg-ulations and regulatory guidance.

Bassiouni Affidavit, 12.

2.

NUREG-0654 and FEMA-43 are the basic guidelines for the design of a prompt notification system for alerting the public within the EPZ.

These guidelines address the 841106G*?2 841102 PDR ADOCK 05000400 0

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licensee's option.for methods of. alerting, such as. outdoor w

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warning sirens, tone alert radios, and automatic telephone l

'd'alers..Bassiouni. Affidavit, 13.

3.

Federal guidance does not require redundant noti-fication systems for the general:public (i.e.,

siren systems to alert the public when it is outdoors, combined with tone alert radios or automatic telephone dialers.to alert the public when it-is' indoors).

Bassiouni Affidavit,.13.

4.

The' federal guidance does not specify criteria for nighttime alerting.

However, it does establish design.

criteria'for public alert systems based on population densi-ty and ambient background noise -- specified as the average measured outdoor daytime (period between 7 am and 10 pm) ambient sound levels.

(One reason that daytime ambient is specified rather than nighttime ambient is because the ambient noise level during the daytime is substantially higher than the level at nighttime).

Bassiouni Affidavit, 14.

5.

According to the federal guidance, a siren system may be designed so that the siren sound level either pro-vides 60/70 dBC acoustic alert coverage (depending on the population density of the area) or provides 10 dBC above the average outdoor daytime ambient sound level.

Bassiouni Af-fidavit, 14.

6.

The siren system design within the Harris EPZ con-sists of 62 high-power electromechnical sirens (rated 125

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dBC at1100 feet)' strategically placed throughout the EPZ to

-provide optimal' alert. coverage to inhabited' areas.

Bassiouni Affidavit', 15.

L1 7.

~ Evaluation of the acoustic coverage for the siren system was accomplished by using a computer model developed by ATI, and field measurements 'f the ambient sound levels.

o The acoustic coverage of the siren system-design was pre-dicted for daytime summer average meteorological conditions, as specified by FEMA-43.

The computer model analysis demon-strates that the siren system has been designed to provide the required 60 and 70 dBC public alert coverage for most 1

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inhabited areas.within the EPZ.

Apex and Fuquay-Varina are covered by 70 dBC contours.

Bassiouni Affidavit, 6.

8.

Apex and Fuquay-Varina are the only areas of EPZ with more than 2,000 persons per square mile.

Pugh Affida-

vit, 7 n.

1.

9.

An ambient background noise survey was conducted within the Harris EPZ in July 1984, in accordance with FEMA-43, to document the average measured outdoor ambient

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I sound level in areas located outside the 60 dBC contours, in order to assess the siren system's ability to meet the 10 dB above ambient criterion in areas not covered by 60/70 dBC coveragc.

Bassiouni Affidavit, 17.

10.

Outdoor daytime ambient sound levels were measured in the range of 24 dB to 39 dB.

Therefore, the average mea-sured outdoor daytime ambient sound level for regions ll x

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'S outside th'e.60 dBC coverage was conservatively. established-as 40'dB,'and the 50 dBC acoustic coverage of the sirens was computed. ?Bassiouni Affidavit,_17.

11.

This analysis of the acoustic coverage of the si-rens clearly demonstrated that the entire Harris EPZ is cov -

ered by a 50.dBC siren contour.

Accordingly, all areas out-

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side:the'60 dBC. contours meet the 10 dB above ambient criterion.

Bassiouni. Affidavit, 17.

12. ~The siren system design complies with the

'NUREG-0654 and FEMA-43 guidelines (and the applicable feder-al' regulations) to alert essentially 100% of the population

- within the plume EPZ in 15 minutes.

Bassiouni Affidavit, 18.

l 13.

The fixed. siren system -- with 62 sirens located throughout the Harris plume EPZ ---will serve as the. primary public alerting system in the. event of an emergency at Harris.

Upon activation, this siren system is designed to warn immediately all areas within the EPZ.

Pugh Affidavit, 12.

14.

In all four counties within the EPZ, vehicles with flashing lights, sirens and/or public address systems will-be immediately dispatched upon the activation of the fixed sirens, to provide additional public warning by driving predesignated routes within the EPZ.

Pugh Affidavit, V2.

15.

Zones within the EPZ have been subdivided into 4-subzones within which the road mileage has been measured. l 4

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.TheLroads have been assigned to countyLagencies, and the routes-planned out.

Estimates have been made of:the time' needed for notification, and all routes are being driven-to.

confirm.these estimates.

The estim'ates include the time needed'for emergency personnel to_ reach'their duty posts to begin the notification process, based upon actual experi-ence.

In addition, it-has been determined that there are sufficient vehicles and personnel to perfoim the mobile alerting in a timely manner.

This conclusion applies to both daytime and. nighttime (1 a.m. to 6 a.m.) conditions.

Pugh Affidavit, 13-16.

16.

In_ addition to the_ predesignated personnel as-signed to perform mobile alerting, each of the four counties has identified additional personnel-(with equipment) who would be available to augment the designated mobile alerting personnel, if necessary.

Pugh Affidavit,'117.

17.

If public officials determine that only a portion of the EPZ needs to be alerted by the fixed siren system and mobile alerting, the warning times stated above could be re-duced by concentrating the identified mobile alerting re-sources in smaller operational areas.

Pugh Affidavit, tl8.

18.

The flashing lights, sirens and/or PA systems of mobile alerting vehicles passing by the homes of EPZ resi-dents -- particularly when combined with the activity of other residents who have already received notification --

would alert most members of the public who might not have heard the fixed sirens.

Pugh Affidavit, 19.

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Following the initial fixed siren and mobile

' alerting warnings, law enforcement and other official vehi-cles would be in the area to ensure complete evacuation or other protective action, and to provide security.

They will be instructed to check premises where no protective action activity is evident.

Pugh Affidavit, 119.

20.

Public response to emergency information and warn-1 ings of impending disasters has been a topic of investiga-tion by social scientists for almost three decades.

Many studies have been performed on the subject in a variety of emergencies, documented in a vast body of emergency litera-ture.

This research record provides' evidence about a wide-

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range of emergency warning /public response phenomena, including public notification and communication between mem-bers of the public in an area at risk.

Mileti Affidavit, 12.

21.

These general principles of emergency warning /

public response -- well established through decades of re-search and investigation -- would be applicable in the event of an emergency at Harris.

Mileti Affidavit, 1 8.

22.

A clear conclusion of this research is that people generally seek out additional information upon receipt of an initial warning, before acting on that warning.

The end re-sult is that, historically, many people in emergencies have first learned of emergencies from other members of the pub-lic.

Mileti Affidavit,

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.23.

The initial response'of most people to a warning of an impending emergency is to seek out more information, and/or engage in. additional communication with.others'.

Mileti. Affidavit, fl.

24. LAs people seek confirmation of warning informa-

. tion, they actually can and.do become part of the warning dissemination effort, albeit informally, through social net-working.

In other words,.in the event of an emergency at the Harris plant, the seeking of confirmation would lead people to contact others who might or might not as yet have learned of the emergency.

Mileti Affidavit,115.

25.

In an emergency, n.ighbors, friends and family --

and even total strangers -- check on one another and offer-assistance if it is needed.

This also causes people to be in communication with other members of the.public who might not as yet have learned of the emergency.

Thus, for exam-ple, people who have been awakened in the night and received notification of an emergency at Harris generally can be ex-pected to notify neighbors whose houses are still dark and where no one appears to be stirring.

Mileti Affidavit, 6.

26.

The high level of activity which would be associ-ated with an emergency at Harris would have a strong " ripple effect," generally alerting members of the public to seek additional information about the events taking place, even if they had not been directly warned by either the fixed si-rens, the mobile alerting system, or another member of the public.

The activities of other residents who have.already.

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s-received notification (turning on the lights in their homes, perhaps preparing to evacuate, or even the stream of traffic driving out of'the EPZ) would awaken (if necessary) and alert most members of the public who may not yet have been warned, and cause them to seek additional information about what is going on (for example, by turning on the TV or

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radio, or by talking to neighbors).

Mileti Affidavit, 17.

Respectfully submitted, W

44 Thomats A.

Baxter,lP/d.

V Delissa A.

Ridgway SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C.

20036 (202) 822-1000 and Richard E.

Jones Samantha F.

Flynn Dale E. Hollar Hill Carrow CAROLINA POWER &' LIGHT COMPANY P.O.

Box 1551 Raleigh, North Carolina 27602 (919).836-7707 Counsel for Applicants Dated:

November 2, 1984

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