ML20137F404

Statement of Matl Facts as to Which There Is No Genuine Issue Re Eddelman Contention EPX-2

ML20137F404
Person / Time
Site:	Harris
Issue date:	01/13/1986
From:	Hollar D CAROLINA POWER & LIGHT CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20137F380	List: ML20137F378 ML20137F394 ML20137F404 ML20137F410 ML20137F417 ML20137F616 ML20137F649
References
OL, NUDOCS 8601170508
Download: ML20137F404 (8)

Text

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DOCKETED USMc January 13,1986 UNITED STATES OF AMERICA 16 A9 :59 NUCLEAR REGULATORY COMMISSION GFF:cEa:5g,~b, BEFORE THE ATOMIC SAFETY AND LICENSING bb2 In the Matter of )

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CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Power Plant) )

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APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON EDDLEMAN CONTENTION EPX-2 Pursuant-to 10 C.F.R. 52.749(a), Applicants state, in support of their Motion for Summary Disposition of Eddleman Contention EPX-2, that there is no genuine issue to be heard with respect to the following material facts:

1. Within the State of North Carolina, many public safety agencies conduct their normal and emergency radio communications on many different frequencies. Radio traffic related to the Harris exercise was added to their normal traffic on May 17 and 18, 1985. Affidavit of Alvin H. Joyner on Contention EPX-2 ("Joyner Affidavit"),14.

I 2. One of these frequencies is the "Special Emergency" frequency of 155.280 mHz VHF. This frequency is referred to in Contention EPX-2 as the " emergency inter-system mutual aid frequency." This frequency is widely available in the radios used in most communities and is also available to some State agencies. Joyner Affidavit,14.

3. In North Carolina, 155.280 n Hz is a widely and heavily-utilized frequency.

However, with the benefit of radios equipped with tone encoding and the characteristics inherent with VHF transmissions, prhticular agency users are able to successfully conduct th ir commurifcations opbrations. L yner Affidavit,15.

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4. Emergency personnel during the Harris exercise were using tone-encoded equipment that prevented interference from extraneous signals. Joyner Affidavit,16.

5. In the four counties comprising the Harris emergency planning zone, all of the ptblic safety organizations operate on multiple frequencies which are dedicated to specific services. Some of these counties have multiple frequencies for just one type of service. None of these counties rely on 155.280 mHz as their sole primary frequency to respend to any emergency situation. Joyner Affidavit,17.

6. If under extenuating' circumstances, this frequency or the other frequencies being utilized were needed on a priority basis, this could be done. A powerful base station from either the State or one of the counties could come on frequency and order

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- the radio traffic to move off frequency. Joyner Affidavit,17.

7. Communications difficulties experienced by the Highway Patrol during the l Harris exercise. were limited to delays in radio communications through the Raleigh

- Radio and to communications difficulties encountered by the Highway Patrol ,

representative in the Harnett County EOC. Affidavit of William Ethridge on Contention L

EPX-2 ("Ethridge Affidavit"),12.

8. During its everyday operations, the Highway Patrol uses four frequencies for its normal traffic. In addition, the Highway Patrol base station, known as "Raleigh Radio," is used by other State and federal agencies with law enforcement -

responsibilities. This radio traffic is normally handled by two telecommunicators, or

" dispatchers " This was the number of telecommunicators during the exercise. Ethridge Affidavit,13.

9. In addition to the four frequencies normally rsed by the Highway Patrol, two additional frequencies were added for purposes of the exercise. The exercise traffic was  !

l added to the routine dispatching done by the telecommunicators on duty. The telecommunicators gave preference to actual situations and emergencies, rather than to l 1

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the exercise-related traffic. This treatment of exercise-related traffic contributed to delays in the transmission of messages. During an actual radiological emegency at the plant, related radio traffic would have received an appropriate priority. Ethridge Affidavit,14.

10. During the exercise, approximately 100 additional radio-equipped vehicles were added to the 350-400 vehicles normally handled by the telecommunicators. This increased radio traffic contributed to minor delays in the transmission of exercise-related traffic. Had the exercise been an actual emergency, much of the Highway Patrol's routine traffic would have been taken off the frequency and, if needed, there would have been no hesitation or difficulty in adding telecommunicators and communications channels to handle increased radio traffic. Ethridge Affidavit,15.

11. The Highway Patrol representative in the Harnett County EOC experienced occasional difficulties with communimtiot.s due to conditions occurring in the temporary EOC. Because of a lack of telephone equipment in the temporary EOC, some difficulties were experienced by the representative in communication of data via telephone.

Ethridge Affidavit,16.

12. 'Harnett County is developing a permanent EOC, equipped with improved communications capabilities. Ethridge Affidavit, 17; Joyner Affidavit, 1 12. The Highway Patrol Communications Section is taking steps to assure that the communications capabilities of the permanent Harnett County EOC will be compatible with that of the Highway Patrol. This will include additional telephone capacity to be available to the Highway Patrol. This corrective action will prevent the communications difficulties experienced by the Highway Patrol in the Harnett County EOC during the exercise from being repeated. The installation of a microwave repeater tower will allow excellent radio coverage for the counties surrounding the Harris Plant. Ethridge Affidavit,17.

13. The Highway Patrol did not experience any other communications problems during the exercise which .could be considered as sufficiently important to actually interfere with the Highway Patrol's responsibilities in the event of an actual emergency. Ethridge Affidavit,18.

14. The North Carolina Division of Emergency Management is currently studying the needs of the new Harnett County EOC and will advise the county on the number of telephones and other resources which will be needed. This study will determine the communications needs required to correct the type of problems which arose during the exercise. Additional telephone lines will be added with the financial support of Carolina Power & Light Company. Current thinking envisions at least eleven telephone lines in the permanent EOC. Completion of the permanent EOC will be prior to full power

-licensing of the Harris Plant. Joyner Affidavit,112.

15. The Harris exercise demonstrated that Chatham Coun$y's overall emergency-response capabilities are good and provided the opportunity to identify areas that could be improved. Affidavit of Mark Scott on Contention EPX-2 (" Scott Affidavit"),13.

16.- Extra radio traffic was only a problem in Chatham County for a brief period of time. At the start of the exercise, Chatham County had one dispatcher on duty. Upon notification of the simulated emergency at the plant, the dispatcher correctly followed a

" call-in" procedure to obtain assistance, and the called-in personnel arrived approximately ten minutes after being notified. Their arrival provided the EOC with two radio dispatchers and two additional dispatchers to handle the telephone communications. After this initial period, the additional dispatchers adequately handled all of-the traffic that took place in Chatham County throughout the remainder of the exercise. Scott Affidavit,14.

17. Radio traffic regarding the simulated emergency was added to Chatham

. County's normal, routine radio traffic. Had an actual emergency been occurring at the l

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r' plant, the radio traffic regarding the county's responsibilities would have received an appropriate priority. Scott Affidavit,15.

18. As a result of Chatham County's assessment of the exercise, the County has improved its communications staff by adding additional personnel. Chatham County now has two full-time radio dispatchers that work in the communications center during the hours of the week that the greatest communications traffic occurs. This provides the ability to effectively handle increased radio communications which might suddenly develop from major emergencies without the immediate call-in of additional personnel--

even if this happens at a time of normally higher radio traffic. Scott Affidavit,16.

19. Chatham County has taken steps to remove some traffic from the airwaves by installing a repeater station which is used for county fire dispatch. This repeater allows all of the units on this frequency in the county to hear each other without the need to relay through the central communications center. Scott Affidavit,16.

20. The additional dispatchers employed by the county will assure the capability to respond to initial and continuing radio traffic levels which would be experienced in the event of an accident at the Harris Plant. Scott Affidavit,17.

21. Comments by the evaluator for the Office of Emergency Medical Services (OEMS) regarding the delay in the receipt of messages were primarily the result of a delay in a single, key message. In particular, the OEMS representatives were not made aware of a briefing in the EOC in which the announcement of a release from the plant was simulated. Joyner Affidavit,18.

22. Within the State EOC, representatives of each state agency making up the State Emergency Response Team (SERT) received messages through a public address system for general announcements and a " message runner" system for special or important messages. The OEMS staff were unaware of the briefing because they did not hear the public address system or because of a failure on the part of the message runners to properly notify them. Joyner Affidavit,19.

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23. Increased emphasis on briefing message runners as to their responsibilities will improve their effectb.eness and assure that their messages have the direct attention of the recipients. DEM plans to develop and implement new procedures for message runners immediately. These procedures will require that the runners receive a direct acknowledgment, such as a signature or initials, from the recipients, thus eliminating the possibility of missed messages. Acknowledgments will be reviewed by the message control officer for completeness of notification and receipt of message traffic. Joyner Affidavit,110.

24. During the Harris exercise, the North Carolina Radiation Protection Section (RPS) had teams of radiation monitoring personnel in the EPZ collecting radiological data. These field teams would transmit, via radio, the data back to the RPS mobile radiological laboratory for processing. Affidavit of Dayne H. Brown on Contention EPX-2 (" Brown Affidavit"),12.

25. Occasionally the radio transmission of a field team must be relayed to the mobile laboratory or other intended receiver. During the exercise and as anticipated, field survey teams came upon some locations in the EPZ that were not as conducive to radio communications as others. Occasional use of a relaying procedure is a necessity for an agency relying on radios to carry out its duties. Brown Affidavit,13.

26. During the exercise, one of the RPS's field teams found it necessary to relay communications at various times. Simulated data were relayed from the field team through the RPS transmitter at the Harris Emergency Operating Facility (EOF) to the mobile radiological laboratory. Brown Affidavit,14.

27. RPS has a procedure in place for relaying data. The potential for inaccurate data transmission during a relay is not significantly greater than through the use of direct communications. The repetition of data back to the originating unit is standard procedure for RPS radio communications. This is the most effective method to check the accuracy of the transmission. Brown Affidavit, T 5.

28. ~ Any delay occasioned by the relay procedure would be only momentary - the time.It tak'es to repeat the transmission to the receiving party. The relay procedure is clearly faster than relocating a field unit or other transmitter, or making some other adjustment, during the emergency solely to attempt to maintain direct radio contact.

The mobile laboratory could consistently monitor the survey teams' survey data, and the

-relay station repeated the data back to the survey team for confirmation. This early preview. of the data by the mobile lab serves to minimize the time required for information flow. Brown Affidavit,16.

29. ~ Throughout the exercise, all of the RPS field units could communicate with either the Harris' emergency operations facility (EOF) or the mobile laboratory. At no time during the exercise was contact with any field unit lost. Brown Affidavit,17.

30. RPS has' considered the suggest,lon of the state evaluator that the mobile radiation laboratory be positioned at an elevated area outside the EPZ. In response, RPS has changed the location of the laboratory to a more elevated area than the location used during the exercise. This should reduce the need to relay messages. However, the use of a relay procedure does not detract from RPS's communications capabilities. Brown Affidavit,18.

31. The relay procedure is a normal operating proce&re for RPS communications and is used whenever conditions require. The relay procedure has been and will continue to be a necessary tool to support RPS operations and communications. Brown Affidavit, 19.

32. The communications difficulties raised by Eddleman Contention EPX-2 represent only relatively minor communications issues that are being fully addressed by the responsible emergency preparedness agencies. Where corrective actions are c . ..

necessary, they either have been or will be taken prior to full power licensing of the

. Harris Plant.

Respectfully submitted, 4.

Dale E. Hollar, Esquire ,

Richard E. Jones, Esquire Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolinr. 27602 (919) 836-8161 Thomas A. Baxter, P.C.

Delissa A. Ridgway, Esquire '

Shaw, Pittman, Potts & Trowbridge 1800 M Stteet, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: January 13,1986 4

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