ML20138P494

Forwards Wj Dircks 851211 Memo & FEMA Re Emergency Nighttime Notification Sent in Response to Encl ASLB .Encls Will Be Served on Parties to Proceeding.Related Correspondence

ML20138P494
Person / Time
Site:	Harris
Issue date:	12/23/1985
From:	Johari Moore NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Bright G, Carpenter J, Kelley J Atomic Safety and Licensing Board Panel
References
CON-#485-579 OL, NUDOCS 8512260137
Download: ML20138P494 (14)

Text

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n UNITED STATES NUCLEAR REGULATORY COMMISSION NM

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r, .. j wAssincrow, o. c. 20sss A.,*****j December 23, 1985 Cydf James L. Kelley, Chairman Mr. Glenn 0. Bright

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Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Lj'6Ensi ~~ Boardi U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatorf ~issio$".

Washington, DC 20555 Washington, DC 20555 Dr. James H Carpenter

' Administrative Judge

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Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 In the Matter of Carolina Power and Light Company and North Carolina Eastern Municipal Power Agency (Shearon Harris Nuclear Power Plant, Units 1 and 2)

Docket Nos. 50-400 and 50-401 -CC

Dear Administrative Judges:

Enclosed for your information is a Memorandum for Chairman Palladino froni William Dircks, E.D.0. with attachment from FEMA prepared at the request of the Chairman. This Memorandum related to the letter sent by the Board to the Commission concerning nighttime notification. Copies of the enclosed document are also being served on the parties to this proceeding.

Sincerely,

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8512260137 851223 PDR ADOCK 05000400 Janice E. Moore O PDR ,

Counsel for NRC Staff

Enclosure:

Palladino Memorandum cc w/ encl.: Service List

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( 'e NUCLEAR REGULATORY COMMISSION RfASHINGTON. D. C. 308E5

..... DEC 11985 MEMORANDUM FOR: Chairman Palladino Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Zech

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FROM: William J. Dircks Executive Director for Operations

SUBJECT:

NIGHTTIME EMERGENCY NOTIFICATION Thismemor'SdumrespondstotheChairman'sNovember22,sNovember 1985, request that the staff respond to the Atomic Safety and Licensing Board 19, 1985, letter notifying the Commission of a possible noneric safety issue involving nighttime emergency notification of residents 'n the plume ex

. planning zones surrounding nuclear power plants (Enclosure 1)posure . Atemergency the staff's

. request the Federal Emergency Management Agency (FEMA) has reviewed the Licensing Board's letter and their response is provided in Enclosure 2. The applicable regulations and guidance relating to public alert and notification systems are summarized in Enclosure 3. 1/ .

4 The Federal Emergency Management Agency has evaluated the information presented in the Licensing Board's letter and has concluded that it does not indicate that there are generic safety problems involving nighttime emergency notification.

Further, FEMA states that the results of their study conducted for the Shearon i Harriscaseconfirmstheirjudgmentthatsirensystemsdesignedandevaluatedin accordance with NUREG-0654/ FEMA-REP-1, Rev. 1, and FEMA-43 meet the NRC require-ments for both daytime and nighttime alerting. .

1/By letter of December 2, 1985, the applicants (Carolina Power and Light Company andNorthCarolinaEasternMunicipalPowerApency)alsoprovidedtheirviewsto the Commission regarding the Licensing Board s November 19 letter. FEMA and the NRC staff have briefly reviewed the submission and find that it generally reflects the record of the Shearon Harris proceeding to date.

CONTACT: D. B. Matthews, IE '

492-9647

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,' The Commissioners Based on FEMA's conclusion in response to the Licensing Board's letter and the staff's understanding of the regulations in 10 CFR Part 50.47(b)(5), Appendix E SIV of 10 C.F.R. Part 50, the guidance in NUREG-0654/ FEMA-REP-1 Rev. 1, and the FEMA-43 review process, the staff does not believe that any generic action need be taken by the Commission in this matter.

ggegWilliam].DW William J. Dircks Executive Director for Operations

Enclosures:

,. 1. Licensing Board 1tr. dtd.

11/19/85

2. FEMA Evaluation

3. Summary of Requirements

.. cc: OGC OPE --- ...

SECY Shearon Harris Service List

,e , . v, . ENCLOSURE 1 UNITE 3 STATES f NUCLEAR REGULATORY COMMISSION

(*****).

, 5 ATOMIC SAFETY AND LICENSING eOARD PANEL wasemorow.ocasses November 19, 1985 i

l Chairman Nunzio J. Palladino " ,

Consissioner Thomas M. Roberts l Commissioner James K. Asselstine Commissioner Frederick M. Betathal Commissioner Lando W. Zeck

Dear Mr. Chairman and Commissioners:

We are writing this letter to bring to your attention evidence of possible generic safety problems involving nighttime emergency notification of residents in the plume emergency planning zones _ ,

surrourfding nuclear power plants. It apmars that under the acceptance criteria,being generally applied by the federal Emergency Management _

Agency 'to nuclear plant siren systems -- criteria wh' ch are based on daytime conditions -- substnntial numbers of EPZ residents would not be,

.. aroused from sleep should an emergency siren notification be necessary between, say, midnight and 6:00 a.m.. particularly if bedroom windows

. were closed.

. We are members of the Atomic Safety and Licensing Board presiding over the application of Carolina Power and Light Co. et al. for an operating license for the Shearon Harris facility. We ncently conducted an

evidentiary hearing in that case on an Intervenor's contention that the l Applicants' sirens would not awaken sleeping residents in the EPZ

! between midnight and 6:00 a.m. particularly those who have closed their windows and turned on their air conditioners. Both the Applicants and -

l the Federal Emergency Management Agency presented extensive testimony and responded to cross-examination on the contention, as reflected in -

the Shearon Harris transcript. Tr. 9356-9976. The parties will be submitting proposed findings of fact on the siren and another contention ,

during December, and the Board expects to decide those contentions in early 1986. In these circumstances, we as a Licensing Board have not drawn any conclusions about the particular siren contention before us in the Shearon Harris case. In any event, we would have no occasion to write to you about Shearon Harris at this time -- in advance of the normal review process -- because Harris is not, of course, an operating facility. Furthermore, should any deficiencies in nighttime notification emerge from the Shearon Harris record, we could fashion l effective measures to deal with them on a site-specific basis. Rather, this letter is prompted by the possible generic implications of certain of the evidence in the Shearon Harris record, and our belief that such evidence should be called to your attention now. Most significantly, you should be aware of the following matters:

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1. The FEMA design critaria provide for siren sound covera 10d8(a)aboveambientnoiselevelsoraminimumof60d8(c)geof .

2. The " FEMA 43" reviews of siren system designs for operating nuclear facilities are based on sunner daytime conditions. Such reviews give no

! consideration to factors only applicable at night -- i.e. almost everyone is indoors and asleep, many with the windows closed. These

. factors are not offset by greater sound propagation at night.

3. The testimon air conditioning)y andisan that, for asiren outdoor house with sound theofwindows.

level 60 dB. theclosed (central is essentially zero. With the windows o.

probability of arousal is open, the probability from sleep (Tr. 9650).

7-85.

4. The sound levels necessary for high probability of arousal are substantially above the. FEMA minimum guidance. For example, a 505 probabfiity of arousal of an individual in a house with the windows closed requires outdoor sound levels of 90-99 decibels (Tr. 9927). The wide range in this estimate reflects the imperfect knowledge of stren i arousal capability, since direct tests have not been conducted, at least in the United States.

5. For the Harris assumed summer scenario -- including 36% of the houses in the EPZ with no air conditioning (windows open) -- arousal is estimated as approximately 705. Assuming the accuracy and acceptability of that estimate lower probable arousal rates in other climatic areas of the United States nevertheless suggest possible generic safety concerns -- particularly in the winter season, when more of the population may sleep with the windows closed.

6. We further note that overall arousal percentages for an EPZ can ..

mask the fact that. in areas of moderate housing density but with a fair number of houses more than one mile from a siren, a substantial ,

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percentage of the houses would have an arousal probability of less than l

505. For example, at siren 70 in the Harris EPZ. about 100 houses of

about 160 in that area, or 635, are in the 70-80 dB area. The l probability of arousing an individual in those houses with the windows closed is approximately 305, and is 555 for household arousal with two residents. If these houses correspond to U.S. averages 185 would have one resident. 305 would have two residents, and the average probability of arousing the household would be 435. Thus, although the risk of not being aroused, averaged over the EPZ. may be roughly 305. in some areas approximately 50% of the houses may have a risk of non-arousal of roughly 575.

NRC regulations require "early notification" to EPZ residents (10 C.F.R. 50.47(b)(5)) and this has been further defined to mean that the design objective of "the prompt public notification system shall be to have the capability to essentially complete the initial notification of the I l

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-3 public within the plume exposure pathway EPZ within about 15 minutes."

10 C.F.R. Part 50. Appendix E. IV D.3. The evidence we have cited indicates that in EPZs which rely primarily on siren notification it is our impression that that is the case for most comercial reactors)(, such notification would not be " essentially complete" urter some. typical nighttime conditions within 15 minutes. To be sure, emergency notification typically includes "back-up" notification by police, fire and other emergency vehicles driving prearranged routes with sirens sounding. However, as was testified to in the Shearon Harris case this back-up notification probably would not be accomplished in the 15-minute period. Testimony of Alvin H. Joyner at 42 ff. Tr. 9374. It seems doubtful that such back-up notification could be completed expeditiously

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if emergency workers had to first be reached and activated between midnight and 6:00 a.m.

We also are aware that persons who are aroused from sleep might not only arouse.their household, but that they would also tend to contact some -

neighbors, friends and relatives in the EPZ. This process of " informal _

notific'ation" was testified to at some length in the Shearon Harris hearing, and the Board does not doubt that such informal notification would occur to some degree. However, the phenomenon cannot be controlled like a stren level or a police car route, and its likely

- effects are difficult to quantify. Therefore, we question whether informal notification should be viewed as a substitute for planned

. notification.

According to testimony in the Shearon Harris case, the siren systems around operating nuclear plants have not been field-tested to determine what percentage of EPZ residents would actually be aroused by their -

activation between midnight and six a.m. Tr. 9935-40. We believe that sirne such testing would be prudent and merits Comission consideration. ,

Respectfully submitted.

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l JysL.Kelley l

LMM DpJamesH. Carp $hter

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% d, NM Glenn D. Eright 47 I

cc: H. Plaine. General Counsel

5. Chilk. Secretary i

Shearon Harris Service List

_..__ _ ___ _.___ _ ,__ _ ~ _ _ _ _ _ _

,. ENCLOSURE 2

.- t- Federal Emergency Management Agency Washington, D.C. 20472 DEC 6 GB5

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MSGANDEM FGts Dave Natthews Osief Baergency Preparedness Branch U.s tory canaission FEM: rt ruon ~ ,

Osief Technological Hazards Division f StBJECT: Nighttime Energency Notification 5

1his memorandsa transnits (see attachnent) FEMA's response to the Atomic Safety and Licensing Board's (ASIS) November 19, 1985 memoran&su notifying the n==fssion of possible generic safety probleas irwolving nighttime energency notification.

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PURPOSE:

The numbers of the Asta presiding over the application of Carolina Power and Light Co. Jo al. for an operating license for the Shearon Harris facility infonned the Ennissioners, in a letter dated November 19, 1985, of " evidence of possible generic safety problene irwolving nighttine emergency notification of residents in the plume energency planning nones surrounding nuclear power plants." This disaassion presents the Federal Snorgency Managerient Agency's (FEMA's) evaluation of the evidence presented in this letter and its conclusions concerning the existence of a possible generic safety problem.

BhCRGROLMD:

The Federal Bnergency Managenent Agency (FSUL), as the lead Federal agency in a Menorandun of Urx!erstanding 000) with the Nuclear Regulatory Cannission

, (NRC), is responsible for evaluating and approving pragt alert and notifi-cation systems that are installed arotmd consercial nuclear poter plants throughout the United States. These systens have been, or are being, installed within the terMaile Dnergency Planning Ione (EPI) of each nuclear power plant'by cogerative agreenents between NRC licensees and State and local goverrnents to provide a mechanien for rapidly alerting the p@lic in the event of an energency at the rmaclear power plant. IRC liconeses were mandated by the Imc to have alert and notification systens installed

, for all gerating nuclear power plants by February 1,1982, (originally July 1, 1981), or face enforcement actions. All nuclear poter plants scheduled to go on line after February 1,1982, sust have an alert and notification systen in place prior to operation.

10 CFR $ 50.47(b)(5) and 44 CFR Part 350 require that "means to provide early notification and clear instruction to the pcpulace within the p1true exp>sure patNay Dnergency Planning zone have been established." 10 CFR Part 50 Appendix E 5 D.3 requires in addition that "The design objective of the pragt p@lic notification systen shall be to have the capability to essentially caglete the initial notification of the p@lic within the  :

plume exposure pathway EPZ within about 15 minutes. 1he.use of this

{ notification capability will range fran innodiate notification of the .

! p@lic (within 15 miraates of the time that State and local officials are

• notified that a situation exists requiring urgent action) to the more i likely events @ere there is s@stantial time available for the State and ,

local governnental officials to make a judpent whether or not to activate the p@lic notification systen."

In 1980, NRC and FEMA pelished final pidance in NLREG-0654AIMA-REP-1 Rev.1, " Criteria for Preparation and Evaluation of Radiological Bnemency Response Plans and Preparedness in Support of Nuclear Pcwor Plants" which defined in technical terms, how the regulatory requirenants in 10 CFR 50 i

where to be not.

In 1983, FEMA p@lished interim widance in FEMA-43 " Standard (kalde for the Evaluation of Alert and Notificatic Systems for Nuclear Power Plants" l which organized the acceptance criteria of NtREG-0654 NEMA-REP-1, Rev.1 into a format that could be used by the utilities to doctment their alert

to and notification systene installations for review and appewal under FEMA's 44 CFR 350 process. FEMA-43 did not change the design criteria established in ERm-0654/FBUHLEP-1, Rev.1.

To date, over 60 plants have stbmitted their prapt alert and notification syste design plans, as prescribed in FEMA-43, for review by FBlA.

FBlA expects to ocuplete its twiew of these sites, including findings to the IstC under the MXJ, by the end of calendar 1986.

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the Asta ==hars, in their letter, cited the ibliowing evidence as the basis

!. of their concern:

"1) The FDIA design criteria provide fbr siren sound coverage of 10dB(a) above ambient noise levels or a minimum of 60dB(c).

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2) The ' FEMA-43' rwiews of siren systen designs fbr cperating

l. nuclear facilities are based on sunner daytine conditions.

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Such rwiews give no consideration to factors only applicable at night-i.e., almost everyone is indoors and asleep, many with the windows ciceed. 1hese factors are not offset by l greater sound propagation at ni$ t.

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3) The testimony is that, for a house with the windows ciceed (central air conditioning) and an outdoor siren sound level of 60dB, the probability of arousal fran sleep is essentially ,

zero. With the windows open, the probability is 7-84.

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i l 4) The sound levels necessary for high gobability of arousal -

l are substantially above the FDIA mininun guidance. Pbr exangle, a 50% probability of arousal d an individual ,

in a house with the windows closed requires outdoor sound -

levels of 90-99 decibels (Tr. 9927). The wide range in this

- estimate reflect.s the inperfect knowledge of siren arousal I capability, since direct tests have not been conducted, at i

least in the United States.

5) Pbr the Harris asstmed stener scenario--including 364 of the houses in the EP2 with no air conditioning (windows open)-

arousal is estimated as approximately 700. Asstning the l

accuracy and acceptability of that estimate, lower probable l arousal rates in other climatic areas of the United States i

nevertheless suggest possible generic safety concerne--per-ticularly in the winter season, then nors of the population may sleep with the windows closed.

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6) Me further note that overall arcusal percentages for an EPE can mask the fact that, in areas of moderate housing density but with a fair nsaber of houses sore than one mile fra a siren, a stbetantial percentage of the houses would have an arousal probability of less than 50%. Ibr example, at siren 70 in the Harris EP2, about 100 houset of about 160 in that area, or 634, are in the 70-80dB area. 1he grobability of arousing an individual in those houses with the windows closed is approminately 304, and is 55% for household arousal with two residents. If these houses correspond to U.S. coverages,18% would have one resident, 30% would have two reridents, and the average probability of arousing the household would be 434. 1hus,

, although the risk of not being aroused, averaged over the ,

EP2, may be roughly 304, in same areas appecuinately 50% of I the houses may have a risk of non-arousal of roughly 574.

7) Walso are aware that persons who are aroused from sleep might not only arouse their household, but that they would also tend to contact some neighbors, friends and relatives in the EP2. His process of " informal notificatiorf was testified to at same length in the thearon Harris hearing, and the Board does not doubt that such informal rx,tification would occur to see degree. However, the phencuenon cannot

! . be controlled like a siren level or a police car route, and its likely effects are difficult to quantify. Therefore, we question whether infonnel notification should be viewed as a substitute for planned notification."

! FE m EVALUATION Issue 01. For acceptance of the licensee's or applicant's siren systen, -

FDE-43 requires that the design report demonstrate that either "(a) tt.2 expected siren sound level generally exceeds 70dBC where the population .

density exceeds 2,000 persons per square mile and 60dBC in other inhabited .-

areas or (b) the expected siren mund level generally exceeds the overage measured daytine anblent sound levels by 108." It should be noted that these are minimun requirements and, in fact, cost effective siren systen design,

• ich locates sirens within population centers, results in many households being exposed siren sound levels that significantly exceed these l mininans. For exsiple, the Sheaton Harris siren systen, which is not atypical, provides sound levels in excess of 80dBC to ainost 60% of the residence in the EP2, under typical stamer nighttine conditions.

l Issue 92. The FEMA-43 reviews are based upon simmer daytime conditions only to the extent that sumer daytine conditions are used to model sound propa-l gation. This approad is taken because siren sound propagation is least l effective ducirg these conditions. Therefore an analysis that davonstrates i

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. that the FMA-43 and NL5tBG-0654/MMA4tEP-1, Rev. I requirements are set under average suuner daytime conditions provides reasonable assurance that they will be met in the event of an actual energency at any time of year. The attenuation of structures, eether windows are open or closed and the need to provide a signal loud enough to alert people was considered in establishing the ministan acceptable sound pressze levels. In particular, as NLELE-0654/

FEMMEP-1, Dev. I states: ,,

! "The los differential above daytime anbient is intended to i

.. provide a distinguishable signal ins of average residential construction mder storage conditions ...research has shown

, that a person is capable of being alerted by such a difforen-tial above or below the background anbient in the case.cf a

predominantly narrow band 300 to 800 Hz emitted by large f

sirens."

Issue 93. 1he cited tastimony is not in agreenent with FEMA expert witness testimony which indicates that the probability of arousing an individual from ,

sleep under the ciramstances cited with windows closed, is approstimately 204 ~

and with wi'ndous open is appecstinately 304. Using the mix of one and two -

.l resident households cited as representative of the U.S. by the board asmbers, this corresponds to an amrage household probability of direct (i.e., by siren) i' ,

arcuy.

open ofIt336 for houses should with be noted # indows thac these direct closedarcusal and 47% for housesare probabilities withfor windows  ;

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• households at the minimian acceptable sound levels and, mder actuni ciraam-i stances, would be supplanented by informal notification by other alerted residents [see evaluation of issue 97].

Issue 94. Again the cited testinony is not in agewenent with FEMA expert witness testimony that indicates that about 85dB wculd provide a 50%

probability of direct arousal of a sleeping individual. Using the mix of one and two resident Museholds cited as representative by the board mosers, this 85d8 sound level would be expected to arouse about 70% of all houseM1ds. As noted in the discussion of issue 3, this direct arousal would be supplemented by infonnal notification by other alerted residents.

Issue 95. The arousal estimated cited is fbr direct arousal only. Both FEMA- l and applicant expert witnesses testified that the inclusion of informal arousal nochaniens (see response to issue 07] would increase the percentage at the population aroused to approstimately 904.

Issue 96. FEMA agrees with the otmervation that, if the overall direct arousal percentage for an EPZ is 70% then there will be households for which j

the direct arousal rate is less than 50%. However, it should be noted that the letter's treatment of multi-resident hcuseholds is improper since it l A Daytime anbient is used because it is higher than nighttime anbient.

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ignores the 52% of the households nationwh with three or more reshnts.

If those are treated (conservatively] as two resident households, the correct average probability of arousing the household would be 50.54. 1hus, although FEMA agrees with the general observation that there will be households with direct arousal probabilities lower than 50%, we note that the cited figures ,

do not provide a s@ porting esseple. i

. Issue 97 In disregarding infonnal alerting nedanians, the board surnbers 1 are failing to conske a phenmenon which is known to occtr and for which quantitative date have been obtained on analogcus occasions. . The Mtc makes predictive findings, often on the basis of engineering judgerent, for other phonamena that are known to happen but are not strictly controllable (e.g.,

accidents). It in FEMA's judgment that conshration of informal alerting mo&anians, based upon quantification of actual experience by disaster

. sociologists, is appropriat.e so long as such conshration incorporates

. suitable conservatism. In addition, FEMA notes that infonnal notification sachanisms have been recognised by NRC boards in other hearings. See go. .

' Juk D P r (Catawba Itaclear Station, Units 1 and 2), IBP-84-37, 20 N.R.C.

933, 984) (Finding 10); Southern California Edison Conpany (San Onofre ~

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j Nuclear Generating Station, Units 2 and 3), IAP-82-46,15 N.R.C.1531, 1534-35 (1982).

l, CONCLUBIQ4:

Evaluation of the evidence presented in the Novesaber 19, 1985, letter to the Corsaissioners frcen the marbers of the ASIA presiding over the application of

! Carolina Power and Light Co. et al. for an gerating license for the Shearon Harris facility does not indi Ete that there are possible generic safety l problens involving nighttime emergency notification of residents in the plusas  ;

i emergency planning mones surrounding nuclear power plants. The evaluation 1 criteria in NLREG-0654/ FEMA 4tEP-1, Rev. I and the acceptance criteria in

! FEMA-43 are intended to answe that alert and notification systems that are designed and evaluated in accordance with these criteria meet letC's 10 CFR 50 Appendix E design objective "to have the capability to essentially caplete

• the initial notification of the p&lic within the plume exposure pathway .

within about 15 minutes.* The siren system for the Shearon Harris Nuclear ,

Power Plant, thich is not atypical of the siren systems at other nuclear power plants, tes designed, evaluated, and found to be acceptable under these criteria. The conclusion reached in FEMA's study, in response to the hearing contention, that this siren systen can be expected to arouse and alert approximately 90% of the EPE residents during a nighttime energency serves to confirm FEMA's judgement that siren systems designed and evaluated in accordance with NLREG-0654/ FEMA-REP-1, Rev. I and FEMA-43 meet the Mtc requirements for both daytine and nighttime alerting.

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ENCLOSURE 3 RE0VIREMENTS AND GUIDANCE RELATING TO PUELIC ALERT AND NOTIFICATION SY5TEMS

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The requirement for a public alert and notification system is set forth in 10 C.F.R. 550.47(b)(5) of the Commission's regulations. This regulation

! requires that: " . . . means to provide early notification and clear instruc-tiontothepopulacewithintheplumeexposurepathwayEmergencV*PlanningZone l

have been estaolished." Appendix E to 10 C.F.R. Part 50 establishes the mini-mun requirements for emergency plans in order to attain an acceptable state of emergency preparedness. 10 C.F.R. Part 50, Appendix E SIV. In addition, the Commission has established a design objective for the prompt public notification

! system; this design objective is that the system ". . . shall.have the capa-

! bility to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes." 10 C.F.R. Part 50, Appendix E SIV.D.3.

The responsibility for determining the adequacy of offsite emergency plans, including the adequacy of the prompt Federal Emefgency Management AFEMA). ency (public notification See, Memorandum system, rests~~with the of Understanding between NRC and FEMA, 50 Fed. . 15485 (AprT F18, 1985). FEMA makes its l determination of the adequacy o offsite emergency plans by evaluating their compliance with the standards and criteria of NUREG-0654/ FEMA-REP-1, Rev. 1 "CriteriaforPreparationandEvaluationofRadiologicalEmergencyResponsePlans j

and Preparedness in Support of Nuclear Power Plants (November 1980). NUREG-0654 l contains acceptance criteria for a prompt public notification system. NUREG-0654 Appendix 3, 58. The minimum acceptable design objectives for coverage by a j prompt public notification system are:

(a) Capability for providing both an alert signal and an informational or instructional message i to the population on an area wide basis throughout the 10-mile EPZ, within 15 minutes.

(b) The initial notification system will assure ,

direct coverage of essentially 100% of the .

population within 5 miles c. the site.

(c) Special arrangements will be made to assure 100% coverage within 45 minutes of the popu-lation who may not have received the initial notification within the entire plume exposure EPZ.

NUREG-0654, Appendix 3 at 3-3 1/ The acceptance criteria of NUREG-0654 have been further clarified by FEMA-43 ".Standard Guide for the Evaluation of Alert and NotificationSystemsforNuclearPowerPlants."

,l/ Appendix 3alsocontainsspecificacceptancecriteriarelatingtosirens and siren systems. These criteria are discussed further in the enclosed FEMA response.

WREG-0654 notes, however, that it is a design objective to meet the criteria of

$8 of Appendix 3, and that this does not mean that there is a ". . . guarantee that early notification can be provided for everyone with 1005 assurance or that the system when tested under actual field conditions will meet the design objec-tive in all cases." WREG-0654 at 3-1. This statement is consistent with the Commission's view of the effect of the actual operation of such a system. As the Commission stated, "The Commission recognizes that not every,. individual would necessarily be reached by the actual operation of such a system under all conditions of system use." 45 F,e,d. e R,eg.

e 55402 (August 19,1980).

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