ML20204H057
| ML20204H057 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/12/1988 |
| From: | Perrotti D Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20204H055 | List: |
| References | |
| OL-1, NUDOCS 8810240303 | |
| Download: ML20204H057 (14) | |
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Uti!TED STATES OF AMERICA NUCLEAR REGULATORY COMMISS!Off BEF0i:E THE ATOMIC SAFETY _AND LICENSING BOAPD In the Matter of )
Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF 50-444 OL-01 NEW HAMPSHIRE, ej al. On-site Emergency Planning
) and Safety Issues l j (Seabrook Station Units 1 ard *) )
AFFIDAVIT OF_ DONALD J. PERROTTI i
I, Denald J. Perrotti, being first duly sworn, hereby affirm that the responses to the questions set forth herein are true and correct to the best of my knowledge and belief:
Q1: Please state your full name, employer, and occupation, A1: Donald Joseph Perrotti. U.S. Nuclear Regulatory Comission, Emergency Preparedness Specialist. ,
I Mr. Perrotti, have you prepared a statement of your professional cualifications? !
A2: Yes, a statement of my professional qualifications is attached as an exhibit to this affidavit.
03: ?!r Perrotti, what is this purpose of this affidavit?
A3: This affidavit addresses the question whetner the "Motion For Sumary Disposition of The Massachusetts Attorney General's Amended
- Cor on On Notification Systen" filed by Applicants on l
j Sepu .er 1.', 1988 should be grantea. As is made clear by my l responses to the questions which follow, it is the Staff's position i that there are no genuine issues as to any material facts relating to
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whether Appticants have established means to provide early 0010240303 001012
, PDR ADOCK 05000443 J 0 YDR i
2 notification and clear instruction to the populace of the Massachusetts portion of the Seabrook emergency planning zone (EPZ).
For this reason, it is the Staff's position that Applicants are entitled as a matter of law to a favorable and summary disposition of the Attorney General's amenced contention on notification systems.
Q4: fir . Perrotti, have you reviewed Applicants' summary disposition motion and the materials submitted by them in support of their motion?
A4: Yes, I have. In particular, I have reviewed Applicants' "Statement Of Material Facts Not In Dispute" and agree with Statement Nos.1-4, 20-24, 37, 43, 45, 56, 70, 79-81, 85 and 87-90 and have no basis for disagreement with Statement Nos. 5-19, 25-36, 38-42, 44, 46-55, 57-69, 71-78, 82-84 and 86, i
05: Mr. Perrotti, are you familiar with Applicants' efforts to establish '
neans to provide clear instruction and early notification to the Massachusetts portion of the Seabrook EPZ in the even' of an emergency at the Seabrook Station?
A5: Yes, I an. In Supplement 4 to the Seabrook Safety Evaluation Report (SSER 4), which was issued in May, 1986 the Staff concluded that Applicants had adequately described the means for alerting and !
providing clear instruction to the public in the Seabrook EPZ. In
, this connection, the Staff found that the Seabrook Station Padiolegical Emergency Plan (SSREP) provided an adequate planning basis for an acceptable state of onsite emergency preparedness as required by 10 C.F.R. Part 50 and Appendix E thereto to warrent the issuance of a license authorizing fuel loading and low power (i.e.,
l up to 5% of rated power) operation. This conclusion was based, in l part, on the Staff's evaluation of the Seabrook Alert Notification i System (ANS) which provided for the installation and use of 133 l
i electrcnic alert notification sirens located throughout the Seabrook EPZ which were to be complemented by seven mechanical alert notification sirens installed in the City of Newburyport, Massachusetts.
As a result of legal actior.s taken by the connunities in the Massachusetts portion of the EPZ subsequent to the issuance of SSER 4 the emergency alert notification sirens and poles that were part of the Seabrook ANS were removed. On ilanuary 7, 1988, Applicants notified the Atomic Safety and Licensing Appeal Board that they ne longer were able to rely on these sirens for alerting the public in the Massachusetts portion of the Seabrook EPZ in the event of an 4 energency at the Seabrook Station.
On February 26, 1988, Applicants submitted a design overview for a proposed "Vehicular Alert and Notificatien System" (VANS) that would replace the fixed siren system for Massachusetts portion of the Seabrook EPZ. On April 1, 1988 Applicants submitted additional information requested by the Staff, and en April 28, 1988 the SSREP was revised to include a description of the VANS Also, during the period April 1 to Augus: 1, 1988, the Seabrook Plan Fo- Massachusetts Ccmunities ("$PMC") was amended to include a description of the VANS I as well as implementing procedures for activ(ting the VANS. In addition, on April 29, 1988 Applicants submitted a VANS final design ,
1 report for evaluatien hv the Federal Entervency Management Agency !
(FEMA) against FEMA-REP-10. "Guide for the Evaluation of Alert and i
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4 Notification Systems for Nuclear Power Plants," (November 1985). The Staff has reviewed the VANS description and, as explained in this affidavit, concluded that the Applicants have adequately described the means to provide early notification and clear instruction to the Massachusetts portion of the Seabrook EPZ in the event of an l emergency at the Seabrook Station.
06: Mr. Perratti, please escribe Applicants' Vehicular Alert Notification System.
A6: The Vehicular Alert Notification System or "VANS" is described in deteil in the April 1988 revision to Appendix E of the SSREP. There r.re six convitnities in the Massachusetts portion of the Seabrook FPZ: ,
Anesbury. Salisbury, Newbury, Newburyport, Merrimac, and k'es t Newbury. Combined, these six conr uni ties represent an area equivalent to approxinately 36 percent of the area of the entire Seabrook EPZ. The corrunities of Amesbury and Salisbury are the closest to the Seabrook Station; their nearest borders are within a 0-mile radius of the site. The communities of Merrimac, Newbury, West Newbury and the City of Newburyport fall within a 10-mile radius of the site.
According to the Applicants, the VANS design utilites proven ;
technology and maintains a configuration and operation similar to a fixed-pole siren system. The VANS is comprised of 16 heavy-duty construction vehicles deployed at six staging areas in or near the Massachusetts portion of the Seabrook EPZ. Each vehicle is equipped ,
i with a tel(scoping crane to which is attached a dual Whelen Model WS 4000 siren system rated at 134 dBC at 100 feet. The VANS vehicles l
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l will be dispatched from their staging areas at an ALERT or higher emergency classification. The Seabrook Station Short-Tenn Emergency Director (STED) will no+1'v the New Hampshire Yankee Offsite Response Office (NHY-ORO) Emergency Operations Center (EOC) Contact Point, who in turn will dispatch the VANS by notifying the VANS operators at the staging areas. The NHY-ORO EOC Contact Point and the VANS staging areas are each continuously staffed by trained personnel 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. Each staging area will be staffed witn enough oparators to deploy each VANS vehicle at all times.
Pursuant to established procedure, routine surveillance checks will be perforred to ensure the operability of the vehicle, siren, lift rechanism, and other supporting equipment (e.g., radios).
Surveillance, maintenance, and operability testing will be perforned en the VANS vehicles every 30 days. Applicants will maintain a -
number of VANS vehicles reserved for replar.ement of vehicles scheduled for surveillance and maintenance so that tr e full 4
corplement of vehicles needed to service the Massachusetts portion of the Seabrook EPZ will be available at all times.
l 07: Mr. Perrotti, how is the VANS intended to accomplish its function of providing early notification to the public in the event of an energency at the Seabrook Station?
j A7: The VANS is designed to accomplish the alerting function within 1
approximately 15 minutes following notification from the EOC Contact j Point. As I indicated in my respvnse to the preceding question,
] parsonnel needed in the event of an emergency (including VANS vehicle l n tors) are notified by telephone with radio backup. This
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. i notification will trigger the dispatch of the VANS vehicles to their I j assigned stations. The vehicles will then travel to their assigned l
stations via predetermined routes, and once there, be set up in the
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! operable position. At this point the VANS are fully deployed for '
remote operation. The VANS sirens are capable of receiving and !
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storing the actuation signal while in transit and of activating as l soon as the mast is raised to its vertical position. The VANS sirens
] also can be activated manually by the vehicle operator. !
i For design purposes, the 15 minute time interval is composed of l
"deployment" time (dispatch, transit and set up times) and "siren
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! activation" time. Except for location VL-165, deployment time of 12 !
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) minutes or less is estimated for each vehicle to reach its 1
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j destination. Location VL-165 is in an area just outside the 10-mile j t
i radius, but within the southwest edge of the Massachusetts portion of l
) the EPZ. Accorc'ing to Applicants, the populated portions of this i I l area will be provided acoustic coverage by a VANS vehicle dispatched I a ,
) from staging area 54 to acoustic location VL-165. The deployment and !
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I siren activation time needed to notify the persons served by location VL-165 is not expected to exceed 20 minutes. Since VANS vehicles are deplejed at the ALERT emergency classification level, this delayed j activation will only occur in an extremely fast-breaking emergency :
situation, Q8: Mr. Perrotti, does the Staff find Applicants' assertion that the VANS i
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vehicles can be deployed and sWens activated within fifteen minutes I after the onset of an emergency at the Seabrook Station reasonable? I A8: Yes. The Staff believes that this estimate is reasonable. The April t
{ 1, 1988 submittal contains preliminary staging area and acoustic ,
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- location designators and deployment and siren activation times. The j VANS design siren activation time is 3 minutes based on the r guidelines in NUREG-0654 The staging area and acoustic locations l
! were chosen to enable prompt dispatch of each vehicle to its i I :
pre-designated acoustical location. Final dispatch and transit times !
- were developed using a Seabrook Station procedure that requires l
- travelling and timing each route at various times during the day on i j ;
I weekdays and weekends over a two-week period using vehicles of the i same weight and class as the VANS vehicles. The procedure also l
, s procides for VANS route drive times to be obtained during three !
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additional seasons: summer, fall and winter.
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On April 26, 1988, the Staff performed an on-the-scene review of the j j steging areas and associated acoustic locations, including the !
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l location with the longest route transit tine in order to confirm the j 1 1
- time representations provided by Applicants in its April 1, 1988 ,
submittal. It was noted by the Staff that all routes to acoustic l j locations are hard-surfaced roads and consist of at least two lanes j l that will allow the VANS vehicle to pass stalled vehicles if j
! required. In addition, the Staff observed a training test of the l 4
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- VANS prot 6typs. Vehicle dispatch, set up and silent activation of (
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, the siren were observed while route transit was simulated. All of I I
l the areas reviewed by the Staff during this period were consistent a
l with the description in the 3eabrook plan, as revised on April 28,
- 1988, the submittals of February 26 and April 1,1988 and the 1930 l l
ANS Final Design Report.
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8-Q9: Mr. perrotti, are the VANS vehicles capable of serving their intended purpose, especially during inclement weather?
A9: The VANS vehicle is a corrnercially available, truck-mounted telescoping crane, et.mplete with outriggers. The crane is mounted on a heavy-duty constructen grade truck. The VANS vehicles will be located at outdoor and indoor staging areas. At indoor VANS staging areas the driveway access and facility will be maintained in a condition suitable for prompt VANS deployment. At outdoor VANS staging areas, the vehicles will employ engine block heaters to maintain the reliability of the vehicles. The truck has a high-grcund clearance and will be equipped with snow tires suitable for its intended use, i
The VANS truck is similar to those used for other energency services i under adverse weather conditions. Additionally, for most acoustic locations there is margin in the total time available for public alert and notification to accommodate additional route transit time [
due to adverse weather or abnormal route conditions. The earlv dispatch of the VANS vehicles at the ALERT stage will provide further i I
margin. In addition, backup VANS will te available at or near !
Seabrook Station to provide acoustic coverage in case a primary VANS vehicle fails. For these reasons, no appreciable delay attributable to adverse weather conditions is anticipated.
Q10: Mr. Perrotti, are the VANS sirens adequate to provide the require:1 level of tone coverage for the entire Massachusetts portion of the Seabrook EP:?
A10: According to the Applicants' Final Design Report on the Seabrook Station Public Alert and Notification Systen dated April 30, 1988 l
9 (1988 ANS Final Design Report), the sirens in the Seabrook plume EPZ !
are a combination of sirens rated at 122, 129 and 134 dBC at 100/ft.
There are 16 sirens (VANS) in the Massachusetts portion and 94 permanently mounted sirens in the New Hampshire portion of thrt Seabrook EPZ. The 1988 ANS Final Design Report has been incorporated :
into the State of New Hampshire radiological Emergency Response Plans. The 1988 ANS Final Design Report provides a description of the Seabrook EPZ topography, climatology, demography and ambient noise environment. The design criteria that was used by Applicants regarding minimum siren coverage of 60 dBC for population densities less than 2000 persons per square mile or 70 dBC sound level for population densities greater that 2000 people per square nile is
, based on the guidance of NUREG-0654 and Figure 1 of FEMA CPG 1-17, "Outdoor Warning Systems Guide" (March 1, 1980).
i The VANS design incorporates a siren system that is capable of repetitive remote or nanual activation for 3-5 uinutes. Thr. sle w are povered by batteries and an onboard generator that will allow the sirens to be capable of repetitive activation as necessary in response to an emergency at Seabrook. The tiren systen is capable of "voice mess 0ge" operation, although use of this mode is not required or anticipated. The current VANS utilizes a dual Whelen Model WS-4000 siren systen rated at 134 dBC at 100/ft, which provides '
i substantially greater coverage than the original fixed sirens. In ;
this nanner Applicants have been able to reduce the number of sirens needed for essentially 4a same coverage as was previously provided
by the fixed sirens. Tha range of the dual Whelen Model WS-4000 siren, as illustrated in Figure 6-1 of the April 1,1988 submittal, is consistent with Figure 1 of CPG 1-17. The six staging areas and 16 acoustic locations were chosen after the Whelen siren system was field-tested by Wyle Laboratories to verify siren rating. The VANS
. M will be tested at the same interval as the New Hampshire pole-mounted strens which is consistent with guidelines provided in NUREG-0654 Q11: Mr. Perrotti, has the Staff conducted any inspections of the VANS?
All: Yes. On June 1-2, 1988, NRC Region I office conducted a special safety inspection of the VANS, consisting of interviews with personnel, examinations of procedures and records, visits to each staging area and a subsequent timing of the runs to each of the 16 acoustic locations. (See Inspection Report No. 50-443/88-08). The timed runs and a review of the data compiled by Applicants indicated that the sirens can be sounded for each acoustical area within 15 ninutes, including location VL-165. This inspection confinted that l the VANS apoears to meet the design criteria for a public alerting and notification system.
Q12: !!r . Perrotti, doe. either 10 C.F.R. 6 50.47(b)(5) or NUREG-0654 :
require Applicants to develop a back-up alert notification system?
A12: No. There is no regulatory provision requiring Applicants to develop i
and have in place a back-up alert notification system. However,
- Applicants have taken this additional but unnecessary measure. The airborne alerting system developed by Applicants utilizes a helicopter based and staffed 24-hours-a-day at Seabrook Station.
This alerting system will b9 used as a secondary backup to the VANS.
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At the ALERT emergency classification or higher, the helicopter is placed on standby. If any VANS primary vehicle fails, a backup VANS vemcle will be dispatched to the acoustic location. However, if a backup VANS vehicle fails to reach the specific acoustic location, the helicopter will be launched to provide required acoustic coverage for that area. Implementing procedures for activating the VANS vehicles and the helicopter alerting system are included in the SPMC.
013: Mr. Perrotti, is it the Staff's position that the description of the VANS conforms to the requirements of 10 C.F.R. Part 50 and NUREG-06547 A13: Yes. Based upon its review of the SSREP, the Staff finds that the Applicants have dese.ribed adequately the means for providing early notificetion and clear instructions to the public in the Massachusetts portion of the Seabrook EPZ in accordance with the requirements of 10 C.F.R. Part 50 and the guidance criteria of hUREG-0654 The VANS appears to be a reasonable and adequate means of providing iarly notification 'o the Massachusetts portion of the Seabrook EPZ.
014: Mr. Perrotti, does this complete your affidavit?
Ald: Yes it does.
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0onald J. TerTotti l Subscribed to and sworn before me this d % ay of October 19CF,:
My Comission Expires: gg
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l DONALD J. PERROTTI ;
j OFFICE OF NUCLLAR REACTOR REGULATION :
- STATEMENT OF PROFESSIONAL CUALIFICATIONS j r I am employed as an tn.ergency Preparedness Specialist in the Emergency
1 j Preparedness Branch, Division of Radiation Protecticn and Emergency Preparedness, i 4 .
Office of Nuclear Reactor Regulation. U.S. Nuclear Regulatory Comission. I l l
) have responsibility for the review and evaluation of radiological emergency l l plans submitted by reactor applicants and licensees to assure that proposed r
plans meet the regulatory requirements and guidance of the Comission. I also !
i function as a Team Leader and Team Member on Emergency Preparedness Appraisal !
j Teams engaged in the onsite irspection of the implementation phase of licensee (
) energency programs. I observe nuclear power plant emergency drills and exercises l 1
involving State and local government response agencies and participate in inter- l 7 ,
agency critiques. I served as the staff's expert witness for onsite emergency ;
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planning during the evidentiary hearings for the Seabrook, Waterford 3 and [
j Perry 1 operating licenses and for the Clinch River Breeder Reactor construction [
- penni t. i i
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from December 1976 to October 1980 I was employed at the NRC's Region 11 !
t j Uf fice of Inspection and Enforcement in Atlanta, Georgia. During the latter !
- portion of this time I was the lead inspector for Region !! emergency planning
) inspections at nuclear power reactors and fuel facilities. My respcnsibilities j ,
, incluoed planning, conducting and documenting inspections cf licensees' emer- 1 1
) gency plans and procedures, emergency facilities and equipment, emergency l
) l l training, exercises and drills, and coordination with offsite support agencies.
From April 1977 to August 1978. I assisted my imediate supervisor who served as
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I Chairman of the Federal Regional Advisory Comittee (RAC) in the review of j State Radiological Emergency Plans. During October 1978 1 assisted in the review '
i and approval of energency plans for two nuclear fuel facilities. During the 1
l period of March - August 1979. I participat2d in the temission's coverage of l J >
j environmental monitoring programs at Three Mile Island, where I served as !
i i Emergency Monitoring Team Leader; in that capacity, I was responsible for coor-i i l
tiination with State and Federal agencies engeged in measurement a'id evaluation ;
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) of environn. ental radioactivity levels in the vicinity of the TMI nuclear plant. l l I i
l From 1973 to 1976, I was employed at Fiorida Pcwer and Light Company's f f
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- Turkey Point f01 clear Power Plant as Health Physics instructor. My duties i included radiatien safety training of plant personnel (general errployees end f technicians), special project reports such as providing background material [
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j for ranagert_nt conwent on proposed changes to the Code of Federal Regulations, !
I and maintaining radiation exposure records for plant personnel.
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Frer 1953 to 1973. I served in the Unitec States Army. As a member of the j U.S. Army Engineer Reactors Group during the period 1961 - 1973, I perforsed a f j
i variety of jobs with varying degrees of responsibility as rank and experience I were gained. Among my more responsible jobs were shift health physics techni- !
l cian at the FM-3A haval nuclear power plant in McMardo, Antarctia (1965-1966), !
I Senior Health Physics / Process Chenistry instructor at Ft. Belvoir, Virginia j (1966-1972.), and Project Officer for the SM-1 nuclear power plant (1972-1973), i i
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. / r 1 received an Associate of Arts Degree from the New York State Regents, e Albany, NY, in 1973. In addition, I attendea Army service schools including l
Special Nuclear Weapons Disposal and the 52-week Nuclear Power Plant Operators !
course. I have completed the following U.S. Public Health Service courses:
Basic Radiological Health i Radionuclide Analysis by Gansna Spectroscopy ;
Environmental Radiation Surveillance Analysis of Radionuclides in Water !
Occupational Radiation Protection !
Chemical Analysia for Water Quality Statistical Methods - Quality Control in the Laboratory Operativ.ial Aspects of Radiation Surveillance :
Reactor Hazards Evaluation I r
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1 attended the "Radiological Emergency Response Operations" course at the l
Nevsda Test Site, the
- Planning for Nuclear Emergencies" course at Harvard University, and the "Advanced Management of Radiation Accidents" course at the University of New Pexico School of Medicire.
I hase successfully completed the NRC's Pressurized Water Reactor Technology, l Boiling Water Reactor Technology, Probat'ility Risk Assessment (PRA) Fundamentals, FRA Ferspectives for Emergency Planning and Response and PRA Basics for Inspec-tion Application courses.
I am and have been a member of the Health Physics Society since 1974.