ML20205M006
ML20205M006 | |
Person / Time | |
---|---|
Site: | Seabrook ![]() |
Issue date: | 03/20/1987 |
From: | Berry G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
To: | Atomic Safety and Licensing Board Panel |
References | |
CON-#287-2953 OL-1, NUDOCS 8704020242 | |
Download: ML20205M006 (27) | |
Text
.
7 953 March 20, 1987 DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 87 mR 27 P2:57 BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD 6FFICE 0? HL :.fMn 00CKETmu v. ;FN,LL In the Matter of )
1
)
i PUBLIC SERVICE COf1PANY OF ) Docket Nos. 50-443-OL-1 NEW HAMPSITIRE, ET AL. ) 50-444-OL-1
) (On-site EmerFency Planning (Seabrook Station, Units 1 and 2) ) and Safety Issues)
NRC STAFF RESPONSE TO MASSACHUSETTS ATTORNEY GENERAL'S MOTION TO REOPEN RECORD AND RECONSIDER LATE-FILED CONTENTION WITH REVISED BASIS
] I. INTRODUCTION On March 3, 1987, the Attorney General of the Commonwealth of
- Massachusetts (" Attorney General") filed a " Motion to Reconsider
] Late-Filed Contention With Revised Basis and to Reopen the Record"
(" Motion") . The Attorney General requests the Board to reopen the on-site emergency planning phase of this proceeding and admit his late-filed contention which alleges that " Applicants have failed to comply with the provisions of 10 C.F.R. I 50.47(b)(5) and Part 50, Appendix E, 9 IV(D)(1) and (3), because no administrative or physical means have been established to provide early notification and clear instruction to the populace within the plume exposure pathway located within the Town of Merrimac, Massachusetts." Id. at 2. As explained below, because the Attorney General has not presented a "tsignificant safety or environmental issue," and has not shown a likelihood that a different result would be reached in the proceeding, the motion to reopen the record should be
'l denied.
B704020242 870320 PDR ADOCK 05000443 G PDR g
i 1
II. BACKGROUND The instant motion represents the Attorney General's second attempt to reopen the on-site emergency planning record to consider a late-nied contention challenging the adequacy of Applicants' siren system. The late-filed contention now proffered by the Attorney General is identical to !
the late-nled contention proposed by the Attorney General on January 12, 1987 and rejected by the Board on February 6,1987. See Memorandum and Order (Denying Mass. Motion of January 12, 1987) (" Order") at 1 n.1. The basis for the Attorney General's January 12, 1987 contention was that one of the three alert sirens which were to be used by Applicants to notify the citizens of the Town of Merrimac, Massachussets in the event of an emergency had not been installed and the other sirens were not connected to electrical power lines. See Order at 3-4. The Board refected the Attorney General's contention because a balancing of the nye factors listed in 10 C.F.R. I 2.714(a)(1) did not weigh in favor of admitting the contention. Order at 2-7. The Board also ruled that the motion to reopen the record failed to meet the standards set forth in 10 C.F.R. I 2.734. In this regard, the Board found that a "signincant safety issue [is] not involved and that a materially different result would not be or would not have been likely had the newly proffered evidence been considered initially." Id. at 9. The Board was persuaded by the responses of the Staff and Applicants "that the noise levels of the two strens [used by Applicants to notify the citizens of Merrimac in the event of an emergency] meet regulatory requirements and that the adequacy of the siren coverage will be routinely examined as part of the emergency exercise held before full power licensing." Id. at 9.
t
t The Attorney General has now introduced a new basis for his contention. According to the Attorney General, in certain areas of a
Merrimac, Applicants' siren system " fails to meet either of the alternative NRC/ FEMA sound level acceptance criteria for providing reasonable 1
assurance that the populace will hear the sirens during an emergency."
l Motion at 2. In particular, the Attorney General alleges that the !
i expected sound pressure from Applicants' sirens does not exceed the ,
I average measured summer daytime ambient sound pressure level in these i
areas by at least 10 decibels (dB). Id. In support of his position, the Attorney General has submitted the aindavit of Brion Koning, an
, acoustical consultant.
As explained below , the revised basis offered by the Attorney l General does not lead to a conclusion different from the one already 3
reached by the Doard -- i.e., a significant safety issue is not involved and a materially different result would not be likely had the newly
! proffered evidence been considered initially.
I i
III. DISCUSSION A. Standards Governing Motions to Roopen In NRC proceedings, motions to reopen a record are governed by 10 C.F.R. I 2.734. See 51 Fed. Reg. 19535 (May 30, 1986). Section
, 2.734(a) of this regulation, which codinen NRC case law, provides i i
1 i (a) A motion to reopen a closed record to consider !
! additional evidence will not be granted unless the i following criteria are satisned:
f (1) The motion must be timely, except that an 1
exceptionally grave issue may be considered in the discretion of the nresiding ofncer even if untimely t presented.
)
l i
)
j
- (2) The motion must address a significant safety or environmental issue.
(3) The motion must demonstrate that a materially different result would be or would have been likely had the newly proffered evidence been considered initially.
10 C.F.R. I 2.734(a). Reopening a closed record is, as the Commission has noted, an " extraordinary action" and thus requirec a movant to bear "a heavy burden." See 51 Fed. Reg at 19538 accord Kansas Gas and Electric Company (Wolf Creek Generating Station. Unit 1), ALAB-462, 7 NRC 320, 338 (1978). The reason a motion to reopen is not to be granted lightly is becct.se of the public interest in ensuring that "once a record has been closed and all timely-raised issues have been resolved, finality will attach to the hearing process." 51 Fed. Reg. at 19539. As the Third Circuit remarked: "[ Alt some point . . . proceedings must terminato in outcomes." In Re Three Mile Island Alert, Inc. v. NRC, 771 F.2d '720, 740 (3d Cir.1985). This principle applies with particular force to a request to reconsider a motion to reopen that previously has been denied.
The thrust of the Attorney General's motion is that Applicants have failed to provide reliable ambient background sound measurements (as required by NUREG-0654 / FEMA-REP-1, Rev.1) to show that the expected sound pressure level emitted by the Merrimac alert strens l
I exceeds by ten decibels (dB) the average summer daytime ambient background noise levels in certain areas of Merrimac. Motion at 3. In J
the Attorney General's view, Applicants' sound measurements are flawed i
because: (1) they were taken on January 19, 1987, a federal and state holiday, and thus a day unrepreacntative of normal sound levels: and 1
(!!) they were taken in the 1000 !!z octave band instead of the 500 !!z
)
1
, _,_ ___ __ . _ _ _ ~ _ _ _ _ _ _ __ __ .
_ = _ _ - ._ _ _ . . - . . .-
l 1
/ octave band. M. at 3-4. According to the Attorney General, background measurements taken in the 1000 H band will produce
- readings approximately 3 dH lower than those taken in the 500 Hz octave band. Id,. at 3.
Applicants do not dispute that the initial background sound i
measurements were taken in the wrong octave band and on Martin Luther King, Jr. Day. See Applicants' Answer To Motion Of Attorney General
! James M. Shanno.1 to Feconsider Late-Filed Contention With Revised Basis !
i i And To Reopen The Record at 3 (March 13, 1987) (" Answer").
j: According to Anthony Callendrello, Manager of Emergency Planning at f Seabrook, incorrect information regarding the frequency of the Merrimac
[ sirens inadvertently was provided to HMM Associates ("l!MM"), the firm I l that conducted the initial background sound measurements. See Affidavit of Anthony M. Callendrello at 13, attached to Answer. Subsequently, IIMM was informed that the correct frequency of the Merrimac sirens was 680 Hz, not 800 Hz as previously assumed. See Answer, Attachment H.
I Accordingly, on March 10, 1987, HMM conducted additional background sound measurements using a frequency band width of one-third octave ,
i centered on 630 IJz. d.: Callendrello Affidavit at 14. The frequency of the Merrimac strens (680 Hr) is encompassed within that band width.
d at 15.
Id. The results obtained by HMM using the new frequency show 1
1 that the sound pressure level of the Merrimac strens exceeds the ambient
) sound level of the affected areas of Merrimac by at least 10 dB , as
- required by NUREG-0654/ FEMA-IIEP-1, Rev.1. See Id. at i 7
- Answer, i
) Attachment 11
! l I I i
The report prepared by HMM establishes that the methodology used by !!MM to monitor the background noise in the affected areas of Merrimac complies with the requirements of FEMA-REP-10. Compare Answer, Attachment B, with FEMA-REP-10 at E-8, E-9. HMM's report:
(i) describes how the average ambient sound pressure levels were determined and explains why the particular survey locations used were l
selected (ii) identiftes the frequency range, time span, and location for the measurements obtained (iii) identifles and explains any assumptions I used in determining the ambient background sound levels (iv) describes i the relationship between the population density and the ambient i
background sound pressure levels and (v) describes the effect, if any,
!, of major transportation routes and commercial activities in the affected j areas. See Answer Attachment B at 1-3.
I
- As noted above, HMM used a one-third octave frequency band width l centered on 630 Hz (which includes the 680 Hz frequency of the Merrimac sirens) in measuring th smbient sound levels of the affected areas of Merrimac. The use of a one-third octave band width is consistent with
]
FEMA's guidelines. FEMA's September 1983 interim " Standard Guide for Nuclear Power Plants" states expressly that "[tlhe ambient background i noisc level should be measured in that one-third octave band (s) containing the predominant tone (s) of the alren(s) u sed ." FEMA-43, I E.6.2.1 (emphasis added). The final version of the Standard Guide 1
(FEMA-REP-10) was issued in November 1985 therein, in response to i
j industry comments, FEMA relaxed the recommendation that ambient
) background noise measurements be taken in the one-third octave band "to i
! permit use of the full octave band in which the predominant stren tone 1
1 1
i
.y i
occurs [.]" 50 Fed. Reg. 43804, 43805 (October 23, 1985). However, while FEffA-REP-10 supersedes FEffA-43, FEMA has stated that FEMA-43 may still be used as a guide for the design and evaluation of alert and l notification systems (see cover to FEMA-REP-10). II Consequently, it is
! permissible to use either a full octave or a one-third octave band to i
! measure ambient background noise.' See 50 Fed. Reg, at 43085.
1 The use of a one-third octave band width by FEMA is recognized by the Attorney General's acoustical expert who states:
Appendix 3, Section (C3a) of NUREG-0654 indicates that large strens emit sound energy in "... a predominately narrow band 300 to 800 HZ. . ." Section (C3f) states: " Background dB should be l determinted in a band about the stren signal frequency.
1 Inclusion of background noise energy from outside this band
! could be misleading." Although Section (C3f) does not specify i
the band width (octave,1/3 octave,1/10 octave, etc.), it clearly ,
j indicates that background measurements should be conducted in a '
band that includes the stren signal frequency.
i Koning Affidavit at 1 5. Thus experts for the Applicants and the l ,
)' Attorney General agree that ambient background sound levels
! measurements should be conducted in a band that includes the siren :'
1 j signal frequency. Compare 5(oning Affidavit at 15, with Callendrello .
i j Affidavit at 14-5. The only variance in the positions of Mr. Callendrello 1
t I and Mr. Koning is that the former states unequivocably that the use of a 1
j one-third octave band width centered on 630 Hz is permissible under 1
j FEMA guidelines while the latter implies that it is proper. Compare l Callendrello Affidavit at 16, with Koning Affidavit at 15. As FEMA has i
i i
t i 1/ For the convenience of the Doard and parties, the cover, table of
- contents , and section E.6.2.1 of FEMA-43 is enclosed as Attach-i ment 1 hereto and the cover, table of contents, and section E.6.2.1
); of FEMA-REP-10 is enclosed as Attachment 2 i,
,e ev,-- - - - - -eer--,w,-----,-e,v-e---r-r-----e=rw-,-~ - - w--, -- w41, e--u-m--.m ---eee---------r-v-*-+----r----------
]. i .
noted, however, so long as the octave band width used encompasses the i frequency of the predominant tone of the alert sirens, it is permissible to l^
use either a full or one-third octave band width in in measuring ambient background sound levels. See 50 Fed. Reg. at 43085, and Attachments 1 and 2 hereto.
Accordingly, in view of these considerations, it appears that no
, significant safety issue is raised by the Attorney General's motion to l
reopen. Similarly, since Applicants' Merrimac sirens appear to satisfy the :
l spplicable regulatory guidance, it cannot be said that the Board likely would reach a materially different result with respect to the on-site f emergency planning phase of this proceeding had the evidence now proffered by the Attorney General been considered initially. U In the absence of a showing that a significant safety issue is involved and that
! thu ovide'nce sought to be presented likely would lead to a materially different result, a motion to reopen a closed record must be denied.
- 10 C.F.R. I 2.734(a).
f B. Late-Filed Contentions The Commission has made it clear that a motion to reopen the record
! to admit a previously uncontested issue must meet the standards set forth L
I
~
2/ The background sound nessurements taken by HMM Associates were '
not conducted in the summer as recommended in FEMA-REP-10. See Callendrello Affidavit at 19. That the sound pressure level of We Merrimac sirens exceeds by 10 dB the summer ambient background
, sound level is a matter capable of verification by objective criteria:
i di that need be done is to take a new measurement in the summer.
l Id. Consequently, Applicants' failure to conduct an ambient j Eackground sound measurement in the summer does not raise a i significant safety issue in the circumstances presented here.
1 t
-D-
- in 10 C.F.R. 5 2.714(a)(1) in addition to the applicable criteria for reopening the record. Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), C LI-8 2-39, 16 NHC 1712, 1714-15 (1982); 51 Fed. Reg. at 19537. As explained above, the Attorney General's motion to reopen does not involve a significant safety issue, nor is consideration of the evidence which the Attorney General seeks to present likely to lead to a materfally different result in the on-site emergency planning phase of this proceeding. Therefore, the Attorney i
General's motion to reopen the record does not meet the standards set forth in 10 C.F.R 6 2.734(a). In view of this circumstance, it is i unnecessary to discuss whether the Attorney General's late-filed siren contention would pass the five-factor test set forth in 10 C.F.H.
I I 2.714(a)(1).
IV. CONCLUSION ror the reasons stated in this Responso, the Attorney General's motion to reopen the record to admit his late-filed siren contention should be denied.
R Sctfully submitted, I
Greg rr3 Counsa for RC Staff w
Dated at Bethesda, Marylane thin 20th day of Pfarch,1987 )
~
- Attachment I l s
.. r. .
-...............\.
l
. . ..,.. . W, J> .
i , , . . . . .
,. ..w$.p.. ' FEMA-43 /.Septem. ber 1983 < .) e
. . , . ,3, . -.
,. 4
. . .y . . ..-
. 42
.3
. . .'.f.a-g t:p. .,
,, i. ' .,
4 * '
. r* ,
s 4.
f
.i, .., . . .. . .
a, .
. .s, .
, ,t r . . .', 9li. ' - *.,', .
L
- ^) . . ) jv- ,
<,'. *[il,i$d.' ' .(d.*g* *; ,b. *,, .' i" '
, .g .v. . .g. *'
...,..,1.. ;. y pL, , ,, . j . a .. m. . .i . . :,,J . .r..
.j...
4 .. -
.. . . . . + . . . -<.,---
v.s
. . .. .c. .,.. - w...
.c g. n .4.. r e.. l.. u
. .. . ry . .e < . . 1.,.'.. . - 4,*~.. . 6. .. w . * .
. . . . ......... . . . . . . . . . ' -. ... .g.)
'*.....,...%...s.Q.,..,,,,...,..,
~
.f.;: ; . . ,g . . .) C .'i.Mr.t.
).% ' .'.' ).. A' ' Y .' * .' ' , ', .,,.
r L .
s
- 4. ,' i . . ' .t .
w n : . . ,.. . . .f.
a g.. ,.wf...4 .
. i..... . . . + . . . . . . :w
. b .;k'p,..c.
.....,. .w t .,
...,.,....w.
&, .sg* o . . , 4 .e.%. . . wit,:r. . ;,,.p y .. .
, . .x. .-
. . .a
.i. , .. ; ve., p . . . . . , ... ; . . .
, ca ..
. n..... . . ~. w ;.. ,, ' g x p6. ..< i . .., ....m..gw,A.,, .r
- .n. . w.7....v w . .
..p i.,p 1Q ip.' ..m H.m M;& :. .n: pt. .%w,.W )
.k. e ,. . . , .:'. .
l i . .
. .; i . .cs . . ;/..,,*.,. .
/ s W .f.'; .y.s : . , . .; v.J " f -- ..
- MM.
1 l ge yi ,#.f..
. SI%.
t h f L, g/.. (
1V.DARD.L.GUIDEW.,b..'s.#g,',RiTHE 3* .s4 -.ge. p-
.' 6 a . a. .'. 8 . ' , , '.'J f
"",..[4 #I ,.3 g
O p, 4? .. *.. s ! . ,* s', . ,. '.P... 'j 41 J ,,s' d E..V, ALUA..T e w y 4 4 - . f s.t,%,.g'.
. .6.
i 32@Fj$E$RTMNDIN INIC1 TION d'VSIMN_ A.
a El.m
,. ., e v9.m. a.g{MM:#
j i &&,p,.c. ,, . ,: FOR; NUCLEAR: POWER PIANTS,,.,.
s..-
w" , .
. c . m. . !
.O .w f ,. m. a ..
s m ,. .
M?@%.. .M9W&b. 4, il E 9 , .. .... . .s..
. > . ..,...,.. . .1 g.r. .q s . v . . , ...
. e *f. t g'. * - e 1
- 1 i
+
ef I
. ' e 1
.e .
l g* .
= m e .. . * . * . . . . . s . , ,s I 8,
- m '*4s.M'[ . # '
j.., '
e, s , . . . . , ,
. h et
- i.. .
, , ^ ' ' . ' , , '.' tc. . . . g a, . r , ,' g ' y ' . ,, I l s~ ,'lI s
.. .s. . ,
y . . ..
- ..el . . . . ...N.
,q . ~.,.,eg. 4 ,, . g . . ,; j., 9. . , .,,. , . , ,
. . . . . ~ ,, .. ,,j.... ., ,g . . , g , ., ; y, , , , ,.,.;,, ,
, .9 ,3 s ., ,.g .. 9. .y . ,
. 8
, , ,,,i- .
e .ag,. . , . . . .f , A y.. , . 9
- 1. -
.,'. ...g... , , .t . ..
...g.h 4
t e .. . s e.,(5.
r
, .; . .7 .,,, c,, , . > ic.,, b, ,;, , .. ,..f..,',,,...,, . ,,
! %(1{ ,g .,.,h.'. )t.i a fs . ,.,"5
,i,:g yi.t. . . g, , e. . ,4,e g.l. s g ,.
T**.d .
, ..); . 5, { . <i,..x ,, ,, , ..
... ,- ,.. ., .,b + . w ,3.<r.,.,....
, ..tet.. .y .,.,g.p.. 3, .
4 ..a, ; p, ., y ,.
s
.(
, ,, , , .' , b(, g, ,R ,,,,t t, p.,pN,.. s s .. ,. . . ... .1
.3
. . , . . ., ., J, .
.t. .. , 4, ,, .
. 6. . . , . . .. .
4 . r . q ll ,. . . . . ....,a *
/.. . .. . ,3, I., .
i.
W.. ! ..,3 . i . .
a , .
..%..D; O sFEDERAL EMERGENCY
\
./ (3 -
- i. '
i i %.w as.MANAGEMENT ..
,, AGENCY I
i \
\
TABLE OF CONTENTS .
INTRODUCTION 1 E. PLANNING STANDARD: NOTIFICATION METHODS :
AND PROCEDURES E-1 F. PLANNING STANDARD: EMERGENCY COMMUNICATIONS F-1 N. PLANNING STANDARD: EXERCISES AND DRILLS N-1 APPENDIX 1: RECOMMENDED FORMAT FOR SUBMITTALS 1-1 DESCRIBING ALERT AND NOTIFICATION SYSTEMS e
5 0
I i
9 l
l i
l E.6.2.1 Sirenn Wherover proposed as part of an alert syntom, a siren syntom donign shall be documented in the donign report. The maps men-tiened,above must additionally delinontos (1) arcan where the population excoedo 2,000 persono por square mile (based on square-milo incromonto) and arcan virtually unpopulated, (2) unique niron identifiers and airon locations, and (3) airon sound contours for C-woighted nound pronauro levoin (SPL) of 60 dBC and 70 dDC. In addition, nhould the donign report choono to show that the niron sound icvol excendo an average measured outdoor daytime (period betwoon 7 a.m. and 10 p.m.) ambient sound lovel(n) by 10 dB, the maps nontioned abovo must include appropriato airon nound lovel contourn for the SPL that in 10 dB above the average outdoor day- l tino ambient nound levol(s). The ambient background .toino lovel should be meanured in that one-third octava band (n) containing the prodominant tono (n) of the ajron(s) used. The C-weighted SPL ,
for thono nound lovel contourn munt bo indicated.
The donign report nhould include a doncription of how the nound contourn woro calculated. The calculation nhould account for, E-6
at a minimum. the effects of topographical featurco, temp 3rature,
{, relative humidity, wind direction, wind magnitude, measured siren sound output, and siren location / height.- Average summer f '. daytime weather conditions may be utilized. The sound contours '
may be based on Appendix 3 of NUREG-0654/ FEMA-REP-1 including ;
the use, in the absence of intervening topographical features, of the sound attenuation factor of 10 dB per doubling of distance used in FEMA CPG l-17.* Where topographical features present .
sound barriers, they must be considered in attenuation compu-i tations. The design report should identify what assumptions from j NUREG-0654/ FEMA-REP-1 were used, i
i I The validity of the calculatien of siren SPL contours depends upon
) the validity of the siren sound output at 100 feet from the siren.
The reasonableness of the method for determining the siren sound j output and the resulting SPL contours should be documented in the design report. There are at least two ways to determine siren j sound output
)
i Onsite field measurements around at least one of each j ,
type of siren used in the EPZr and l .
Anochoic, semi-anechoic, or reverberation chamber tests j in a qualified laboratory on sirens that are representative 3
of each type of siren used in the EPZ.
Since consensus standards for field and chamber siren measurements j are not available, the design report must detail the measurement procedures employed and their rationale.
l The NURCO-0654/ FEMA-REP-1 criteria, as quoted earlier, are satisfied j when the design :erort shows that, for those geographical areas to f I be covered by fixed sirens, either (a) the expected siren sound i
1 .
level generally exceeds 70 dBC where the population density ex- l
- coeds 2,000 persono per square mile and 60 dDC in other inhabited j
i .
areas, or (b) the expected siren sound level generally exceeds l
l i
- " outdoor Warning Systems Guide," CP0 1-17, Federal Emergency l !!anagement Agency, March 1, 1900.
l E-7
l l .
the average measured daytime ambient sound levels by 10 dB. Should the design report show that the siren sound level exceeds a meas-i ured ambient by 10 dB, the following information should be provided:
(1) a description of how the average daytime ambient sound icvols i were determined including survey locations and the rationale for their selection, (2) identification of actual measurements including
- frequency range measured and measurement timo span and location, (3) assumptions used in the design report along with rationale, (4) population density relationships to measured ambient levels, (5) effects of major transportation routes, and (6) effects of com-mercial activities. Where the estimated siren sound level does not generally meet the specified lovel based either on population density or a 10 dB differential between the measured averaga am-bient sound and estimated siron sound level, the siren system must be enhanced by other alerting methods which must be described in the design report.
Once the siren system is installed and operational, thoro should be a test and maintenanco program for the system. The program should include regularly scheduled testing of the siren system including silent, growl, and full-scale tests. Silent tests should be conducted at least overy two wooks. Growl testa should be conducted at least quarterly'and when preventativo maintenance is performod. Full-scalo tonting should be conducted at least annually and as required for formal exorcises. The maintenance of the siren system should include prompt repair to any compononts which do not perform as expected during the tests. The program should include records of tests and repaire performed. The oper- '
ability of the siron system will be considered acceptable when an average of 90% of the nirons can be shown to be functional over a 12-month period, an datormined by a simplo averago of all testa conducted. Special considerations will be given for siron systems that havo not boon oporational for 12 months. Available records of the maintenanco program should be summarized, assessed, and included in tho design report.
l l
l l
s l
E-0
. Attachment 2 .
FEMA F1EP 10/ November 1985 FEDERAL EMERGENCY MANAGEMENT AGENCY 2 "J::M t^1" "*"*" ""
G. ui.de for m, e evaluation o Alert and Notification Systems !
for Nuclear Power Plants I
6,+.n* - ., .
- v. -
...s...... .. . - ,, . ..
- WM _ . __ w - T M *** . -----,m99**2, _ v , . m , - s _- 2_ m . .m :_-._ ,_m _-
-- -x g M _ - -__-:_u c.t_hw,
^
- -. - ,r a ~ _~c --_u _ __ -
\
E '_**:* t-x t- -. .2+-: -- m 12-_ . _ - .,. - - - = . = . , - -- -
- . .u _w = = . x - -
r r c;j u ; -r.. ... r
_'L_...-- m- ---
. _ _z __ r _ z --
L%**DQb -- -
' o.'). W::_Q: T -
_ :,h's k** D: = 2_'-2 L _ g ,; y :. , 1 _ . . , -
l
._ _ . , , , . . . , . - . . , -- . . - n.
_ _ . __c . . - _ . -
__ a _ _ m a . . _ . . _ _ ._ .i ._ = ee..,
.. . _v.,. _ . ~. . , - ,
g_...r. _ _
e___ . m. m _,a m...<._1 .......;.. . .
2....,
m, c. . ; ... ... c... . c_ , .. .; . . . .. ; . c;. 3 . c. . . .s ,,
w {4 --
- * '** S N.*_ ' . '[f)wmY wm Y' OY'b ', kb. Y' . ,;- ". _' ,'_bbJ'Y-_
.' * ' * *E 'n e . ..// . 'f*I,I .
( . '. ' ( l' . *d *
- 4. /.E. ' .','N5 .' #
f
. . ._ r.
) yr ,
L_is e em. - -
, '.4 e 6
_ L8 ., _e.
e I
q-J
- m' ' % ,_* Id
- m. m . w m.m.- .
1
, .r
- t* 1 ****
_. _, s.
gA!'+,t d#
~
/ # * ' '
' ' , . : ', , ., .-- -- je 0* .v
. . I,a,,-J,,,,,,
I 'a **, , )sejt # ,
, ,}.,, ,
- se
- _ - -, 4 f [' _a4 m,4],*4 e,s* 4im, Y2 *e.'
h,j ? O #.. lf ,* 8 '
- 1 *
)
_A a
FEMA-REP-10/ November 1985 t
GUIDE FOR THE EVALUATION OF ALERT AND NOTIFICATION SYSTEMS FOR NUCLEAR POWER PLANTS Prepared for:
Federal Emergency Management Agency Washington, D.C. 20472 Under Contract No. EMW-83-C-1217 t
TABLE OF CONTENTS
'a INTRODUCTION i
CHAPTER 1:
! NUREG-0654/ FEMA-REP-1, Revision 1, PLANNING STANDARD E - NOTIFICATION METHODS AND PROCEDURES E- 1 Evaluation Criterion E.5: Notification Methods Areas of Review E- 1 i Acceptance Criteria E- 1 E- 1 Evaluation Criterion E.6: Alerting Methods E- 3 Areas of Review Acceptance Criteria E- 3 E- 4 Administrative Procedures Physical Means E- 4 Fixed Sirens E- 5 E- 6 Mobile Siren Vehicles
- E-10 Tone Alert Radios E-13 Special Alerting E-15 General Acceptance Criteria for Special Alerting Methods E-15 Use of Institutional Alerting Systems E-17 Use of Aircraft for Alerting E-18 Use of Automatic Telephone Dialers / Switching Equipment E-19 Use of Modulated Power Lines E-20 Use of Police, Fire, or Rescue Vehicles and Personnel E-20 i
CHAMER 2:
NUREG-0654/ FEMA-REP-1, Revision 1, PLANNING STANDARD F - EMERGENCY COMMUNICATIONS F- 1 Evaluation Criterion F.1: Emergency Communications F- 1 Areas of Review Acceptance criteria F- 2 F- 2 CHAPTER 3:
NUREG-0654/ FEMA-REP-1, Revision l e PLANNING STANDARD N - EXERCISES AND DRILLS N- 1 Evaluation Criterion N.I.at Exercise Definition N- 1 Evaluation Criterion N.I.b Exercise Requirements N- 1 Areas of Review Acceptance Criteria N- 1 N- 2 Evaluation Criterion N.2.as Communication Drills N- 5 Areas of Review '
Acceptance Criteria N- 5 N- 5
A o'
Evaluation Criterion N.3: Scenarios and Objectives N- 6 Areas of Review N- 6
., Acceptance Criteria N- 6 1
Evaluation Criterion N.5 : Observer and Participant Comments N- 7 Areas of Review N- 7 Acceptance Criteria N- 7 APPENDIX 1: Procedures for Preparation and Submission j
of a Design Report Describing Alert and Notification Systems 1- 1 APPENDIX 2: A Summary of Design Report Map Requirements 2- 1 APPENDIX 3: A Summary of the Alert and Notification
] Survey Methodology j
l Survey Methodology 3- 1 sample Size Determination 3- 4 i FEMA Nuclear Power Plant Alerting and Notification System: Public Telephone Survey 3- 7 i APPENDIX 4: A Summary of Design Report Routine Siren 1 Testing Procedures and Operability Requirements 4- 1
) -
4 i
I i
t l
l i
i i
1 -
I l '
1 ,
9 e
E. 6 . 2 .1 Fixed sirens !
Wherever proposed as part of an alert system, the siren system design and its routine testing procedures and maintenance program should be documented in the design report (see Appendix 4: A Summary of Design Report Routine Siren Testing Procedures E-6
- w
and Operability Requirements) . The design report should also include maps depicting siren sound contours for C-weighted sound pressure levels (see Appendix 2:
,j - A Summary of Design Report Map
' Requi rem ent s) , a description of how the sound pressure level contours were calculated, and any assumptions used including those f rom NUREG-0654/ FEMA-REP-1, Revision 1. The sound contours may be based on Appendix 3 of NURDG-0654/ FEMA-REP-1, Revision 1, including the use, in the absence of intervening topographical features, of the 10 dB loss per distance doubled sound attenuation factor used in FEMA CPG l-17.* However, topographical features that act as sound barriers must be
' considered in such contour calculations. If the FEMA CPG l-17 attenuation factor is not used, the design calculation should,
! at a minimum, account for the effects of topographical features, tempe ratur e, relative humidity, wind direction, wind speed,
' measured siren sound output, and siren location and height.
Average summer daytime weather conditions may be used. Average daytime should be that period of time, during the day, that meteorologists define as representing neutral or unstable weather conditions.
To facilitate FEMA's evaluation of the computation, the design report should contain plant meteorological tower data repre- l senting 3 months of summer daytime conditions. The following parameters, taken f rom the lowest and intermediate tower positions, should be included:
tempe ratur e, wind speed, wind direction, $
pressure.
relative humidity or dew point, and barometric The data may be averaged or presented in an hourly {
format. l 1
- Guide,"
Federal Emergency CPG Management 1-17, March 1,1980 Agency, " Outdoor Warning Systems E-7 l
_ _ _ _____A---
I 4 l
. l l
i
.' The reasonableness of the method for determining the siren sound .;
l
' output and the resulting siren sound pressure level contours :
l should be documented in the design rsport. The validity of the Il i
sound pressure level contour calculation depends upon the l validity of the determination of siren sound output at 100 feet I f rom the siren. There are at least two ways to determine siren sound output:
4:
Onsite type offield sirenmeasurements around used within the EPZ;atorleast one of each Anechoic, remi-anechoic, or reverberation chamber tests
- in a qualified laboratory on sirens that are repre .
sentative of each type of siren used within the EPZ.
1 Since consensus standards are not available for field and chamber siren measurements, the rationale for the employed 3
1 measurement procedures must be detailed in the design report.
! I The design report should provide a list of all sirens and should contain the'following information for each siren: unique iden-tifier, siren type, sound output in dBC at 100 feet, and -
mounting height.
l The design report demonstrates compliance with NUREG-0654/
i FEMA-REP-1, Revision 1, criteria for those geographical areas j covered by fixed sirens by showing that either:
I i
The expected siren sound pressure level generally i exceeds 70 dBC where the pooulation exceeds 2,000 persons per square mile and 60 dBC in other inhabited areas; or The expected siren sound pressure level generally j
exceeds the average measured summer daytime ambient sound pressure levels by 10 dB less than 2,000 persons per squa(geographical re mile) . areas with I
]
If the design report documents that the siren sound pressure levels exceed a . measured ambient by 10 dB, then the following information should be provided:
1
) E-8 '
3 J
A description of how the average summer daytime ambient o sound pressure levels were determined, including survey -
locations and the rationale for their selection; Identification of actual measurements including f re , .
quency range, time span, and location; Any assumptions used to determine the measured ambient along with rationale for those assumptions; Relationships of population density to measured ambient levels; ,
Effects of major transportation routes; and 1
4 Effects of any commercial activities in the area.
If the estimated siren sound pressure level does not generally meet the specified level based on either population density or a i
10 dB differential between the measured average summer daytime 1
ambient sound pressure level and the estimated siren sound pres-sure level, the siren system should be enhanced by the addition of sirens or by other alerting methods. These methods must.be described'in the design report.
Once the siren system 'is installed and operational, the licensee should develop and implement a routine siren testing and opera-bility program (see Appendix 4: A . Summary of Design Report Routine Siren Testing Procedures and Operability Requirements) .
i This routine siren testing and operability program should include regularly scheduled testing of the siren system including but not limited to: silent, growl, and full-scale tests. NUREG-0654/ FEMA-REP-1, Revision 1, suggests the followino f requency:
Silent tests should be conducted at least every two weeks; Growl tests should be conducted at least quarterly and whenever preventive maintenance is performed; Full-scale testing should be conducted at least annually and as required for formal exercises; and i i
i i
. E-9 !
-~ ---w._ , , .. .,-- - , ,v, . , ._, _ . , _ , . . . , .,, g ---my.m,,--
Other siren testing programs will be reviewed on a case-o by-case basis.
The maintenance of the siren system should include prompt repair of any components not performing as expected during a test.
This maintenance program should also include records of tests and repairs perf ormed. The operability of a siren system is considered acceptable when an average of 90% of the sirens (as determined by a simple average of all regularly conducted tests) can be demonstrated as being functional over the 12-month period immediately preceding the submittal of the design report.
Special conditions (e.g. , siren systems that have not been operational for 12 months) will be considered on a case-by-case basis. A description of the routine siren testing procedures and a summary of the operability records should be included in the design report. This summary should contain a description of the computations used to determine the average operability of the siren system.
I 1
E-10
UNITED STATES OF AMERICA !
NUCLEAR REGULATORY COMMISSION l BEFORE THE ATOMIC SAFETY AND LICENSING DOARD In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Mos. 50-443-OL-1 NEW HAMPSHIRE, ET AL. ) 50-4 44-OL-1
) (On-Site Emergency Planning (Seabrook Station, Units 1 and 2) ) and Safety Issues)
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter. In accordance with 10 C.F.R. I 2.713(b) the following information is provided:
Name '
Gregory Alan Berry Address -
U.S. Nuclear Regulatory Commission Ofnce of the General Counsel Washington, D.C. 20555 Telephone Number -
Area Code (301) 492-7852 Admission -
Supreme Court of the Commonwealth of l Pennsylvania; Court of Appeals for the 1 District of Columbia; United States l District Court for the District of Columbia; United States Court of Appeals for the District of Columbia; and the Supreme Court of the United i States of America.
Name of Party -
NRC Staff U.S. Nuclear Regulatory Commission Washington, D.C. 20555 n
( b Gre@ dry Alfh Bef yr
?bs % '
Counsel fo RCytaff Dated at Bethesda, Maryland this 20th day of March 1987
l . 00LKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 87 tiAR 27 P2 57 BEFORE THE ATOMIC SAFETY AND LICENSING bog Ify[
In the Matter of )
) Docket Nos.50-443 OL-01 PUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW HAMPSHIRE, et al. ) On-site Emergency Planning
) and Safety Issues (Seabrook Station, Units 1 and 2 )
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO MASSACHUSETTS ATTORNEY GENER A L'S MOTION TO REOPEN RECORD AND RECONSIDER LATE-FILED CONTENTION WITH REVISED BASIS" and " NOTICE OF j' APPEARANCE" for Gregory Alan Derry in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, (*) by deposit in the Nuclear Regulatory Commission's internal mail system, or (**) hand delivery, this 20th day of March,1987:
Sheldon J. Wolfe, Esq. , Chairman ** Dr. Emmeth A. Luebke**
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour ** Ms. Carol Sneider, Esq.
Administrative Judge Assistant Attorney Ceneral Atomic Safety and Licensing Board Office of the Attorney General !
U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor ;
Washington, DC 20555 Boston, MA 02108 l i
Beverly Hollingworth Richard A. Hampe, Esq.
- 209 Winnacunnet Road New Hampshire Civil Defense Agency Hampton, NH 03842 107 Pleasant Street
, Concord, NH 03301 Sandra Gavutis, Chairman Calvin A. Canney, City Manager Board of Selectmen City Hall RFD 1 Box 1154 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
Stephen E. Merrill Paul McEachern, Esq.
Attorney General Matthew T. Brock, Esq.
George Dana Bisbee Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue
- Office of the Attorney General P.O. Box 360 25 Capitol Street Portsmouth, NH 03801 Concord, NH 03301 Roberta C. Pevear .
Angie Machiros, Chairman State Representative '
Board of Selectmen Town of Hampton Falls 25 Iligh Road Drinkwater Road ,
Newbury, MA 09150 Hampton Falls, NH 03844 Allen Lampert Mr. Robert J. Harrison Civil Defense Director President and Chief Executive Officer Town of Brentwood Public Service Co. of New Hampshire 20 Franklin Street P.O. Box 330 Exeter, NH 03833 Manchester, NH 03105 Charles P. Graham, Esq. Robert A. Backus, Esq.
McKay, Murphy and Graham Backus, Meyer & Solomon 100 Main Street 116 Lowell Street Amesbury, MA 01913 Manchester, NH 03106 Diane Curran, Esq. Philip Ahren, Esq.
i Harmon & Weiss ,
Assistant Attorney General l 2001 S Street, NW Office of the Attorney General i Suite 430 State House Station #6 Washington, DC 20009 Augusta, ME 04333 Edward A. Thomas Thomas G. Dignan Jr. , Esq. ,
Federal Emergency Management Agency Ropes & Gray 1 442 J.W. McCormack (POCH) 225 Franklin Street I Boston, MA 02109 Boston, MA 02110 H.J. Flynn, Esq. William Armstrong Assistant General Counsel Civil Defense Director Federal Emergency Management Artency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing Atomic Safety and Licensing i Appeal Panel
- Board
- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 l
Jane Doughty Docketing and Service Section* i Seacoast Anti-Pollution League Office of the Secretary )
5 Market Street U.S. Nuclear Regulatory Commission 1
Portsmouth, NH 03801 Washington, DC 20555 Maynard L. Young, Chairman William S. Lord l Board of Selectmen Board of Selectmen 10 Central Road Town Hall - Friend Street South Hampton, NH 03287 Amesbury, MA 01913 4
1
.-.--_..--,-.1
3-
- Michael Santosuosso, Chairman Peter J. Matthews, Mayor Board of Selectmen City Hall South Hampton, NH 03287 Newburyport, MN 09150 Mr. Robert Carrigg, Chairman Judith H. Mizner, Esq.
Board of Selectmen Silverglate, Gertner, Baker Town Office Fine and Good Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Boston, MA 02110 R. K. Ged III, Esq. Mrs. Anne E. Goodman, Chairman Ropes & Gray Board of Selectmen 225 Franklin Street 13-15 Newmarket Road Boston, MN 02110 Durham, NH 03824 Gary W. Holmes, Esq.
Holmes & Ellis 47 Winnacunnet Road Ilampton, NII 03842 }
Gregoryfs tlan/ 3erry
~
Counsellj)r lytC Staff 1
l l
meam-e mm% w