ML20207J733

Requests Responses to Listed Questions Re Significant Defects in Alert & Notification Sys & Other Concerns Re Emergency Plan.Served on 860728

ML20207J733
Person / Time
Site:	South Texas
Issue date:	07/25/1986
From:	Bechhoefer C Atomic Safety and Licensing Board Panel
To:	Axelrad M NEWMAN & HOLTZINGER
References
CON-#386-102 OL, NUDOCS 8607290239
Download: ML20207J733 (6)

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't UNITED STATES f* t j NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL DOCK Ib0[gg .

(J3 4, v ,/ W ASHIN GTON, D.C. 20555 y JL 28 p10 ya July 25, 1986 MYTt }

Maurice Axelrad, Esq.

Newman & Holtzinger 1615 L Street, N.W.

Washington, D.C. 20036 g pg g g g HOUSTON LIGHTING AND POWER COMPANY, ET AL.

(South Texas Project, Units 1 and 2)

Docket Nos. STN 50-498 OL and STN 50-499 OL

Dear Mr. Axelrad:

The Atomic Safety and Licensing Board is currently undertaking the requisite examination it must give to uncontested generic and other issues in this operating license nroceeding. See Louisiana Power and Light Co. (Waterford Steam Electric Si . tion, Unit 3), ALAB-732,17 NRC 1076, 1110-12 (1983); Virginia Electric and Power Co. (Horth Anna Power Station, Units 1 and 2), ALAB-491, 8 NRC 245 (1978). Based on the material before us, the Board has serious concern that there may be significant defects in the alert and notification system apparently being utilized by HL&P to fulfill the requirements of 10 C.F.R. 9 50.47(b)(5) and (6) and Part 50, Appendix E, 5 IV.D.3.1 as well as I Appendix E, Q IV.D.3 provides that "The design objective of the prompt public notification system shall be to have the capability to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes."

8607290239 860725 0 ADOCK 0500 PDR G

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Maurice Axelrad, Esq. 2 July 25, 1986 applicable guidance documents.2 Before determining whether the apparent defects constitute a serious safety matter sufficient to warrant our review pursuant to 10 C.F.R. 5 2.760a, the Board wishes to be apprised of certain additional details of the emergency plan, as set forth below.

By way of background, the Licensing Board in the Shearon Harris proceeding recently issued an opinion involving, inter alia, nighttime alerting and notification at that facility. Carolina Power & Light Co.

(Shearon Harris Nuclear Power Plant), LBP-86-11, 23 NRC 294, 364-96 (April 28, 1986). The emergency plan approved for that facility utilized a combination of sirens and tone-alert radios (as well as other measures) to provide adequate alerting and notification within the 10-mile plume exposure pathway Emergency Planning Zone (EPZ). Among other provisions, the plan relied on 68 sirens for nighttime alerting (id. at 374), together with tone-alert radios for every household within the first 5 miles of the EPZ (id_. at 391).

The issue of nighttime alerting and notification has also been recently raised in conjunction with the Indian Point 2 facility (Docket No. 50-247). See letters to Connissioners from two Administrative Judges, dated June 9 and July 10, 1986, and letter to Commissioners from the Assistant General Counsel of Consolidated Edison Co. of New York, 2

Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (NUREG-0654), Rev. 1 (November 1980); Federal Emergency Management Agency, Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants (FEMA-43, issued September 1983).

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Maurice Axelrad, Esq. 3 July 25, 1986 Inc., dated July 3, 1986. The latter document (at p. 5) indicates that the Indian Point emergency plan currently relies on 151 sirens for alerting and notification, together with tone-alert radios in schools, hospitals and other special facilities within the EPZ.

This Board has examined the STP emergency plan (Revision 2) submitted to the NRC Staff for review (and to us for information) on April 8, 1986. As we understand it, the plan (through its Prompt Notification System) relies primarily on a combination of sirens and tone-alert radios for alerting and notification (similar to the plans for Shearon Harris and Indian Point 2 referenced above). The plan contemplates seven sirens within the EPZ and four additional sirens outside the EPZ, together with tone-alert radios in all residences and establishments where the level of the sirens will be less than 70 db.,

as well as in other special facilities. Emergency Plan (Rev. 2),

SSE-1.3, G-1.17, G-1.18, I-1.5 and Fig. G-7.

There are several aspects of the STP Prompt Notification System which raise questions as to compliance with the Commission's regulations and guidelines, particularly with respect to nighttime alerting and l

notification. Assuming (without deciding) that satisfactory standards 3

for fulfilling the requirements for " essentially 100%" alerting are as set forth in the Shearon Harris decision--i.e., better than 95% initial l alerting within the 0-5 mile range of the EPZ and around 90% alerting I

3 NUREG-0654, Appendix 3, p. 3-3.

4 Maurice Axelrad, Esq. 4 July 25, 1986 for the 5-10 mile range of the EPZ--it seems likely that the 70 db.

siren level would arouse less than the required percentage of persons on a summer night (when considerable sound attenuation because of closed windows and air conditioners would likely be present). Moreover, the apparently exclusive reliance on a siren sound level of at least 70 db.

to alert certain persons or households appears to be premised on an assumption that all sirens will be operable at all times. It seems likely to us that one (or more) of the sirens may not operate at any given point in time.4 That circumstance appears to be more serious at STP (where there are only seven sirens in the EPZ and four more slightly outside the EPZ) than at Shearon Harris (68 sirens) or Indian Point 2 (151 sirens) in similar-sized EPZs. Failure of even one siren at STP might well result in the lack of timely notification of various households. Differences in topography and population location, and the existence of other forms of alerting, would, of course, have to be taken into account in any comparison between systems and evaluation of the adequacy of any such systems.

The foregoing information would appear to present a prima facie basis for concluding that the proposed Prompt Notification System may not comply with applicable standards and hence constitutes a serious safety question sufficient to warrant consideration under 10 C.F.R. i 4 FEMA-43 (p. E-8) suggests that an average of 90% siren operability on an annual basis is sufficient for demonstrating the adequacy of a siren alert system.

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Maurice Axelrad, Esq. 5 July P.5, 1986 2.760a. Before reaching such a determination, however, we would appreciate responses from the Applicants to the following questions:

1. In utilizing the 70 db. level for determining the conditions for which sirens are to be relied upon for alerting and notification, upon what conditions (time, season, etc.) has the 70 db. criterion been formulated?

2, How many households are located (a) within the 0-5 mile EPZ, and (b) within the 5-10 mile EPZ? (The Emergency Plan sets forth a 5

population of 231 within the 0-5 mile EPZ and 2270 within the 5-10 mile EPZ (5 A-1.7) but does not appear to set forth the number of 1

households.)

3. How many households are to be equipped with tone-alert' radios (a) within the 0-5 mile EPZ and (b) within the 5-10 mile EPZ?

4. Has account been taken of the presence of seasonal residentihl population in planning siren locations and distributing tone-alert radios? If so, in what manner?

5. What provisions have been made for servicing the sirens and maintaining their operability?

6. What provisions have been made for servicing the tone-alert radios? Are batteries to be routinely replaced by HL&P? Will lists be maintained by the company of persons whose tone-alert radios are being 5

2501-231 = 2270.

i Maurice Axelrad Esq. 6 July 25, 1986 I l

serviced by HL&P? (Cf. Emergency Plan, 6 G-1.18 with Shearon-Harris, LBP-85-11, supra, 23 NRC at 394, Finding 76.)

We w9uld appreciate HL&P's responses to these questions at its earliest convenience. Other parties may provide comments within 10 days of service of HL&P's answers (15 days in the case of the Staff). On the basis of the various responses, we will determine whether our raising an issue pursuant to 10 C.F.R. 5 2.760a is warranted. (If we determine that such an issue should be raised, we will of course follow applicable procedures for doing so. See LBP-81-54, 14 NRC 918, 922-23 (1981).)

Since these questions bear upon an issue which is not relevant to fuel loading or low-power operation (up to 5% of rated power) (see 10 C.F.R.

s 50.47(d)), our consideration of this matter will not delay our ruling on other issues currently hafore us, leading to a decision with respect to whether low-power operation should be authorized.

FOR THE ATOMIC SAFETY AND LICENSING BOARD

.d'4 V v b - cnj Charles Bechhoefer,' Chaipan ADMINISTRATIVE JUDGE cc: Service List Dr. N. Prasad Kadambi, NRR, Project Manager

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