ML20209E791
| ML20209E791 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/22/1987 |
| From: | Cumming W Federal Emergency Management Agency |
| To: | |
| References | |
| CON-#287-3270 OL-3, OL-5, NUDOCS 8704300120 | |
| Download: ML20209E791 (20) | |
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April 22, 1987 COM EiEP 95Niit 87 APR 27 P12:53 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFKE y ;.2
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'D BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket No. 50-322-OL-3 (Emergency Planning)
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-5
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(EP Exercise)
(Shoreham Nuclear Power Station,
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Unit 1) )
FEMA GUIDANCE OF POTENTIAL APPLICABILITY TO SHOREHAM PLAN AND EXERCISE PROCEEDINGS FEMA Counsel hereby supplements the December 29, 1986, December 17, 1986, November 25, 1986, and November 21, 1986 guidance documents served on all parties with the attached Dave McLoughlin to Regional Directors Memorandum dated April 21, 1987, subject: Guidance Memorandum (GM) AN-1, FEMA Action to Qualify Alert and Notification Systems Against NUREG-0654/ FEMA-REP-1 and FEMA REP-10.
This guidance was marked but not entered in the OL-5 proceeding on the Hearing Day of March 19, 1987, in draft format as FEMA Exercise Exhibit #2.
FEMA intends to mark, authenticate, and enter as an exhibit the April 21, 1987, final document as FEMA Exercise Exhibit #4 in that proceeding.
Respectfully submitted, h6'd 4~ $ hss/# #
William R. Cumming Counsel for FEMA i
Dated this 22nd day of April, 1987 Washington, D.C.
8704300120 870422 DR ADOCK 05000322 PDR
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Federal Emergency Management Agency Washington, D.C. 20472
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APR 2 l 1987 MEMORANDCM EOR:
Regional Directors Acting Regional Director FPOM:
McLoughlin Deputy Associate Director State and Ircal Programs and Support SUELTECI:
Guidance Memorandum (GM) AN-1, FEMA Action to Qualify Alert and Notification Systems Against NUREG-0654/ FEMA-REP-1 and FEMA-REP-10.
Guidance Metterandum AN-1 is provided as an operative GM for your use in implementing alert and notification system components of FEMA's radiological emergency preparedness program and for assisting util.ities and State and local governments in developing and evaluating alert and notification system capabilities for ccxtimercial nuclear power plant accidents. With the issuance of GM AN-1, GM-18, Revision 1 (FEMA Action to Qualify Alert and Notification Systems Against NURED-0654/ FEMA-REP-1, Revision 1, dated October 19, 1983) is terminated.
A current listing of all operative GM's is also' attached for your use.
We are appreciative of the comments provided by the Regions and, through your cooperation, many states.
Please provide ccpies of this GM and the current listing of cperative G4's to the states in your Regions.
Your review and ccrments on the draft ccpy of GM AN-1 were helpful in developing the final version. Any questions concerning the implementation of this GM should be directed to either Megs Hepler (ETS 646-2867) or Vern Wingert (ETS 646-2872).
Attachttents As Stated 1
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Federal Emergency Management Agency I
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Washington, D.C. 20472 s
w APR 2 I 1987 GUImNCE MEMOPANIXM AN-1 FD% ACTICN TO QUALICY ALERT AND NOTIFICATION SYSID4S AGAINST NURSG-0654 FD4A-REP-1 AND FEt%-REP-10
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PURPOSE This Guidance Memorandum (G4) describes policy and procedures to be followed by the Federal Emergency Management Agency (FDM) Headquarters and Regional Of fices in assessing and making findings and determinations on the adequacy of alert and notification systems installed around coumercial nuclear powr plants.
Planning Standards E, F, and N and Appendix 3 of NUREG-0654/FD4A-REP-1, and FEMA-REP-10, the " Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" contain the specific technical criteria against which alert and notification system designs will be reviewed. This G4 supersedes the currently operative G4-18, Revision 1, entitled "FD4A Action to Qualify Alert and Notification Systems Against NUREG-0654/FD4A-REP-1, Revision 1" dated October 19, 1983.
I BACKGROLND The President of the United States, in a statetent on December 7,1979, assigned FDM as the lead Federal Agency for coordinating State and local radiological emr-gency planning and preparedness activities around ccumercial nuclear power plants.
This responsibility incitxied evaluating and approving. State and local radiological emergency planning and preparedness for dealing with the consequences of an accident at a conmercial nuclear power plant.
Following this Presidential directive, FDR and the Nuclear Regulatory Comission (NRC) jointly produced, in November 1980, NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of Radiolcgical Emergency Resp:nse Planc and Preparedness in Support of Nuclear Power Plants".
This guidance document provides the basis for the develognent of radiological emer-gency response plans and preparedness by State anci local goverrments and the NRC licensees for dealing with accidents at conmercial nuclear power plants.
NUREG-0654/FD4A-REP-1 also provides the basis for the review of radiological emergency response plans and preparedness by Federal agencies.
Appendix 3 of NUREG-0654/FD%-REP-1 states that NRC licensees are required to install alert and notification systems around coumercial nuclear power plants and that activation of these systems is the responsibility of the State and local governrmnts. The licensees were mandated by NRC to have alert and notification systens installed arcund operating conmarcial ruclear power plants by February 1, 1982 (originally by July 1,1981). Any nuclear power plant scheduled for operation after February 1,1982, is required to have an alert and' notification systen installed prior to counercial operation of the facility.
Through agreement with the NRC, FEMA accepted the lead respcnsibility for review-ing and acproving alert and notification systems. This included confirming that the systens are in full conpliance with NUREG-0654/FDR-REP-1, FDM Rule 44 CFR 350, and NRC Rule 10 CFR 50, Appendix E.
As part of this lead responsibility, FD%
develcped the " Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" (FD%-43) which was issued as interim-use guidance for
. cvaluating alert and notification systems.
FEMA-43 presented an elaboration on and an application of the criteria contained in NUREG-0654/ FEMA-REP-1 for purposes of reviewing and approving alert and notification systems.
FD4A-43 was subsequently revised to reflect corrnents received during the interim-use pericd.
In November 1985, final guidance was issued in FEMA-REP-10, which superseded FD1A-43.
The guidance contained iri this Gi addresses the procedural steos which will be followed by the FD4A Regions and Headquarters in the evaluation of alert and noti-fication systems leading up to approval of the systems.
All technical aspects involved in the review and approval process are contained in FD4A-REP-10.
RESPONSIBILITIES The responsibilities for the procedural aspects of evaluating alert and noti-fication systems are described below:
FEMA Headcuarters is resconsible for the followina:
Establishing and reviewing policy for making findings and determinations on the' adequacy of alert and notification systems; In coordination with the Regions, developing standard formats, content, and acceptance criteria for reviewing the technical aspects of alert and notifi-cation systen design submittals frcm State goverrinents and/or NRC licensees; Issuing recoumendations and policy concerning the Dnergency Broadcast System (EBS), National Oceanic and Atmospheric Mministration radio systems, etc.,
as they relate to alert and notification systens; Coordinating arrangenents with other Federal Agencies, if necessary, to couplete the alert and notification system design reviews:
Providing assistance in making policy determinations on specific issues and problems when requested by the FD4A Regions; Mministering contracts for the provision of technical assistance in review-ing and evaluating alert and notification systens; 1
Coordinatirg the scheduliry of ' alert and notification system telephone surveys with the FD4A Regions and technical assistance contractor; Coordinating contractual arrargements for conductirg the telephone surveys and resurveys, if necessary, for each alert and notification system; Coordinatirn arrargements with the Office of Management and Budget (018) for clearance to conduct the telephone surveys; Issuing tormal findings to the NRC on the adequacy or inadequacy of alert and notification systems based on FQ4A Regional recormendations and findirgs; and
Issuing guidance, as necessary, for the FEM Regions to follow in reviewing the raatine alert and notification system testing program and operability following the initial alert and notification system approval.
,FDG_R_egi,onal Offices are resconsible for the folicwigg,:,
Reviewing alert and notification system design subnittals as a part of FDR's evaluation and approval process of State and local radiological emergency plans and preparedness in accordance with FEMA Rule 44 CFR 350; Making preliminary and final recmmendations to FDM Headquarters on approving or disapproving alert and notification systems pursuant to NUREG-0654/ FEM-REP-1 evaluation criteria E.5., E.6.(with technical assistance), F.1., N.l.,
N.2., N.3., and N.5.;
Confirming that State and local governments have demonstrated the capability to alert and notify the population within the 5-or 10-mile plume emergency planning zone (EPZ) in accordance with the time requirements in 10 CFR 50, Aptxrdix E, Section D.3, NUREG-0654/FDR-REP-1, Appendix 3, and FDm-REP-10; Confirming that acceptable procedures are established, have been demonstrated if required, and are in full canpliance with all FDM guidance for alerting and notifying the permanent population in rural and remote areas and the transient population in recreational areas, State Parks, wildlife refuges, hunting areas, river areas, ocean areas, beaches, and other areas frequented by the transient population; Reviewing the routine alert and notification systen testing program employed by the licensee and/cr the State aM local governments to maintain and test the systens, so as t assist FD% Headquarters in determining the adequacy of the program; Reviewing State / licensee operability reports to confirm that the siren oper-ability standard of 90% required in FDR-REP-10 has been achieved based on the most recent 12 months of test results before the system is approved (the operability of the system will be determined by averaging the results of all regularly scheduled tests employed as part of the testing program, e.g. silent, growl, full-cycle);
Reviewing alert and notification systen testing results annualA after the initial system approval to confirm that testing has been ccmpleted in accord-ance with approved procedures and that the siren operability remains at or above 90%; and notifying FEMA Headquarters if it falls below 90% (this may be included as part of the periodic requirenents stipulated in G4 PR-1);
- Assisting in the alert and notification system telephone surveys by coor-dinating all necessary arrangements with State and local officials and by providing a representative at the alert and notification system activation point (Emergency Operations Centers, etc.) the day of the survey, if possible and if travel funds permit, to act as a liaison to the technical assistance contractor; Reviewing and evaluating changes to alert and notification systems as necessary following the initial approval of the system; and Mvising FE% Headquarters of alert and notification system problems after the initial systen approval and reccrrending resurveys if warranted.
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Th7 Technical Assistance Contractor is resconsible for the following:,
Reviewing alert arxi notification system design submittals pursuant to eval-uation criterion E.6. in NUREG-0654/Fam-REP-1 and FE4A-REP-10; Documenting the results of the technical review in preliminary and final reports for use by the FER Regions and Headquarters; Providing technical assistance and advice on problens that may arise in the alert and notification systen reviews; Conducting a public telephone survey immediately following activation of the alert and notification system arxi statistically analyzing the results for inclusion in a final report on the adequacy of the system; and Conducting telephone resurveys if directed.
, State and local _goverrsnents are resconsible for the fol_ lowing:,
Coordinating with licensees to ensure proper consideration of offsite radio-logical energency response plans and preparedness in the design of alert and notification systems; Reviewing, to the extent possible, the alert and notification system designs sutxnitted by the NRC licensees and providing appropriate segments of their radiological emergency response plans (or at a minimum, an accurate cross reference) for inclusion in the alert and notification system design; Forwarding the licensee's alert and notification system design submittal to the FE R Region for review; i
Assuring activation of the alert and notification systems for telephone survey purposes and for routine tests and exercises; Revising offsite radiological emergency plans and preparedness to reflect any changes to an alert and notification systc 1 after it is approved and providing the FDIA Pegional Office with copies of the revisions; Coordinating on and subnitting a report on alert and notification system siren operability and testing results to the FDtA Regions for review annually if the data is not already provided by the licensee (the data can be submitted in conjunction with the Gi PR-1 submission);
Assuring that address registers containing information on the distribution of tone alert radios within the energency planning zone are updated annually and are availacle for inspection; Confirming that appropriate testing and maintenance of tone alert radios has been ccmpleted pursuant to the guidance in FD%-REP-10 for those systems con-taining tone alert radios; and
Conducting resurveys of alert and notification systems after the initial sys-tem approval, if the resurvey cannot be conducted by FE!G but is determined jointly by FEMA Headquar&rs and the FatA Region to 'be necessary to certify the continued adequacy of the system. This is more likely to apply to systems with a significant tone alert radio conponent; however, the reasons for the resurvey will be outlined for State and local officials, the licensee, and tne 22C and i
sufficient thne will be allowed in which to conduct it if other satisfactory arrangements to correct the problem cannot be made.
t NBC licensees are responsible for the following:
J Preparing alert and notification system design reports in accordance with the guidance in FEMA-REP-10 and in NUREG-0654/FD1A-REP-1, Appendix 3, and coordi nating the design with State officials (and local government officials if i
necessary); and submitting the designs to the appropriate State government j
for review; l
Depending on established procedures, submitting alert and notification system j
operability and testing records either directly to the State government or to the FD1A Regions for review annually; and 1
l Assisting in alert and notification system telephone surveys and resurveys, l
as necessary, and promptly correcting systen problens.
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NRC is responsible for the following:
Reviewing and approving alert and notification system designs prior to installation of the systems by the. licensees; and Reviewing FEMA findings on the adequacy or inadequacy of alert and notifi-cation systems and following up with appropriate actions to ensure that l
pranpt corrective actions are taken when needed.
i PROCECURAL ASPECTS OF ALERI AND NOTIFICATION SYSTEM REVIEWS a
NRC licensees are responsible for preparing and submitting three copies of their alert and notification system designs to State officials (and to local government officials if necessary) for coordination and review. ' State and local government J
officials will be expected to incorporate appropriate sections of the offsite radio-logical emergency response plans into the alert and notification system design sub-i mittal.
Following the review by State and local officials, the designs will be submitted to the FHiA Region, and the Region will in turn submit a copy of the design to FEMA Headquarters for review by the technical assistance contractor.
It is acceptable for the alert and notification system design submission to l
incorporate an accurate cross reference to evaluation criteria E.5., E.6., F.1.,
l N.l., N.2., N.3., and N.5. as addressed in the State and local radiological emergency response plans instead of having those portions of the plans rewritten just for the alert and notification system design report.
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The FEMA Regional review of the alert and notification system design and of the technical assistance contractor's preliminary draft report on the alert and j
notification system design should consist of the following:
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- A verification or reverificatico of the adequacy of evaluation criteria E.5.,
E.6.(administrative aspects and if possible, physical aspects), F.1., N. l.,
N.2., N.3., and N.5. as documented in the most recent interim finding, exer-cise report, or 44 CFR 350 approval;
- A review of and contents on the technical assistance contractor's preliminary draft report especially as it relates to evaluation criterion E.6.(physical aspects) and a revies of the routine system testing procedures and operability;
- A confimation of ccmpliance of the State and local governments with the time requirements in 10 CFR Part 50, Appendix E, Section 0.3, NCREG-0654/FDR-REP-1, Appendix 3, and FD%-REP-10 (See Attachment I to this GM for more details);
- A review of both institutional alerting procedures and special alerting pro-cedures utilized for the transient pcpulation to detemine the adequacy of these procedures.
Following their preliminary review, the Regional Office should provide a preliminary finding of adequacy or inadequacy to FD% Headquarters.
If the system is found to have adequate alerting coverage, a date for the telephone survey will be established by FDM Headquarters that is agreeable to the Regicnal Office, State and local governnents, technical assistance contractor, and the NRC licensee.
If the system is found to have inadequate alerting coverage or other problems, the State and/or utility will be notified through the FDM Regional Office that further documentation to support the alert and notification syste design is required. A trere detailed review of the alert and notification system design by the Regional Office may be r: quired if significant time has elapsed since the last Regional interim finding, 44 CFR'350 review, or exercise was canpleted in which the alert and notification,
systen related plan eletents were reviewed.
As part of the review prccess, the technical assistance contractor will conduct a telephone survey of pemanent residents in the 10-mile EPZ after activation of the alert and notification system.
Households will be polled to ascertain whether or not they were alerted during the activation of the system.
Such a telechone sur-v:.y will be performed only once to approve the alert and notification system unless the results are unacceptable during the initial survey.
The telephone survey can b3 conducted following activation of the alert and notification system either during routine testing, as part of a scheduled exercise, or as a separate activation.
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The ' technical assistance contractor will prepare a final draft report on the alert and notification system following the telephone survey.
This final draft report will document the results of the survey along with.the results of the earlier tech-nical review of the system design. The FDR Regions will review this final draf t report, address the acceptability of the routine siren testing procedures and oper-ability with respect to established standards, address any remaining issues.not covered in their preliminary finding, as discussed above, and make a final recon-mendation on approving or disapproving the systen.
The Regional finding may include recomtendations for system modifications or enhancements.
FD% Headquarters will incorporate all appropriate Regional recomendations into a final rerrrt and issue a finding to the NRC on the adequacy or inadequacy of the alert and notification system.
It is important to note that findings on alert and notification systers employing sirens cannot be issued without documentation that the routine siren t: sting procedures are adequate and that the operability standard of 90% in FDM-REP-10 has been achieved based en 12 ttonths of current testing recnrds.
. State and local goverment emergency planning and preparedness can be approved by FDR pursuant to 44 CFR 350 without approval of the alert and notification In these cases, FDR will issue a conditional 44 CFR 350 approval cave-system.
ated on the ultimate approval of the alert and notification system. The caveat in the 44 CFR 350 approval will be removed once the alert and notification system is approved. However, in scme cases, alert and notification system related prob-lems may delay a 44 CFR 350 approval and in other cases the alert and notification
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systen approval may be granted simultaneously with the 44 CFR 350 approval.
An' alert and notification system is subject to an engineering analysis against NUREG-0654/FDtA-REP-1, and FDm-REP-10 by this procedure cnly once, unless a significant change, as specified in 44 CFR 350.14, is made to the system. 'Ihe FEMA Regional of fices will be responsible for advising FEMA Headquarters of significant changes to alert and notification systems or of significant changes in the EP2 that might impact the alert and notification systea after the initial approval. The Regions will also be responsible for assisting in re-reviews that may becane necessary.
If necessary, technical assistance may be provided and a telephone resurvey conducted if such re-reviews are undertaken.
Following the initial, qualifying telephone survey and approval of an alert and notification system, FEMA will not conduct nor require that additional telephone surveys be conducted to assess the continued capabilities of the system unless one or more of the following conditions is encountered that would warrant such surveys:
A significant change occurs in the demographics or in the configuration of the EPZ around the nuclear powr plant; A significant mcdification is made to the physical ccmponents of the alert and notification system that actually or potentially decreases the effectiveness of the systen; A significant problem is identified in scme aspect of the alert and notification system or there is documentation provided by the Region supporting concerns over the continued Mequacy of the system; Should any of these conditions be encountered, it will be incumbent upon the Regional Office to notify FDR Headquarters and reccamend revisions and/or corrective actions which could include a telephone resurvey conducted either by FEMA or the State. 'If FEMA conducts the resurvey, FDR Headquarters will coordinate all apprcpriate arrangements for the additional surveys with the NRC, CMB, and other offices as necessary.
State ard local governments, in conjunction with the licensees, are encouraged to conduct their own annual surveys as a method of monitoring the continued effectiveness of their systems, especially those with significant tone alert radio conponents.
Following the initial approval of an alert and notification system, the FE!%
Begions will be responsible for routinely receiving the results of alert and notificatien system tests and will be expected to review the results and report them to FDtA Headquarters annually. The results should be submitted as part of the pericdic requirements reporting.
This is necessary to verify that siren system operability is maintained at 90% or higher, the standard in FDR-REP-10, and to confirm that routine testing, including testing of special alerting ccmponents, is being conducted at the proper frequency and in accordance with those procedures
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reviewed and approved by FEMA. The cperability results my be submitted to the FEMA Fegion by either the State and local governments or the licensee.
For alert and notification systems consisting of tone alert radios, the FEMA Regiors should receive confirmation fran State and local officials and/or the licensee annually that the tone alert registers have been reviewed and updated and that annual maintenance and testing of these systems has been performed
.by the appropriate authorities. This information can be provided in conjunction with the GM PR-1 submission.
Attachment I to this guidance memorandum contains an explanation of the time requirements for alert and notification systems cutlined in NUREG-0654/ FEMA-REP-1, Appendix 3, FEMA-REP-10, and 10 CFR 50, Appendix E.
Attachment II contains an approximate time line for reviewing alert and notification system designs as outlined in the procedures above.
Nuclear Regulatory Cmmission Coordination This Guidance Memorandum was coordinated with the Nuclear Regulatory Cairtission staff.
Attachments As Stated D
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ATTACHMENT I: ALERT AND NOTIFICATION TIME RECUIREMENTS PURPOSE The purpose of this attachment is twofold:
- To elaborate upon the accepted FEiA interpretation and application of alert and notification system design objectives outlined in 10 CFR 50, Appendix E, NUREG-0654/ Feta-REP-1, Appendix 3, and FEiA-REP-10 that,
relate to alert and notification system activation and timing; and
- To provide guidance and' suggestions for evaluating and confirming com-pliance with these design objectives during offsite radiological emer-gency preparedness exercises;
'Ihe provision of timely and apprcpriate alerting and notification cculd be one of the nest critical aspects of protecting the public in the event cf an acci-
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dent at a nuclear power plant.
Ensuring that alert and notification systems installed around nuclear power plants are in fact capable of rapidly warning the public is an important aspect of FEMA's review of of fsite radiological emergency planning and preparedness.
BACKGRCCND Each alert and notification system must have the capability to rapidly alert the public and advise them of protective action recomendaticns.
'Ihe actual design cbjectives against which these systms must be designed are outlined in the Nuclear Regulatory Comission (NRC) Rule 10 CFR 50, Appendix E, NUREG-0654/FD4A-REP-1, Appendix 3, and FEMA-REP-10. As stated in NLPEG-0654/ FEMA-REP-1, Appendix 3, and in FC4A-REP-10 the minimun acceptable design objectives for coverage by an alert and notification system are:
" a) Capability for providing both an alert signal and an informational or instructional message to the population on an area wide basis throughout the 10 mile EP2, within 15 minutes.
b) The initial notification system will assure direct coverage of essentially 100% of the pcpulation within 5 miles of the site.
c) Special arrangements will be made to assure 100% coverage within,
45 minutes of the population wro may not have received the initial notification within the entire plume exposure EP2.
The basis for any special requiremen'ts exceptions (e.g., for extended water areas with transient boats or remote hiking trails) must be documented. "
The NRC rule 10 CFR Sd Appendix E,Section IV. D.3. requires that licensees "shall demonstrate that the State /lecal otficials have the capacility to make a public notification decision pecmptly on being inforned by the licensee of an emergency condition." The rule further states that "the design objectiva of the pecmpt public notification system shall be to have the capability to essentially ccmplete the initial notification of the public within the plume exposure pathway EP2 within about 15 minutes.
The use of this notification
I-2 capability will rance frcm immediate notification of the public (within 15 minutes of the time that State and local officials are notified that a situation exists requiring urgent actien) to the more likely event where there is substantial time available for the State and local governmental officials to make a judgment whether or not to activate the public notification system."
A very important aspect of the formal FEMA process for reviewing and approving alert and notification systems is confirming that the. design objectives and requirements outlined above have been met.
In confirming alert and notification system capa-bility, FEMA nust consider a conservative scenario, i.e., the condition requiring system activation and issuance of an instructional message by offsite authorities within 15 minutes of notification by the licensee that inrediate protective acticns are required. NRC Rule 10 CFR 50, Appendix E requires that licensees have the capa-bility to notify responsible offsite officials within 15 minutes after declaring an emergency.
Similarly offsite, in extreme situations with no decision-making time available, the capability must exist to activate the system and broadcast an instruc-tional message within 15 minutes of notification by the licensee; or.if decision-making time is available, the capability nust exist to activate the system and broadcast an instructional message within 15 minutes of a decision by the responsible official to warn the population. While FEMA and NRC require that this 15 minute capability exist, it is recognized that not all emergency cenditions will necessitate offsite notification within as short a time as 15 minutes.
The "15-minute capability" is confirmed through the observation of actual demon-strations or simulations of this capability during offsite radiological emergency pre-
'paredness exercises. Actual demonstrations are encouraged.
During these exercises, exercise evaluators actually time the alert and notification process to confirm that the administrative procedures and mechanical ccmponents of the system are in place and satisfy FEMA and NRC requirements.
INTERPRETATICNS FEMA's interpretation of the design objectives outlined in NUREG-0654/ FEMA-REP-1, Appendix 3 and of the requirements in 10 CFR 50, Appendix E are based on geographic location within the emergency planning zone.
We alert is considered to be the warning signal and the notification is considered to be the issuance of public in-structions via the Emergency Broadcast System (EBS) or other systens.
We design ob-jectives will be applied by FEMA in alert and notification system reviews as follows:
- Within 0 to 5 Miles of the Site Alert and notification systems must be capable of providing an alert signal and an instructional message within 15 minutes to populated (permanent and transient) areas located within 5 miles of the facility. 21s includes alerting and noti-fying the transient population in recote rural areas, cpen water areas, rivers, hunting areas, recreational areas, private ecmpcunds, beaches, national forests, and other icw population areas which may require special alerting procedures.
- Within 5 to 10 Miles of the Site Alert and notification systems must also be capable of providing an alert signal and an instructional message within 15 minutes between 5 and 10 miles of the facility.
However, in extremely rural, low population areas beyond 5
I-3 miles, up to 45 minutes may be allcwed for providing an alert signal and an instructional message to the permanent and transient population.
Examples of such areas include rural far.rs, hunting areas, recreational areas, open water
. areas, national forests, beaches, and rivers. The alert and notificatien system design submittal shculd contain the rationale for requiring up to 45 minutes to alert such areas as well as the other documentation required in FEMA-REP-10. Areas proposed in the alert and nctification system design sub-
' mission for alerting within 45 minutes will be reviewed on a case-by-case basis.
- All. Areas Within the Emercency Planning tone In all situations the time frames for activating the alert and notification system are measured frcm the point at which the designated official, or officials if two or more jurisdictions are involved, reaches a decision which necessitates the activation of the alert and notification system.
As indicated in the chart below, there is decision-making time available to offsite officials that shculd not be calculated in the 15 or 45 minutes.
The following chart illustrates the key steps in the alert and notification process:
TIMING CHART Alert Signal Authorized Public Activated and Official Reaches Instructional Licensee Decision Which Re-Message Issued Emergency Notifies quires Activating via Emergency Declaration Public the Alert and Noti-Broadcast or by a Utility Officials fication System Other Systems 15 Minutes Varies 15(or 45) Minutes Decision-inaking Time for Public Officials Varies Frcm Virtually No Time Available In A Fast-Breaking Accident To Substantial Time In A Slowly Evolving Accident CCNFIPMATICN OF CAPABILITIES CURING EXERCISES In preparing to evaluate the 15 minute alert and notification capability during an exercise, there are steps that can be taken to make this task easier for the evaluator.
Below are suggestions and considerations regarding evaluating this capability before, during, and following exercises:
I-4 Pre-Exercise Activities Before exercise activity begins, the Regions should confirm or be aware of the following aspects:
- That for the offsite jurisdictions with alert and notification responsi-bilities, all administrative procedures for completing the entire process are clearly coordinated and documented in the plans.
- That the plans clearly state that the alert and notification process
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can be carried out within the required time frames.
- That the plans clearly identify the official or appointed official (s) with decision-making authority who can, issue protective action reccmendations and authorize activation of the system (this official might be the Governor, a County Administrator, a County Judge, or other similar officials). The 15 or 45 minutes begins with this official's authorization to activate the system.
- That the plans, clearly indicate the planned alert and notification activi-ties related to each emergency classification level outlined in the plan.
- Khich emergency classification level will be used to verify the alert ard notification system capabilities. It is acceptable to verify the capabilities of the system at any one of the activations, if there is more than one, as long as the entire sequence can be observed during the activation chosen for verification.
- Which routes will be observed if route alerting is part of the alert and notification system and is being confirmed during the exercise.
- That any backup alerting procedures that have been developed are clearly outlined in the plan including how these procedures will be implemented and the time frames proposed by the responding organization for completing them, if any are proposed.
ExercI.se Activities During exercises, the Regions should be cognizant of the following:
- Startino the Clock In confirming that the alert and notification system time requirements are satisfied, the evaluator should begin the timing frcm the point at which the decision to activate the alert and notification system is made.
Within 15 or 45(if applicable) minutes of this decision by offsite officials, the alert signal must be activated and an instructional message must.be on the air.
- Monitoriro Each Stec Every step of the alerting prccess shculd be monitored starting with the decision to activate the system through the actual or simulated broad-l
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cast of the protective action reccumendation to confirm that proper pro-cedures are being followed.
During exercises, decision-making time should be available to offsite offic-ials.. However, it will be incunbent upon the exercise evaluators to deter-mine if the time required by dffsite officials to make protective action recomendations is excessive and would result in the public being placed at risk. Obviously in a real emergency, the nature of the emergency will dictate the amount of time available to offsite officials in arriving at protective action reccmmendations. Similarly, during an exercise, the scenario and exercise play will give an indication of what reasonable de-cisien-making time is and when a lack of action should result in a required corrective action citation or deficiency. Decision-making time cculd range frcm absolutely zero in a serious, fastbreaking accident, to the mre likely situation whereby consultation time would be available to offsite officials.
Once the offsite officials make a decision to implement a protective action, the 15-minute clock begins. Since every exercise is different, the decision-making time observed will vary.
- Prirary Route Alerting If route alerting is a primary means of providing the alert signal, the' Region can assign evaluators to acccrepany the individuals performing this function to confirm that proper procedures are followed and that the ap-plicable 15-or 45-minute requirements are achieved including all steps cut-I lined in FEMA-REP-10~(e.g., mobilization of personnel, transit time to the i
beginning of the route).
If multiple routes are involved and sufficient j
evaluators are not available for evaluating every route, a sampling of the routes may be chosen for evaluation, possibly, focusing on the most difficult routes or the mee populated routes.
- Backup Rcute Alerting If backup route alert and notification system procedures are demonstrated during exercises, evaluators shculd be aware of the time required for off-site authorities to cceplete the entire backup route alerting process.
These systems are designed to be put into effeet only when primary systems, especially sirens, fail. There is no hard and fast time requirement for ccupleting the backup rcute alerting process; however, 45 minutes is a suggested objective for ccupleting the process.
- Simlation 1
j It is acceptable to simulate the activation of alert and notification systems during exercises.
However, even though the system activation is being simu-l lated, the 15-minute capability can still be confirmed.
It is important that i
all jurisdictions participating in the notification process are operating off the same simulated alert activation time. Route alertirq times should be con-firmed through actual observation.
Even thcugh the notification process is Ming simulated, the observer should see the preparation of the instructional message, coordination with participating jurisdictions, comunication with the broadcast station and ccmpletion of the authentication process.
I-6 Post-Exercise Activities In preparing the post-exercise report, the following items shculd be addressed:
- A clear statement of whether or not the exercise objectives associated -
with the alert and notification system were achieved.
- A chart or some other method of indicating the exact times of the various steps in the alert and notification process that will make it clear if the time requirements have been achieved.
- Failure by offsite authorities to emplete the primary alert and notifi-cation process within the time frames stipulated in NURfDG-0654/ FEMA-REP-1, Appendix 3 and FEMA-REP-10 should automatically result in a " deficiency" citation, regardless of the type of system (e.g.
sirens, tone alert radios, route alerting) employed.
- Failure to cmplete backup route alerting in accordance with the time frames established by the respoMing organi'zations should be cited as an
" area reemmended for improvement".
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i
Attac! rent II, Below is m approximate time line representing each at the major steps leading up to ard following an alert and notificatico systen demonstration.
Tnis time line is approximate and for planning purposes cnly.
Due to changes in priorities, it may be modified oy FC% Headquarters as needed on a site-specific basis.
PRE-SURVEY
-16 Weeks
- FEMA Headcuarters receives a copy of the licensee's design submission through the FD% Regional Office with a copy remaining in the Region for review.
-15 Weeks FEMA Headquarters provides the licensee's design submittal to the technical assistance contractor for review.
-12 Weeks FDiA Headquarters and Region jointly agree on a preliminary date for the alert and notification demonstration and survey.
-9 Weeks FEMA Headquarters receives the preliminary reprt on the design fron the technical assistance contractor.
-8 Weeks
- FEMA Headquarters submits the preliminary report to the Regional Office for review.
-4 Weeks Regional Office completes a review of the preliminary regort fron the technical assistece contractor and, incitding their own' review, makes a preliminary findirrg of adequacy or inadequacy to FD4A Headquarters.
If the design submission is found to be adequate, the Region completes final scheduling for the alert and notification denenstration.
At this point l
the tidhnical_ assistance contractor initiates ef forts with i
the subcontractor to prepare for the telephone survey.
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POST-SURVEY
+8 Weeks Technical asslstance contractor provides final report on the alert and notification denenstration to FE% Headquarters.
I
+10 Weeks FEMA Headquarters transmits report to the Regional Director for final revie.< and evaluaton.
+14 Weeks Regional Director submits final reconnendations on the alert and notification demonstration to FD% Headquarters.
+16 Weeks FEMA Headquartets issues final findings and certificatico to NRC. *If a site has a conditional 350 approval, caveatais lif ted and the Governor is notified of approval.
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UNITED STATES OF AMERICA 00LMETEP NUCLEAR REGULATORY COMMISSION 05NPC BEFORE'THE ATOMIC SAFETY AND LICENSING BOARD'87 APR 27 P12:53 0FFICE P h uk" As t In the Matter of
)
00CMETing f 3Env;u BRANCH
)
Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5 (Shoreham Nuclear Power ^ Station,
)
Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of " NOTICE OF FEMA GUIDANCE" in the above-captioned proceedings have been served on the following by deposit in the United States mail, first class, this 22th day of April,1987:
John H. Frye, III, (Courtesy Copy)
Fabian G. Palomino, Esq.
Administrative Judge Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, D.C.
20555 Albany, NY 12224 Oscar H. Paris (Courtesy Copy)
W. Taylor Reveley III, Esq.
l Administrative Judge Hunton & Williams Atomic Safety and Licensing Board 707 East Main Street l
U.S. Nuclear Regulatory Commission P.O. Box 1535 i
Washington, D.C.
20555 Richmond, VA 23212 Frederick J. Shon Jonathan 0.'Feinberg, Esq.
Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Empire State Plaza Washington, D.C.
.20555 Albany, NY 12223 I
Morton B. Margulies, Chairman Dr. Jerry R. Kline Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S.. Nuclear Regulatory Commission U1 5. Nuclear Regulatory Commission East-West Towers, Rm. 430 East-West Towers, Rm. 430 4350 East-West Hwy.
4350 East-West Hwy Bethesda, Maryland 20814 Bethesda, MD 20814 Stephen B. Latham, Esq.
John F. Shea, III, Esq.
Christopher M. McMurray, Esq.
Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.
Attorneys at Law David T. Case, Esq.
P.O. Box 398 Kirkpatrick & Lockhart 33 West Second Street 1800 M Street, N.W.
Riverhead, NY 11901 9th Floor Washington, D.C.
20036 Atomic Safety and Licensing Board Panel Joel Blun, Esq.
U.S. Nuclear Regulatory Commission Director, Utility Intervention Washington, D.C.
20555 NY State Consumer Protection Board Suite 1020 Atomic Safety and Licensing 99 Washington Avenue Appeal Board. Panel Albany, NY 12210 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Monroe Schneider North Shore Committee P.O. Box 231 Docketing and Service Section Wading River, NY 11792 Office of the Secretary U.S. Nuclear Regulatory Commission Philip H. McIntire Washington, D.C.
20555 Federal Emergency Management Agency 26 Federal Plaza Spence Perry, Esq.**
New York, New York 10278 General Counsel, Rm. 840 Federal Emergency Management Agency 500 C Street, S.W.
Washington, D.C.
20472 Robert Abrams, Esq.
Attorney General of the State Mary M. Gundrum, Esq..
of New York New York State Dept. of Law Attn:
Peter Bienstock, Esq.
120 Broadway Department of Law 3rd Floor, Room 3-116 New York, N.Y Two World Trade Center 10271 Room 46-14 New York, NY 10047 Anthony F. Earley, Jr., Esq.
MHB Technical Associates General Counsel 1723 Hamilton Avenue Long Island Lighting Company Sui ~te K 250 Old County Road San Jose, CA 95125 Mineola, NY 11501
. County Executive Martin Bradley Ashare, Esq.
Suffolk County Executive Suffolk County Attorney County Executive / Legislative Bldg.
H. Lee Dennison Building Veteran's Memorial Highway Veteran's Memorial Highway Hauppauge, NY 11788 Hauppauge, NY 11788 Mr. Jay Dunkleberger Ms. Nora Bredes New York State Energy Office Shoreham Opponents Coalition Agency Building 2 195 East Main Street o
Empire State Plaza Smithtown, NY 11787 Albany, New York 12223 O
Ellen Blackler Mr. Robert Hoffmnan New York State Assembly Ms. Susan Rosenfeld Energy Committee Ms. Sharlene Sherwin 626 Legislative Office Building P.O. Box 1355 Albany, NY 12248 Massapequa, NY 11758 Brookhaven Town Attorney Richard Bachman, Esq.
475 E. Main Street U.S Nuclear Regulatory Agency Patchogue, NY 11772 7735 Old Georgetown Road Bethesda, MD 20814
/ufr x $um
/
William R. Cumming
,j Federal Emergency Management Agency J
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