ML20211N673

Suppls 861121 & 25 Guidance Documents Served on All Parties W/Attached RW Krimm to El Jordan 861211 Memo Re Generic Safety Concerns on Alert & Notification Sys.Certificate of Svc Encl

ML20211N673
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	12/17/1986
From:	Cumming W Federal Emergency Management Agency
To:
References
CON-#486-1918 OL-3, OL-5, NUDOCS 8612180279
Download: ML20211N673 (8)

Text

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M/7 December 17, 1986 000KETED r USNRC

'86 DEC 17 P2 :07 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION , .

DCcrA !

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket No. 50-322-OL-3 (Emergency Planning)

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5

) (EP Exercise)

(Shoreham Nuclear Power Station, )

Unit 1) )

FEMA GUIDANCE OF POTENTIAL APPLICABILITY TO SHOREHAM PLAN AND EXERCISE PROCEEDINGS FEMA Counsel hereby supplements the November 21, 1986, and November 25, 1986 guidance documents served on all parties with the attached Richard H. Krimm to Edward L. Jordan Memorandum dated December 11, 1986, subject: Generic Safety Concerns Regarding Alert and Notification Systems.

Respectfully submitted,

.#/4x / '

l William R. Cumming Counsel for FEMA lb 8612180279 861217 PDR ADOCK 05000322, o PDR i

• • i 44

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f ' p( J Federal Emergency Management Agency

, 1 . Washington, D.C. 20472 DEC i 1 1986 -

MEMORANDUM FDR: Edward L. Jordan -

Director Division of Ehergency Preparedness and Engineering Response Office of Inspection and Enforcement U.S. Nuclear .to , Comnission F10M: R W. rimn Assistant Associate Director Office of Natural and Technological Hazards Programs

SUBJECT:

Generic Safety Concerns Regarding Alert and Notification Systems This is in response to your memorandum dated September 15, 1986, in which you requested that FEMA provide further assistance in the formulation of a response to Chairman Zech's memorandum dated August 7, 1986. His memorandum discussed generic safety concerns raised by the Shearon Harris (SH) Licensing Board regarding the adequacy of prcrnpt alert and notification systans at night.

In the SH letter dated May 16, 1986, the Board reached the conclusion that "the practical effect of the FEMA and NRC staff positions on nighttime alerting with-in the 15 minutes based on sirens and informal alerting are that (1) in the sume, about 10% of the people will not be alerted (more in hot climates) and (2) in the winter in cold climates,15-30% of the people will not be alerted".

De Board based its conclusion with respect to the sumer nighttime condition on FEMA's testimony frcan the SH operating license proceedings. D e Board's conclusion relative to cold climates was based on a 1982 NRC contractor analysis titled " Evaluation of the Prcr9t Alerting Systems at Four Nuclear Power Stations,"

NUREX3/CR-2655, PNL-4226 which projected siren alerting rates under winter nighttime conditions. Ultimately, the Board held that the Camission's requirement of

" essentially 1004" means a notification system capable of alerting greater than 95% of the emergency planning zone (EP2) residents within the first 5 miles.

Rus, the SH Licensing Board interpretation of 10 CFR 50 Appendix E regulatory i requirements that the " design objective of the prcmpt public notification system shall be to have the capability to essentially comlete the initial notification of the public within the plume exposure pathway EP2 within about 15 minutes" has been equated to alerting greater than 95% of the population within 5 miles of the site (scrnething less than 90% was acceptable in the 5-10 mile area) under probable worst case conditions within 15 minutes. Following is a discussion of FEMA's position concerning the adequacy of the current standards for nighttime conditions in light of the SH Board interpretation of the Camission's emergency notification regulations.

I). D e conclusion reached by the Board in response to the hearing contention, was that 91% of the 10-mile EP2 population would be alerted within 15 minutes for sumer nighttime conditions. n e 914 estim te included an analysis of the acoustical output of the sirens, calculation of the probab'ility that the given sound level would awaken the individuals who reside in the EP2, and a prediction of the extent to which awakened individuals would informally notify friends, h . . +

c l

, the predicted 914 was insufficient for the first 5 miles of the EPZ. However, '

• they accepted the system as adequate based on the applicant's connitment to distribute tone alert radios to about 600 bcznes within the first 5 miles.

E is raised the expected level of alerting above the 954 threshold. It is inportant to note that the dif ference of 44 between the SH Board's accepted level of 954 and the predicted level of 91% represents approximately 24 h ees (600 X .04) in the 5-mile zone and is less than 1/2 of one percent of the total number of homes in the 10-mile EP2. Also, considering the typical sunmer nighttime meteorological conditions at the SH site, it is unlikely that the entire 5-mile area would be exposed to the plume in the first 15 to 30 minutes under most accident scenarios. h is would further reduce the number of households / individuals potentially at risk. If as an exanple, one quarter of the area was exposed in the first 15 minutes, the fraction of the population not initially alerted that would be subject to additional risk would be approximately 2 to 3 percent (100% less 914 times 1/4). Based on these results, FDM remains satisfied' that the design of the SH alert and notification system, prior to enhancement with tone alert receivers, meets the intent of the Comission regulations.

II). As stated previously, 10 CFR 50 Appendix E requires that the initial notification be essentially conpleted within about 15 minutes. FD% believes that the flexibility inplied in the phrase "within about 15 minutes" is per-tinent to this issue of judging the adequacy of alert and notification systems.

This belief stems fra an examination of what occurs in the sequence of events during an actual emergency. Most comercial nuclear power plant alert and notification systems rely primarily on sirens to alert the population.

However, it is important to note that most plans call for back-up notification by police, fire, and other emergency vehicles which would be deployed during an emergency situation. Dese backup systems would provide inportant ongoing benefits in terms of alerting the population residing within 5 miles of the site who may not have received the initial notification within the first 15 minutes. Furthermore, the primary systems, typically sirens, would continue to operate beyond the initial 15 minutes. The repeated sounding of the sirens in conjunction with the abovementioned backup systems would provide an effective means of alerting the fraction of the population not initially alerted.

Thus, FD%'s interpretation of the design objective terminology in 10 CFR 50 Appendix E is to assure that the system provides coverage of the population through primary means within 15 minutes with sufficient backup capability to emplete the coverage of the non-alerted population as soon as possible thereafter. Eis interpretation is consistent with the statements of consideration for the Final Rule on Dnergency Planning where "he Cmmission recognize (d) that not every individual would necessarily be reached by the actual operation of such a system under all conditions of system use." nis interpretation is reinforced by two pertin9nt statements in NURII)-0654/

FD%-REP-1, Appendix 3:

1) 21s design objective does not, hcuever, constitute a guarantee that early notification can be provided for everyone with 100%

assurance or that the system when tested under field* conditions will meet the design objective in all casest and,

' 2) hat special arrangemnts will be mde to assure 100% coverage within 45 minutes of the population who may not have received the initial notifications within the entire plume exposure,EPZ.

The primary system at SH was predicted to notify 911 of the population within 15 minutes.

Further soundings of the sirens supplemnted by route alerting provide the capability to alert those individuals who may not have received the initial signal.

Based on discussion points in GI and III, the SH Board decision which prescribed a greater than 954 alerting level within 5 miles of the site in 15 minutes appears to FEMA to be an extreme interpretation of the intent of the Ccmnission's language that "the design objective of the prcnpt 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".

III). De other major issue discussed in the SH Board corres adequacy of alert systems under winter nighttime conditions. pondence concerns the D e members of the Indian Point Licensing Board raised related concerns regarding the adequacy of alert systems during stormy winter nights.

W e SH Board conclusions were based on the winter nighttime alerting percentages for four plants which were calculated in the NUREG/CR-2655 analysis.

by 10 to 20 percentage points based on testimony.These We adjusted percentages figures for thewere adju four 851. plants predicted a probable range for winter nighttime alerting from 70 to n is corresponds to 15-30 porcent of the people who would not be alerted within the first 15 minutes, a condition viewed by the SH Board as not meeting the " essentially complete" regulatory requirement.

However, one of the SH licensing board reccmmendations in their letter of May 16, 1986, stated that if such alerting lavels (70-854) are acceptable and correspond to an absence of undue risk in the first 5 miles of the EP2, then the prer ant regulatory language should be clarified and if necessary changed. IT.MA be Lieves this recom mndation may be appropriate. This belief stems from the optiora avail-able as protective actions under severe accident conditions. During a release at night (defined as 1 a.m. to 6 a.m. in the SH proceedings) those individuals failing to hear the sirens because they are sleeping indoors would already be in a sheltered condition.

De structures providing shelter in the colder climtes should provide greater shielding protection and prevention from intrusion than in hot climates.

nus, for the nest likely protective action reccmmendation of shelter during stomy winter nights, there should be virtually no additional risk to the non-alerted population situation. within the first 5-nile zone because they are already in a sheltered For the more unlikely protective action reconnendation of inmediate evacuation, FD% questions that a dose savings would result in alerting 95 percent versus 70 to 85 percent of the population in the first 15 minutes in light of the total time required to evacuate residents surrounding nuclear pcwr plants during inclement winter nighttime weather conditions.

In the other situation where a f.

precautionary evacuation would be reccmmnded before an inpending release, those who may not have heard the sirens initially could still be alerted in time to ecmplete an orderly ard effective evacuation.

Under either protective action, shelter or evacuation, during inclement winter a nights, it is unlikely that enhancemnts to the alert systems would substantially increase the cuerall ef fectiveness of the emergency response to a given accident

I

-4 r situation resulting in additional protection to the public health and safety.

• Thus, meeting the absence of undue risk criteria during a stormy winter night condition may not necessarily depend on alerting levels as high a:s 954 in the first 15 minutes based on the above discussion.

In stenary, EMA currently makes its determination regarding the adequacy of the pronpt alert and notification systems based on the standards and criteria set forth in NURm -0654 Appendix 3 and FEMA-REP-10, " Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants", a doctanent which further clarifies the acceptance criteria. EMA-REP-10 requires that the siren systems he designed to produce certain minimum outdoor sound levels based on sunmer daytime weather conditiors. Stmner is the time least favorable for outdoor sound propagation, therefore, systems designed against this standard are reasonably conservative.

MMA believes that the daytime condition is the situation that is more critically dependent on a high, percentage alert of the EPZ population within about 15 minutes, because this is the time when individuals are more likely to be out of doors, thus increasing their potential for exposure.

The SH decision has raised a fundamental question as to what percentage of the persons in the EP2 nust receive some sort of alert notice of an emergency in order to protect them fran undue risk for all reasonably anticipated conditions. Further review of this issue may be required fran a policy perspective.

6

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h UNITED STATES OF AMERICA M MEILP NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 80ARD OFFR . O ,u.

In the Matter of ) 00thr:7 . tr7,t

)

[ LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5

) (EP Exercise)

(Shoreham Nuclear Power Station, )

Unit 1) )

CERTIFICATE OF SERVICE k

I hereby certify that copies of " FEMA GUIDANCE OF POTENTIAL APPLICA8ILITY TO SHOREHAM PLAN AND EXERCISE PROCEEDINGS" in the above-captioned proceedings have been served on the following by deposit in the United States mall, first class, this 17th day of December, 1986:

John H. Frye, III, 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 W. Taylor Reveley III, Esq.

Administrative Judge Hunton & W1111ams Atomic Safety and Licensing Board 707 East Main Street U.S. Nuclear Regulatory Commission P.O. Box 1535 i Washington, D.C. 20555 Richmond, VA 23212 l Frederick J. Shon Jonathan D. 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

L Morton B. Margulies Jerry R. KIlne Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. 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. Herbert H.. Brown, Esq.**

Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.

Attorneys at Law Karla J. Letsche, Esq.

P.O. Box 398 Kirkpatrick & Lockhart 33 West Ser.ond Street 1800 M Street, N.W.

Riverhead, NY 11901 9th Floor Washington 0.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 Sulte 1020 Atomic Safety and Licensing 99 Washington Avenue l 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 Gerald C. Crotty, Esq. of New York Ben Wiles. Esq. Attn: Peter Blenstock, Esq.

Counsel to the Governor Department of Law Executive Chamber State of New York State Capitol Two World Trade Center Albany, NY 12224 Room 46-14 New York, NY 10047 Anthony F. Earley, Jr., Esq. MHB Technical Associates General Counsel 1723 Hamilton Avenue Long Island Lighting Company Suite K 250 Old County Road San Jose, CA 95125 Mineola, NY 11501 l

k 3-Hon. Peter Cohalan Martin Bradley Ashare, Esq.

Suffolk County Executive Suffolk County Attorney County Executive / Legislative Bldg. H. L 1 Dennison Building Veteran's Memorial Highway Vete. n'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 Empire State Plaza Smithtown, NY 11787 Albany, New York 12223 Ellen Blackler Mr. Robert Hoffmnan New York State Assembly Ms. Susan Rosenfeld Energy Commtttee Ms. Sharlene Sherwin 626 Legislative Office Building P.O. Box 1355 Albany, NY 12248 Massapequa, NY 11758 Brookhaven Town Attorney Bernard M. Bordenick, Esq.

l 475 E. Main Street Maryland National Bank Building Patchogue, NY 11772 Rm. 9604 Washington, DC 20555

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'Hilliam R. Cumming /

Federal Emergency Management Agthey 4

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