ML20235F353

Informs That E Reis to Recipients Did Not Contain Ref to Commonwealth of Ma Areas of Disagreement W/Proposed Procedure for Test of Plant Emergency Notification Sirens. Summary of Each Objection to Procedure Presented

ML20235F353
Person / Time
Site:	Seabrook
Issue date:	09/22/1987
From:	Fierce A MASSACHUSETTS, COMMONWEALTH OF
To:	Edles G, Rosenthal A, Wilbur H NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#387-4475 OL, NUDOCS 8709290060
Download: ML20235F353 (3)

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(( ' x 44/72T b THE COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF THE ATTORNEY GENERAL yL;.

JOHN W. McCoRMACK STATE OFFICE BUiLolNG >

oNE ASHBURTON PLACE, BOSTON 02108-1698

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'87 SE~ 24 ;;;; :43 JAMES M. SHANNoN ATTORNEY GENERAL 1s September 22, 1987 Alan S. Rosenthal, Esq., Chairman Gary J. Edles, Esq. .

Atomic Safety and Licensing Atomic Safety and Licensing l Appeal Board Appetl Board j U.S. Nuclear Regulatory U.S. Nuclear Regulatory -

l Commission Commission Washington, DC 20555 Washington, DC 20555 Howard A. dilbur Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, DC 20555 In the Matter of PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ET AL.

(Seabrook Station, Units 1 and 2)

Docket Nos. 50-443, 50-444 Off-Site Emergency ?lanning -Ob-

Dear Members of the Appeal Board:

In his letter to you dated September 11, 1987, whi.ch we

received September 16, 1987, Edwin Reis, the NRC's Deputy

' Assistant General Counsel, listed certain " areas of disagreement" regarding the proposed procedure for a test of tne Seabrook emergency notification sirens that you indicated should be conducted in your order of July 30, 1987 At the end of the letter, Mr. Reis suggests that the Appeal Board be informed within seven days if the parties views have been

, mischaracterized or inadequately stated.

We are writing to you now to inform you that Mr. Reis' letter did not contain any reference whatsoever to the " areas of disagreement" we have with the proposed test procedure.

Perhaps this is because at the very time --late August-- when Mr. Reis was obtaining the views of the parties on the test procedure, Don Bronstein, the attorney who was handling this matter for our office, left his job here for a position in private practice. In any event, we do have some strong objections to the adequacy of the test p'ocedure, and these objections are listed briefly below.

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Pursuant to your recent Order of September 17, 1987, in ,

which you direct each interested party to file a memorandum, on l or before October 5, 1987, detailing its positions on the matters on which agreement has not been achieved, we intend to file a memorandum which describes tl.ese objections in greater detail.

A summary of each of our objections to the test procedure is as follows:

A. The Expectent Observers Problem The proposed test procedure utilized an unspecified number of " field" and " pole" observers who are to be stationed at various distances from sirens to listen carefully at exactly specified times (requiring that they have watches) for the sirens to be activated in the various modes. These " expectant observers," because they will be listening carefully through the ever-percent background noise for a specific kind of sound at a specified time, could easily hear faint or muffled siren noises that the unexpectant public would not notice. The Observer Data Sheets for " pole observer" and " field observer,"

1 Attachments 4 and 5 to the proposed test procedure, ask observers to rate the noises heard simply as either " sat." or "unsat." without utilizing any objective criteria whatsoever.

Such a test says nothing about whether the sirens are capable '

of providing emergency notification to the unexpectant i populace. Because the siren system was designed to meet certain sound coverage (decible level) criteria which enable its noise emissions to be heard above the background noise throughout the EPZ, any test of sirens must employ sound testing equipment, not expectant observers, to objectively assess whether the sirens emit sounds which meet the system's objective design criteria. The subjective assessments of expectant observers are worthless measures of a siren system's adequacy.

B. The Observer Location Problem The proposed test procedure calls for three (3) observers s at each poles one at the pole, one at 1000 ft., and one at 5,000 ft. The procedure notes, however, that "[t]he 1000 ft.

and 5000 ft. locations are approximate and are intended as guidelines. It may not be practical (or even possible) to locate field observers at these distances." If one seeks to have a meaningful siren audibility test in wintertime conditions, when siren audibility is possibly muffled by snow and ice, these test procedures provide inadequate coverage of the geographic area each siren is designed to cover. The sound contour map for the siren system, provided in Volume 1 of the New Hampshire Radiological Emergency Response Plan, indicates that because of hills and other geographic features the sound g level contours around each siren are far from uniform. In many

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.l cases the 70dBC coverage , contour line is not a circle but is a 1 circle with a " wedge" or a " notch" in it, typically due to the effects of a hillside. It is in these " gap" areas where snow-muffled sirens would least likely be heard; so observers should be stationed in these " gap" areas as the top priority.

The distance an observer is from a siren in and of itself, is a poor criteria to use for determining where observers should be placed, because it is the sound coverage contour lines, not distance, which describe areas most likely to receive an 1 inaudible or unintelligible signal.

C. The Voice Mode In.telligibility Problem 1

- i- Since there have been serious problems created by snow and 4 ice accumulation when sirens were tested last winter, any fair test this winter should test the " intelligibility" of the messages emitted by the sirens when they are used in the voice mode. Acoustics experts utilize a variety of test procedures to t-ast voice intelligibility, but no voice mode intelligibility test whatsoever are included in the proposed test procedure. As with the " expectant observer" problem described above, the fielo observers who have been carefully j- instructed to listen for a particular message is more likely than an unexpectant resident not only to hear that message but to understand it as well, even if garbled or muffled due to snow and ice accumulation in the sirens. Objective voice intelligibility tests should be incorporated into the test

procedure to eliminate the expectant observer problem when sirens are tested in the voice mode.

Very truly yours,

' Allan R. Pierce Assistant Attorney General Nuclear Safety Unit Department of the Attorney General One Ashburton Place

, Boston, MA 02108 (617) 727-1090 ARF /ds cc: Service List i

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