ML20235T379
| ML20235T379 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/06/1987 |
| From: | Berry G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#487-4561 OL-1, NUDOCS 8710130067 | |
| Download: ML20235T379 (15) | |
Text
7 4/J'6 f 10/06/87 20thfiE0 USNRC UNITED STATES OF AMERICA
'87 ET, -7 Pl2:00 NUCLEAR PEGULATORY COMMISSION CFFICE EMCKO.AU 990KElING Cd WICL BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARDBRANCH in the Matter of
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Docket Nos. 50-443 OL-01 PUDLIC SERVICE COMPANY OF
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50-444 OL-01 j
NEW HAMPSHIRE, g al.
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On-site Emergency Planning
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and Safety issues 1
(Seabrook Station,
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{
Units 1 and 2)
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NRC STAFF SUPPLEMENTAL RESPONSE TO APPEAL BOARD ORDER OF SEPTEMBER 17, 1987 REGARDING EAST KINGSTON SIRENS On September 25, 1987, the NRC Staff filed its response to the Appeal Board's Order of September 17, 1987, in which the Staff set forth its views on the matters of disagreement between the Staff, Applicants, and the Seacoast Anti-Pollution League (SAPL) regarding the testing of emergency sirens this winter in East Kingston, New Hampshire. See NRC Staff's Response to Appeal Board Order of September 17,1987 (Sepamber 25, 1987).
Subsequently, the Staff received a copy of a letter sent to the Appeal Board by the Commonwealth of Massachusetts in which the Commonwealth sets forth its concerns with the proposed emergency siren test.
See Letter to Appeal Board from Allan R. Fierce (September 22, 1987) (hereinafter " September 22, 1987 Letter").
This supplemental response addresses the concerns raised by the Commonwealth.1 As
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During his initial efforts to obtain an agreement among the parties regarding the conduct of the test of the East Kingston emergency (FOOTNOTE CONTINUED ON NEXT PAGE) l 8710130067 871006
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explained below, none of the concerns expressed by the Commonwealth is meritorious.
1.
The " Expectant Observers" Problem The Commonwealth argues that the proposed test procedures are flawed because they call for the use of observers stationed at various distances from the sirens to listen for the siren sounds instead of sound l
testing equipment.
According to the Commonwealth, only sound testing i
equipment can be relied upon "to objectively assess whether the strens emit sounds which meet the system's objective design criteria."
September 22, 1987 Letter at 2.
The Staff do;is not share the Commonwealth's concern.
It should be pointed out that the purpose in utilizing human observers is not to establish that the sound pressure emitted by the strens is at least 60 decibel (dB) or exceeds the ambient background noise level by at least 10 dB as requrired by FEMA REP-10.
That fact must be independently established by more reliable means.
FEMA REP-10 at E-8.
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Rather, the proposed test is intended to (FOOTNOTE CONTINUED FROM PREVIOUS PAGE) sirens this winter, Staff counsel was informed by the Commonwealth that because "SAPL was principally interested in this matter, [it]
would abide by any agreement SAPL made concerning the testing of the strens."
See Letter to Appeal Board from Edwin J. Reis at 1 (August 31,1970.
Thus, the Staff was not, and had no reason to be, aware of the concerns expressed by the Commonwealth in its September 22, 1987 Letter to the Appeal Board.
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"There are at least two ways to determine siren sound output:
(FOOTNOTE CONTINUED ON NEXT PAGE)
determine whether the sirens would be heard by the affected population in the event of an actual emergency.
Therefore, it is preferable to utlilze human rather than mechanical listeners.
Second, as pointed out by the Appilcants, nothing in the proposed test procedures prevents the Commonwealth from posting its own listeners or using its own sound testing equipment to challenge the test results.
See Applicants' Memorandum Regarding Test of East Kingston Sirens at 4 (September 30, 1987). -
For these reasons, the concern expressed by the Commonwealth does not call into serious question the integrity of the proposed siren test.
(FOOTNOTE CONTINUED FROM PREVIOUS PAGE)
Onsite field measurements around at least one of each type of siren used within the EPZ: or Anechoic, semi-anechoic, or reverber t%1 chamber tests in a qualified laboratory on sirens that are pyresentative of each type of siren used within the EPZ."
FEMA REP-10 at E-8.
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In stating that "the subjective assessments of expectant observers are worthless measures of a stren system's adequacy,"
September 22, 1987 Letter at 2,
the Commonwealth falls to appreciate a significant fact.
The results of the proposed test are not dispositive as to the " adequacy" of the siren system.
That determination will I
not be made by Appilcants, Interveners, or the NRC Staff but rather by FEMA in the normal course of its review of the Seabrook offsite emergency preparedness program under 44 C.F.R. Part 350 of l
FEMA's rules.
With respect to the issuance of a low-power license,
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however, the Commission's regulations only require as a precondition that a siren system be determined to be installed and operable. See 10 C.F.R. 6 50.47(d).
The applicant, of course, certifies that the j
sirens are designed to be in accordance with NUREG-0654/ FEMA l
REP-1, Appendix 3.
The Staff has previously verified the Merrimac sirens have been installed and are operable.
See inspection Report Nos. 50-443/86-46 and 50-443/86-54.
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2.
The " Observer Location Problem" The proposed test procedures provide that for each siren pole an observer be stationed at the point of origin and at distances of 1,000 and 5,000 feet away respectively.
The Commonwealth states that instead of distance, the controlling consideration in the placement of observers should be those areas within the sound coverage contour zone most likely to receive inaudible or unintelligible signals.
September 22, 1987 Letter at 3.
The Staff does not believe it is unreasonable to deploy observers at specified distances from each sirens.
The Staff has reviewed the proposed test procedures in this regard and verified that they "are adequate in scope and content to assure a valid test of the sirens." See inspection Report No. 50-433/87-22 at 5 (Attachment 1).
Recognizing that some parts of East Kingston will not be covered by the four strens located in East Kingston but will be covered by sirens located in neighboring towns, see id_.
at 4,
the main consideration in deploying observers during a test of the East Kingston sirens is to assure that the observers are located in areas intended to be covered by those sirens.
l The proposed plan appears to accomplish this goal.
The Commonwealth, of course, is free to deploy its own observers in the sound coverage zone at distances and locations of its choosing.
3.
The " Voice Mode Intelligibility" Problem Finally, the Commonwealth argues that " voice intelligibility" tests J
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should be incorporated into the test procedure.
September 22, 1987 q
i Letter at 3.
A similar concern was raised by SAPL and addressed by the j
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Staff in its September 25, 1987 response in which the Staff pointed out that the function of the East Kingston sirens in the event of an emergency at Seabrook is to broadcast a " tone alert" signal to members of the public alerting them to turn on their radios for additional information.
See Seabrook FSAR, Radiological Emergency Plan, Appendix E at E-1.
For this reason it is unnecessary to test the public address function of the East Kingston sirens. S CONCLUSION Applicant's procedure for testing the East Kingston sirens is acceptable to the Staff.
As far as the Staff is concerned, the purpose of the test is not to estab!!sh that the Seabrook public alert and notification system compiles with NUREG-0654 but rather to assure that the problems encountered during the January 31, 1987 test conducted by the Town of
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The only sirens that might be used to carry voice messages to the public in the event of an emergency are those that service the beach population.
But as the Staff noted in its initial response, there is not likely to be a significant beach population during the winter when the test is scheduled to be conducted.
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. l East Kingston do not recur.
The adequacy of the Seabrook public alert and notification system will be determined by FEMA In the normal course of its review of the Seabrook offsite emergency preparedness program.
R pectfully submitted, C
lpn erry rcgory Counsel for C Staff Dated at Bethesda, Maryland this 6th day of October 1987
OCT 01 '87 13:44 NRC MILLSTONE i PO7 4
U. S. NUCLEAR REGULATORY COMMISSION REGION I Report No._50-443/87-22 Docket No.
,5_0,44 3,'
04 License No..ljPF-56 Permit No.
CPPR-135 Priority Category B/C Licensee: Public Service Companyiof New Hampshire.
Tooo ETm street
}Tinchester]lew Hampshire 03105 Facility Name: Seabrook. New Hampshire Inspection At: Seabr_ook Station, Unit 1 imepaa+ den Co..J o L%J. Auyu,L IS-el, a moi.
Inspectors:
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23 /f5/
7['~Schumacher,SeniorEmergency
'date' froparodness Specialist Approved by:
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9 #/ E7 b.. Jfjpiarup',,Khicf ciato Errorqency Pferaredness Section EP&RPB.
DRSS Inspection Summary: Inspection on August 19-21, 1987-(Report No. 50-443/87 M Areas Inspected: Routino announced inspection by two. region-based inspectors to review cTJde%ccy of licensen actions in enerort = Wotico of violatica is suco for f ailing tu notify both Massachusetts and Hew Hampshire during an Ur. usual Event r.n February 11. 1987 and follow-up of 1.everal issues concerning the clert and tiotification system sirens.
Results: No violations were identified.
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- OCT 01 *87 13:46 NRC MILLSTONE.1 P01 DETAILS _,
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Persons Contacted.
- A. Callendrello Emergency Assistance Manager
- T. Harpster, Director, Emergency' Preparedness ;
- D. Moody Station Manager
- D.
perkins, Licensing
- J. Mcdonald, Radiological Assessment Manager R. Strickland, Shift Superintendent-R. Thompson,iShift Superintendent i
- Indicates those present at the exit interview; 2.
l.icensee Action.on previous Inspect. ion Findings During the inspection, the. inspector reviewed the licensee's progress concerning the items opened during inspection 50'443/87-08.
Follow up of licensca actions to address a Notice of Violation and related items are discusted below:
-(Closed) Violation (87-08-01):
Failuretto report the declaration of an "Unusuel Event" to the Commonwealth of Massachusetts within 15 minutes.
NHY rasponded to the March 23, 1987 Notice of Violation in letter (NYN-S7057) dated April 23, 1987.
The insp.1ctor r? viewed both immediate -and long tem corrective actions taken ty HHY to address the Notice of Violation. Hanagement directives were provided to all shift' supervisors stating that when procedures requite the declaration of an emergency class, the Cor;rnonwealth of Massachusetts and the State of New Hampshire will be notified within the rquired time frame.
In addition Emergency Response Procedures were ravised whcre necessary to imprave guidance to operators concerning classification, notification, and termination of emergencies. Training was provided to all shift supervisors, Unit shift supervisors and operations managerrent on the revised proceddres and the circumstances surrounding the violation.
The inspector reviewed the training lesson plans and conducted interviews with shif t supervisors and the team leader for Requi.lification Training to ensure training was adoquately conducted t.nd received by ail shift superv. sors.
Revisions to procedures were also revie.md. The intpactor concluded, based on the above, that training and procedure revisions are adequate.
Bated on the above, this item is closed.
-(Closed) Unrosolved Item (87-08-02).
The relationship betwcon the shift supervisor and the operations trcnager (or other Puty Station Emergency Lirector) during rmargency classification and notification, needs to be clari fied e nd s crossed in training.
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OCT.01 '87'13:47' NRC MILLSTONE 1 P02
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The inspector reviewed requalification training program lesson plans which covered the role of the shiftisuper,intendent as the Short Term i
Emergency Director.(STED). The STED is responsible for. emergency classification and notification until relieved'by Site Emergency I-Director.
In addition, selected. shift supervisors and the team leader.
for Requalification Training were interviewed.. The inspector determined that all 'hift supervisors were trained in their responsibilities and that tb.
knowledge level was adequate. '
Based on the above, this item is closed.
-(01osed) Unresolved Items-(87-08-03 & 04) Additional training may be necessary to clarify what events.are' classified as Unusual: Events;.the procedure for reporting events which have been classified under the Emergency Plan, but have cleared before reporting is possible, needs to be evalntted.
The inspector reviewed Emergency Response Procedures. ER-1.0,
" Classification and t; notification of Emergencies at Zero Power. " and Ot-1.1, *C14 ssifict,tten of Emcruencies" to evaluate procedural adequacy for clar.sification of events and for Guidance en report'ng requirements.;
loth procedures now contain the necestary classification for an operator.
In both cintsify crd leport cyants as required.
Each procedure discusses
" htt;-ic rcport an c\\ent that has cic6 red before reporting was possible.
during the event.
Use of these procedures was demonstrated for inspector by a selected shift supervisor.
Based on the above, this item is closed.
-(Cinsed) Unresolved Itom (87-08-05) The acceptability of using the sta te nt,tification " hot line" by the states for calling in for additional information needs to be evaluated.
The inspector reviewed a'NHY memorandum which documents that New Hampshire Civil Defense Agency officials new have a clear understanding of the notification process and the use of the " hot line."
Dased er the above, this item is closed.
-(Closec) Unresolved item (87-08-07):
The conmon-mode failure of the equalizing valve linkage on both the inner and outer emergency personnel air lock doors needs to be evaluated, and necessary reports completed if appropriate.
On April 24, 1987 NHY submitted a.10 CFR 21 to the NRC report (NYM-87059) report concerning the equalizing valve failure. The above item is tharefore closed end will be tracked under item 67-88-02 until resolved (see lit 50-443/07-1D).
i OCT'01 '87 13:48 NRC MILLSTONE.1 P03 1
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Follow-up on Public Alertino System ($1ren), Issues A.
East Kingston Siren-Yest of, January 1987 A test of the four sirens in East Kingston New Hampshire was conducted on January 31,' 1987!at the reques,t of the town of East Kingston.
to determine the adequacy of sound coverage of the fou Kingston sirens, in cese the town ever needed to activate their sirens, separately from the complete Seabrook alert and notification.
system, in case of a non-radiological emergency.
It was recognized be sufficient to alert all of East Kingston since part of Kingston depended upon the sirens in neighboring towns.
this was not intended to be a test of the Seabrook Alert and Because Notification System, it was conducted by the town without an approved Seabrook test procedure.
As a result, the location of the observers stationed to listen.for the sirens w;.s not contrniled in e manaar to ensure that they were iocated in tn urca intended to bc covarcd soloiy by the East Kingston sirens in the event of actisation of the complete alert and notification system.
observers in the field.i.he test. lower than expected sound level uts exp During Based upon the licensee's review and reconstruction of the test by intneviews uith test personnel and review of the tapa recordings nr.ca ci the radio cctivation s.ignals, it w;s detemined that the
- re.as were not actuated.long ennugh for the test to be valid.
30 seconds, and during the test sirens ucre activated approximately 15 seconds.
long enough to cover all the intendedConsequently, sirens were not activated been rointed away from the observer (s) area and could very well have duririg the test.
In addition to the procedural inadeqeocy of insufficient activation tur.e, sone actual malfunctions woro idautified as a result of severe weather conditions which existed just prior to the stren testing.
heavy wet snow with driving wind and subsequently falling temperat A
hac occurred the night before the test.
mth the sirens facing north, allowing th.)The sirens were installed on the siren grates and throats from the aTiects of snow and ice to build up uind.
of the activation (both on transmission catt receiving) anteana.
These pintos.serva as a ground planc.
activation signal.o factively detunod the antenna, lesiening the streng three out of four sirons foiled tc, cctive te;During the *est from tne East Kingt. ton
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- 0CT 01 '87 13:49 NRC MILLSTONE 1 PO4 5
l antenna, one of four failedito activate. :After: removal of the snow from the activation antennai activation was normal from both activation points. Wheniactivated, a lower than expected acoustic icvol from the sirens was noted by the observers (exact decibel level is unknown), apparently, due to snow and ice build-up.
j As a result of the above noted; deficiencies, the licensee has taken the following actions:
A siren activation test procedure has been developed and approved for East Kingston sirens.
The inspector reviewed
" Siren Activation Test Pnocedure-East Kingston", dated April 4, 1987, and verified that it' is adequate in scope and content to assure a valid test of the sirens.
The~ procedure is sufficiently generic in nature so that it could be modified for tests by other tewns as desired. A retest of the East Kingston sirens m s conducted on April 4, 1987, with acceptsble results.
The inspector verifded that test procedure 1S0608.002, " Quarterly Func'icaal fest of the ENS Remote $ircn Locutions" and c
106f>03.003 "'Annue.1 Functional Test, cnd Maintenance Procedure of the Emerlancy Notification System Romoto Siren I.ccations",
hhvo I c.r. canngcc' to reflect the Efter test orientr tion of the
., irons as " south". This orientation was selected by the licc. nee based en a revies of wind rose data for the winter months and should significr.ntly reduce the possibility of it.0/ snow bui %up on the siren crates.or throats.
Di rec t n',servation of several sirens du,*ing r. tour verified that they
'cere oriented to south.
The inspectv verified that the licensee has mocified the activntior antalna ground planes (except for the six sirens located in Rye) by replacing the flat plates with four short ra6 t&1 wiros. This precludes the possibility of snow / ice buildup on the i.1round plane plates mth the resultant de-tuning of the antenna, and increues the radiability of the sirens.
The liceqsce plans to codify the entenna on the Rye, !!ew thrcpshire sirens when acrec::ent is rocched with tht: town cn t.1is enharic7.nent to the siren synte.m.
The inspoetor verified that, at the time of this inspectico, 79 of the sirens and grates nad been tr(.ated with "Vellox 140," an af.ii-icing cortpw nd.
The renainder of the sirens era schcduled for receipt of this treatment this simner.
The sirens located in Pyo, Ucw I!snpchiro will be trertvl with this cot. ting ulxn acrwnen:; is reacnad with the soun -( nearnirig thia enhanecment to the s?ren systoa.
Co eletion of this action will be wrified in a subsecuent i nspec t ir.n.
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OCT 01 '87 13:49 NRC MILLSTONE 1 P05
- t 6 i The completion:of the modifications to the antennae in Rye, Now Hampshire, and completion of the application of the anti-icing coating will be verified in a subsequent inspection (50-443/87-22-01).
B.
Merrimac, Mas _sachusetts Sirens-Eectuse of legal: challenge by the town.of Merrimac, one of the sirons called for in the final design report was not installed.
As a result, the licensee was required to perform background / ambient noite readings to verify that the required alerting margin of 10db above cverage daytime. ambient background would be met by the remaining sirens (rather than the 60 db covbrage which is acceptable without l
perfonnance of background measurements)..The inspector observed i
the contractor laboratory technician recording the ambient noise l
1evels at one location during this inspection.
The results of this i
testing will be provided to FEMA for review as part of the aiorting j
sys"em receptability verifi.setion.
I A second issue with the Merrimac sirens involves the fact that the tonn has prey?ntad cosinection of AC power to the sirens.
As the riccns are lattery operated, AC re.ier 15. only used for char:f ng th a '. c Sn t enri ~,.
la (,rd r to asrure operability, tha licen:co had bcnn rep 1;citm the siren t.ctterics every tuo uteks, but hcc t
sux;equently installed solar cell battery chargers to keep the bet:orics et or notr full charge.
Even without the battery chs gers, test reiults reviewed by the inspector demonstrated that bat. cry capr, city w0s sufficicnt (after two weaks of in:ctivity) for i.t cast two corr.plete three minuto activation cycles, which is sufficient to u0et the plan rcquiremcnts for length of activation.
The tddition o'T the !.nlar tric kle char]erc c nnancor that cap;bility.
4.
Exit l'ee(ing i
The insp?ctor met with representatives of the licensee at the conclusion l
of the inspection (sco detail 1 for attendees) to discuss the scope and findings of this inspection as detailed in this report.
At no tir during ths inspecticn was eny written material trovidad to the licensee, i
DOLKETED USNRC UNITED STATES OF AMERICA 87 0:i -7 P12:00 NUCLEAR REGULATORY COMMISSION 4FflCE er SEC W p Y BEFORE THE ATOMIC SAFETY AND LICENSING APPEALBSDARGi& SE7MCE iRANCH j
1 in the Matter of
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Docket Nos. 50-443 OL-01 l
PUBLIC SERVICE COMPANY OF
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50-444 OL-01 NEW HAMPSHIRE, et al.
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On-site Emergency Planning
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and Safety Issues (Seabrcok Station, Units 1 and 2)
)
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l CERTIFICATE OF SERVICE l
l hereby certify that copies of "NRC STAFF RESPONSE TO APPEAL BOARD ORDER OF SEPTEMBER 17, 1987 REGARDING EAST KINGSTON SIRENS" in the above-captioned proceeding have been served on the following by deposit in the United States
- mall, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mall system, this 6th day of October 1987.
Alan S. Rosenthal, 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 General 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 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 Stcphen 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 Angle Machiros, Chairman State Representative Board of Selectmen Town of Hampton Falls 25 High 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.
McMay, Murphy and Graham Backus, Meyer 6 Solomon 100 Main Street 116 Lowell Street Amesbury, MA 01913 Manchester, NH 03106 Diane Curran, Esq.
Philip Ahren, Esq.
Harmon s Weiss Assistant Attorney General 2001 S Street, NW Office of the Attorney General 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 442 J.W. McCormack (POCH) 225 Franklin Street Boston, MA 02109 Boston, MA 02110 H.J. Flynn, Esq.
William Armstrong Assistant General Counsel Civil Defense Director Federal Emergency Management Agency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel
- Board
- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Jane Doughty Docketing and Service Section*
Scacoast Anti-Pollution League Office of the Secretary 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, DC 20555 Maynard L. Young, Chairman William S. Lord Board of Selectmen Board of Selectmen
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- 10 Central Road Town Hall - Friend Street South Hampton, NH 03287 Amesbury, MA 01913 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. Gad lil, 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.
l Holmes & Ellis 47 Winnacunnet Road Hampton, NH 03842 I
1 006 (fow l
l Gregory (t uan yBerry Counsel Yar NRC Staff 1
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