ML20236P865
| ML20236P865 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/13/1987 |
| From: | Fierce A MASSACHUSETTS, COMMONWEALTH OF |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20236P840 | List: |
| References | |
| OL-1, NUDOCS 8711190041 | |
| Download: ML20236P865 (7) | |
Text
-
t l
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BOARD l
Before Administrative Judges I
Alan S. Rosenthal, Chairman Howard A. Wilber
)
In the matter of
)
Docket Nos.
)
50-443-OL-1 PUBLIC SERVICE COMPANY OF
)
50-444-OL-1 i
NEW HAMPSHIRE, et al.
)
(On-Site EP)
(Seabrook Station, Units 1 and 2)
)
November 13, 1987
)
ATTORNEY GENERAL JAMES M.
SHANNON'S REPLY TO APPLICANTS' OCTOBER 30, 1987 SUPPLEMENTAL MEMORANDUM IN RESPONSE TO APPEAL BOARD ORDER OF OCTOBER 13, 1987 Attorney General James M. Shannon hereby submits his reply to the Applicants' October 30, 1987 Supplemental Memorandum in respo'#e to th?s Appeal Board's order of October 13, 1987.
I.
Applicants' Supplemental Memorandum On October 13, 1987, this Appeal Board requested that the Applicants file a supplemental memorandum to, inter alia, inform the Board, if the information was available, of the sound pressure levels at the locations in Merrimac where Cavanaugh Tocci Associates conducted its measurements.
8711190041 871113 DR ADOCK 05000 3
y t'
With their~ response, datedLoctober130, 1987, the Applicants Dhave' submitted the' Affidavit of Louis C. Sutherland of Wyle Laboratories.
Mr. Sutherland states that he has utilized a-computer /model,to predict'the' expected siren 1 sound levels at these' locations in Merrimac, and he sets forth his predictions.
II..
Attorney' General's'Reoly A.
The Sutherland Affidavit proves ~that for at.least one location in Merrimac the'"10 dBC above background" standard'is not met.
In' paragraph 5 of his Affidavit, Louis Sutherland states'that, based on calculations.by Wyle's computer.model for
' predicting siren sound propagation, the predicted siren sound level in the vicinity.of 23 South Pleasant Street is 53 dBC.
This, if true, means that for the "10dBC above. background" standard to be met the average daytime ambient-sound level at 23 South Pleasant Street should not exceed 43 dBC.
However, as 11s set forth in the attached Affidavit of Gregory C. Tocci dated November 12, 1987, at paragraph 4, the ambient sound level study conducted by Cavanaugh Tocci Associates found the ambient sound level at that location to exceed 43 dBC for most of the daytime hours.1!
Therefore, it must be concluded that
)
1/
This study, as we have previously argued in our last two submissions to the Appeal Board on this topic, was far more i
comprehensive than the study of background noise conducted by
-Wyle Laboratories for the Applicants in August.
Applicants' i
study was-done by taking measurements on only one day for only l
15 minutes at each site and, therefore, provides no basis for calculating " average daytime" ambient sound levels.
As is stated in the Affidavit of Gregory C. Tocci dated October 2, 1987, at p.
5: "[tihis brief sampling period does not account for the usual variation of ambient sound through the course of t
a day.
Moreover, a single 15 minute sample on one day does not exhibit day-to-day (or] weekday-to-weekend.
Variations in y
ambient sound level.",
e
}
.. ~
A; for:at leastithis-one" populated locationLin Merrimac, the Applicants' alert and. notification siren-system fails-to meet-h the applicable "10'dBC above background" standard.
If the Attorney-General's' late-filed contention were:
currently admitted, he would now move-for partial, summary-disposition as'to this' location.
B.
The'Sutherland' Affidavit raises. questions about.Wyle's computer modeling input data, sound propagation
- assumptions, and estimation techniques that necessitate-1 further investigation through formal' discovery.
The Sutherland Affidavit is based upon the use of.a.
4 1
computer model which calculated predicted' siren sound' pressure levels at four sites in Merrimac.
'As with any computer modL1, t
the validity of its outputs cannot be evaluated at all withoutL
{
- scrutinizing the assumptions upon which it is based, its imput i
data, and its estimation techniques.
At the present time, to the Attorney General and the NRC alike, this model is an unexamined " black box."
As is further set forth in the attached Affidavit of-Gregory C. Tocci, there are reasons to question the siren sound levels generated by Wyle's computer model at these sites in Merrimac. -According to the computer, the siren sound level in the vicinity of 16 High Street is 8 dB higher than the siren sound level at 21 South Pleasant Street, which is located only a few hundred yards away.
According to Gregory Tocci, this
- i
=_ _ _ _ _ _ - _ _ - - _ -.
l T
difference of 8 dB in expected siren sound levels at two locations in such close proximity appears to be unusually high and bears further explanation.
In addition,.the 61 dBC reading in the vicinity of 16 High Street bears further scrutiny for another reason.
This is a location which according to HMM Associates, the Applicants' previous siren consultant and the author of the Final Decign Report for Seabrooks sirens, was said to receive siren sound levels less than 60 dBC.
See letter from David Keast of HMM Associates to James MacDonald of New Hampshire Yankee, dated January 20, 1987, attached hereto as "B".
Thus, there is an.
apparent discrepancy between Wyle's computer calculations and HMM's calculation of siren sound levels at this location.
Because of these questions about the numbers generated by this computer model, and because this model is currently a
" black box" about which nothing is known, the' Attorney General is submitting herewith his motion asking that he be allowed to conduct formal discovery with respect to Wyle's computer model, its assumptions, inputs, and techniques.
Clearly, the Appeal Board is exploring the Merrimac siren issue fully and on the merits.
If this matter had been handled in the normal course by a licensing board, the Attorney General would, unless limited by order of the presiding officer, have been entitled to conduct discovery.
10 C.F.R.
S 2.740.
We anticipate that we would first seek to obtain information about the model by - _ - _
sc vix waylof_ interrogatories ~and.a' request for the! production.of supportingfdocumentation.
.After. reviewing the information)
. produced) weJwould assessithe need to conduct Mr.LSutherland's-depositionLand/or obtainLa copylof~the computer software fo'r L
mo're detailed scrutiny.
The information about siren sound levels in the Sutherland.
~
i>
~ Affidavitis'not.' complete.enough to meet the.' requirements'a<
design report must meet to comply _with FEMA-REP-10.
On page E-7, FEMA-REP-10. states:
.The design report.should.also include. maps depicting siren sound contours'for C-weighted-sound pressure levels
.., a description of' how the sound pressure level contours were calculated, and any assumptions used including those.from NUREG-0654/ FEMA-REP-1, Revision.l.
All the Attorney General seeks now is that information,about sound pressure level calculations in Merrimac which would have been required in'a final siren design' report.
Respectfully submitted, JAMES M.
SHANNON ATTORNEY GENERAL By:
Allan R. Fierce' Assistant Attorneys General Nuclear Safety Unit Department of the Attorney General One Ashburton Place, Room 1902 Boston, MA 02108 (617) 727-2220 Dated:
November 13, 1987 I
i
{
r m
hm 1
m W Agernas h Reasseenwootte 01742
' etM 3F1 tem e
1 1
HWN Ref..No. 979/3378f January 20, 1987 Mr. James A. MacDonald Nee Hampshire Yankee Seabrook Station P.O. Box 300 Seabrook, New Hampshire 03874 RE:
Background Noise Measurements in Merrimac, Massachusetts Oear Mr. MacDonald:
As indicated in our letter to you of July 7, 1984, most of.the
-town of Merrimac Massachusetts is covered by a siren design sound level of 66 d8C or more from the existing two sirens in that town or from sirens in adjacent communities.
A siren design coverage of 40 dBC or more is considered acceptable for l
lightly-populated areas such as Merrimac under Section C, 3. e
{
of Appendix 3 of NUREG-0454/ FEMA REP-1, Revision 1.
There are, however, five small areas in Merrimac where the siren design sound level coverage is betecen 50 and 40 dec.
Teo of these areas are unpopulated and appear inaccessible by road.
The other three areas contain residences.
These are along a portion of Bear Hill Road part of Merrimaccort, and in Merrimac Terrace.
On January 19, 1987,HMNconductedbackgroundnoise measurements in these populated areas.
1 The background noise measurements sere conducted in accordance with Section C, 3, f of Appendix 3 of MUREG-0454 and with FEMA REP-10/ FEMA-43.
Data were observed continuously for a period of 30 minutes at each location in the standard 1000 Hz octave band and were subjuct to a statistical analysis.
The L90 levels (i.e., the levels exceeded 90 percent of the time during the measurement period at each location) are reported belos:
Location L90 Bear Hill Road 26 de Merrimacport 40 de Merrimac Terrace (no.)
34 de Merrimac Terrace (so.)
34 dB e
A e
1
j
~
.g.
These measured levels are all 40 de or less.
Hence, a siren design sound level of 50 dSC or more provides adequate coverage in these areas, in accordance with Section C, 3,-f of Appendix 3 of NUREG-0654/ FEMA REP-1.
~
f 1
Yours trulyg
- l s
yDavidN.Kaast v
~
DNK/jf
~ ~
~ ~ '
-