ML20237G704
| ML20237G704 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/09/1987 |
| From: | Cumming W Federal Emergency Management Agency |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL-5-I-FEMA-004, OL-5-I-FEMA-4, NUDOCS 8709020374 | |
| Download: ML20237G704 (18) | |
Text
.30-322.-DL-5 y,
?/WE'I y use.n # 4
_. gcg g-
'Apri? 22, 1987 00pjjif'
'87 E3 25 A9 :27 UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION
[
t BEFORE THE ATCMIC 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 suppitments the December 29, 1986, December O
ser,ved on all parties with the attached Dave McLoughlin to Regional 17 1986, November 2.5, 1986, and November 21, 1986 guidance documents Directors Memorandum dated April 21, 1987, subject: Guidance Memorandum (GM) AN-1, FEMA Action to Quailfy 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, h6U 4.~. k f4 A e #
William R. Cumming Counsel for FEMA Dated this 22nd day of April, 1987 C
Washington, D.C.
8709020374 h h 22 PDR ADOCK ppg O
~
O h
9 7
s
/
E A/D -i \\
s 2
=
v a
a 5
!! =
J E
a O
N a
8
- Ese o cac*
gi
.c 4
E
-. E Q h u
o V)
)8 g 5
J 1-Y v
m C
e 0
af N E du k $g g *s.$
Ig*t h.
~
%., a2lE2 E*
C
=t
<~aa*
f 2 ~.
[
% Federal Emergency Management Agency 5f Washington, D.C. 20472
,w I
APR 21 1987 l
MFlCBMCCM ECR:
Regional Directors Acting Regional Directbr FFCM:
McLoughlin
~
Deputy Associate Director State and Ix: cal Prcgrams and Support SURIECI:
Guidance Memorandum (GM) AN-1, FEMA Action to Qualify.
Alert and Notification Systems Against NUREG-0654/FFFA-REP-1 and FEMA-REP-10.
I Guidance Memorandum AN-1 is provided as an operative GM for your use in
]
implementing alert and notification system components of FEMA's i
l radiological emergency preparedness prcgram and for assisting util.ities I
and State and local governments in developing and evaluating alert and notification system capabilities for ccmercial nuclear power plant accidents.
With the issuance of GM AN-1, GM-18, Revision 1 (FEMA Action l
to Qualify Alert and Notification Systems Against NtTAEG-0654/FFl4A-REP-1, Revision 1, dated October 19, 1983) is terminated.
A current listing
' J of all operative GM's is also attached for your use.
l We are appreciative of the ccrnments provided by the Regions and, through your cooperation, many states.
Please provide copies of this GM and the current listing ~ of operatiive GM's to the states in your Regions.
Your review and certznents on the draft ccpy of GM AN-1 were helpful in developing the final version.
Any questions concerning the imple:rentation of this GM should be directed to either Megs Eepler (FIS 646-2867) er Vern Wirgert (FIS 646-2872).
Attachments As Stated U
_a
r
[$a Federal Emergency Management Agency J
Washington, D.C. 20M2 GUICANCE ME_MOPANECM ;d-1 FEMA ACT!CN "O CUALIFY ALERT AND NcrrIFICACICN SysrStS AGAINST NUREG-0654/FE4A-REP-1 AND FCG-REP-10 PURPOSE This Guidance Memorandum (GM) describes policy and procedures to be followed by the Federal Emergency Management Agency (FEMA) Headquarters and Regional Of fices in assessing and making findings and determinations on the adequacy of alert and notification systems installed around caumercial nuclear power plants.
Planning Standards E, F, and N and Appencix 3 of NURS3-0654/FE4A-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 GM supersedes the currently operative G4-lS, Revision 1, entitled "FE4A Action to Qualify Alert and Notification Systems Against NUREG-0654/FD4A-REP-1, Revision 1" dated October 19, 1983.
BACKGROLND The President of the United States, in a statenent on December 7,1979, assigned JC4A as the lead Federal Agency for coordinating State and local radiological emr-hency planning and preparedness activities arcund caumercial nuclear power plants.
VIhis responsibility included evaluating and approving State and local radiological emergency planning and preparedness for dealing with the consequences of an accident at a camercial nuclear pcwr plant.
Followirg this Presidential directive, FE4A and the Nuclear Pegulatory Ccmission (NRC) jointly prcduced, in November 1980, NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of Radiological Drergency Response Plans and Preparedness in Support of Nuclear Power Plants".
This guidance docunent provides the basis for the development of radiological emer-gency response plans and preparedness by State and local goverrrnents and the NRC licensees for dealing with accidents at conmercial nuclear power plants.
NUPEG-0654/FE4A-REP-1 also provides the basis for the review of radiological emergency response plans and preparedness by Federal agencies.
Appendix 3 of NURH3-0654/FD4A-REP-1 states that NPC licensees are required to install alert and notification systems around camercial nuclear power plants and that activation of these systens is the responsibility of the State and local governments. The licensees were mandated by NRC to have alert and notification systems installed arcund operating comercial nuclear power plants by February 1, 1982 (originally by July 1, 1981).
Any nuclear power plant scheduled < for operatica after February 1,1982, is required to have an alert and' notification system installed prior to connercial operation of the facility.
Through agreement with the NRC, FEMA accepted the lead responsibility for review-ing and approvirg alert and notification systems.
This included confirning that p the syste's are in full ccmpliance wi.h NUPEG-0654/FC4A-SEP-1, FE4A Rule 44 CFR
(
350, and NRC Rule 10 CFR 50, Appendix E.
As part of this lead responsibility, FE4A l
developed the " Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" (FEiA-43) which was issued as interim-use guidance for
. 'atirq alert and notificatica systems.
FD!A-43 presented an elaceration on an apolicaticn of the criteria centained in NUREG-0654/FDM-?2P-1 for pur:oses of reviewirq and approving alert and notification systems.
FStA-43 ms subsequently revised to reflect c:rrents received durirg tne interim.se pericd.
In Sevemcer 1985, final guidance was issued in Fe%-REP-10, -nich superseded FC1A-43.
The guidance centained in this Gi addresses the procedural steos wnich will ce follced by the FD% Regicns and Headquarters in the evaluatien of alert and noti-fication systens leadirq up to approval of the systems.
All technical aspects involved in the review and approval process are contained in FEMA-REP-10.
RESENSIBILITIES The responsibilities for the procedural aspects of evaluating alert and noti-fication system are described belcw:
FEMA Headquarters is responsible for the followino:
Establishing and reviewing policy for making findings aM determinations on the' adequacy of alert and notification systems; In coordination with the Regions, develcping standard formats, content, and acceptance criteria for reviewing the technical aspects of alert and notifi-cation system design submittals frcm State governments and/or NRC licensees; Issuing reccmrcendations and policy concerning the Emergency Broadcast System (EBS), National Oceanic and Atmospheric Mministratien radio systems, etc.,
as they relate to alert and notification systems; Coordinating arrangements with other Federal Agencies, if necessary, to ecmplete the alert and notification system design reviews; Providing assistance in making policy determinations on specific issues and problems when requested by the FD4A Pegions; Ministering centracts for the provision of technical assistance in review-ing and evaluating alert and notification systans; Coordinating the scheduling of ' alert and notification system telephone surveys with the FEMA Pegions and technical assistance contractor; Coordinating contractual arrangements for conducting the telephone surveys and resurveys, if necessary, for each alert and notification system; Coordinating arrangements with the Cffice of Managemnt and Budget (CMB) for clearance to conduct the telephone surveys; Issuing for al findings to the NRC cn the adequacy or inadequacy of alert and notification systems based on FC4A Pagional recanmendations and findirgs; and
I
. Issuing guidance, as necessary, fcr the FSG Regicas to folicw :.n reviewing the routine alert and notification system testing prcgram and Operability (O) followirq :ne initial &ler; and notification system approval.
FEMA Recional Offices are rescensicle for the follcwi g_:,
f Reviewing alere and notification system design submittals as a part of FEG's evaluaticn and apprcval prccess of State and local radiological emergency plans and preparedness in accordance with FD% Rule 44 CFR 330; Making preliminary and final recommendations to FDM Headquarters on approving or disapproving alcr and notification systems pursuant to NUREG-0654/ FEMA-l REP-1 evaluation criteria E.5., E.6. (with technical assistance), F.1., N. l.,
N. 2., N. 3., and N. 5. ;
Confiming that State and local governments have demonstrated the capability to alert and notify the population within the 5-or 10-mile pluma emergency planning zone (EP2) in accordance with the time requirements in 10 CFR 50, Appendix E, Section D.3, NUREG-0654/FD%-REP-1, Appendix 3, and FD %-REP-10; l
Con 51rming that acceptable procedures are established, have been demonstrated if required, and are in full ccmpliance with all FEMA 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 fo) by the transient population; v
Reviewing the routine alert and notification system testing pregram employed by the licensee and/or the State and local governments to maintain and test the systems, so as to 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 FD%-REP-10 has been achieved based on the most recent 12 months of test results before the syr m is approved (the operability of the system will be determined by averaging the results of all regularly rcheduled tests employed as part of the testing prcgram, e.g. silent, growl, full-cycle);
Reviewing alert and notification system testing results annually af ter the initial system approval to confirm that testing has been ecmpleted in accord-ance with approved procedures and that the siren operability remains at er above 90%; and notifying FD% Headquarters if it falls below 90% (this tray be included as part of the pericdic requirements stipulated in GM PR-1);
Assisting in the elert and notification system telephone surveys by ccor-dinatirg all necessary arrangements with State and local officials and by providing a representative at the alert and notification system activatien point (Emergency Cperations Centers, etc.) the day of the survey, if possible fm and if travel funds permit, to act as a liaison to the technical assistance
(
contractor; V
Reviewing and evaluating changes to alert and notification systems as necessary following the initial approval of the system; and l
r
-4_
Mvising FE4A Headquarters of aler; and notification system prcolems after (3 the initial system apcreval and recccanding resurveys if *~arranted.
The Technical Assistance Centractor is rescensible for the folicwinc:
Reviewirg alert and notification system design submit:als pursuant to eval-uation criterion E.6. in E'PSG-0654/Fr m-REP-1 and FC4A-REP-10; Documenting the results of the technical review in preliminary and final reports for use by the FD4A Regions and Headquarters; Providirg technical assistance and advice on problens that may arise in the alert and notification system reviews; l
Conductirg a public telephone survey immdiately followirg activation of the alert and notification system ard statistically analyzing the results for inclusion in a final report en the' adequacy of the system; and Conductirg telephone resurveys if directed.
l State and localgoverntents tre responsible for the follcuing:,
Coordinating with licensees to ensure proper consideration of offsite radio-1cgical emergency response plans and preparedness in the design of alert and b notification systems;
\\
Reviewing, to the extent possible, the alert and notification system designs subnitted by the NRC licensees and providirg 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; Forwardity the licensee's alert and notification system design submittal to the F01A Pagion for review; 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 system af ter it is approved and providing the FD4A Pagional Office with copies of the revisions; 1
Coordinating on and submittirg a report on alert and notification syste.n siren operability and testiry results to the FC4A Regions for review annually if the data is not already provided by the licensee (the data can be sunnitted in conjunction with the G1 PR-1 submission);
Assuring that address registers containirg infor:tation on the distribution of tcne alert radies within the emergency plannirg zone are updated annually and are availacle for inspection:
1
(
)
l
\\d Confirmirg that appropriate testing and maintenance of tone alert radios has been ecmpleted pursuant to the guidance in FC%-REP-10 for these systems con-tainirg tone alert radics; and 1
_3_
[\\ Conductirg resurveys Of alert and notification systems af ter de initial sys-t tem accreval, if de resur/ey cannot ce conducted bv FE G but is determined b jointEy by FE% Meadquar^ers and de FEG Region tite necessary to certify the conttnued adequacy of de system. This is more likely to apply to systems witn a significant tone alert radio tcmponent; however,.he reascns for the resurvey will be cutlined for State and local officials, the licensee, and tne NRC snd sufficient time will be alicwed in wnich to conduct it if cther satisfac: cry arrangements to c0rrect the proclem cannot be made.
NFC licensees are responsible for the_ follcwing:_
Preparing alert and notification system design reports in accordance with the guidance in FEMA-REP-10 and in NUREG-0654/FEIA-REP-1, Appendix 3, and coordi-nating the design with State officials (and local government officials if necessary); and submitting the designs to the appropriate State goverment for review; l
l Depending on established precedures, submitting alert and notification system operability and testing records either directly to the State government or to I
the FCG Regions for review annually; and Assisting in alert and notification system telephone surveys and resurveys, as necessary, and prangtly correcting systen problems.
m is responsible for the followina:
I Reviewing and approving alert and notification system designs prior to l
installation of the systems by the licensees; and l
l Reviewing FEMA findings on the adequacy or inadequacy of alert and notifi-1 l
cation systems and following up with appropriate actions to ensure that l
prcmpt corrective actions are taken when needed.
PFCCEEURAL ASPECTS OF ALERT AND NOTIFICATION SYSTEM REVIEWS
)
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 goverrment officials will be expected to incorporate appropriate sections of the offsite radic-Icgical emergency response plans into the alert and notification system design sub-mittal.
Following the review by State and local officials, the designs will be submitted to the FEG Region, and the Region will in turn submit a copy of the j
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., 5.6., F.1.,
]
N. l., N. 2., N. 3., and N.5. as addressed in the State and local radiological emergency response plans instead of having these portions of the plans rewritten
)
st for the alert and notification system design rerort.
/
\\
'1he FCG Regional review of the alert and notification system design and of the technical assistance contractor's preliminary draf t report on the alert and notification system design should consist of the following:
i l
F l l l
'? A verification or reverification of.ne adecuacy Of evaluaticn criteria I.5.,
i l
V E.6.(administrative aspects and if possible, Onysical aspects),
F.1.,
l N. 2., N. 3., and N. 5. as decurented in -J.e mcst recent interim findin;, exer-cise report, or 44 CFR 350 approval;
- A review of and coments on the technical assistance centractor's preliminary draft report especially as it relates to evaluation criterien E.6.(physical aspects) and a review of the routine system testing procedures and operability;
- A confirmation of ccmpliance of the State and local goverments with the time j
I requirements in lu CFR Part 50, Appendix E, Section D.3, NUREG-0654/FD1A-REP-1, Appendix 3, and FDR-REP-10 (See Attachment I to this GM for acre details);
- A review of botn institutional alertirq procedures and special alerting pro-
)
cedures utilized for the transient population to determine the adequacy of these procedures.
Following their preliminary review, the Begional Office should provide a preliminary finding of adequacy or inadequacy to FEMA Headquarters.
If the system is found to have adequate alerting coverage, a date for the telephone survey will be established by FDiA Headquarters that is agreeable to the Regional Office, State and local governments, technical assistance contractor, and the NRC licensee.
If the system l
is found to have inadequate alertirq coverage or other problems, the State and/or utility will be notified thrcugh the FD1A Regional Office that further documentation i
support the alert and notification system design is required.
A more detailed q,,lew of the alert and notification system design by the Fegional Of fice may be I
required if significant time has elapsed since the last Regional interim finding, 44 CFR' 350 review, or exercise was ccmpleted in which the alert and notification,
systen related plan ele tents wre reviewed.
1 As part of the review process, the technical assistance contractor will conduct a telephone survey of pen anent residents in the 10-mile EP2 after activation of the i
alert and notification system.
Households will be polled to ascertain whether or not they wre alerted during the activation of the system.
Such a telechone sur-voy will be performed only once to approve the alert and notification system unless i
the results are unacceptable during the initial survey.
The telephone survey can be conducted following activation of the alert and notification systen either during routine testing, as part of a scheduled exercise, or as a separate activation.
The technical assistance contractor will prepare a final draf t report en the alert j
and notification system following the telephone survey.
This final draft report will dccument the results of the survey alceg with the results of the earlier tech-nical review of the system design. The FEMA Regions will review this final draf t l
report, address the acceptability of the rcutine siren testirq procedures and ocer-ability with respect to established standards, address any remainirg issues.not covered in their preliminary finding, as discussed above, and rake a final reccm-mendation en approving er disapprovirq the system.
The Regicnal finding may include I
"ccmnendatiens for system modifications or enhancements.
EEMA Headquarters will l
incorporate all acocopriate Regional ecamendatiens into a final recor and issue l
findicg to the NRC cn the adequac/ or inadequacy of the alert and notification l
3 tem.
It is important to note that findings on alert and notification systems s'eIrloying sirens cannot be issued without documentation that the reutine siren testing procedures are adequate and that the operability standard of 90% in FmA-i REP-10 has been achieved based on 12 acnths of current testing reenrds.
l l
l E
_7-vte and local gover: rent emergency planning and preparedness can te approved oy FD % pursuant to 44 CFR 350 without approval of the alert and notification In.heso cases, FDR will issue a conditional 44 CFR 350 approval cave-system.
ated on ene ultimate apcroval of the alert and not:.fication system.
The caveat in tne 44 CFR 350 apcroval will be removed 'once the alert and notification system is approved.
Hvwever, 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 systs approval may be granted simultaneously with the 44 CFR 350 approval.
An, alert and notification system is suoject to a.: engineering analysis against NUREG-0654/ FEM-REP-1, and FDR-?SP-10 by this procedure only once, unless a significant change, as specified in 44 CFR 350.14, is made to the system.
The FFNA Regional Of fices will be responsible for advising' FEMA Headquarters of significant changes to alert and notification systems or of significant charges in the EP2 that might I
impact the alert and notification systen af ter the initial approval. The Regions l
will also be responsible for assisting in re-reviews that may beccme necessary.
1 If necessary, technical assistance may be provided and a telephone resurvey I
conducted if such re-reviews are undertaken.
1 Following the initial, qualifyirg telephone survey and approval of an alert and l
i I
notification system, FEMA will not conduct nor require that additional telephone f
surveys be conducted to assess the continued capabilities of the systen unless one or more of the following conditions is encountered that would warrant such surveys:
i (0
l
- /
A significant charge occurs in the demographics or in the configuration of the EP2 around the nuclear power plant; A significant modification is made to the physical etmponents of the alert and notification system that actually or potentially decreases the effectiveness of the system; 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 adequacy of the system; Should any of these conditions be encountered, it will be incumbent upon the Regional Office to notify FD% Headqui eters and reccmmend revisions and/or corrective actions which could include a telephone resurvey conducted either by FC4A or the State.
If FEMA conducts the resurvey, FDR Headquarters will coordinate all appropriate 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 deir systems, especially those with significant tone alert radio ecmponents.
Following the initial approval of an alert and notification system, the FC%
Regions will be responsible for routinely receivirg the results of alert and l
notification system tests and will be excected to review the results and recor:
l f$them to FDR Headquarters anrlaally. The'results should be submitted as par' of ythe 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 confim that routine testing, includirg testing of special alerting ccmpenents, is being conducted at the proper frequency and in accordance with those procedures
_a-t%
Q l viewed and appreved by FDtA.
~he cperacility results ray be submitted to the wt% ?agion by ei-her the State and local governments er the licersee.
For aler; and nctificatien systems corsisting of tone alert radics, the FEG Regiers shculd receive conficatien frcm State and local officials and/cr 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 infocation can be provided in conjunction with the GM PR-1 submission.
Attachment I to this guidance memorandum contains an explanation of the tire require:mnts for alert and notification systems cutlined in NUREG-0654/FDtA-?IP-1, Appendix 3, FFl%-REP-10, and 10 CFR 50, Appendix E.
Attachment Il contains an approximate time line for reviewing alert and notification system desigra as outlined in the precedures above.
Nuclear Reculatory Ccmission Coordination l
l l
This Guidance Memorandum was coordinated with the Nuclear Pagulatory Ccmission staff.
Attachments As Stated
)
G l
v) t
7 AITACWENT I: AI.ZRT AND SCTr!FICATICN TI."I FICUIRE"lSTS
- JRFCSE
)
7he purpose of this attachment is twofold:
- To ela'corate ucen the accepted Fr% inter:retation and application of alert and notification system design cbjectives outlined in 10 CFR 50, Appendix E, NUPEG-0654/FDG-?IP-1, Appendix 3, and fem-REP-10 that relate to alert and notification system activatien and timinc; and
- To provide guidance and' suggestions for evaluating and confirming com-i pliance with these design objectives during offsite radiological emer-gency preparedness exercises; The provision of timely and appropriate alerting and noti'fication cculd be one of the nest critical aspects of protectirg the public in the event of an acci-
~
dent at a nuclear power plant.
Ensurirg 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 l
Each alert and notification system must have the capability to rapidly alert
%the public and advise them of protective action recommendations.
The actual hesign cbjectives against which these systes must be designed are outlined
~
in the Nuclear Regulatory Ccmmission (NRC) Rule 10 CFR 50, Appendix E, NUREG-0654/FDM-REP-1, Appendix 3, and FEMA-REP-10. As stated in NUREG-0654/ FEMA-REP-1, Appendix 3, and in FDG-REP-10 the minimun acceptable design objectives for coverage by an alert and notification system are:
" a) Capability for providing teth an aleet signal and an informational or instructional ressage to the pcpulation on an area wide basis throughout the 10 mile EP2, within 15 mirutes.
b) The initial notification system wi11 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 l
45 minutes of the population wbc may not have received the initial l
notification within the entire plume exposure EP2.
)
i The basis for any special requirements exceptions (e.g., for. extended l
l water areas with transient boats or remote hiking trails) must be j
documented. "
i The NRC rule 10 CFR 5d Acpendix E, Section FI. D.3. requires that licensees "shall demonstrate that the State /lecal officiah have the capacility to make a puolic notification decision pr motly on ceirq infor.ed by the licensee of an emergency condition." The rule further states that "the design objectiva of the prcmpt public notification system shall be to have the capability to essentially ccmplete the initial notification of the public within the plume exposure pathway EP2 witnin about 15 minutes.
The use of this notification
]
I I-2
$cability will rance frcm imediate notification of de public (wi$in 15,inutes bd de tibe that State and local officials are notified dat a si=ation exists requiring urgent actien) to de more likely event where &ere is substantial time available for the State and local governmental officials to rake a judg.ent whether ce not to activate the public necification system.*
I A very important aspect of the formal FEMA process for reviewing and approving aler-and notification systems is confirming that the design objectives and requirements outlined above have been met.
In confirming alert and notification system capa-bility, FE4A must ' 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 imediate protective acticns are required.
NRC Rule 10 CFR 50, Apperdix E requires that licensees have the capa-bility to notify responsible offsite officials within 15 minutes af ter declaring an emergency.
Similarly offsite, in extreme situations with no decision-making time available, the capability cust exist to activate the system and brcadcast an instruc-tional cassage 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 pcpulation. hhile FEMA and NRC require that this 15 minute capability exist, it is reccgnized that not all emergency conditions will necessitate offsite notification within as short a time as 15 minutes.
The "15-minute capability" is confirmed through the c'eservation of actual demon-1
- strations or simulations of this capability during offsite radiological emergency pre-i paredness exercises. Actual demonstrations are enceuraged.
Curing these exercises, exercise evaluators actually time the alert and notification process to confim that the administrative procedures ard mechanical ccmponents of the system are in place and satisfy FEMA and NRC requirements.
IhTERPRETATICNS FEMA's interpretation of the design objectives outlined in NUREG-0654/ FEMA-PEP-1, Appendix 3 and of the requirements in 10 CFR 50, Appendix E are based on gecgraphic location within the emergency planning zone.
The 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 (ESS) or other systems.
The design cb-jectives will be applied by FE4A in alert and notification system reviews as follcws:
- 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 lccated within 5 miles of the facility.
This includes alerting and noti-fying the transient pcpulation in remote rural areas, cpen water areas, rivers, hunting areas, recreational areas, private ccmpounds, beaches, national forests, and other 1cw population areas which may require special alerting procedures.
- Within 5 to 10 Miles of the Site i
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.
Ecwever, in extrenely rural, icw pcpulation areas beyond 5
I-3 miles, up to 45 minutes may be allcwed for prcviding an aler signal and an instructional message to the pecanent and transient pcpulatien.
Examcles c:,
such areas include rural facs, hunting areas, recreational areas, open water
. areas, national ferests, beaches, and rivers.
2.e aler and notificacicn l
system design submittal shculd centain the rationale for recuiring up tc 45 l
minutes to alert such areas as well as the other documentation required in FEMA-FIP-10. Areas prepcsed in the alert and notification system design sub-mission for alerting within 45 mindtes will be reviewed on a case-by-case basis.
- All Areas Within the Emergency Planninc 2cr.e In all situations the time frames for activating the alert and notification system are measured frcm the point at which the designated official, er 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 folicwing chart illustrates the key steps in the alert and notification process:
TIMING CHART Alert Signal Authorized Public Activated and Official Reaches Instructional Licensee Cecision Which Re-Message Issued Emergency Notifies quires Activating via Emergency Declaration Public the Alert and Noti-Broaccast or by a Utility Officials fication System Other Systems 15 Minutes Varies 15(or 45) Minutes Cecision-makirs Time for Public Officials Varies Frcm Virtually No Time Available In A Fast-Breaking Accident To Substantial Time In A Slowly Evolving Accident CCNFIEMATICN CF CAPABILITIES CURING FECISES 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.
Eelcw are suggestions and considerations regarding evaluating this capability before, during, and folicwing exercises:
a r_4 1
i Dre-Exercise Accivities I
Before exercise activity begins, the Regions should confirm or be aware of l
the follcwing aspects:
- That for the offsite jurisdictions with alert and notification responsi-bilities, all administrative procedures for ccmpleting the entire process are clearly coordinated and dccumented in the plans.
.);)
- !l
- That the plans clearly state that the alert and notification process 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 recommendations and authorize activation of the system (this official might be the Governorr o
a County Administrator, a County Judge, or other similar officials).
The l
15 or 45 minu.tes begins with this official's authorization to activate the i
system.
- That the plans clearly indicate the planned alert and notification activi-ties related to each emergency classification level outlined in 'the plan.
i l
- Which emergency classification level will be used to verify the alert and notification system capabilities. It is acceptable to verify the l
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 5V activation chosen for verification.
- Nhich 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 ccmpleting i
them, if any are proposed.
percise Activities l
Dur'ing exercises, the Regions should be cognizant of the following:
- Startina the Clock In confirming that the alert and notification system time requirements are satisfied, the evaluator should begin the timing fran 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.
- Mcnitorina Each Stec l
Every step of the alerting process should be monitored starting with the decision to activate the system thrcugh the actual or simulated broad-
I-5
~[
cast of the protective action reccamendation to cenfi= that precer pro-V cedures are being followed.
During exercises, decision-making cime shculd be available to offsite Offic-ials. Ecwever, it will be incumbent upcn che exercise evaluators to decer-mine if the time required by offsite officials to make proteceive accion reccrrendations 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 recommendations.
Similarly, during an exercise,~ the scenario and exercise play will give an indication of what reasonable de-cision-making time is and when a lack of action should result in a required corrective action citation er deficiency.
Decisien-making time could range frcm absolutely zero in a serious, fastbreaking accident, to the dere 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.
- Primarv 3 cute Alertina If route alerting is a primary means of providing the alert signal, the' Region c.in assign evaluators to accompany the individuals perfoming 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-1 y
lined in FEMA-REP-10' (e.g., mobilization of personnel, transit time to the beginning of the route).
If multiple routes are involved and sufficient 3
evaluators are not available for evaluating every route, a sampling of the rcutes may be chosen for evaluation, possibly focusing on the most difficult routes or the more populated routes.
- p ckue Fcute Alertirc If backuo route alert and notification system procedures are denenstrated during exercises, evaluators should be aware of the time required for off-site authorities to cceplete the entire backuo route alerting process.
These systems are designed to be put into effect only when primary systems, especially sirens, fail. There is no hard and fast time requirement for j
comleting the backup route alerting process; however, 45 minutes is a suggested objective for completing the process.
- Simulatien It is acceptable to simulate the activation of alert and notification systems during exercises.
Ecwever, even though the system activation is being simu-lated, the 15-minute capability can still be confi =ed.
It is important that all jurisdictions participating in the notification process are cperating off the same simulated alert activation time. Pcute alerting times shculd be cen-fi=ed thrcugn accual ctservaticn.
Even thcugh the nccification process is being simulated, the cb. server should see the preparation of the instructional U/
message, coordination with participating jurisdictions, communication with the brcadcast station and ccmpletion of the authentication precess.
i i m___
e I-6 I
/nT f
D )est-Exercise Accivities l
i In prepari.q the pcs:-exercise report, the."1 cwi.c items shculd be addressed:
A clear statement of whether or not the exercise objectives associated with the alert and notification system were achieved.
4 A chart or scme other meched of indicating the exact times of the various steps in the alert and notification process that will make it clear if l
the time require: rents have been achieved.
Failure by offsite authorities to ecmplete the crimarv alert and notifi-cation process within the time frames stipulated in NUREG-0654/FF#A-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 i
radios, route alerting) employed.
Failure to cmplete backuo route alerting in accordance w th the time J
frames established by the respondirg organi'zations should be cited as an
" area rec:rmended for improvement".
's o
\\
l U
l
)
\\
/
VAttactrent II selow is an approxi ace time line representing each of the major steps leading up to and following an aler and notification systen dem:nstration.
~his :iT.e line is approximate and for planning purposes only.
the to changes in priorities, i
l it may te' modified oy FC% Headquar ers as needed on a site-specific basis.
\\,
FRE-SURVEY
)
l
-16 Weeks FEMA Headquarters receives a ccpy of the licensee's j
design submission through the FD% Regional Office with I
a copy remaining in the Regico for review.
{
l I
-15 Weeks FEMA Headquarters provides the licensee's design submittal to the technical assistance contractor for review.
-12 Weeks FENA Headquarters and Region jointly agree on a preliminary date for the alert and notification demonstration and survey.
l
-9 Weeks FEMA Headquarters receives the preliminary report on the design fran the technical assistance contractor.
-8 Weeks FEMA Headquarters submits the preliminary report to the
[%O}
l Regional Office for review.
l
-4 Weeks Regional Office completes a review of the preliminary report fro" the technical assistance contraetor and, ir.:1uding their own review, makes a preliminary finding of adequacy or inadequacy to FD4A Headquarters.
If the design submission is fourd to be adequate, the Region congletes final scheduling for the alert and notification demonstration.
At this point I
the technical assistance contractor initiates ef forts with the subcontractor to prepare for the telephone survey.
l KST-SURVEY l
l
+8 Weeks Technical assistance contractor provides final report on the alert and notification demonstration to FER Headquarters.
+10 Weeks FEMA Headquarters transmits report to the Regional Director for final review ard evaluaton.
+14 Weeks Fegional Director submits final recommendations on the alert and notification demonstration to FC% Headquarters.
l l
-16 Weeks TEMA Headquarters issues final findings and certification to I
NRC.
If a site has a conditional 350 approval, caveat is lif ted n
(
and tne Governor is notified of approval.
U l
e