ML20138D197

Testimony of Tf Carter Re Eddleman Contention 57-C-3 Concerning Nighttime Emergency Siren Sys at Facility.Related Correspondence

ML20138D197
Person / Time
Site:	Harris
Issue date:	10/18/1985
From:	Ted Carter INTERNATIONAL ENERGY ASSOCIATES, LTD.
To:
Shared Package
ML20138D190	List: ML20138D187 ML20138D197 ML20138D220 ML20138D256 ML20138D262 ML20138D276
References
OL, NUDOCS 8510230211
Download: ML20138D197 (17)

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9, UNITED STATES OF AMERICA q NUCLEAR REGULATORY COMMISSION oY h-90T g- n ,

BEFORE THE ATOMIC SAFETY AND LICENSING B0A hepyf[6 ff y, 56, y A g In the Matter of ) . .,x CAROLINA POWER AND LIGHT COMPANY AND )

NORTH CAROLINA EASTERN MUNICIPAL ) Docket Nos. 50-400 OL POWER AGENCY 50-401 OL (Shearon Harris Nuclear Power Plant, Units 1 and 2) )

TESTIMONY OF THOMAS F. CARTER REGARDING EDDLEMAN CONTENTION 57-C-3 Q.1. Mr. Carter, where do you live?

A.I. 'I reside at 10529 Brevity Drive, Great Falls, Virginia, 22066.

Q.2. What degree do you hold?

A.2. I have a Bachelor of Science Degree .(1961) in Civil Engineering from Mississippi State University, Starkville, Mississippi.

Q.3. What position do you hold?

A.3. I am Vice. President, Consulting Services Group, International Energy Associates Limited.

Q.4. What is the purpose of this panel's testimony?

A.4. The purpose of this testimony is to address Eddleman Contention 57-C-3 which states:

"The plan does not have provisions for notification at night, e.g. in the hours between I am and 6 am when  !

most people living near the plant would normally be h02gOD DR T

asleep. Nor does the plan assure that they would be timely awakened to take sheltering action, as e.g. on a summer night when many might have windows open or air conditioners on. The plan should provide auto-matic phone-dialing equipment to transmit an emergency message to all households in the EPZ for Harris, asking people to alert their phoneless neighbors."

Q.5. What experience do you possess that is relevant to the contention before this Board?

A.S. From 1975 to 1982 I held a series of management positions with the Nuclear Regulatory Commission: Chief, Contingency Planning Branch; Deputy Director, Division of Safeguards; Deputy Director, Division of Fuel Cycle and Material Safety. In this last position I had the responsibility for formulating the emergency planning policy for all fuel cycle facilities. I also was Chairman of NRC's "Three Mile Island" Task Force on Emergency Planning.

Under subcontract to Argonne National Laboratory, I was the principal author of FEMA-43, " Standard Guide For The Evaluation Of Alert And Notification Systems For Nuclear. Power Plants". I am

currently Manager of IEAL's project to support FEMA in the evalua-tion of alert and notification systems at nuclear power plants.

Q.6. What work have you been asked to do in connection with Eddleman Contention 57-C-3?

A.6. I have been asked, under FEPA contract, to convene a panel-of experts to prepare testimony in response to the Eddleman contention I

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3-57-C-3. I have engaged the professional services of Dr. Van Lee, Dr. Karl Kryter, and Dr. Jiri Nehnevajsa for this purpose.

Q.7. How did you prepare and task this panel of experts?

A.7. I provided copies of the following documents to the panel:

1. Eddleman Contention 57-C-3

2. Affidavit of Thomas I. Hawkins on Eddleman 57-C-3, November 26, 1984.

3. Affidavit of M. Reada Bassiouni on Eddleman 57-C-3, October 26, 1984

4. Affidavit of H. Doug Hoell on Eddleman 57-C-3, December 6,1984.

5. Affidavit of Jesse T. Pugh, III on Eddleman 57-C-3, November 2, j 1984.

, 6. Affidavit of Dennis S. Mileti on Eddleman 57-C-3, November 2,1984.

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7. Applicants' Motion for Summary Disposition of Eddleman 57-C-3, 3

November 2,-1984.

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, 8. Applicants' Statement of Material Facts as to which there is No l

Genuine Issue to be Heard on Eddleman 57-C-3, November 2, 1984. ,

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9. FEMA Staff Response to Applicants' Motion for Summary Disposition of Eddleman Contention 57-C-3, December 6, 1984.

10. Wells Eddleman's Response to Summary Disposition Motions on Contention 57-C-3 (Alerting / Notification during Normal Sleeping Hours lam-6am), December 21, 1984.

11. Memorandum and Order (Ruling on Eleven Summary Disposition Motions), February 27, 1985.

12. Transcript of the hearing in the Matter of: Duke Power Company, et al.: (Catawba Nuclear Station, Units 1 and 2), Docket Nos.

50-413 OL, 50-414 OL, May 11, 1984.

13. " Outdoor Warning Systems Guide," CPG 1-17, Federal Emergency Management Agency, March 1980.

14. " Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants," FEMA-43, Federal Emergency Management Agency, September 1983. ,

15. " Procedures for Analyzing the Effectiveness of Siren Systems i for Alerting the Public," NUREG/CR-2654, PNL-4227, U.S. Nuclear Regulatory Commission, September 1982. i i

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16. " Evaluation of the Prompt Alerting Systems at Four Nuclear Power Stations," NUREG/CR-2655, PNL-4226,.U.S. Nuclear Regulatory Commission, September 1982.

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17. " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654/ FEMA-REP-1, Pevision 1, Nuclear Regulatory Commission and Federal Emergency Management Agency, November 1980.

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18. "Shearon Harris Nuclear Power Plant Site-Specific Offsite Radiological Emergency Preparedness Alert and Notification System Quality Assurance Verification," International Energy Associates Limited, June 12, 1985.

19. "Shearon Harris Power Plant, Census Population Details--American Profile," Donnelley Marketing Information Services, June 26, 1985.

Dr. Lee was asked to predict the acoustical performance of the Shearon Harris siren system. Dr. Kryter was asked'to address the arousal of people from sleep in response to the operation of the siren system. Dr. Nehnevajsa was asked to address some of the key issues which arise in the context of behavioral implications of possible nighttime emergencies at the Shearon Harris Nuclear Power

Plant. Working sessions were held with all panel experts to discuss

the background material and their individual responsibilities in the context of the other experts' responsibilities.

Q.8. Mr. Carter, what does your testimony address?

A.8. My testimony summarizes: 1) the NRC and FEMA requirements and guidance for EPZ siren systems; 2) IEAL's review of the Shearon Harris siren system under our FEMA contract; and 3) the conclusions

, reached by this panel of experts regarding the Eddleman contention 57-C-3.

Q.9. How would you summarize the NRC and FEMA requirements for nuclear power plant siren systems?

A.9. 10 CFR 9 50.47(b)(5) and 44 CFR Part 350 require that "means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established." 10 CFR Part 50 Appendix E 9 D.3 requires in addition that "The design objective of the prompt public notiff-cation 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. The use of this notification capability will range from immediate notification of the public (within 15 minutes of the time that State and local

! officials are notified that a situation exists requiring urgent action) to the more likely events where there is substantial time available for the State and local governmental officials to make a judgment whether or not to activate the public notification system."

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The FEMA and NRC staff use the criteria in NUREG-0654/ FEMA-REP-1 Rev. 1, " Criteria for Preparation and Evaluation of Radiological Emergency. Response Plans and Preparedness in Support of Nuclear Power Plants" and FEMA-43 " Standard Guide For The Evaluation of Alert Notification Systems For Nuclear Power Plants" to detennine whether a prompt public notification system meets these requirements.

Both NUREG-0654/ FEMA-REP-1, Rev. I and FEMA-43 were subject to public comment.

Specifically Appendix 3, Section C.3 of NUREG-0654/ FEMA-REP-1 addresses siren systems. Basically it presents, as an acceptance criterion, that the target level for the design of an adequate siren system should be 10dB above average daytime ambient back-ground levels. It is further stated that the 10dB dissonant differential is a conservative use of the 9dB differential which is {

presented in FEMA document CPG-1-17, " Outdoor Warning Systems Guide",

and that the 10dB differential is meant to provide a distinguishable signal inside of average residential construction under average conditions. Appendix 3 then states that for areas with population densities below 2,000 persons per square mile the siren system must be designed to produce a minimum of 60 dBC or, alternatively,10dB above a measured average daytime ambient background noise level.

Among other things, FEMA-43 organizes the criteria of NUREG-0654/

FEMA-REP-1 into a format that'can be used by utilities to document their siren system installations. FEMA-43 states that whereever proposed as part of an alert system, a siren system design shall be

k documented in a design report. Maps must be included that delineate:

t (1) areas where the population exceeds 2,000 persons per square t t

mile and areas virtually unpopulated, (2) unique siren identifiers  !

and siren locations, and (3) siren sound contours for C-weighted .

i sound pressure levels (SPL) of 60dBC and 70dBC. In addition, should the design report choose to show that the siren sound level exceeds l 2

an average measured outd)or daytime (period between 7 a.m. and i 10 p.m.) ambient sound level (s) by 10 dB, the maps must include appropriate siren sound level contours for the SPL that is 10 dB l above the average outdoor daytime ambient sound level (s). The design report, per FEMA-43, should include a description of how the

. sound contours were calculated accounting for, at a minimum, the f effects of topographical features, temperature, relative humidity,  !

wind direction, wind magnitude, measured siren sound output, and I siren location / height.

FEMA-43 also states that the NUREG-0654/ FEMA-REP-1 criteria are satisfied when the design report shows that, for those geographical f areas to be covered by fixed sirens, either (a) the expected siren i

sound level generally exceeds 70 dBC where the population density exceeds 2,000 persons per square mile and 60 dBC in other inhabited areas, or (b) the expected siren sound level generally exceeds the

! average measured daytime ambient sound levels by 10 dB.

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a Q.10. Under the support contract to FEMA, how did IEAL evaluate the Shearon Harris Nuclear Power Plant's siren system and what conclusions did you reach?

A.10. Under our contract to provide technical support to FEMA for a series of reviews of alert and notification systems under NUREG-0654/ FEMA-REP-1, Rev. I and FEMA-43, IEAL received from FEMA a report prepared by Carolina Power and Light Company entitled, "Shearon Harris Nuclear Power Plant Alert / Notification System Report" (hereinafter referred to as the Design Report) which described the public-alert and notification system. A description of, and supplementary information for, the physical means of alerting for the Shearon Harris Nuclear Power Plant were contained i in Section 2.3 and Attachment 13 to this Design Report. The system as presented consisted of 62 Federal Signal (FS) Thunderbolt Model 1000 rotating sirens rated at 125 dBC by the siren manufacturer.

IEAL's evaluation results are documented in a draft report entitled "Shearon Harris. Nuclear Power Plant Site-Specific Offsite Radio-logical Emergency Preparedness Alert And Notification System Quality Assurance Verification" dated June 12, 1985.

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The evaluation of the siren system design calculation procedure was conducted by:

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. Verifying the licensee's computer modeling results as presented in Attachment 13 to the Design Report against i

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the 10 dB loss per distance doubled attenuation rate in v

the absence of special conditions; and 3

. Ascertaining the adequacy of the licensee's computer-predictive coverage in the presence of site-specific topographical and meteorological conditions through comparisons of the licensee's results with IEAL's Outdoor Sound Propagation Model (0SPM) results for specific sirens.

The Design Report's Attachment 13 stated that the Shearon Harris Nuclear Power Plant siren warning system design took into consideration meteorological and topographical factors and land surface conditions that affected the propagation of sound generated by each siren. The computer model utilized to. design the system, as described, calculates sound attenuation with i

distance due to hemispherical wave divergence, atmospheric absorption, absorption due to vegetation and other types of ground cover, propagation of sound over water, propagation of sound through urban and suburban areas, upwind sound shadow, and topo-graphical barriers. The Design Report, however, did not provide any discussion of the assumptions used, the methodologies employed, or the calculations performed to generate the final sound contours.

Therefore, IEAL's review was based on an evaluation of the presented predictions of acoustical coverage (Map 1 of the Design

Report) and sought to ascertain whether the computer model used in l

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the siren system design adequately accounted for site-specific terrain and weather conditions.

Eleven FS 1000 sirens, representative of the site-specific topographical conditions within the Shearon Harris Nuclear Power Plant EPZ, were selected for the review. These 11 sir'ns also cover the relatively more populated areas within the EPZ.

Surface weather parameters, representative of site prevailing summer daytime conditions, were used in the OSPM calculations. To compare the acoustical coverage estimates of OSPM with the data I

presented in the Design Report, each analyzed siren azimuth was 4

classified into two categories according to terrain profiles

i partially hilly (minor obstructions) and relatively flat (generally unobstructedline-of-sight). Regressions of d8C versus the I logarithm of distance were performed for the FS 1000 siren data for terrain categories. These regressions were computed utilizing both OSPM and Design Report data.

Some general comparative observrtions were made. The OSPM results showed attenuation rates of from 9 dB loss per distance doubled for flat terrain to 10 dB loss per distance doubled over partially hilly terrain within the range of 1,000 to 10,000 ft of the strens, while the Design Report's results indicated a constant 15 dB loss

per distance doubled attenuation rate for all site terrain condi-tions. The average 60 and 70 dBC ranges from the Design Report's L

predictions were, therefore, much more conservative than the OSPM predictions over both flat and partially hilly terrain categories.

This overall conservatism in estimating the 60 and 70 dBC ranges was further supported by comparison of individual siren coverages in terms of the area within the 70 dBC and 60 dBC contours. Area integrations were performed on the individual OSPM siren predic-tions. The average area with 60 dBC or higher was 21.00 square miles and, for 70 dBC, was 7.12 square miles. The resulting average effective ranges were estimated to be over 10,000 ft and 7,900 ft, respectively, for 60 dBC and 70 dBC. Area computations using data from the Design Report resulted in average area coverages that corresponded to effective ranges of 7,137 f t and 5,056 f t for 60 dBC and 70 dBC, respectively.

The results of the 11 OSPM runs were combined to generate representative contours around the selected sirens. A surface interpolation and contouring program utilizing the output results of the 11 sirens was used to generate a sound pressure level contour overlay. Comparison of the OSPM-predicted 60 dBC and 70 dBC countours with the 60 dBC and 70 dBC contours presented in Map 1 of the Design Report indicated that the Design Report's estimated coverage by the 11 sirens was very conservative.

The Design Report's Attachment 13 stated that there were geographical areas inside the EPZ boundary that were predicted to be below 60

dBC. The design criteria for these areas was chosen to be a 10 dB dissonant level above the ambient. The Design Report established the summer daytime average background noise level through a random spot survey process. No monitoring location selection, sample record length, or sampling frequency methods were described; thus, no judgement on the appropriateness and representativeness of the data could be made and the alternate design criteria of 50 dBC (10 dB above an ambient of 40 dBC) was rejected. However, based on the conservatism of the Design Report's predictive results, it was considered likely that some of the areas would experience siren sound pressure levels of 60 dBC or greater.

Therefore, IEAL recommended that the Shearon Harris Nuclear Power Phnt siren warning system be found conditionally acceptable.

Although the design procedure was found to be conservative, the licensee had not fully demonstrated that the system met FEMA-43 specific design criteria throughout the 10-mile EPZ. The licensee was subsequently requested by FEMA to: (1) ascertain that those geographical areas below 60 dBC coverage, as depicted on Map 3 of the Design Report, of greater than 60 dBC, (2) establish appro-I priate ambient noise levels in those geographical areas through a

statistically valid sampling plan, or (3) provide another primary alerting mechanism (such as route alerting) in those geographical areas.

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Carolina Power and Light Company responded to FEMA's request by letter dated October 7, 1985. The letter stated that personnel had visited each of the areas identified as being outside of predicted 60 dBC coverage to determine if resident housing existed.

On the basis of these visits, 13 areas were determined not to contain dwellings or commercial buildings and therefore did not require 60 dBC coverage. The letter identified six locations where additional sirens would be added because of high ambient background readings. Five of these six sirens are intended to cover areas previously identified as being outside of 60 dBC coverage. Addi-tional field testing was performed by Carolina Power and Light Company personnel to ascertain siren coverage for five additional areas. One of these areas was identified as being covered by less than 60 dBC. Carolina Power and Light Company stated that an additional siren would be installed to ensure adequate coverage for this area.

Based upon an analysis of the information presented in this letter, I conclude that the Shearon Harris Nuclear Power Plant siren system, when augmented with the additional sirens, will satisfy the design criteria of FEMA-43. The Shearon Harris siren system is considered adequate in that it conservatively meets the intent of NRC and FEMA guidance, specifically NUREG-0654/ FEMA-REP-1 which presents definitive guidelines for the design of siren systems.

The Background section of NUREG-0654/ FEMA-REP-1, Rev. I states in part that the guidance, after being commented upon by interested l

parties during a formal public comment period, is classified as final guidance; will be used by Federal agencies in their review of the preparedness of NRC facility licensees; and that the document is supportive of the NRC Final Rule on Emergency Planning (45 Fed.

Reg. 55402) and is referenced therein.

0.11. What conclusions did the panel of experts reach regarding the Eddleman contention?

A.11. The conclusions incorporated three major considerations:

The effect of nighttime activities, so that some percentage of people are awake:

Between midnight and 2 AM; Between 2 AM and 4 AM; and Between 4 AM and 6 AM.

The effect of intrafamily networking, given household size and composition, household distribution by peak dBC estimates, and individual arousal probabilities.

The effect of social, interfamily networking, assuming that about i

half of those awake or aroused by the initial siren alerting signal will make one single contact with some other household so that some of these contacts arouse and alert households that may not have

been alerted by the sirens and in which no member is awake during the period in which the sirens.are sounded.

And, furthermore, that one third .of the people who will- have been aroused by the end of the second siren signal will attempt to contact others.

The interfamily ripple effect was applied only to a situation in which half of the residents sleep with all bedroom windows closed because of the use of air conditioning, and half keep at least one window (in at least one bedroom) open.

The " worst" night hours were assumed, that is between 2 AM and 6 AM, hours when the potential alerting " payoff" due to people.who are

{ awake anyway'is at a minimum.

Some 87.8 percent of the people in the EPZ can then be expected to be aroused and alerted as a result of activating the Shearon Harris siren system for 15 minutes with a pattern of 3 minutes on and 3 minutes off.

0.12. Can the Shearon Harris siren system be improved?

A.12. Certainly, any public siren system can be improved. In considering adequacy, and further system improvement, we must address what is prudent and reasonable. NUREG-0654/ FEMA-REP-1 states on page 3-1 that the design objective does not constitute a guarantee that

m early notification can be provided for everyone with 100% assurance.

The NRC elaborated on this aspect in its statements of consideration for the Final Rule, 10 CFR Parts 50 and 70, Emergency Planning (45 Fed. Reg. 50705), regarding public notification systems:

"The commission recognizes that not every individual would necessarily be reached by the actual operation of such a system under all conditions of system use."

The Shearon Harris siren system, as currently being augmented, is capable of providing, under average conditions, a sound coverage of greater than 80 dBC to almost 60% of the residences in the EPZ.

This coverage is 20 dBC greater than that required by FEMA and NRC guidance. This 80 dBC represents 10 times the sound pressure of 60 dBC. Therefore in the Shearon Harris EPZ almost 60% of the residences are exposed to 10 times the sound pressure level considered by FEMA and NRC to be adequate.