ML20205F598

Forwards Responses to ASLB Questions Re Prompt Notification Sys.Provision of Tone Alert Radios to Households within 10 Miles of Plant Provides Redundant Notification Sys. Certificate of Svc Encl.Related Correspondence

ML20205F598
Person / Time
Site:	South Texas
Issue date:	08/14/1986
From:	Gutterman A HOUSTON LIGHTING & POWER CO., NEWMAN & HOLTZINGER
To:	Bechhoefer C, John Lamb, Shon F Atomic Safety and Licensing Board Panel
References
CON-#386-343 OL, NUDOCS 8608190257
Download: ML20205F598 (17)

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E Chairman, Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. James C. Lamb, III Administrative Judge 313 Woodhaven Road Chapel Hill, NC 27514 Frederick J. Shon Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Houston Lighting & Power Co., et al.

South Texas Project, Units 1 & 2 Docket Nos. 50-498 OL, 50-499 OL

Dear Members of the Board:

In response to the Licensing Board's letter to Maurice Axelrad dated July 25, 1986, enclosed are " Applicants' Answers to Board Questions Concerning the South Texas Project Prompt Notification System" (Applicants' Answers). As explained in Applicants' Answers and below, the STP Prompt Notification System (PNS) described in the STP Emergency Plan (Rev. 2), has been designed in accordance with applicable NRC and FEMA Staff guidance and regulatory require-ments. Applicants' Answers also identify a change to the STP PNS to be reflected in the next revision of the STP Emergency Plan, which further addresses the concerns described in the Board's letter. Accordingly, there is no serious safety issue within the meaning of 10 C.F.R. 5 2.760a and no basis for sua sponte review.

The PNS, as described in the STP Emergency Plan (Rev. 2),

consists of a siren system supplemented by tone alert radios

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Charles Bechhoefer, Esq.

Dr. James C. Lamb, III Frederick J. Shon August 14, 1986 Page Two provided to households outside the 70db range of the sirens.

As explained in Applicants' Answers, the sirens are subject to a program of rigorous preservice and inservice testing, routine preventive maintenance and prompt corrective maintenance which provides assurance that they will operate reliably throughout the operating lifetime of STP. (Answer 5). Similarly, the tone alert radios will be tested frequently and will be promptly repaired or replaced. Batteries, which are used as a backup power source for the radios, will be replaced annually or more frequently if necessary. (Answer 6).

In its July 25 letter the Licensing Board referenced the April 28, 1986 decision of the Licensing Board in the Shearon Harris proceeding (LBP-86-ll). The concerns of the Shearon Harris Licensing Board related to the difficulty of arousing people sleeping with their windows closed in households located near the lower range of siren volume. Unlike the original Shearon Harris emergency plan, the STP PNS, as described in the STP Emer-gency Plan (Rev. 2), provides for tone alert radios in more than a third of the households within a ten mile radius of the Plant.

(Answers 2 and 3). Since the effectiveness of the tone alert radios would not be reduced by closed windows, the concern of ,

the Shearon Harris Licensing Board would be proportionately less applicable to the STP PNS. In addition, the average measured daytime background sound pressure level for residential areas within the STP EPZ is below 50db (Answer 1). 1/ Thus, the 70db design objective for the STP siren system exceeds the sound pres-sure level required to comply with the NRC and FEMA Staff guidance (60db or 10db above background) by a substantial margin. (Answer 1).

Prior to its April 28 decision, the Shearon Harris Licensing Board wrote a letter to the Commission expressing concern that the NRC and FEMA Staff guidelines are inadequate to assure compli-l ance with the Commission's regulations. 2/ Subsequently, the Commission has received further submittals on this issue from 1/ As the Shearon Harris Board has recognized, nighttime back-ground levels can be expected to be even lower. (Letter, l Shearon Harris Licensing Board to the Commission (May 16, 1986) at 1).

2/ Letter, Shearon Harris Licensing Board to the Commission (November 19, 1985).

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Charles Bechhoefer, Esq.

Dr. James C. Lamb, III Frederick J. Shon August 14, 1986 Page Three the Shearon Harris Applicants, the NRC Staff, and the Shearon Harris Licensing Board, 3/ as well as from two members of the Indian Point 2 Licensing Board and the Licensee for Indian Point

2. 4/ The NRC Staff, in particular, endorses FEMA's view that the Staff guidelines are consistent with the regulations. 5/

The Commission has indicated that it is assessing the issues raised by the Shearon Harris Licensing Board and will determine whether " relevant rules or guidance documents need to be revised." 6/

At this point it is unclear when the Commission will act to resolve this issue. In the mean time, Applicants recognize the concern apparently shared by several Licensing Boards. Although Applicants continue to believe that the PNS as described in Revi-sion 2 of the Emergency Plan meets all applicable regulatory requirements, in order to avoid potential delays in licensing, Applicants have decided to provide tone alert radios to all house-holds in the portions of the EPZ within 10 miles of the Plant.

This change will be reflected in the next revision of the Emergency Plan. (Answer 3).

The PNS described in Revision 2 of the STP Emergency Plan complies with the applicable regulatory requirements, and the provision of tone alert radios to all households within 10 miles of the Plant provides a redundant system of notification for 3/ Letter, Thomas A. Baxter to the Commission (December 2, 1985); Memorandum, William J. Dircks to the Commission (December 11, 1985); Memorandum, Victor Stello, Jr. to the Commission (February 25, 1986); Letter, Shearon Harris Board to the Commission (May 16, 1986); NRC Staff / FEMA Motion for Leave to Withdraw Notice of Appeal (May 21, 1986).

4/ Letter, Oscar H. Paris and Frederick J. Shon to the Commis-sion (June 9, 1986); Letter, Brent L. Brandenburg to the Commission (July 3, 1986); Letter, Oscar H. Paris and Frederick J. Shon to the Commission (July 10, 1986).

5/ Memorandum, Victor Stello, Jr. to the Commission (February 24, 1986) at 1-2.

l 6/ Letter, Lando W. Zech, Jr. to the Shearon Harris Board (August 7, 1986) (Attached); see also, Memorandum, Samuel J. Chilk to Victor Stello, Jr. (February 4, 1986), COMSECY-85-9. f

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Charles Bechhoefer, Esq..

Dr. James C. Lamb, III Frederick J. Shon August 14, 1986 Page Four those households which are also within range of the sirens.

Since the PNS provides an adequate mechanism for nctification of the public, there is no serious safety question regarding the' design of the PNS, and no basis for the Board to raise a sua sponte issue. ]/

Respectfully submitted, k

Alvin H. Gutterman Attorney for Applicants Enclosures cc: Service List 2/ There is also some question about the Licensing Board's continuing jurisdiction to raise such a sua sponte issue in view of the fact that its June 13, 1986 Partial Initial Decision resolved all Phase II and III issues except for limited aspects of contention 4. Since the Licensing Board reserved only this limited jurisdiction in its decision and the Appeal Board's July 10 Order stated that it would be conducting its sua sponte review, jurisdiction over such matters may no longer reside in the ASLB. Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2),

ALAB-726, 17 NRC 755 (1983); Florida Power and Light Co.

(St. Lucie Nuclear Power Plant, Unit No. 2), ALAB-579, 11 NRC 223 (1980). Contra, Cincinnati Gas & Electric Co. (William H. Zimmer Nuclear Power Station, Unit 1), LBP-83-58, 18 NRC 640, 643-46 (1983).

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NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 2056s DOC O

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Judge James L. Kelley Judge James H. Carpenter Judge Glenn O. Bright .

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Dear Judges Kelly,

Carpenter, and Bright:

Thank you for ,your letters of November 19, 1985 and May 16, 1986 concerning the. adequacy of emergency alerting siren systems at nuclear power reactors.' The Commission is. continuing to as'ess s the issues raised.by your letters and your initial decision, and has been closely following the resolution of this issue in the licensing proceeding. The Commission will be asking staff for its views on the generic issue which you raise, with a view to deciding whether the relevant rules or guidance documents need to be revised.

Thank you for bringing this matter to our spe'cific attention.

. Sincerely, 4t4#4 W.k 1.

Lando.W. Zec , Jr l

cc: Service List

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! August 13, 1986 k UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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P24 HOUSTON LIGHTING & POWER Docket Nos. 50-498 OL S g

COWANY, ET AL. ) 50-499 OL h[Np[..[gc S

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(South Texas Project, )

Units 1 and 2) )

Applicants' Answers to Board Questions Concerning the South Texas Project Prompt Notification System QUESTION 1:

In utilizing the 70 db. level for determining the conditions for which sirens are to be relied upon for alerting and notification, upon what conditions (time, season, etc.) has the 70 db. criterion been formulated?

ANSWER 1:

The 70 db(C)I# design objective for the South Texas Project (STP) siren system was established in accordance with NRC and Federal Emergency Management Agency (FEMA) guidance provided in NUREG-0654, FEMA-REP-1, Rev. 1 (November, 1980) and FEMA-REP-43 (September 1983), " Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" (FEMA-43). In particular, Appendix 3 of NUREG-0654 states that, "[a]s an acceptable criteria at most locations 10 db above average daytime ambient background [ sound pressure levels] should be a target level for the design of an adequate siren system."

I#Applicable guidance specifies that siren sound levels be defined in terms of db(C), a broad band signal level. FEMA-REP-43, p. E-6; FEMA-REP-10, p. E-7.

• NUREG-0654, p. 3-8. FEMA-43 states that in establishing sound pressure level contours, "[a]verage summer daytime weather conditions may be utilized.".II FEMA-43, p. E-7.

In order to determine the average daytime ambient sound pressure levels for the STP plume exposure pathway emergency planning zone (EPZ) (as well as to identify any major intruding sources which might influence the design of the STP Prompt Notification System (PNS) and the placement of warning sirens), the daytime noise environment was monitored in October and December 1983 and measurements were performed at 26 sites including industrial, commercial and residential areas in which ambient background levels were expected to represent the upper bound of the daytime noise environment. The average measured ambient background level was approximately 46 db Y and was even lower in areas designated as residential. These levels are believed to be representative of the average summer daytime ambient noise environment for the geographic region around the STP sita, due to the temperate climate in that region during October and December. Based upon the results of these

- measurements, 70 db(C) was determined to be a conservative design objective for the STP siren system.

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- FEMA-43 has been superseded by FEMA-REP-10 (November, 1985) which states that for geographical areas with less than 2,000 persons per square mile (such as at STP), compliance with NUREG-0654 can be demonstrated by showing that

"[t]he expected siren sound pressure level generally exceeds the average measured summer daytime ambient sound pressure levels by 10 db...." FEMA-10,

p. E-8.

I*#After conversion to the noise level in the one-third octave band containing the predominant tone of the STP sirens in accordance with FEMA-43, p. E-6.

. Additional measurements of ambient background sound pressure levels were taken at different locations in July,1985 and verify that the 70 db(C) design objective exceeds ambient daytime background sound pressure levels by more than 10 db. Actual sound pressure levels generated by sirens will be greater than 70 db(C) with increased proximity to the siren. The 70 c design objective was used to identify the alerting range of the sirens beyond which other means of alerting the public would be provided.

QUESTION 2:

How many households are located (a) within the 0-5 nile EPZ, and (b) within the 5-10 mile EPZ? (The Emergency Plan sets forth a population of 231 within the 0-5 mile EPZ and 2270 within the 5-10 mile EPZ (SA-1.7) but does not appear to set forth the number of households.)

ANSWER 2:

According to a 1985 demographic study conducted for HL&P, there are 182 residential structures within a 0-5 mile radius of STP and 1,523 residential structures within a 5-10 mile radius of the Plant. While the precise number of households (i.e., individual family units) is not known, there are very few multi-family units within a 10 mile radius of the Plant. Thus, the number of residential structuret. should closely approximate the number of individual households (both permanent and seasonal).

QUESTION 3:

How many households are to be equipped with tone-alert radios (a) within the 0-5 mile EPZ and (b) within the 5-10 mile EPZ?

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. ANSWER 3:

The current revision of the STP Emergency Plan (Rev. 2) states that tone alert radios will be provided to residences within a 10 mile radius of the Plant and outside the 70 db(C) range of the sirens. There are approximately 700 such residences. In addition, the STP Emergency Plan calls for tone alert radios to be provided to all special facilities (as listed in SA-1.7 of the Emergency Plan), and, upon request, to residents residing within the 70 db(C) range of the sirens. While HL&P believes that the STP PNS, as described in the STP Emergency Plan, has been designed in accordance with applicable NRC and FEMA Staff guidance and complies with applicable requirements, it has, nevertheless, decided to provide tone alert radios to all households in the portion of the EPZ within a 10 mile radius of the Plant. This change will be reflected in the next revision of the STP Emergency Plan.

QUESTION 4: --

Has account been taken of the presence of seasonal residential population in planning siren locations and distributing tone-alert radios? If so, in what manner?

ANSWER 4:

Yes. The presence of seasonal residential population has been taken into account in establishing the design requirements for the STP PNS, including the

( number, type and location of sirens and the distribution of tone alert radios.

Sirens have been located in or near the areas of highest population density in the EPZ. In identifying the number and location of residential structures, no t

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distinction was drawn between permanent and seasonal residences. In addition, the location of recreational areas used by the permanent and seasonal population was taken into account in designing the siren system. Finally, as indicated in Answer 3 above, tone alert radios will be provided to all households in the portion of the EPZ within a 10 mile radius of STP. This includes seasonal as well as permanent residences.

QUESTION 5:

What provisions have been made for servicing the sirens and maintaining their operability?

ANSWER 5:

Prior to HL&P's acceptance of the siren system from the vendor, tests will be performed to verify its operational characteristics, including the proper functioning of the status / control system, siren operational performance, siren output levels and siren range. The siren system must perform in accordance with specifications during pre-acceptance testing for a period of thirty consecutive days (including daily silent and weekly " growl" testing). In addition, the status and condition of the completed installation will be examined to verify compliance with specifications.

In order to ensure continued operability, sirens will be silent tested on a daily basis to verify electrical operation, " growl" tested at least quarterly to verify acoustical operation, and fully sound tested at least annually to

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. verify simultaneous activation of all sirens and mechanical and acoustical operations. In the event of a loss of AC power to the sirens or tampering

, with the controls, the siren communicates the problem to a computer which monitors siren status and generates a printout at both HL&P and Matagorda County emergency operations facilities, identifying the location and nature of the problem. In addition to the scheduled tests described above, several sirens are routinely used by local volunteer fire departments.

E HL&P has entered into a contract with a maintenance contractor which requires L that inoperative sirens be returned to service within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of notification by HL&P. In addition to the prompt performance of corrective maintenance, preventive maintenance will be regularly performed. One complete siren assembly, as well as other spare parts, are maintained by the contractor.

Technical information, manuals, maintenance records and service reports will be maintained by HL&P.

QUESTION 6:

What provisions have been made for servicing the tone-alert radios? Are batteries to be routinely replaced by HL&P? Will lists be maintained by the company of persons whose tone-alert radios are being serviced by HL&P7 ( q .

Emergency Plan, 6 G-1.18 with Shearon-Harris LBP-86-11, supra, 23 NRC at 394, finding 76.)

ANSWER 6:

Tone alert radios will be tested prior to distribution. Thereafter, they will be activated on a weekly basis by the local Emergency Broadcast System radio station and will also be activated as part of the annual full system testing of the PNS. Guidance provided upon distribution of the radios will advise

. recipients to call Matagorda County emergency management if a radio does not operate properly. Defective radios will be repaired at the residence or replaced, rather than removed for service.

In the event of loss of AC power, batteries are used as a backup power source.

The tone alert radios include a " low battery" indicator light, and batteries will be issued to all registered holders of radios on an annual basis or more frequently as requested by the user. If residents are not home at the initial distribution of the radios, HL&P will follow up to ensure distribution.

Addresses for billing and electrical service will be available for this purpose. Matagorda County emergency management will maintain a list of the names and addresses of persons that have not accepted tone alert radios and will centact such persons in the event of an emergency in accordance with County procedures governing the notification of persons with special needs.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 OL COMPANY, ET AL. ) 50-499 OL

)

(South Texas Project, )

Units 1 and 2) )

AFFIDAVIT OF WARREN H. KINSEY Warren H. Kinsey, being duly sworn, deposes and says:

1. My name is Warren H. Kinsey. I am employed by Houston Lighting & Power Company as Plant Manager for the South Texas Project. My business address is South Texas Project, P. O. Box 289, Wadsworth, Texas 77483.

A summary of my education and professional experience is attached.

2. I have personal knowledge of the information contained in " Applicants' Answers to Bcard Questions Concerning the South Texas Project Prompt Notification System" dated August 13, 1986. Such information is true and correct to the best of my knowledge and belief.

OmMba Warren H. Kinse Q Subscribed and sworn to before me, a Notary Public in and for Matagorda County, Texas, this 13th day of August, 1986.

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I Summary of Education and Professional Experience WARREN H. KINSEY Education:

1965 U.S. Navy Nuclear Power Training Program 1975 BSME - University of Missouri Experience:

1965 - 1968 - U.S. Navy Senior Reactor Operator-Reactor Technician assigned to the U.S.S. Enterprise. Participated in two cruises. Operated reactor and performed maintenance on reactor control instru-mentation.

1968 - 1971 Senior Reactor Operator - Instructor assigned to the DIG Nuclear Prototype. Responsible for shift crew of reactor operators and technicians. Performed in plant and classroom training of Navy and civilian employees. Participated in site refueling activities.

1971 - 1975 - University of Missouri Licensed Senior Reactor Operator on 10 MW research reactor at University of Missouri. Operated the reactor for experi-mental and industrial uses. Performed maintenance and modi-fications en equipment. Participated in upgrade work for 5 MW to 10 MW conversion.

1975 - 1982 - Tennessee Valley Authority 1975 - 1978 Mechanical Engineer assigned to the Equipment Performance Group at Browns Ferry Nuclear Plant. Responsible for restart of numerous systems following major fire at the plant. Also responsible for initial startup of systems on new unit. Developed ASME Section XI testing program. Pre-pared procedures for startup tests and performed startup tests on mechanical equipment.

1978 - 1982 Engineering Section Supervisor assigned to Sequoyah Nuclear Plant. Supervised staff of subordinate supervisors, engi-neers of varying disciplines, laboratory technicians, and engineering aides. Responsible for nuclear startup test program, water chemistry, radio-chemistry and environmental (NPDES) regulations. Also responsible for ASME Section XI and Appendix J testing and performance testing of HEPA and

4 e charcoal filters, heat exchangers, and pumps. Responsible i for the performance of the makeup water treatment plant and .

full flow condensate demineralizers. Responsible for gen- I eral engineering problems associated with the operation of the plant.

[. 1982 - 1984 - Houston Lighting & Power Company Plant Superintendent at STP.

1984 (October) - Present - Houston Lighting & Power Company P] ant Manager at STP.

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. ' UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 OL COMPANY, ET AL. ) 50-499 OL

)

(South Texas Project, Units 1 )

and 2) )

CERTIFICATE OF SERVICE I hereby certify that ccpies of the letter to the Atomic Safety and Licensing Board from Alvin H. Gutterman dated August 14, 1986, and Applicants' Answers to Board Questions Con-corning the South Texas Prompt Notification System dated August 13, 1986 have been served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid, or by arranging for hand delivery as indicated by asterisk, on this 14th day of August 1986.

Charles Bechhoefer, Esq.* Brian Eerwick, Esq.

Chairman, Administrative Judge Assistant Attorney General Atomic Safety and Licensing For the State of Texas Board Panel Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548, Capitol Station Washington, D.C. 20555 Austin, TX 78711 Dr. James C. Lamb, III Kim Eastman, Co-coordinator Administrative Judge Barbara A. Miller 313 Wocdhaven Road Pat Coy Chapel Hill, NC 27514 Citizens Concerned About Nuclear Power Frederick J. Shon* 5106 Casa Oro Administrative Judge San Antonio, TX 78233 U.S. Nuclear Regulatory Commission Lanny Alan Sinkin, Esq.*

Washington, D.C. 20555 Christic Institute 1324 North Capitol Street, N.W.

Mrs. Peggy Buchorn Washington, D.C. 20002 Executive Director Citizens for Equitable Oreste Russ Pirfo, Esq.*

Utilities, Inc. Robert G. Perlis, Esq.

Route 1, Box 1684 Office of the Executive Legal Brazoria, TX 77422 Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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t Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

' Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 s Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555

[ - H1 m Donald J.fgilverman

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