ML20235X168

Applicant Rebuttal Testimony 12 (Commercial Telephone Sys).* Related Correspondence

ML20235X168
Person / Time
Site:	Seabrook
Issue date:	02/28/1989
From:	Callendrello A, Catapano G, Nelson R ALLCOMM, INC., NEW ENGLAND BELL TELEPHONE CO., PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Shared Package
ML20235W814	List: ML20235W811 ML20235W833 ML20235W884 ML20235W975 ML20235X042 ML20235X098 ML20235X147 ML20235X168 ML20235X220 ML20235X278 ML20235X312
References
OL, NUDOCS 8903130349
Download: ML20235X168 (17)

Text

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y anD cORRE.SfogD$fd IO y.u t; awc gg ga -3 N0:24 gn c . February 28, 1989 00CKE b* y^i'I((~ f:

DFaht4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE,,et al. ) 50-444-OL

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(Seabrook Station, Units 1 and 2) ) (Off-site Emergency

) Planning Issues)

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l APPLICANTS REBUTTAL TESTIMONY NO.- 12 (COMMERCIAL TELEPHONE SYSTEMS) 4 Panel Members: Anthony M. Callendrello, Manager, Emergency i Preparedness Licensing, New Hampshire Yankee I l

Gary J. Catapano, President, ALLCOM, Inc.

Robert O. Nelson, District Manager, Network Operations, New England Telephone I;

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TABLE OF CONTENTS I. INTRODUCTION . . . . . . . . . . . . . . . . . .. . 1~

II. ORO EMERGENCY COMMUNICATIONS THAT DO NOT RELY ON THE COMMERCIAL TELEPHONE SYSTEM . . . . . . . . . . 1 A. Initial Notification of Massachusetts Authorities . . . . . . . . . . . . . . . . . 1 B. ORO Communications for Initiation of Public Notification . . . . . . . . .. . . . . . . . . 2 C. Communication of Dosimetry Readings By ORO Traffic Guides . . . . . . . . . . . . . . . . 3 III. ALTERNATE COMMUNICATION MEANS FOR ORO EMERGENCY COMMUNICATIONS THAT RELY ON COMMERCIAL TELEPHONE. . 4 A. ORO Interfacility Communications . . . . . . . 4 B. Communications with Massachusetts State and

-Local Governments . . . . . . . . . . . . . . 5 C. ORO School Liaison and Special Population Liaison Communications . . . . . . . . . . . . 6 IV. ORO MEASURES TO LIMIT COMMERCIAL TELEPHONE USE BY THE GENERAL PUBLIC . . . . . . . . . . . . . . . . 9 V. COMMERCIAL TELEPUOlfE NETWORK CAPACITY AND FACILITIES FOR HANDLING ORO-GENERATED EMERGENCY CALL TRAFFIC . . . . . . . . . . . . . . . . . . . 12 i

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-I. INTRODUCTION This testimony addresses Joint Intervenor (JI)

Contention 30 regarding the reliance of Offsite Response Organization (ORO) communications on commercial telephones and potential for commercial telephone system overload. The ORO does not rely on commercial telephone as a primary means for some emergency communications. In cases where ORO relies on commercial telephone as a primary means for communication, sufficient alternate means of communication exist. The measures the ORO has taken to limit commercial telephone use by the public and the capabilities of the commercial telephone system that serves the EPZ communities are described herein.

II. ORO EMERGENCY COMMUNICATIONS THAT DO NOT RELY ON THE COMMERCIAL TELEPHONE SYSTEM.

A. Initial Notification of Massachusetts Authorities Initial notification of offsite authorities of an emergency at Seabrook Station does not rely on the commercial telephone network. Such notification, including that of l Massachusetts governmental entities, is made by Seabrook Station Control Room via the Nuclear Alert System (NAS). The NAS is comprised of various microwave and leased telephone  ;

links and does not rely on commercial telephone line i availability. SPMC, Section 4.1.

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As a backup to the NAS, the Seabrook Station Control Room and the New Hampshire Yankee (NHY) Offsite Response Emergency Operations Center (EOC) Contact Point have access to a Dimension 2000 Telephone System through which they can contact offsite authorities. This system has offsite capabilities that do not rely solely on telephone company central office switching. SPMC, Section 4.2. In addition, the ORO has the capability to communicate directly with Massachusetts entities, including the State Police, over the Massachusetts Governmental Interface'(MAGI) radio network.

B. ORO Communications for Initiation of Public Notification The public notification system in Massachusetts does not rely on the availability of commercial telephone lines for primary communications. Initial activation of the Vehicular Alert and Notification System (VANS) operators at the VANS Staging Areas will be made by the EOC Contact Point via the Vehicular Alert and Communications System (VACS) which transmits a radio signal that activates an audible and visual alarm system. Subsequent voice communications between the Offsite Response EOC and the VANS Operator is via the NHY ORO Emergency Radio Network (ERN). SPMC, Section 4.5.

The Offsite Response EOC communicates with Emergency Broadcast System (EBS) radio station WHAV/WLYT via a dedicated telephone ring-down circuit which is independent of

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L the Public Switched Telephone Network and provides secure' primary communications between these facilities. SPMC, Section 4.7. Ring-down circuits are exclusive, hard-wired telephone lines linking particular facilities, for which no manual dialing is required. Commercial telephone serves as a back-up to the ring-down circuits.

A Remote Programming Unit, which is an ultra high frequency radio link, serves as a radio backup to the commercial telephone for communication with EBS stations.

The Remote Programming Unit is described in the SPMC, Section 4.7.2.

C. Communication of Dosimetry Readings By ORO Traffic Guides ORO Traffic Guides utilize two-way multi-channel portable radios operating on the ORO ERN as the primary means of reporting dosimetry readings and support requests to the Evacuation Support Dispatcher at the Staging Area. SPMC, Appendix J at J-1.4 and J.3.14. Should their assigned radio channel become inoperable due to an ERN repeater failure, there are three other channels available for Traffic Guides  ;

to communicate with the Evacuation Support Dispatcher.

Upon failure of a channel, a backup system to the failed ERN repeater would be activated, allowing normal communications to take place on the previously inoperable repeater channel. The main component of this backup system

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is a high-power base station unit which is co-located with the ERN repeater units and is activated automatically in the

-event of a repeater failure to allow communications to continue on the failed frequency. Direction to switch to an alternate channel would then be given by the ORO Communications Coordinator at the Offsite Response EOC on the primary frequency.

In the event the primary and backup systems for all (4) channels. completely fail, telephone numbers for the Evacuation Support Dispatcher are provided prior to Traffic Guides being dispatched from the Staging Area so that commercial telephones may be utilized as a backup means of reporting, SPMC, IP 2.11 at 5.1.3. Therefore, the SPMC provides for primary and multiple backup communication links which allow Traffic Guides to report their dosimetry readings from the field.

III. ALTERNATE COMMUNICATION MEANS FOR ORO EMERGENCY COMMUNICATIONS THAT RELY ON COMMERCIAL TELEPHONE.

This section addresses provisions for alternate communications in all cases where the ORO relies on commercial telephone service for essential communications.

A. ORO Interfacility Communications Commercial telephone lines have been installed for dedicated use by key officials in the NHY Offsite Response EOC. " Dedicated commercial telephone lines" are those which

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l have been administratively set aside for a particular ORO em'ergency response position or function. Commercial telephone lines for interfacility use will serve as the primary means of communication between the NHY Offsite Response EOC, the NHY ORO Staging Area, and the ORO Reception-Centers. SPMC, Section 4.5 and IP 1.8 at 5.1.4.

Emergency Radio Network communications via channels 5 and 6 exist between the Offsite Response EOC,.ORO Staging Area and ORO Reception Centers (SPMC, Section 4.5). In addition, the ORO intercom links the EOC and Staging Area.

B. Communications with Massachusetts State and Local Governments In instances where the SPMC relies on commercial telephones as the primary communications link between the NHY ORO and Massachusetts state and local governments, a reliable backup mode of communications exists.

The ORO Assistant Offsite Response Director, Support Liaison and the Local EOC Liaison Coordinator have commercial telephones dedicated for their use at the Offsite Response {

1 EOC. These phones provide communication with ORO State and Local Liaisons assigned to Massachusetts facilities. SPMC, Section 4.5 As a backup to the commercial telephone-based communications described in the paragraph above, the NHY ORO maintains the capability to communicate with non-

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participating state and local governments and response organizations via the Massachusetts Governmental Interface.

(MAGI) system, as described in the SPMC, Section 4.6. This l capability is provided by the MAGI control center located in l

the NHY Offsite Response EOC. The MAGI control center provides the capability for ORO communications with Massachusetts state and local governmental response facilities.

In addition to the MAGI system, backup communications between the NHY Offsite Response EOC and both the Massachusetts Civil Defense Agency Area I EOC and the Massachusetts State EOC is provided by the NAS extension located at the Offsite Response EOC.

Additional backup communications between the ORO and local EOCs is provided by portable cellular telephones issued to ORO Local EOC Liaisons for use in transit and on arrival at the local EOC.

C. ORO School Liaison and Special Population Liaison Communications The action items of the ORO School Liaisons, as described in SPMC, IP 1.9, have been redefined to facilitate implementation of their communications tasks. The amount of equipment to accomplish these tasks is planned to be ,

I increased over the amount indicated in the SPMC, which will be revised so that each liaison now has a commercial y

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telephone dedicated for their use. School Liaisons will no longer share a telephone with Special Population Liaisons or

Local EOC Liaisons. The Staging Area Layout (SPMC, Figure 5.2-4 and IP 3.2 at Attachment 5) will be revised to reflect this equipment allocation.

The applicable procedure directs that notification of schools and day care centers be made by the School Liaisons from their assigned work area in the Staging Area. School Liaisons are no longer instructed to report to the local EOC, so that they may devote all their time to their respective tasks. SPMC, IP 1.9 at 5.2.

Similarly, the action items of the ORO Special Population Liaisons have been redefined and the amount of equipment for implementation will be increased. The applicable procedure will direct that notification of special facilities and non-institutionalized hearing-impaired and medically homebound individuals be made by the Special Population Liaisons from the assigned work area in the Staging Area, and Special Population Liaisons are no longer instructed to report to the local EOC, allowing them more time to perform their assigned responsibilities. SPMC, IP 1.10 at 5.2. A telephone and desk space will be provided for each of the six Special Population Liaisons to make their notification calls (one liaison is assigned to each EPZ community). Special Population Liaisons will no longer share

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L a telephone with School Liaisons or. Local EOC Liaisons. The  !

l Stating Area Layout (SPMC, Figure 5.2-4 and IP 3.2 at Attachment 5) will be revised to reflect this equipment allocation.

The SPMC provides that ORO School Liaisons and Special Population Liaisons are notified and instructed to report to the ORO Staging Area at the ALERT level. SPMC, Table 3.2-1.

These personnel will make notifications to schools, special facilities and special needs individuals upon arrival at this facility. Under these conditions, notification. calls will be made at the early stages of an emergency. Therefore, it is anticipated that the commercial telephone system would not be subject to overload conditions at this time.

In addition, supplementary means exist to provide information and assistance to special populations, including schools. These are as follows:

First, the ORO has the capability to activate the EBS, which could be used to provide specific information for special population groups over AM and FM frequencies. Tone-alert radios, tuned to a radio station activated by EBS, will be offered to schools, day care centers, nursing homes,

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hospitals, medical facilities, campgrounds, businesses with 50 or more employees at one location, and other selected facilities. SPMC at 3.2-15.

Second, the SPMC contains default values reflecting planned special population transportation requirements, as listed in the SPMC, Appendix M. These default values would serve as the basis for allocating transportation resources to special populations in the event any facilities or individuals could not be directly contacted at the time of an emergency.

IV. ORO MEASURES TO LIMIT COMMERCIAL TELEPHONE USE BY THE GENERAL PUBLIC 10 CFR 50.47 (b) (6) requires that provisions exist for prompt communications among principal response organizations and to emergency personnel and to the public. It does not require that communications provisions exist so that members of the public can telephone requests for assistance should the need arise.

Pre-emergency measures taken by NHY, coupled with SPMC provisions for informing and instructing the public at the time of an emergency, limit the need for the general public to contact the NHY ORO by telephone during an emergency.

These measures include a survey NHY has conducted to pre ~

identify those residents of the Massachusetts portion of the Seabrook Station EPZ who may need special assistance during an emergency. The results of this survey will be updated annually. See Applicants' Rebuttal Testimony No. 6

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(Protective Actions for Particular Populations) for further detail on this survey process and its results.

Requirements for emergency help as identified by the survey may include special notification needs or special transportation assistance. In either case, these pre-identified needs have been incorporated into the SPMC planning basis.and specific NHY ORO resources have been allocated for them. In addition, the ORO will attempt'to contact pre-identified special needs individuals at the time of an emergency to verify their needs. SPMC, Section 3.6.1.C.

If there are special needs individuals that have not been pre-identified there is an 800 number that these people can call to receive assistance from the ORO. The 800 number is published in the Emergency Plan Information Calendar which is distributed to all residences in the EPZ. See Applicants' i

Exhibit No. 40. It is also located in flyers and posters distributed to special facilities, hotels, motels, restaurants, recreational facilities as well as post offices and public libraries.

Notwithstanding the above, if special needs individuals cannot find the 800 number, these people have the opticn to contact their local police and fire departments or civil j defensa agencies. Unlike a county-wide public safety dispatch system which serves multiple communities (such as

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the 911 system referenced in the Guy Daines testimony), each community in the EPZ has its own public safety response l organizations with local telephone numbers to receive calls for assistance from people within the community.

j Additionally, these people may contact state agencies, such' as the Massachusetts. Civil Defense Agency (MCDA), for assistance.

Information received by the. local public safety agencies may_be relayed to the ORO EOC for action by several means.

First, the Local EOC Liaison may communicate this information to the Local EOC Liaison Coordinator. Second, the public safety agencies themselves may contact the ORO EOC directly via MAGI to request assistance. Further, Massachusetts State Liaisons at the MCDA EOC and the MCDA Area 1 headquarters would be available to communicate requests for assistance to the Offsite Response EOC.

Implementation of the overall evacuation assistance aspect of the SPMC is not predicated upon the ability of the general public to contact the ORO. Persons who need a ride will receive instructions on how to obtain bus transportation through EBS messages and pre-distributed Public Information i Material (PIM).

The prescripted EBS niessages found in the SPMC at IP 2.13 state that persons requiring transportation assistance will receive transport to Reception Centers via buses t..

traveling along emergency routes in their area. The EBS messages will indicate when buses will begin running routes i and also refer listeners to the pre-distributed PIM. The .

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pre-designated bus routes are depicted on the' Emergency Plan Information Calendar mailed to every household in the EPZ and.

on materials made available to transients. -The. calendar also instructs. residents to tune to an EBS station ~for the latest evacuation bus information. Both sources of information are intended to obviate the need for individuals to use their telephone to contact ORO emergency-response personnel at the time of an emergency.

Further, EBS messages and the PIM advise people to refrain from the use of telephones unless absolutely necessary. Indeed, given these pre-emergency identification measures and resultant resource allocations, the verification contacts at the time of an emergency, and public information and emergency messages, special needs individuals need not initiate telephone contact with the ORO at the time of an emergency.

V. COMMERCIAL TELEPHONE NETWORK CAPACITY AND FACILITIES FOR HANDLING ORO-GENERATED EMERGENCY CALL TRAFFIC During implementation of.the SPMC, the following New England Telephone Ccmpany Central Offices would be primarily involved with handling initial ORO call traffic: Haverhill, Newburyport, West Newbury, Merrimac, and Amesbury, l

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Massachusetts, and Portsmouth, New Hampshire. The Newburyport Central Office serves Newburyport, Salisbury, )

Newbury and a small portion of Amesbury. At present, these )

1 central office facilities consist of a number of switching system technologies including electromechanical, step-by-step (SXS), Number 5 Cross-Bar (No. 5XB), and state of the art l l

Electronic Switching System Remote Switching Modules (RSM) such as 1AESS, 1ESS, 2 BESS and SESS. By facility, service is presently provided by and will be updated as follows:

Present Proposed Upgrade Switch Switch conversion Central Office Technoloav Technoloav Date Amesbury, MA No. 5XB SESS RSM 10-14-89 Haverhill, MA 1ESS - -

Merrimac, MA SXS SESS RSM 10-14-89 Newburyport, MA 1 BESS - -

Portsmouth, NH 1AESS - -

West Newbury, MA SXS SESS RSM 10-14-89 After the Amesbury, Merrimac and West Newbury Central Offices are converted to SESS Remote Switching Modules, which work off of the SESS Host Office in Haverhill, all of these central offices will be of the Stored Program Control type (state of the art),_which provide technologically advanced I l

service protection features. I Dynamic Service Protection, also known as Essential Service Protection, and Line Load Control is a feature built i

into the generic programs of the Stored Program Switching j i

Systems such as 1ESS, IAESS, 2 BESS and SESS and the SESS RSM. J l

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j_ In the event of a demand for dial tone greater than what the i

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( office is engineered for and capable of, this feature will be activated automatically. The activation of this feature will 1 i

provide priority dial tone to those customers with an Essential Service class of service. Some examples of these types of customers are: police and fire departments, hospitals, and ambulance services. With the planned upgrades in place, all of the aforementioned central offices will have Dynamic Service Protection in place for emergency service providers. Dynamic Service Protection does not deny service to any telephone user. It merely gives essential customers, described above, priority service while other customers are served as rapidly as equipment becomes available.

Each of the six central offices listed above is equipped with an emergency backup power supply.

Relative to New England Telephone's response to any type of a large scale public safety emergency, a New England Telephone Company employee, the Area Operations Manager -

Government Accounts, assumes the position of the Federal Government Coordinator and is responsible for immediate two-way communication with FEMA. The New England Telephone Company Emergency Restoration Center, located at 185 Franklin Street, Boston, would be staffed immediately and remain operational 24-hours a day, seven days a week for the duration of the emergency.

4 During the time of an emergency relative to the entire New England Telephone Company telecommunications network, the Network Management Center will exercise controls on the Tandem and local switching systems to keep call congestion to a minimum. The effectiveness of these controls will be influenced by the total New England and national network traffic load.

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