FEMA-2009-0001-0079 2nd Comment Received

From: HUSSAIN, Saqib [mailto:[email protected]] On Behalf Of PERKINS-GREW, Susan
Sent: Tuesday, January 05, 2010 4:25 PM
To: FEMA-POLICY,
Subject: Docket ID: FEMA-2009-0001 - NEI Comments on Docket Number FEMA-2009-0001, 74 Federal Register
FR 57508, November 6, 2009
January 5, 2010

Office of Chief Counsel
Regulation and Policy Team
Federal Emergency Management Agency
U.S. Department of Homeland Security
500 C Street, SW
Room 835
Washington, DC 20472–3100

Subject: NEI Comments on Docket Number FEMA-2009-0001, “Telephone Survey Related to Alert and Notification
Systems,” 74 Federal Register FR 57508, November 6, 2009
The Nuclear Energy Institute (NEI), on behalf of the nuclear energy industry, is pleased to comment on Docket
Number FEMA-2009-0001, “Telephone Survey Related to Alert and Notification Systems,” 74 Federal Register FR
57508, November 6, 2009.

NEI believes that the telephone survey is an inappropriate method for obtaining the desired results described in
the supplementary information section of 74 FR 57508. The basis for why the survey will not produce data relevant
to the three stated goals is provided below.
1. Confirm that the siren system achieves an operability standard of greater than or equal to 90% in the
twelve month period prior to approval of the system.

NEI Response:
Questions asked in the survey pertain to activities related to a single audible test of the siren system on a
given date. In addition, members of general public surveyed may have been at work or not heard the siren
because the test may be of a short duration by procedure. Or, members of the public surveyed may not be
even aware of the test. These circumstances could cause the reporting of inaccurate data to FEMA.
Therefore, no conclusion can be drawn pertaining to operability within a twelve month period based on the
survey results.

2. Determination that the alert and notification system testing results have been completed in accordance
with approved procedures.
NEI Response:
Members of the public are not familiar with the procedures related to the alert and notification system.
Therefore, it is not reasonable to determine, by a telephone survey, whether testing results have been
completed in accordance with approved procedures.

3. Siren operability remains at or above 90%.

NEI Response:
Siren operability is determined by calculating the ratio of the number of sirens that activated upon demand
to the total number of sirens for which activation was demanded. The public has insufficient information to
know whether or not the ratio described was above 90%.

Emergency Planning Zone (EPZ) populations vary from a few thousand, and in some areas, greater than one
hundred thousand. Therefore, finding 338 respondents at home to respond to the survey will be difficult in some
EPZs and might be demographically biased in others.

In conclusion, the telephone survey as proposed will not produce data relevant to the stated reasons for
conducting the survey. Further, the survey should be abandoned as a means for gathering data on alert and
notification system (ANS) performance. U.S. Nuclear Regulatory Commission (NRC) licensees are required to
maintain detailed records of system operability. The records document the results of testing performed in
accordance with the ANS design specifications and are part of NRC’s performance indicator system for its nuclear
power reactor licensees. Reviewing records of system operability described above would be a more appropriate
means to obtain data to best suit FEMA’s interests.
Please do not hesitate contact me at (202) 739.8016; [email protected] if you have any questions.
Susan Perkins-Grew
Director, Emergency Preparedness
Nuclear Energy Institute
1776 I Street NW, Suite 400
Washington, DC 20006
www.nei.org
P: 202-739-8016
F: 202-533-0130
E: [email protected]

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Susan Perkins-Grew
DIRECTOR
EMERGENCY PREPAREDNESS
NUCLEAR GENERATION DIVISION

January 5, 2010
Office of Chief Counsel
Regulation and Policy Team
Federal Emergency Management Agency
U.S. Department of Homeland Security
500 C Street, SW
Room 835
Washington, DC 20472–3100
Subject: NEI Comments on Docket Number FEMA-2009-0001, “Telephone Survey Related to Alert
and Notification Systems,” 74 Federal Register FR 57508, November 6, 2009
The Nuclear Energy Institute (NEI)1, on behalf of the nuclear energy industry, is pleased to
comment on Docket Number FEMA-2009-0001, “Telephone Survey Related to Alert and Notification
Systems,” 74 Federal Register FR 57508, November 6, 2009.
NEI believes that the telephone survey is an inappropriate method for obtaining the desired results
described in the supplementary information section of 74 FR 57508. The basis for why the survey
will not produce data relevant to the three stated goals is provided below.
1. Confirm that the siren system achieves an operability standard of greater than or equal to
90% in the twelve month period prior to approval of the system.

NEI Response:

Questions asked in the survey pertain to activities related to a single audible test of the siren
system on a given date. In addition, members of general public surveyed may have been at
work or not heard the siren because the test may be of a short duration by procedure. Or,
members of the public surveyed may not be even aware of the test. These circumstances
could cause the reporting of inaccurate data to FEMA. Therefore, no conclusion can be
drawn pertaining to operability within a twelve month period based on the survey results.

1

NEI is the organization responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy
industry. NEI’s members include all utilities licensed to operate commercial nuclear power plants in the United States, nuclear
plant designers, major architect/engineering firms, fuel fabrication facilities, nuclear material licensees, and other organizations
and individuals involved in the nuclear energy industry.

1776 I Street, NW l Suite 400 l Washington, DC l 20006-3708 l P: 202.739.8016 l F: 202.533.0130 l [email protected] l www.nei.org

Office of Chief Counsel
January 05, 2010
Page 2

2. Determination that the alert and notification system testing results have been completed in
accordance with approved procedures.

NEI Response:

Members of the public are not familiar with the procedures related to the alert and
notification system. Therefore, it is not reasonable to determine, by a telephone survey,
whether testing results have been completed in accordance with approved procedures.
3. Siren operability remains at or above 90%.

NEI Response:

Siren operability is determined by calculating the ratio of the number of sirens that activated
upon demand to the total number of sirens for which activation was demanded. The public
has insufficient information to know whether or not the ratio described was above 90%.
Emergency Planning Zone (EPZ) populations vary from a few thousand, and in some areas, greater
than one hundred thousand. Therefore, finding 338 respondents at home to respond to the survey
will be difficult in some EPZs and might be demographically biased in others.
In conclusion, the telephone survey as proposed will not produce data relevant to the stated reasons
for conducting the survey. Further, the survey should be abandoned as a means for gathering data
on alert and notification system (ANS) performance. U.S. Nuclear Regulatory Commission (NRC)
licensees are required to maintain detailed records of system operability. The records document the
results of testing performed in accordance with the ANS design specifications and are part of NRC’s
performance indicator system for its nuclear power reactor licensees. Reviewing records of system
operability described above would be a more appropriate means to obtain data to best suit FEMA’s
interests.
Please do not hesitate contact me at (202) 739.8016; [email protected] if you have any questions.
Sincerely,

Susan Perkins-Grew
c:

Mr. James R. Kish, FEMA