AEP-NRC-2012-83, Communications Assessment Requested by Nuclear Regulatory Commission Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendation 2.1, 2.3, and 9.3.

From kanterella
Jump to navigation Jump to search

Communications Assessment Requested by Nuclear Regulatory Commission Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendation 2.1, 2.3, and 9.3.
ML12318A176
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 10/31/2012
From: Carlson M
Indiana Michigan Power Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2012-83
Download: ML12318A176 (45)
v • d • e


Text

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant 1POWER0 One Cook Place Bridgman, MI 49106 A unit ofAmerican Electric Power Indiana Michiga nPower.com October 31, 2012 AEP-NRC-2012-83 10 CFR 50.54(f)

Docket No.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 Communications Assessment Requested by Nuclear Regulatory Commission Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dal-ichi Accident," dated March 12, 2012.

References:

1. Letter from E. J. Leeds and M. R. Johnson, U.S. Nuclear Regulatory Commission (NRC), to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012, (ML12056A046).
2. Letter from J. P. Gebbie, Indiana Michigan Power Company (A&M) to NRC Document Control Desk, "60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dal-Ichi Accident; dated March 12, 2012," dated May 11, 2012 AEP-NRC-2012-34.
3. Letter from P. S. Tam, NRC, to L. J. Weber, I&M, "Review of 60-Day Response to Request for Information Regarding Recommendation 9.3 of the near-Term Task Force Related to the Fukushima Dai-ichi Nuclear Power Plant Accident (TAC Nos. ME8683 and ME8684)," dated June 8, 2012, (ML12145A640).
4. Letter from D. L. Skeen, NRC, to S. Perkins-Grew, Nuclear Energy Institute (NEI), "U. S.

NRC Review of NEI 12-01, 'Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,' Revision 0, dated May 2012,"

dated May 15, 2012, (ML12131A043).

14-Y-95

U. S. Nuclear Regulatory Commission AEP-NRC-2012-83 Page 2 On March 12, 2012, the NRC staff issued Reference 1, a Request for Information pursuant to 10 CFR 50.54(f), to I&M, the licensee for the Donald C. Cook Nuclear Power Plant (CNP) Units 1 and 2. Enclosure 5 of the letter contained specific Requested Actions and Requested Information associated with Recommendation 9.3 for Emergency Preparedness (EP) programs.

Specifically, I&M was requested to assess the means to power communications equipment onsite and offsite during a prolonged station blackout (SBO). By Reference 2, I&M provided a response to the Request for Information that proposed an alternative course of action and estimated completion date. I&M indicated that the communications assessment, prepared per the guidance of NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," and an implementation schedule of the time needed to implement the results of the communications assessment would be provided to the NRC by October 31, 2012. By Reference 3, the NRC agreed to the alternative course of action. to this letter provides an affirmation. Enclosure 2 provides the communications assessment. Enclosure 3 provides the implementation timeline.

This letter contains no new or revised regulatory commitments. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.

Sincerely, Michael H. Carlson Vice President - Site Support Services MCS/kmh

Enclosures:

1. Affirmation
2. Communications Assessment
3. Implementation Timeline

U. S. Nuclear Regulatory Commission AEP-NRC-2012-83 Page 3 c: C. A. Casto, NRC Region III J. T. King, MPSC S. M. Krawec, AEP Ft. Wayne, w/o enclosures MDEQ - RMD/RPS NRC Resident Inspector T. J. Wengert, NRC Washington DC to AEP-NRC-2012-83 AFFIRMATION AFFIRMATION I, Michael H. Carlson, being duly sworn, state that I am Vice President - Site Support Services of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are. true and correct to the best of my knowledge, information, and belief.

Indiana Michigan Power Company Michael H. Carlson Vice President - Site Support Services SWORN TO AND SUBSCRIBED BEFORE ME THIS 5 & DAY OF 06Vb&e( ,2012 Notary P lic My Commission Expires 1 - 1\_ \

to AEP-NRC-2012-83 Communications Assessment to AEP-NRC-2012-83 Bridgman, Michigan Berrien County to AEP-NRC-2012-83 Table of Contents 1 . P u rp o se ..................................................................................................................... 1 2 . B a c kg ro u n d ................................................................................................................ 1

3. Methodology .............................................................................................................. 1
4. Assumptions and Limitations ........................................ 2
5. Assessment Sum mary .......................................................................................... 4
6. Recom m endations .................................................................................................. 5
7. References ................................................................................................................. 6 Appendix A - Assessment (tabular form) ................................................................... 7 Appendix B - NEI 12-01 Roll-up ................................................................................ 22 to AEP-NRC-2012-83
1. Purpose This report documents the assessment of the Donald C. Cook Nuclear Plant's (CNP) communication capabilities performed in accordance with Nuclear Energy Institute (NEI) 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities", Revision 0, dated May 2012. This assessment is completed for Unit 1 and Unit 2.
2. Background Based on the adverse effects of the March 11, 2011, Tohoku earthquake and subsequent tsunami on the Fukushima Dai-lchi Nuclear Power Plant, the United States Nuclear Regulatory Commission (NRC) issued a request for information (RFI) in accordance with 10 CFR 50.54(f) to Indiana Michigan Power Company (I&M), the licensee for the CNP, entitled "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," dated March 12, 2012. In the RFI, the NRC requested that I&M assess their current communications systems and equipment used during an emergency event given a set of standard assumptions. The NRC also requested that consideration be given to any enhancements that may be appropriate for the emergency plan with respect to communications requirements of 10 CFR 50.47, Appendix E to 10 CFR 50, and the guidance in NUREG-0696. I&M was also to consider the means necessary to power the new and existing communications equipment during a multi-unit event, with a loss of all AC power.

I&M's objective is to maintain the capability to perform critical communication during and following an event that results in an extended loss of AC power. NEI 12-01 provides criteria for assessing the availability of communication systems and equipment necessary for implementation of emergency planning standard requirements.

Communications capabilities that support implementation of mitigation strategies and repair actions intended to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling are also to be assessed.

3. Methodology The CNP communications assessment is based on the methodology set forth in NEI 12-01. More specifically, this assessment is based on NEI 12-01 Section 2, Assessment Assumptions, and NEI 12-01 Section 4, Communications During an Extended Loss of AC Power.

In order to perform the methodology in NEI 12-01,' the following steps were performed:

1. Discussed the communications assessment methodology with CNP stakeholders to ensure plant objectives are met.

1 to AEP-NRC-2012-83

2. Reviewed plant documentation related to CNP's Emergency Plan Procedures.
3. Reviewed CNP-specific responses to INPO IER 11-4.
4. Completed facility discussions with plant staff, including Information Systems (IT)/Communications Systems personnel.
5. Developed an assessment report containing the results of the assessment and recommendations.
6. Using the information gathered from the above steps, completed Appendix B of this document, which is based on the NEI communications assessment template.
4. Assumptions and Limitations 4.1. The assumptions for this report are consistent with those presented in NEI 12-01.

4.1.1. A large-scale external event occurs that results in:

0 all on-site units affected

  • extended loss of AC power 0 impeded access to the units 4.1.2. Initially, all on-site reactors are operating at full power and are successfully shut down.

4.1.3. A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.

4.1.4. The event impedes site access as follows:

A. Post event time: 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - No site access. This duration reflects the time necessary to clear roadway obstructions, use different travel routes, mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.

B. Post event time: 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g., private resource providers or public sector support).

C. Post event time: 24+ hours - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.

2 to AEP-NRC-2012-83 4.1.5. Installed sources of AC power, including alternate AC power sources, are not available. These power sources are typically classified as safety-related or governed by augmented quality requirements.

4.1.6. Nonessential loads from DC battery buses are stripped in accordance with plant emergency or abnormal operating procedures, or other response guidelines to extend battery life.

4.1.7. Installed inverters and battery chargers remain available provided they are protected from external events consistent with the current station design. If the flood protection walk-downs performed in response to Near Term Task Force (NTTF) Recommendation 2.3 identify a lack of sufficient flood protection margin, the communications assessment should be updated to reflect the potentially lost equipment. A regulatory submittal of the updated assessment is not required.

4.1.8. On-site diesel fuel oil is available provided that it is stored in a manner protected from external events consistent with the current station design. If the flood protection walk-downs performed in response to NTTF Recommendation 2.3 identify a lack of sufficient flood protection margin, the communications assessment should be updated to reflect the potentially lost fuel oil. A regulatory submittal of the updated assessment is not required.

4.1.9. Portable equipment staged for implementation of accident management strategies (e.g., Severe Accident Mitigation Guidance (SAMG) and Extensive Damage Mitigation Guidelines (EDMG) may be used provided it is stored on-site; is reasonably protected from seismic, wind, and flooding events; is maintained through programmatic controls; and has implementing actions specified in existing procedures or guidelines. This includes use of portable AC and DC power sources.

4.1.10. On-site communications infrastructure remains available provided that the credited components are reasonably protected from seismic, wind, and flooding events; maintained through programmatic controls; have a power source consistent with the other assumptions in this section; and employed in accordance with implementing actions specified in existing procedures or guidelines.

4.1.11. Offsite infrastructure supporting communications systems is inoperable in the area surrounding the site (e.g., cellular telephone or off premise extensions (OPXs), telephone central office buildings, telephone lines, etc.). A licensee has two options for determining the affected area.

" Apply a default distance value, in all directions, of approximately 25 miles from the plant site, OR

" Develop a site-specific distance assumption and document the basis.

3 to AEP-NRC-2012-83 Communications infrastructure in locations beyond the area defined above is not-significantly impacted by the event.

4.1.12. Communications equipment located at an offsite response facility, and supplied from a backup power source, is assumed to be functional. The availability of this equipment must be determined in conjunction with Assumption 4.1.11, above. For example, a diesel generator-powered satellite telephone system at an Emergency Operations Center (EOC) located 4 miles from the plant would be available since the system does not rely upon ground-based communications infrastructure within the affected area. A land-line telephone in the same EOC would not be available due to local infrastructure impacts consistent with Assumption 4.1.10.

5.0 Assessment Summary Appendix A provides the assessment in tabular form.

The in-plant radio system is used extensively for a variety of emergency response purposes, including equipment operation, fire brigade, in-plant monitoring, etc. Under normal conditions, the in-plant radio system uses repeaters to ensure radio coverage throughout the plant. In addition, if the repeaters are not available due to loss of AC power, the radios can be operated for point-to-point communications, which may not ensure coverage throughout all areas of the plant. The public address (PA) and the voice powered phone system provide alternatives to the radios.

Communications with the off-site response organizations (OROs) utilize the on-site public branch exchange (PBX) telephone system and the public switched telephone network (PSTN). The Control Room currently has two direct outside lines to the PSTN that automatically bypass the PBX if it is out of service. These lines are not aerial during any portion of their route. However, as previouslydiscussed, the PSTN is assumed to be non-functional for purposes of this assessment. In the event of land-line telephone unavailability, communications can be carried out using the plant 450 MHz radios.

Assuming that the on-site repeater is unavailable, radio communications will be limited based upon line of sight and radio power. Additional communications capability is being provided by satellite telephones. Satellite telephones will be distributed to the State of Michigan, Berrien County Sheriff's Department and the Lake Township Fire Department.

Field Teams dispatched from the site use the 450 MHz radio system to communicate with the Emergency Operations Facility (EOF). The radios in the vehicles are powered by the vehicle's electrical system. With the postulated loss of AC power to the on-site repeater, these radios will be limited to point-to-point communications. Although this will limit the range, the teams can still be effective for providing measurements for dose projection tasks within limited distances from the site. As a backup to the radios, cell phones are provided for each vehicle. Again, based on the assumptions used for the assessment, the cell phone infrastructure is considered to be out of service. Satellite 4

to AEP-NRC-2012-83 telephones have been purchased and received at the site and will be provided to the Field Team vehicles.

6. Recommendations Recommendations to further evaluate or enhance communications capabilities were developed as a part of the assessment.

6.1 Supplement direct telephone lines linking the CNP Emergency Facilities to the Lake Township Fire Department and the Berrien County and State of Michigan Emergency Operations Centers with satellite phones for the postulated loss of the public phone system infrastructure.

6.2 Evaluate off-site radio communications including:

a) Ability of existing 450 MHz trunked radios to function in "point-to-point" mode.

b) Mapping of radio reception in the Emergency Planning Zone (EPZ) and to the EOCs without the repeater in service.

c) Reasonable assurance of survivability for the off-site radio repeater and antennae.

The following actions related to communications will be evaluated as a part of CNP's mitigation strategies for beyond-design-basis events (FLEX) strategy:

6.3 Determine feasibility for the following future actions associated with FLEX:

1. Provide additional battery backup for the PA system.
2. Provide capability for hooking up alternate power generator for the intra-plant 450 MHz radio system
3. Provide capability for hooking up alternate power generator for the public address system.
4. Harden exterior antennae to the extent necessary to provide reasonable assurance of survivability.
5. Provide survivable offsite 450 MHz radio system (including repeater and antennae) or portable repeater equipment.

6.4 Provide alternate power supplies for the following locations (assuming survivability):

a) EOF, which also has an existing diesel generator b) Operations Support Center (OSC) 6.5 Provide standalone uninterruptible power supply (UPS) units for equipment in the Emergency Operations Facility (EOF) and Technical Support Center (TSC) that 5

to AEP-NRC-2012-83 is needed to manage the emergency (computers, multi-line telephones and portable phones).

6.6 Provide a dedicated source of backup power (portable generator) for charging batteries for handheld radios.

6.7 Update training programs to address emergency communications equipment consistent with implementation of FLEX.

7. References 7.1. Cook Emergency Plan, Revision 30.

7.2. Emergency Plan Implementing Procedure PMP-2080-EPP-100, Emergency Response, Revision 22.

7.3. Emergency Plan Implementing Procedure RMT-2080-EOF-001, Activation and Operation of the EOF, Revision 19.

7.4. Emergency Plan Implementing Procedure RMT-2080-ENC/JIC-001, Activation and Operation of the ENC/JIC, Revision 4.

7.5. Emergency Plan Implementing Procedure RMT-2080-OSC-001, Activation and Operation of the OSC, Revision 12.

7.6. Emergency Plan Implementing Procedure RMT-2080-TSC-001, Activation and Operation of the TSC, Revision 16.

7.7. NEI Template. Communications During an Extended Loss of AC Power Roll-Up Document. Revision 1, August 2012.

7.8. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, May 2012.

7.9 Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.

6 to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems (Current Capabilities including Satellite Phone Implementation)

Communications Systems/Equipment (with Emergency Plan Alternate methods System/Equipment Description/Application cross-reference where applicable)

PA System

  • PBX Telephone System For all emergency classifications, all personnel within the Protected Area are notified of an emergency by recognizable Cook Emergency Plan (CEP),
  • Commercial Telephone alarms and/or verbal announcements over the plant PA Section F-Emergency System System. The PA system can be used by individuals in the Communications plant through PA system phones located in various plant
  • ERO Pagers areas.

Emergency Plan Implementing Procedure (EPIP) PMP-2080-

  • Company Intranet EPP-100, Emergency Response, messages paragraph 1.3
  • Company e-mail
  • Voice Powered Phones
  • Handheld radios (450 MHz)
  • Handheld bullhorns 7

to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems (Current Capabilities including Satellite Phone Implementation)

Communications Systems/Equipment (with Emergency Plan Alternate methods System/Equipment Description/Application cross-reference where applicable)

Plant PBX Telephone System

  • Commercial Telephone The PBX telephone system provides communication dSystem capability between telephones located within the plant by CEP FAA Sdialing the last four digits of the commercial phone number.
  • Cellular telephones (Not and Operations Support Center (OSC). The PBX telephone in the Emergency Plan) system also provides for outside communications through interconnections with the commercial telephone lines. There
  • Plant System Pagers are currently 2 PBX locations. These are located in the Lakeside Office Building and Training Center. Both PBXs are equipped with backup batteries.

Wide Area Fiber Optic System 0 Cellular telephones (Not This system provides communications connectivity to (Not in the Emergency Plan) in the Emergency Plan) extensions at CNP for communication with the CNP Emergency Response Facilities (ERF), Lake Township Fire 0 Satellite Phones (Not in Department, Berrien County Emergency Operations Center, the Emergency Plan) and the Michigan State Emergency Operations Center.

Commercial Telephone System 0 Cellular telephones (Not This system provides standard commercial telephone service din the Emergency Plan) through the public infrastructure, consisting of central offices CEP FAd iand the fiber line and microwave carrier. The commercial

  • Satellite Phones (Not in telephone system includes connections to PBX, emergency the Emergency Plan) telephone system, dedicated lines to CNP ERFs and the Berrien County 911 Dispatcher. The commercial vendor provides primary and secondary power for their lines at their central office (CO).

8

Enclosure 2 to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems (Current Capabilities including Satellite Phone Implementation)

Communications Systems/Equipment (with Emergency Plan Alternate methods System/Equipment Description/Application cross-reference where applicable)

Other telephones 0 PBX There are two telephone lines in each Control Room that automatically bypass the plant PBX if it fails.

CEP, F.A.d

Nuclear Emergency Alarm ° PA Announcements For all emergency classifications, all personnel within the System Protected Area, buildings in the Owner Controlled Area and

° Pagers the Buchanan Office Building are notified of an emergency by EPIP PMP-2080-EPP-100, recognizable alarms and/or verbal announcements over the Emergency Response,

  • Handheld bullhorns plant PA System. The evacuation alarm is generated by a

-paragraph 1.3 solid state multi-frequency audio oscillator capable of producing distinctive tones which can be heard over all plant paging zones via the plant paging system.

Ring Down Telephone Commercial Telephone Point to Point phones connected through the PBX and are "conference lines" that automatically ring when any one of the EPIP PMP-2080-EPP-100, System receivers is picked up. The direct lines are located in both Emergency Response, 0 Satellite Phones (Not in Control Rooms, Central Alarm Station, Secondary Alarm Attachment 12 (Berrien County the Emergency Plan) Station, the EOF, and the Berrien County 911 Dispatcher.

Sheriff Notification).

RMT-2800-EOF-001, Activation and Operation of the EOF, Attachment 16 (County Communications) 9 to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems Current Capabilities including Satellite Phone Implementation)

Communications Systems/Equipment (with Emergency Plan Alternate methods System/Equipment Description/Application cross-reference where applicable)

NRC Communications

) ETS Plant Telephone System Communications with the NRC Operations Center will be (ENS & HPN) performed via the NRC Emergency Notification System (ENS)

  • Commercial Telephone and Health Physics Network (HPN) circuits on the commercial CEP, F.1.f System telephone line. Information is normally communicated from an ERO-approved member prior to establishing an open ENS
  • Cellular telephones (Not and/or HPN line.

in the Emergency Plan)

ENS: Dedicated telephone equipment is in place between Control Room and the NRC, with an extension of that line in the TSC and EOF.

HPN: There is a separate dedicated telephone between the NRC, the TSC, and EOF for conveying health physics information to the NRC as requested or as an open line. In addition, NRC counterpart lines are located in the Control Room, TSC and EOF.

10 to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems (Current Capabilities including Satellite Phone Implementation)

Communications Systems/Equipment (with Emergency Plan Alternate methods System/Equipment Description/Application cross-reference where applicable)

Facsimile (Fax) Communications 0 Commercial Telephone Fax communications capability is provided via the PBX 3System telephone system between the Control Rooms, CNP ERFs, CEP Hd H.2.d and H.3.d SyState of Michigan, and Berrien County Sheriff's offices.

lnternet/WebEOC (Not in EPIP PMP-2080-EPP-100, the Emergency Plan)

Emergency Response, Attachments: 11 (MSP 0 Satellite Phones (Not in Notification) and 12 (Berrien the Emergency Plan)

County Sheriff Notification).

EPIP RMT-2080-EOF-001, Activation and Operation of the EOF, Attachments: 15 (MSP Notification) and 16 (Berrien County Sheriff Notification).

ERO Pagers (Call Out) 0 ERO Pagers Paging is done at CNP through a commercial provider.

Telephones can also be used as a backup. The paging EPIP PMP-2080-EPP-100,

  • Commercial Telephone provider maintains antennas on local communications towers.

Emergency Response, System paragraph 3.1.9 0 Cell Phones (Not in the Emergency Plan)

Cellular Telephones 0 Commercial telephone This system provides standard commercial telephone service asystem through the public infrastructure consisting of central offices, Not in Emergency Plan sthe fiber line, microwave carrier, and commercial cell phone towers and repeaters.

11 to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems (Current Caoabilities including Satellite Phone IMolementation)

Communications Systems/Equipment (with Emergency Plan Alternate methods System/Equipment Description/Application cross-reference where applicable)

Satellite Telephones 0 Plant PBX Telephone Eighteen satellite phones have been purchased. The phones System have not been installed, but have been received and Not part of Emergency Plan programmed.

a Local Commercial Telephone System

Field Monitoring Team Cellular telephones (Not Teams are dispatched from the OSC. Handheld radios are Communications iin the Emergency Plan) used purchasedfor communicating.

and will be installed Satellite phones have Team been in both Field Monitoring CEP F.1.d vehicles.

12 to AEP-NRC-2012-83 Appendix A - Assessment Table 2 Emergency Response Communication Systems - Hazard Analysis (Current Capabilities including Satellite Phone Im lementation)

System/Equipment Primary System Protected from Protected from Protected from (with Emergency Plan cross-reference Simca Component defined in Flooding as defined Wind as defined Comments wherea ce Location ned1- in NEI 12-01 in NEI 12-01 where applicable) NEI 12-01 PA system / Various plant Yes Yes Yes Powered from essential Emergency locations power bus.

Evacuation Alarm System EPIP PMP-2080-EPP-100, Emergency Response, paragraph 1.3 PBX Telephone Lakeside Office No No No No protection System Building and enhancements currently Training Center planned CEP, F.A.d Commercial Interface No No No Some phone lines are Telephone System equipment direct in dialing. These (Fiber to Central phones bypass the PBX CEP, F.1.d Offices (CO). and go directly to Lakeside Office locations within the plant.

Building and Powered by the PSTN CO Training Center)

Other telephone lines Lakeside Office Yes Yes Yes There are two telephone Building and lines in each Control CEP F.1.d Training Center Room that automatically bypass the plant PBX if it fails.

13 to AEP-NRC-2012-83 Appendix A - Assessment Table 2 Emergency Response Communication Systems - Hazard Analysis (Current Capabilities including Satellite Phone Im lementation)

System/Equipment Primary System Protected from Protected from Protected from (with Emergency Component Seismic as Flooding as defined Wind as defined Comments Location defined in in NEI 12-01 in NEI 12-01 where applicable) NEI 12-01 Nuclear Emergency Various plant Yes Yes Yes Powered from essential Alarm System locations plant bus.

EPIP PMP-2080-EPP-100, Emergency Response, paragraph 1.3 Ring Down Telephone Both Control No No No Point to point phones are Rooms, Central connected through the EPIP PMP-2080- Alarm Station, PBX. They are EPP-100, Emergency Secondary "conference lines" that Response, Alarm Station, automatically ring when Attachment 12 EOF, and 911 any one of the receivers (Berrien County dispatch are picked up. The direct Sheriff Notification). lines are located in both Control Rooms, Central RT-2080-EOF-001, Alarm Station, Secondary Activation & Alarm Station, the EOF, Operation of the EOF, and the Berrien County Attachment 16 911 dispatcher.

(County Communications)

NRC Communications Control Rooms Yes Yes Yes Powered from the CO.

(ENS & HPN) Phone TSC Yes Yes Yes Additional NRC Lines are Line/Circuit EOF No No No provided (counterpart lines).

CEP, F.1.f 14 to AEP-NRC-2012-83 Appendix A - Assessment Table 2 Emergency Response Communication Systems - Hazard Analysis (Current Capabilities including Satellite Phone Implementation)

System/Equipment Primary System Protected from Protected from Protected from (with Emergency Component Seismic as Flooding as defined Wind as defined Comments Location in NEI 12-01 in NEI 12-01 where applicable) NEI 12-01 Facsimile (Fax) Control Rooms Yes Yes Yes Message sent via PBX Communications - TSC Yes Yes Yes EOF/OSC, No No No CEP H.l.d, H.2.d and ENC/JIC H.3.d EPIP PMP-2080-EPP-100, Emergency Response, Attachments: 11 (MSP Notification) and 12 (Berrien County Sheriff Notification)

EPIP RMT-2080-EOF-001, Activation and Operation of the EOF, Attachments: 15 (MSP Notification) and 16 (Berrien County Sheriff Notification).

15 to AEP-NRC-2012-83 Appendix A - Assessment Table 2 Emergency Response Communication Systems - Hazard Analysis (Current Capabilities including Satellite Phone Im lementation)

System/Equipment Primary System Protected from Protected from Protected from (with Emergency Plan Simca cross-reference Component defined in Flooding as defined Wind as defined Comments Location in NEI 12-01 in NEI 12-01 where applicable) NEI 12-01 ERO Pagers (Call OPX No No No Paging is done by CNP Out) through a commercial provider. Telephones can also be used as a backup.

The paging provider maintains antenna on local communications towers. The commercial towers have been designed for severe weather and are equipped with an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery Cellular Telephones Various No No No The Microwave tower has been designed for severe Not in Emergency weather and is equipped Plan with 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> batteries.

Satellite Telephones Control Rooms Yes Yes Yes Battery Powered. Extra batteries and chargers are Not in Emergency CNP ERFs No No No available.

Plan 16 to AEP-NRC-2012-83 Appendix A - Assessment Table 2 Emergency Response Communication Systems - Hazard Analysis (Current Capabilities including Satellite Phone Im lementation)

System/Equipment Primary System Protected from Protected from Protected from (with Emergency Plan crossrEmergency Cmoet dfndi n Component Sefinmic aFlooding as defined Wind as defined Comments cross-reference Location in NEI 12-01 in NEI 12-01 where applicable) NEI 12-01 Field Monitoring EOF/ EP No No No Teams dispatched from Team Vehicles OSC. Handheld radios are Communications used for communicating.

Field Teams also have cell CEP, F.A.d phones. Satellite phones will be installed in both Field Monitoring Team vehicles.

Diesel Fuel Oil Use existing To be To be determined To be Will be evaluated as a part Storage Areas used diesel fuel oil determined determined of CNP's mitigation for fueling portable storage tanks strategies for beyond-equipment used for design -basis external communications events (FLEX) strategy Not in Emergency Plan 17 to AEP-NRC-2012-83 Appendix A - Assessment Table 3 Emergency Response Communication Systems - Power Supply Analysis (Current Capabilities including Satellite Phone Implementation)

System/Equipment Primary Power Alternate Power Backup power Comments (with Emergency Plan Supply (List the Supply (List the availability (e.g.,

cross-reference where power source) power source) batteries, portable applicable) generators, etc.)

Yes/No Public Address (PA) Critical Control Emergency Yes -Battery No power supply enhancements currently System Room Power Diesel backup planned.

CEP F.1.e Plant PBX Telephone Battery Yes - battery Yes - battery No power supply enhancements currently System backup backup planned.

CEP F.1.e Commercial Telephone PBX Yes - Battery Yes - Battery There are two PBX locations. One is System backup backup located in the Lakeside Office Building and the other is in the Training Center.

CEP F.A.d Plant Radio Transmitter- OPX Emergency Yes - Battery System uses repeaters, satellite receivers Receiver System Diesel backup and comparators inside the plant. One additional repeater for offsite CEP F.A.d communication is located at the OPX and has battery and generator backup Other telephone lines CO CO Yes There are two telephone lines in each Control Room that automatically bypass CEP F.1.d the plant PBX ifit fails.

Nuclear Emergency Critical Control Emergency Yes - battery No power supply enhancements currently Alarm System Room power diesel backup planned.

EPIP PMP-2080-EPP-100, Emergency Response, paragraph 1.3 18 to AEP-NRC-2012-83 Appendix A - Assessment Table 3 Emergency Response Communication Systems - Power Supply Analysis (Current Ca pabilities including Satellite Phone Implementation)

System/Equipment Primary Power Alternate Power Backup power Comments (with Emergency Plan Supply (List the Supply (List the availability (e.g.,

cross-reference where power source) power source) batteries, portable applicable) generators, etc.)

Yes/No Ring Down Telephone PBX CO Yes The Ring Down phones are Point to Point Lines phones connected through the PBX and are "conference lines" that automatically EPIP PMP-2080-EPP- ring when any one of the receivers is 100, Emergency picked up. The direct lines are located in Response, Attachment both Control Rooms, Central Alarm 12 (Berrien County Station, Secondary Alarm Station, the Sheriff Notification). EOF, and the Berrien County 911 Dispatcher.

RT-2080-EOF-001, Activation & Operation of the EOF, Attachment 16 (County Communications)

NRC Communications CO Unknown Unknown No power supply enhancements currently planned.

Facsimile PBX Battery back-up Battery back-up Uses PBX & PSTN Communications CEP H.l.d, H.2.d and H.3.d 19 to AEP-NRC-2012-83 Appendix A - Assessment Table 3 Emergency Response Communication Systems - Power Supply Analysis (Current Ca abilities includina Satellite Phone Implementation)

System/Equipment Primary Power Alternate Power Backup power Comments (with Emergency Plan Supply (List the Supply (List the availability (e.g.,

cross-reference where power source) power source) batteries, portable applicable) generators, etc.)

Yes/No ERO Pagers (Call Out) OPX No Diesel generator Paging is done by CNP through a and Battery commercial provider. Telephones can also EPIP PMP-2080-EPP- be used as a backup. The paging provider 100, Emergency maintains antennas on local Response, paragraph communications towers. The commercial

.3.2.4 towers have been designed for severe weather and are equipped with an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery.

Cellular Telephones Cell Phone AC Outlet No Eighteen satellite phones have been Battery purchased and will be located in both Not in Emergency Plan Control Rooms, Security (x4: Central Alarm Station, Secondary Alarm Station, and 2 mobile), TSC, Onsite Survey Teams (x2), EOF (x3: State Communicator, Incident Command Post, and Field Team Communicator), Offsite Survey TeamsNehicles (2), Lake Township Fire Department, and the Berrien County and State of Michigan Emergency Operations Centers.

20 to AEP-NRC-2012-83 Appendix A - Assessment Table 3 Emergency Response Communication Systems - Power Supply Analysis (Current Capabilities including Satellite Phone Implementation)

System/Equipment Primary Power Alternate Power Backup power Comments (with Emergency Plan Supply (List the Supply (List the availability (e.g.,

cross-reference where power source) power source) batteries, portable applicable) generators, etc.)

Yes/No Satellite Telephones Battery Additional Yes, portable Eighteen satellite phones have been powered, batteries generators purchased and will be located in both Not in Emergency Plan recharges at Control Rooms, Security (x4: Central local power Alarm Station, Secondary Alarm Station, outlet and 2 mobile), TSC, Onsite Survey Teams (x2), EOF (x3: State Communicator, Incident Command Post, and Field Team Communicator), Offsite Survey TeamsNehicles (2), Lake Township Fire Department, and the Berrien County and State of Michigan Emergency Operations Centers.

Field Monitoring Team Battery Additional Yes, portable Portable generators are currently located Communications powered, batteries generators at the Bridgman material Center recharges at approximately 5 miles from the plant.

CEP F.1.d local power outlet 21 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up NEI 12-01 Revision 0 (May 2012) 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.1 REQUIRED EMERGENCY COMMUNICATIONS CAPABILITIES Consistent with emergency planning standard requirements, communications systems and equipment associated with the following emergency response functions should be available during an extended loss of AC power. Availability should be determined after a review of existing capabilities and consistent with the assumptions listed in NEI 12-01, Rev. 0, Section 2. In particular, it is important that the primary and backup (if applicable) power source for each communications system or piece of equipment be identified.

End-point equipment identified for a communications link listed below should be used solely for the purpose indicated. For example, a satellite telephone assigned to the Control Room should not be credited for performing both Offsite Response Organization (ORO) and NRC notifications. When performing this assessment, consideration should be given to the desirability of providing some communications capabilities in alternate facilities at offsite locations instead of their normal locations in on-site facilities.

4.1.1 Notifications to, and communications with, OROs [per 10 CFR 50, Appendix E.IV.D and E.9.a]

Primary Method Backup Available -Backup Method(s) Planned or Refer to Emergency Minimum Primary Method following Method(s) Available Potential Following Section for Additional E-Planin site Response Facility Communications Described Assumed Large-Scale E-Planin site Described following Assumed Improvement Identified? Information Links Natural Event LSNE?

(LSNE)?

CEP Room 1 per Control Room Direct Phone No PSTN None Satellite Phone 5.1 CEP FAAd1pe otrlRo Line EOF Direct Phone 1 for the EOF Di ne No PSTN None Satellite Phone 5.1 CEP F..d Line 22 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.2 Notifications to, and communications with, the Nuclear Regulatory Commission (NRC) Headquarters Incident Response Center and the appropriate NRC Regional Office Operations Center [per 10 CFR 50, Appendix E.IV.D and E.9.d]

Primary Method Backup Backup Method(s) Planned or Refer to EmergencyMinimum Primary Method Available Method(s) Available Potential Following Section ResponsenFacity Communications Described in site following Described in site following Improvement for Additional Response Facility Links E-Plan Assumed E-Plan Assumed Identified? Information LSNE? LSNE?

Control Room 1 per Control Room FTS No PSTN None Satellite Phone 5.2 for ENS CEP F.l.d Communicator TSC 1 for ENS and HPN FTS No PSTN None Satellite Phone 5.2 Communicator CEP F.1.d EOF 1 for ENS and HPN FTS No PSTN None Satellite Phone 5.2 Communicator CEP F.1.d 23 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.3 Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E.9.c. Additional links that support performance of critical response functions are also specified.] The minimum communications links to support this function are listed below by facility. For example, if the normally used telephone system cannot be restored to service, these links could rely upon some combination of radio, Voice powered and satellite-based communications systems.

Emergency Minimum Primary Method Primary Backup Backup Planned or Refer to Response Facility Communications Links Described in site Method Method(s) Method(s) Potential Following E-Plan Available Described in Available Improvement Section for following site E-Plan following Identified? Additional Assumed Assumed Information LSNE? LSNE?

Control Room 2 per unit PBX / PA system and PA system and PA system and Satellite Phones 5.3 Commercial handheld handheld radios handheld radios CEP F.A.d Phone Lines and radios PA system------

TSC 1 each for: PBX / PA system and PA system and PA system and Satellite Phones 5.3 Commercial handheld handheld radios handheld radios Site Emergency Phone Lines and radios Emergency Coordinator PA system

Response

Organization Radiological Directory Section Assessment 7 (Emergency Coordinator Phone Numbers),

Section 8 Plant Evaluation Team (Emergency Plan Phone Use Key & TSC Security Director Facility Maps) and Section 9 Board Writer (Communications in the ERO) 24 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up Emergency Minimum Primary Method Primary Backup Backup Planned or Refer to Response Facility Communications Links Described in site Method Method(s) Method(s) Potential Following E-Plan Available Described in Available Improvement Section for following site E-Plan following Identified? Additional Assumed Assumed Information LSNE? LSNE?

OSC 1 each for: PBX / PA system and PA system and PA system and Satellite Phones 5.3 Commercial handheld handheld radios handheld radios OSC Manager Phone Lines and radios Emergency Rmesponse PA system Response Radiation Protection Organization Director Directory Section 7 (Emergency Board Writer Phone Numbers),

Section 8 (Emergency Plan Phone Use Key &

Facility Maps) and Section 9 (Communications in the ERO)

EOF 1 each for: PBX / Handheld Handheld None Satellite Phones 5.3 Commercial radios radios Emergency Emergency Director Phone Lines and

Response

Organization Operations Advisor handheld radio Directory Section Dose Assessment 7 (Emergency Phone Numbers), Reactor Physics Section 8 Analyst (Emergency Plan Board Writer Phone Use Key &

Facility Maps) and Section 9 (Communications in the ERO) 25 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up Emergency Minimum Primary Method Primary Backup Backup Planned or Refer to Response Facility Communications Links Described in site Method Method(s) Method(s) Potential Following E-Plan Available Described in Available Improvement Section for following site E-Plan following Identified? Additional Assumed Assumed Information LSNE? LSNE?

Emergency News 1 each for: PBX / None None None TBD N/A Center (ENC) / Commercial Joint Information Media Center Manager Phone Lines Center (JIC)

Technical Communicator EPIP RMT-2080-ENC/JIC-001, Activation and Operation of the ENC/JIC 26 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.4 Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix E.9.c]

Emergency Minimum Primary Method Primary Method Backup Backup Planned or Refer to Response Communications Described in site Available Method(s) Method(s) Potential Following Facility Links E-Plan following Described in site Available Improvement Section for Assumed E-Plan following Identified? Additional LSNE? Assumed Information LSNE?

EOF 1 for each Handheld Radio Yes, Limited to None None Satellite Phones 5.5 field/offsite radio reception monitoring team without CEP H.2.d repeaters OSC 1 for each Handheld Radio Yes, Limited to None - EOF None Satellite Phones 5.5 Primary location field/offsite radio reception assumes from which field/ monitoring team without command and offsite monitoring repeaters control after teams are dispatched.

deployed EPIP RMT-2080-OSC-001, Activation and Operation of the OSC Attachment 6, Briefing Checklist 27 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.5 Communications with other Federal agencies as described in the site emergency plan (e.g., the US Coast Guard) [per 10 CFR 50 Appendix E.9.b]

Emergency Minimum Primary Method Primary Method Backup Backup Planned or Refer to Response Facility Communications Described in site Available Method(s) Method(s) Potential Following Links E-Plan following Described in site Available Improvement Section for Assumed E-Plan following Identified? Additional LSNE? Assumed Information LSNE?

Primary location Coordination with FTS, PSTN No PSTN None Satellite phones 5.2 where Federal agencies communication with Federal agencies is performed Emergency

Response

Organization Directory Section 8 (Emergency Plan Phone Use Key &

Facility Maps) 28 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.6 Coordination and direction of on-site and in-plant response teams. This includes teams necessary to affect emergency repairs, firefighting, search and rescue, radiological monitoring, and implementation of Transition Phase coping and severe accident management strategies. To accommodate the timeline associated with NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (as discussed in Section 1), this element should be assessed in 2 phases.

4.1.6.1 Phase 1 Assessment Emergency Minimum Primary Method Primary Method Backup Backup Planned or Refer to Response Facility Communications Described in site Available Method(s) Method(s) Potential Following Links E-Plan following Described in site Available Improvement Section for Assumed E-Plan following Identified? Additional LSNE? Assumed Information LSNE?

On-shift staff Number necessary for the on-shift staff PA, handheld PA, handheld Yes - Voice CEP Table B-1 to perform Initial radios and voice radios and Voice Powered (CNP Staffing for Phase coping Powered Yes Powered Phones and Satellite phones Note 1 Radiological actions (reflecting telephones- telephones handheld Emergencies current staff & radios) strategies) 1 each for:

- On-site radiological OSC and other monitoring site-specific locations as 2 each for: Yes - Voice necessary (The - Firefighting (1 for PA and PA and Powered Fire Brigade and brigade leader and 1 handheld radios Yes handheld Phones and Satellite phones 5.3 Work It Now for OPS handheld (WIN) Team). representative) radios)

CEP F.1.f 1 each per unit for:

- WIN Team 29 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.6.2 Phase 2 Assessment Emergency Minimum Primary Method Primary Method Backup Backup Planned or Refer to Response Communications Described in site Available Method(s) Method(s) Potential Following Section Facility Links E-Plan following Described in site Available Improvement for Additional Assumed E-Plan following Identified? Information LSNE? Assumed LSNE?

Site-specific number PA, handheld Yes PA and Yes - Voice Satellite phones Note 1 needed to implement radios and Voice handheld radios Powered any 2 strategies Powered Phones and OSC and other developedtoinNRC telephones handheld radios) site-specific response locations as repnet R locatosasy. Order Modifying necessary. Licenses with Regard to Requirements for CEP F.1.f Mitigation Strategies for Beyond-Design-Basis External Events 4.2 Plant Paging (Announcement) System The plant paging system is powered from a battery-backed source and would remain available to provide the initial emergency declaration and direction announcement to plant staff. No further action is required.

30 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.3 Communications Equipment at ORO Facilities Primary Backup Refer to Minimum Primary Method Method Backup Method(s) Planned or Following Emergency minimum Pribedyinethod Available Method(s) Available Potential Section for Response Facility Links E-Plan following Described in following Improvement Additional Assumed site E-Plan Assumed Identified?

LSNE? LSEE? Information Location where At least one. See Commercial No PSTN No Satellite phones 5.7 OROs receive assumptions and phone lines and notifications of an discussion in facsimile emergency NEI 12-01.

declaration or a Protective Action Recommendation (as described in the site emergency plan).

CEP F.1.a EPIP PMP-2080-EPP-1 00, Emergency

Response, Attachments: 11 (MSP Notification) and 12 (Berrien County Sheriff Notification).

EPIP RMT-2080-EOF-001, Activation and Operation of the EOF, Attachments:

15 (MSP Notification) and 16 (Berrien County Sheriff Notification).

31 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.4 NOTIFICATION OF THE EMERGENCY RESPONSE ORGANIZATION (ERO) Emergency Plan Implementing Procedure PMP-2080-EPP-100, Emergency Response, paragraph 3.2.4 The ERO is notified using pagers. The Control Room initiates the notification process through a commercial provider. Telephones are used as a backup to the pagers. The paging provider maintains antennas on local communications towers. These systems are considered to be unavailable under the assumptions of this analysis. The ERO will self activate in the event of a large scale natural disaster if they cannot be contacted using the notification process.

4.5 EQUIPMENT LOCATION REQUIREMENTS Voice communications equipment has been determined to be survivable.

Spare radios will be stored consistent with these requirements. Exact locations have not been determined but will be determined upon completion of mitigation strategy for beyond-design-basis external events (FLEX) activities. (See Note 1) 4.6 PERFORMANCE CHARACTERISTICS (Post event with FLEX)

CNP emergency response facilities, including Security, have use of the 450 MHz handheld radios, PA system and satellite phones.

Field/offsite monitoring teams and the location controlling deployment of the teams (e.g., the EOF). Field teams are dispatched from the OSC and utilize handheld radios as the primary communications mode. They have cell phones and will also have satellite telephones as a backup.

The Shift Communicator, TSC and EOF Communicators, and the ORO contact points will communicate with a combination of radios and satellite phones.

ENS and HPN communications to the NRC staff are not dependent on site resources. The lines connect directly to the local phone company central office by way of buried conductors/pathways. The site will have satellite phones to use as a backup.

On-site teams and the location controlling deployment of the teams (e.g., the OSC): The OSC will have handheld radios for the dispatch and control of response teams. The Control Room is also equipped with a Voice Powered jack (telephone hand-set type) system and radios.

32 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.7 OTHER ASSESSMENT CONSIDERATIONS All radios and Satellite phones are provided with chargers and spare batteries. Emergency Preparedness vehicles used by the field monitoring teams are equipped with radios powered from the vehicle electrical system.

Batteries for handheld radios have approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of charge. Chargers are locally powered and plans have been made to have a dedicated source of backup power and can be charged from portable generators provided by FLEX.

4.8 PERSONNEL TRAINING Response personnel should receive periodic training on the location and use of communications systems and equipment: Training programs will be updated to address emergency communications equipment consistent with implementation of CNP's mitigation strategy for beyond-design-basis external events (FLEX).

5.0 ADDITIONAL INFORMATION The following actions will be evaluated as a part of CNP's FLEX strategy:

a) Provide additional battery backup for the PA system.

b) Provide capability for hooking up alternate power generator for the intra-plant 450 MHz radio system.

c) Provide capability for hooking up alternate power generator for the public address system.

d) Harden exterior antennae to the extent necessary to provide reasonable assurance of survivability.

e) Provide survivable offsite 450 MHz radio system (including repeater and antennae) or portable repeater equipment.

5.1. Direct lines are provided linking the Emergency Facilities to the Berrien County Emergency Operations Center (BCEOC) and is provided with emergency power by way of an installed diesel generator. There are direct lines from: both Control Rooms, Central Alarm Station, Secondary Alarm Station and the EOF to the 911 dispatcher, which is located in the same building as the BCEOC. These are OPX (off premise extensions) powered by the Plant PBX.

These phones will be supplemented by satellite phones for the postulated loss of the public phone system infrastructure.

5.2. In addition to the ENS and HPN phones, there are two additional phone extensions included in the Control Rooms which are included in the emergency plan. These lines go directly to the local CO via underground transmission and bypass site PBX systems.

5.3. The CEP identifies the available methods of communications available to the various entities and facilities. The communications pathways include telephones, two-way radios, dedicated phones, FTS, Voice powered telephones, and the Public Address system.

5.4 -The Field teams use 450 MHz radios powered from the emergency vehicles. The range of these radios is limited to line of sight without a repeater but near plant readings would be useful in projecting any potential offsite radiation effects. With the use of a portable repeater or hardening of the existing repeater full capability is returned to the radio system.

33 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 5.5 Paging (Public Announcement) System: The plant paging system is powered from an essential power bus. In the event of a loss of offsite power, provisions are made for the bus to automatically "seek" whichever bus is being provided with power from an emergency diesel.

5.6 Communications Equipment at ORO Facilities: The. Berrien County Emergency Operations Center (BCEOC) is provided with emergency power by way of an installed diesel generator. There are direct lines from both Control Rooms, Central Alarm Station, Secondary Alarm Station and the EOF to the 911 dispatcher, which is located in the same building as the BCEOC. These are OPX (off premise extensions) powered by the Plant PBX. These phones will be supplemented by satellite phones for the postulated loss of the public phone system infrastructure.

Note 1: Final planning for FLEX has not been completed, thus information concerning Mitigating Strategies communications requirements and portable emergency generators have not been finalized.

34 to AEP-NRC-2012-83 Implementation Timeline to AEP-NRC-2012-83 Page 1 of 3 Communications Assessment Implementation Timeline Completion Action Comments Date February 28, Supplement direct telephone 2013 lines linking the CNP Emergency Facilities to the Lake Township Fire Department and the Berrien County and State of Michigan Emergency Operations Centers with satellite phones for the postulated loss of the public phone system infrastructure.

October 31, Evaluate capabilities of off-2013 site radio communications including:

1. Verifying the ability of existing 450 MHz trunked radios to function in "point-to-point" mode.
2. Mapping of radio reception in the EPZ and to the Emergency Operation Centers without the repeater in service.
3. Assuring reasonable survivability for the off-site radio repeater and antennae.

to AEP-NRC-2012-83 Page 2 of 3 Communications Assessment Implementation Timeline Completion Action Comments Date July 31, 2014 Determine feasibility for the To be evaluated as a part of CNP's FLEX strategy.

following future actions associated with FLEX:

1. Provide additional battery backup for the PA system.
2. Provide capability for hooking up alternate power generator for the intra-plant 450 MHz radio system.
3. Provide capability for hooking up alternate power generator for the public address system.
4. Harden exterior antennae to the extent necessary to provide reasonable assurance of survivability.
5. Provide survivable offsite 450 MHz radio system (including repeater and antennae) or portable repeater equipment.

September 30, Provide alternate power To be evaluated as a part of CNP's FLEX strategy.

2014 supplies for the following locations (assuming survivability) at a minimum:

1. EOF, which also has an existing diesel generator.
2. OSC to AEP-NRC-2012-83 Page 3 of 3 Communications Assessment Implementation Timeline Completion Action Comments Date September 30, Provide standalone UPS To be evaluated through CNP's FLEX strategy.

2014 units for equipment in the EOF and TSC that will be needed to manage the emergency (computers, multi-line telephones and portable phones).

September 30, Provide a dedicated source To be evaluated through CNP's FLEX strategy.

2014 of backup power (portable generator) for charging batteries for handheld radios.

March 31, 2015 Update training programs to To be performed as a part of the CNP's FLEX address emergency strategy.

communications equipment consistent with implementation of FLEX.

Retrieved from "https://kanterella.com/w/index.php?title=AEP-NRC-2012-83,_Communications_Assessment_Requested_by_Nuclear_Regulatory_Commission_Letter,_Request_for_Information_Pursuant_to_Title_10_of_the_Code_of_Federal_Regulation_50.54(f)_Regarding_Recommendation_2.1,_2.3,_and_9.3.&oldid=2092123"