AEP-NRC-2014-91, Update to Communications Assessment Implementation Actions and Timeline - Fukushima Dai-ichi Near-Term Task Force Recommendation 9.3, Emergency Preparedness

Update to Communications Assessment Implementation Actions and Timeline - Fukushima Dai-ichi Near-Term Task Force Recommendation 9.3, Emergency Preparedness

ML14352A250
Person / Time
Site:	Cook
Issue date:	12/16/2014
From:	Gebbie J American Electric Power, Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2014-91, EP-NRC-2014-91
Download: ML14352A250 (10)

Text

INDIAN_ Indiana Michigan Power MICHIGAN Cook Nuclear Plant POWER One Cook Place Bridgman, MI 49106 A unitof American ElectricPower India naMichigan Power.com December 16, 2014 AEP-NRC-2014-91 10 CFR 50.54(f)

Docket No.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Donald C. Cook Nuclear Plant Units 1 and 2 Update to Communications Assessment Implementation Actions and Timeline - Fukushima Dai-ichi Near-Term Task Force Recommendation 9.3, "Emergency Preparedness"

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, Agencywide Documents Access Management Systems (ADAMS) Accession No. ML12056A046.

2. Letter from J. P. Gebbie, Indiana Michigan Power Company (A&M), to NRC, "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 Dai-ichi Accident; dated March 12, 2012," AEP-NRC-2012-34, dated May 11, 2012, ADAMS Accession No. ML12142A110.

3. Letter from P. S. Tam, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - 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, ADAMS Accession No. ML12145A640.

U. S. Nuclear Regulatory Commission EP-NRC-2014-91 Page 2

4. Letter from M. H. Carlson, I&M, to the NRC, "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 Dai-ichi Accident,' dated March 12, 2012," AEP-NRC-2012-83, dated October 31, 2012, ADAMS Accession No. ML12318A176.

5. Letter from T. J. Wengert, NRC, to L. J. Weber, I&M, " Donald C. Cook Nuclear Plant, Units 1 And 2 - Staff Assessment in Response to Recommendation 9.3 of The Near Term Task Force Related to the Fukushima Dai-ichi Nuclear Power Plant Accident (TAC Nos. ME9950 and ME9951)," dated June 6, 2013, ADAMS Accession No. ML13148A294.

By Reference 1, the U. S. Nuclear Regulatory Commission (NRC) requested that licensees provide an assessment of their current communications systems and equipment used during an emergency event to identify any enhancements that may be needed to ensure communications are maintained during a large scale natural event resulting in a loss of all alternating current power. By Reference 2, Indiana Michigan Power Company (I&M) provided a response to the Reference 1 Request for Information. I&M's response proposed an alternative course of action and estimated completion date for the Donald C. Cook Nuclear Plant (CNP), Unit 1 and Unit 2. By Reference 3, the NRC approved the alternative course of action. By Reference 4, I&M transmitted the communication assessment performed in accordance with the approved alternative.

The communication assessment identified recommendations to further evaluate or enhance the CNP communications capabilities, and identified actions to be evaluated as part of the mitigation strategies for beyond design basis events. Enclosure 3 of Reference 4 provided an implementation timeline for the recommended evaluations and enhancements. Reference 5 transmitted an NRC Safety Assessment which included a review of the enhancements. The Safety Assessment documented the NRC staff's conclusion that the enhancements, in conjunction with other communication system attributes, would help ensure that communications are maintained. As tabulated in Enclosure 2 to this letter, I&M has either completed the recommended communications enhancement or determined that the enhancement is not needed. I&M considers that the conclusion documented in Reference 5 remains valid. to this letter provides an affirmation. Enclosure 2 provides the updated enhancement 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, Joel P. Gebbie Site Vice President JRW/amp

U. S. Nuclear Regulatory Commission EP-NRC-2014-91 Page 3

Enclosures:

1. Affirmation

2. Updated Implementation Timeline c: M. L. Chawla, NRC Washington, DC J. T. King, MPSC, w/o enclosures E. J. Leeds, NRR, NRC MDEQ - RMD/RPS NRC Resident Inspector C. D. Pederson, NRC Region III A. J. Williamson, AEP Ft. Wayne, w/o enclosures

Enclosure 1 to AEP-NRC-2014-91 AFFIRMATION I, Joel P. Gebbie, being duly sworn, state that I am Site Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this document with the U. S.

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 Joel P. Gebbie Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS JL4DAY OF ý_.Pp r-j h C , 2014 MC s Notan Public My Commission Expires r3 Ilw1*3 \g to AEP-NRC-2014-91 Updated Implementation Timeline to AEP-NRC-2014-91 Page 1 The following table provides an updated status for the Donald C. Cook Nuclear Plant (CNP) Communication Assessment recommended enhancements presented in Enclosure 3, "Communications Assessment Implementation Timeline," of the letter from M. H. Carlson, Indiana Michigan Power Company (I&M), to U. S. Nuclear Regulatory Commission (NRC), dated October 31, 2012, Agencywide Documents Access Management Systems Accession No. ML12318A176.

Communications Assessment Implementation Timeline Recommendation Stated in I&M Letter Updated Status dated October 31, 2012 Updated Status Supplement direct telephone lines linking Complete as Stated - Satellite phones are available to provide offsite communication.

the CNP Emergency Facilities to the The satellite phones are periodically checked to assure their availability for Berrien County Emergency Operations communication among key emergency response functions including the BCEOC, the Center (BCEOC) with satellite phones for Lake Township Fire Department, the Emergency Operations Facility (EOF), the the postulated loss of the public phone Technical Support Center (TSC), offsite survey teams, onsite survey teams, security, system infrastructure, and the Shift Manager complex.

Evaluate capabilities of offsite radio communications including:

1. Verifying the ability of existing 450 Complete as Modified - As noted above, satellite phones are available to provide Megahertz (MHz) trunked radios to offsite communication. Therefore, the 450 Mhz portable radios need not be part of a function in "point-to-point" mode. trunked radio system. However, these radios do have the capability of communicating point-to-point.

2. Mapping of radio reception in the Not Needed - As noted above, satellite phones are available to provide offsite Emergency Planning Zone (EPZ) and communication. Therefore, mapping of radio reception in the EPZ and to the to the Emergency Operation Centers Emergency Operation Centers without the repeater in service is not necessary to without the repeater in service. support the FLEX strategies.

3. Assuring the survivability for the offsite Not Needed - As noted above, satellite phones are available to provide offsite radio repeater and antennae, communication. Therefore, the offsite repeater and antennae need not be survivable for all Beyond Design Basis External Events (BDBEE) to support the diverse and flexible mitigation (FLEX) strategies.

to AEP-NRC-2014-91 Page 2

- Communications Assessment Implementation Timeline Recommendation Stated in I&M Letter Updated Status dated October 31, 2012 Determine feasibility for the following future actions associated with FLEX:

1. Provide additional battery backup for Not Needed - The PA system receives power from the Critical Control Room Power the Public Address (PA) system. Supply (CCRP). In the event of an extended loss of alternating current (AC) power (ELAP) condition, the CCRP will automatically switch to a backup battery reserve capable of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> operation. The FLEX validation process determined that power can be restored to the battery chargers within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 35 minutes, using the 600 volts alternating current (VAC), 500 kilowatts (kW) portable diesel generator (DG). Therefore, additional battery backup is not needed to support the FLEX strategies.

2. Provide capability for hooking up Not Needed - The stated action referred to the radio system normally used for alternate power generator for the day-to-day plant operation. The FLEX strategies rely on separate dedicated FLEX intra-plant 450 MHz radio system. radios served by Portable Tactical Repeaters (PTR) and Bi-Directional Amplifiers (BDA) which would be deployed at strategic locations in the plant. This would provide radio coverage to the expected response areas without reliance on the radio system normally used for day to day plant operation.

The PTRs and BDAs are powered by batteries to ensure operability during an ELAP event. There are battery chargers located in the FLEX Storage Building. Procedure 1-OHP-4027-FSG-501, "FLEX Equipment Staging" includes the deployment of a DG to provide power to the battery charging stations. Therefore, the capability for hooking up alternate power generator for the intra-plant 450 MHz radio system is not needed to support the FLEX strategies to AEP-NRC-2014-91 Page 3 Communications Assessment Implementation Timeline Recommendation Stated in I&M Letter Updated Status dated October 31, 2012 Updated Status

3. Provide capability for hooking up Complete as Stated - As noted above, the PA system receives power from the alternate power generator for the PA CCRP which will be automatically switched over to a backup battery reserve capable system. of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> operation in the event of an ELAP. As also noted above, the 600 VAC, 500 kW portable DG can be used to provide power to the battery chargers within the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period.

4. Harden exterior antennae to the extent Not Needed - The FLEX communication strategy does not rely on the existing necessary to provide reasonable exterior antenna. The deployment of PTRs and BDAs as described above will assure assurance of survivability, adequate in plant radio communication. Therefore, the hardening of the exterior antennae is not needed to support the FLEX strategies.

5. Provide survivable offsite 450 MHz Not Needed - The offsite repeater and antennae may not be survivable for all radio system (including repeater and BDBEEs. However, as described above, satellite phones will be available to provide antennae) or portable repeater offsite communication. Therefore the offsite repeater and antennae need not be equipment. survivable for all BDBEEs to support the FLEX strategies.

Provide alternate power supplies for the following locations (assuming survivability) at a minimum:

1. The EOF, which also has an existing Not Needed - The EOF is located in the Buchanan Office Building and receives power DG. from two 12 kilovolt (kV) power lines. If one 12 kV line is lost, an automatic transfer switch will shift to the other line. If both lines are lost, an existing 400kW DG will automatically start and supply emergency power. Two uninterruptable power supply (UPS) systems would provide power for a short duration for certain EOF communication equipment and the Local Area Network (LAN) servers if the generator was briefly unavailable.

2. The Operations Support Center (OSC). Not Needed - The OSC has not been shown to be survivable for all BDBEEs assessed for CNP. The OSC function may be re-located based on habitability concerns. The procedure for activation and operation of the OSC designates the to AEP-NRC-2014-91 Page 4 Communications Assessment Implementation Timeline Recommendation Stated in I&M Letter Updated Status dated October 31, 2012

~1-Radiation Protection Access Control Building or other onsite location as an alternate location for the OSC as directed by the Radiation Protection Director and the OSC Manager. Personnel manning the primary or alternate onsite OSC can utilize the FLEX radio system and satellite phones. As noted in the letter from J. P. Gebbie, I&M, to NRC, dated May 23, 2014, transmitting the CNP On-Shift Staffing Assessment Report, if access to designated emergency response facilities is not possible, OSC personnel may also respond to the EOF. Power supplies for the EOF are discussed in the updated status items preceding and following this item.

Therefore, an alternate power supply to the OSC is not needed to support the FLEX strategies.

Provide standalone UPS units for Complete as Stated - A UPS system feeds the 120V AC distribution panels to support equipment in the EOF and TSC that will be the essential TSC loads, (e.g. computers, multi-line telephones, etc.). The UPS needed to manage the emergency. system consists of a battery, two battery chargers, two inverters, and two 120V AC (computers, multi-line telephones, and distribution panels.

portable phones). As noted above, there are 12 kV power lines and a DG providing redundant power supplies to the EOF. Additionally, two UPS systems would provide power for certain EOF communication equipment and LAN servers. As also noted above, satellite phones (battery powered) would also be available in the EOF. These provision are considered to provide adequate assurance of EOF communication capabilities.

Provide a dedicated source of backup Complete as Stated - Per 1-OHP-4027-FSG-501, "FLEX Equipment Staging," a 26 kW power (portable generator) for charging DG is available in the Turbine Building. This generator can be used to power portable batteries for handheld radios. charging stations for the radios. Additionally, portable charging stations are available in the FLEX Storage Building and may be staged near any available power source inside or outside the building. Power can be provided to the FLEX Storage Building by portable generators.

to AEP-NRC-2014-91 Page 5 Communications Assessment Implementation Timeline Recommendation Stated in I&M Letter Updated Status dated October 31, 2012 Update training programs to address Complete as Stated - A formal hands-on study guide (FX-I-004, "FLEX Portable emergency communications equipment Communications") utilizing actual communication equipment and knowledge consistent with implementation of FLEX. demonstrations for the new FLEX communication equipment was developed, and was administered to applicable Operations and Fire Protection personnel.