NRC 2012-0095, NextEra Energy Point Beach. LLC Response to 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 9.3, Emergency Preparedness

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NextEra Energy Point Beach. LLC Response to 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 9.3, Emergency Preparedness
ML12305A538
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 10/31/2012
From: Meyer L
Point Beach
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC 2012-0095
Download: ML12305A538 (30)


Text

NEXT ENERW

/- POINT BEACH October 31,2012 NRC 2012-0095 10 CFR 50.54(f)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant, Units 1 and 2 Docket 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 NextEra Energv Point Beach. LLC Res~onseto 10 CFR 50.54(f) Request for lnformation Regarding Near-Term Task Force Recommendation 9.3, Emergencv Pre~aredness

References:

(1) NRC letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, Request for lnformation Pursuant to Title 10 of the Code of Federal Regulations 50.540 Regarding Recommendations 2.1,2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident (MLI 2073A348)

(2) NRC letter to Nuclear Energy Institute (NEI), dated May 15, 2012, U.S. Nuclear Regulatory Commission review of NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, Dated May 2012 (ML12131A043)

On March 12, 2012, the NRC staff issued Reference (I), requesting information pursuant to 10 CFR 50.54(f). Enclosure 5 of Reference (1) contains specific Requested Actions and Requested lnformation associated with Recommendation 9.3 for Emergency Preparedness (EP) programs. Reference (1) requested addressees provide an assessment of the 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 meeting the described conditions.

Reference (2) documents the NRC1sreview and acceptance of NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, as providing an acceptable method for licensees to employ when responding to the 10 CFR 50.54(f) letter regarding Recommendation 9.3.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, W154241

Document Control Desk Page 2 The Point Beach Nuclear Plant Communications Assessment During an Extended Loss of AC Power is provided in Enclosure 1 and was prepared in accordance with the guidance of NEI 12-01, Revision 0. The planned communications improvements resulting from the assessment, along with an implementation schedule, are identified as new Regulatory Commitments and are provided in Enclosure 2.

If you have any questions please contact Mr. Michael Millen, Licensing Manager, at 9201755-7845.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 31,201 2.

Very truly yours, NextEra Energy Point Beach, LLC Enclosures cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Director of Office of Nuclear Reactor Regulation, USNRC

ENCLOSURE 1 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 NEXTERA ENERGY POINT BEACH, LLC RESPONSE TO 10 CFR 50.54(F) REQUEST FOR INFORMATION REGARDING NEAR-TERM TASK FORCE RECOMMENDATION 9.3, EMERGENCY PREPAREDNESS POINT BEACH NUCLEAR PLANT COMMUNICATIONS ASSESSMENT DURING AN EXTENDED LOSS OF AC POWER 26 pages follow

POINT BEACH NUCLEAR PLANT COMMUNICATIONS ASSESSMENT DURING AN EXTENDED LOSS OF AC POWER Page I of 26

Point Beach Nuclear Plant response to NRC 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-Team Task Force Review of insights from the Fukushima Dai-ichi Accident, dated March 12,2012. The NRC requested among other things, information related to Emergency Communications.

Dates of Assessment:

August 15,2012 through September 28,2012 Page 2 of 26

Executive Summary:

This assessment reviews the communications capabilities of Point Beach Nuclear Plant to support emergency response to events involving loss of AC power and large scale natural events that disable the communications infrastructure in the area surrounding the plant out to 25 miles. Disabled infrastructure includes normal AC electrical service, commercial telephone service, cellular telephone service, and radio communications towers. Backup power sources at offsite locations within the 25 mile area may be considered available and functional.

This assessment was conducted in accordance with industry guidance contained in NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012.

The concIusion of the assessment is that Point Beach Nuclear Plant has a diverse set of communications systems, designed to ensure reliable communications during normal plant operations and during emergency situations, including loss of offsite power. The communications systems are not safety related. Reliability is established by providing primary and backup systems that are sufficiently independent of one another and by backup power capability to protect against loss of offsite power events.

The beyond design basis events assumed in this assessment introduce failure modes that could render a significant portion of existing communications capabilities non-functional. The assessment concludes that enhancements are necessary to maintain communications capabilities for responding to beyond design basis events. These enhancements include:

Provide additional radio repeaters or backup power for existing repeaters to allow multiple talk groups at any given time.

Provide additional portable generators to power battery chargers for the existing installed batteries that supply power to the radio system, Private Branch Exchange (PBX) phone system, and Gai-Tronics system, within the station power block. (The same battery supplies both the radio and Gai-Tronics system)

Install larger Unintemptible Power Supply (UPS) devices or re-power existing UPS devices for the PBX phone system and Stationary Satellite phone system.

Provide additional portable generators to power battery chargers for portable radio batteries and portable satellite phone batteries.

Provide permanent docking stations and remote antenna capabilities for portable satellite phones.

Provide backup emergency power at the Emergency Operations Facility (EOF).

Provide a portable radio antenna at the EOF.

Page 3 of 26

Topic: 10 CFR 50.54(f) Request For lnformation - Near Term Task Force (NTTF) Recommendation 9.3 - Communications NRC Requested Information NRC Requested Actions It is requested that addressees assess their current communications systems and equipment used during an emergency event. It is also requested that consideration be given to any enhancements that may be appropriate for the emergency plan with respect to communications requirements of 1 0 CFR 50.47, Appendix E to 10 CFR Part 50, and the guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities. Also addressees are requested to consider the means necessary to power the new and existing communications equipment during a prolonged Station Black Out (SBO).

NRC Request Assumptions The NRC requests that the following assumptions be made in preparing responses to this request for information: the potential onsite and offsite damage is a result of a large scale natural event resulting in a loss of all AC power.

In addition, assume that the large scale natural event (LSNE) causes extensive damage to normal and emergency communications systems both onsite and in the area surrounding the site. It has been recognized that following a large scale natural event that AC power may not be available to cell and other communications infrastructures.

NRC Requested Information Addressees are requested to provide an assessment of the 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 meeting the conditions described above.

Page 4 of 26

NEI 12-01 Revision 0 (May 2012) 4.0 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 emergency response functions described in the tables below, 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 in the tables 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.

NOTE: In the tables below, when referring to "Additional Informationnin column 8, ensure the following is addressed:

I.Provide a description of any new communications system(s) or technologies that will be deployed based upon the assumed conditions described above, and

2. Provide a description of how the new and/or improved systems and power supplies will be able to provide for communications during a loss of all AC power.

4.1.1 Notifications to, and communications, with OROs [per 10 CFR 50 Appe 7dk E]

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

Control Room (Common for both units)

Technical Iper Control Room Two Digit Dial NO for Shift Communicator 1for Key TSC Support Center Communicator (TSC) (adjacent Select Two Digit Dial I Select NO PBX Phone Cell Phone Satellite Phone PBX Phone 1 Cell Phone NO NO YES NO NO YES !Satellite phone

- Attachment B

- Attachment B to Operational Satellite Phone YES Support Center (OSC))

Page 5 of 26

4.1.1 Continued Emergency Minimum Primary Primary Backup Backup Planned o r Refer t o Response Communications Method Method Method(s) Method(s) Potential Following Facility Links Described in Available Described in Available lmprovement Section for site E-Plan following site E-Plan following Identified? Additional Assumed Assumed Information LSNE? LSNE? -

Emergency 1 for Key EOF Two Digit Dial NO PBX Phone NO NO Satellite phone Operations Communicator Select - Attachment I3 Facility (EOF) Cell Phone NO NO Satellite Phone YES YES 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]

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

Control Room 1 per Control Room Emergency NO PBXPhone NO NO Satellite phone (Common for both for Emergency units)

Notifications Cell Phone NO NO - Attachment B Notifications System (ENS)

System (ENS) Sat. Phone YES YES Communicator TSC (adjacent to 1 for ENS ENS NO PBXPhone NO NO Satellite phone OSC) Communicator Cell Phone NO NO - Attachment B Sat. Phone YES YES EOF Ifor Health Physics Health Physics NO PBXPhone NO NO Satellite phone Network (HPN) Network Cell Phone NO NO - Attachment B Communicator (HPN)

Sat. Phone YES YES TSC (adjacent to 1 for HPN HPN NO PBX Phone NO NO Satellite phone OSC) Communicator Cell Phone NO NO - Attachment B Sat. Phone YES YES Page 6 of 26

4.1.3 Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E. Addifional links that support performances of critical response functions are also specitied.] 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, sound-powered and satellite-based communications systems.

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

Control Room Iper unit PBXPhone YES FM Radio YES YES PBX Phone (Common for both units) Cell Phone NO NO - Attachment A Public Address YES NO FM Radio System (Gai- - Attachment C Tronics) Gai-Tronics Satellite YES YES - Attachment D Phones Satellite Phone

-Attachment B TSC 1 each for PBX Phone YES FM Radio YES YES PBX Phone Senior/Lead TSC - Attachment A Manager Cell Phone NO NO Operations Public Address YES NO FM Radio Coordination System (Gai- - Attachment C Maintenance Tronics) Gai-Tronics Coordination Engineering Satellite YES YES - Attachment D Coordination Phones Satellite Phone Radiological - Attachment B Support Additional response coordination links for multi-unit sites:

1 for each position providing Unit

Response

Coordination.

Page 7 of 26

4.1.3 Continued Primary Primary Backup Backup Planned or Refer to Method Method Method(s) Method(s) Potential Following Facility Links Described in Available Described in Available Improvement Section for site E-Plan following site E-Plan following Identified? Additional Assumed Assumed lnformation I LSNE? LSNE?

OSC I 1 each for: PBX Phone YES FM Radio YES YES PBX Phone SeniorILead OSC Manager I Cell Phone NO NO - Attachment A Radiological PubIic Address YES NO FM Radio Support System - Attachment C (Gai-Tronics) Gai-Tronics Additional response - Attachment D coordination links Satellite YES YES for multi-unit sites: Phones Satellite Phone Ifor each position -Attachment B providing Unit In-Plant Team Coordination.

I EOF 1 each for:

- SeniorILead Manager PBX Phone YES 1

FM Radio Cell Phone YES NO YES NO PBX Phone

- Attachment A Key Protective Satellite YES YES FM Radio Measures Phones - Attachment C Operations or Satellite Phone Technical Support - Attachment B (as needed to support performance of dose projections, formulation of PARS and plant status updates to OR0 authorities).

Joint Public 1 for Senior PBX Phone NO Cell Phone NO NO Satellite Phone Information Manager - Attachment B Center (JPIC) SatelIite YES YES Phones Page 8 of 26

4.1.4 Communications with fieldloffsite monitoring teams [per 10 CFR 50 Append2 4 Emergency Minimum Primary Primary Backup Backup Planned or Refer to Response Communications Method Method Method(s) Method(s) Potential Following Facility Links Described in Available Described in Available Improvement Section for site E-Plan following site E-Plan following Identified? Additional Assumed Assumed Information LSNE? LSNE?

Primary Fieldloffsite FM Radio Yes Cell phone NO NO FM Radio location where monitoring team Satellite YES YES - Attachment C fieldloffsite coordination Satellite Phone monitoring team

- Attachment B coordination is performed Primary 1for each FM Radio Yes Cell phone NO NO FM Radio location from field/offsite Satellite YES YES which field1 monitoring team Satellite Phone offsite monitoring

- Attachment B teams are deployed 4.1.5 Communications with other Federal agencies as described in the site emergency plan (e-g., the US Coast Guard) ber 10 CFR 50 Appendix Ej Emergency Minimum Primary Primary Backup Backup Planned or Refer to Response Communications Method Method Method(s) Method(s) Potential Following Facility Links Described in Available Described in Available Improvement Section for site E-Plan following site E-Plan following Identified? Additional Assumed Assumed Information LSNE? LSNE?

Primary location where communication 1 Coordination with Federal agencies I

PBX Phone NO I

Cell phone

/

NO Satellite phone YES (

NO YES Satellite Phone with Federal agencies is performed Page 9 of 26

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 two phases.

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

LSNE? LSNE?

On-shift staff Number necessary FM Radio YES Gai-Tronics YES YES FM Radio for the on-shift staff - Attachment C to perForm Initial Gai-Tronics Phase coping actions (reflecting

- Attachment D current staff &

strategies)

Ieach for: FM Radio YES Cell Phone NO YES FM Radio site-specific On-site - Attachment C locations as radiological Gai-Tronics YES YES Gai-Tronics necessary monitoring - Attachment D 2 each for:

Firefighting (1 for brigade leader and 1 for the brigade) 2 each per unit for:

In-plant rad.

monitoring Search and Rescue Emergency repairs Page 10 of 26

4.2 Plant Paging (Announcement) System - - -

Emergency Minimum Primary Primary ~ a c k u ~ Backup Planned or Refer t o Response Communications Method Method Method(s) Method(s) Potential Following Facility Links Described in Available Described in site Available Improvement Section for site E-Plan following E-Plan following Identieed? Additional Assumed Assumed lnformation LSNE? LSNE?

Control Room See assumptions Gai-Tronics YES Face-to-face YES Gai-Tronics (Common for and discussion in communications - Attachment D both units) NEI 12-01.

TSC See assumptions Gai-Tronics YES Face-to-face YES NO Gai-Tronics and discussion in communications - Attachment D NEI 12-01.

4.3 Communications Equipment t OR0 Facilities Emergency Minimum Primary Primary Backup Backup Planned or Refer t o Response Facility Communications Method Method Method(s) Method(s) Potential Following Links Described in Available Described in Available Improvement Section for site E-Plan following site E-Plan following Identified? Additional Assumed Assumed lnformation LSN E? LSNE?

Location where At least one. See PBX Phone No Cell Phone NO Satellite Phone OROs receive assumptions and - Attachment B notifications of an discussion in NEI emergency -l2-01. Satellite YES YES declaration or a phone Protective Action Recommendation (as described in the site emergency plan)

Page 11 of 26

4.4 Notification of the Emergency Response Organization (ERO)

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

Location where At least one. See Pager NO Predetermined YES YES Pager ERO assumptions and response based - Attachment E notifications of discussion in NEI on wide area loss an emergency 12-01. of power (memo (as described to employees) in the site emergency plan)

Page 12 of 26

4.5 EQUIPMENT LOCATION REQUIREMENTS To be assumed functional, a piece of on-site communications equipment should be stored in a location, and maintained in a manner, that maximizes survivability following a beyond design basis event.

The Interim Staff Guidance for FLEX equipment was issued, by the NRC on August 30, 2012. All equipment storage locations will be assessed and where needed, enhancements identified earlier in this assessment report will be made to verify:

1. Location or manner of storage reasonably precludes wetting from flooding;
2. Location or manner of storage reasonably precludes damage from a seismic event; and,
3. Equipment is stored, or otherwise available, in locations that can be readily accessed when needed. To the degree practical, potential constraints to equipment access or movement when selecting a storage location will be considered.

When assessing storage locations, criteria presented in regulatory and industry guidance applicable to equipment associated with NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External events (e.g.,

FLEX equipment) has beenlwill be considered.

This guidance applies to equipment at the point of use (e.g., a radio) a s well a s any supporting infrastructure components. Such components may include portable power sources, and radio system repeaters and antennas.

4.6 PERFORMANCE CHARACTERISTICS

1. This assessment has confirmed that once the communications enhancements have been implemented, the systems and equipment identified for usage will support communications among and between:
a. Licensee emergency response facilities, including Security.
b. Fieldloffsite monitoring teams and the location controlling deployment of the teams (e-g., the EOF).
c. The Shift Communicator, Key TSC and EOF Communicators, and the O R 0 contact points.
d. ENS and HPN communicators and the NRC staff.
e. On-site and in-plant teams and the location controlling deployment of the teams (e.g., the OSC).
2. This assessment has verified that with the enhancements implemented, radio system(s) used by ERO personnel will possess the necessary design and operating characteristics to adequately support emergency communications.
3. This assessment has verified that expected reliance upon "multi-use" equipment is minimized. This means that communications equipment used to implement emergency response functions is not relied upon to simultaneously support other functions (e.g.,

Security). There are no cases where multiple-usage is unavoidable.

Page 13 of 26

4.7 OTHER ASSESSMENT CONSIDERATIONS I. Portable backup AC power source(s) for communications systems and components have been assessed, and in accordance with final rulemaking:

a. Backup AC power sources credited as operable will meet the assumptions and requirements discussed in section 4.5 above.
b. Sufficient power source fuel will be available on-site to support the expected run time.
2. Assess battery-operated equipment:

Enhancements have been identified to verify that there are a sufficient number of on-site and charged batteries to support operation of required equipment. This number was determined with consideration given to the following items:

a. A sufficient number of charged batteries available at the start of an event to support performance of the required emergency response functions listed in Section 4.1, Required Emergency Communications Capabilities.
b. The vendor's stated minimum reliable operability period for a fully-charged battery was used.
c. Availability of on-site battery charging capability.
d. Delivery of replacement batteries - assumed to occur any time after T + 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.(T= time of beyond design basis event)
3. This assessment has identified that the only manual action that may need to be taken by emergency responders to facilitate the use of any communication link would be if the portable generators were used to provide power. Procedure enhancements will be needed and potential training on the process will be needed.

4.8 QUALITY AND MAINTENANCE-RELATED REQUIREMENTS Preventive maintenance requests will be generated to check new equipment purchased/installed for this assessment. EP procedures will be changed 1 added to account for new equipment.

4.9 NATIONAL COMMUNICATIONS SYSTEM (NCS) SERVICES Government Emergency Telecommunications Service (GETS) cards will be made available to some of our EP personnel and emergency response positions. Wireless Priority Service (WPS) cards are telephone specific and contain monthly fee. It was determined that WPS cards are not needed.

4.10 COMMUNlCATlONS PROVIDER EMERGENCY SERVICES Cellular providers in the area have mobile devices capable of extending cellular service to affected areas.

Page 14 of 26

4.1 1 PERSONNEL TRAINING Need training for EP and other personnel on the new communications devices (interim devices and final configuration).

5.0 Planned Improvements 5.1 Planned or potential improvements to existing on-site communications systems and their required normal and/or backup power supplies:

Install larger UPS devices or re-power existing UPS devices for the PBX Phone system and Stationary Satellite phone system.

Extend life of battery supply for the PBX phone system with temporary power (portable generator) for the installed charger.

Provide external antennas and docking stations (Control Room and TSC) to allow indoor use of portable Satellite phones.

Provide portable repeaters or enhance the power supply of installed repeaters to allow simultaneous conversations.

Provide portable generators for charging radio and satellite phone batteries.

Provide portable generator to allow charging of the communications inverter battery (Supply to the radio and Gai-tronics system).

Revise training and procedures to reflect portable generator use and portable satellite phone use.

lncorporate testing, maintenance, and storage of any new equipment into existing procedures.

Include information from NPM 2012-0171, ERO Response During Major Losses of Communication, in ERO training.

5.2 Planned or potential improvements to off-site communications systems and their required normal andlor backup power supplies:

Acquire Government Emergency Telecommunications Service (GETS) cards for selected phones/positions and update training and procedures a s required.

Provide external antennas and docking stations in the EOF to allow indoor use of portable Satellite phones.

Improve satellite phone availability at OR0 facilities and update existing procedures to incorporate the phone numbers.

Provide backup emergency power at the EOF Provide a portable radio antenna at the EOF.

Revise training and procedures to reflect portable generator use and portable satellite phone use.

Provide portable generators for charging radio and satellite phone batteries.

Incorporate testing, maintenance, and storage of any new equipment into existing procedures.

Page f5of 26

5.3 Provide a description of any new communications system(s) or technologies that will be deployed based upon the assumed conditions; No new communications systems will be deployed.

5.4 Provide a description of how the new andlor improved systems and power supplies will be able to provide for communications during a loss of all a c power.

Portable generators will be able to supply the existing battery chargers for the PBX phone system and the communications inverter (supplies power to the FM radio system and Gai-Tronics system). Providing power to these installed batteries would allow the radio system and Gai-Tronics system to operate for an indefinite amount of time.

Portable generators will be able to recharge portable communication equipment batteries. Providing a means to recharge the batterieslspare batteries will allow each piece of equipment to operate for an indefinite amount of time.

Re-powering or installing larger UPS units on the PBX phone system and Stationary Satellite phone system needs to be done to maintain the PBX phones and Stationary Satellite phones available on a long term loss of AC power.

Providing portable repeaters or enhancing the power supply of installed repeaters will allow multiple conversations to take place on the radio system.

External antennas will allow users to be in a sheltered area when using a portable satellite phone. The antennas need to be connected to a docking station to be functional.

Obtaining GETS card for select positions/phones will ensure line prioriiy is given in the event of an emergency.

Page q6 of 26

6.0 PBNP Emergency Response Communication Systems (Current Capabilities)

Communications Alternate methods SystemlEquipment Description SystemslEquipment PBX Telephone System. Radios PBX telephone system with at least 1,200 telephone extensions, ERO Pagers including locations at the TSC, OSC, EOF, Off Site Radiation Protection Company lntranet messages Facility (OSRPF), Alternate Emergency Operations Facility (AEOF) and Company e-mail JPIC.

Cellular telephones Gai-Tronics See Attachment A for a more detailed description.

Handheld bullhorn HPN Local Commercial Telephone The HPN is a special commercial telephone circuit (FTS) controlled by System the NRC. During an emergency event, it is used at the request of the Cellular telephones NRC, to provide onsite and offsite radiological data to the NRC.

Satellite phones See Attachment A for a more detailed description.

Cellular telephones Radios US Cellular is the Cell phone provider for Company issued cell phones.

Plant PBX Telephone System Gai-Tronics system See Attachment B for a more detailed description.

Satellite Phones Satellite phones Radios Point Beach has Stationary Satellite phones and Portable Satellite Plant PBX Telephone System phones.

Cellular telephones Gai-Tronics system See Attachment B for a more detailed description.

ENS Plant PBXTelephone System The ENS is a special commercial telephone circuit controlled by the Cellular telephones NRC. During an emergency event, it is used to provide initial notification Satelllie Phones of the event to the NRC.

Two digit dial select . Plant PBXTelephone System Cellular telephones See Attachment A for a more detailed description.

The Two-Digit Dial Select circuit is a unique, dedicated telephone network and is used as the primary means of notifying the state and Satellite Phones counties of events at Point Beach.

See Attachment A for a more detailed description.

Page 17 of 26

6.0 Continued Communications Alternate methods SystemlEquipment Description SystemslEquipment Radios Plant PBXTelephone System The Point Beach FM radio system has base station consoles in the Gai-Tronics Control Room, OSC, Central Alarm Station, Secondary Alarm Station, ERO Pagers and the Site Boundary Control Center (SBCC). The radio system utilizes an automatically actuated radio transmitter (repeater) which retransmits signals received from hand held units. This extends the hand-held units' range and provides for better reception throughout the plant. Radios are also capable of operating point-to-point.

See Attachment C for a more detailed description.

ERO Pagers Plant PBX Telephone System Point Beach utilizes the NXT Communicator system to activate the Cellular telephones ERO during emergency events. The NXT system software and transmission towers are located in two geographically separate locations in the United Sates; Tennessee and Arizona. These separate locations act as primary and secondary base stations for issuing ERO activation transmissions to ERO member's home phones, work phones, cell phones if applicable and ERO pagers. The ERO pager transmissions are initiated through the JSM Communications See Attachment E for a more detailed description Radios The plant paging system (Gai-Tronics) is an internal plant five-channel (Plant Public Address System) Plant PBX Telephone System multi-station public address system. Each public address station has Cellular telephones the capability of general announcement of party-line conversation via ERO pagers any channel. Plant fire and Evacuation alarms use this system.

See Attachment C for a more detailed description.

Page 18 of 26

Attachment A PBNP Phone System Description PBX Phone System:

There are 2 PBXs, one located on the Turbine Deck, Unit I(Plant), and the other in the Nuclear Engineering Services (NES) Building. Telephones located in the TSC, OSC, EOF, OSRPF, AEOF and the JPlC are connected to the PBX located on the Turbine Deck. The PBX in the NES Building services the NES, Training Building and the trailer complex near the Energy Center. The turbine deck PBX is powered from lighting panel 65-L via telephone equipment room lighting transformer (XL-34) and 480V MCC IB-11. The NES PBX is normally supplied from lighting panel 133L and 480V MCC B-60. Both PBX systems have a battery backup power supply with about eight hours of capacity. Eight in-plant extensions automatically take over eight Mishicot, Wisconsin exchange lines upon loss of all in-plant PBX system power.

The two PBX Systems are connected together through a number of T I fold connections. Each PBX has a backup capability of approximately eight hours in the event of loss of power, however the T I connection between the two will go down within minutes of the power outage.

The PBX system satisfies the equipment location requirements of Section 4.5 and will be available as described below after a Beyond Design Basis External Event (BDBEE).

Stationary Satellite system communications are availabIe from all the Emergency Response Facilities and Security through the PBNP PBX lines with dedicated callback numbers to the Control Room, TSC, and EOF.

Assumptions are that there is a loss of all AC power within a 25 miles radius and has the following affects on the PBNP phone system:

Plant PBX Svstem Communicationwithin the plant will remain for eight hours.

Communication to the buildings north of the site (Outside the protected area), will remain for eight hours.

Communication to the Energy Center will be lost.

Communication to the JPlC will be lost.

Communication to the NES, Training Building, and the Trailer complex near the Energy Information Center will be lost.

Communication anywhere offsite will be lost.

NES PBX Svstem Communicationwithin the NES and Training Building will remain for eight hours.

Communication to the Plant will be lost.

Communication to the buildings north of the site (Outside the protected area), will be lost.

Communication to the Energy Information Center will remain for eight hours.

Communicationto the AEOF will be lost.

Communication anywhere offsite will be lost.

Page 19 of 26

Attachment A (continued)

Stationarv Satellite Phones Satellite Communication offsite from within the NES will remain for eight hours.

Satellite Communication offsite from the Plant will be lost.

Satellite Communication offsite from the buildings north of the site (Outside the protected area), will be lost.

Satellite Communication offsite from the Energy Center and EOF will be lost.

Satellite Communication offsite from the AEOF will remain. There are two stationary Satellite phones at the AEOF.

Two Digit Dial Select Phone Systems:

The Two-Digit Dial Select circuit is a unique, dedicated telephone network and is used a s the primary means of notifying the state and counties of events at Point Beach. The system allows for conference calling with any or all of the following locations: Manitowoc and Kewaunee County EOCs and Sheriff Dispatch centers, Wisconsin EOC and State Patrol in Madison, Kewaunee Power Station Control Room, EOF and TSC, and Point Beach's TSC, EOF, AEOF, and Control Room. Commercial telephones are used as the back-up means for notification if the Two-Digit Dial Select System becomes out-of-service.

This system will be lost during a BDBEE due to loss of external phone- lines.

ENS Phone System:

The ENS is a special commercial telephone circuit controlled by the NRC. During an emergency event, it is used to provide initial notification of the event to the NRC and thereafter is to be used to communicate plant systems and radiological data.

This system's power supply will be lost during a BDBEE and it will not be available.

HPN Phone System:

The HPN is a special telephone circuit (FTS) installed by the NRC. During an emergency event, it is used at the request of the NRC, to provide onsite and offsite radiological data to the NRC. There are two desk-sets in both the TSC and EOF. It is assumed that one will be staffed by licensee personnel and the other by a member of the NRC response team. Continuous communications of the licensee may be requested.

This system's power supply wiIl be lost during a BDBEE and it will not be available.

Page 20 of 26

Attachment A (continued)

Point Beach Phone System Enhancements Extend life of battery supply for the PBX phone system with temporary power for the installed charger.

Install larger UPS devices or re-power existing UPS devices for the PBX system.

Obtain GETS Cards for selected phones/positions.

Page 21 of 26

Attachment B PBNP Stationary Satellite Phone Svstem Description Satellite system communications are available from all the Emergency Response Facilities and Security through the PBNP PBX lines with dedicated callback numbers to the Control Room, TSC, OSRPF, and EOF. Direct satellite phone units (independent of the PBX) are also available in the Control Room, AEOF, TSC, and with the Security Group.

Stationary Satellite phone system will not be available after a BDBEE for the Control room, TSC, and EOF.

PBNP Portable Satellite Phone Svstem Descri~tion There are 15 portable satellite phones. These phones require the user to be outdoors with a clear view to the sky. The phones are located as follows; Control room (3),TSC (3), EOF (4), OSC (2),JPIC (I), and Security Group (2).

The portable satellite phones will be stored in locations that meet the requirements of Section 4.5 and will be available following a BDBEE.

SateIlite Phone Enhancements Extend life of battery supply for the PBX phone system with temporary power for the installed charger.

Install larger UPS devices or re-power existing UPS devices for the satellite phone system.

Provide external antennas and docking stations (Control Room, TSC, EOF) to allow indoor use of portable Satellite phones.

Provide portable generator to charge satellite phone batteries.

Revise procedures and training to support the use, testing, maintenance and storage of any new equipment.

Improve satellite phone availability at O R 0 facilities and update existing procedures to incorporate the phone numbers.

Page 22 of 26

Attachment B (continued)

PBNP Cell Phone System Descri~tion PBNP cellular service is provided through U S Cellular. The Radiation Protection group h a s cellular phones available for offsite field monitoring teams in the OSRPF. Cellular phones are also supplied to approximately 100 plant employees in all major departments.

Emergency service is available through U S Cellular. It is assumed that all cellular service is lost at the plant a t the initiation of the event. There will be some service available on the fringe of the 25 mile zone and could be used to communicate with sateIlite phones located in various emergency facilities. There is also emergency service available form other cellular vendors. The availability of cellular service would be a long term enhancement but short term recovery of this communication method is not needed for emergency plan communications.

It is assumed the Cellular service is not available following a BDBEE.

Point Beach Cell Phone Enhancements There are no enhancements identified at this time.

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Attachment C PBNP Radio System Description The Point Beach FM radio system has base station consoles in the Control Room, OSC, Central Alarm Station, Secondary Alarm Station and the SBCC. The radio system utilizes an automatically actuated radio transmitter (repeater) which retransmits signals received from hand held-units.

This extends the hand-held units' range and provides for better reception throughout the plant. These hand-held units are also capable of operating point-to-point independent qf the repeater system. Point-to-point communication has limited range due to the configuration of the plant structures. These hand-held units are available in the Control Room, TSC, Radiation Protection Station, SBCC, and from Security. The radio +

system is used for in-pant security, operations, maintenance and radiation protection surveys, and would be used during emergencies. Using this radio system, Control Room personnel can also communicate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day with the Manitowoc County Sheriff's Department. This allows indirect communications with the Aurora Medical Center-Manitowoc County. The radio system also provides a direct communications link with the Security Building or the TSC from the Control Room.

The major components of the radio system are located in an enclosed room located within the non-nuclear room,,Unit 2, 52' elevation of the plant.

The major components of the radio system are powered from instrument bus distribution panel Y-12. This panel is fed from inverter 1DY-201, which is powered by a 125vdc bus supplied by either station battery ID-205 or battery charger 1D-207. Other components are fed from various emergency lighting panels in several locations. Only one repeater is powered from Y-12, which will allow only one individual to be talking at any given time. Point-to-point communications would be available for additional conversations but the distance between radios in point-to-point mode is limited.

The radio system meets the equipment location requirements of Section 4.5 and will be available following a BDBEE.

Point Beach Radio System Enhancements Provide portable repeaters or enhance the power supply of installed repeaters to allow simultaneous conversations.

Provide portable generator to power battery charger 1D-207to maintain communications inverter.

Provide backup emergency power at the EOF.

Provide portable generator to charge radio batteries.

r Provide a portable radio antenna at the EOF.

Revise procedures and training to support the use, testing, maintenance and storage of any new equipment.

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Attachment D PBNP Plant Paging System Description The plant paging system (Gai-Tronics) is an internal plant five-channel multi-station public address system. Each public address station has the capabilrty of general announcement of party-line conversation via any channel.

The normal power supply to the Gai-Tronics system is from instrument bus distribution panel Y-12. This panel is fed from inverter IDY-201, which is powered by a 125vdc bus supplied by either station battery 1D-205 or battery charger ID-207.

The Gai-Tronics system meets the equipment location requirements of Section 4.5 and will be available following a BDBEE.

The Gai-Tronics system is assumed to be functional immediately after an event and will accomplish in-plant notification of on-site employees.

Point Beach Plant Paging System Enhancements Provide portable generator to power battery charger 1D-207 to maintain communications inverter. (Same as enhancement for radio system)

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Attachment E Point Beach ERO Paqina System Description PBNP utilizes the NXT Communicator system to activate the ERO during emergency events. The NXT Communicator system software and transmission towers are located in two geographically separate locations in the United Sates; Tennessee and Arizona. These separate locations act as primary and secondary base stations for issuing ERO activation transmissions to ERO members' home phones, work phones, cell phones if applicable, and ERO pagers. The ERO pager transmissions are initiated through the J S M Communications Company, who owns the alpha numeric pagers worn by the PBNP ERO and area towers for transmitting messages originating from the NXT Communicator system. There are six J S M pager transmission towers located 'I80 degrees around the plant that are outside the 25 mile radius. Those towers are located in the towns of Sturgeon Bay, Sobieski, Appleton, Brillion, Chilton, and Sheboygan. When a call is made from the site to NXT Communicator to activate the ERO, the NXT Communicator software sends commands to the PBX phone system, in-plant phone system, and the ERO pager system. These pager transmission towers outside of the 25 mile radius would reach ERO pagers approximately 15 miles into the 25 mile radius. As such, most ERO personnel living outside of a 10 mile radius around the PBNP site could receive the page. The initial call to NXT Communicator can be made from a stand alone satellite phone.

In the event that there is a major loss of communication capabilities, NPM 2012-0171 ERO response during Major Losses of Communication, was sent to all ERO members. The memo provides guidance to ERO members that if they are aware of gird disturbances, siren activations, major power outages or other events that could impact the stability of the Point Beach site; they should take the following actions:

If possible, monitor local radio communications for the extent of impact from the event. Do not call the control room.

Should the situation appear to be of a magnitude that could affect the stability of the Point Beach site and there are major disturbances to communications such that phone, pager, and cellular service are not functioning, first ensure your family and homes are safe. Then, if you can travel safely, report to your emergency response facility.

In the event that your respectivefacility is inaccessible, ERO members are directed to go to the JPIC, located approximately 25 miles from Point Beach, in Green Bay, Wisconsin.

Point Beach ERO Paging System Enhancements Include information from NPM 2012-0171, ERO Response During Major Losses of Communication, in ERO training.

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ENCLOSURE 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 NEXTERA ENERGY POINT BEACH, LLC RESPONSE TO 10 CFR 50.54(F) REQUEST FOR INFORMATION REGARDING NEAR-TERM TASK FORCE RECOMMENDATION 9.3, EMERGENCYPREPAREDNESS

SUMMARY

OF REGULATORY COMMITMENTS NextEra Energy Point Beach, LLC proposes the following new Regulatory Commitments:

Implementation Planned Communications Improvement Schedule Improve availability of satellite phones at Offsite Response Organization 6115113 (ORO) facilities and update the applicable procedures.

Obtain Government Emergency Telecommunications Service (GETS) cards for selected phoneslpositions. Complete appropriate training and update the 6115113 applicable procedures.

Install larger Uninterruptible Power Supply (UPS) devices or re-power existing UPS devices for the PBX phone system and Stationary Satellite phone 9115113 system.

Provide backup emergency power at the Emergency Operations Facility 9115113 (EOF).

Provide additional portable generators to power battery chargers for portable radio batteries and portable satellite phone batteries. Complete appropriate 12115113 training and update the applicable procedures.

Provide permanent docking stations and remote antenna capabilities for our portable satellite phones. Complete appropriate training and update the 12115113 applicable procedures.

Provide additional radio repeaters or backup power for existing repeaters to allow multiple talk groups at any given time. Complete appropriate training 10131114 and update the applicable procedures.

Provide additional portable generators to power battery chargers for the existing installed batteries that supply power to the radio system, PBX phone system and Gai-Tronics system within the station power block (The same 10131114 battery supplies both the radio and Gai-Tronics system). Complete appropriate training and update the applicable procedures.

Provide a portable radio antenna at the EOF. 10131114 Page 1 of 1