GNRO-2012/00131, Entergy'S Response to the March 12,2012 Information Request Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 for Completing Emergency Communication Assessments

Entergy'S Response to the March 12,2012 Information Request Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 for Completing Emergency Communication Assessments

ML12306A245
Person / Time
Site:	Grand Gulf
Issue date:	10/31/2012
From:	Mike Perito Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
GNRO-2012/00131
Download: ML12306A245 (30)

Text

~*Entergx Entergy Operatio ns, Inc.

P. O. Box 756 Port Gibson. MS 39150 Michael Perito Vice President, Operations Grand Gulf Nuclear Station Tel. (601) 437-6409 GNRO-2012/00131 October 31, 2012 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Entergy's Response to the March 12,20 12 Information Request Pursuant to 10 CFR 50.54(f) Regarding Recommenda tion 9.3 for Completing Emergency Communication Assessments Grand Gulf Nuclear Station, Unit No.1 Docket No. 50-416 License No. NPF-29

Dear Sir or Madam:

On March 12, 2012, the NRC issued a letter (Reference 1) 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-ichi Accident. Enclosure 5 of the letter contained specific requested actions and requested information associated with Recommendation 9.3 for Emergency Preparedness programs communications. In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f), addressees were requested to submit a written response to the information requests within 90 days or provide a response within 60 days of the date of the letter and describe the alternative course of action that it propos es to take.

Entergy Operations, Inc. (Entergy) responded within 60 days (Refer ence 2) proposing to take the alternative course of action for communications that was descri bed in Attachment 1 of Reference 2. Entergy implemented the first part of this alterna te course of action with the submittal of Reference 3 which described interim actions or planne d actions to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete. This letter completes the alternate course of action by summarizing the results of the communicat ions assessment and the potential enhancements that could be made.

The communications assessment was performed using the guidan ce of NEI 12-01 (Reference 4) and identified enhancements that may be approp riate for the

GNRO-2012/0131 Page 2 of 3 emergency plan with respect to communications requirements of 10 CFR 50.47, Appendix E to 10 CFR 50, and the guidance in NUREG-0696. The current planned enhancements are discussed in Attachment 1. The new regulatory commitment is identified in Attachment 2.

These enhancement commitments are subject to change as a result of Diverse and Flexible Coping Strategies (FLEX) developments, advances in technology and progress in the manner of addressing the need for these enhancements.

If you have any questions concerning the content of this letter, please contact Jeffery A. Seiter, Acting Licensing Manager at (601) 437-2344.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 31,2012.

MP/jas

References:

1. NRC letter 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 (ADAMS Accession ML12053A340)

2. Entergy Letter to NRC (GNRO-2012/00038), Entergy's 60-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments, dated May 9,2012

3. Entergy Letter to NRC (GNRO-2012/00052), Entergy's 90-Day Response to the March 12,2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments, dated June 9, 2012

4. Nuclear Energy Institute (NEI) 12-01, "Guideline for Assessing Beyond DBA Response Staffing and Communications Capabilities," Revision 0 (May 2012)

Attachments and cc: (see next page)

GNRO-2012/0131 Page 3 of 3 Attachments: 1 Grand Gulf Nuclear Station (GGNS) Communications Assessment 2 List of Regulatory Commitments cc: Mr. Elmo Collins Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Mr. A. Wang, NRRlDORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Robert J. Fretz Jr.

OWFN, Mailstop # 4A15A 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Robert L. Dennig OWFN, Mailstop # 10E1 11555 Rockville Pike Rockville, MD 20852-2378

ATTACHMENT 1 TO GNRO-2012/0131 GRAND GULF NUCLEAR STATION (GGNS)

COMMUNICATIONS ASSESSMENT to GNRO-2012/0131 Page 1 of 24

1. Executive Summary:

The purpose of this report is to document performance of an NRC-requested assessment of the current communications systems and equipment used at the Grand Gulf Nuclear Station (GGNS) site (Unit 1) during an emergency event as defined by Nuclear Energy Institute (NEI) 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities."

Power supplies for the existing communications equipment to be credited have been assessed to determine power availability during a prolonged Station Blackout (SBO) event.

The beyond design basis events assumed in this assessment introduce conditions that could render a significant portion of existing communications capabilities inoperable. The assessment identifies enhancements to maintain communications capabilities for responding to emergency events. These enhancements include:

• Sizing of existing UPS batteries in Emergency Planning (EP) facilities to ensure that adequate power capacity exists.

• Correction of various seismic-related issues related to Anchorages, Spatial Interactions and Housekeeping in EP facilities.

2. Methodology This report is based on the recommended criteria from NEI 12-01, for use in identifying enhancements that will ensure the availability of critical communications capabilities during an extended loss of alternating current (AC) power, including evaluation of power sources for communications equipment. This approach provides the flexibility to perform a communications capability assessment that accommodates specific site needs while, at the same time, ensuring consistency with industry-developed standards, and NRC regulations and guidance.

The assessment focused on the communication systems to be credited. For example, existing telephone communications are assumed to be inoperable and therefore are not credited or evaluated in this assessment. Communication links are assumed to be established via satellite phones and use of the existing site radio system(s). Walk downs to evaluate the equipment locations and function were performed. Enhancements identified within the assessment will be further developed as implementation progresses. Alternate approaches will be utilized if prudent (e.g. alternate/new technology, improved capability, cost savings, etc.).

3. Assumptions:

o Extended loss of AC power event o Successful plant shutdown o No hostile action o 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> post event - no site access o 6-24 hours post event -limited site access, individual access by walking, personal transport or alternative transport o 24+ hours post event - site access restored to near normal status o Installed sources of AC power not available to GNRO-2012/0131 Page 2 of 24 o Non-essential loads from direct current (DC) battery sources are stripped per station procedures o Installed inverters and battery chargers remain available provided they are protected from external events o Onsite diesel fuel oil is available provided it is stored in a protected manner from external events o Portable equipment may be used provided it is stored onsite and protected from seismic, wind and flooding events. Includes portable AC and DC power sources o Onsite communications infrastructure remains available provided it is protected from seismic, wind and flooding events.

o Offsite communications infrastructure is inoperable out to 25 miles o Communications equipment located at an offsite response facility and supplied from a backup power source is assumed to be functional.

j

4. COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER NEI 12-01 Section 4, "Communications During an Extended Loss of AC Power,"

provides the basis for the following assessment.

4.1 Required Emergency Communication Capabilities (NEI 12-01 Section 4.1)

The GGNS Emergency Planning Department has reviewed the communications links and has determined the method of communications (Le. radio or satellite phone) for each defined link and overall the number of satellite phones and radios needed. GGNS has performed an analysis and determined that no additional satellite phones or radios are needed to establish the required links. There may be an opportunity to optimize the amount of equipment needed. The attached rollup tables provide additional detail on the identified communication links.

4.2 Plant Paging (Announcement) System (NEI 12-01 Section 4.2)

NEI 12-01 Section 4.2 requires notification of the plant staff at the onset of the event. The GGNS plant paging system provides public address capability over a large portion of the site. Considering the event as defined by NEI 12-01, the system is limited primarily by the lack of system wide back up power. Although portions of the system may be available, it will not be credited as available for notification of plant personnel. Alternative measures should be established (e.g.

non-essential plant personnel should be trained to report to site assembly areas during SSO conditions).

4.3 Communications Equipment at ORO Facilities (NEI 12-01 Section 4.3)

Per NEI 12-01, "Some communications capability should be available at the ORO facilities that normally receive licensee notifications of an emergency declaration or a Protective Action Recommendation." The GGNS Emergency Planning Department has assessed capabilities as their Offsite Response Organization (ORO) facilities. All four (4) ORO facilities [Mississippi Emergency Management Agency (MEMA), Governor's Office Homeland Security/Emergency Preparedness (GOSHEP), Claiborne County Sheriff's Department, Tensas Parish Sheriff's to GNRO-2012/0131 Page 3 of 24 Department] have backup power. Additional communication capabilities (Le.

satellite phones) would be required at some of the facilities.

4.4 Notification of the Emergency Response Organization (ERO) (NEI 12-01 Section 4.2)

NEI 12-01 offers two potential options to promote timely staff augmentation by the ERO. GGNS will ensure that "ERO members are trained to automatically respond to their assigned facilities or a designated staging area when made aware of a wide loss-of-grid (e.g. by direct observation, media reports, word-of-mouth, etc.)."

This expectation has been communicated to the ERO and will also be included in annual ERO requalification training.

4.5 Equipment Location Requirements (NEI 12-01 Section 4.5)

Communication equipment to be used or considered operable, "should be in a location and maintained in a manner that maximizes survivability following a beyond design basis external event. In particular, the location or manner should reasonably preclude wetting from flooding or impact damage from a seismic event". The communication links as defined by NEI 12-01 should be established using satellite phones and radios. Existing, installed communications equipment to be credited (Le. considered operable) is limited to the plant radio system(s).

Assessments have been performed, including walkdowns, of the existing installed radio equipment. Enhancements are recommended to address some identified concerns associated with the equipment's ability to survive a seismic event.

Structural capability of the equipment support/mounting as well as impact from adjacent equipment and/or stored material should be addressed. No issues associated with wetting from flooding were identified. See Sections 4.12.1 - 4.12.5 and Table 9 in attached rollup tables for details. Programmatic requirements need to be established to ensure the credited equipment is maintained in a manner that maximizes survivability.

4.6 Performance Characteristics (NEI 12-01 Section 4.6)

The performance characteristics as identified in this section of NEI 12-01 requires that communication pathways (e.g., radio channels, satellite phone) designated to support multiple functions must be analyzed to demonstrate that they can simultaneously support both functions. Entergy has not identified any communication pathway assigned to support multiple functions.

4.7 Other Assessment Considerations (NEI 12-01 Section 4.7)

Enhancements (physical and programmatic) are recommended to ensure considerations, as identified in this section of NEI 12-01, are met. Provisions for portable backup power sources and batteries for battery operated equipment should be established.

to GNRO-2012/0131 Page 4 of 24 4.8 Quality and Maintenance-Related Requirements (NEI 12-01 Section 4.8)

The requirements identified in this section of NEI 12-01 should be incorporated into the program for ensuring the credited equipment is maintained in a manner that maximizes survivability. Programmatic controls should be established to ensure that equipment remains available and operable.

4.9 National Communications System (NCS) Services (NEI 12-01 Section 4.9)

Entergy information technology (IT) has assessed the NCS services. Entergy IT recommends that GETS access cards be acquired for key GGNS site positions.

4.10 Communication Provider Emergency Services (NEI 12-01 Section 4.10)

Entergy has contacted the major communications service providers which service the Entergy nuclear fleet (i.e. Verizon and AT&T). Neither company has a separate emergency services priority other than government TSP (Telecommunications Service Priority), which is addressed in Section 4.9. No further enhancements are planned.

4.11 Personnel Training (NEI 12-01 Section 4.11)

Additional training is needed to ensure ERO and plant staff is familiar with the credited equipment's use and location.

4.12 Equipment Locations and Capabilities The communications functions, radio reception/transmission equipment, and protection of each location from seismic, wind, and flooding are discussed below.

Specifically, the structural capacity of the equipment in its current configuration was evaluated in its ability to withstand the identified external hazards. These hazards include seismic, flooding, and high winds. The structural evaluation was based on engineering judgment developed by a consensus of two engineers experienced in structural design and construction.

It is required that EP Communication equipment be reasonably protected from a beyond design basis seismic event. To the extent possible, the existing guidance provided in Electric Power Research Institute (EPRI) NP-6041, " Nuclear Power Plant Seismic Margin" is used for determination of the seismic/wind design capabilities of structures containing and Systems, Structures and Components (SSC's) in the vicinity (adjacent and overhead) of existing Emergency Plan (EP)

Communication equipment. Additionally, existing seismic/wind housekeeping procedures should be used to establish secure storage of EP communication equipment. This included consideration of adjacent SSCs that may pose a potential seismic/wind interaction hazard.

Where these procedures and guidance cannot be applied, it should be ensured that EP Communication equipment be contained within one or more of the configurations:

to GNRO-2012/0131 Page 5 of 24

• In an existing safety related structure designed for the Safe Shutdown Earthquake (SSE), or

• In a structure designed to or evaluated equivalent to ASCE 7-10, "Minimum Design Loads for Buildings and Other Structures", or

• Outside a structure and evaluated for seismic interactions to ensure equipment is not damaged by non-seismically robust components or structures, and

• Equipment is located above the design basis flood elevation for the plant (114.5 ft) or is otherwise protected and would not be subjected to localized flooding.

The sections below provide a summary of the area walk downs and their potential configuration concerns that could present challenges in maintaining an operable communication system in the event of one or more of the identified environmental hazards.

4.12.1 189' Turbine Building Deck Radio Room Location and General Description The communications equipment is located in a room constructed with steel channel framing and metal panels on four sides and the ceiling. The floor is the concrete floor of Turbine Building EI. +189 ft. The room is bounded by the Turbine Building exterior. Entrance is through an interior fire door from the main building entrance. The room is normally cooled via air conditioning. The antennae for the repeaters are located outside on the top of the Turbine Building.

While the Radio Room is not a seismically designed structure nor is it located in or anchored to a seismically designed structure, the steel frame and panel construction, as well as the construction of the Turbine Building appears robust enough to survive a seismic event.

Equipment & Functionality The radio room contains six repeaters covering radio channels 1, 2, 3, 4, 5 and

6. The repeaters are Motorola Model MTR2000 T5766A and are connected to receive and transmit antennas on the roof. These provide coverage for all interior and exterior areas of the plant. The equipment does not have a hardwired interface and is a RF retransmission location only. A simplified block diagram of the equipment is shown Plant Radio System Drawing E-6087 rev.

OOO,Appendix E. A Mitsubishi ST121 satellite phone terminal dedicated for control room communication is installed in the turbine deck radio room.

Transceiver unit is connected to antenna unit mounted on the roof of Turbine Building.

Power Power to the radio system equipment and satellite phone terminal is supplied from a local 120V AC Power Panel R61-1(per GGNS engineering personal during walk down). Power to P61-1 is fed from 120-240V Uninterruptable Power Distribution Panel 1Y91. Panel 1Y91 gets power feed from inverter cabinet 1Y82. Primary AC power to inverter cabinet 1Y82 comes from 480V MCC16842, to GNRO-2012/0131 Page 6 of 24 breaker no. 52-164213 via step down transformer 1XY74 (drawing E-1024).

Backup power to inverter cabinet 1Y82 is fed from 125V DC Bus 11 DE, breaker 72-11 E08. 125V DC Bus 11 DE is connected to 125V DC battery 1E3 via breaker 72-11 E01. Capacity of Battery 1E3 is 2175 Amp Hour at 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge rate (drawing E-1022). As an enhancement, the UPS batteries will be sized to provide adequate amp hour capacity as required.

Structural Assessment Radio room, Turbine Building Elevation 189 ft.

Seismic Protection - ENHANCEMENT o Anchorages

• The racks that support the Zetrons as well as some other communications equipment are anchored to the floor and are unsupported at the upper end (two racks have a small bracket anchored to the ceiling). The free end (upper end) of these racks needs to be supported. In addition, the Zetron rack is not anchored to the floor with bolts that penetrate the rack base plate. The majority of the baseplate anchorages should penetrate through the baseplates as is the case with the other racks in the room.

• Some electrical equipment is missing hardware that fastens it to the racks.

For example the switches located on the Zetron racks are missing screws and some gauge panels are missing screws to anchor to the mounting rack.

o Spatial Interactions

• In the back left of the Radio Room, there are two Motorola cabinets. The smaller cabinet houses a portion of the satellite phone system. This cabinet should be anchored to the floor and the satellite phone system should be anchored within the cabinet or the satellite system relocated and adequately anchored. The tall cabinet should either be anchored to the floor or removed from the room if it is not needed.

• On the right side of the room, behind the racks near the door, another Motorola cabinet that stands alone is unanchored. This cabinet should be anchored to the floor or removed if not needed. This cabinet could fall on the Zetrons.

o Housekeeping

• There are a lot of miscellaneous items laying on some of the transmitters that needs to be removed.

• The entire room needs to be cleaned up. GGNS representatives stated that some modifications were made to some of the equipment in the room and clean up from this activity has not taken place. Cardboard tubes, spare cables, trays near the equipment racks, miscellaneous equipment on top of spare Motorola boxes, and chairs should be removed or organized.

Flood Protection - ACCEPTABLE to GNRO-2012/0131 Page 7 of 24 High Winds Protection - ACCEPTABLE (equipment located inside building)

Antennae. Turbine Building Roof Seismic Protection - ACCEPTABLE Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE 4.12.2 Containment Building EI. 161' Location and General Description The communication equipment is located inside of the Containment Building on approximately the +161 ft elevation. The cabinet sits on a landing constructed of steel grating. The cabinet is anchored to Unistrut which is anchored to the metal grating.

Equipment & Functionality The Containment Building contains two repeaters Motorola Model MTR2000 T5766A. Per verbal discussion with GGNS EP and Jackson Communication personal during walk down, the assessment team was informed that containment building radio system equipment is not used by station emergency response organization.

Power Not Applicable (NA)

Structural Assessment Seismic Protection - ACCEPTABLE Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE 4.12.3 Emergency Operations Facility (EOF)

Location and General Description The EOF is located northwest of the reactor at an elevation above the power block yard grade elevation. Equipment is located in four portions of the EOF.

The EOF is located on the first floor of the Energy Service Center (ESC). The EOF is situated in the north section of the building. A diesel generator is located in a room on the first floor in the west section of the building. A mechanical to GNRO-2012/0131 Page 8 of 24 penthouse located on the third floor in the east section of the building houses satellite phone and an air compressor that supplies the air starter on the diesel generator. On the roof of the ESC antennae are located to send and receive communications to and from the EOF.

Equipment & Functionality The EOF contains portable, handheld mobile radios covering radio channels for EOF Communicator for communications between the EOF and the TSC or ORO.

The EOF Penthouse contains one Mitsubishi ST122 satellite phone terminal.

Transceiver unit is connected to antenna unit mounted on the roof of EOF.

Building Satellite phones are used by the EOF Director, EOF Rad Manager for the Rad Protection measuring and dose assessment team and the Health Physics Network bridge for offsite communications.

Power 120V AC power supply to communication equipment in EOF is fed thru distribution panel HDP1 BS. Primary power to EOF building comes from GGNS site facility power loop thru a pad mounted step down transformer. Backup power supply is connected to 625 KVA diesel generator tag # SX46-S001 via ASCO transfer switch. As an enhancement, it is recommended to purchase spare batteries to ensure all communication links are fully functional.

Structural Assessment EOF Building The desktop communication equipment located in the EOF was not evaluated as a part of this walk down. This equipment is considered similar to a portable phone and would not ordinarily be required to be fixed to a desk and doing so would be considered cumbersome. Therefore from a structural perspective, the equipment in this room is judged as acceptable.

Seismic Protection - ENHANCEMENT o Anchorages

• Diesel skid is mounted on compressible (rubberized) pads that elevate the skid off of the equipment foundation. The skid should be mounted directly on the equipment pad.

• Diesel anchorage hardware not fully engaged.

• Diesel Generator Battery Boxes not anchored to the floor.

o Spatial Interactions

• Air pipes in overhead have some long unsupported spans. The air piping is required for starting the generator.

• Fluorescent lights in overhead could fall out of the light fixture and needs to to GNRO-2012/0131 Page 9 of 24 be secured.

• Lube oil tank stand is not adequately restrained. The tank could very easily tip over even without a seismic event. The tank needs to be anchored to the floor as it could impact the diesel air lines and preclude the diesel from starting.

• Grey plastic piping (carrying water) in the overhead is supported by conduit on one side of the room. This pipe should be appropriately supported Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE (equipment located inside building)

Mechanical Penthouse Seismic Protection - ENHANCEMENT

• Anchorages

• Power strip that supplies power to the equipment should be secured. All other equipment is anchored to the concrete walls via unistrut or anchored to plywood anchored to the wall. This is not an issue that causes the seismic to be considered unprotected, but is discussed to identify an easy fix in this area.

o The air compressor skid is anchored using only 3 of 4 anchor locations -

only two of the three anchors are fully engaged to secure the compressor.

o The air compressor skid is elevated on compressible (rubberized) pads that are only located under the mounting feet. The tank and motor load is transferred to the feet through the skirt and mounting feet welds. The skirt and the mounting feet should be in contact with the floor.

• Spatial Interactions o Another cabinet that is located within a "tipping distance" <<2 ft.) of the communication equipment is not anchored - this cabinet should be secured or moved out of the possible range of impact.

o Fire protection piping directly overhead of electronic equipment. Depending on the seismic event fire protection piping could leak or spray on communications equipment. Consideration should be made to moving the equipment out the leak range of the piping or shielding the equipment.

o Power and antenna cables are not organized or all in cable trays. Some extra antenna cables are coiled up between connection points and the mass of the coiled antennas could place unintended loads on the equipment during a seismic event. The antenna coils should be adequately secured.

to GNRO-2012/0131 Page 10 of 24 o Air discharge piping from the air compressor is constructed of thin walled rigid copper tubing. The tubing is routed directly to the wall and rigidly supported. An expansion loop should be installed in the tubing or the tubing routed from the compressor should be flexible.

• Housekeeping o Cables in the area local to the EP Communication equipment needs to be better organized.

o There is an unused motor on the same equipment foundation pad as the air compressor that should be moved. There is a fan and vacuum cleaner very near the air compressor that could be correctly stored.

Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE Antennae Seismic Protection - ACCEPTABLE Flood Protection - ACCEPTABLE High Winds Protection - ENHANCEMENT o Antenna cables could be restrained to the support stanchions.

4.12.4 Technical Support Center (TSC)

Location and General Description The TSC is located directly above and overlooking the Control Room on the mezzanine level (EL 177') of the control building. The control building which houses the TSC is designed Safety Class 3. The control building is seismic category I, and is designed to withstand tornadoes and extreme wind phenomena.

Equipment & Functionality The TSC room contains portable, handheld mobile radios and satellite link providing communications between the TSC and various EP stations.

The TSC contains a portable, handheld mobile radio covering radio channels provided for Unit Response Coordination in the TSC. The TSC contains portable, handheld mobile radio channels for TSC Communicator for communications between the TSC and the EOF. The TSC contains satellite phone covering the ENS Communicator for Emergency Notification System (ENS), Site Emergency Director, Operations Manager for OPS bridge communications, Maintenance Manager for Maintenance bridge to GNRO-2012/0131 Page 11 of 24 communications, Engineering Manager for Engineering bridge communications and Radiological Support for Radiation Protection bridge communications..

Power The 120V AC power supply for ERF dedicated communications equipment in TSC is fed from a local Uninterruptable Power Distribution Panel and is backed up by a ups. As an enhancement, the UPS batteries will be sized to provide adequate amp hour capacity as required.

Structural Assessment The desktop communication equipment located in the TSC was not evaluated as a part of this walkdown. This equipment is considered similar to a portable phone and would not ordinarily be required to be fixed to a desk and doing so would be considered cumbersome. Therefore from a structural perspective, the equipment in this room is judged as acceptable.

4.12.5 Ingleside Remote Site Location and General Description The Ingleside Remote Site is located approximately 3.5 miles North East of site.

A small building is located at the site inside a fence. The building has two rooms, one room for housing the electronic equipment and one room that houses a propane generator. A propane storage tank is located behind the building outside. The building is a steel framed concrete structure that is secured to a concrete slab.

Equipment & Functionality The Ingleside Remote Site location contains two radio repeaters covering radio channels 7 and 8. The repeaters are Motorola Model MTR2000 T5766A and are connected to receive and transmit antennas on the roof.

Power 120V AC power to radio system equipment is supplied from local Power Panel MBP that is fed from offsite utility power line thru a pole mounted step down transformer. During shut down of offsite utility line, alternate power is fed from a locally installed propane gas engine driven generator 30 KVA, 1-phase120/240V AC, thru an auto transfer switch located inside the Ingleside Remote Site building.

Structural Assessment Seismic Protection - ENHANCEMENT to GNRO-2012/0131 Page 12 of 24 Radio Equipment Room (right side of building)

• Anchorages o The Channel 7 equipment cabinet is not anchored and could shift or impact rack mounted equipment.

Spatial Interactions o There is a rolling toolbox, 2 spare Motorola cabinets that are not fixed in place. These could be fixed in place or removed.

o There is an unanchored file cabinet in the area that needs to be secured or removed.

Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE Propane Generator Room (left side of building)

Seismic Protection - ACCEPTABLE Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE Propane Tank (outside)

Seismic Protection - ENHANCEMENT

• Anchorages o The propane tank is not anchored to the concrete pad Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE to GNRO-2012/0131 Page 13 of 24 Rollup Document 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 power source (if applicable) 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.

Note: Enhancements have been identified for power supplies for credited equipment (Le. equipment expected to be operable following LSEE). Detailed engineering should be performed to finalize the approach for these enhancements (e.g. UPS/batteries and/or portable generators).

to GNRO-2012/0131 Page 14 of 24 Table-1: Offsite Response Organization Notifications to, and communications with, OROs [per 10 CFR 50 Appendix E.IV.D and E.g.a]

Emergency Minimum Primary Method Primary Method Backup Backup Planned or Potential Response Communications Described in Available Method(s) Method(s) Improvement Facility Links site E-Plan following Described in Available Identified?

Assumed Large site E-Plan following Scale External Assumed Event (LSEE)? LSEE?

Control Room 1 per Control Operational Hot NO UHF Radio YES NO Room for Line Communicator Technical Support 1 for Key TSC Operational Hot NO UHF Radio YES YES Center (TSC) Communicator Emergency 1 for Key EOF Line NO UHF Radio YES YES Operations Communicator Facility (EOF) to GNRO-2012/0131 Page 15 of 24 Table-2: Nuclear Regulatory Commission 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]

Emergency Minimum Primary Method Primary Method Backup Backup Planned or Potential Response Communications Described in Available Method(s) Method(s) Improvement Facility Links site E-Plan following Described in Available Identified?

Assumed site E-Plan following LSEE? Assumed LSEE?

Control Room 1 per Control Dedicated Phone NO None N/A NO Room for ENS Line Communicator Technical Support 1 for ENS Dedicated Phone NO NONE N/A NO Center (TSC) Communicator Line Location(s) where 1 for HPN Dedicated Phone NO NONE N/A NO HPN Communicator Line Communications are performed to GNRO-2012/0131 Page 16 of 24 Table-3: Licensee Emergency Response Facilities 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, sound-powered and satellite-based communications systems.

Emergency Minimum Primary Primary Method Backup Backup Method(s) Planned or Response Communications Method Available following Method(s) Available following Potential Facility Links Described in Assumed LSEE? Described in Assumed LSEE? Improvement site E-Plan site E-Plan Identified?

Control Room 1 per Unit Fiber Optic NO UHF RADIO YES* NO Phone Line Technical 1 each for: Fiber Optic NO UHF RADIO YES* YES Support

• Senior/Lead TSC Phone Line Center Manager

• Operations Coordination

• Maintenance Coordination

• Engineering Coordination

• Radiological Support Additional response coordination links for multi-unit sites:

• 1 for each position providing Unit

Response

Coordination.

to GNRO-2012/0131 Page 17 of 24 Emergency Minimum Primary Primary Method Backup Backup Method(s) Planned or Response Communications Method Available following Method(s) Available following Potential Facility Links Described in Assumed LSEE? Described in Assumed LSEE? Improvement site E-Plan site E-Plan Identified?

Operations 1 each for: Fiber Optic NO UHF RADIO YES* NO Support Phone Line

• Senior/Lead OSC Center (OSC) Manager

• Radiological Support Additional response coordination links for multi-unit sites:

• 1 for each position providing Unit In-Plant Team Coordination.

1 each for: Fiber Optic NO UHF RADIO YES* YES Emergency

• Senior/Lead Manager Phone Line Operations

• Key Protective Facility (EOF)

Measures

• Operations or Technical Support (as needed to support performance of dose projections, formulation of PARs and plant status updates to ORO authorities).

Joint 1 for Senior Manager EOF/ENMC NO NONE N/A N/A Information Hot Line Center (JIC)

• There would be limited radio communication capability to GNRO-2012/0131 Page 18 of 24 Table-4: Field I Offsite Monitoring Teams Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix E.9.c].

Emergency Minimum Primary Method Primary Method Backup Backup Planned or Potential Response Communications Described in Available Method(s) Method(s) Improvement Facility Links site E-Plan following Described in Available Identified?

Assumed site E-Plan following LSEE? Assumed LSEE?

Primary location Field/offsite UHF RADIO NO NONE N/A YES where field/offsite monitoring team monitoring team coordination coordination is performed (EOF)

Primary location 1 for each NO NONE N/A YES UHF RADIO from which field/ field/offsite offsite monitoring monitoring team teams are deployed (TSC) to GNRO-2012/0131 Page 19 of 24 Table-5: Other Federal Agencies 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 Potential Response Communications Described in Available Method(s) Method(s) Improvement Facility Links site E-Plan following Described in Available Identified?

Assumed site E-Plan following LSEE? Assumed LSEE?

Primary location Coordination with N/A N/A N/A N/A N/A where Federal agencies -

communication with Federal agencies is performed to GNRO-2012/0131 Page 20 of 24 Table-6: On-site and In-plant Response Teams 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).

Emergency Minimum Primary Method Primary Method Backup Backup Planned or Potential Response Communications Described in Available Method(s) Method(s) Improvement Facility Links site E-Plan following Described in Available Identified?

Assumed site E-Plan following LSEE? Assumed LSEE?

On-shift staff Number UHF RADIO NO NONE N/A YES necessary for the on-shift staff to perform Initial Phase coping actions (reflecting current staff &

strategies) to GNRO-2012/0131 Page 21 of 24 Emergency Minimum Primary Method Primary Method Backup Backup Planned or Potential Response Communications Described in Available Method(s) Method(s) Improvement Facility Links site E-Plan following Described in Available Identified?

Assumed site E-Plan following LSEE? Assumed LSEE?

Operational 1 each for: UHF Radio NO NONE N/A YES Support Center

• On-site radiological (All)

(OSC) and monitoring other site-specific 2 each for:

locations as

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

• In-plant radiological monitoring

• Search and Rescue

• Emergency repairs Site-specific number needed to implement any 2 severe accident mitigation strateQies

• There would be limited radio communication capability to GNRO-2012/0131 Page 22 of 24 Table-7: Plant Paging (Announcement) System Emergency Response Minimum Communications Is this system available Planned or Potential Improvement Facility Links following assumed LSEE? Identified?

N/A See assumptions and NO YES - alternate approach see Section 4.2 discussion in NEI 12-01.

to GNRO-2012/0131 Page 23 of 24 Table-8: Communications Equipment at ORO Facilities Emergency Minimum Primary Primary Method Backup Backup Planned or Potential Response Facility Communications Method Available Method(s) Method(s) Improvement Links Described in following Described in Available Identified?

site E-Plan Assumed LSEE? site E-Plan following Assumed LSEE?

Location where At least one. See OROs receive assumptions and notifications of an discussion in NEI emergency 12-01.

declaration or a Protective Action ORO FACILITY Recommendation (as described in the (MEMA) Operational Hot NO NO N/A NO site emergency plan) Line (GOHSEP) Operational Hot NO NO N/A NO Line Claiborne Operational Hot NO UHF Radio YES YES Line Tensas Parish Operational Hot NO UHF Radio YES YES Line to GNRO-2012/0131 Page 24 of 24 Table-9: Equipment Locations and Protection Primary System Equipment protected from the below hazards System/Equipment Component Protected from Protected from Protected from Location Seismic Flooding Wind EOP N/A N/A N/A In-Facility Satellite TSC N/A N/A N/A Phones CR N/A N/A N/A Turbine Deck Radio NO YES YES UHF Radio Repeaters Room 189' Ingleside Remote Site NO YES YES

ATTACHMENT 2 TO GNRO-2012/0131 LIST OF REGULATORY COMMITMENTS to GNRO-2012/0131 Page 1 of 2 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED (Check One) COMPLETION COMMITMENT DATE ONE-TIME CONTINUING (If Required)

ACTION COMPLIANCE Enhancements identified within the x Prior to Startup from assessment (GNRO-2012/00131, Refueling Outage ) will be further developed as (RFO) Spring 2016 implementation progresses. Alternate approaches will be utilized if prudent (e.g.,

alternate/new technology, improved capability, cost savings, etc.). These enhancement commitments are subject to change as a result of Diverse and Flexible Coping Strategies (FLEX) developments, advances in technology, and progress in the manner of addressing the need for these enhancements.