NG-12-0430, Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 9.3, Emergency Preparedness

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Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 9.3, Emergency Preparedness
ML12307A120
Person / Time
Site: Duane Arnold 
Issue date: 10/31/2012
From: Richard Anderson
NextEra Energy Duane Arnold
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-12-0430
Download: ML12307A120 (31)


Text

NEXTera ENERG_-7YQA DUAN ARN OLDOL q October 31, 2012 NG-12-0430 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49 Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 9.3, Emergency Preparedness

References:

1. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident; dated March 12, 2012, (ML12073A348)
2. NRC Letter, D.L. Skeen (NRC) to S. Perkins-Grew (NEI), "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," dated May 15, 2012, (ML12131A043)

3. NextEra Energy Duane Arnold, LLC's 90 Day Response to NRC Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident," NG-12-0232, dated June 8, 2012, (ML12165A473)

On March 12, 2012, the NRC staff issued the Reference 1 letter requesting information pursuant to Title 10 of the Code of Federal Regulations 50.54(f). Enclosure 5 of the letter contains specific Requested Actions and Requested Information associated with Recommendation 9.3 for Emergency Preparedness (EP) programs. The requested information consists of the following three items:

(1) 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. The assessment should:

Identify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies, NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-12-0430 Page 2 of 3 Identify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies, 0

Provide a description of any new communications system(s) or technologies that will be deployed based upon the assumed conditions described above, and 0

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; (2) a description of any interim actions that have been taken or are planned to be taken to enhance existing communications systems power supplies until the communications assessment and resulting actions are complete; and (3) an implementation schedule of the time needed to conduct and implement the results of the assessment.

The Reference 2 letter documents the NRC's review and acceptance of NEI 12-01, Revision 0 as providing an acceptable method for licensees to employ when responding to the 10 CFR 50.54(f) letters regarding Recommendation 9.3.

Table 1.1 of NEI-12-01 provides a summary of licensee actions and due dates pertaining to the subject NRC information request. Consistent with Action # 3 of this table, NextEra Energy Duane Arnold, LLC (hereafter, NextEra Energy Duane Arnold) responded to item 2 of the information request via the Reference 3 letter. In that response, NextEra Energy Duane Arnold identified an interim action to make portable satellite phones available in various Emergency Response Organization facilities. That interim action has been completed. Consistent with Action # 5 of this table, this letter is responsive to items 1 and 3 of the information request and completes our response to the Communications portion of Recommendation 9.3.

The enclosed report, "DUANE ARNOLD ENERGY CENTER COMMUNICATIONS ASSESSMENT DURING AN EXTENDED LOSS OF AC POWER," was prepared in accordance with the guidance of NEI 12-01, Revision 0. This report documents the requested communications assessment. The planned communications improvements resulting from the assessment, along with an implementation schedule, are identified below as new commitments.

This submittal contains the following new commitments:

Implementation Planned Communications Improvement Schedule

1. Develop procedural guidance to recharge portable July 31, 2013 communications systems batteries.
2. Develop procedural guidance to periodically test new July 31, 2013 communications equipment and portable generators.
3. Acquire Government Emergency Telecommunications July 31, 2013 Service (GETS), and the Wireless Priority Service (WPS) cards for each communication link, as appropriate to each communication type (wired or wireless).
4. At least 24 portable radios will be stored in the Control July 31, 2013 Building.

Document Control Desk NG-12-0430 Page 3 of 3 If you have any questions or require additional information, please contact Ken Putnam at 319-851-7238.

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

Executed on October 31, 2012 Richard L. Anderso Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure cc:

NRC Regional Administrator (Region III)

NRC Resident Inspector (DAEC)

NRC Licensing Project Manager (DAEC)

Enclosure to NG-12-0430 DUANE ARNOLD ENERGY CENTER COMMUNICATIONS ASSESSMENT DURING AN EXTENDED LOSS OF AC POWER Page 1 of 28

Duane Arnold Energy Center 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 Assessment Condcte By:/e Ken Putnam DAEC License Renewal Manager Name e

//

Title Mike Davis DAEC Emergency Preparedness Manager Name Title Nicole Knapp Emergency Preparedness Coordinator Name-YJ Title Jon Aller t

J.

Nuclear Technology Analyst Name (I

Title Mike Fairchild c

Principal Engineer Name Title Name Title Name Title Page 2 of 28

Executive Summary:

This assessment reviews the communications capabilities of Duane Arnold Energy Center to support emergency response to events involving loss of AC power and large scale natural events (LSNE) 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 operable.

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, dated May 2012.

The conclusion of the assessment is that Duane Arnold Energy Center 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 non-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 inoperable. The assessment concludes that enhancements are necessary to maintain communications capabilities for responding to beyond design basis events. These enhancements include:

" Develop procedural guidance to recharge portable communications systems batteries.

Develop procedural guidance to periodically test new communications equipment and portable generators.

" Acquire Government Emergency Telecommunications Service (GETS), and the Wireless Priority Service (WPS) cards for each communication link, as appropriate to each communication type (wired or wireless).

" At least 24 portable radios will be stored in the Control Building.

Page 3 of 28

Topic: 10 CFR 50.54(f) Request For Information - Near Term Task Force (NTTF) Recommendation 9.3 - Communications NRC Requested Information NRC Reauested 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 10 CFR 50.47, Appendix E to 10 CFR Part 50, and the guidance in NUREG-0696. Also addressees are requested to consider the means necessary to power the new and existing communications equipment during a prolonged 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 alternating current (ac) power.

In addition, assume that the large scale natural event 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

1. 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.

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 following emergency response functions should be available during an extended loss of AC power. Availability should be determined after a review of existing capabilities and consistent with the assumptions listed in NEI 12-01 Rev. 0 Section 2. In particular, it is important that the primary and backup (if applicable) power source for each communications system or piece of equipment be identified.

End-point equipment identified for a communications link listed below should be used solely for the purpose indicated. For example, a satellite telephone assigned to the Control Room should not be credited for performing both Offsite Response Organization (ORO) and NRC notifications.

When performing this assessment, consideration should be given to the desirability of providing some communications capabilities in alternate facilities at offsite locations instead of their normal locations in on-site facilities.

Page 4 of 28

NOTE:

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

1. 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 Page 5 of 28

4.1.1 Notifications to, and communications with OROs [per 10 CFR 50 Appendix 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 I per Control Room Microwave No Telephone No No Attachment D for Shift Facilities System Attachment A Communicator (Telephone)

Installed No No Satellite Phone Commercial No No Cell Phone Portable Yes (1)

Yes Satellite Phone Technical 1 for TSC Admin Microwave No Telephone No No Attachment D Support Center Supervisor Facilities System Attachment A (TSC)

(Telephone)

Installed No No Satellite Phone Commercial No No Cell Phone Portable Yes (1)

Yes Satellite Phone Emergency 1 for EOF Support Microwave No Telephone No No Attachment D Operations Supervisor Facilities System Attachment A Facility (EOF)

(Telephone)

Installed No No Satellite Phone Commercial No No Cell Phone Portable Yes (1)

Yes Satellite Phone Note 1: Portable satellite phones are available at each ERO facility to provide communications to off-site facilities in the event that all other communications links are lost. These portable satellite phones are not described in the E-Plan.

Page 6 of 28

4.1.2 Notifications to, and communications with, the Nuclear Regulatory Commission (NRC) Headquarters Incident Response Center and the aDorooriate NRC Reaional Office Operations Center rDer 10 CFR 50 A Dendix El 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 1 per Control Room Federal No Telephone No No Attachment A for ENS Telecommunic System Attachment D Communicator ations System Microwave No No (FTS 2001)

Facilities Installed No No Satellite Phone Commercial No Yes Cell Phone Portable Yes (1)

Yes Satellite Phone TSC I for ENS Federal No Telephone No No Attachment A Communicator Telecommunic System Attachment D ations System Microwave No No (FTS 2001)

Facilities Installed No No Satellite Phone Commercial No Yes Cell Phone Portable Yes (1)

Yes Satellite Phone Page 7 of 28

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 LSNL?

LSNE?

EOF 1 for HPN Federal No Telephone No No Attachment A Location where Communicator Telecommunic System Attachment D HPN ations System Microwave No No communications (FTS 2001)

Facilities are performed Installed No No Satellite Phone Commercial No Yes Cell Phone Portable Yes (1)

Yes Satellite Phone TSC 1 for HPN Federal No Telephone No No Attachment A Location where Communicator Telecommunic System Attachment D HPN ations System Microwave No No communications (FTS 2001)

Facilities are performed Installed No No Satellite Phone Commercial No Yes Cell Phone Portable Yes (1)

Yes Satellite Phone Note 1: Portable satellite phones are available at each ERO facility to provide communications to off-site facilities in the event that all other communications links are lost. These portable satellite phones are not described in the E-Plan.

Page 8 of 28

4.1.3 Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E. 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 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 1 per unit Telephone No Microwave No No Attachment A System Facilities Attachment D Installed No No Note 1 Satellite Phone All Commercial No Yes communications Cell Phone between the Plant Radio No Yes Control Room System and other ERO Portable Yes (2)

Yes facilities is Satellite Phone through the Control Room Communicator.

Technical 1 each for:

Telephone No Microwave No No Attachment A Support Center

  • Senior/Lead TSC System Facilities Attachment D (TSC)

Manager Installed No No Note 1 Co-Located with

  • Operations Satellite Phone All OSC Coordination Commercial No Yes communications
  • Maintenance Cell Phone with the OSC is Coordination Plant Radio No Yes face-to face. All
  • Engineering System communications Coordination Portable Yes (2)

Yes to other ERO

- Radiological satellite facilities is Support phones through the TSC Communicator.

Page 9 of 28

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?

Operational I each for:

Face-to-Face Yes Face-to-Face Yes No The TSC &

Support Center

. Senior/Lead OSC OSC are (OSC)

Manager adjacent to Co-located with

- Radiological each other.

TSC Support Normal communications between them is Face-to-Face communications Emergency 1 each for:

Telephone No Microwave No No Attachment A Operations

  • Senior/Lead System Facilities Attachment D Facility (EOF)

Manager Installed No No Note 1

  • Key Protective Satellite Phone All Measures Commercial No Yes communications
  • Operations or Cell Phone between the Technical Support Portable Yes (2)

Yes EOF and other (as needed to satellite phone ERO facilities is support through the performance of EOF dose projections, Communicator.

formulation of PARs and plant status updates to ORO authorities).

Joint Information 1 for Senior Telephone No Face-to-Face Yes No The JIC and the Center (JIC)

Manager System EOF are in the same building.

Face-to-Face communications will suffice.

Page 10 of 28

Note 1: The Control Room Communicator, TSC Communicator and EOF Communicator are all on a phone bridge to allow communications between all three facilities at once. Other communications between the Control Room and TSC can be by portable (handheld) radio if the telephone systems are not available.

Note 2: Portable satellite phones are available at each ERO facility to provide communications to off-site facilities in the event that all other communications links are lost. These portable satellite phones are not described in the E-Plan. The current portable satellite phones are being replaced.

Page 11 of 28

4.1.4 Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix 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?

Primary Field/offsite Radiological Yes (Using Radiological Yes (Using Yes Attachment B location where monitoring team Survey Radio portable Survey Backup portable field/offsite coordination System radios)

Radio System radios) monitoring team coordination is performed Primary 1 for each Radiological Yes (Using Radiological Yes (Using Yes Attachment B location from field/offsite Survey Radio portable Survey Backup portable which field/

monitoring team System radios)

Radio System radios) offsite monitoring teams are deployed Page 12 of 28

4.1.5 Communications with other Federal agencies as described in the site emergency plan (e.g., the US Coast Guard) [per 10 CFR 50 Appendix E]

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 Coordination with There are no N/A N/A N/A N/A N/A where Federal agencies communications communication with other with Federal Federal agencies is agencies performed described in the E-Plan.

Page 13 of 28

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

4.1.6.1 Phase 1 Assessment Emergency Minimum Primary 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?

On-shift staff Number necessary Plant Radio Yes (Using Plant Wireless No Yes Attachment A for the on-shift staff System portable Telephone Attachment B to perform Initial radios)

System Phase coping actions (reflecting current staff &

strategies)

Operational 1 each for:

Plant Radio Yes (Using Plant Wireless No Yes Attachment A Support Center o On-site System portable Telephone Attachment B (OSC) and radiological radios)

System other site-monitoring specific 2 each for:

locations as loc one s asay Firefighting (1 for necessary brigade leader and 1 for the brigade) 2 each per unit for:

- In-plant rad.

monitoring

  • Search and Rescue o Emergency repairs Page 14 of 28

4.2 Plant Paging (Announcement) System 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 See assumptions Plant Public Yes (Control Security Yes No Attachment E and discussion in Address Building &

Personnel NEI 12-01.

System Reactor Walkthrough Building only)

TSC See assumptions All Public N/A N/A N/A N/A and discussion in Address NEI 12-01 System announcements are made by the Control Room. The TSC does not make any announcements Page 15 of 28

4.3 Communications Equipment at ORO Facilities 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 Microwave No Telephone No No Attachment A OROs receive assumptions and Facilities System Attachment D notifications of discussion in NEI (Telephone)

Installed No No an emergency 12-01.

Satellite Phone declaration or a Commercial No Yes Protective Cell Phone Action Recommendati Portable Yes (1)

Yes on (as Satellite Phone described in the site emergency plan)

I I

I I

I Note 1: Portable satellite phones are available at each ERO facility to provide communications to off-site facilities in the event that all other communications links are lost. These portable satellite phones are not described in the E-Plan.

Page 16 of 28

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 Telephone No Predetermined Yes No Attachment C ERO assumptions and System response based notifications of discussion in NEI Paging on wide area loss an emergency 12-01.

System of power (memo (as described in Cell Phone to employees) the site emergency plan)

Page 17 of 28

Considerations for performing the communications assessment and identifying enhancements:

4.5 EQUIPMENT LOCATION REQUIREMENTS To be assumed operable, 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 8/29/12. 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 been/will be considered.

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

4.6 PERFORMANCE CHARACTERISTICS DAEC communications equipment is listed in existing emergency plan and UFSAR descriptions. While this review documents the robust and diverse equipment available for communications, the systems that are fully assured for the specific assumed conditions of this analysis are the plant page in the Control Building and Reactor Building portable radios and portable satellite phones. Performance characteristics of communications equipment is discussed further in the attachments.

4.7 OTHER ASSESSMENT CONSIDERATIONS DAEC identified that site communications capabilities could be enhanced by establishing a procedure for using a portable generator to charge the batteries of portable communications equipment. The battery chargers and a portable generator are available on-site.

4.8 QUALITY AND MAINTENANCE-RELATED REQUIREMENTS DAEC has established programmatic controls. As noted in the DAEC Emergency Plan Section F, Periodic tests are conducted to determine the operability of the communications systems discussed in this section. The test (preferably in conjunction with the exercise addressed in DAEC E-Plan Section N) is performed to test all communications links and notification procedures and the system used to alert the public. The NRC ENS, NRC HPN, and the other telephone lines in the FTS-2001 network are tested on a monthly basis. The Emergency Response Data System (ERDS) is tested quarterly by establishing a link with the NRC ERDS system. DAEC identified that site communications capabilities could be enhanced by adding portable satellite phones and portable generators to the list communications equipment that are periodically tested.

Page 18 of 28

4.9 NATIONAL COMMUNICATIONS SYSTEM (NCS) SERVICES NextEra Energy has arrangements to utilize the services of the National Communications System. Phone system in the emergency operations facilities could be enhanced by ensuring each applicable off site communication node has an associated GETS card for use. The fixed cell phone system can be enhanced by ensuring each applicable cell phone lines have an associated WPS card.

4.10 COMMUNICATIONS PROVIDER EMERGENCY SERVICES Existing communications vendors utilized by DAEC were contacted to determine if emergency communications services were available beyond what currently is used to improve communications for the scenarios assumed in NEI 12-01. No additional enhancements were identified. The providers contacted were Windstream Communications, Palo Phone Co., USA Communications, and Century Link.

4.11 PERSONNEL TRAINING Emergency response personnel receive periodic training on the location and use of communications systems via periodic ERO training drills.

Page 19 of 28

5.0 Planned Improvements 5 1 Planned improvements to existing on-site communications systems and their required normal and/or backup power supplies;

" Develop procedural guidance to recharge portable radio batteries.

" Develop procedural guidance to periodically test portable generators.

" At least 24 portable radios will be stored in the Control Building 5,2 Planned improvements to off-site communications systems and their required normal and/or backup power supplies

" Acquire Government Emergency Telecommunications Service (GETS) and the Wireless Priority Service (WPS) cards for each communication link, as appropriate to each communication type (wired or wireless).

" Develop procedural guidance to recharge portable satellite phone batteries.

" Develop procedural guidance to periodically test portable generators.

5,3 Provide a description of any new communications system(s) or technologies that will be deployed based upon the assumed conditions; 0 No new communications systems will be deployed.

5A4 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.

Portable generators will be able to recharge portable communication equipment batteries. Each portable radio or portable satellite phone has limited battery life. Providing a means to recharge the batteries will allow each piece of equipment to work during a loss of all ac power.

Page 20 of 28

6.0 DAEC Emergency Response Communication Systems (Current Capabilities)

Communications Alternate methods System/Equipment Description Systems/Equipment Telephone System Portable Satellite Phones See Attachment A for a detailed description.

Radio Systems Radio System 0

Portable Radios See Attachment B for a detailed description.

Emergency Response Data None ERDS needs the Plant Process Computer, the Intranet and the Internet System to communicate with the NRC. Internet connection requires TI communications with Juno Beach or Main Office (Florida). All internet connections are through servers there. T1 communications is assumed to be lost.

ERO Notification System Telephone System See Attachment A for a detailed description.

Portable Satellite Phones Federal Telecommunications Telephone System See Attachment A for a detailed description.

System (FTS 2001)

Portable Satellite Phones Installed Satellite Phone Telephone System See Attachment A for a detailed description.

Portable Satellite Phones Microwave Facilities Telephone System See Attachment D for a detailed description Radio System Public Address System

= Runner See Attachment E for a detailed description Loudspeaker Portable Satellite Phone None See Attachment A for a detailed description.

Page 21 of 28

Attachment A DAEC Telephone System Description Figure F-6 of DAEC Emergency Plan Section "F" illustrates the telephone system. The system is operated and maintained by the Palo Cooperative Telephone Association and Qwest which serves the Alliant Tower. The DAEC PBX is connected to the central office by 20 active Central Office (CO) trunk lines, 48 long distance trunks, 23 duplex dial trunks, and 24 direct dial trunk lines. The PBX also contains six direct-dial tie trunks to the microwave terminal at the DAEC Substation. The PBX currently handles approximately 1,500 telephone stations. There are 4 emergency lines with unlisted numbers which connect directly to the Control Room and several offices but do not connect through the PBX. There are 6 dedicated telecommunications circuits which bypass the local system switch in the EOF and directly connect to the public switched network provided by Qwest. There are seven data lines used for computer operations which do not connect through the PBX. A telephone cable connects the DAEC to the central office with a redundant fiber connection. This cable terminates at the DAEC PBX.

The Installed Satellite Phone System connects the DAEC Control Room to a communications satellite. This phone system provides an alternative in the event the surrounding local area communications infrastructure is degraded for any reason. In addition to a dedicated phone in the Control Room, the Installed Satellite Phone System can be accessed from any site phone via the PBX. The power supply for the Installed Satellite Phone System was upgraded in April 2012 to include an uninterruptable power supply that is sized consistent with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of use with no AC power. The antennas for the Installed Satellite Phone System are on the PSC Building.

A fixed cell phone system connects the DAEC Control Room and TSC with the Shellsburg Cell tower via exterior antenna. This phone system has a UPS power supply in the event of a loss of power.

NRC ENS and NRC HPN telephones are connected to the Federal Telephone System (FTS-2001). The NRC ENS telephones are located in the Control Room, TSC, and EOF which gives those facilities the capability to contact NRC Headquarters in Rockville, MD. The NRC HPN telephones are located in the TSC and EOF and can be used to call regional NRC offices, the NRC Headquarters, or other sites within the region. FTS-2001 is a simple phone connection of copper wire at DAEC. The box on F-7 of DAEC Emergency Plan Section "F" that says "Local" would be the local CO (Central Office) providing the dial tone. We have a DEMARC in the Computer Room were the line is installed. From there it is a patching/distributing function to get the line to the various locations; Control Room and TSC. There are no "active" devices at DAEC that support the FTS-2001 system, just copper wire and jumper panels.

The Emergency Operations Facility has available dedicated circuits to the NRC on the Federal Telecommunications system FTS-2001, Direct-ring leased telephone lines and dedicated microwave circuits to the Control Room, Technical Support Center, and Operational Support Center. In addition the EOF has direct inward dialing to unlisted numbers in the telephone system direct-ring microwave and land-based telephone lines between the Control Room, Technical Support Center, Simulator, Iowa Homeland Security and Emergency Management Division, Benton County and Linn County Emergency Operations Centers, Benton County and Linn County Sheriff 911 Dispatch Centers The Portable Satellite Phones allow communications via a communications satellite. This phone system provides an alternative in the event the surrounding local area communications infrastructure is degraded for any reason. These phones have an internal battery and can be powered by 120 VAC or 10 to 32 VDC. The antenna does not require pointing at the satellite. The phones come with a docking station.

NextEra Energy has arrangements to utilize the services of the National Communications System. Phone system in the emergency operations facilities could be enhanced by ensuring each applicable off site communication node has an associated GETS card for use. The fixed cell phone system can be enhanced by ensuring each applicable cell phone lines have an associated WPS card.

Page 22 of 28

DAEC Telephone System Communication within the plant will remain for a minimum of sixteen hours with a loss of AC power but is not protected from all natural events.

Communication anywhere offsite will be lost as the assumption for this evaluation is that all normal communications with 25 miles of the plant is lost.

Installed Satellite Phones Installed Satellite Phone communications will remain operational for a minimum of twenty four hours with a loss of AC power but is not protected from all natural events.

Fixed Cell Phone System Fixed Cell Phone System will be lost as the assumption for this evaluation is that all normal communications with 25 miles of the plant is lost.

NRC ENS and NRC HPN telephones Connection to the FTS-2001 System will be lost Emergency Operations Facility Phones 0

Emergency Operations Facility Phone connections out of the facility will be lost Portable Satellite Phones Portable Satellite Phone communications will remain operational with a loss of AC power and will be protected from all natural events.

Telephone system enhancements Provide the capability to recharge the portable communications equipment batteries via a portable generator Develop procedural guidance to periodically test new communications equipment and portable generators.

" Acquire Government Emergency Telecommunications Service (GETS), and the Wireless Priority Service (WPS) cards for each communication link, as appropriate to each communication type (wired or wireless)..

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Attachment B DAEC Radio System Description As discussed in the DAEC Emergency Plan, the DAEC has four radio systems for communications during an emergency; DAEC Radiological Survey Radio System, DAEC (Backup Radiological Survey) Radio System, Plant Operations Radio System and the Point-to Point Radio System.

The DAEC Radiological Survey Radio System (Figure F-1 of DAEC Emergency Plan Section "F") provides base-to-portable communications for conducting radiological surveys throughout the DAEC plume exposure EPZ. The base station is a mobile relay (repeater) type using two VHF frequencies for a single frequency simplex talk-around, or for monitoring short range portable-to-portable communications in the event the base station is inoperative for a short period of time. In addition, the DAEC Radiological Survey teams have three vehicles equipped with a 50-watt radio transceiver for communications to the DAEC at distances greater than obtainable with the high power portables. The transmitter is located at the Microwave Tower at DAEC.

DAEC (Backup Radiological Survey) Radio System (Figure F-2 of DAEC Emergency Plan Section "F") provides backup capability for the VHF radio listed above and provides base-to-portable communications for conducting radiological surveys throughout the DAEC plume exposure EPZ. The backup system is an 800 MHz (UHF) trunked/conventional repeater system. The trunked base is located at the Alliant Tower with conventional repeaters located at the Belle Plaine (26.5 mi.), Traer (35 mi.) and Coggon substations (16.9 mi.).

The Plant Operations Radio System (Figure F-3 of DAEC Emergency Plan Section "F") which consists of a UHF base station connected to an omni-directional antenna. Seven remote control units are associated with this base station, located in the Control Room, Control Room Back panel, Technical Support Center, Secondary Alarm Station, Security Control Point, and the Central Alarm Station. Hand-held transceivers are used in this system to provide simplex communications within the plant and onsite.

The Point-to-Point Radio System (Figure F-4 of DAEC Emergency Plan Section "F") is a base station licensed for operation in the Police Radio Service on the law enforcement statewide, point-to-point VHF frequency. This station is for communications with the Iowa Department of Public Safety radio station, Linn County Sheriffs office, Benton County Sheriff's office, and the Cedar Rapids Fire Department, and uses a two-tone sequential signal to alert the latter two public-safety stations. This point-to-point channel is also used by the Linn County Emergency Management and other public safety organizations throughout the state of Iowa. DAEC has access to a mobile communications vehicle that has the capability to replace the base stations listed above. The mobile communications vehicle has a portable generator to supply power.

There are 210 UHF radio hand held transceivers, 80 VHF radio hand held transceivers and 35 VHF/UHF radio hand held transceivers. All hand held transceivers can communicate with other hand held transceivers on the same frequency. There are sufficient hand held transceivers to equip the appropriate ERO personnel with sufficient spare hand held transceivers that can be charging while other hand held transceivers are in use.

DAEC Radio Systems All base station communications will be lost as they are not protected from all natural events Portable radios can communicate as long as the batteries last

  • The 800 MHz repeaters at Belle Plaine and Traer will remain operable as they are beyond 25 miles from the plant Radio system enhancements

" Provide the capability to recharge the portable communications equipment batteries via a portable generator a Store at least 24 radios in the Control Building.

" Develop procedural guidance to periodically test new communications equipment and portable generators.

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Attachment C ERO Notification systems - Duane Arnold has multiple methods to contact designated ERO members in the event of an emergency. All ERO members will be contacted via a phone call to their home or cell phone as needed. All management personnel filling a key ERO duty position will also have one of the following two methods available:

" A pocket-radio paging system, operated and maintained by a local contractor. The system is designed to enable simultaneous contact of such personnel in the event of an emergency.

" Cell phones or other similar devices that are programmed to be automatically contacted in the event of an emergency.

In the event of a wide scale natural event that impaired the ERO notification system, ERO members are expected to respond to their ERO facility without formal notifications. This expectation was communicated to the ERO members as part of the required annual training.

ERO Notification Systems Communication anywhere offsite will be lost as the assumption for this evaluation is that all normal communications with 25 miles of the plant is lost.

ERO Notification system enhancements None identified at this time Page 25 of 28

Attachment D Microwave Facilities - Duane Arnold, with a group of Iowa utilities, participates in a shared microwave system, a portion of which is illustrated in Figure F-5. The hub of this system is located at the Alliant Tower in Cedar Rapids. A westerly path extends from Cedar Rapids to the DAEC and contains the following:

  • 24 channels used for outdial telephone, which connect the Duane Arnold phone system in Cedar Rapids to the DAEC phone system.
  • Various circuits which connect the Central Alarm Station, the Secondary Alarm Station, the Linn County EOC and sheriff, the Benton County EOC and sheriff, the State of Iowa EOC's, the EOF, the TSC, Simulator, and the Control Room into a private telephone network referred to as the "DAEC ALL-CALL". See Figure F-8.

Additional microwave facilities provide paths east and west from the DAEC through the Alliant Energy substations at Vinton, Dysart, Traer, Wellsburg, and Marshalltown to complete the microwave loop system from Cedar Rapids. This enables a greater degree of reliability since loop switching equipment is installed at all microwave repeaters in the loop. Thus, if one microwave path becomes inoperative, signals will be switched continuing to provide communications to all points around the loop Microwave Facilities Microwave communication anywhere offsite will be lost as they are not protected from all natural events.

Microwave Facilities enhancements None identified at this time Page 26 of 28

Attachment E Public Address System (Plant Page) - The Public Address System is used at DAEC to notify plant personnel of initial emergency declaration. The Public Address System is divided into eight zones (reference ACP 1406.10 Attachment 1) so that power or circuit failures in one zone will not prevent operability in other zones (reference UFSAR section 9.5.2.1.2). Zone 1 supports the Reactor Building and Control Building and is powered from 1Y23 Circuit 12 which is powered from Uninterruptable AC power which is battery backed (reference ACP 1406.10 and drawing BECH-E29<1 >). Other zones are powered from reliable sources, but are not battery backed. For the assumed conditions defined for this evaluation it is anticipated that plant personnel on site would readily recognize the loss of all AC power on site and respond appropriately to their designated ERO location regardless of the status of the plant page system. In addition, EPIP 1.3 "Plant Assembly and Site Evacuation" defines alternate methods to provide notification of plant personnel using a runner system and megaphone or security vehicle loudspeaker system in the event the plant page system is inoperable for any reason. This provides reasonable assurance plant staff can be notified within approximately 30 minutes.

Public Address System

" The Public Address System in the Reactor Building and Control Building will remain operable for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> The Public Address System on all other buildings will be lost as a result of the loss of AC power.

Paging system enhancements None identified at this time Page 27 of 28

Attachment F ORO Facility Communications - ORO facilities that normally receive notifications of emergency declaration or protective action recommendations are the Benton County Emergency Operations Center, the Linn County Emergency Operations Center, and the Iowa State Emergency Operations Center. Federal facilities that receive notifications are outside Iowa and are not the subject of this evaluation. Discussion with state and county facility operators indicates that they have back up power options that ensure they maintain some communications capabilities during an extended loss of grid event. Each facility includes radio communications that are not dependent on local phone exchanges. The Linn County Emergency Operations Center and the Iowa State Emergency Operations Center have satellite phones. The Benton County Emergency Operations center will have a satellite phone in the near future. The structures housing these off site facilities and their capacity to tolerate external events were not the subject of this evaluation. The Iowa State Emergency Operations Center is located over 100 miles west of the station and would not be expected to be impacted by the assumed event in NEI 12-01. State response capabilities include the capability to deploy supplemental communications equipment to the counties if requested during an emergency.

ORO Facility Communications enhancements None identified at this time. The state and county emergency operations centers are responsible for providing their own robust communications links.

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