ML12311A028

Emergency Preparedness Information Requested by NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1,...

ML12311A028
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	10/31/2012
From:	Waldrep B Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML12311A028 (36)

Text

SDuke Benjamin C.Waldrep

~Energy PdhmnrgyCharlotte, 526 South Church Street NC 28202 Mailing Address:

Mail Code EC07H/ P.O. Box 1006 Charlotte,NC 28201-1006 704-382-8162 704-382-4541 fax October 31, 2012 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

Duke Energy Carolinas, LLC (Duke Energy)

Catawba Nuclear Station (CNS), Units 1 and 2 Docket Nos. 50-413 and 50-414 Renewed License Nos. NPF-35 and NPF-52 McGuire Nuclear Station (MNS), Units 1 and 2 Docket Nos. 50-369 and 50-370 Renewed License Nos. NPF-9 and NPF-17 Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Nos. 50-269, 50-270, and 50-287 Renewed License Nos. DPR-38, DPR-47, and DPR-55 Emergency Preparedness Information Requested by NRC Letter, Request for Information Pursuantto Title 10 of the Code of FederalRegulations 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-IchiAccident; dated March 12, 2012

Reference:

1. NRC Letter, Request for Information Pursuantto Title 10 of the Code of FederalRegulations 50.54(f RegardingRecommendation 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-IchiAccident, dated March 12, 2012

2. Duke Energy's 60-Day Response to the March 12, 2012, Request For Information RegardingEnclosure 5, Recommendation 9.3: Emergency Preparedness,dated May 9, 2012

3. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,Revision 0 On March 12, 2012, the NRC staff issued Reference 1. Enclosure 5 of Reference 1 contains specific Requested Actions and Requested Information associated with Recommendation 9.3 for Emergency Preparedness (EP) programs. 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.

www. duke-energy. corn

United States Nuclear Regulatory Commission October 31, 2012 Page 2 On May 9, 2012, Duke Energy responded to Reference 1 and submitted an alternative course of action for providing the requested information including revised information due dates and the basis for those due dates. In addition, Duke Energy committed to providing the communications assessments (Communications Request #1) for CNS, MNS, and ONS and a communications implementation schedule (Communications Request #3).

Subsequently, Duke Energy revised its commitment to provide the communications assessments and opted instead to provide communication assessment results and communication assessment rollups. In accordance with NEI 99-04, "Guidelines for Managing NRC Commitment Changes," this letter provides notification of the commitment change. The commitment change was made to ensure consistency with similar responses from other licensees.

The communication assessment results and implementation schedule is provided as Enclosure

1. Communications assessment rollups are provided as Enclosures 2 through 4. This is Duke Energy's consolidated response for all its licensed operating plants (CNS Units 1 and 2; MNS Units 1 and 2; and ONS Units 1, 2, and 3).

This letter contains no new regulatory commitments. Any actions discussed in this document should be considered intended or planned enhancement actions.

Should you have any questions concerning this letter, or require additional information, please contact Jeff Thomas, Manager, Fukushima Response Program Operations and Support, at (704) 382-3438.

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

Respectfully,

'ýadep Benjamin C ade Vice President - Corporate Governance &

Operations Support

Enclosures:

1. Communication Assessments Results and Implementation Schedule

2. Emergency Communications Assessment Rollup for Catawba Nuclear Station (CNS Units 1 and 2)

3. Emergency Communications Assessment Rollup for McGuire Nuclear Station (MNS Units 1 and 2)

4. Emergency Communications Assessment Rollup for Oconee Nuclear Station (ONS Units 1, 2, and 3)

United States Nuclear Regulatory Commission October 31, 2012 Page 3 xc:

V. M. McCree, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 Eric J. Leeds, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 13-H16M 11555 Rockville Pike Rockville, MD 20852-2738 J. H. Thompson, Project Manager (CNS & MNS)

U. S. Nuclear Regulatory Commission One White Flint North, Mailstop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 John Boska, Project Manager (ONS)

U. S. Nuclear Regulatory Commission One White Flint North, Mailstop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Oconee Nuclear Station J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station G. A. Hutto, III NRC Senior Resident Inspector Catawba Nuclear Station Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-001

Enclosure 1 Communication Assessment Results and Implementation Schedule

Communication Assessment Results and Implementation Schedule Enclosure I Duke Energy did not try to assess the survivability of primary or backup communications systems described in the Emergency Plan (E-Plan) or Emergency Plan Implementing Procedures (EPIPs) during a beyond design basis extended loss of alternating current (AC) power event. Instead, Duke Energy elected to conservatively assume that land line and cellular based communications systems would not be relied upon during a beyond design basis extended loss of AC power event. As a result of this assessment, no improvements will be made to existing onsite and offsite communications systems and their required normal and/or backup power supplies.

During a beyond design basis extended loss of AC power event, onsite communications will be established via existing hand-held radios (line-of-sight) and offsite communications will be established via hand-held satellite phones. In addition, small generators were purchased for each site. These portable diesel generators can be used to power hand-held radio battery chargers and hand-held satellite phone battery chargers. The hand-held satellite phones, radios, and small diesel generators will be incorporated into site programs and procedures (see Recommendation R-4, below).

The following recommendations (improvements), including their milestone implementation dates, were identified:

R-1: Ensure that an appropriate inventory of portable hand-held satellite phones, spare batteries, and chargers is available for use by the Emergency Response Organization.

Due Date: 03/28/2013 R-2: Evaluate and purchase, if necessary, additional portable radios, spare batteries, and chargers to ensure required communications links are fully established.

Due Date: 03/28/2013 R-3: Ensure that portable communications equipment (i.e., satellite phones, radios, and diesel generators) are stored in a manner such that maximizes survivability from applicable external events per NEI 12-01, Section 4.5.

Due Date: Consistent with the implementation due dates of Order EA-12-049.

R-4: Ensure that programmatic controls are established for communications equipment (e.g.,

portable satellite phones, radios, small generators) to ensure availability and reliability, including the performance of periodic inventory checks and operability testing per NEI 12-01, Section 4.8. Also, provide training on the locations and use of communications systems and equipment (NEI 12-01, Section 4.11).

Due Date: 9/30/2013 R-5: Ensure that programmatic controls are established for the Government Emergency Telecommunications Service (GETS)IMireless Priority Service (WPS) programs.

Due Date: 3/28/2013 R-6: Ensure that arrangements are in place with communications service providers to utilize their emergency services as described in NEI 12-01, Section 4.10.

Due Date: 9/20/2013 R-7: McGuire should evaluate and establish a reasonable alternate method to communicate initial response instructions to the plant staff, when the Public Address System is unavailable.

Due Date: 3/28/2013 Page 1 of 1

Enclosure 2 Emergency Communications Assessment Rollup for Catawba Nuclear Station (CNS), Units I and 2 Docket Nos. 50-413 and 50-414 Renewed License Nos. NPF-35 and NPF-52

Catawba Nuclear Station (CNS), Units 1 and 2 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 consistent with the assumptions in NEI 12-01, 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. Endpoint 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.

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

Primary Method Backup Refer to the Primary Available Backup Method(s) Planned or Following Emergency Minimum Method Following Method(s) Available Potential Section(s)

Response Communication Links Described in Assumed Large Described in E- following Improvement for Facility Plan1 Facility E-Plan 1 Scale External Assumed Identified? Additional Event (LSEE)? LSEE? Information 1 per Control Selective Assumed Not PBX Phones, Assumed Not Portable Control Room Room for Shift Signaling Available Radio Available Satellite Phone 4 Communicator System Technical 1 for Key TSC Selective Assumed Not PBX Phones, Assumed Not Portable Support Communicator Signaling Available Radio Available Satellite Phone 4.7 Center (TSC) System Emergency 1 for Key EOF Selective Assumed Not PBX Phones, Assumed Not Portable Operations Communicator Signaling Available Radio Available Satellite Phone 4.5, 4.7 Facility (EOF) System NOTES:

1. When used in Enclosures 2, the phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs).

Page 1 of 9

Catawba Nuclear Station (CNS), Units 1 and 2 4.1.2 Notifications to, and communications with, the Nuclear Regulatory Commission (NRC) Headquarters Incident Response Center and the appropriate NRC Regional Office Operations Center [per 10 CFR 50 Appendix E.IV.D and E.9.d]

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

1 per Control ETS Assumed Not Commercial Assumed Not Portable Control Room Room for ENS Communicator Telephone Available Telephone Available Satellite Phone 4 TechnicalET Support Center 1 for ENS ETS Assumed Not Commercial Assumed Not Portable (TSC) Communicator Telephone Available Telephone Available Satellite Phone 4.5,4.7 Location(s) where HPN 1 for HPN HPN Assumed Not Commercial Assumed Not Portable Communicator Telephone Available Telephone Available Satellite Phone 4.5 4.7 communications are performed 4.1.3 Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E.9.c. Additional links that support performance of critical response functions are also specified.]

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

Control Room ControlRoom 1 p unit 1iper jtelephone PBX Assumed Not Available PA System, Radios Available Not Assumed Portable Satellite Phone 4.5,4.7 Page 2 of 9

Catawba Nuclear Station (CNS), Units I and 2 Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or Following Response Communication Method Available Method(s) Available Potential Section(s) for Facility Links Described in Following Described in E- Following Improvement Additional E-Plan Assumed Plan Assumed Identified? Information LSEE? LSEE?

1 each for:

" Senior/Lead TSC Manager

" Operations Coordination

" Engineering Coordination Technical - Radiological PBX Assumed Not PA System, Assumed Not Portable Support Center Support Telephone Available Radios Available Satellite Phone 4.5,4.7 (TSC) Additional response coordination links for multi-unit sites:

• 1 for each position providing *F Unit Response Coordination.

Page 3 of 9

Catawba Nuclear Station (CNS), Units 1 and 2 Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or Following Response Communication Method Available Method(s) Available Potential Section(s) for Facility Links Described in Following Described in E- Following Improvement Additional E-Plan Assumed Plan Assumed Identified? Information LSEE? LSEE?

1 each for:

" Senior/Lead OSC Manager

" Radiological Support Operational Additional response PBX Assumed Not PA System, Assumed Not Portable Support Center coordination links Available Satellite Phone 4.7 (OSC) for multi-unit sites: Telephone Available Radios

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

1 each for:

" Senior/Lead Manager

" Key Protective Measures

" Operations or Technical Emergency Support (as Commercial Assumed Not Radios Assumed Not Portable 45147 Operations needed to Telephone Available Available Satellite Phone Facility (EOF) support performance of dose projections, formulation of PARs and plant status updates to ORO authorities).

JointIJit1 for Senior Commercial Assumed Not Information foraSer Com e Assume Satellite Phones Yes No N/A Center (JIC) Manager Telephone Available Page 4 of 9

Catawba Nuclear Station (CNS), Units I and 2 4.1.4 Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix E.9.c]

Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or, Following Response Communication Method Available Method(s) Available Potential Section(s) for Facility Links Described in Following Described in Following Improvement Additional E-Plan Assumed E-Plan Assumed Identified? Information LSEE? LSEE?

Primary location where field/offsite Field/offsite Satellite Portable monitoring monitoring team Radio Yes Phones Yes Satellite Phone 4.5,4.7 team coordination coordination is performed Primary location from which field/ 1 for each Satellite Portable offsite field/offsite Radio Yes Phones Yes Satellite Phone 4.5; 4.7 monitoring monitoring team teams are deployed 4.1.5 Communications with other Federal agencies as described in the site emergency plan (e.g., the US Coast Guard) [per 10 CFR 50 Appendix E.9.b]

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

Primary location where communication Coordination with PBX Assumed Not None N/A Portable 4.514.7 with Federal Federal agencies Telephone Available Satellite Phone 4 agencies is performed Page 5 of 9

Catawba Nuclear Station (CNS), Units 1 and 2 4.1.6 Coordination and direction of on-site and in-plant response teams.

4.1.6.1 Phase I Assessment Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or Following Response Communication Method Available Method(s) Available Potential Section(s) for Facility Links Described in Following Described in Following Improvement Additional E-Plan Assumed E-Plan Assumed Identified? Information LSEE? LSEE?

Number necessary On-shift staff for the on-shift staff PBX Assumed Not PA System, Assumed Not Portable Radios 4.5, 4.7 to perform Initial Telephone Available Radios Available Phase coping actions 1 each for:

- On-site radiological monitoring 2 each for:

- Firefighting (1 for brigade leader &

Operational 1 for the brigade)

Support Center 2 each per unit for:

(OSC) and

• In-plant PBX Assumed Not PA System, Assumed Not other site- radiological Telephone Available Radios Available Portable Radios 4.5, 4.7 specific monitoring locations as

• Search and necessary Rescue

- Emergency repairs Site-specific number needed to implement any 2 severe accident mitigation strategies Page 6 of 9

Catawba Nuclear Station (CNS), Units I and 2 4.2 Plant Paging Primary Backup Refer to the Method Backup Method(s) Planned or Following Emergency Minimum Primary Method Available Method(s) Available Potential Section(s)

Response Communication Described in E- Following Described in Following Improvement for Facility Links Plan Assumed E-Plan Assumed Identified? Additional LSEE? LSEE? Information See assumptions Assumed Not PBX N/A and discussion in PA System Available Telephone No Portable Radios 4.5,4.7 NEI 12-01 4.3 Communications Equipment at ORO Facilities Page 7 of 9

Catawba Nuclear Station (CNS), Units I and 2 Considerations for performing the communications assessment and identifying enhancements:

4.4 NOTIFICATION OF THE EMERGENCY RESPONSE ORGANIZATION This area was previously assessed. Information for all three of Duke Energy's licensed operating plants (CNS Units 1 and 2; MNS Units 1 and 2; and ONS Units 1, 2, and 3),

was provided to the NRC via the "90-Day Response to Recommendation 9.3 of 10CFR50.54(f) Request for Information" dated June 8, 2012. Therefore, no further assessment activities are required for this assessment area.

4.5 EQUIPMENT LOCATION REQUIREMENTS Duke Energy conservatively assumed that primary communication systems and equipment for onsite and offsite communications capabilities during a beyond design basis extended loss of AC power event would not be relied upon. Given that assumption, alternate communications systems and equipment should be stored in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external event. For example, equipment location requirements should satisfy the guidance in NEI 12-01, Section 4.5.

The adequacy of equipment storage and locations is ongoing, and is yet to be finalized.

Therefore, Duke Energy identified a recommendation/enhancement in this area. Refer to Enclosure 1, Recommendation R-3.

4.6 PERFORMANCE CHARACTERISTICS NEI 12-01 (section 2.4.7) states: "Offsite infrastructure supporting communications systems is inoperable in the area surrounding the site (e.g., cellular telephone or microwave towers, telephone central office buildings, telephone lines, etc.). For this assessment, the company has elected to "apply a default distance value, in all directions, of approximately 25 miles from the plant site." Based on these assumptions, satellite-based communications systems will be utilized to provide offsite communications.

Each site will ensure that an appropriate inventory of hand-held satellite phones is available for use by the Emergency Response Organization in their associated Emergency Response Facilities. This minimizes any reliance on "multi-use" equipment.

Refer to Enclosure 1, Recommendation R-1 4.7 OTHER ASSESSMENT CONSIDERATIONS Pursuant to the information previously provided in Duke Energy Carolina's, LLC (Duke Energy) 90-Day Response to the March 12, 2012, request for information regarding enclosure 5, recommendation 9.3 Emergency Preparedness, dated June 8, 2012, Catawba purchased small portable diesel generators that can be used to power handheld radio chargers and portable satellite phone chargers. These portable diesel generators are expected to be on site by late fall 2012. In addition, Catawba will ensure an appropriate inventory of portable hand-held satellite phones and radios, spare batteries, and chargers is available for use by the Emergency Response Organization.

Refer to Enclosure 1, Recommendations R-1 and R-2.

4.8 QUALITY AND MAINTENANCE-RELATED REQUIREMENTS Catawba's E-Plan and its EPIPs provide programmatic controls for communications equipment, and related power sources and infrastructure. Similar programmatic controls should be applied to other communications-related equipment to ensure availability and Page 8 of 9

Catawba Nuclear Station (CNS), Units 1 and 2 reliability, including the performance of periodic inventory checks and operability testing.

Refer to Enclosure 1, Recommendation R-4 4.9 NATIONAL COMMUNICATIONS SYSTEM (NCS) SERVICES Catawba will ensure that a Government Emergency Telecommunications Service (GETS) account is established and that the account is verified annually. Refer to Enclosure 1, Recommendation R-5.

4.10 COMMUNICATIONS PROVIDER EMERGENCY SERVICES Duke Energy is in the process of evaluating the emergency services offered by communication service providers. Duke Energy will ensure that arrangements are in place with communications service providers to utilize their emergency services as described in NEI 12-01, Section 4.10. Refer to Enclosure 1, Recommendation R-6.

4.11 PERSONNEL TRAINING Appropriate training will be developed for and provided to response personnel on the location and use of communications systems and equipment. Refer to Enclosure 1, Recommendation R-4.

Page 9 of 9

Enclosure 3 Emergency Communications Assessment Rollup for McGuire Nuclear Station (MNS), Units 1 and 2 Docket Nos. 50-369 and 50-370 Renewed License Nos. NPF-9 and NPF-17

McGuire Nuclear Station (MNS), Units 1 and 2 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 consistent with the assumptions in NEI 12-01, Revision 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. Endpoint 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.

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

Primary Method Backup Refer to the Minimum Primary Available Backup Method(s) Planned or Following Emergency mmum Method Following Method(s) Available Potential Section(s)

Response Communication Described in Assumed Large Described in E- following Improvement for Facility Links E-Plan 1 Scale External Plan1 Assumed Identified? Additional Event (LSEE)? LSEE? Information 1 per Control Selective Assumed Not PBX Phones, Assumed Not Portable Control Room Room for Shift Signaling Available Radio Available Satellite Phone 4 Communicator System Technical 1 for Key TSC Selective Assumed Not PBX Phones, Assumed Not Portable Support Communicator Available Radio Available Satellite Phone 45.

Center (TSC) System Emergency 1 for Key EOF Selective Assumed Not PBX Phones, Assumed Not Portable Operations Communicator Signaling Available Radio Available Satellite Phone 4.5,4.7 Facility (EOF) System NOTES:

1. When used in Enclosures 3, the phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs).

Page 1 of 10

McGuire Nuclear Station (MNS), Units 1 and 2 4.1.2 Notifications to, and communications with, the Nuclear Regulatory Commission (NRC) Headquarters Incident Response Center and the appropriate NRC Regional Office Operations Center [per 10 CFR 50 Appendix E.IV.D and E.9.d]

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

1 per Control ETS Assumed Not Commercial Assumed Not Portable Control Room Room for ENS Communicator Telephone Available Telephone Available Satellite Phone 4 Technical 1 for ENSETS Assumed Not Commercial Assumed Not Portable (TSC) Communicator Telephone Available Telephone Available Satellite Phone 4.5,4.7 Location(s) where HPN 1 for HPN HPN Assumed Not Commercial Assumed Not Portable communications Communicator Telephone Available Telephone Available Satellite Phone 4 4 are performed 4.1.3 Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E.9.c. Additional links that support performance of critical response functions are also specified.]

Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned Rergen

Response

Comimunicatn Communication Method Available Method(s) Available Potentialor Following for Section(s)

Described Following Described in Following Improvement Sectionsf in E-Plan Assumed E-Plan Assumed Identified? Information LSEE? LSEE?

C PBX Assumed Not PA System, Assumed Not Portable 4.5,4.7 Control Room 1 per unit Telephone Available Radios Available Satellite Phone Page 2 of 10

McGuire Nuclear Station (MNS), Units 1 and 2 Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or Following Response Communication Method Available Method(s) Available Potential Section(s) for Facility Links Described Following Described in Following Improvement Additional in E-Plan Assumed E-Plan Assumed Identified? Information LSEE? LSEE?

1 each for:

" Senior/Lead TSC Manager

" Operations

. Coordination

" Engineering Coordination Technical Radiological Support PBX Assumed Not PA System, Assumed Not Portable Support Center Additional response Telephone Available Radios Available Satellite Phone 45.

(TSC) coordination links for multi-unit sites:

- 1 for each position providing Unit

Response

Coordination.

Page 3 of 10

McGuire Nuclear Station (MNS), Units 1 and 2 Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or Following Response Communication Method Available Method(s) Available Potential Section(s) for Facility Links Described Following Described in Following Improvement Additional in E-Plan Assumed E-Plan Assumed Identified? Information LSEE? LSEE?

1 each for:

" Senior/Lead OSC Manager

" Radiological Operational Support Support Center Additional response PBX Assumed Not PA System, Assumed Not Portable 4.5,4.7 S Ce coordination links for Telephone Available Radios Available Satellite Phone (OSC) multi-unit sites:

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

1 each for:

" Senior/Lead Manager

" Key Protective Measures

" Operations or Emergency Technical Support Commercial Assumed Not Assumed Not Portable Operations (as needed to Telephone Available Radios Available Satellite Phone 4.5,4.7 Facility (EOF) support performance of dose projections, formulation of PARs and plant status updates to ORO authorities).

Joint Commercial Assumed Not None N/A Portable 4.5, 4.7 Information 1 for Senior Manager Telephone Available Satellite Phone Center (JiC) I '_ I I Page 4 of 10

McGuire Nuclear Station (MNS), Units 1 and 2 4.1.4 Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix E.9.c]

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

Primary location where field/offsite Field/offsite Portable monitoring monitoring team Radio Yes None N/A Satellite Phone 4.5, 4.7 team coordination coordination is performed Primary location from which field/ 1 for each Portable offsite field/offsite Radio Yes None N/A Satellite Phone 4.5, 4.7 monitoring monitoring team teams are deployed 4.1.5 Communications with other Federal agencies as described in the site emergency plan (e.g., the US Coast Guard) [per 10 CFR 50 Appendix E.9.b]

Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or Following Rmespneny CoMimunicatio Method Available Method(s) Available Potential Section(s) for Response Communication Described in Following Described in Following Improvement Additional Facility Links E-Plan Assumed E-Plan Assumed Identified? ition LSEE? LSEE?

Primary location where communication Coordination with PBX Assumed Not None N/A Portable 45,47 with Federal Federal agencies Telephone Available Satellite Phone agencies is performed Page 5 of 10

McGuire Nuclear Station (MNS), Units 1 and 2 4.1.6 Coordination and direction of on-site and in-plant response teams.

4.1.6.1 Phase I Assessment Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or Following Response Communication Method Available Method(s) Available Potential Section(s) for Facility Links Described in Following Described in Following Improvement Additional E-Plan Assumed E-Plan Assumed Identified? Information LSEE? LSEE?

Number necessary for the On-shift staff on-shift perform staff Initialto PBX Assumed Available Not PA System, Assumed Available Not Telephone Radios Portable Radios 4.5, 4.7 Phase coping actions 1 each for:

- On-site radiological monitoring 2 each for:

• Firefighting (1 for brigade leader & 1 for Operational the brigade)

Support Center 2 each per unit OSu Center for:

other S site- In-plant PBXPA System, Assumed Not Portable Radios 4.5, 4.7 specific radiological Available Radios Available locations as monitoring n Search and necessary Rescue

- Emergency repairs Site-specific number needed to implement any 2 severe accident mitigation strategies Page 6 of 10

McGuire Nuclear Station (MNS), Units I and 2 4.2 Plant Paging Primary Backup Refer to the Emergency Minimum Primary Method Method Backup Method(s) Planned or Following Response Communication Described in E- Available Method(s) Available Potential Section(s) for Facility Links Plan Following Described in Following Improvement Additional Assumed E-Plan Assumed Identified? Information LSEE? LSEE?

See assumptions Assumed Not See N/A and discussion in PA System Available None N/A Yes Recommendation NEI 12-01 7 4.3 Communications Equipment at ORO Facilities Primary Backup Refer to the Emergency Minimum Method Method(s) Planned or Following Response Communication Primary Available Backup Available Potential Section(s) for Facility Links Method Following Method(s) Following Improvement Additional Assumed Assumed Identified? Information LSEE? LSEE?

1 for key WP Selective Commercial Lincoln Communicator Selective Assumed Not Com e Assumed Not Portable 4.5,4.7 County EOC 1 for key EOC Signaling Available Telephone Available Satellite Phone Communicator System Lines 1 for key WP Selective Commercial Mecklenburg Communicator Signaling Assumed Not Telephone 4.5,4.7 County EOC 1 for key EOC Sigaln Available LneAvailable Satellite Phone Communicator System Lines 1 for key WP Selective Commercial Gaston Communicator Selive Assumed Not Com e Assumed Not Portable 4.5,4.7 County EOC 1 for key EOC Signaling Available Lne Available Satellite Phone Communicator System Lines 1 for key WP Selective Commercial Iredell Communicator Selive Assumed Not Com e Assumed Not Portable 4.5,4.7 County EOC 1 for key EOC System Available Lines Available Satellite Phone Communicator System AvaIlable I I I Page 7 of 10

McGuire Nuclear Station (MNS), Units I and 2 Primary Backup Refer to the Emergency Minimum Method Method(s) Planned or Following Response Communication Primary Available Backup Available Potential Section(s) for Facility Links Method Following Method(s) Following Improvement Additional Assumed Assumed Identified? Information LSEE? LSEE?

1 for key WP Selective Commercial Catawba Communicator Signaling Assumed Not Telephone Assumed Not Portable 4.5,4.7 County EOC 1 for key EOC System Available Line Available Satellite Phone Communicator System Lines 1 for key WP Selective Commercial NC State Communicator Signaling (>25 Telephone Yes (> 25 Portable 4.5, 4.7 EOC 1 for key EOC Sigaln miles) miles) Satellite Phone Communicator System Lines Page 8 of 10

McGuire Nuclear Station (MNS), Units I and 2 Considerations for performing the communications assessment and identifying enhancements:

4.4 NOTIFICATION OF THE EMERGENCY RESPONSE ORGANIZATION This area was previously assessed. Information for all three of Duke Energy's licensed operating plants (CNS Units 1 and 2; MNS Units 1 and 2; and ONS Units 1, 2, and 3),

was provided to the NRC via the "90-Day Response to Recommendation 9.3 of 10CFR50.54(f) Request for Information" dated June 8, 2012. Therefore, no further assessment activities are required for this assessment area.

4.5 EQUIPMENT LOCATION REQUIREMENTS Duke Energy conservatively assumed that primary communication systems and equipment for onsite and offsite communications capabilities during a beyond design basis extended loss of AC power event would not be relied upon. Given that assumption, alternate communications systems and equipment should be stored in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external event. For example, equipment location requirements should satisfy the guidance in NEI 12-01, Section 4.5.

The adequacy of equipment storage and locations is ongoing, and is yet to be finalized.

Therefore, Duke Energy identified a recommendation/enhancement in this area. Refer to Enclosure 1, Recommendation R-3.

4.6 PERFORMANCE CHARACTERISTICS NEI 12-01 (section 2.4.7) states: "Offsite infrastructure supporting communications systems is inoperable in the area surrounding the site (e.g., cellular telephone or microwave towers, telephone central office buildings, telephone lines, etc.). For this assessment, the company has elected to "apply a default distance value, in all directions, of approximately 25 miles from the plant site." Based on these assumptions, satellite-based communications systems will be utilized to provide offsite communications.

Each site will ensure that an appropriate inventory of hand-held satellite phones is available for use by the Emergency Response Organization in their associated Emergency Response Facilities. This minimizes any reliance on "multi-use" equipment.

Refer to Enclosure 1, Recommendation R-.1 4.7 OTHER ASSESSMENT CONSIDERATIONS Pursuant to the information previously provided in Duke Energy Carolina's, LLC (Duke Energy) 90-Day Response to the March 12, 2012, request for information regarding enclosure 5, recommendation 9.3 Emergency Preparedness, dated June 8, 20,12, McGuire purchased small portable diesel generators that can be used to power handheld radio chargers and portable satellite phone chargers. These portable diesel generators are expected to be on site by late fall 2012. In addition, McGuire will ensure an appropriate inventory of portable hand-held satellite phones and radios, spare batteries, and chargers is available for use by the Emergency Response Organization.

Refer to Enclosure 1, Recommendations R-1 and R-2.

4.8 QUALITY AND MAINTENANCE-RELATED REQUIREMENTS McGuire's E-Plan and its EPIPs provide programmatic controls for communications equipment, and related power sources and infrastructure. Similar programmatic controls should be applied to other communications-related equipment to ensure availability and Page 9 of 10

McGuire Nuclear Station (MNS), Units 1 and 2 reliability, including the performance of periodic inventory checks and operability testing.

Refer to Enclosure 1, Recommendation R-4.

4.9 NATIONAL COMMUNICATIONS SYSTEM (NCS) SERVICES McGuire will ensure that a Government Emergency Telecommunications Service (GETS) account is established and that the account is verified annually. Refer to Enclosure 1, Recommendation R-5.

4.10 COMMUNICATIONS PROVIDER EMERGENCY SERVICES Duke Energy is in the process of evaluating the emergency services offered by communication service providers. Duke Energy will ensure that arrangements are in place with communications service providers to utilize their emergency services as described in NEI 12-01, Section 4.10. Refer to Enclosure 1, Recommendation R-6.

4.11 PERSONNEL TRAINING Appropriate training will be developed for and provided to response personnel on the location and use of communications systems and equipment. Refer to Enclosure 1, Recommendation R-4.

Page 10 of 10

Enclosure 4 Emergency Communications Assessment Rollup for Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Nos. 50-269, 50-270, and 50-28 Renewed License Nos. DPR-38, DPR-47, and DPR-55

Oconee Nuclear Station (ONS) Units 1, 2, and 3 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 consistent with the assumptions in NEI 12-01, Revision 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. Endpoint' 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.

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

Primary Method Backup Refer to the Emergency Minimum Primary Available Backup Method(s) Planned or Following Response Communication Method Following Method(s) Available Potential Section(s)

Described in Assumed Large Described in following Improvement for Facility Links E-Plan 1 Scale External E-Plan1 Assumed Identified? Additional Event (LSEE)? LSEE? Information 1 per Control Selective Assumed Not Commercial Assumed Not Portable Control Room Room for Shift Signaling Available Phones, Radio Available Satellite Phone 4.5, 4.7 Communicator System TechnicalSectv Support 1 for Key TSC Selective Assumed Not Commercial Assumed Not Portable Support Signaling Available Phones, Radio Available Satellite Phone 4 Center (TSC) Comnctr System Emergency 1 for Key EOF Selective Commercial Portable Operations Signaling Yes (> 25 miles) Phones, Radio Yes (> 25 miles) Satellite Phone 4.5, 4.7 Facility (EOF) Communicator System NOTES:

1. When used in Enclosures 4, the phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs).

Page 1 of 9

Oconee Nuclear Station (ONS) Units 1, 2, and 3 4.1.2 Notifications to, and communications with, the Nuclear Regulatory Commission (NRC) Headquarters Incident Response Center and the appropriate NRC Regional Office Operations Center [per 10 CFR 50 Appendix E.IV.D and E.9.dj Primary Backup Refer to the Emergency Minimum Primary Method Method(s) Planned or Following Response Communication Resmeth Availabl Backup Method(s) Available Potential Described in Following Described in Following Improvement Section(s) for Facility Links E-Plan Assumed E-PlanAssumed Identified? Additional LSEE? LSEE?

1 per Control ETS Assumed Not Commercial Assumed Not Portable Control Room Room for ENS Communicator Telephone Available Telephone Available Satellite Phone 4.5, 4.7 Technical TS Support Center 1 for ENS ETS Assumed Not Commercial Assumed Not Portable (TSC) Communicator Telephone Available Telephone Available Satellite Phone 4.5,4.7 Location(s) where HPN 1 for HPN HPN Assumed Not Commercial Assumed Not Portable 4.5147 communications Communicator Telephone Available Telephone Available Satellite Phone are performed 4.1.3 Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E.9.c. Additional links that support performance of critical response functions are also specified.]

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

Assumed Not PA System, Assumed Not Portable Control Room 1 per unit PBX Telephone Available Phones, Available Satellite Phone 4.5,4.7 Radios Page 2 of 9

Oconee Nuclear Station (ONS) Units 1, 2, and 3 Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or Following Response Communication Method Available Method(s) Available Potential Section(s) for Facility Links Described in Following Described in Following Improvement Additional E-Plan Assumed E-Plan Assumed Identified? Information LSEE? LSEE?

1 each for:

" Senior/Lead TSC Manager

" Operations Coordination

" Engineering Coordination

" Radiological Technical Support Assumed Not PA System, Assumed Not Portable Support Center Additional PBX Telephone Available Radios Available Satellite Phone 4 (TSC) response coordination links for multi-unit sites:

- 1 for each position providing Unit Response Coordination.

Page 3 of 9

Oconee Nuclear Station (ONS) Units 1, 2, and 3 Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or Following Response Communication Method Available Method(s) Available Potential Section(s) for Facility Links Described in Following Described in Following Improvement Additional E-Plan Assumed E-Plan Assumed Identified? Information LSEE? LSEE?

1 each for:

" Senior/Lead OSC Manager

" Radiological Support Operational Additional Support Center response Assumed Not PA System, Assumed Not Portable 4.5,4.7 coordination links Available Radios Available Satellite Phone (OSC) for multi-unit sites:

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

1 each for:

" Senior/Lead Manager

" Key Protective Measures

" Operations or Technical Emergency Support (as Commercial Yes (> 25 Radios Yes (> 25 Portable 45147 Operations needed to Telephone miles) miles) Satellite Phone Facility (EOF) support performance of dose projections, formulation of PARs and plant status updates to I ORO authorities).

Joint Information 1 for Senior Commercial Yes (> 25 Satellite Yes (> 25 No N/A CentermJIC Manager Telephone miles) Phone miles)

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Oconee Nuclear Station (ONS) Units 1, 2, and 3 4.1.4 Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix E.9.c]

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

Primary location where field/offsite Field/offsite Portable monitoring monitoring team Radio Yes None N/A Satellite Phone 4.5, 4.7 team coordination coordination is performed Primary location from which field/ 1 for each Portable offsite field/offsite Radio Yes None N/A Satellite Phone 4.5, 4.7 monitoring monitoring team teams are deployed 4.1.5 Communications with other Federal agencies as described in the site emergency plan (e.g., the US Coast Guard) [per 10 CFR 50 Appendix E.9.b]

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

Primary location where communication Coordination with PBX Assumed Not Commercial Assumed Not Portable with Federal Federal agencies Telephone Available Telephone Available Satellite Phone 4 agencies is performed Page 5 of 9

Oconee Nuclear Station (ONS) Units 1, 2, and 3 4.1.6 Coordination and direction of on-site and in-plant response teams.

4.1.6.1 Phase I Assessment Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s) Planned or Following Response Communication Method Available Method(s) Available Potential Section(s) for Facility Links Described in Following Described in Following Improvement Additional E-Plan Assumed E-Plan Assumed Identified? ition LSEE? LSEE? Information Number necessary On-shift staff for the on-shift staff PBX Assumed Not PA System, Assumed Not Portable Radios 4.5, 4.7 to perform Initial Telephone Available Radios Available Phase coping actions 1 each for:

- On-site radiological monitoring 2 each for:

- Firefighting (1 for brigade leader &

Operational 1 for the brigade)

Support Center 2 each per unit for:

(OSC) and

• In-plant PBX Assumed Not PA System, Assumed Not other site- radiological Telephone Available Radios Available4.7 specific monitoring locations as

• Search and necessary Rescue

- Emergency repairs Site-specific number needed to implement any 2 severe accident mitigation strategies Page 6 of 9

Oconee Nuclear Station (ONS) Units 1, 2, and 3 4.2 Plant Paging Primary Backup Refer to the Emergency Minimum Primary Method Method Backup Method(s) Planned or Following Response Communication Described in Available Method(s) Available Potential Section(s) for Facility Links E-Plan Following Described in Following Improvement Additional Assumed E-Plan Assumed Identified? Information LSEE? LSEE?

See assumptions Assumed Not PBX Portable N/A and discussion in PA System Available Telephone No Radios 4.5,4.7 NEI 12-01 4.3 Communications Equipment at ORO Facilities Primary Backup Refer to the Emergency Minimum Method Method(s) Planned or Following Response Communication Primary Available Backup Available Potential Section(s) for Facility Links Method Following Method(s) Following Improvement Additional Assumed Assumed Identified? Information LSEE? LSEE?

1 for key WP Selective Commercial Oconee Communicator Signaling Assumed Not telephone Assumed Not Portable 4.5,4.7 County EOC 1 for key EOC System Available Line Available Satellite Phone Communicator System Lines 1 for key WP Selective Commercial Pickens County Communicator Signaling Assumed Not Telephone Assumed Not Portable EOC 4.5, 4.7 1 for key EOC Available Available Satellite Phone Communicator System Lines 1 for key WP Selective Commercial SC State Communicator Signaling Yes (> 25 Telephone Yes (> 25 Portable 4.5 4.7 EOC 1 for key EOC System miles) Lines Communicator Page 7 of 9

Oconee Nuclear Station (ONS) Units 1, 2, and 3 Considerations for performing the communications assessment and identifying enhancements:

4.4 NOTIFICATION OF THE EMERGENCY RESPONSE ORGANIZATION This area was previously assessed. Information for all three of Duke Energy's licensed operating plants (CNS Units 1 and 2; MNS Units 1 and 2; and ONS Units 1, 2, and 3),

was provided to the NRC via the "90-Day Response to Recommendation 9.3 of 10CFR50.54(f) Request for Information" dated June 8, 2012. Therefore, no further assessment activities are required for this assessment area.

4.5 EQUIPMENT LOCATION REQUIREMENTS Duke Energy conservatively assumed that primary communication systems and equipment for onsite and offsite communications capabilities during a beyond design basis extended loss of AC power event would not be relied upon. Given that assumption, alternate communications systems and equipment should be stored in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external event. For example, equipment location requirements should satisfy the guidance in NEI 12-01, Section 4.5.

The adequacy of equipment storage and locations is ongoing, and is yet to be finalized.

Therefore, Duke Energy identified a recommendation/enhancement in this area. Refer to Enclosure 1, Recommendation R-3.

4.6 PERFORMANCE CHARACTERISTICS NEI 12-01 (section 2.4.7) states: "Offsite infrastructure supporting communications systems is inoperable in the area surrounding the site (e.g., cellular telephone or microwave towers, telephone central office buildings, telephone lines, etc.). For this assessment, the company has elected to "apply a default distance value, in all directions, of approximately 25 miles from the plant site." Based on these assumptions, satellite-based communications systems will be utilized to provide offsite communications.

Each site will ensure that an appropriate inventory of hand-held satellite phones is available for use by the Emergency Response Organization in their associated Emergency Response Facilities. This minimizes any reliance on "multi-use" equipment.

Refer to Enclosure 1, Recommendation R-1 4.7 OTHER ASSESSMENT CONSIDERATIONS Pursuant to the information previously provided in Duke Energy Carolina's, LLC (Duke Energy) 90-Day Response to the March 12, 2012, request for information regarding enclosure 5, recommendation 9.3 Emergency Preparedness, dated June 8, 20"12, Oconee purchased small portable diesel generators that can be used to power handheld radio chargers and portable satellite phone chargers. These portable diesel generators are expected to be on site by late fall 2012. In addition, Oconee will ensure an appropriate inventory of portable hand-held satellite phones and radios, spare batteries, and chargers is available for use by the Emergency Response Organization. Refer to Enclosure 1, Recommendations R-1 and R-2.

4.8 QUALITY AND MAINTENANCE-RELATED REQUIREMENTS Oconee's E-Plan and its EPIPs provide programmatic controls for communications equipment, and related power sources and infrastructure. Similar programmatic controls Page 8 of 9

Oconee Nuclear Station (ONS) Units 1, 2, and 3 should be appl~ied to other communications-related equipment to ensure availability and reliability, including the performance of periodic inventory checks and operability testing.

Refer to Enclosure 1, Recommendation R-4.

4.9 NATIONAL COMMUNICATIONS SYSTEM (NCS) SERVICES Oconee will ensure that a Government Emergency Telecommunications Service (GETS) account is established and that the account is verified annually. Refer to Enclosure 1, Recommendation R-5.

4.10 COMMUNICATIONS PROVIDER EMERGENCY SERVICES Duke Energy is in the process of evaluating the emergency services offered by communication service providers. Duke Energy will ensure that arrangements are in place with communications service providers to utilize their emergency services as described in NEI 12-01, Section 4.10. Refer to Enclosure 1, Recommendation R-6.

4.11 PERSONNEL TRAINING Appropriate training will be developed for and provided to response personnel on the location and use of communications systems and equipment. Refer to Enclosure 1, Recommendation R-4.

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