RA-12-038, Florida Power Corp.S Response to Request for Information Pursuant to Title 10 of Code of Federal Regulations 50.54 (F) Recommendations 2.1, 2.3, & 9.3 of Near Term Force Review of Insights from Fukushima Dai-Ichi.

Florida Power Corp.S Response to Request for Information Pursuant to Title 10 of Code of Federal Regulations 50.54 (F) Recommendations 2.1, 2.3, & 9.3 of Near Term Force Review of Insights from Fukushima Dai-Ichi.

ML12311A299
Person / Time
Site:	Harris, Brunswick, Crystal River, Robinson
Issue date:	10/31/2012
From:	Waldrep B Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-12-038
Download: ML12311A299 (63)

Text

Benjamin C. Waldrep Duke 526 South Church Street

rEnergy, Charlotte, NC 28202 Mailing Address:

Mail Code ECO7H / P.O. Box 1006 Charlotte, NC 28201-1006 704-382-8162 704-382-4541 fax 10 CFR 50.4 10 CFR 50.54(f)

Serial: RA-1 2-038 October 31, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 / RENEWED LICENSE NOS. DPR-71 AND DPR-62 CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 / LICENSE NO. DPR-72 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. I DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23

SUBJECT:

CAROLINA POWER & LIGHT COMPANY AND FLORIDA POWER CORPORATION'S RESPONSE TO 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-ICHIACCIDENT; DATED MARCH 12, 2012

REFERENCES:

1. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(6) Regarding Recommendations 2.1, 2.3, 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, dated March 12, 2012

2. Progress Energy Letter, Carolina Power & Light Company and Florida Power Corporation's 60-Day Response to the March 12, 2012, Request for Information Regarding Enclosure 5, Recommendation 9.3: Emergency Preparedness, dated May 9, 2012

3. Progress Energy Letter, Carolina Power & Light Company and Florida Power Corporation's 90-Day Response to the March 12,2012, Requestfor Information Regarding Enclosure 5, Recommendation 9.3: Emergency Preparedness, dated June 11, 2012

4. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities Ladies and Gentlemen:

The NRC staff issued Reference I on March 12, 2012. Enclosure 5 of Reference I contains specific Requested Actions and Requested Information associated with Recommendation 9.3 for www. duke-energy. corn

United States Nuclear Regulatory Commission RA-12-038 Page 2 Emergency Preparedness (EP) programs. In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f), addressees were requested to submit written responses to the information request on requested due dates.

In accordance with Reference 1, on May 9, 2012, Carolina Power & Light Company (CP&L) and Florida Power Corporation (FPC) submitted, via Reference 2, an alternative course of action for providing the requested information. The alternative course of action included revised information due dates and the basis for those dates. As described in the alternative course of action, this letter transmits the information required for the Phase 1 Communications Assessment (Communications Request #1) and an implementation schedule of the time needed to implement the results (Communications Request #3). provides information applicable to all of the sites listed above. Attachments 2 through 5 provide the requested plant specific information for each site listed above. The information provided was developed in accordance with the guidance provided in Reference 4.

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

Should you have any questions concerning this letter, or require additional information, please contact Donna Alexander, Nuclear Regulatory Affairs Manager, at (919) 546-5357.

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

Respectfully, BenjaiC.ade Vice President - Corporate Governance &

Operations Support JLO

United States Nuclear Regulatory Commission RA-12-038 Page 3 Attachments:

1. Communication Assessment Results and Implementation Schedule for CP&L and FPC Nuclear Sites

2. Emergency Communications Assessment Rollup for Brunswick Steam Electric Plant, Unit Nos. I and 2

3. Emergency Communications Assessment Rollup for Crystal River Unit 3 Nuclear Generating Plant

4. Emergency Communications Assessment Rollup for Shearon Harris Nuclear Power Plant Unit No. 1

5. Emergency Communications Assessment Rollup for H.B. Robinson Steam Electric Plant Unit No. 2 cc:

USNRC Region II, Regional Administrator USNRC Resident Inspector - BSEP, Unit Nos. 1 and 2 USNRC Resident Inspector - CR3 USNRC Resident Inspector - SHNPP, Unit No. 1 USNRC Resident Inspector - HBRSEP, Unit No. 2 F. Saba, NRR Project Manager - BSEP, Unit Nos. I and 2; CR3 A. T. Billoch Col6n, NRR Project Manager - S1-NPP, Unit No. 1; HBRSEP, Unit No. 2

United States Nuclear Regulatory Commission RA-12-038 Communication Assessment Results and Implementation Schedule for CP&L and FPC Nuclear Sites

United States Nuclear Regulatory Commission RA-12-038, Attachment I Carolina Power & Light Company (CP&L) and Florida Power Corporation (FPC) 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, CP&L & FPC elected to conservatively assume that such communication 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 can be established via existing hand-held radios (line-of-sight) and offsite communications via recently purchased hand-held satellite phones. In addition, small generators were purchased for each site.

These portable generators can be used to power hand-held radio battery chargers and hand-held satellite phone battery chargers. The hand-held satellite phones and small generators are onsite.

The hand-held satellite phones and small generators are being incorporated into site programs and procedures (Recommendation R-4, below). Storage to maximize the survivability of the hand held radios and chargers, satellite phones and chargers, and small generators will be addressed consistent with the NEI 12-01, Section 4.5 (Recommendation R-3, below).

The following recommendations (enhancements), including their 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: 3/28/2013 R-2:

Evaluate and purchase, if necessary, additional portable radios, spare batteries, and chargers to ensure required communications links are fully established.

Due Date: 3/28/2013 R-3:

Ensure that portable communications equipment (i.e., satellite phones, radios, and small generators) are stored in a manner that maximizes survivability from applicable external events per NEI 12-01, Section 4.5.

Due Date: Consistent with the implementation due date for Order EA-1 2-049.

R-4:

Ensure that programmatic controls are established for communications equipment (i.e.,

portable satellite phones and portable radios) 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 Page 1 of 2

United States Nuclear Regulatory Commission RA-12-038, Attachment 1 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)/Wireless 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 Page 2 of 2

United States Nuclear Regulatory Commission RA-12-038 Emergency Communications Assessment Rollup for Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324 / Renewed License Nos. DPR-71 and DPR-62

United States Nuclear Regulatory Commission RA-12-038, Attachment 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 of NEI 12-0 1, 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, Sections IV.D and IV.E.9.a]

Offsite Response Organizations (OROs) [per 10 CFR 50 Appendix E, Primary Method Backup Refer to the Emergency Minimum Primary Method Available Backup Method(s)

Planned or Following

Response

Communication Described in E-Assumed Method(s)

Available Potential Sections for Facility Links Plan' Large Scale Described in E-following Improvement Additional External Plan' Assumed Identified?

Information Event LSEE?

(LSEE)?

Commercial telephone, BNP PBX telephones, Security radio link to Brunswick 1 per Control County Sheriff's Control Room Room for Shift Selective Assumed Not Dept., Satellite Assumed Not Portable 4.5,4.7 Communicator Signaling System Available radio; Statewide Available Satellite Phone Emergency Communication Network (SECN),

Satellite telephone (I fixed)

Page 1 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 Primary Method Backup Refer to the Emergency Minimum Primary Method Available Backup Method(s)

Planned or Following

Response

Communication Described in E-Assumed Method(s)

Available Potential Sections for Facility Links Plan' Large Scale Described in E-following Improvement Additional External Plan' Assumed Identified? ?i tion Event LSEE?

(LSEE)?

Commercial telephone, BNP PBX telephones, Security radio Technical link to Support 1 for Key TSC Selective Assumed Not Brunswick Assumed Not Portable Center2 Communicator Signaling System Available County Sheriffs Available Satellite Phone 4

(TSC)

Dept., Satellite radio, Statewide Emergency Communication Network (SECN)

Commercial telephone, BNP PBX telephones, State Decision Line - State and County EOC's, Emergency 1 for Key EOF Selective Assumed Not Security radio Assumed Not Portable Operations link to 4.5,4.7 Facility (EOF)

Communicator Signaling System Available Brunswick Available Satellite Phone County Sheriff's Dept., Cellular telephones, Satellite radio; Statewide Emergency Page 2 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 Primary Method Backup Refer to the Emergency Minimum Primary Method Available Backup Method(s)

Planned or Following

Response

Communication Described in E-Assumed Method(s)

Available Potential Sections for Facility Links Plani Large Scale Described in E-following Improvement Additional External Plan' Assumed Identified?

Event LSEE?

Information

~(LSEE)?

Communication Network (SECN),

Satellite telephone (1 fixed and 2 portable), MOU w/Brunswick County -

Interoperability Mobile Communications Vehicle NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

2.

If applicable per site Emergency Plan Page 3 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 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, Sections IV.D and IV.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 Sections for Described in E-Described in following Improvement Additional Facility Links Plan' Assumed E-Plan1 Assumed Identified?

AIn tiona LELSEE?

Information LSEE?

BNP PBX telephones, I per Control Assumed Not Satellite Assumed Not Portable Control Room Room for ENS ENS Phone Available telephone (1 Available Satellite Phone 4.5,4.7 Communicator fixed),

Commercial telephone BNP PBX telephones, Satellite Technical 1 for ENS Assumed Not telephone Assumed Not Portable Support Center Communicator ENS Phone Available (fixed and Available Satellite Phone 4.5, 4.7 (TSC) portable units available),

Commercial telephone BNP PBX telephones, Satellite Location(s) telephone (1 where HPN I for HPN Assumed Not fixed and 2 Assumed Not Portable communications Communicator HPN Phone Available portable units Available Satellite Phone 4

are performed available in EOF),

Commercial telephone Page 4 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 4.1.3 Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E, Section IV.9.c. Additional links that support performance of critical response functions are also specified. I Backup Refer to the Emergency Minimum Primary Primary Method Backup Method(s)

Planned or Following PrmethodmryMeho Method(s)

Available Potential

Response

Communication Desrbd Available Desc iE-fllo Povent Sections for Facility Links Described in Described in E-following Improvement Additional EPlan' Plan' Assumed Identified?

Information LSEE?

ARD, Satellite telephone (1 Control I

Assumed Not fixed),

Assumed Not Portable Room Available Commercial Available Satellite Phone telephone, Site PA, Radios 1 each for:

" Senior/Lead TSC Manager

" Operations Coordination

" Maintenance Technical Coordination

ARD, Support

• Engineering PBX telephone Assumed Not Commercial Assumed Not Portable 45,47 Center (TSC)

Coordination Available telephone, Site Available Satellite Phone

" Radiological PA, Radios Support Additional response coordination links for multi-unit sites:

Page 5 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 Backup Refer to the PiayBackup Method(s)

Planned or Rfetollowin Emergency Minimum Primary Primary Method Backup M

or Following

Response

Communication Method Method(s)

Available Potential Sections for Facility Commn i

o Described in Available Described in E-following Improvement Sectional Facility Links E-Plan' Assumed LSEE?

Pa AsmdIetfd?

Additional SPlan' Assumed Identified?

Information LSEE?

1 for each position providing Unit

Response

Coordination.

I each for:

" Senior/Lead OSC Manager

" Radiological Support Additional Operational response Assumed Not Commercial Assumed Not Portable Support coordination links PBX telephone Assume telephone, Site Assume Sable Center (OSC) for multi-unit PA, Radios sites:

9 1 for each position providing Unit In-Plant Team Coordination.

1 each for:

Commercial

• Senior/Lead Telephone Emergency Manager

System, Operations Maaer Assumed Not Corporate Assumed Not Portable Facility

• Key Protective PBX telephone Available Telephone Available Satellite Phone 4.5,4.7

(,OF)

Measures (ommrnunication

• Operations or System Technical (Voicenet),

Page 6 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 Backup Refer to the Emergency Minimum Primary Method Backup Method(s)

Planned or Following Primary Primary Method Method(s)

Available Potential Follo r

Response

Communication Described in Available Described in E-following Improvement Sections for Facility Links E-Plan' Assumed LSEE?

Pa AsmdIetfd?

Additional SPlan' Assumed Identified?

Information LSEE?

Support (as Cellular needed to telephones, support Satellite phones, performance 800 MHz of dose Radios projections, formulation of PARs and plant status updates to ORO authorities).

Joint Information 1 for Senior Commercial Assumed Not Cellular Assumed Not Portable Center (JIC)

Manager telephone Available Telephones Available Satellite Phone 4.5, 4.7 NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 4.1.4 Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix E, Section IV.9.c]

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

Planned or Following ResponseMethod Method(s)

Available Potential Sections for

Response

Communic n

Described in Av led Described in following Improvement Facility Links EPlan' Ased E-Plan1 Assumed Identified?

I tion LSEE?

LSEE?

Information Primary Field/offsite Plant PBX Assumed Not Portable location where Radio Yes Telephone Available Satellite Phone 4.5,4.7 location where monitoring team

System, Page 7 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s)

Planned or Following

Response

Communication Method Method(s)

Available Potential Sections for Method Available Described in following Improvement Sectional Repne Cmuiain Described in Assumed Additional Facility Links E-Plan1 E-Plan' Assumed Identified?

LSEE?

LSEE?

Information field/offsite coordination Commercial monitoring Telephone, team Corporate coordination is Telephone performed Communication System (Voicenet),

Plant Public Address System (Plant PA),

Cellular telephones Primary location from which field/

I for each Cellular Assumed Not Portable offsite field/offsite Radio Yes telephones Available Satellite Phone 4.5,4.7 monitoring monitoring team teams are deployed NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

Page 8 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 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, Section IV.9.b]

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

Planned or Following Method Method(s)

Available Potential

Response

Communication Described in Available Described in following Improvement Sectionsfor Facility Links EPlani E-Plan' AddiionaAssumed Identifiedl LSEE?

LSEE?

Information Cellular Primary location telephones, where Satellite communication Coordination with PBX Assumed Not telephone (1 Assumed Not Portable 4.5,4.7 with Federal Federal agencies telephone Available fixed and 2 Available Satellite Phone agencies is portable performed available),

Radios NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 4.1.6 Coordination and direction of on-site and in-plant response teams.

4.1.6.1 Phase 1 Assessment Backup Refer to the Emergency Minimum Primary Primary Backup Method(s)

Planned or Following Res Communication Method Method Method(s)

Available Potential Sections for

Response

Comunk Described in Available Described in following Improvement Sectional Facility Links EPlani Assumed E-PlanI Assumed Identified?

Additional LSEE?

LSEE?

Information Number necessary Site PA, BNP for the on-shift Radio - Yes PA, BNP On-shift staff staff to perform Radio & PA PA - Assumed As ot 4.7 INot Availabe telephones, Available Satellite Phone Inpinctia s

Bull horn

~~coping actions Page 9 of 16

United States Nuclear Regulatory RA-12-038, Attachment 2 Commission Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s)

Planned or Following Derge mmum Method Available Method(s)

Available Potentialfor FaciliAs sunme Described in Described in following Improvement Additional yEPlan' Ased E-Plan' Assumed Identified?

Information FacilitLinksnLSEE?

LSEE?

1 each for:

• Onsite radiological monitoring 2 each for:

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

Operational 2 each per unit Support Center2eahprui Suo Cnt for:

Site PA, BNP (OSC) and PXAsmdNt Pral other site-

• In-plant Radio Yes PBX Assumed Not Portable4.7 specific radiological telephones, Available Satellite Phone locations as monitoring Bull horn necessary 9 Search and Rescue

• Emergency repairs Site-specific number needed to implement any 2 severe accident mitigation strategies NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan implementing Procedures (EPIPs)

Page 10 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 4.2 Plant Paging Emergency

Response

Facility Minimum Communication Links Primary Method Described in E-Plan' Primary Method Available Assumed LSEE?

Backup Method(s)

Described in E-Plan' Backup Method(s)

Available following Assumed LSEE?

Planned or Potential Improvement Identified?

Refer to the Following Sections for Additional Information Bullhorns, See assumptions Assumed Not Sound Powered N/A and discussion in PA System Available

Phones, Yes No NEI 12-01 Two way radios NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 4.3 Communications Equipment at ORO Facilities Primary Backup Refer to the Emergency Minimum Method Method(s)

Planned or Following

Response

Communication mary Available Backup Avalle Pot ent Sections for Facility Links Method Assumed Method(s) following Improvement Additional LSEE?

Assumed Identified?

Information LSEE?

Commercial Telephone

System, Plant PBX Brunswick Co.

Communicator Selective Assumed Not Telephone Assumed Not Portable WP/EOC C for key EOC Signaling Available

System, Available Satellite Phone N/A Communicator System State Decision Line (EOF only),

Radio links, Satellite phone, Page 11 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 Primary Backup Refer to the Emergency Minimum Method Method(s)

Planned or Following

Response

Communication Primary Available Backup ntial Sections for Facility Links Method Assumed Method(s) following Improvement LSEE?

Assumed Identified?

Information LSEE?

Cell Phones Commercial Telephone

System, Plant PBX 1 for key WP Selective Telephone New Hanover Communicator Assumed Not

System, Assumed Not Portable Co. WP/EOC I for key EOC Sigaln Available State Decision Available Satellite Phone Communicator System Line (EOF only),

Radio links, Satellite phone, Cell Phones Commercial Telephone

System, Plant PBX I for key WP Selective Telephone State WP &

Communicator Assumed Not

System, Assumed Not Portable State EOC 1 for key EOC Sigaln Available State Decision Available Satellite Phone Communicator System Line (EOF only),

Radio links, Satellite phone, Cell Phones US Coast 1 for key Selective Assumed Not Commercial Assumed Not Portable N/A Guard communicator Signaling Available Telephone Available Satellite Phone System

System, Page 12 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 Primary Backup Refer to the Emergency Minimum Method Method(s)

Planned or Following

Response

Communication Primary Available Backup Available Potential Sections for Facility Links Method Assumed Method(s) following Improvement LSEE?

Assumed Identified?

Information LSEE?

Plant PBX Telephone

System, State Decision Line (EOF only),

Radio links, Satellite phone, Cell Phones Page 13 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 Considerations for performing the communications assessment and identifying enhancements:

4.4 NOTIFICATION OF THE EMERGENCY RESPONSE ORGANIZATION (ERO)

CP&L has implemented a new ERO self-activation process as follows:

During an electrical grid disturbance (i.e., large scale natural disaster, regional blackout, technological disaster, etc.) communications capabilities (i.e., pagers, cell phones, internet, landline telephone systems, etc.) may be lost or severely degraded. ERO members, regardless of on-call status, are expected to monitor local radio, and emergency alert system (EAS) communications for impact to the grid structure.

Should the situation appear to be a major disturbance to the power grid, then:

• Ensure your home and family are safe, and

• If you are fit for duty and able to leave your family unattended, then

• Report to your designated emergency response facility (ERF).

4.5 EQUIPMENT LOCATION REQUIREMENTS CP&L 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 must be stored in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external event. For example, equipment locations requirements should satisfy the guidance in NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Section 4.5. Moreover, CP&L and FPC should ensure adequate power supplies for the alternate communications systems and equipment.

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

Therefore, CP&L identified a recommendation/enhancement in this area. Refer to, 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 can be utilized to provide offsite communications.

Page 14 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 CP&L has purchased additional hand-held satellite phones and they have been delivered to the site and dedicated for usage by the Emergency Response Organization at their associated Emergency Response Facilities. These satellite phones are being incorporated into site programs and procedures. This minimizes any reliance on "multi-use" equipment. Refer to Attachment 1, Recommendation R-4.

4.7 OTHER ASSESSMENT CONSIDERATIONS Pursuant to the information previously provided in Carolina Power & Light Company and Florida Power Corporation's 90-day Response to the March 12, 2012, Request for Information Regarding Enclosure 5, recommendation 9.3 Emergency Preparedness, dated June 11, 2012, via Reference 3:

CP&L has purchased small portable generators for each site that can be used to power handheld radio chargers and portable satellite phone chargers. In addition, CP&L has purchased additional satellite phones that utilize a battery power source to increase the overall diversity of the communication system power supplies. CP&L 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, Recommendations R-1 and R-2.

4.8 QUALITY AND MAINTENANCE-RELATED REQUIREMENTS Brunswick's E-Plan and its E-Plan Implementing Procedures 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 reliability, including the performance of periodic inventory checks and operability testing. Refer to Attachment I, Recommendation R-4.

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

4.10 COMMUNICATIONS PROVIDER EMERGENCY SERVICES CP&L is in the process of evaluating the emergency services offered by communication service providers. CP&L 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 Attachment 1, Recommendation R-6.

Page 15 of 16

United States Nuclear Regulatory Commission RA-12-038, Attachment 2 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 Attachment 1, Recommendation R-4.

Page 16 of 16

United States Nuclear Regulatory Commission RA-12-038 Emergency Communications Assessment Rollup for Crystal River Unit 3 Nuclear Generating Plant Docket No. 50-302 / License No. DPR-72

United States Nuclear Regulatory Commission RA-12-038, Attachment 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 of 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 50Appendix E.IVD and E.9.a]

Primary Backup Refer to the Primary Method Backup Method(s)

Planned or Following Emergency Minimum Method

~

Availablds)

AviabeoentSectionslorin ResponseMethod(s)

Available Potential Sections for

Response

omuicai Described in Described in following Improvement Additional Facility n Links E-Plan' Assumed E-Plan' Assumed Identified?

Information LSEE?

LSEE?

1 per Control

EMnet, Control Room Room for Shift State Hot Ring Assumed Not Commercial Assumed Not Portable4.7 Communicator Down Phone Available telephone Available Satellite Phone Technical

EMnet, 2

1 for Key TSC State Hot Ring Assumed Not meAssumed Not Portable S

C)

Communicator Down Phone Available telephone Available Satellite Phone 4.5,4.7 (TSC) telephone Emergency 1 for Key EOF State Hot Ring Assumed Not

EMnet, Assumed Not Portable Operations Communicator Down Phone Available Commercial Available Satellite Phone 4.5,4.7 Facility (EOF) telephone NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

2.

If applicable per site Emergency Plan Page 1 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 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.IVD and E.9.d]

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

Method(s)

Planned or Following Backupeho~s Potential Scin o

Response

Communication Described in Available Described in E-Available Improvement Facility Links EbPlani Assumed PlanI following Improvement Additional LSEE?

an Assumed LSEE?

entiie Information I per Control Assumed Not Commercial Assumed Not Portable Control Room Room for ENS ENS Phone Available telephone Available Satellite 4.5, 4.7 Communicator Phone Technical I for ENS Assumed Not Commercial Assumed Not Portable Support Center ENS Phone Satellite 4.5, 4.7 (TSC)

Communicator Available telephone Available Phone Location(s)

NRC Health Portable where HPN I for HPN Pyis Assumed Not Commercial Assumed Not Saelt4.,7 S

Physics Aaabe tlpoeAialeSatellite 4.5, 4.7 communications Communicator Network Available telephone Available Phone are performed NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 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 Method Available Assumed LSEE?

Assumed Not Available Page 2 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 3 Primary Backup Backup Refer to the Eegny MnmmPrimary Method BakpMethod(s)

Planned or Following Emergency Minimum Method Avilbl Method(s)

Potentialfo

Response

Communication Described in E-Available Described in E-Available Improvement Sections for Facility Links Plan' Assumed Plan' following Identified?

Additional LSEE?

Assumed LSEE?

Information I each for:

" Senior/Lead TSC Manager

" Operations Coordination

• Maintenance Coordination

• Engineering Coordination T Radiological Portable Support Support AARD Assumed Not Commercial Assumed Not Center Additional Telephones Available telephone Available Phone (TSC) response coordination links for multi-unit sites:

1 for each position providing Unit

Response

Coordination.

I each for:

Operational 9 Senior/Lead AARD Support OSC Manager Telephones Assumed Not Commercial Assumed Not Portable Satellite 4.5, 4.7 Center e Radio,logical Available telephone Available Phoe DARD Phone (OSC)

Support Telephones Additional I

Page 3 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 3 Primary Backup Refer to the Eegny MnmmPrimary Prmetho Backup Method(s)

Planned or Following Emergency Minimum Method ethod Method(s)

M Potentialfo

Response

Communication Described in E-Available Described in E-Available Improvement Sections for Facility Links Plan' Assumed Plan' following Identified?

Additional LSEE?

Assumed LSEE?

Information response coordination links 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 Emergency Technical AARD Operations Support (as Telephones Assumed Not Commercial Assumed Not Portable Failt neddto.Satellite 4.5, 4.7 Facility neededto DARD Available telephone Available Phone (EOF) support DR hn performance Telephones of dose projections, formulation of PARs and plant status updates to ORO Page 4 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 3 Primary Backup Refer to the Emergency Minimum Mary Method Backup Method(s)

Planned or Following Prmetho Describethds inilbl Potential Scin o

Response

Communication De d

Available Described in E-Available Improvement ions for Facio Described in E-Assumed Plan' following Identified Additional Facility Links Plan' PlpnoId enife Adiioa LSEE?

Assumed LSEE?

Information authorities).

Emergency Portable News I for Senior NONE specified Assumed Not NONE specified Assumed Not Potale Satellite 4.5, 4.7 Center Manager in E-Plans Available in E-Plans Available Phone (ENC)

NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 4.1.4 Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix E.9.c]

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

Method(s)

Potential Following

Response

Communication Described in E-Available in E-Available Improvement Sections for Facility Links Plan' Assumed Plan' following Identified?

Additional LSEE?

Assumed LSEE?

Information Primary location where Field/offsite Commercial Portable field/offsite monitoring team 450 MHz Radio Assumed Not Telephones, Assumed Not Potale 45 ~ RdoSatellite 4.5, 4.7 monitoring coordination Available Cellular Available Phone team Telephones coordination is performed Primary Commercial location 1 for each Assumed Not Telephones, Assumed Not Portable from which field/offsite 450 MHz Radio Available Cellular Available Satellite 4.5,4.7 field/ offsite monitoring team Telephones Phone monitoring I

I Telep s

I I

Page 5 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 3 Primary Backup Backup Planned or Refer to the Emergency Minimum Primary Method Method Method(s)

Method(s)

Planned Following

Response

Communication Described in E-Available Available potent Sections for Facility Links Plan' Assumed Plan' following Improvementified?

Additional LSEE?

Assumed LSEE?

Information teams are deployed NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 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 Backup Refer to the Primary Method Method)

Pannds)

Emergency Minimum Method Method(s)

Potential Following EergonsenCy m nimumio Metd in Available Described in E-Available Improvement Sections for Facility Links EPlan1 Assumed Plan' following Identified?

LSEE?

Assumed LSEE?

Information Primary loainwee Coordination Portable communication wher Coorat Commercial Assumed Not Cellular Assumed Not Potable with Federal wies phone system Available Telephones Available Phone agencies is performed NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

Page 6 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 3 4.1.6 Coordination and direction of on-site and in-plant response teams.

4.1.6.1 Phase 1 Assessment Primary Backu Backup Planned or Refer to the Emergency Minimum Primary Method Method Backup Method(s)

Plnedtorl Following

Response

Communication Described in E-Available D

edhin E-Available Potential Sections for Facility Links Plan' Assumed nfollowing Improvement Additional LSEE?

Plan Assumed LSEE?

Identified?

Information Number necessary for the Portable On-shift on-shift staff to PAX phone Assumed Not Handheld Assumed Not Potale Satellite 4.5, 4.7 staff perform Initial system Available Radios Available Phase coping Phone actions I each for:

• On-site radiological monitoring 2 each for:

• Firefighting Operational (1 for brigade Support leader & I for PAX phone Center the brigade) system Portable (OSC) and 2 each per unit Assumed Not Handheld Assumed Not Potable Satellite 4.5, 4.7 other site-for:

Portable UHF Available Radios Available Phone specific 9 In-plant Radio locations as radiological necessary monitoring

" Search and Rescue

" Emergency repairs Site-specific number needed Page 7 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 3 Primary Backup Backup Refer to the Emergency Minimum Primary Method Method Method(s)

Method(s)

Potential Following

Response

Communication Described in E-Available Available poent Sections for Facility Links Plan' Assumed Plan following Identifmed?

Additional LSEE?

Assumed LSEE?

Information to implement any 2 severe accident mitigation strategies NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 4.2 Plant Paging Primary Backup Refer to the Emergency Minimum Method Method Method(s)

Method(s)

Planned or Following

Response

Communicatio Desrbd in ethod(s) Avalle Potent Sections for Facility n Links Described in Assumed Described in following Improvement Additional E-Plan1 E-Plan' Assumed Identified?

Information LSEE?

LSEE?

See assumptions Assumed Not radios Yes No N/A N/A and discussion PAX System Available Two way inNEL12-01 NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

Page 8 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 3 4.3 Communications Equipment at ORO Facilities Page 9 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 3 Considerations for performing the communications assessment and identifying enhancements:

4.4 NOTIFICATION OF THE EMERGENCY RESPONSE ORGANIZATION (ERO)

Florida Power Corporation (FPC) has implemented a new ERO self-activation process as follows:

During an electrical grid disturbance (i.e., large scale natural disaster, regional blackout, technological disaster, etc.) communications capabilities (i.e., pagers, cell phones, internet, landline telephone systems, etc.) may be lost or severely degraded. ERO members, regardless of on-call status, are expected to monitor local radio, and emergency alert system (EAS) communications for impact to the grid structure.

Should the situation appear to be a major disturbance to the power grid, then:

Ensure your home and family are safe, and If you are fit for duty and able to leave your family unattended, then Report to your designated emergency response facility (ERF).

4.5 EQUIPMENT LOCATION REQUIREMENTS FPC 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 must be stored in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external event. For example, equipment locations requirements should satisfy the guidance in NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Section 4.5. Moreover, FPC should ensure adequate power supplies for the alternate communications systems and equipment.

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

Therefore, FPC identified a recommendation/enhancements in this area. Refer to, 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 can be utilized to provide offsite communications.

Page 10 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 3 FPC has purchased additional hand-held satellite phones and they have been delivered to the site and dedicated for usage by the Emergency Response Organization at their associated Emergency Response Facilities. These satellite phones are being incorporated into site programs and procedures. This minimizes any reliance on "multi-use" equipment. Refer to Attachment 1, Recommendation R-4.

4.7 OTHER ASSESSMENT CONSIDERATIONS Pursuant to the information previously provided in Carolina Power & Light Company and Florida Power Corporation's 90-day Response to the March 12, 2012, Request for Information Regarding Enclosure 5, recommendation 9.3 Emergency Preparedness, dated June 11,2012, via Reference 3.

FPC has purchased small portable generators for each site that can be used to power handheld radio chargers and portable satellite phone chargers. In addition, FPC has purchased additional satellite phones that utilize a battery power source to increase the overall diversity of the communication system power supplies. FPC 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, Recommendations R-1 and R-2.

4.8 QUALITY AND MAINTENANCE-RELATED REQUIREMENTS Crystal River's E-Plan and its E-Plan Implementing Procedures 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 reliability, including the performance of periodic inventory checks and operability testing. Refer to Attachment 1, Recommendation R-4.

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

4.10 COMMUNICATIONS PROVIDER EMERGENCY SERVICES FPC is in the process of evaluating the emergency services offered by communication service providers. FPC 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 Attachment 1, Recommendation R-6.

Page 11 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 3 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 Attachment 1, Recommendation R-4.

Page 12 of 12

United States Nuclear Regulatory Commission RA-12-038 Emergency Communications Assessment Rollup for Shearon Harris Nuclear Power Plant, Unit No. 1 Docket No. 50-400 / Renewed License No. NPF-63

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 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 of 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 communicationslink 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.IVD and E.9.a]

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

Planned or Following

Response

Communication Method Available Method(s)

Available Potential Sections for

Response

C in Described in Assumed Described in following Improvement Additional Facility Links Eln Assumedumd dntfid LSEE?

E-Plan Assumed Identified?

Information LSEE?

1 per Control Selective HNP PBX Assumed Control Room Room for Shift Signaling Assumed Not

phones, NotPortable 4.5, 4.7 Available HEEC phones, Satellite Phone Communicator System Satellite phones Technical Support1 for Key TSC N/A N/A N/A N/A N/A N/A SupotCener Communicator (TSC)

Emergency Selective HNP PBX Assumed Portable Operations 1 for Key EOF Signaling Assumed Not

phones, Not 4.5,4.7 Facility (EOF)

Communicator System Available HEEC phones, Not 4t5, 4.7

____________________________________________Satellite Phone Avial SteiePhn NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

2.

If applicable per site Emergency Plan Page 1 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 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.IVD and E.9.d]

Primary Backup Backup Refer to the Primry ethd Mtho~s)

Planned or Following Emergency Minimum Method Method(s)

Potential Sectins Primary Methd Method~s)Available Imrv en Eergeny minimum Method Available Described in ll Improvement Sections for

Response

Communication Described in AsmdfloigAdtoa Facility Links EPlan Assumed EPlan' Identified?

Additional LSEE?

Assumed LSEE?

Information 1 per Control Assumed Not HNP PBX Assumed Not Portable Control Room Room for ENS ENS Available phones, HEEC Available Satellite 4.5, 4.7 Communicator PBX phones Phone Technical HNPPBX Portable 1 for ENS Assumed Not Assumed Not Support Center Communicator ENS Available phones, HEEC Available Satellite 4.5,4.7 (TSC) phones Phone Location(s)

HNPPBX Portable where HPN 1 for HPN Assumed Not P

PBX Assumed Not Potable HPN Phones, HEEC Satellite 4.5, 4.7 communications Communicator Available phones Available Phone are performed phonesPhone NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 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.]

PrimaryRefer to the Primary Primary Backup Backup Method(s)

Planned or Following Emergency Minimum Method Method Method(s)

Available Potential Sectins

Response

Communication Described in Available Described in following Assumed Improvement Sections for Facility Links EPlan' Assumed EvPlan' LSEE?

Identified?

Additional LSEE?

Information HEEC phones, Control PBX Assumed Not Sound Powered Assumed Not Portable Room1 per unit telephone Available Phones to OSC Available Satellite Phone 4 and TSC only Page 2 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 PrimaryRefer to the Primary Primary Backup Backup Method(s)

Planned or Following Emergency Minimum Method Method Method(s)

Available Potential Folwn

Response

Communication MehovMthdi)lvilbllPtetil Sections for Described in Available Described in following Assumed Improvement Sectional Facility Links E-Plan' Assumed E-Plan' LSEE?

Identified?

Additional LSEE?

Information 1 each for:

" Senior/Lead TSC Manager

" Operations Coordination

" Maintenance Coordination

" Engineering Coordination HEEC phones, Technical e Radiological Satellite phones, Support Support PBX telephone Assumed Not

Radios, Assumed Not Portable 4.5,4.7 Center Aditona Available Sound Powered Available Satellite Phone (TSC)

Phones to MCR response and OSC only coordination links for multi-unit sites:

1 for each position providing Unit

Response

Coordination.

I each for:

HJEEC phones, Operational e Senior/Lead Satellite phones, Support OSC Manager PBX telephone Assumed Not

Radios, Assumed Not Portable 4.5,4.7 Center 9 Radio!ogical Available Sound Powered Available Satellite Phone (OSC)

Support Phones to MCR Additional and TSC only Page 3 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 response coordination links 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 Support (as needed to support performance of dose projections, formulation of PARs and plant status updates to ORO PBX telephone Assumed Not Available HNP PBX phones Assumed Not Available Portable Satellite Phone 4.7 Page 4 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 Primary Backup Backup Method(s)

Planned or Refer to the Emergency Minimum Method Method Method(s)

Available Potential Following

Response

Communication PrmayaehoislvalblePtetil Sections for Described in Available Described in following Assumed Improvement Sectionaf Facility Links EPlan' Assumed E-Plan' LSEE?

Identified?

Additional LSEE?

Information authorities).

Joint for Senior Assumed Not Assumed Not Portable Information Commercial Available N/A Center (JIC)

Manager Phone AvailabeAvailable Satellite Phone4 NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 4.1.4 Communications with field/offsite monitoring teams Lper 10 CFR 50AppendixE.9.c]

Primary Primary Method Emergency Minimum Method

Response

Communication Described in Available Facility Links E.Plan' Assumed LSEE?

Primary location where field/offsite monitoring team coordination is performed Field/offsite monitoring team coordination Radio Yes Assumed Not Available Portable Satellite Phone N/A Primary location I for each Assumed Not Portable from which field/offsite Radio Yes Satellite field/ offsite monitoring team N/A Available Phone monitoring teams are I

Page 5 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 Primary Backup Backup Method(s)

Planned or Refer to the Emergency Minimum Meto Method Method(s)

Available Potential Following

Response

Communication Dsrbdi AvlaeMethod(s)

AvalbePtnil Sections for Described in Described in following Assumed Improvement Additional Facility Links E-Plan Assumed EPian LSEE?

Identified?LS LSEEn Information deployed NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 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 Refer to the Emergency Minimum Primary Method Backup Backup Method(s)

Planned or Following Prergen C

ominimum Methoda Method(s)

Available Potential Sections for

Response

Communication Described in Assumed Described in following Improvement Additional Facility Links EPlan' Ased E-Plan1 Assumed LSEE?

Identified?

LSEE?

Information Primary Coordination Portable communication PBX Assumed Not HEEC PBX Assumed Not with Federal Satellite 4.5, 4.7 with Federal agencies telephone Available phones Available Phone agencies is performed NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

Page 6 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 4.1.6 Coordination and direction of on-site and in-plant response teams.

4.1.6.1 Phase 1 Assessment PrimaryRefer to the Primary Primary Backup Backup Method(s)

Planned or Following Emergency Minimum Method ethod Method(s)

Available Potential Sectins

Response

Communication Described in Available Described in following Assumed Improvement Facility Links E-Plan' Assumed E-Plan' LSEE?

Identified?

Additional LSEE?

Information Number necessary for the On-shift on-shift staff to PBX Assumed Not Radios Assumed Not Portable 45 47 staff perform Initial telephone Available Available Satellite Phone Phase coping actions 1 each for:

• On-site radiological monitoring 2 each for:

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

(OSC) and 2 each per unit PBX Assumed Not Assumed Not Portable other site-for:

telephone Available Radios Available Satellite Phone 4.5,4.7 specific

• In-plant locations as radiological necessary monitoring

" Search and Rescue

" Emergency repairs Site-specific number needed Page 7 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 PrimaryRefer to the Primary Primary Backup Backup Method(s)

Planned or Following Emergency Minimum Method Method Method(s)

Available Potential Sectins

Response

Communication Described in Available Described in following Assumed Improvement Facility Links E-Plan' Assumed E.PlanI LSEE?

Identified?

Additional LSEE?

Information to implement any 2 severe accident mitigation strategies NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 4.2 Plant Paging Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s)

Planned or Following Rergen C

ominimum Method Available Method(s)

Available Potential Resp eAsme Described in following Improvement Sections for Rsos Comncto Deciein Assumed DsrbdAdditional EPlan' E-Plan1 Assumed Identified?

Information acilit LinksnLSEE?

LSEE?

Sound Powered See assumptions Assumed Not

Phones, N/A and discussion in PA System Available Two way radios Yes No N/A NEI 12-01 NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

Page 8 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 4.3 Communications Equipment at ORO Facilities PrimaryRefer to the Primary Backup Method(s)

Planned or Following Emergency Minimum Primary Method Backup Available Potential Sections for

Response

Communication Method Available Method(s) following Assumed Improvement Facility Links Assumed Identified?

Additional LSEE?

Information I for key WP Chatham Communicator Selive Assumed Not Commercial Assumed Not Portable N/A County I for key EOC Signaling Available Telephone Lines Available Satellite Phone Communicator System Chatham I for key WP Selective Communicator Selective Assumed Not Commercial Assumed Not Portable County 1 for key EOC Signaling Available Telephone Lines Available Satellite Phone N/A Backup Communicator System I for key WP Selective Harnett Communicator Assumed Not Commercial Assumed Not Portable N/A County I for key EOC Signaling Available Telephone Lines Available Satellite Phone Communicator System I for key W PSe ct v 1 fCommunicator Selive Assumed Not Commercial Assumed Not Portable N/A Lee County okey EOC Signaling Available Telephone Lines Available Satellite Phone Communicator System I for key WP Selective Communicator Assumed Not Commercial Assumed Not Portable 1 for key EOC Signaling Available Telephone Lines Available Satellite Phone Communicator System Wake I for key WP Selective Wake 1

Communicator Selive Assumed Not Commercial Assumed Not Portable N/A County Alt for key m

EOC Available Telephone Lines Available Satellite Phone EOC Communicator System Wake 1 for key WP Selective County Communicator Assumed Not Commercial Assumed Not Portable N

I for key EOC Available Telephone Lines Available Satellite Phone EOC Communicator System Page 9 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 Primary Backup Method(s)

Planned or Refer to the Emergency Minimum Method Backup Methodbs)

Planned Following

Response

Communication Primary Available Backup Available Potential Sections for Facility Links Method Assumed l

ssumed Improvement Additional LSEE?

Identified?

LSEE?

Information W ake I for key W PSe ctv County Communicator Signaling Assumed Not Commercial Assumed Not Portable N/A Warning t

for key EOC Available Telephone Lines Available Satellite Phone Point Communicator System Ava Page 10 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 Considerations for performing the communications assessment and identifying enhancements:

4.4 NOTIFICATION OF THE EMERGENCY RESPONSE ORGANIZATION (ERO)

Carolina Power and Light Company (CP&L) has implemented a new ERO self-activation process as follows:

During an electrical grid disturbance (i.e., large scale natural disaster, regional blackout, technological disaster, etc.) communications capabilities (i.e., pagers, cell phones, internet, landline telephone systems, etc.) may be lost or severely degraded. ERO members, regardless of on-call status, are expected to monitor local radio, and Emergency Alert System (EAS) communications for impact to the grid structure.

Should the situation appear to be a major disturbance to the power grid, then:

• Ensure your home and family are safe, and

• If you are fit for duty and able to leave your family unattended, then

• Report to your designated Emergency Response Facility (ERF).

4.5 EQUIPMENT LOCATION REQUIREMENTS CP&L 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 must be stored in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external event. For example, equipment locations requirements should satisfy the guidance in NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Section 4.5. Moreover, CP&L should ensure adequate power supplies for the alternate communications systems and equipment.

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

Therefore, CP&L identified a recommendation/enhancements associated with equipment location requirements. Refer to Attachment 1, Recommendation 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 can be utilized to provide offsite communications.

Page ll of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 CP&L has purchased additional hand-held satellite phones and they have been delivered to the site and dedicated for usage by the Emergency Response Organization at their associated Emergency Response Facilities. These satellite phones are being incorporated into site programs and procedures. This minimizes any reliance on "multi-use" equipment. Refer to Attachment 1, Recommendation R-4.

4.7 OTHER ASSESSMENT CONSIDERATIONS Pursuant to the information previously provided in Carolina Power & Light Company and Florida Power Corporation's 90-day Response to the March 12, 2012,Request for Information Regarding Enclosure 5, Recommendation 9.3 Emergency Preparedness, dated June 11,2012, via Reference 3.

CP&L has purchased small portable generators for each site that can be used to power handheld radio chargers and portable satellite phone chargers. In addition, CP&L has purchased additional satellite phones that utilize a battery power source to increase the overall diversity of the communication system power supplies. CP&L 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, Recommendations R-I and R-2.

4.8 QUALITY AND MAINTENANCE-RELATED REQUIREMENTS Harris's E-Plan and its E-Plan Implementing Procedures 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 reliability, including the performance of periodic inventory checks and operability testing. Refer to Attachment 1, Recommendation R-4 4.9 NATIONAL COMMUNICATIONS SYSTEM (NCS) SERVICES Harris will ensure that a Government Emergency Telecommunications Service (GETS) account is established and that the account is verified annually. Refer to Attachment 1, Recommendation R-5.

4.10 COMMUNICATIONS PROVIDER EMERGENCY SERVICES CP&L is in the process of evaluating the emergency services offered by communication service providers. CP&L 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 Attachment 1, Recommendation R-6.

Page 12 of 13

United States Nuclear Regulatory Commission RA-12-038, Attachment 4 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 Attachment 1, Recommendation R-4.

Page 13 of 13

United States Nuclear Regulatory Commission RA-12-038 Emergency Communications Assessment Rollup for H. B. Robinson Steam Electric Plant, Unit No. 2 Docket No. 50-261 / Renewed License No. DPR-23

United States Nuclear Regulatory Commission RA-12-038, Attachment 5 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 of 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.IVD and E.9.a]

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

Planned or Following Method Method Method(s)

Available Potential

Response

Communicatio Described in Assume Described in following Improvement Additional Facility n Links E-Plan' LSEE?

E-PlanI Assumed Identified?

Information LSEE?

perAssumed Not Assumed Not Portable Control Room Room for Shift Signaling Available PBX phones Available Satellite Phone 4.5,4.7 Communicator System Technical 2

1 for Key TSC N/A N/A N/A N/A N/A N/A Support Center Communicator (TSC)

Emergency 1 for Key EOF Selective Assumed Not Assumed Not Portable Operations Communicator Signaling Available PBX phones Available Satellite Phone 4.5, 4.7 Facility (EOF)

System NOTES:

1.

The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

2.

If applicable per site Emergency Plan Page 1 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 5 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.IVD and E.9.lj 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 Sections for Facility Links PlanC Assumed Described in following Improvement E-Plan' Assumed Identifed9 Additional LSEE?

LSEE?

Information I per Control NRC Emergency Assumed Not Assumed Not Portable Control Room Room for ENS Telecommunication Available PBX phones Available Satellite 4.5,4.7 Communicator System (ETS)

Phone Technical 1 forENS NRC Emergency Assumed Not Assumed Not Portable Support Center Communicator Telecommunication Available PBX phones Available Satellite 4.5, 4.7 (TSC)

System (ETS)

Phone Location(s)

Portable where HPN I for HPN NRC Health Assumed Not Assumed Not Potable PBX phones Satellite 4.5, 4.7 communications Communicator Physics Network Available Available Phone are performed NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 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 Refer to the Emergency Minimum Primary Method Backup Backup Method(s)

Planned or Following PriMethod ary Method(s)

Available Potential Sections for

Response

Communication Described in Available Described in E-following Assumed Improvement Sectional Facility Links EPlan1 Assumed Plan' LSEE?

Identified?

Additional LSEE?

Information Control PBX Assumed Not PA system, Assumed Not Portable Room Telephone Available ESSX phones Available Satellite Phone 4

Page 2 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 5 Primry Panne or Refer to the Primary Primary Backup Backup Method(s)

Planned or RFollowing Emergency Minimum Method Method Method(s)

Available Potential Sectins

Response

Communication Described in Available Described in E-following Assumed Improvement Sectional Facility Links E-Plan' Assumed Plan' LSEE?

Identified?

Additional LSEE?

Information 1 each for:

" Senior/Lead TSC Manager

" Operations Coordination

" Maintenance Coordination

" Engineering Coordination Techncal Radiological Support Support PBX Assumed Not PA system, Assumed Not Portable Center Additional Telephone Available ESSX phones Available Satellite Phone 4

(TSC) response coordination links for multi-unit sites:

1 for each position providing Unit

Response

Coordination.

1 each for:

Operational

• Senior/Lead Support OSC Manager PBX Assumed Not PA system, Assumed Not Portable 4.5,4.7 Center R ological Telephone Available ESSX phones Available Satellite Phone (OSC)

Support Additional Page 3 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 5 Primary Emergency Minimum Method

Response

Communication Desrbd Facility Links EPian' response coordination links 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 Emergency Technical Operations Support (as PBX Facility needed to Telephone (EOF) support performance of dose projections, formulation of PARs and plant status updates to ORO Assumed Not Available PA system, ESSX phones Assumed Not Available Portable Satellite Phone Page 4 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 5 PrimaryRefer to the Primary Primary Backup Backup Method(s)

Planned or Following Emergency Minimum Method Method Method(s)

Available Potential Sectins

Response

Communication Described in Available Described in E-following Assumed Improvement Sections for Facility Links EPlan' Assumed Plan' LSEE?

Identified?

Additional LSEE?

Information authorities).

Joint for Senior PBX Assumed Not Assumed Not Portable Information 1 o eir PXAsmdNt Cellular Phones AvialSteiePhn Center (JIC)

Manager Telephone Available Available Satellite Phone 4.5,4.7 NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 4.1.4 Communications with field/offsite monitoring teams [per 10 CFR 50Appendix E.9.c]

Primary Method Available Assumed LSEE?

Primary location where field/offsite monitoring team coordination is performed Field/offsite monitoring team coordination Radio Yes Cellular Phones Assumed Not Available Portable Satellite Phone Primary location I for each Portable from which field/offsite Radio Yes Cellular Phones Assumed Not Satellite field/ offsite monitoring team Available Phone monitoring teams are Page 5 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 5 NOTES:

1.

The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 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 Backup Refer to the Eegny MnmmPrimary Method BakpMethod(s)

Planned or Following Emergency Minimum ethod Method(s)

M Potentialfo

Response

Communication Available Described in E-Available Improvement Sections for Repne CmuiainDescribed inE1ssmdfollowing mpoe nt Additional Facility Links PlanAssumed Plan' Assumed Identified?

LSEE?

Assumed LSEE?

Information Primary location where conicationCoordination Portable Coordinationn Assumed Not Cluaphns Availabedo w

ical with Federal PBX Telephone Assume Cellular phones Assume Satellite 4.5, 4.7 with Federal agnisAvailableAvialPhn agencies is agencies Phone performed NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

Page 6 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 5 4.1.6 Coordination and direction of on-site and in-plant response teams.

4.1.6.1 Phase 1 Assessment PrimaryRefer to the Primary Primary Backup Backup Method(s)

Planned or Following Emergency Minimum PrMetho Method Method(s)

Available Potential Folwn

Response

Communication Method MehoasiAaiabebotntal Sections for

Response

Co ains Described in Available Described in E-following Assumed Improvement Sectional Facility Links E-Plan' Assumed Plan' LSEE?

Identified?

Additional LSEE?

Information Number necessary for the On-shift on-shift staff to PBX Assumed Not PA system, Assumed Not Portable staff perform Initial Telephone Available Radios Available Satellite Phone 4

Phase coping actions 1 each for:

• On-site radiological monitoring 2 each for:

o Firefighting Operational (1 for brigade Support leader & I for Center the brigade)

(OSC) and 2 each per unit PBX Assumed Not PA system, Assumed Not Portable other site-for:

Telephone Available Minicell (PBX)

Available Satellite Phone 4

specific 9 In-plant locations as radiological necessary monitoring

" Search and Rescue

" Emergency repairs Site-specific number needed Page 7 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 5

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs) 4.2 Plant Paging Primary Backup Refer to the Emergency Minimum Primary Method Backup Method(s)

Planned or Following

Response

Communicatio Method Available Method(s)

Available Potential Sections for Facility ninks Described in Assume Described in following Improvement Additional Facility n Links E-Plan1 Assumed E-Plan1 Assumed Identified?

Information LSEE?

LSEE?

See and assumptions PA System Assumed Not Bullhorns NOTES:

iand discussion P

Available Two way radios Yes No N/A in NEI 12-01 NOTES:

1. The phrase "Described in the E-Plan" refers to the Emergency Plan and/or Emergency Plan Implementing Procedures (EPIPs)

Page 8 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 5 4.3 Communications Equipment at ORO Facilities Primary Backup Planned or Refer to the Emergency Minimum Primary Method Backup Method(s)

Potential Following

Response

Communication Mary Available Backup Available potent Sections for FaiiyLnsMethod AsmdMethod(s) folwn Improvement Facility Links Assumed following Additional LSEE?

Assumed LSEE?

Information Chesterfield C for key WP Selective Portable ConyCommunicator Sgaig Assumed Not Commercial Assumed Not SaeltN/

County 1for key EOC Signaling Satellite N/A EOC/WP ICommunicator System Available telephone lines Available Phone Darlington 1 for key WP Portable Caunto Communicator Selective Assumed Not Commercial Assumed Not Potable County 1 for key EOC System Available telephone lines Available Phone Communicator I for key WP Portable Communicator PBX Assumed Not Assumed Not Potable JIC Cellular Phones Satellite N/A 1 for key EOC Telephone Available Available Phone Communicator 1 for key WP Selective Portable Lee County Communicator Signaling Assumed Not Commercial Assumed Not EOC/WP 1 for key EOC Sigaln Available telephone lines Available Satellite N/A Communicator System Phone Remote 1 for key AsueWoPomrca sue o

Communicator Selective Portable Remote Communicator Sgaig Assumed Not Commercial Assumed NotSaeltN/

Facility I for key EOC Signaling Available telephone lines Available Satellite N/A Communicator System Phone I for key WP I o e

P Selective Portable State EOC Communicator Selive Assumed Not Commercial Assumed Not Potable 1 for key EOC Signaling Available telephone lines Available Satellite N/A Communicator System Phone Page 9 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 5 Considerations for performing the communications assessment and identifying enhancements:

4.4 NOTIFICATION OF THE EMERGENCY RESPONSE ORGANIZATION (ERO)

Carolina Power and Light Company (CP&L) have implemented a new ERO self-activation process as follows:

During an electrical grid disturbance (i.e., large scale natural disaster, regional blackout, technological disaster, etc.) communications capabilities (i.e., pagers, cell phones, internet, landline telephone systems, etc.) may be lost or severely degraded. ERO members, regardless of on-call status, are expected to monitor local radio, and emergency alert system (EAS) communications for impact to the grid structure.

Should the situation appear to be a major disturbance to the power grid, then:

• Ensure your home and family are safe, and;

• If you are fit for duty and able to leave your family unattended, then Report to your designated emergency response facility (ERF).

4.5 EQUIPMENT LOCATION REQUIREMENTS CP&L 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 must be stored in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external event. For example, equipment locations requirements should satisfy the guidance in NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Section 4.5. Moreover, CP&L should ensure adequate power supplies for the alternate communications systems and equipment.

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

Therefore, CP&L identified a recommendation/enhancement in this area. Refer to, 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 can be utilized to provide offsite communications.

Page 10 of 12

United States Nuclear Regulatory Commission RA-12-038, Attachment 5 CP&L has purchased additional hand-held satellite phones and they have been delivered to the site anddedicated for usage by the Emergency Response Organization at their associated Emergency Response Facilities. These satellite phones are being incorporated into site programs and procedures. This minimizes any reliance on "multi-use" equipment. Refer to Attachment 1, Recommendation R-4.

4.7 OTHER ASSESSMENT CONSIDERATIONS Pursuant to the information previously provided in Carolina Power & Light Company and Florida Power Corporation's 90-day Response to the March 12, 2012,Request forlinformation Regarding Enclosure 5, Recommendation 9.3 Emergency Preparedness, dated June 1H, 2012, via Reference 3:

CP&L has purchased small portable generators for each site that can be used to power handheld radio chargers and portable satellite phone chargers. In addition, CP&L has purchased additional satellite phones that utilize a battery power source to increase the overall diversity of the communication system power supplies. CP&L 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, Recommendations R-I and R-2.

4.8 QUALITY AND MAINTENANCE-RELATED REQUIREMENTS Robinson's E-Plan and its E-Plan Implementing Procedures 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 reliability, including the performance of periodic inventory checks and operability testing. Refer to Attachment 1, Recommendation R-4.

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

4.10 COMMUNATIONS PROVIDER EMERGENCY SERVICES CP&L are in the process of evaluating the emergency services offered by communication service providers. CP&L 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 Attachment 1, Recommendation R-6.

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United States Nuclear Regulatory Commission RA-12-038, Attachment 5 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 Attachment 1, Recommendation R-3.

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