ML13057A116

Response to NRC Technical Issues for Resolution Regarding Licensee Communication Submittals Associated with Near-Term Task Force Recommendation 9.3

ML13057A116
Person / Time
Site:	River Bend
Issue date:	02/22/2013
From:	Olson E Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME7951
Download: ML13057A116 (39)

Text

Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61N IFrancisville, LA 70775 E tSt. Tel 225-381-4374 Eric W. Olson Site Vice President February 22, 2013 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RBG-47335

Subject:

Entergy's Response to NRC Technical Issues for Resolution Regarding Licensee Communication Submittals Associated with Near-Term Task Force Recommendation 9.3 (TAC No. ME7951)

River Bend Station - Unit 1 Docket No. 50-458 License No. NPF-47

REFERENCES:

1. NRC letter to Entergy, 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 (RBC-51012)

(ADAMS Accession ML12053A340)

2. Entergy Letter to NRC (RBG-47239), Entergy's 60-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments, dated May 10, 2012

3. Entergy Letter to NRC (RBG-47247), Entergy's 90-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments, dated June 8, 2012

4. Entergy Letter to NRC (RBG-47290), Entergy's Response to the March 12, 2012, Information Request Pursuantto 10 CFR 50.54(f) Regarding Recommendation 9.3 for Completing Emergency Communication Assessments, dated October 31, 2012

5. NRC letter to Entergy, Follow-up Letter on Technical Issues for Resolution RegardingLicensee Communication Submittals Associated with Near-Term Task Force Recommendation 9.3 (TAC No. ME7951),

dated January 23, 2013 (RBC-51099) (ML13010A162)

10 CFR 50.54(f) Response Regarding Emergency Communication Assessments RBG-47335 Page 2 of 3

Dear Sir or Madam:

On March 12, 2012, the NRC issued a letter (Reference 1) entitled, Request for Information Pursuantto Title 10 of the Code of FederalRegulations50.54(0 Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term.Task Force (NTTF) Review of Insights from the Fukushima Dai-ichiAccident. Enclosure 5 of the letter contains specific requested actions and requested information associated with Recommendation 9.3 for Emergency Preparedness programs communications. In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f),

addressees were requested to submit a written response to the information requests within 90 days or provide a response within 60 days of the date of the letter and describe the alternative course of action that it proposes to take.

Entergy Operations, Inc. (Entergy) responded within 60 days (Reference 2) proposing to take the alternative course of action for communications that was described in Attachment 1 of Reference 2[ Entergy implemented this alternate course of action with the submittal of Reference 3 (described interim I planned actions to enhance existing communications systems power supplies pending the communications assessment and completion of actions) and Reference 4 (summarized the results of the communications assessment and the potential enhancements).

The purpose of this letter is to respond to Reference 5, the NRC follow-up letter regarding technical issues to be resolved with Reference 4. Responses to the eight technical issues in Reference 5 are provided in Attachment 1. The communications assessment, originally provided in Reference 4, has been revised to reflect the responses in Attachment 1 and is found in Attachment 2. These responses are subject~to change as a result of Diverse and Flexible Coping Strategies developments, advances in technology, and progress in the manner of addressing the need for these enhancements.

There are no new commitments identified in this submittal.

Should you have any questions regarding the content of this letter, please contact Mr. Joseph Clark, Manager, Licensing at (225) 381-4177.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 22, 2013.

EWO/JCR/JAC/wjf Attachments: 1. River Bend Station Communications Assessment - Addressing Eight Technical Issues

2. Supplemented Communications Assessment

RBS Response to Technical Issues RBG-47335 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Blvd.

Arlington, TX 76011-4511 NRC Resident Inspector PO Box 1050 St. Francisville, LA 70775 Ms. Tracie Lowrey Public Utility Commission of Texas 1701 N. Congress Ave.

Austin, TX 78711-3326 Department of Environmental Quality -7 Office of Environmental Compliance Radiological Emergency Planning and Response Section Attn: JiYoung Wiley P.O. Box 4312 Baton Rouge, LA 70821-4312 Mr. Alan Wang, Project Manager U.S. Nuclear Regulatory Commission MS O-8B1 11555 Rockville Pike Rockville, MD 20852-2738

ATTACHMENT 1 TO RBG-47335 RIVER BEND STATION COMMUNICATIONS ASSESSMENT -

ADDRESSING EIGHT TECHNICAL ISSUES

Attachment 1 to RBG-47335 Page 2 of 5 Technical Issue 1:

The staff identified that licensees need to discuss how the power for the equipment analyzed is expected to be available, and how the planned communications enhancements are expected to be maintained. The following areas were identified:

A. A detailed description of how power will be maintained for (1) planned or potential enhancements to the communication links, and (2) existing equipment analyzed to be available.

1. The number of replacement batteries expected to be needed for a 24-hour duration, per the Nuclear Energy Institute (NEI) 12-01 "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities".

2. Generator availability to charge batteries without offsite equipment for a duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3. A description of how ancillary equipment supports operations for a 24-hour duration (e.g. adequacy of fuel supplies for the generators; and the minimum number of battery chargers expected to be necessary.

Response

As stated in Section 2 of the October 31, 2012, submittal, "Communication links are assumed to be established via satellite phones and use of the existing site radio system(s)". Backup power was to be provided via uninterruptable power supplies (UPSs) initially and then by portable generators. Entergy has clarified that it plans to utilize UPS units to provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of back-up power for radio system repeaters; see Sections 4.13.1 through 4.13.4. Hand-held equipment (radios and satellite phones) will have adequate spare batteries to provide for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; see Section 4.1. As such no generator use is planned for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The specific number of batteries will be determined during the detailed engineering activity of the project. If during detailed engineering and planning, it is identified that these enhancements are not feasible or practical; an alternate approach will be developed.

Technical Issue 2:

The use and function of the planned enhancements for the improvement of communications:

A. A description of the use of the planned enhancements:

1. A discussion of whether each planned enhancement identified is only to be used for maintaining the communication link identified, or if it is expected to be shared among other communication links.

2. A general description of the planned enhancement and how the equipment will be integrated.

3. The title and general description of the procedure that will be developed and used by plant personnel to describe protocols for shared usage of communication capabilities.

Attachment 1 to RBG-47335 Page 3 of 5

Response

Communication links will be established using the existingsite radio system and satellite phones. Adequate hand-held equipment (radios and satellite phones) will be provided for each link (i.e. no sharing required). As stated in Section 4.6 of our submittals, Entergy "did not identify where a single communication pathway was assigned to support multiple functions". (Note that field teams will be using the same radio channel.) Entergy will not be implementing shared usage; therefore, a procedure is not required.

Technical Issue 3:

The protection of the new equipment purchased as a planned enhancement as well as the protection of existing communications equipment analyzed as being available:

A. A discussion of how the existing equipment analyzed to be available and enhancements to these communication links as well as associated ancillary equipment will be stored in a manner that is protective from a large scale natural event:

1. A description of pre-identified areas that are considered protective for existing equipment and whether new equipment will be stored in a similar location. The title and brief description of a procedure for new communications equipment storage is acceptable, if this procedure is planned to be developed in the future; or a statement that this will be completed in alignment with NRC order EA-12-049.

2. Equipment stored off-site, should have an analysis of duration to set-up this equipment for use.

3. The analysis demonstrates that the existing equipment that is expected to be available will be functional.

Response

New power supplies for radio equipment will be installed adjacent to the existing equipment and therefore are protected per the discussion provided in Section 4.13 of the assessment report. The enhancements identified for the existing equipment would also apply to the new power supplies. Section 4.5 of the report has been revised to clarify this point.

No equipment is currently planned to be stored off site for site deployment.

Analysis is per section 4.13 of the assessment report.

Technical Issue 4:

The programmatic controls for the use of the new equipment. purchased as a planned enhancement:

A. A description of planned proceduralization and training for the use of these planned enhancements. It is acceptable to provide a title and description of a new procedure for communications equipment.

1. A description of any credited manual actions and their procedures.

2. A description of any maintenance for this equipment, including operability testing.

ý3. A description of periodic inventory checks.

4. A description of planned staff training.

Attachment 1 to RBG-47335 Page 4 of 5

Response

Section 4.8 has been revised to indicate that existing site procedures for inventory checks and testing will be updated and used for the new equipment. Site Maintenance programs will be used as appropriate for controlling required maintenance (e.g. replacing UPSs' batteries).

Section 4.11 has been revised to indicate that training will be conducted to ensure personnel are familiar with the operation of the new equipment, storage location and any other requirements. A specific procedure number has not been identified at this time.

Technical Issue 5:

A discussion on what assumptions are used as part of the Communications Assessment:

A. A description of the assumptions used for the submitted Communications Assessment Summary, and technical justification for any differences from the assumptions within NEI 12-01, Sections 2.2 "Assumptions common to Both Assessments" and 2.4 "Assumptions for Communications Assessments."

Response

Section 3 has been revised to indicate that assumptions are as stipulated in NEI 12-01.

Technical Issue 6:

How plant personnel will be notified in the event of a large scale natural event that causes a loss of all AC power:

A. A description and title of the procedure for emergency notification of essentially all plant staff within 30 minutes (if applicable to the site Emergency Plan).

B. A description and title of procedure for notification of emergency response organization staff (i.e., self activation) (if applicable).

Response

Section 4.2 has been revised to indicate that plant personnel will become aware of the large scale natural event by personal observation. General Employee Training (GET) will be updated to include direction regarding actions to be taken by personnel upon observation of the event. That is, they are to report to the designated site assembly area.

Site accountability processes will be implemented to ensure all personnel are notified.

Section 4.4 indicates that notification of the Emergency Response Organization (ERO) will be as discussed in Section 4.4 (second bullet) of NEI 12-01. This expectation has been communicated to site EROs and has been included in initial and continuing ERO training.

Attachment 1 to RBG-47335 Page 5 of 5 Technical Issue 7:

How communications will be maintained during the period of final implementation of the communications enhancements:

A. Identification and description of the interim actions that will in place to bridge the gap until all final mitigation strategies being proceduralized are implemented. This also includes equipment protection.

Response

Section 6 has been added to the submittal providing a summary of interim actions, including:

• Number of satellite phones provided (minimum of nine at single unit sites and 11 at dual unit sites).

• Existing radio system capability during loss of AC power (e.g. existence of UPS, talk around capability, etc.)

• ERO notification methodology established/implemented.

Technical Issue 8:

Descriptions are needed regarding how communications will be maintained with the on-site and in-plant response teams and offsite response organizations iftheir communication links are not expected to be available:

A. A timeline for when the evaluation for site specific improvements for on-site and in-plant response teams will be completed.

B. A discussion of the enhancements that are planned for the offsite response organization communication links.

Response

Section 7 has been added to the report and includes a table providing target dates for implementation of the identified enhancements.

Section 4.3 indicates that all Offsite Response Organization (ORO) facilities that receive notifications have back-up power and that some of the facilities would require the addition of a satellite phone. Entergy has clarified that it will ensure all ORO facilities have satellite phones.

ATTACHMENT 2 TO RBG-47335 RIVER BEND STATION SUPPLEMENTED COMMUNICATIONS ASSESSMENT

RBG-47335 Attachment 2 Page 2 of 31

1. EXECUTIVE

SUMMARY

The assessment of the current communications systems and equipment used at the River Bend Station (RBS) during an emergency event as defined by NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities" (Reference 4) has identified several areas where enhancements could be made in order for the Emergency Plan (EP) equipment to survive a Beyond-Design-Basis External Event. These enhancements are listed in Table 10, "Summary of Enhancements" and include the following:

(1) Sizing of existing UPS batteries in EP facilities to ensure that adequate power capacity exists (2) Correction of various seismic-related issues related to Anchorages, Spatial Interactions and Housekeeping in EP facilities (3) Purchase of the necessary number of satellite phones, portable radios and spare batteries to ensure all communications links are fully functional

2. METHODOLOGY:

This report is based on the recommended criteria from NEI 12-01, for use in identifying enhancements that will ensure the availability of critical communications capabilities during an extended loss of AC power, including evaluation of power sources for communications

.equipment. This approach provides the flexibility to perform a communications capability assessment that accommodates specific site needs while, at the same time, ensuring consistency with industry-developed standards, and NRC regulations and guidance.

The assessment focused on the communication systems to be credited. For example, existing telephone communications are assumed to be inoperable and therefore are not credited or evaluated in this assessment. Communication links are assumed to be established via satellite phones and use of the existing site radio system(s). Walk downs to evaluate the equipment locations and function were performed.

Enhancements identified within the assessment will be further developed as implementation progresses. Alternate approaches will be utilized if prudent (e.g. alternate/new technology, improved capability, cost savings, etc.).

3. ASSUMPTIONS: The assumptions as stated in NEI 12-01 form the basis for this assessment, including:

• Extended loss of AC power event

• Successful plant shutdown

• No hostile action

• 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> post event - no site access

• 6-24 hours post event - limited site access, individual access by walking, personal transport or alternative transport 0 24+ hours post event - site access restored to near normal status 0 Installed sources of AC power not available

RBG-47335 Attachment 2 Page 3 of 31

• Non-essential loads from DC battery sources are stripped per station procedures

" Installed inverters and battery chargers remain available provided they are protected from external events

" Onsite diesel fuel oil is available provided it is stored in a protected manner from external events

• Portable equipment may be used provided it is stored onsite and protected from seismic, wind and flooding events. Includes portable AC and DC power sources

• Onsite communications infrastructure remains available provided it is protected from seismic, wind and flooding events.

• Offsite communications infrastructure is inoperable out to 25 miles

• Communications equipment located at an offsite response facility and supplied from a backup power source is assumed to be functional.

4. COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER:

NEI 12-01 Section 4, "Communications During an Extended Loss of AC Power," provides the basis for the following assessment.

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

The RBS Emergency Planning Department has reviewed the communications links and has determined the method of communications (i.e. radio or satellite phone) for each defined link and overall the number of satellite phones and radios needed. RBS has performed an analysis and determined that a total of 26 satellite phones and 29 radios are' needed to establish the required links. Adequate batteries to provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of hand held equipment (radios and satellite phones) usage should be provided. Based on the analysis performed, no additional spare batteries are needed. There may be an opportunity to optimize the amount of equipment needed. The RBS analysis was tracked in the Entergy corrective action program as LO-HQNLO-2011-0138, CA-00026.

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

NEI 12-01 Section 4.2 requires notification of the plant staff at the onset of the event. The RBS plant paging system provides public address capability over a large portion of the site.

Considering the event as defined by NEI 12-01, the system is limited primarily by the lack of system wide back up power. Although portions of the system may be available, it will not be credited as available for notification of plant personnel. Alternative measures should be established instead. Plant personnel will become aware of the large scale natural event by personal observation (e.g. loss of lighting). Personnel training (GET) will be updated to include direction regarding actions to be taken by personnel upon observation of the event.

That is, they are to report to the designated site assembly area(s). Site accountability process will be implemented to ensure all personnel are notified. A tracking item will be generated to evaluate this requirement (Table 11, Item #1).

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

Per NEI 12-01, "Some communications capability should be available at the ORO facilities that normally receive licensee notifications of an emergency declaration or a Protective Action Recommendation." The RBS Emergency Planning Department has assessed capabilities as their ORO facilities per LO-HQNLO-2011-0138 CA-00036. All nine (9) ORO facilities (West

RBG-47335 Attachment 2 Page 4 of 31 Feliciana Parish, East Feliciana Parish, West Baton Rouge Parish, East Baton Rouge Parish, Pointe Coupee Parish, Governors Office of Homeland Security & Emergency Preparedness (GOHSEP), Louisiana Department of Environmental Quality (LDEQ), Mississippi Emergency Management Agency (MEMA), and the Mississippi Highway Patrol (MHP)) have backup power. Based on the analysis performed, no additional communication capabilities (i.e.

satellite phones) will be required at the ORO facilities.

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

NEI 12-01 offers two potential options to promote timely staff augmentation by the ERO. RBS will ensure that "ERO members are trained to automatically respond to their assigned facilities or a designated staging area when made aware of a wide loss-of-grid (eg. by direct observation, media reports, word-of-mouth, etc.)." This expectation has been established with the ERO (see LO-HQNLO-2011-0138 CA-00016). This expectation will also be included in initial and annual ERO requalification training. A tracking item will be generated to include this expectation (Table, 11, Item #3).

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

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

Assessments have been performed, including walkdowns, of the existing installed radio equipment. Enhancements are recommended to address some identified concerns associated with the equipments' ability to survive a seismic event. Structural capability of the equipment support/mounting as well as impact from adjacent equipment and/or stored material should be addressed. Power supply enhancements are expected to be installed adjacent to the existing equipment and therefore would be subject to same assessment findings and resulting enhancements. A minor issue associated with wetting from flooding was identified for the Services Building 1 st floor (95' elevation) battery room. See Sections 4.13.1 - 4.13.4 for details. Programmatic requirements need to be established to ensure the credited equipment is maintained in a manner that maximizes survivability. A tracking item will be generated to establish these requirements (Table 11, Item #4).

No equipment is currently planned to be stored off site for onsite use.

4.6 Performance Characteristics (NEI 12-01 Section 4.6)

The RBS Emergency Planning Department has evaluated the required communications pathways to determine ifthe current systems are sufficient to support the emergency communications needs following severe environmental events. Where the current system did not meet the communications needs following severe environmental events, enhancements were identified. These enhancements are summarized in Table 10. The results are shown in Sections 4.13.1 - 4.13.4.

RBG-47335 Attachment 2 Page 5 of 31 The performance characteristics as identified in this section of NEI 12-01 requires that communication pathways (e.g., radio channels, satellite phone) designated to support multiple functions must be analyzed to demonstrate that they can simultaneously support both functions. The RBS Emergency Planning Department has assessed capabilities on a radio channel by radio channel or satellite phone device basis and did not identify where a single communication pathway was assigned to support multiple functions.

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

Enhancements (physical and programmatic) are recommended to ensure considerations, as identified in this section of NEI 12-01, are met. Provisions for portable backup power sources and batteries for battery operated equipment should be established. A tracking item will be generated to establish these provisions (Table 11, Item #5).

4.8 Quality and Maintenance-Related Requirements (NEI 12-01 Section 4.8)

The requirements identified in this section of NEI 12-01 should be incorporated into the program for ensuring the credited equipment is maintained in a manner that maximizes survivability. A tracking item will be generated to incorporate these requirements (Table 11, Item #6). A corporate level policy or procedure that takes the PF Project and puts requirements on it (e.g., housekeeping, walkdown by procedure), such that the facilities are maintained free of storage items and satellite phones are maintained and charges are adequate. This may include documenting inventories and adding PMs for periodic testing of the satellite phones, chargers. Existing site inventory and test procedures will be updated and used for the new equipment to ensure the equipment is available and operable. Site maintenance programs will be used as appropriate for controlling required maintenance (e.g.

replacing UPS batteries).

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

Entergy IT has assessed the NCS services per LO-HQNLO-2011-0138 CA-00045. Entergy IT recommends that Government Emergency Telephone Service access cards be acquired for key RBS positions. See CA-00045 for additional discussion. A tracking item will be generated to track this recommendation (Table 11, Item #7).

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

Entergy IT has contacted the major communications service providers which service the Entergy nuclear fleet (i.e. Verizon and AT&T). Neither company has a separate emergency services priority other than government TSP (Telecommunications Service Priority), which was assessed per LO-HQNLO-2011-0138 CA-00046. No further action is required. For further discussion, see LO-HQNLO-2011-0138 CA-00046.

4.11 Personnel Training (NEI 12-01 Section 4.11)

The requirements identified in this section of NEI 12-01 are recommended to be incorporated into the Entergy Emergency Training program. Additional training is needed to ensure required ERO and plant staff is familiar with the credited equipment's use, storage location and other requirements. Training may include: drills, tabletops, classroom and/or computer based training. Appropriate personnel will be familiarized with the communication equipment use,

RBG-47335 Attachment 2 Page 6 of 31 capabilities and limitations during the interim period prior to full implementation of the identified enhancements. A tracking item will be generated to incorporate these requirements (Table 11, Item #8).

4.12 Emergency Plan (E-Plan) Identified Systems Overview The following sections summarize the communications systems discussed in the RBS E-Plan, Section 13.3.6.2. The E-Plan Sections 13.3.6.2.1 and 13.3.6.2.2 state that communications may be established by different means (radio, phone, public address system). For the purposes of this evaluation, the communications capabilities in E-Plan Sections 13.3.6.2.1 and 13.3.6.2.2 are assumed to be successfully met ifthey are continuously available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the loss of onsite and offsite AC power via any method or combination of methods (radio, satellite phone, administrative controls, etc.). It is acknowledged that the majority of the installed EP systems have deficiencies which would prevent their survival in the Beyond-Design-Basis External Event. See Sections 4.13.1 - 4.13.4 for details concerning enhancements.

4.13 Equipment Locations and Capabilities The communications functions, radio reception/transmission equipment, and protection of each location from seismic, wind, and flooding are discussed below. Specifically, the structural capacity of the equipment in its current configuration was evaluated for its ability to withstand the identified external hazards. These hazards include seismic, flooding, and high winds. The structural evaluation was based on engineering judgment developed by a consensus of two engineers experienced in structural design and construction. The sections below provide a summary of the area walkdowns and their potential configuration concerns that could present challenges in maintaining an operable communication system in the event of one or more of the identified environmental hazards.

The EP Communications Equipment is located above the design basis flood elevation for the plant or is otherwise protected. The design basis flood elevation for RBS is 96 ft. This includes wave action and an upstream dam failure coincident with maximum precipitation and a standard hurricane.

4.13.1 Normal Switchgear Building (NSB)

Location and General Description The NSB is classified as a non safety-related structure and is designed Seismic Category II with interior and exterior masonry walls above grade. The NSB is a three-story structure located south of the Control Building with a basement floor slab at the 67'-6" elevation. The two upper floors are located at 96' and 123'-6" elevation. The two upper floors consist of concrete supported by a steel deck and beams. The exterior walls above elevation 98' are constructed using concrete blocks. The communications equipment is located in an air conditioned communication room in the NSB (123'-6" elevation). Entrance is through an interior fire door from the stairwell. The antennae for the repeaters are located on a tower attached to the top of the NSB structure.

The NSB interior wall structure does not provide reasonable assurance that the EP

RBG-47335 Attachment 2 Page 7 of 31 Communications Equipment is protected during a seismic event, as defined in NEI 12-01. See "Seismic Protection" discussion below.

Equipment & Functionality The communications equipment cabinet located in NSB (123'-6" elevation) houses the radio system cabinets. The communication equipment cabinet contains four repeaters (Operations, Maintenance, Radiological Field Monitoring, and Security). In addition, the Old Paging equipment, Radiax Antenna System, and combiner equipment is located in the communication equipment cabinets. The Operations and Maintenance Radio System is the primary radio communications network for normal onsite communication for Operations and Maintenance personnel. The Radiological Field Monitoring Radio Network is used to transmit offsite radiological data during an emergency. The Security Radio System is used to communicate with security personnel during normal and emergency conditions.

Remote radio stations are located inside and outside of the protected area. These stations provide coverage to interior and exterior areas of the plant. The antenna is located on a tower attached to the top of the NSB structure.

Power Control Room Distribution Panel 1VBN-PNL01A1, circuit 6 provides power to the radio system equipment. Distribution Panel 1VBN-PNL01A1 receives its 120 VAC power from Transformer 1VBN-XRC20Cl. The upstream power source, 13.8 KV Bus 1NPS-SWGIA, provides a main and alternate feed to Distribution Panel 1VBN-PNL01AI. The 13.8 KV power is stepped down to 120VAC thru a series of step down transformers. The communication equipment is backed up by a 40 KVA Uninterruptible Power Supply (UPS) System. As an enhancement, the UPS batteries should be sized to provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of capacity (see Table 10, Item #1).

Seismic Protection Switchgear, Inverter, and Battery Room NSB (123'-6" Elevation)

Seismic - ENHANCEMENT RECOMMENDED (see Table 10, Item #2)

Anchorages - ENHANCEMENT RECOMMENDED Issues:

o The black Motorola cabinets are not anchored to the floor. There is one bolt (in the vertical plane) tying the black Motorola cabinets to the gray cabinets. This attachment may not be seismically adequate.

o The batteries inside Battery Room C do not have seismic rails. The batteries are sitting on the rack and the battery rack is not anchored to the floor.

Acceptable Anchorage:

o The gray communication equipment cabinets are anchored to the floor. The anchorage of this equipment is seismically acceptable. There are no concerns regarding degraded anchorages.

o The Inverter and battery charger anchorage is acceptable. There are no concerns regarding degraded anchorages.

RBG-47335 Attachment 2 Page 8 of 31 Spatial Interactions Issues:

o The NSB is a non safety-related building with interior and exterior masonry walls above grade, which pose seismic Il/I concerns to the communication equipment (radios cabinets, batteries, and inverter).

Acceptable Spatial Interactions:

o Cable raceways are approximately 50% filled and are mounted using standard Unistrut rod hanger hardware. The coiled cables tie wrapped to the inside of the cable tray above Inverter INVO1 are judged acceptable.

• Housekeeping Issues:

o The communication equipment cabinets' door locks are broken. The cabinet doors are held closed using "Caution Tape".

Flood Protection - ACCEPTABLE Switchgear Room NSB (123'-6" Elevation) o There is a Fire Hose Station behind the communication equipment cabinets. The walkdown team could not see if it has Victaulic coupling on the fire piping due to insulation.

o No additional concerns for the NSB since the communication equipment cabinets are located at the 123'-6" elevation. Per RBS USAR Table 3.4-1, the average plant grade is 94'-6" elevation and the design flood elevation is at 96', which would be caused by an occurrence of the Probable Maximum Flood in the immediate plant area prior to completion of excavation backfilling operations. The dynamic effect resulting from wave forces at this low level of ponding (1' to 1.5' at the plant buildings) is considered negligible.

High Winds Protection - ACCEPTABLE The NSB is a seismic category II three story structure located south of the Control Building (CB). According to FSAR Section 3.9, normal wind loads applied to the buildings and structures is taken to be 100 mph, the annual extreme fastest mile speed, 30 it. above ground for a 100-year recurrence interval, at the plant Site. The EP communication equipment inside the NSB is reasonably protected from wind effects.

4.13.2 Services Building (SB)

Location and General Description The SB is classified as a non safety-related structure designed to the Uniform Building Code (UBC) and the Southern Building Code. The SB is a Seismic Category II three-story steel framed structure located east of the CB. The SB is equipped with a penthouse room at roof level. The exterior walls are constructed using concrete masonry blocks draped with metal siding. The building is supported by spread footings on compact fill. The Technical Support

RBG-47335 Attachment 2 Page 9 of 31 Center (TSC) and Operations Support Center (OSC) is located on the third floor at the +123' elevation in the SB.

The TSC is an onsite emergency response facility located near the Reactor Building. The TSC, as part of the SB, has been~built in accordance with the UBC and provides habitability comparable to the Main Control Room. The TSC has been designed to have approximately 4500 square feet of working area to accommodate EOI personnel with specific TSC responsibilities. In addition, space is provided for pre-designated NRC response personnel.

The SB structure provides reasonable assurance that the EP Communications Equipment is protected during a seismic event, as defined in NEI 12-01.

Equipment & Functionality The communications equipment is located on the second floor of the SB (109' elevation) in an air-conditioned environment. The communication equipment racks contain five Hotline Phone Systems (Corporate, Hospital, Shutdown, Facilities, and Security). In addition, the NRC Data Circuit and Site Radio Audio Bridges equipment is located in the communication equipment racks.

The Corporate Hotline is a dedicated system that serves the TSC, EOF, and Alternate EOF at Government Street (Baton Rouge). This system does not utilize any Central Branch Exchange (CBX) or public telephone services, but does use dedicated EOI pilotwire cables, fiber optic communications, and microwave facilities.

The Hospital Hotline provides a dedicated means of communication with the two hospitals idesignated to work with RBS during an emergency. Locations covered by this system include the Main Control Room, TSC, EOF, Our Lady of the Lake Hospital, and West Feliciana Hospital. This system does not utilize any CBX or public telephone services, but does utilize dedicated leased telephone circuits, EOI pilotwire cable, and fiber optic facilities.

TheShutdown Hotline provides a dedicated communications between the Main Control Room, OSC, TSC, Radiation Work Permit Office, and Hot Chemical Laboratory. It does not rely on any CBX or leased or public telephone facilities.

The Facilities Hotline is a dedicated onsite hotline, which serves the Main Control Room, TSC, OSC, and EOF. This system does not rely on any CBX or leased or public telephone facilities.

It does utilize EOI pilotwire cable and fiber optic communication facilities.

The Security Hotline provides a dedicated means of communication between the West Feliciana Sheriffs Office and the RBS Security Groups located in the Security Alarm Stations.

Power Distribution Panelboard 1SCA-PNL9K2, circuit 12 provides power to the communication equipment racks. Distribution Panelboard 1SCA-PNL9K2 receives its 120 VAC power from Transformer 1SCA-XD9K2. The upstream power source is connected to 13.8 KV Bus 1NPS-SWGI B. The 13.8 KV power is stepped down to 120VAC thru a series of step down transformers. The communication equipment is backed up by a 1 KVA Uninterruptible Power Supply (UPS) System. As an enhancement, the UPS batteries should be sized to provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of capacity (see Table 10, Item #3).

RBG-47335 Attachment 2 Page 10 of 31 Seismic Protection Seismic - ENHANCEMENT RECOMMENDED (see Table 10, Item #4)

" Anchorages - ENHANCEMENT RECOMMENDED Issues:

o The battery rack located on the 1st floor (95' elevation) is not properly anchored to the floor.

Acceptable Anchorage:

o The anchorage for the inverter, battery charger, and communication equipment racks located on the 2 ND floor (109' elevation) is acceptable.

o The TSC equipment (ESP computer, State and Local Hotline Phone, and radio console) are located on the desktop. There are no concerns due to the equipment small mass.

o The small satellite phone on wheeled cart in the OSC is judged acceptable. There are no seismic concerns due to the equipment small mass.

• Spatial Interactions Issues:

o Acoustical ceiling tiles with 2' X 4' fluorescent lighting in the Old PBX and New PBX room judged acceptable.

Acceptable Spatial Interactions:

o The masonry block walls in the 1 ST floor (95' elevation) battery room are judged acceptable although the batteries are not properly anchored to floor.

o The communication equipment inside the SB is reasonably protected from adverse seismic spatial interactions.

• Housekeeping Issues:

o Minor issue related to a computer chair on wheels near communication equipment racks.

o The casters for the Mod 80 phone cabinet next to the inverter rack are not locked.

Flood Protection- ENHANCEMENT RECOMMENDED (see Table 10, Item #5)

The only concern from flooding is associated with the batteries located in the 1 ST floor (95' elevation) battery room. The postulated one foot height of floodwater can short out the lower bank of batteries. Although the exterior security door is not water tight, it will slow the ingress of water into the room. A simple solution could be to mount the battery rack on a raised concrete pad.

RBG-47335 Attachment 2 Page 11 of 31 No flooding concerns for the communication equipment located at Elevations 109' and 123'-6". Per RBS USAR Table 3.4-1, the average plant grade is 94'-6" elevation and the design flood elevation is at 96'.

High Winds Protection - ACCEPTABLE According to Stone and Webster Calculation S25.5, the normal wind applied to the building is 110 mph per ANSI. The communication equipment located inside the SB is reasonably protected from high wind effects.

4.13.3 Fancy Point Radio Tower Site (FPRTS)

Location and General Description The FPRTS consists of a radio house, microwave house, and tower structure located near the RBS 230 KV Switchyard. Both the radio house and microwave house are non safety-related pre-fabricated fiberglass trailer like structures on a skid beneath a metal covered roof. The small fiberglass structure skids are bolted to the concrete slab via uplift angle clamps.

Although the fiberglass structures are non safety-related, their relative low profile was judged favorable in terms of seismic resistance. Per Drawing 12210-EY-8N-5, Sheet 2, the FPRTS is approximately at +114' elevation. Therefore, the FPRTS is above the RBS design flood level of +96'. The communication equipment is located within the radio house and 48 VDC batteries and battery charger are located within the microwave house.

The FPRTS structure provides reasonable assurance that the EP Communications Equipment is protected during a seismic event, as defined in NEI 12-01.

Equipment & Functionality The radio house contains a State and Local Hotline, Trunking Radio System, Tone Alert Monitor Paging System, and three repeaters (Radiological Field Monitoring, Siren, and WFPSO Detective Radio repeater). The Radiological Field Monitoring team radio network is used to transmit offsite radiological data. The Siren radio is used to provide notification to the Control Room, EOF, and five offsite parishes. The Siren radio is part of the Prompt Notification System. The WFPSO Detective Radio is used to provide a dedicated means of communication between the West Feliciana Sheriffs Office and the RBS Security personnel located in the Security Alarm Stations.

The State and Local Hotline provides the direct communications links with the Governor's Office of Homeland Security and Emergency Preparedness, the Louisiana Department of Environmental Quality, the initial points of contact and EOCs in the local Parishes, the Mississippi Highway Patrol, and the Mississippi Emergency Management Agency. This system, plus the data circuit, serves as the primary means of communications between RBS and offsite authorities.

The Tone Alert Monitor Paging System repeater is one of several paging repeaters that is used by local parishes in performing notifications to special facilities.

The Trunking Radio System is used to communicate with offsite agencies during any type of emergency. It can provide communication links with local parishes and State agencies.

RBG-47335 Attachment 2 Page 12 of 31 Power Per verbal discussion with RBS engineering personnel during walk down, AREVA team was informed that communication equipment is fed from the Fancy Point and Grant Substations. In addition, the communication equipment is backed by UPS and a local propane powered generator unit. The power supply source documents for the communication equipment were not made available during the walkdown. In addition, RBS engineering personnel noted that no documentation exists to show the electrical interface between the radio house, microwave house, and the local propane powered generator unit. As an enhancement, the UPS batteries should be sized to provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of capacity (see Table 10, Item #6).

Seismic Protection Seismic - ENHANCEMENT RECOMMENDED (see Table 10, Item #7)

• Anchorages - ENHANCEMENT RECOMMENDED Issues:

o The trunking system cabinets, radio cabinets, and communication equipment racks located inside the radio house are not anchored to the floor.

o The Motorola paging cabinet with wheels sits on plywood on the floor.

o The backup generator propane tank is not strapped to the concrete pad. In addition, the propane supply line to the generator consists of rigid piping. The supply line configuration has several hard spots, which can shear the line during a seismic event.

Acceptable Anchorage:

o There are no seismic concerns related to the UPS batteries and battenr charger anchorage.

o There are no seismic concerns related to the antenna tower.anchorage o The mounting of the equipment to the racks is acceptable.

• Spatial Interactions Issues:

o None Acceptable Spatial Interactions:

o The lightly filled cable raceways are judged acceptable. There are no concerns related to the electrical conduits in the room.

o There are no acoustical ceilings in the radio house. The room lighting is judged acceptable.

o The raceways located above the equipment are lightly filled and judged acceptable.

o The small fiberglass structure skid is bolted to concrete slab via uplift angle clamps.

Considering the low profile and the flexibility of both structures (a closed cell structure),

the EP communication equipment inside the radio house and the microwave house is reasonably protected from adverse seismic spatial interactions.

RBG-47335 Attachment 2 Page 13 of 31 Housekeeping Issues:

" There is a storage cabinet located next to the trunking system cabinet.

o There are several boxes of spare equipment stored on top of the radio cabinets.

o There are various boxes, trash, and plywood stored inside the radio house.

Flood Protection - ACCEPTABLE Per Drawing 12210-EY-8N-5, Sheet 2, the FPRTS is approximately at +114' elevation.

Therefore, the FPRTS is above the RBS design flood level of +96'. Therefore no flooding concerns are associated with the communications equipment located at the FPRTS.

High Winds Protection - ACCEPTABLE Considering the low profile of the radio and microwave house structures and the fact that both structures survived Hurricane Gustav in 2008, the communication equipment located inside the structures is reasonably protected from wind effects. The existing metal roof mounted on 4X4 posts may not survive strong winds and may shear off. Since the metal roof is not attached to the radio and microwave structures, a catastrophic failure of the structures has been ruled out.

4.13.4 Emergency Operations Facility (EOF)

Location and General Description The EOF is located within the RBS Training Center outside the plant security boundary near the intersection of U.S. Highway 61 and the River Bend Power Station Road. The RBS Training Center, in which the EOF is located, is outside the exclusion area and approximately 1.1 miles from the reactor building. The EOF is located on the 1 ST floor of the RBS Training Center at the +132' elevation. The EOF radio house\dog house is a non safety-related pre-'

fabricated trailer like structure on a skid located across the parking lot on the North side of the RBS Training Center. The small fiberglass structure skid is bolted to the concrete pad via uplift steel clamps.

The EOF has been designed to meet the requirements as specified in Supplement 1 to NUREG-0737. The EOF wing is a one-story seismic category II structure. The building is supported by spread footings on compact fill. The exterior walls are concrete with brick face.

The interior walls inside of the EOF wing are constructed using masonry blocks.

There is a natural gas generator located outside of the EOF. Since RBS does not provide power to the EOF, credit is taken for this generator in this assessment.

The EOF structure provides reasonable assurance that the EP Communications Equipment is protected during a seismic event, as defined in NEI 12-01.

Equipment & Functionality The EOF communication equipment consists of the Tone Alert Monitor Radio, three Hotline Phone Systems (Corporate, Hospital, and Facilities) and State and Local Hotline Radio, a Civil

RBG-47335 Attachment 2 Page 14 of 31 Defense Radio, Offsite Team Radio System, and an Emergency Siren System radio as well as Pager System paging terminal.. The Paging System terminal is used for notifying the RBS emergency organization personnel. This system can be activated by a computer based application as well as regular telephone service to access the system and activate paging sequences.

The Tone Alert Monitor Radio is used by local parishes in performing notifications to special facilities.

The Corporate Hotline is a dedicated system that serves the TSC, EOF, and Alternate EOF at Government Street (Baton Rouge). This system does not utilize any Central Branch Exchange (CBX) or public telephone services, but does use dedicated EOI pilotwire cables, fiber optic communications, and microwave facilities.

The Hospital Hotline provides a dedicated means of communication with the two hospitals designated to work with RBS during an emergency. Locations covered by this system include Main Control Room, TSC, EOF, Our Lady of the Lake Hospital, and West Feliciana Hospital.

This system does not utilize any CBX or public telephone services, but does utilize dedicated leased telephone circuits, EOI pilotwire cable, and-fiber optic facilities.

The Facilities Hotline is a dedicated onsite hotline, which serves the Main Control Room, TSC, OSC, and EOF. This system does not rely on any CBX or leased or public telephone facilities.

It does utilize EOI pilotwire cable and fiber optic communication facilities.

The State and Local Hotline Radio provides the direct communications links to connect the key emergency response facilities at RBS with GOHSEP, LDEQ, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification points, and the local emergency operations centers in the five local parishes, MHP, and MEMA. This system, plus the data circuit, serves as the primary means of communications between RBS and offsite authorities.

The Civil Defense Radio is used to communicate with offsite agencies during any type of emergency. It can provide communication links with local parishes and State agencies. The Radiological Field Monitoring team radio network is used to transmit offsite radiological data.

The Siren radio is used to communicate with the sirens in the five local parishes from the EOF or Control Room. The Siren radio is part of the Prompt Notification System.

Power Per verbal discussion with RBS engineering personnel during walk down, AREVA team was informed that EOF primary power feed comes from the Grant Substation. In addition, the communication equipment is backed up by multiple UPS units, battery banks, and a local 150 KVA natural gas powered generator unit. The power supply source documents for the communication equipment were not available during the walkdown. In addition, RBS engineering personal noted that no documentation exists to show the electrical interface between EOF and the local 150 KVA natural gas powered generator unit. As an enhancement, the UPS batteries should be sized to provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of capacity (see Table 10, Item #8).

RBG-47335 Attachment 2 Page 15 of 31 Seismic Protection Seismic - ENHANCEMENT RECOMMENDED (see Table 10, Item #9)

Anchorages - ENHANCEMENT RECOMMENDED Issues:

o The Siren 2 rack and the Teletouch paging cabinet are not anchored to the floor inside the EOF radio house\dog house.

o The backup battery charger rack and battery rack is properly anchored to the floor inside the EOF radio house\dog house.

o The 48-volt batteries inside the Simulator Battery Room are not seismically restrained.

The batteries are sitting on the rack without seismic rails.

o The UPS cabinet is not anchored to the floor inside the storage room. Neither is the adjacent battery cabinet properly anchored to the floor. The batteries sit on metal shelving inside the cabinet with no seismic restraints.

Acceptable Anchorage:

o The Plexiglas, (0.5" thick) used to provide personnel protection and limit the battery lateral movement for the batteries in the EOF radio house\dog house is judged acceptable with no adverse seismic concerns.

o No concerns associated with the natural gas backup generator outside of the EOF.

The natural gas line is made of HPDE and connected to the generator via a flexible hose.

o No concerns associated with the inverter rack, Mod 30, and Mod 80 phone cabinets located inside of the PBX Room. The telephone system backup battery rack is anchored to the floor.

o No seismic concerns on communication equipment (ESP computer, civil defense radio, or state and local hotline radio) located in the Siren Room.

Spatial Interactions Issues:

o None Acceptable Spatial Interactions:

o Overhead ceiling tiles and 2' X 4' fluorescent lighting in the PBX Room is judged acceptable.

o The River Bend Training Center is a non safety-related building designed to UBC and Southern Building Code. The EP communication equipment inside the. EOF is reasonably protected from adverse seismic spatial interactions based on the exterior concrete wall construction and being a single story building.

o The EOF radio house is a non safety-related pre-fab trailer like structure on skid. The small fiberglass structure skid is bolted to concrete via uplift steel clamps. Considering the low profile and the flexibility of the structure (a closed cell structure); the EP

RBG-47335 Attachment 2 Page 16 of 31 communication equipment inside the radio house is reasonably protected from adverse seismic spatial interactions.

Housekeeping Issues:

o There is a computer on a rolling cart located near the telephone batteries in the PBX Room.

o There are two (2) large tool chests on wheels near the UPS and battery cabinet in the storage room.

Flood Protection - ACCEPTABLE No flooding concerns for the EP communication equipment at EOF since they are located at an elevation above the design flood elevation. The River Bend Training Center grade is approximately El. -+132' and is well above the design flood elevation at El. +96' for RBS. This included the backup battery room and the diesel generator located outside of the building.

High Winds Protection - ACCEPTABLE The River Bend Training Center is a non safety-related building designed to UBC and Southern Building Code. The EP communication equipment inside the EOF is, reasonably protected from adverse wind effect based on the exterior concrete wall construction and being a single story building.

The EOF radio house is a non safety-related pre-fab trailer like structure on skid. The small fiberglass structure skid is bolted to concrete via uplift steel clamps. Considering the low profile and the flexibility of the structure (a closed cell structure) and the fact that the structure survived Hurricane Gustav in 2008 per plant engineers; the EP communication equipment inside the EOF radio house is reasonably protected from high wind effects.

5.0 ENHANCEMENTS

5.1 Portable Satellite Phones / Radios The RBS Emergency Planning Department has reviewed the communications links and has determined that a total of 26 satellite phones and 29 radios are needed to establish the required links (refer to Section 4.1). The evaluation identified that one additional satellite phone is needed. Additionally, spare batteries may also be needed.

Enhancement As an enhancement, recommend purchase of necessary number of satellite phones and spare batteries to ensure that communications links are fully functional. See Table 10, Item #10 6.0 INTERIM ACTIONS:

Interim measures were initially provided under letter RBG-47247, Entergy's 90-Day Response to the March 12, 2012, Information Request, Action Plan for Completing

RBG-47335 Attachment 2 Page 17 of 31 Emergency Communication and Staffing Assessments, dated June 13, 2012. Interim measures include:

" Satellite phones (11) have been distributed to the ERFs (EOF, TSC/OSC, CCR(s) and JIC. The phones are stored in hardened/cushioned cases or cabinets for protection. User aids are located with the phones for ease of use.

• Additional hand held radios (10) and spare batteries have been purchased and staged in the TSC/OSC. Ten additional radios and associated spare batteries have been staged in the EOF. Radios are stored in hardened/cushioned cases or cabinets for protection. Site personnel are familiar with use of these type radios.

• Hand held radios are programmed with talk around capability (allows usage without repeaters for limited distances).

• ERO notification methodology (per NEI 12-01, Section 4.4, second bullet) has been determined and implemented (see Section 4.4 above).

7.0 SCHEDULE

The above assessment has identified potential enhancements to provide the required communications capability during a beyond design basis event consistent with the assumptions specified in NEI 12-01. The table below summaries required actions and provides target completion dates.

Implementing Actions Target Completion Date Communication Equipment

" Additional satellite phones (11) staged in ERFs. complete

" Additional radios/batteries staged in ERFs complete

• Resolve non-engineering spatial interactions 12/31/13

• Complete engineering for indentified enhancements 5/15/14 (e.g. power supplies and structural upgrades).

• Procure additional portable equipment (e.g. radios, 8/15/14 satellite phones, batteries, generators) as required.

" Complete installation of engineered upgrades. 3/12/15 Communication with OROs

• Ensure ORO facilities are equipped with satellite 12/31/13 phones Miscellaneous

• ERO notification methodology implemented complete

" Finalize storage location(s) of portable generators 8/15/14

• Finalize training needs 5/15/14

" Implement required training 3/12/15

" Revise procedures to incorporate new equipment 3/12/15

• Revise GET to include assembly requirements during 12/31/13 a large scale external event.

• Ensure adequate GETS cards are available. 12/31/13

• Complete evaluation of TSP circuits 12/31/13

• Implement TSP enhancements per evaluation results 12/31/14

RBG'-47335 Attachment 2 Page 18 of 31 Table I Offsite Response Organization Notifications to, and communications with, OROs [per 10 CFR 50 Appendix E.IV.D anCd E.9.a]

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

Event (LSEE)? Assumed LSEE?

Control 1 per Control Emergency Support YES Plant-to-Offsite YES NO Room Room for Shift Package/State and Radio System Communicator Local Hotline (Civil Defense Radio)

Technical 1 for Key TSC Emergency Support YES Plant-to-Offsite YES NO Support Communicator Package/State and Radio System Center (TSC) Local Hotline (Civil Defense Radio)

Emergency 1 for Key EOF Emergency Support YES Plant-to-Offsite YES YES Operations Communicator Package/State and Radio System Facility (EOF) Local Hotline (Civil Defense Radio)

RBG-47335 Attachment 2 Page 1,9 of 31 Table 2 Nuclear Regulatory Commission Notifications to, and communications with, the Nuclear Regulatory Commission (NRC) Headquarters Incident Response Center and the appropriate NRC Regional Office Operations Center [per 10 CFR 50 Appendix E.IV.D and E.9.d]

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

Control Room 1 per Control ENS Bridge - NO N/A N/A N/A Room for ENS Dedicated J" Communicator phone Technical 1 for ENS ENS Bridge - NO Health PhySics NO NO Support Center Communicator Dedicated Network (HPN)

(TSC) phone _ ___

Location(s) 1 for HPN ENS Bridge - NO HPN NO YES where HPN Communicator Dedicated communications phone are performed (TSC, EOF)

RBG-47335 Attachment 2 Page 20 of 31 Table 3 Licensee Emergency Response Facilities Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E.9.c. Additional links that supportperformance of critical response functions are also specified.]. The minimum communications links to support this function are listed below by facility. For example, if the normally used telephone system cannot be restored to service, these links could rely upon some combination of radio, sound-powered and satellite-based communications systems.

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

Assumed LSEE?

Control 1 per unit Onsite Hotline YES CBX NO NO Room Technical 1 each for:

Support

• Senior/Lead TSC Onsite Hotline YES CBX NO NO Center Manager (TSC)

• Operations Onsite Hotline YES CBX NO NO Coordination

- Maintenance Onsite Hotline YES CBX NO NO Coordination

- Engineering Onsite Hotline YES CBX NO NO Coordination

- Radiological Support Health Physics NO CBX NO 'NO Network Additional response coordination links for multi-unit sites:

1 for eac position

. ANA N/A NIA providing Unit Response Coordination Operational 1 each for:

Support

• Senior/Lead OSC Onsite Hotline YES CBX NO NO Center Manager (OSC)

• Radiological Support HPN YES CBX NO NO

.RBG-47335 Attachment 2 Page 21 of 31 Emergency Minimum Primary Method Primary Method Backup Backup Planned or Response Communications Described in site Available Method(s) Method(s) Potential Facility Links E-Plan following Described in site Available Improvements Assumed LSEE? E-Plan following Identified?

Assumed LSEE?

Additional response coordination links for multi-unit sites:

- 1 for each position N/A N/A N/A N/A N/A providing Unit In-Plant Team Coordination Emergency 1 each for:

Operations ° Senior/Lead Manager Onsite Hotline YES CBX NO YES Facility - Key Protective Onsite Hotline YES CBX NO YES (EOF) Measures

- Operations or Onsite Hotline YES CBX NO YES Technical Support (as needed to support performance of dose projections, formulation.

of PARs and plant status updates to ORO authorities)

Joint 1 for Senior Manager CBX NO N/A NO NO Information Center (JIC)

RBG-47335 Attachment 2 Page 22 of 31 TableW4 Field I Offsite Monitoring Teams Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix E.9.c]

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

Assumed Assumed LSEE? LSEE?

Primary location Field/offsite Radiation Team YES N/A NO NO where field/offsite monitoring team Radio monitoring team coordination coordination is performed (CR)

Primary location 1 for each field/offsite Radiation Team YES N/A NO NO from which field/ monitoring team Radio offsite monitoring teams are deployed (EOF)

RBG-47335 Attachment 2 Page 23 of 31 Table 5 Other Federal Agencies Communications with other Federal agencies as described in the site emergency plan (e.g., the US Coast Guard) [per 10 CFR 50 Appendix E.9.b]

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

Assumed LSEE?

Primary location Coordination with ENS Bridge - NO HPN, NO NO where Federal agencies Dedicated phone communication with Federal agencies is performed (CR, TSC, EOF)

RBG-47335 Attachment 2 Page 24 of 31 Table 6 On-site and In-plant Response Teams Coordination and direction of on-site and in-plant response teams. This includes teams necessary to affect emergency repairs, firefighting, search and rescue, radiological monitoring, and implementation of Transition Phase coping and severe accident management strategies. To accommodate the timeline associated with NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (as discussed in Section 1), this element should be assessed in 2 phases.

o Phase 1 - Current Configuration Emergency Minimum Primary Method Primary Backup Backup Planned or Response Communications Described in Method Method(s) Method(s) Potential Facility Links site E-Plan Available Described in Available Improvements following site E-Plan following Identified?

Assumed Assumed LSEE?

LSEE?

On-shift staff Number necessary for Hand-Held YES NONE NO YES the on-shift staff to Portable Radio perform Initial Phase System coping actions (reflecting current staff

& strategies)

RBG-47335 Attachment 2 Page 25 of 31 Emergency Minimum Primary Primary Backup Backup Method(s) Planned or Response Communications Method Method Method(s) Available Potential Facility Links Described in Available Described in following Improvements site E-Plan following site E-Plan Assumed LSEE? Identified?

Assumed LSEE?

Operational 1 each for:

Support Center *On-site radiological RADIO YES NONE NO YES (OSC) and monitoring other site- 2 each for:

specific a Firefighting (1 for RADIO YES NONE NO YES locations as brigade leader and 1 necessary for the brigade) 2 each per unit for:

• In-plant radiological RADIO YES NONE NO YES monitoring

• Search and Rescue

• Emergency repairs Site-specific number RADIO YES NONE NO YES 1IVVU%=U LU II I I1JIVI I IVI It.

any 2 severe accident mitigation .

strategqies o Phase 2 - Configuration with all FLEX strategies (LATER)

RBG-47335 Attachment 2 Page 26 of 31 Table 7 Plant Paging (Announcementr System imunications Is this system available Planned or Potential following assumed LSEE? Improvement Identified?

'ns and discussion NO YES

RBG-47335 Attachment 2 Page 27 of 31 Table 8 Communications Equipment at ORO Facilities Emergency Minimum Primary Method Primary Method Backup Method(s) Backup Planned or Response Communications Described in Available Described in site Method(s) Potential Facility Links site E-Plan following E-Plan, Available Improvement Assumed following Identified?

LSEE? Assumed LSEE?

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

declaration or a ORO FACILITY Protective West Feliciana Parish ESP System YES Local Parish Radio YES NO Action Recommendatio n (as described East Feliciana Parish ESP System YES Local Parish Radio YES NO in the site emergency plan) GOHSEP ESP System YES Local Parish Radio YES NO LDEQ ESP System YES Local Parish Radio YES NO West Baton Rouge ESP System YES Local Parish Radio YES NO Parish

RBG-47335 Attachment 2 Page 28 of 31 Emergency Minimum Primary Primary Method Backup Method(s) Backup Planned or Response Communications Method Available Described in site Method(s) Potential Facility Links Described in following E-Plan Available Improvement site E-Plan Assumed LSEE? following Identified?

Assumed LSEE?

East Baton Rouge ESP System YES Local Parish Radio YES NO Parish Pointe Coupee Parish. ESP System YES Local Parish Radio YES NO MHP ESP System YES Local'Parish Radio YES NO MEMA ESP System YES Local Parish Radio YES NO

RBG-47335 Attachment 2 Page 29 of 31 Table 9 Equipment Locations and Protection SystemlEquipment Primary System Equipment protected from the below hazards Component Protected from Protected from Protected from Location Seismic Flooding Wind Comments as defined in this as defined in this as defined in this document document document EP Communication See Section 4.13.1 Equipment: (Radios, for details of NSB (+123'-6") No Yes Yes Repeaters, Battery protection Banks, Hotline Phone conclusions Systems, Audio See Section 4.13.2 Bridge, UPS, etc.) for details of Yes No Yes protetion SB (+95') protection conclusions See Section 4.13.2 for details of SB (+109') Yes Yes Yes protetion protection conclusions See Section 4.13.2 for details of SB (+123-6"') Yes Yes Yes protetion protection conclusions See Section 4.13.3 for details of FPRTS (+114) Yes Yes Yes protection conclusions See Section 4.13.4 for details of EOF (+132) Yes Yes Yes protection conclusions J h &

RBG-47335 Attachment 2 Page 30 of 31 Table 10: Summary of Enhancements Description Section #

Size the 40 KVA UPS batteries to provide adequate amp hour capacity as required. 4.13.1 Issues related to Anchorages, Spatial Interactions and Housekeeping in the NSB are 4.13.1 recommended to be addressed.

Size the 1KVA UPS batteries to provide adequate amp hour capacity as required. 4.13.2 Issues related to Anchorages, Spatial Interactions and Housekeeping in the SB are 4.13.2 recommended to be addressed.

Issue related to flooding in the 1 ST floor (+95 elevation) battery room is recommended be 4.13.2 addressed.

Size the FPRTS UPS batteries to provide adequate amp hour capacity as required. 4.13.3 Issues related to Anchorages and Housekeeping at the FPRTS are recommended to be 4.13.3 addressed.

Size the EOF UPS batteries to provide adequate amp hour capacity as required. 4.13.4 Issues related to Anchorages and Housekeeping at the EOF are recommended to be 4.13.4 addressed.

As an enhancement, recommend purchase of necessary number of satellite phones and 5.1 spare batteries to ensure all communications links are fully functional. I l

RBG-47335 Attachment 2 Page 31 of 31 Table 11: Tracking Items The items listed below require a tracking item to be generated to track the disposition of the item and will be managed as enhancements per this submittal.

Item # Description Section #

-1 Alternate means (in lieu of the PA system) for providing notification of the plant staff 4.2 at the onset of the event should be developed.

2 Not Used N/A 3 The expectation that "ERO members are trained to at'tomatically respond to their 4.4 assigned facilities or a designated staging area when made aware of a wide loss-of-grid (by direct observation, media reports, word-of-mouth, etc.)" will be included in annual ERO requalification training.

4 Programmatic requirements should be established to ensure credited equipment is 4.5 maintained in a manner that maximizes survivability.

5 Provisions for portable backup power sources and batteries for battery operated 4.7 equipment should be established.

6 The requirements identified in Section 4.8 of NEI 12-01 should be incorporated for 4.8 ensuring the credited equipment is maintained in a manner that maximizes survivability.

7 Entergy IT recommends that GETS access cards be acquired for key RBS 4.9 positions.

8 The requirements in Section 4.11 of NEI 12-01 should be incorporated into the 4.11 Entergy Emergency Planning program.