ML13116A125
| ML13116A125 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/30/2013 |
| From: | Siva Lingam Plant Licensing Branch II |
| To: | James Shea Tennessee Valley Authority |
| Lingam S NRR/DORL/LPL2-2 | |
| References | |
| TAC MF0032, TAC MF0033 | |
| Download: ML13116A125 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 April 30, 2013 Mr. Joseph W. Shea Vice President, Corporate Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 SUB.JECT: SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - STAFF ASSESSMENT IN RESPONSE TO RECOMMENDATION 9.3 OF THE NEAR-TERM TASK FORCE RELATED TO THE FUKUSHIMA DAHCHI NUCLEAR POWER PLANT ACCIDENT (TAC NOS. MF0032 AND MF0033)
Dear Mr. Shea:
By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information pursuant Section 50.54, paragraph (f) of Title 10 of the Code of Federal Regulations, regarding Recommendations 2.1 (seismic and flooding evaluations),
2.3 (seismic and flooding walkdowns), and 9.3 (emergency preparedness communication and staffing) of the Near-Term Task Force (NTTF) review of insights from the Fukushima Dai-ichi accident. With respect to NTTF Recommendation 9.3, Enclosure 5 to the NRC's letter requested licensees to assess their means to power communications equipment onsite and offsite during a prolonged station blackout event and to perform a staffing study to determine the staff required to fill all necessary positions in response to a multi-unit event.
By letter dated October 31,2012, Tennessee Valley Authority (the licensee) responded to this request for Sequoyah Nuclear Plant, Units 1 and 2. Generic technical concerns were issued by the NRC in a letter dated January 23,2013 (ADAMS Accession No. ML13016A111). The licensee supplemented its response in a letter dated February 22, 2013 (ADAMS Accession No. ML13058A067).
The NRC staff has reviewed the communications assessments for Sequoyah Nuclear Plant, Units 1 and 2 and, as documented in the enclosed staff analysis, determined that the assessment for communications is reasonable, and the interim measures, analyzed existing systems, and proposed enhancements will help to ensure that communications are maintained.
J. Shea -2 Further, in coordination with the NTTF Recommendation 4.2 (mitigating strategies), NRC staff is planning on following up with the licensee to confirm that upgrades to the site's communications systems have been completed.
If you have any questions, please contact me at (301) 415-1564.
Sincerely,
~~.~
Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328
Enclosure:
Safety Assessment cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY ASSESSMENT BY THE OFFICE OF NUCLEAR REACTOR REGULATION ASSESSMENT OF COMMUNICATIONS IN RESPONSE TO REQUEST FOR INFORMATION DATED MARCH 12, 2012 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 and 50-328
1.0 INTRODUCTION
By letter dated October 31, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12311A297), the Tennessee Valley Authority (the licensee), for Sequoyah Nuclear Plant (SQN), Units 1 and 2 provided an assessment of its communications capabilities in response to the U.S. Nuclear Regulatory Commission's (NRC's) March 12,2012 (ADAMS Accession No. ML12053A340), request for information, regarding the Near-Term Task Force (NTrF) Recommendation 9.3 on emergency preparedness communications, under Section 50.54(f) to Title 10 to the Code of Federal Regulations (10 CFR).
Within the licensee response letter, an assessment of the current communications systems and equipment to be used during an emergency event was performed to identify any enhancements needed to ensure communications are maintained during and following a beyond design basis large-scale natural event. In this assessment it was assumed that a large-scale natural event causes: (1) a loss of all alternating current (ac) power; and (2) extensive damage to normal and emergency communications systems both onsite and in the area surrounding the site (Le.,
within 25 miles of the site, consistent with the guidance endorsed by NRC's May 15, 2012
[ADAMS Accession No. ML12131A043], letter). Additionally, interim actions (ADAMS Accession No. ML12164A678) were identified by the licensee during the period of implementation of the planned improvements to the communications systems or procedures.
1.1 Background On March 12,2012, NRC issued a letter entitled "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident." In accordance with 10 CFR 50.54(f), addressees were requested to submit a written response to the information requests within 90 days.
The March 12, 2012, letter states that if an addressee cannot meet the requested response date, then the addressee must respond within 60 days of the date of the letter, and describe the Enclosure
- 2 alternative course of action that it proposes to take, including any estimated completion date.
On May 11,2012 (ADAMS Accession No. ML12136A131), the licensee committed to submitting their completed communications assessment and implementation schedule by October 31,2012. On June 11,2012 (ADAMS Accession No. ML12164A678), the licensee also provided their description of any interim actions (discussed in further detail in Section 3.0) that have been taken or are planned to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete.
The NRC staff found the proposed schedule acceptable by letter dated July 26, 2012 (ADAMS Accession No. ML12200A106).
Enclosure 5 of NRC's March 12,2012, letter contained specific requested information associated with NRC's NTTF Recommendation 9.3 for emergency preparedness communications. Specifically, the letter requested that licensees provide an assessment of the current communications systems and equipment used during an emergency event to identify any enhancements that may be needed to ensure communications are maintained during a large-scale natural event and subsequent loss of ac power. The licensee's assessment should:
- identify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies;
- identify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies;
- provide a description of any new communications system(s) or technologies that will be deployed based upon a large-scale natural event and damage to communications systems onsite and offsite; and
- provide a description of how the new and/or improved systems and power supplies will be able to provide for communications during a loss of all ac power.
The letter also asked for licensees to:
- describe any interim actions that have been taken or are planned to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete; and
- provide a schedule of the time needed to implement the results of the communications assessment.
2.0 REGULATORY EVALUATION
The NRC staff reviewed the licensee's responses to the March 12, 2012,10 CFR 50.54(f),
request for information against the regulations and guidance described below.
2.1 Regulations Section 50.47, "Emergency plans," to 10 CFR Part 50, sets forth emergency plan requirements for nuclear power plant facilities.
-3 Section 50.47(b) establishes the standards that the onsite and offsite emergency response plans must meet for NRC staff to make a positive finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency. Planning Standard (6) of this section requires that a licensee's emergency response plan contain provisions for communications among response organizations to emergency personnel and the public. Planning Standard (8) requires that the design should include adequate emergency facilities and equipment to support emergency response.
Section IV. D of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, requires that a licensee have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency. The design objective of the alert and notification system shall be to have the capability to complete the alerting and initiate notification of the public within the plume exposure pathway within approximately 15 minutes. This alerting and notification capability will include a backup method of public alerting and notification.
Section IV. E of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, states that adequate provisions will be made and described for emergency facilities including at least one onsite and one offsite communications system; and each system shall have a backup power source. These arrangements will include:
- a. Provision for communications with contiguous Statellocal governments within the plume exposure pathway emergency planning zone.
- b. Provision for communications with Federal emergency response organizations.
- c. Provision for communications among the nuclear power reactor control room, the onsite technical support center, and the emergency operations facility; and among the nuclear facility, the principal State and local emergency operations centers, and the field assessment teams.
- d. Provisions for communications by the licensee with NRC Headquarters and the appropriate NRC Regional Office Operations Center from the nuclear power reactor control room, the onsite technical support center, and the emergency operations facility.
2.2 Guidance Nuclear Energy Institute (NEI) 12-01 "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," presents a methodology for licensees to analyze their ability to perform critical communications during and after a large-scale natural event. NRC staff has previously reviewed NEI 12-01 (ADAMS Accession No. ML12131A043) and determined that it was an acceptable method for licensees to use in responding to NRC's March 12, 2012 information request.
The NRC staff reviewed the licensees' analyses against the assumptions and guidance within NEI 12-01, Sections 2.2, 2.4 and 4. These sections provide a discussion on the assumptions and criteria to be used for a communications assessment.
-4
3.0 TECHNICAL EVALUATION
In its October 31,2012, letter, the licensee submitted its assessment of communications assuming a large-scale natural event. which would lead to an extended loss of all ac power.
This letter included a discussion of required communications links, primary and backup methods of communications, and any identified improvements.
On February 22,2013 (ADAMS Accession No. ML13058A067), the licensee submitted supplemental information to its October 31,2012, communications response, which the NRC staff reviewed as part of this evaluation.
3.1 Communication Areas Reviewed SQN, Units 1 and 2 currently has communications capabilities with offsite response organizations, the NRC, between licensee emergency response facilities, with field and offsite monitoring teams, and with in-plant and offsite licensee emergency response organization staff.
As part of its communications assessment, the licensee has determined that many of the communications equipment described in its emergency plan can be assumed not available.
However, certain existing onsite communications system equipment such as satellite phones, radio-to-radio communications, and sound powered phones would be available after implementation of planned enhancements, for some communication links listed above given a seismic, high wind, or flooding event. The availability of these systems was determined by evaluating the equipment against seismic, flooding, and high-wind events. The tinallocation of the portable equipment will be consistent with criteria contained within NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide." NEI 12-01 discusses that this FLEX criteria is a reasonable definition of protectiveness.
As an interim measure prior to the implementation of all planned enhancements, the licensee purchased additional supplies of portable satellite phones that are available for use onsite.
Existing radio-to-radio communications are available to allow for onsite communications; a repeater with antenna will be added prior to June 30, 2013, to augment radio communications.
Portable generators have been purchased for the site as well, to help power satellite phone and radio batteries. Portable communications equipment is currently stored in the technical support center.
As the planned enhancement, the licensee plans on purchasing a new radio system for the site and further enhancing existing communication systems for the links outlined in Section 4 of NEI 12-01. The new radio system and satellite phones will be utilized as one of the key methods for maintaining each offsite communication link. Communications onsite will utilize combinations of the sound powered phones, and radio communications. The existing radio-to radio communications will be enhanced by the new radio system and associated repeaters.
The new radio system and repeaters will be in a protected area with backup power. The existing sound powered phones provide a backup onsite communications system to the radio system, if necessary. The licensee also confirmed that satellite communications with offsite response organizations are available at these offsite locations. The licensee will put most of these enhancements in place by December 30, 2014. 1 1 Power source items related to FLEX will be completed in alignment with NRC Order EA-12-049.
- 5 The NRC staff has reviewed the licensee's expected communications links within their communications assessment. In reviewing their submittal, the NRC staff considered whether it is reasonable that each communication link can be maintained, after the implementation of all planned enhancements, in accordance with the NRC-endorsed guidance of NEI12-01. The onsite satellite telephones are expected to help maintain communications offsite by their ability to function without infrastructure postulated to be damaged by a large-scale natural event. The new radio system will help maintain communications offsite and between emergency response facilities due to it being in a protected location with backup power. The new radio system and associated repeaters will also help ensure communications in areas of the plant due to its protective location and backup power. The sound powered phones will provide communications capabilities to augment the radio system in needed areas of the plant. The NRC staff concludes that since the licensee's assessment for the availability of communications systems is reasonable, and planned enhancements are to be made for communications areas to help ensure reliability, the licensee's interim measures and proposed enhancements will help to ensure that communications are maintained consistent with the assumptions in NRC-endorsed guidance of NEI12-01.
3.1.1 Equipment Location The licensee for SQN, Units 1 and 2 has analyzed the survivability of its existing equipment for large-scale natural events by utilizing guidance in Electric Power Research Institute (EPRI)
NP-6041 "Nuclear Power Plant Seismic Margin" and/or similar to FLEX guidance. Further, equipment locations were also analyzed to be protective against wind, and flooding.
Enhancements to equipment protection will be made by storing portable equipment in accordance with FLEX criteria. Specifically, a new building is to be constructed to meet NEI 12-06 guidance, which will house portable communications equipment, and contain its own stand-alone electrical system. Protectiveness criteria (e.g., seismic, wind, and flooding) was also used to determine ancillary equipment storage locations, including the new radio repeaters and generators that will be used to support the interim measures and/or planned enhancements. The completion of the new protective building will be in alignment with FLEX.
NRC staff reviewed the licensee's submittal and verified that the licensee has considered the equipment location and protection contained within the NRC-endorsed guidance of NEI 12-01.
The NRC staff also verified that a" equipment discussed in Section 3.1.1 of this document has been analyzed to be available after a large-scale natural event or would be stored in a reasonably protected area from seismic, flooding, and high-wind events as discussed in NEI 12-01. The NRC staff also ensured that ancillary equipment, such as generators would be protected from seismiC, flooding, and high wind events.
Based on this review, the NRC staff considers the licensee's analysis of communications assessment equipment survivability and proposed enhancements for equipment location to be consistent with NRC endorsed guidance NEI 12-01. This determination of equipment protection, support the conclusion that these measures will help to ensure communications equipment availability for a large-scale natural event.
-6 3.1.2 Equipment Power and Fuel The licensee for SON, Units 1 and 2 has analyzed the availability of their communications system power supplies following the loss of all ac power. The licensee has proposed a combination of batteries and generators to power site communications equipment, including the satellite phones, and radios. The site strategies will result in: (1) radios allowing for generator charging of batteries; (2) satellite phones allowing for generator charging of batteries; (3) the new site radio system and associated repeaters will have an 8-hour battery backup with generator charging after that period; and (4) sufficient fuel for the generators for a greater than 24-hour duration. It is expected that this equipment has power to support communications for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, based on assumptions for impeded site access. Finalized procedures for the generator operator actions will be completed in alignment with NRC order EA-12-049 and will be completed in accordance with licensee procedure NPG-SPP-09.3, "Plant Modifications and Engineering Change ControL" The NRC staff has reviewed the licensee's communications assessment power supplies. In reviewing their submittal, the NRC staff finds it reasonable that power for the existing equipment and proposed enhancement equipment, as listed in Section 3.1.1 of this document, would remain available for a 24-hour duration, based on the expected availability of programmatic controls, generator fuel, and generators. Additionally, the licensee's proposed enhancement is in accordance with NRC-endorsed guidance of NEI 12-01.
Based on this review, the staff considers the licensee's analysis of equipment power and proposed enhancements for equipment power to be consistent with NRC endorsed guidance NEI 12-01. This determination of available equipment power, support the conclusion that these measures will help to ensure communications equipment functionality for a large-scale natural event.
3.1.3 Procedura\ization and Training The licensee for SON, Units 1 and 2 plans on implementing site programmatic control strategies for communications equipment, in accordance with procedure NPG-SPP-09.3 and FLEX. This will ensure programmatic controls for potential shared use, operator action, testing, and maintenance. Procedures for Emergency Preparedness-related communications equipment will be in-place by October 15, 2014. Licensee staff training will be evaluated and the results will be incorporated into operations and emergency response organization training programs by October 15, 2014.
Existing site procedures allow for the notification of plant employees after a large-scale natural event. The licensee also has procedures in place for emergency response organization staff self-activation due to large-scale disasters. These existing site capabilities will activate the offsite emergency response organization and notify plant staff.
The NRC staff reviewed the licensee's commitments on the planned quality assurance and maintenance of the equipment and licensee staff training on the use of this equipment. The NRC staff determined that the licensee's submittal is in accordance with the NRC-endorsed guidance of I\lEI 12-01.
-7 Based on this review, the /\IRC staff considers the licensee's planned proceduralization of equipment use and licensee staff training to be consistent with NRC endorsed guidance, NEI 12-01. This determination of equipment availability and functionality, support the conclusion that these measures will help to ensure communications equipment functionality for a large-scale natural event.
3.2 Regulatory Commitments The licensee's regulatory commitments were provided in its submission dated October 31, 2012, in response to the March 12, 2012, request for information.
The NRC staff's review did not solely rely on the regulatory commitments made for determination of the acceptability of the licensee's communications assessment and the interim measures, analyzed existing systems, and proposed enhancements for the site.
4.0 CONCLUSION
The NRC staff has reviewed the licensee's communications assessment for communications with or among: offsite response organizations, NRC, licensee emergency response facilities, field and offsite monitoring teams, and on-site and in-plant response teams. In reviewing their submittal, the NRC staff considered the factors outlined above, and determined that their assessment of existing equipment, proposed enhancements and interim actions was in accordance with the NRC-endorsed guidance of NEI 12-01. The NRC staff concludes that the licensee's assessment for communications is reasonable, and the licensee's interim measures, analyzed existing systems, and proposed enhancements will help to ensure that communications are maintained. Further, in coordination with the NTTF Recommendation 4.2 (mitigating strategies), NRC staff is planning on following up with the licensee to confirm that upgrades to the site's communications systems have been completed.
J.Shea - 2 Further, in coordination with the NTTF Recommendation 4.2 (mitigating strategies), NRC staff is planning on following up with the licensee to confirm that upgrades to the site's communications systems have been completed.
If you have any questions, please contact me at (301) 415-1564.
Sincerely, IRA!
Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328
Enclosure:
Safety Assessment cc w/encl: Distribution via Listserv DISTRIBUTION:
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,I NAME Slingam BClayton KWilliams* JQuichocho II DATE 04/29/13 04/29/13 4124113 04/30/13 OFFICIAL RECORD COpy