ML13134A050
| ML13134A050 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 06/05/2013 |
| From: | Siva Lingam Plant Licensing Branch II |
| To: | Nazar M Florida Power & Light Co |
| Lingam S NRR/DORL/LPL2-2 301-415-1558 | |
| References | |
| TAC MF0028, TAC MF0029 | |
| Download: ML13134A050 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 5, 2013 Mr. Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420
SUBJECT:
SAINT LUCIE PLANT, UNITS 1 & 2 - STAFF ASSESSMENT IN RESPONSE TO RECOMMENDATION 9.3 OF THE NEAR-TERM TASK FORCE RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NOS. MF0028 AND MF0029)
Dear Mr. Nazar:
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 to 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 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 (ADAMS Accession Number ML12307A116), Florida Power and Light Company responded to this request for Saint Lucie Plant. 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 21, 2013 (ADAMS Accession Number ML13057A033).
M. Nazar
- 2 The NRC staff has reviewed the communications assessments for Saint Lucie 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. 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,
~(f.~
Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389
Enclosure:
Safety Assessment cc: 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 FLORIDA POWER AND LIGHT COMPANY SAINT LUCIE NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-335 AND 50-389
1.0 INTRODUCTION
By letter dated October 31, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12307A116), Florida Power & Light Company (the licensee),
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 (NTTF) 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 (i.e.,
within 25 miles of the site, consistent with the guidance endorsed by NRC's May 15, 2012, letter (ADAMS Accession No. ML12131A043). Additionally, interim actions were identified by the licensee in a letter dated June 11,2012 (ADAMS Accession No. ML12172A145) 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.
Enclosure
- 2 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 alternative course of action that it proposes to take, including any estimated completion date.
On May 11, 2012 (ADAMS Accession No. ML12136A165), the licensee committed to submitting their completed communications assessment and implementation schedule by October 31, 2012. On June 11, 2012 (ADAMS Accession No. ML12172A145), 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). 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.
- 3 2.1 Regulations Section 50.47, "Emergency plans," to 10 CFR Part 50, sets forth emergency plan requirements for nuclear power plant facilities.
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.
- 4 The 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.
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 21, 2013 (ADAMS Accession No. ML13057A033), 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 3.1.1 Communication Links Saint Lucie Nuclear Plant, 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 certain existing communications system equipment such as portable satellite phones, radios, and sound powered phones would be available after implementation of planned enhancements, for the communication links listed above given a seismic, high wind, or flooding event. This was determined by evaluating the storage location of the equipment within seismic class I buildings as well as for winds and flooding.
As an interim measure prior to the implementation of all planned enhancements, the licensee purchased additional supplies of satellite phones, radios, associated batteries and a generator for the site. The licensee plans on utilizing existing site communications (including satellite phones and radios) and enhancing them with the additional equipment purchased as an interim measure. Instructions will be in place to help ensure the availability of the interim measures by providing for their maintenance and use. This equipment will be stored in protective areas and will be essentially in place by April 30,2013.
As the planned enhancement, the licensee plans on enhancing communication systems for each link outlined in Section 4 of NEI 12-01. Satellite phones will be utilized as one of the key methods for maintaining each communication link. Some communication links will augment the satellite phones with a combination of sound powered phones and radios, with the exception of field and offsite monitoring team and onsite and in-plant response team communications.
Onsite and in-plant response teams will utilize combinations of radios (and two radio repeaters) and their sound powered telephone system. Field and offsite monitoring teams will use radios for communications. The licensee is planning on enhancing the satellite telephones by staging the phones in protected areas, such as the emergency operations facility and technical support center and installing base stations. Additional portable radios will be stored in the technical support center. No enhancements were found to be necessary for the sound powered phones to be able to support communications during a large-scale natural event. The licensee also
- 5 confirmed that communications with offsite response organizations will be maintained with available portable satellite phones. The licensee will put most of these enhancements in place, with licensee approved procedures by April 30, 2013; however, the satellite phone base stations will be completed at a later date.
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 satellite telephones are expected to help maintain communications offsite by their ability to function without offsite infrastructure postulated to be damaged by a large-scale natural event.
The radios will help ensure communications in areas of the plant due to future system enhancements of equipment storage and the expected survivability of these existing radio system repeaters. The sound powered phones will help to ensure onsite communications, given the protective storage locations of the headsets and its ability to function without power.
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 NEI 12-01.
3.1.2 Equipment Location The licensee for Saint Lucie Nuclear Plant, Units 1 and 2, has analyzed the survivability of their communications equipment for large-scale natural events by utilizing plant design criteria. This was accomplished by analyzing equipment locations to be protective against seismic, wind, and flooding. Modifications have also been made to communications systems to help provide for further measures of survivability given a large-scale natural event (e.g., the storage of portable satellite phones and radios in the technical support center). The relocation of equipment for its protection will be completed by April 30, 2013.
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 NEI12-01.
The NRC staff also verified that communications 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 batteries and fuel supplies also would be protected from seismic, flooding, and high wind events.
Based on this review, the 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 3.1.3 Equipment Power and Fuel The licensee for Saint Lucie Nuclear Plant, 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 new generators to power site communications equipment, including the satellite phones, and radio systems, and has procured extra batteries for this equipment. The site strategies will result in: (1) each satellite phone having an adequate battery supply for operations and to allow for generator charging of spare batteries; (2) radios will have an adequate battery supply for operations and to allow for generator charging of spare batteries; (3) the radio repeaters can be powered by a portable generator; and (4) sufficient fuel for the generators are available 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. The licensee is planning on having these enhancements to the communication system power supplies completed by April 30, 2013, with approved procedures.
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 availability of extra batteries and generator fuel, and planned proceduralization of charging strategies. 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.
3.1.4 Proceduralization and Training The licensee for Saint Lucie Nuclear Plant, Units 1 and 2 has confirmed that there are sufficient reserves of equipment to minimize the need of multi-use equipment for different communication functions. The licensee plans on proceduralizing the strategies for charging the satellite phone and radio batteries, and the strategies for maintaining operations of the generators. Further, the licensee is developing operating and inventory procedures for this communications equipment.
Proceduralized guidance will be in-place by April 30, 2013. Licensee staff will receive periodic training on this communications equipment location and use.
Existing site procedures utilize the station public address system (provided with battery backup) to provide for notification to plant employees of an event. The licensee has procedures in place for emergency response organization staff self-activation due to major disturbances in the power grid. These site procedures 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
- 7 NRC staff determined that the licensee's submittal is in accordance with the NRC-endorsed guidance of NEI 12-01.
Based on this review, the 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.
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 as 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 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.
ML13134A050 e-mail