ML13142A160
| ML13142A160 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/06/2013 |
| From: | Balwant Singal Plant Licensing Branch IV |
| To: | Koehl D South Texas |
| Singal B NRR/DORL/LPL4 | |
| References | |
| TAC MF0034, TAC MF0035 | |
| Download: ML13142A160 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 6, 2013 Mr. Dennis L. Koehl President and CEO/CNO STP Nuclear Operating Company South Texas Project P.O. Box 289 VVadsworth, TX 77483
SUBJECT:
SOUTH TEXAS PROJECT, UNITS 1 AND 2 - SAFETY ASSESSMENT IN RESPONSE TO INFORMATION REQUEST PURSUANT TO 10 CFR SO.S4(f)
RECOMMENDATION 9.3 COMMUNICATIONS ASSESSMENT (TAC NOS. MF0034 AND MF003S)
Dear Mr. Koehl:
By letter dated March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued a request for information pursuant to Section SO.S4(f) to Title 10 of the Code of Federal Regulations (henceforth referred to as the SO.S4(f) letter}. The request was issued as a part of implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant.
Enclosure S to the SO.S4(f) letter contained specific requested information associated with the NRC's Near-Term Task Force Recommendation 9.3 for emergency preparedness communications. Specifically, the letter requested that licensees to provide an assessment of the current communications systems and equipment used during an emergency event.
By letter dated October 31,2012, STP Nuclear Operating Company (STPNOC, the licensee) responded for South Texas Project (STP), Units 1 and 2. In response to NRC staff questions, STPNOC provided additional information by letter dated February 21, 2013.
The NRC staff has reviewed the communications assessment for STP, Units 1 and 2, and, as documented in the enclosed safety assessment, 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 Near-Term Task Force Recommendation 4.2 (mitigating strategies), the NRC staff plans to follow up with the licensee to confirm that upgrades to the site's communications systems have been completed.
D. Koehl
- 2 If you have any questions, please call me at 301-415-3016 or via e-mail at Balwant. Singal@nrc.gov.
Sincerely, Docket Nos. 50-498 and 50-499
Enclosure:
As stated 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 REVIEW OF COMMUNICATIONS ASSESSMENT IN RESPONSE TO REQUEST FOR INFORMATION DATED MARCH 12,2012 STP NUCLEAR OPERATING COMPAN SOUTH TEXAS PROJECT. UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499
1.0 INTRODUCTION
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(f) to Title 10 of the Code of Federal Regulations (10 CFR) (henceforth referred to as the 50.54(f) letter). The request was issued as a part of implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 5 to the 50.54(f) letter contained specific requested information associated with the NRC's Near-Term Task Force Recommendation 9.3 for emergency preparedness communications. Specifically, the letter requested that licensees to provide an assessment of the current communications systems and equipment used during an emergency event.
By letter dated October 31,2012 (ADAMS Accession No. ML12318A096), as supplemented by letter dated February 21, 2013 (ADAMS Accession No. ML13092A258), STP Nuclear Operating Company (STPNOC, the licensee), provided an assessment of its communications capabilities in response to the NRC's request for information for South Texas Project (STP), Units 1 and 2.
Within the licensee's 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 the NRC's letter dated May 15, 2012'). Additionally, interim actions were identified by the licensee during the period of implementation of the planned improvements to the communications systems or procedures.
Skeen, D. L., U.S. Nuclear Regulatory Commission, letter to Susan Perkins-Grew, Nuclear Energy Institute, "U.S. Nuclear Regulatory Commission Review of NEI 12-01, 'Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,' Revision 0," dated May 2012," dated May 15, 2012 (ADAMS Accession No. ML12131A043).
Enclosure
- 2
1.1 Background
On March 12, 2012, the 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 50.54(f) letter stated that if an addressee could not 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. By letters dated May 9 and June 4,2012 (ADAMS Accession Nos. ML12136A472 and ML12163A344, respectively), the licensee committed to submit its completed communications assessment and implementation schedule by October 31, 2012. By letter dated June 4, 2012 (ADAMS Accession No. ML12163A331), the licensee also provided a 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 the 50.54(f) letter contained specific requested information associated with NRC's Near-Term Task Force 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 extensive damage to normal and emergency communications systems both 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 50.54(f) 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 an implementation schedule of the time needed to conduct and implement the results of the communications assessment.
- 3
2.0 REGULATORY EVALUATION
The NRC staff reviewed the licensee's responses to the 50.54{f) letter against the regulations and guidance described below.
2.1 Regulations Section 50.47, "Emergency plans," of 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 adequate emergency facilities and equipment to support emergency response are provided and maintained.
Section IV.D, "Notification Procedures," 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 prompt public alert and notification system shall have the capability to complete the alerting and initiate notification of the public within the plume exposure pathway within about 15 minutes. This alerting and notification capability will include a backup method of public alerting and notification.
Section IV.E, "Emergency Facilities and Equipment," of Appendix E to 10 CFR Part 50, states that adequate provisions shall 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.
- 4 2.2 Guidance Nuclear Energy Institute (NEI) 12-01, Revision 0, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," dated May 2012, presents a methodology for licensees to analyze their ability to perform critical communications during and after a large-scale natural event. The 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 the NRC's March 12, 2012, information request.
The NRC staff reviewed the licensee's 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, as supplemented by its February 21, 2013, 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.
3.1 Communication Areas Reviewed 3.1.1 Communication Links STPNOC currently has communications capabilities with offsite response organizations (OROs),
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 some existing communications system equipment such as radios (i.e., line-of-sight radio communications) and sound-powered phones would be available after implementation of planned enhancements, for certain communication links listed above given a seismic, high-wind, or flooding event. This was determined by ensuring that the final location of the equipment will be located within protective buildings (e.g., seismic category I) and also protected from wind and flooding events.
As an interim measure prior to the implementation of all planned enhancements, the licensee is utilizing existing site communication systems, including radios and sound-powered telephones.
The licensee has also purchased additional supplies of satellite phones, batteries, sound powered phone headsets and portable diesel generators. Procedures on the inventory and function checks of this new equipment has been implemented. The protectiveness of the interim measures for communications is based on the diversity of the storage locations within seismically protected buildings.
As the planned enhancement, the licensee intends to ensure that: 1} satellite capabilities for communications offsite; and 2) radios and sound-powered phones for communications onsite, are available for links outlined in Section 4 of NEI 12-01. The licensee has confirmed that communications with OROs can be maintained by satellite phone. The licensee will put these enhancements in place, with licensee-approved procedures by November 2015.
- 5 The NRC staff has reviewed the licensee's expected communications links within its communications assessment. In reviewing its 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 NEI 12-01. The additional satellite communication capabilities, in conjunction with existing satellite telephones, are expected to help maintain communications offsite of the plant due to their ability to function without installed infrastructure. The radios and sound-powered telephones will help ensure communications onsite due to their ability to function line-of-site and the redundancy of communication systems. 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 availability, 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 has analyzed the survivability of its existing equipment for large-scale natural events by crediting equipment primarily located in seismically designed buildings. Further, equipment locations were also analyzed to also be protective against wind and flooding. Other enhancements to equipment protection will be made by storing ancillary equipment, such as generators, consistent with criterion contained within NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," May 2012 (ADAMS Accession No. ML12143A232).
New communications equipment will be stored in similar locations. The determination of final storage locations of communications equipment will be completed by November 2015, in alignment with FLEX.
The 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 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 also 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 the NRC-endorsed guidance of NEI 12-01. This determination of equipment protection supports the conclusion that these measures will help to ensure communications equipment availability for a large-scale natural event.
3.1.3 Equipment Power and Fuel The licensee has analyzed the availability of its 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, and has procured extra batteries for this equipment. The site strategies will result in: (1) radios having a supply of spare batteries and, if necessary, to allow for generator charging of batteries; (2) satellite communications having a combination of batteries and/or generator power available;
- 6 and (3) fuel supplies for the generators to support 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of communications developed in alignment with FLEX. The licensee will also develop, as part of its FLEX analyses, generator operating procedures and confirm that power supplies are functional for communications equipment analyzed as available. 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 November 2015.
The NRC staff has reviewed the licensee's communications assessment power supplies. In reviewing the licensee's 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 planned proceduralization of generator operation and fueling strategies. Additionally, the licensee's proposed enhancement is in accordance with NRC-endorsed guidance of NEI 12-01.
Based on this review, the NRC staff considers the licensee's analysis of equipment power and proposed enhancements for equipment power to be consistent with the NRC-endorsed guidance NEI 12-01. This determination of available equipment power supports 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 has confirmed that there procedures for the shared use of equipment will be developed for different communication functions. The licensee plans on implementing programmatic control strategies for new communications equipment, including periodic testing and maintenance, in alignment with existing site procedures or FLEX. Interim measures equipment has already been included into existing site procedures. Licensee staff is trained through drills and exercises, which also includes communications equipment, per the site emergency plan.
Existing site procedures utilize security to provide for notification to plant employees outside of the protective area if the public address system is non-functional after a large-scale natural event. The licensee is evaluating methods within the protective area and will have methods in place by November 2015 (existing sound-powered phones are available in the interim for onsite communications). The licensee also has procedures in place for emergency response organization staff self-activation due to large-scale external events. These site capabilities will activate the offsite emergency response organization and notify plant staff.
The NRC staff reviewed the licensee's plans for the 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 NEI12-01.
Based on this review, the NRC staff considers the licensee's planned proceduralization of equipment use and licensee staff training to be consistent with the NRC-endorsed guidance, NEI12-01. This determination of equipment availability and functionality supports the conclusion that these measures will help to ensure communications equipment functionality for a large-scale natural event.
- 7 3.2 Regulatory Commitments The licensee provided the following regulatory commitments in its letters dated October 31, 2012, and February 21,2013:
No.
Commitment Condition Report No.
Scheduled Due Date 1
STPNOC will perform 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. The assessment will be provided to the NRC.
12-11657-7 10/31/12 (Complete) 2 STPNOC will provide an implementation schedule of the time needed to implement the results of the communications assessment.
12-11657-8 10/31/12 (Complete) 3 The numbers for four new handheld satellite phones will be added to the Emergency Communications Directory during the next quarterly update in March 2013.
12-11657-21 3/31/13 4
Two additional satellite phones will be purchased for use in the EOF as an interim measure. These phones will be stored in the EOF, procedures will be revised to inventory and check the functionality, and their numbers added into the Emergency Communications Directory.
12-11657-22 9/30/13 i
5 For each unit, two additional satellite phone batteries and one battery charger will be purchased for use onsite as an interim measure. These batteries and chargers will be purchased, stored in the EAB, and procedures will be revised to inventory and check the functionality.
12-11657-23 9/30/13
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4.0 CONCLUSION
The NRC staff has reviewed the licensee's communications assessment for communications with or among: OROs, the NRC, licensee emergency response facilities, field and offsite monitoring teams, and on-site and in-plant response teams. In reviewing the licensee's submittal, the NRC staff considered the factors outlined above, and determined that its 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 Near-Term Task Force 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.
Principal Contributor: R. Chang, NSIRlNRLB Date: June 6, 2013
D. Koehl
- 2 If you have any questions, please call me at 301-415-3016 or via e-mail at Balwant.Singal@nrc.gov.
Docket Nos. 50-498 and 50-499
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC Branch Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNsirDprDdep Resource RidsNrrLAJBurkhardt Resource Sincerely, IRA by JSebrosky forI Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsNrrPMSouthTexas Resource RidsRgn4MailCenter Resource MMitchell, NRRlJLD/PMB BHarris, NRRlJLD/PMB RChang, NSIR ADAMS Accession No. ML13142A160
- via email OFFICE NRRJDORULPL4/PM NRR/DORULPL4/LA NSIRIDPRJDDEP/NRLB/BC NAME BSingal JBurkhardt KWilliams" DATE 05/30/13 05129/13 05/20/13 IOFFICE OGC -NLO NRR/DORULPL4/BC NRR/DORULPL4/PM NAME MSpencer MMarkley JSebrosky for BSingal
~TE 06/03/013 06/06/13 06/06/13 OFFICIAL AGENCY RECORD