ML13149A171
| ML13149A171 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/03/2013 |
| From: | Lyon C Plant Licensing Branch IV |
| To: | Matthew Sunseri Wolf Creek |
| Lyon C | |
| References | |
| TAC MF0044 | |
| Download: ML13149A171 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 3,2013 Mr. Matthew W. Sunseri President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839
SUBJECT:
WOLF CREEK GENERATING STATION - SAFETY ASSESSMENT IN RESPONSE TO INFORMATION REQUEST PURSUANT TO 10 CFR 50.54(f)
RECOMMENDATION 9.3 COMMU NICATIONS ASSESSMENT (TAC NO. MF0044)
Dear Mr. Sunseri:
By letter dated March 12, 2012, 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 (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. 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 provide an assessment of the current communications systems and equipment used during an emergency event.
By letter dated October 31,2012, Wolf Creek Nuclear Operating Corporation (the licensee),
responded for the Wolf Creek Generating Station. In response to NRC staff questions, the licensee provided additional information by letter dated February 26, 2013.
The NRC staff has reviewed the communications assessment for WCGS, 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.
M. Sunseri -2 If you have any questions, please contact me at 301-415-2296 or via e-mail at fred.lyon@nrc.gov.
Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482
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 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. SO-482
1.0 INTRODUCTION
By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 120S3A340), 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 (10 CFR) (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 provide an assessment of the current communications systems and equipment used during an emergency event.
By letter dated October 31, 2012 (ADAMS Accession No. ML12313A009), as supplemented by letter dated February 26,2013 (ADAMS Accession No. ML13072A090), Wolf Creek Nuclear Operating Corporation (WCNOC), the licensee for Wolf Creek Generating Station (WCGS),
provided an assessment of its communications capabilities in response to the NRC's request for information.
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 (Le., within 2S miles of the site, consistent with the guidance endorsed by the NRC's letter dated May 1S, 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 NEI12-01, '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 SO.S4(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 SO.S4(f), addressees were requested to submit a written response to the information requests within 90 days.
The SO.S4(f) letter stated 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. By letter dated May 9, 2012 (ADAMS Accession No. ML12138A012), the licensee committed to submitting its completed communications assessment and implementation schedule by October 31,2012. By letter dated June 6,2012 (ADAMS Accession No. ML 1216SAS79), 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).
Enclosure S of the SO.S4(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 SO.S4(f) letter also requested the 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 principal response organizations to emergency personnel and to the public. Planning Standard (8) requires that adequate emergency facilities and equipment to support emergency response are provided and maintained.
Section IV.O, "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 be to have the capability to complete the initial 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 State/local 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 SO.S4(f) letter.
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 letter dated February 26,2013, 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 WCGS currently has communications capabilities with offsite resource 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 many of the communications equipment described in its emergency plan can be assumed to not be available. However, certain existing onsite communications system equipment such as radio-to-radio communications would be available after implementation of planned enhancements, for some communication links listed above given a seismic, high-wind, or flooding event. The field monitoring team will have radio-to-radio and satellite communications available. The availability of these systems was determined by evaluating the equipment against seismic, flooding, and high-wind events. The final location of the equipment will be consistent with criteria contained within NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"
May 2012 (ADAMS Accession No. ML12143A232). In addition, 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 portable satellite phones and batteries. These portable satellite phones have been ordered and are available for use onsite. Existing radio-to-radio communications are available to allow for onsite communications. The satellite phones are in water- and impact-resistant cases and site communications equipment is stored in diverse locations onsite, if not stored within the control room, technical support center, or emergency operations facility. Portable radios are existing site equipment and laminated usage aids are included with each satellite phone.
-5 As the planned enhancement, the licensee is enhancing the communication links outlined in Section 4 of NEI 12-01. Satellite phones in conjunction with radios will be utilized as one of the key methods for maintaining each offsite communication link. Communications onsite will primarily utilize radio-to-radio communications 2 . These satellite telephones will be enhanced by modifications resulting from analyses to add external satellite antennas and recharging stations to the technical support center, emergency operations center, and control room. The radios will be enhanced by the evaluation of additional portable generators to be used for charging batteries and by assessing its storage under FLEX. The licensee also confirmed that communications with OROs will be maintained with portable satellite phones at these offsite locations. The licensee will put these enhancements in place in alignment with FLEX.
The NRC staff has reviewed the licensee's expected communications links within its communications assessment. In reviewing the licensee's 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 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 site radios will help ensure communications offsite and in areas of the plant due its ability for these radios to communicate without repeaters. 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 the NRC-endorsed guidance of NEI 12-01.
3,1.2 Equipment Location WCNOC has analyzed the survivability of its existing equipment for large-scale natural events by analyzing it to be protective against seismic, wind, and flooding, Enhancements to equipment protection will be made by storing eqUipment in accordance with FLEX criteria, This FLEX criterion was also used to determine ancillary equipment storage locations, including the batteries and battery chargers that will be used to support the interim measures and/or planned enhancements. The determination of final storage locations of communications equipment will be completed in alignment with FLEX (interim equipment storage locations include emergency response facilities).
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 all 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 also would be protected from seismic, flooding, and high-wind events.
2 The licensee's October 31, 2012 submittal discusses that potential improvements for the public address system, and replacement of the plant private branch exchange system with a voice over internet protocol phone system would help communications onsite. These systems would help augment communications onsite.
- 6 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 WCNOC 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 an adequate battery supply for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; (2) each satellite phone having a spare battery and the ability to charge batteries while in operation; (3) a generator to charge batteries; and (4) large amounts of fuel for the generator to charge batteries. It is expected that this equipment has power to support communications, based on assumptions for impeded site access. The licensee is planning on having these enhancements to the communication system power supplies completed in alignment with FLEX.
The NRC staff has reviewed the licensee's communications assessment power supplies. In reviewing its submittal, the NRC staff concludes that it is 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 generator fueling strategies. Additionally, the licensee's proposed enhancement is in accordance with the NRC-endorsed guidance of NEI12-01.
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 WCNOC has confirmed that it will develop protocols for the shared usage of communications capabilities in alignment with FLEX. The licensee also plans on implementing programmatic control strategies for communications equipment. These procedures will be in-place in alignment with FLEX, and includes new or modified procedures for inventory checks and maintenance. The licensee's staff will receive training on this communications equipment location and use through emergency plan drills.
Existing site procedures allow for the use of portable radios to provide for notification to plant employees if the public address system is non-functional after a large-scale natural event. The licensee also has procedures in place for emergency response organization staff self-activation due to significant natural disasters. These existing site procedures will activate the offsite emergency response organization and notify plant staff.
-7 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 NEI 12-01.
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 of NEI 12-01. 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.
3.2 Regulatory Commitments The licensee made regulatory commitments in Attachment IV of its submittal 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 licensee's regulatory commitments for determination of the acceptability of the licensee's communications assessment and the interim measures, analyzed existing systems, and proposed enhancements for the site. The regulatory commitments do not warrant the creation of regulatory requirements (items requiring prior NRC approval of subsequent changes).
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 a number of 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), the NRC staff plans to follow up with the licensee to confirm that upgrades to the site's communications systems have been completed.
Principal Contributors: R. Chang, NSIRlNRLB E. Robinson, NSIR/NRLB Date: June 3, 2013
ML13149A171 *email dated OFFICE NRRlDORULPL4/PM NSIRIDPRIDDEP/NRLB/BC NAME FLyon RChang for KWilliams*
DATE 05/30/13 5130113 5/23/13 C NRRIDORULPL4/BC NRRlDORULPL4/PM illiamson MMarkley FLyon 06/03/13 06/03/13