ND-19-0753, (VEGP) Units 3 and 4 - Emergency Preparedness Communications Assessment

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(VEGP) Units 3 and 4 - Emergency Preparedness Communications Assessment
ML19240A071
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Site: Vogtle  Southern Nuclear icon.png
Issue date: 08/16/2019
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Southern Nuclear Operating Co
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Office of New Reactors
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ND-19-0753
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Southern Nuclear Operating Company ND-19-0753 Enclosure Vogtle Electric Generating Plant(VEGP) Units 3 and 4 EMERGENCY PREPAREDNESS COMMUNICATIONS ASSESSMENT (This Enclosure consists of 39 pages, including this cover page)

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment BACKGROUND 10 CFR 50.54(p Request for Information - Near Term Task Force(NTTF)

Recommendation 9.3 - Communications Nuclear Reoulatorv Commission fNRC) Reouested Actions It is requested that addressees assess their current communications systems and equipment used during an emergency event. It is also requested that consideration be given to any enhancements that may be appropriate for the emergency plan with respect to communications requirements of 10 CFR 50.47, Appendix E to 10 CFR Part 50, and the guidance in NUREG-0696. Also, addressees are requested to consider the means necessary to power the new and existing communications equipment during a prolonged SBO.

NRC Request Assumptions The NRC requests that the following assumptions be made in preparing responses to this request for information; the potential onsite and offsite damage is a result of a large-scale external event(LSEE) resulting in a loss of all alternating current(AC) power.

In addition, assume that the LSEE causes extensive damage to normal and emergency communications systems both onsite and in the area surrounding the site. It has been recognized that following a LSEE that AC power may not be available to cellular and other communications infrastructures.

NRC Requested Information Addressees are requested to 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 LSEE meeting the conditions described above.

Assessment Methodoloov Nuclear Energy Institute (NEI) 12-01, "Guidelines for Assessing Beyond Design Basis Accident Response Staffing and Communications CapaM/f/es,"(NE112-01) provides the methodology for the preparation of assessments to determine the required staff necessary for responding to a beyond design basis external event that affects multiple units at a site, and the identification of enhancements that could provide a means to power equipment needed to communicate on-site and offsite during an extended loss of AC power event. NEI 12-01 was endorsed by the NRC in May of 2012.

Page 2 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment

SUMMARY

The specific requests, identified within the communications section of Recommendation 9.3:

Emergency Preparedness, are restated below. Southern Nuclear Company's(SNCs) Vogtle Electric Generating Plant(VEGP) Units 3 and 4 response to the requested information is provided below after each request.

VEGP Units 3 and 4 are currently under construction and utilize the Westinghouse AP1000 design (AP1000). The inherent safety features of the AP1000 are acknowledged in NRC Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"with the following statement:

The design bases of Vogtie Units 3and 4 includes passive design features that provide core, containment and SFP cooling capability for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, without reliance on alternating current(ac) power. ... The NRC staff reviewed these design features prior to issuance of the combined licenses for these facilities and certification of the AP1000 design referenced therein. The AP1000 design also includes equipment to maintain required safety functions in the long term (beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days... The staff concluded in its final safety evaluation report for the AP1000 design that the instaiied equipment(and alternatively, the use of transportable equipment) is capable of supporting extended operation of the passive safety systems to maintain required safety functions in the long term.

1. Addressees are requested to 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 meeting the conditions described above. The assessment should:
  • identify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies, VEGP Units 3 and 4 Resoonse:

No improvements have been identified to existing onsite communications systems.

Evaluation using both deterministic and Probabilistic Risk Assessment(PRA)criteria has determined that there are no critical human actions necessary for post-accident mitigation due to the predominant use of passive safety features in the AP1000 design, as described above. Therefore, there is a significantly reduced dependence on human actions following an event at VEGP Units 3 and 4, and the necessity for onsite communications between plant staff during a prolonged station blackout(SBO), prior to the availability of off-site resources, is minimized.

  • identify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies, VEGP Units 3 and 4 Response:

No improvements have been identified to existing offsite communications systems.

Page 3 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment

  • Provide a description of any new communications system(s) or technoiogies that wili be depioyed based upon the assumed conditions described above, and VEGP Units 3 and 4 Resoonse:

Sufficient satellite telephones will be procured and deployed enabling use by either unit's Main Control Room (MCR)or the Technical Support Center(ISC) until either the RAPIDCASE or RAPIDCOM systems are deployed. Two of the handheld satellite phones will be located in each MCR, and one will be maintained in the TSC. Internal batteries and external AC/DC power sources can be used to power these hand-held portable devices. However, operation of satellite phones physically within the MCR and TSC will not be assured when using the hand-held devices.

A rapidly deployable communications kit, RAPIDCASE, and a mobile communication system, RAPIDCOM, will be procured and deployed which each have the capability to supply multiple satellite phone lines within the TSC and the MCR. The RAPIDCOM system will also supply a UHFA/HF capability supporting multiple radio stations in the TSC and in each MCR.

The RAPIDCASE will be expected to be deployed within six hours from the start of the extended loss of all AC power. These units will be stored in reasonably protected locations at the Vogtle site which are expected to survive the initial LSEE. Specific locations are to be determined when allowed by the completion of construction activities.

The RAPIDCOM can be deployed within six hours after a debris path has been cleared.

  • Provide a description of how the new and/or improved systems and power supplies wiii be able to provide for communications during a loss of all AC power.

VEGP Units 3 and 4 Response:

The telephone/page system is supplied with a two-hour Uninterruptible Power Supply (UPS)and will provide for initial notifications and directions to on-site personnel, the on-shift Emergency Response Organization (ERO) personnel, and in-plant response teams for the initial period after the LSEE occurrence until AC power is restored, or alternative communications are available. In the event the telephone/page system is unavailable due to the event, a multi-faceted approach will be utilized to ensure onsite communications are maintained:

  • If site-wide announcements are unable to be made following a LSEE, personnel onsite will be trained to rally at a pre-determined position. Runners will then be sent to these locations to provide further direction to all staff.
  • On-shift Nuclear Security Officers will make rounds throughout the Owner Controlled Area while making announcements via loudspeakers to communicate direction to individuals on the site.
  • The combination of these means will be capable of notifying essentially 100% of the plant staff within approximately 30 minutes of the LSEE.

As part of the standard design, the API000 has a multiloop sound-powered system throughout the plant for refueling, startup, and maintenance testing. In limited cases, this system will be utilized for operators to communicate with the MCR to perform in-field operations.

Page 4 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Battery operated satellite phones will be maintained in a charged condition and will not be dependent on the availability of external power, nor will they rely on existing onsite or off-site terrestrial infrastructure.

The RAPIDCASE kit will be maintained in a charged condition and operation of the kit will be independent of the availability of AC power. Additionally, the kit will not rely on existing AC powered onsite or off-site communications infrastructure.

The RAPIDCOM system will be self-powered via a propane-fueled generator located on board with a dedicated 72-hour fuel supply. This system can support both satellite and radio communications if needed for the ERO, including field monitoring teams. The system does not rely on the availability of on-site or nearby off-site terrestrial infrastructure, which are assumed to be affected by the postulated LSEE.

2. Addressees are requested 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, VEGP Units 3 and 4 Response:

No interim actions are needed since VEGP Units 3 and 4 are still completing construction. Until the units are fully constructed and all Inspections, Tests, Analyses, and Acceptance Criteria(ITAAC) have been completed, there is no requirement for functional communications systems and equipment for use during an emergency event.

  • Provide an implementation schedule of the time needed to conduct and implement the results of the communications assessment.

VEGP Units 3 and 4 Response:

Since much of the VEGP Units 3 and 4 communications capabilities have not yet been constructed, completion of the equipment installation per the approved system design documents is still subject to various ITAAC which must be completed, with all Section 52.99(c)(1) ITAAC Closure Notifications submitted to NRC,to support the Commission finding that all acceptance criteria are met prior to plant operation. Examples of ITAAC related to design basis emergency communications capabilities and demonstration of their use include;

  • 486(ITAAC No. 2.3.19.02a) demonstrates the as-built configuration of the plant Communications System (EPS), including the telephone/page as well as sound-powered equipment capabilities.
  • 847(ITAAC No. E.3.9.03.00.01) demonstrates the capability for communications between the Main Control Room (MCR), Operations Support Center(OSC), TSC, Emergency Operations Facility (EOF), principal State and local emergency operations centers(EOCs), and radiological field monitoring teams as described in the VEGP Emergency Plan annexes.
  • 848(ITAAC No. E.3.9.03.00.02) demonstrates the capability for communications from the MCR,TSC, and EOF to the NRC headquarters and regional EOC as described in the VEGP Emergency Plan annexes.

Page 5 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment

  • 866(ITAAC No. E.3.9.07.01.02) Demonstrates the capability to warn and advise onsite individuals of an emergency, including; o Employees not having emergency assignments, o Visitors, o Contractor and construction personnel, and o Other persons who may be in the public access areas, on or passing through the site, or within the owner-controlled area.
  • 870(ITAAC No. E.3.9.08.01.01) Demonstrates during an Emergency Preparedness (EP)exercise the ability to notify responsible state and local government agencies within the plume exposure Emergency Planning Zone (EPZ) within 15 minutes and notify the NRC immediately after the completion of the notification to the State and local authorities and no later than 60 minutes after declaring an emergency.

Completion criteria for these ITAAC will ensure that installation and testing of the necessary communications capabilities as described in the facility design basis are completed prior to VEGP initial fuel load on each unit.

Page 6 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment The foiiowing table provides the implementation milestones and projected completion dates for the construction-related activities, as well as improvements to the communications capabilities during a LSEE identified as a result of this assessment.

Estimated Milestone Completion Date BP Gommunications Implementation Plan 1 3^^ quarter 2019 Approved 2 Develop implementation procedures 3"^^ quarter 2019 3 Procure satellite phones 4*^ quarter 2019 4 Identify staff that require training 4*^ quarter 2019 5 Complete training 2"^ quarter 2020 Complete VEGP Unit 3 Communication 6 3"^^ quarter 2020 Systems installation per Part 52 license Complete Unit 3 ITAAC communications-7 4^ quarter 2020 related items Complete VEGP Unit 4 Communication 8 1'quarter 2021 System installation per Part 52 license Complete Unit 4 ITAAC communications-9 3^'=' quarter 2021 related items 10 Letter to NRC documenting completion 4'*^ quarter 2021 Page 7 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 1 - Emergency Response Communication Systems(Current Designed Capabiiities)

Communications Systems/Equipment Aiternate methods System/Equipment Description (iDENTiFY AS APPROPRiATE) (iDENTiFY AS APPROPRiATE)

Wireless Telephone System Telephone/Page System The wireless telephone system consists of wireless portable (aka ASCOM) handsets, hands-free type portable headsets, a comprehensive PABX Telephone System antenna system, and necessary electronics equipment. The Sound-powered phones wireless telephone system is the primary means of (FSAR, Section 9.5.2.2.1)

Motorola Radios (150/450 MHz) communication for plant operations and maintenance (SNC SEP - VEGP Units 3 & 4 Annex Local Commercial Telephone personnel.

section 5.2) System Emergency Notification System The wireless telephone system has the ability to dial fixed (ENS)/Health Physics Network PABX telephone stations and vice versa. The wireless system (HPN) has the capability to access the telephone-page system and the capability to access offsite emergency communication links.

Emergency Notification Network (ENN)

Further details are not yet available as the system is still under Satellite or Cellular telephones buildout due to construction completion activities on each unit.

(Not part of Emergency Plan)

Telephone/Page System (aka Plant Wireless Telephone System The primary means for notification of personnel within the Public Address System (PA)) protected area is the public address(PA)system using by Motorola Radios (150/450 MHz) recognizable tone signals and/or verbal announcements (FSAR, Section 9.5.2.2.2) Local Commercial Telephone specific to each of the classes of emergency (Notification of System Unusual Event, Alert, Site Area Emergency, General (SNC SEP - VEGP Units 3 & 4 Annex Satellite or Cellular telephones Emergency) and fire.

section 5.2) (Not part of Emergency Plan)

Power to the telephone/page system is provided from the non-Class 1E DC and uninterruptible power supply system sized to supply power for 120 minutes after a loss of AC power.

Further details are not yet available as the system is still under buildout due to construction completion activities on each unit.

Page 8 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Private Automatic Branch Exchange Wireless Telephone System The private automatic branch exchange(PABX)system (PABX)Telephone System provides communication between the system stations, with Telephone/Page System capability for transferring calls and providing conference calls.

(FSAR, Section 9.5.2.2.3) Sound-powered phones PABX telephones are programmable. Buttons on the phone Motorola Radios(150/450 MHz) can be dedicated and color coded to specific telephone (SNO SEP - VEGP Units 3 & 4 Annex Local Commercial Telephone numbers.

section 5.2) System ENS/HPN The PABX system also interfaces with the following communication systems:

ENN

  • The wireless telephone system, Satellite or Cellular telephones (Not part of Emergency Plan)
  • Redundant connectivity to commercial telephone services to provide communication capability with the load dispatcher to support and coordinate the system,
  • Access to the telephone page system, and
  • Direct extensions from the PABX locations exterior to the plant.

All Emergency Response phones on the operating desks will be PABX phones. Business phones will be in the conference rooms and in certain locations in the TSC. These are direct commercial telephone lines provided by the local area telephone company.

The separate, redundant connections between the PABX and commercial telephone service provides communications between the main control room and the headquarters or other facilities in case of a single fault.

Power to the PABX is provided from the non-Class 1E DC and uninterruptible power supply system sized to supply power for 120 minutes after a loss of AC power.

Further details are not yet available as the system is still under buildout due to construction completion activities on each unit.

Sound-Powered Telephone System Wireless Telephone System Two unitized systems are provided for refueling and for use throughout the plant for startup and maintenance testing. The Page 9 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 1 - Emergency Response Communication Systems(Current Designed Capabilities)

Communications Systems/Equipment Alternate methods System/Equipment Description (IDENTIFY AS APPROPRIATE) (IDENTIFY AS APPROPRIATE)

(FSAR, Section 9.5.2.2.4)

  • Telephone/Page System sound-powered system does not require external power supply
  • PABX Telephone System for operation. The function of each Sound-Powered Telephone subsystem is to provide an independent, reliable
  • Motorola Radios(150/450 MHz) communications system for plant personnel. Operation of each
  • Local Commercial Telephone subsystem requires no outside power source for operation, System making it a highly dependable system which can be utilized for
  • Satellite or Cellular telephones operators to communicate with the MCR to perform in-plant (Not part of Emergency Plan) operations.

Motorola Radios(UHF - Primary and

  • Wireless Telephone System The 150/450 MHz radio system consists of several base VHP - Backup) stations and the associated cabling and antennas that will be
  • Telephone/Page System strategically located to afford the best possible coverage and (SMC SEP - VEGP Units 3 & 4 Annex
  • PABX Telephone System accessibility with respect to maintenance, security, and section 5.2)
  • Sound-powered phones uninterrupted power.
  • Satellite or Cellular telephones (Not part of Emergency Plan) Hand held radios form part of the radio system - These are small portable radios capable of one or several channels. They are battery operated and the batteries must be changed regularly to assure proper operation. Some mobile radios will be mounted in vehicles and use a 12V DC power source supplied by the vehicle's battery. These mobile radios are capable of one or several channels and have an external antenna mounted on the vehicle.

Page 10 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 1 - Emergency Response Communication Systems(Current Designed Capabiiities)

Communications Systems/Equipment Alternate methods System/Equipment Description (iDENTiFY AS APPROPRiATE) (IDENTIFY AS APPROPRiATE)

Local Commercial Telephone System

  • Wireless Telephone System Commercial telephone lines will be provided by AT&T.

Telephone lines will be provided from separate offsite offices so

  • PABX Telephone System (SNC SEP - VEGP Units 3 & 4 Annex that access onto and off site is available from two separate wire
  • ENS/HPN centers. Some commercial telephone lines will not terminate at section 5.3)
  • ENN the PABX but will bypass the switch and ring directly at a
  • Satellite or Cellular telephones telephone set. These numbers will be located in each MCR, (Not part of Emergency Plan) TSC, OSC, Security, Safety, and at specific management offices throughout the site.

Further details are not yet available as the system is still under buildout due to construction completion activities on each unit.

Business LAN (SouthernNet)

  • Telephone/Page System This system supplies networking capabilities to VEGP computers and Power over Ethernet(PoE)capabilities to
  • PABX Telephone System business Voice Over Internet Protocol (VoIP) phones and
  • Motorola Radios (150/450 MHz) Wireless Local Area Network(WLAN)access points.
  • Local Commercial Telephone System Further details are not yet available as the system is still under
  • ENS/HPN buildout due to construction completion activities on each unit.

Page 11 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 1 - Emergency Response Communication Systems(Current Designed Capabilities)

Communications Systems/Equipment Alternate methods System/Equipment Description (IDENTIFY AS APPROPRIATE) (IDENTIFY AS APPROPRIATE)

Offsite Cellular Service

  • Wireless Telephone System ERO personnel are provided with cellular telephones to be used for ERO notification and call-outs prior to and during
  • PABX Telephone System (Not part of Emergency Plan) emergencies. These phones are not expected to be used in
  • Sound-powered phones the MCR or Power Block due to possible interference with plant
  • Motorola Radios (150/450 MHz) equipment and probable loss of signal to the phone.
  • Local Commercial Telephone System
  • ENS/HPN

Emergency Notification System (ENS)

  • Wireless Telephone System Communications with the NRC will be maintained with the Emergency Notification System (ENS). Notification of NRC
  • PABX Telephone System (SNC SEP section E.2.3) headquarters in Rockville, MD and the Region II NRC office in
  • Local Commercial Telephone Atlanta, GA (during normal working hours) is accomplished via System the ENS. The ENS telephone service is provided by the Federal Telecommunications System (FTS)2001 Network.
  • Satellite or Cellular telephones Dedicated telephone equipment will be located in each Control (Not part of Emergency Plan) Room,the TSC and the EOF.

Further details are not yet available as the system is still under buildout due to construction completion activities on each unit.

Page 12 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 1 - Emergency Response Communication Systems(Current Designed Capabiiities)

Communications Systems/Equipment Alternate methods System/Equipment Description (iDENTiFY AS APPROPRiATE) (iDENTiFY AS APPROPRiATE)

NRG Health Physics Network(HPN)

  • Wireless Telephone System The HPN Is a portion of the FTS and will be located In the TSC In addition to the existing EOF location. This telephone
  • PABX Telephone System (SNC SEP section E.2.3) network Is used to exchange radiological and dose assessment
  • Local Commercial Telephone Information between NRC facilities and VEGP. Data can be System transmitted to the NRC verbally using one of the alternate
  • Satellite or Cellular telephones methods Identified.

(Not part of Emergency Plan)

Further details are not yet available as the system Is still under bulldout due to construction completion activities on each unit.

Emergency Response Data System

  • PABX Telephone System 4). This system will retrieve Information from the Enterprise (SNC SEP section E.2.3)
  • Local Commercial Telephone Data Server(EDS)and provide selected plant data to the System NRCs Operations Center In Rockvllle, Maryland for evaluating
  • Satellite or Cellular telephones plant conditions.

(Not part of Emergency Plan)

Data can be manually acquired and transmitted to the NRC verbally using one of the alternate methods Identified.

Further details are not yet available as the system Is still under bulldout due to construction completion activities on each unit.

Page 13 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 1 - Emergency Response Communication Systems(Current Designed Capabiiities)

Communications Systems/Equipment Aiternate methods System/Equipment Description (iOENTiFY AS APPROPRiATE) (iOENTIFY AS APPROPRiATE)

Emergency Recall System (ERG Wireless Telephone System The Emergency Recall System is a commercially provided Notification System) system consisting of a computer controlled automatic dialing PABX Telephone System system. The Emergency Recall System's facilities are located Local Commercial Telephone greater than 25 miles from the plant site and provide System geographically diverse call center locations and back-up ENS/HPN capability.

Satellite or Cellular telephones (Not part of Emergency Plan) Once activated, the system initiates notification to ERG personnel via voice, text messaging, and email to all devices registered for the individual ERG member (e.g., phone, pager, smart phone, etc.). This method will reach ERG members outside the 25-mile zone as well as a portion of the ERG with notification coverage (device dependent) near the fringes of the 25-mile zone. Additional ERG members will be notified as communications infrastructure is returned to service through the affected area.

Emergency Notification Network(ENN) Wireless Telephone System The ENN is a multiparty dedicated telephone system from VEGP to state, county, and Savannah River Site (SRS)

PABX Telephone System (SNC SEP section E.2.2 and VEGP authorities. Gperation will be accomplished by dialing a two-Units 3 & 4 Annex section 5.3) Local Commercial Telephone digit calling code to call all stations or individual stations. Each System telephone will have a speaker and telephone handset at each ENS/HPN location. The ENN is used for initial notification, changes in Satellite or Cellular telephones classification level and updates on status. The ENN will also (Not part of Emergency Plan) be used by SRS to notify states and counties of an SRS emergency.

Further details are not yet available as the system is still under buildout due to construction completion activities on each unit.

Page 14 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 1 - Emergency Response Communication Systems(Current Designed Capabilities)

Communications Systems/Equipment Alternate methods System/Equipment Description (IDENTIFY AS APPROPRIATE) (IDENTIFY AS APPROPRIATE)

Handheld Satellite Telephones

  • Wireless Telephone System Handheld satellite phones will be procured. Location specific data is not available until the completion of plant construction
  • Local Commercial Telephone System
  • ENS/HPN

RAPIDCASE

  • Handheld satellite phone (Not A rapidly deployable case that will be procured capable of part of Emergency Plan) providing a battery-powered satellite telephone system (Not part of Emergency Plan) supplying multiple phones to the TSC and MCR of each unit.

RAPIDCOM

  • Handheld satellite phone (Not A rapidly deployable, self-contained, and generator-powered part of Emergency Plan) satellite communications uplink station and UHFA/HF capability (Not part of Emergency Plan) will be procured. This unit will be stored in a protected and survivable area.

Once deployed, the RAPIDCOM will support multiple telephone lines to the TSC and MCR of each unit. It will also supply several UHFA/HF radio stations in the TSC and each MCR to allow radio communications directly between each facility.

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ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 2- Equipment Locations(Current Configuration)

Equipment protected from the below hazards Primary System Protected from Protected from Protected from System/Equipment Component Seismic as Flooding as Wind as defined in Comments Location(s) defined in this defined in this this document document document This system has yet to be fully deployed as the system is still under buildout due to Wireless Telephone Room B-119 of construction completion System BIdg. 305, and in activities on each unit.

No Yes No Room 40316 of (aka ASCOM) each unit Run time on the UPS supporting the controllers in high availability mode is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

This system has yet to be fully deployed as the system is still under buildout due to Telephone/Page Room B-103 of construction completion System BIdg. 305, and activities on each unit.

No Yes No Room 40317 and (aka Plant Public 20513 of each unit. Run time on the UPS supporting Address System (PA))

the controllers in high availability mode is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

This system has yet to be fully deployed as the system is still under buildout due to Room B-103 of Private Automatic construction completion BIdg. 305, and Branch Exchange activities on each unit.

Room 40317 of the No Yes No (PABX)Telephone Annex Building of System Run time on the UPS supporting Unit 3.

the controllers in high availability mode is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Page 16 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 2- Equipment Locations(Current Configuration)

Equipment protected from the beiow hazards Primary System Protected from Protected from Protected from System/Eq uipment Component Seismic as Fiooding as Wind as defined in Comments Location(s) defined in this defined in this this document document document This system has yet to be fully deployed as the system is still Sound-Powered Power blocks of under buildout due to Yes Yes Yes Telephone System each unit construction completion activities on each unit.

  • Handheld radios in line-of sight/talk-around mode are Motorola Radios(UHF - reasonably protected from Rooms 20513 and Primary and VHP - No* Yes* No* seismic, wind, and flooding 40317 of each unit Backup) events depending on usage location at the start of the event.

Commercial system not Local Commercial available per assessment 147B Fiber Hut No No No Telephone System assumptions.

This system has yet to be fully deployed as the system is still Business LAN Distributed under buildout due to No Yes No (SouthernNet) throughout facility construction completion activities on each unit.

Commercial system not SouthernLinc Plant Wilson Line available per assessment (Not part of Emergency No No No site assumptions.

Plan)

Page 17 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 2- Equipment Locations(Current Configuration)

Equipment protected from the beiow hazards Primary System Protected from Protected from Protected from System/Equipment Component Seismic as Fiooding as Wind as defined in Comments Location(s) defined in this defined in this this document document document Commercial system not Offsite Cellular Service Offsite, varies available per assessment (Not part of Emergency No No No based on carrier assumptions.

Plan)

This system has yet to be fully deployed as the system is still Emergency Notification Rooms 40136 and under buildout due to No No No System (ENS) 40137 of each unit. construction completion activities on each unit.

This system has yet to be fully deployed as the system is still NRC Health Physics Rooms 40136 and under buildout due to No No No Network(HPN) 40137 of each unit. construction completion activities on each unit.

This system has yet to be fully deployed as the system is still Emergency Response Rooms 40136 and under buildout due to No Yes No Data System (ERDS) 40137 of each unit. construction completion activities on each unit.

Vendor maintains facilities >25 miles VEGP may access this service Emergency Recall from VEGP and by means of a satellite phone, System (ERO facilities are Yes Yes Yes however, devices assigned to Notification System) assumed to be receive notification may be unaffected by the located within 25 miles of VEGP.

LSEE.

Page 18 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 2- Equipment Locations(Current Configuration)

Equipment protected from the beiow hazards Primary System Protected from Protected from Protected from System/Equi pment Component Seismic as Flooding as Wind as defined in Comments Location(s) defined in this defined in this this document document document This system has yet to be fully deployed as the system is still Emergency Notification No under buildout due to EP Tower No Yes Network(ENN) construction completion activities on each unit.

Devices will be stored in a location, and maintained in a manner, that maximizes Handheld Satellite Yes - when Yes - when Yes - when survivability following a LSEE.

Telephones(Not part of deployed as deployed as deployed as In particular, the location MGR and TSC Emergency Plan) planned. planned. planned. selected will provide reasonable protection from seismic, wind, and flooding events.

Devices will be stored in a location, and maintained in a manner, that maximizes Yes - when Yes - when Yes - when survivability following a LSEE.

RAPIDCASE (Not part TBD deployed as deployed as deployed as In particular, the location of Emergency Plan) planned. planned. planned. selected will provide reasonable protection from seismic, wind, and flooding events.

Page 19 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 2- Equipment Locations(Current Configuration)

Equipment protected from the below hazards Primary System Protected from Protected from Protected from System/Equipment Component Seismic as Flooding as Wind as defined in Comments Location(s) defined in this defined in this this document document document Devices will be stored in a location, and maintained in a manner, that maximizes Yes - when Yes - when Yes - when survivability following a LSEE.

RAPIDCOM (Not part of TBD deployed as deployed as deployed as In particular, the location Emergency Plan) planned. planned. planned. selected will provide reasonable protection from seismic, wind, and flooding events.

Page 20 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 3- Equipment Power Source(s)

Backup power Primary Power avaiiabiiity (e.g., Comments Aiternate Power Supply System/Equipment Suppiy (List the batteries, portable Will interim actions be taken to (List the power source) power source) generators, etc.) enhance the power supplies?

Yes/No Wireless Telephone System Non-Class IE 120 VAC N/A Yes No (aka ASCOM)

Telephone/Page System (aka Plant 2 Hour uninterruptible Non-Class 1E DC Yes No Public Address System power supply(UPS)

(PA))

Private Automatic Branch Exchange 2 Hour uninterruptible Non-Class 1E DC Yes No (PABX)Telephone power supply(UPS)

System No power supply Sound-Powered required N/A No No Telephone System Motorola Radios(UHF -

Security power supply 2 Hour uninterruptible Primary and VHP - Yes No system power supply(UPS)

Backup)

Local Commercial 2 Hour uninterruptible Non-Class 1E DC No No Telephone System power supply(UPS)

Business LAN Non-Class IE 120 VAC None No No (SouthernNet)

Page 21 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 3- Equipment Power Source(s)

Backup power Primary Power avaiiabiiity (e.g., Comments Alternate Power Suppiy System/Equipment Suppiy (List the batteries, portable Will interim actions be taken to (List the power source) power source) generators, etc.) enhance the power supplies?

Yes/No The Plant Wilson site has Off-site power to Plant a UPS with an expected 8-SouthernLinc Wilson SouthernLinc hour runtime following a Yes No site. loss of power.

Not applicable, offsite Not applicable, offsite Not applicable, offsite system provided by Offsite Cellular Service system provided by system provided by No cellular service.

cellular service. cellular service.

Emergency Notification Not applicable, local Not applicable, local Not applicable, local No System (ENS) telephone provider telephone provider telephone provider NRC Health Physics Not applicable, local Not applicable, local Not applicable, local No Network(HPN) telephone provider telephone provider telephone provider Emergency Response 2 Hour uninterruptible Non-Class 1E DC No No Data System (ERDS) power supply(UPS)

No Emergency Recall Not applicable, service System (ERO provided by offsite N/A N/A Notification System) supplier.

Non-Class 1E DC and Emergency Notification uninterruptible power Non-Class 1E 120 VAC Yes No Network(ENN) supply system (2-hour UPS)

Handheld Satellite Spare battery or 12 VDC Yes Built-in battery adapter No Telephones Page 22 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Section 3- Equipment Power Source(s)

Backup power Primary Power availability (e.g., Comments Alternate Power Supply System/Equipment Supply (List the batteries, portable Will Interim actions be taken to (List the power source) power source) generators, etc.) enhance the power supplies?

Yes/No Yes Each RAPIDCASE will be outfitted with a larger battery to allow standalone power from its initial setup. Before this power supply is depleted, a small propane-powered generator will be connected to RAPIDCASE Built-in battery No No the system by on-shift personnel to extend the power supply. This generator will be small enough to be carried from its reasonably protected onsite storage location to the RAPIDCASE by on-shift personnel.

Onboard generator RAPIDCOM with 72-hour fuel None No No supply Page 23 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment 4.0 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.1 REQUIRED EMERGENCY COMMUNICATIONS CAPABILITIES 4.1.1 Notifications to, and communications with, Offsite Response Organizations(OROs)[per 10 CFR 50 Appendix E.IV.D and E.Q.a]

Emergency Minimum Primary Primary Backup Backup Pianned or Refer to Response Communications Method Method Method(s) Method(s) Potentiai Foiiowing Facility Links Described in Availabie Described in Avaiiable improvement Section for E-Pian foiiowing E-Pian foiiowing identified? Additionai Large Scaie LSEE? information Externai Event (LSEE)?

1 per Control Room Emergency PABX or See Note 1 for Main Control for Shift ENN Notification commercial No Limited Yes additional Room (MCR) Communicator Network telephone information (ENN) lines Technical Under the SNC Standard Emergency Plan, notifications to and communications with OROs passes from the MCR directly to the Support EOF. Therefore, this capability is not applicable to the TSC for SNC plants.

Center(TSC)

Emergency PABX or Emergency See Note 2for 1 for Key EOF Notification commercial Operations Yes Yes No additional Communicator Network telephone Facility(EOF) information (ENN) lines Page 24 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment 4.1.2 Notifications to, and communications with, the NRG Headquarters Incident Response Center and the appropriate NRC Regional Office Operations Center[per 10 CFR 50 Appendix E.IV.D and E.9.d\

Emergency Minimum Primary Primary Method Backup Backup Planned or Refer to Response Communications Method Avaiiabie Method(s) Method(s) Potential Following Facility Links Described in following Described in Avaiiabie improvement Section for E-Pian LSEE? E-Pian following identified? Additional LSEE? information PABX or 1 per Control Room See Note 3for Main Control commercial for ENS FTS ENS line No No Yes additional Room (MCR) telephone Communicator information lines PABX or Technical See Note 3for 1 for ENS commercial Support FTS ENS line No No Yes additional Communicator telephone Center(ISC) information lines PABX or Emergency See Note 2for 1 for ENS commercial Operations FTS ENS line Yes Yes No additional Communicator telephone Facility(EOF) information lines PABX or Technical See Note 3for 1 for HPN commercial Support FTS HPN line No No Yes additional Communicator telephone Center(TSC) information lines PABX or Emergency See Note 2for 1 for HPN commercial Operations FTS HPN line Yes Yes No additional Communicator telephone Facility(EOF) information lines Page 25 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment 4.1.3 Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E.9.C. Addltlonalllnks that support performance of critical response functions are also specified.] The minimum communications links to support this function are listed below by facility. For example, if the normally used telephone system cannot be restored to service, these links could rely upon some combination of radio, sound-powered and satellite-based communications systems.

Emergency Minimum Primary Primary Backup Backup Planned or Refer to Response Communications Method Method Method(s) Method(s) Potential Following Facility Links Described in Available Described in Available improvement Section for E-Pian following E-Pian following LSEE? identified? Additional LSEE? information No (line-of sight/talk-Dedicated See Notes 4 and Control Room 1 per unit around mode will PABX No Two-way radio Yes 5 for additional not be available telephone lines information to users inside the power block)

Technical Support 1 each for:

Center(TSC)

  • Senior/Lead TSC Manager
  • Operations Coordination
  • Maintenance Coordination
  • Engineering Coordination Yes Dedicated See Notes 4 and
  • Radiological (line-of sight/talk-Support PABX No Two-way radio Yes 5 for additional around mode vs.

telephone lines information repeater)

Additional response coordination links for multi-unit sites:

  • 1 for each position providing Unit

Response

Coordination.

Page 26 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Emergency Minimum Primary Primary Backup Backup Pianned or Refer to Response Communications Method Method Method(s) Method(s) Potentiai Foiiowing Facility Links Described in Avaiiabie Described in Avaiiabie improvement Section for E-Pian foilowing E-Plan foiiowing LSEE? identified? Additional LSEE? Information Operational 1 each for:

Support Center

  • Radiological Support Dedicated Yes Additional response See Notes 4 and PABX Two-way (line-of sight/talk-coordination links for No Yes 5 for additional telephone radio around mode vs.

multi-unit sites: information lines repeater)

  • 1 for each position providing Unit In-PlantTeam Coordination.

Emergency 1 each for:

Operations

  • Senior/Lead Facility(EOF) Manager
  • Key Protective Measures
  • Operations or No Technical Support Dedicated (site No See Notes 2 and (as needed to EOF PBX Two-way dedicated (site transmitter Yes 6 for additional support telephone radio lines unavailable) information performance of lines unavailable) dose projections, formulation of PARs and plant status updates to ORO authorities).

Local See Note 7 for Joint Information Cellular 1 for Senior Manager commercial No No Yes additional Center (JIC) telephone telephone line information Page 27 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment 4.1.4 Communications with field/offsite monitoring teams[per 10 CFR 50 Appendix E.9.c]

Emergency Minimum Primary Primary Backup Backup Planned or Refer to Response Communications Method Method Method(s) Method(s) Potential Following Facility Links Described in Availabie Described in Available Improvement Section for site E-Plan following site E-Plan following Identified? Additional LSEE? LSEE? Information Primary location No-where field/offsite (transmitter monitoring team unavailable Field/offsite See Note 8 for coordination is Field team and limited Alternate radio monitoring team No Yes additional performed (EOF) radios range for line- channels coordination information of sight/talk-around mode)

Primary location No-from which field/ (transmitter offsite monitoring unavailable 1 for each See Note 8 for teams are Field team and limited Alternate radio field/offsite No Yes additional deployed (OSC) radios range for line- channels monitoring team information of sight/talk-around mode)

Page 28 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment 4.1.5 Communications with other Federal agencies as described in the site emergency plan (e.g., the US Coast Guard)[per 10 CFR 50 Appendix E.9.b]

Emergency Minimum Primary Primary Backup Backup Planned or Refer to Response Communications Method Method Method(s) Method(s) Potential Following Facility Links Described in Avaiiabie Described in Avaiiabie improvement Section for E-Pian following E-Pian following Identified? Additional LSEE? LSEE? Information Primary location where Dedicated See Notes 1, 2, communication Dedicated EOF Coordination with PABX No 5, and 9 for with Federal PBX telephone Yes(EOF) Yes Federal agencies telephone additional agencies is lines lines information performed (TSC) 4.1.6 Coordination and direction of on-site and in-plant response teams. This includes teams necessary to affect emergency repairs, firefighting, search and rescue, radiological monitoring, and implementation of Transition Phase coping and severe accident management strategies.

Emergency Minimum Communications Primary Primary Backup Backup Planned or Refer to Response Links Method Method Method(s) Method(s) Potential Following Facility Described Avaiiabie Described Avaiiabie improvement Section for in E-Pian following in E-Pian following LSEE? identified? Additional LSEE? information On-shift staff Number necessary for the Wireless Yes, limited Telephone/Page Yes, limited by 2- Yes See Note on-shift staff to perform Initial Telephone by 2-hour System hour UPS 10 for Phase coping actions System UPS additional (reflecting current staff & PABX Yes, limited by 2- information strategies) Telephone hour UPS System Motorola Radios Yes, line-of sight /

(150/450 MHz) talk-around mode Sound-powered Yes phones Page 29 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Operational 1 each for: Wireless Yes, limited Telephone/Page Yes, limited by 2- Yes See Notes Support

  • On-site radiological Telephone by 2-hour System hour UPS 11 and 12 Center monitoring System UPS for (OSC)and 2 each for: PABX Yes, limited by 2- additional other site-
  • Firefighting (1 for Telephone hour UPS information; specific brigade leader and 1 System locations as for the brigade) necessary 2 each per unit for: Motorola Radios Yes, line-of sight /
  • In-plant radiological (150/450 MHz) talk-around mode monitoring
  • Search and Rescue Sound-powered Yes
  • Emergency repairs phones
  • Site-specific number needed to implement any 2 severe accident mitigation strategies 4.2 Plant Paging (Announcement)System Refer to Emergency Minimum Following is this system available Planned or Potential improvement Response Communications Section for following LSEE? identified?

Facility Links Additional Information See assumptions See Notes 12 and Site-wide and discussion in No No 13 for additional NEI 12-01. information 4.3 Communications at ORO Facilities Page 30 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Emergency Minimum Primary Primary Method Backup Backup Planned or Refer to Response Communications Method Avaiiabie Method(s) Method(s) Potential Following Facility Links Described in following Described in Avaiiabie Improvement Section for site E-Pian LSEE? site E-Plan following Identified? Additional LSEE? information Location where At least one. See Emergency Only available to Commercial Only available to No See Note 14 OROs receive assumptions and Notification GA (Atlanta) and telephone GA (Atlanta) and for additional notifications of an discussion in NEI Network SO (Columbia) lines and SC (Columbia) information emergency 12-01. (ENN) state EOCs South state EOCs declaration or a telephones located outside Carolina located outside Protective Action 25 miles. Emergency 25 miles.

Recommendation All county EOC's Management All county EOC's (as described in (Allandale, Division (Allandale, the Emergency Aiken, Barnwell, Radio Aiken, Barnwell, Plan) Burke), the GA Burke), the GA Fon/vard EOC Forward EOC (Waynesboro) (Waynesboro) and Savannah and Savannah River Site are River Site are within 25 miles. within 25 miles.

Page 31 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Notes for Section 4 Assessment of Required Emergency Communications Capabilities Note 1: Satellite telephones (handheld and RAPI DOOM/RAPIDCASE) will be procured and deployed to provide a means of off-site communications with OROs during a LSEE.

Note 2; Normal and backup communication systems will be available at the EOF, since it is located outside the 25-mile affected zone near Birmingham, AL.

Note 3; Reasonable protection is not assured due to location of key phone network components. Satellite telephones (handheld and RAPIDCOM/RAPIDCASE) will be procured and deployed to provide a means of off-site communications with NRG during a LSEE.

Note 4: Line-of sight / talk-around mode radio use is limited to users outside the reinforced concrete power block structures of each unit.

Note 5: A rapidly deployable communications kit, RAPIDCASE, and a mobile communication system, RAPIDCOM, will be procured and deployed which each have the capability to supply multiple satellite phone lines within the TSC and the MGR. The RAPIDGOM system will also supply a UHFA/HF capability supporting multiple radio stations in the TSG and in each MGR.

Note 6: Due to potential damage onsite at VEGP,the EOF's capability to communicate with site ERO personnel would be limited to those site responders equipped with satellite telephones.

Note 7: The VEGP JIG is located in Waynesboro, Georgia adjacent to the Georgia Power Gompany operating headquarters. This location is within the assumed 25-mile effected zone (approximately 14 miles from VEGP)and is assumed to not have normal or backup power available for this scenario.

Note 8: The power source to the primary method, field team radio transmitter won't be available during a LSEE after depletion of the UPS with limited (2-hour) run time. Once deployed, the RAPIDGOM system will supply a UHFA/HF capability supporting multiple radio stations, including the radios used by the field monitoring teams. Normal communications will be available at the EOF since it is located outside the 25-mile effected zone.

Note 9: The backup method is for responders in the EOF to assume this responsibility.

Note 10: In plant communications will be available for a limited period of time(2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />)following an LSEE. The telephone/page, PABX telephone, and sound-powered communication systems serve as a backup to the wireless system, but telephone/page and Page 32 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Notes for Section 4 Assessment of Required Emergency Communications Capabiiities PABX telephones may not be available since reasonable protection is not assured in some scenarios due to location of key network components. Satellite telephones (handheld and RAPIDCOM/RAPIDCASE) will be procured and deployed to provide an alternate means of on-site communications during LSEE. The RAPIDCOM system is also capable of supplying a UHFA/HF radio capability supporting multiple stations in the JSC and in each MGR.

Note 11; In plant communications will be available for a limited period of time (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />)following an LSEE. The telephone/page, PABX telephone, and sound-powered communication systems serve as a backup to the wireless system, but telephone/page and PABX telephones may not be available since reasonable protection is not assured in some scenarios due to location of key phone network components. Battery-powered handheld radios will be available for use by onsite personnel in the line-of sight/talk-around mode only.

Note 12: Evaluation using both deterministic and PRA criteria has determined that there are no critical human actions necessary for post-accident mitigation due to the predominant use of passive safety features in the API000 design. Therefore, there is a significantly reduced dependence on human actions following an event at VEGP Units 3 and 4, and the necessity for onsite communications between plant staff during a prolonged SBO, prior to the availability of off-site resources, is minimized.

Note 13: The telephone/page system primary system components are located in Room B-103 of BIdg. 305 and Room 40317 of each unit. This area does not supply "reasonable protection" to ensure system availability in some scenarios. The battery backup capability has a limited 2-hour run time, but this will provide ample time for the initial emergency declaration and direction announcements to the plant staff. A supplemental method to the telephone/page system capability for emergency notification to the plant staff will be developed to support emergency notification to essentially 100% of plant staff within 30 minutes.

Note 14: Offsite notifications are normally received by state and county designated offsite agencies from the MGR and EOF using the ENN. The only ORO locations where either of these methods would be available is the state EGG's in GA (Atlanta) and SG (Golumbia). All other ORO locations described in the Emergency Plan are within 25 miles, where power and communications systems are assumed to be unavailable.

Page 33 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment GENERIC TECHNICAL ISSUES On January 23, 2013, the NRG Staff issued a letter to all power reactor licensees and holders of construction permits in active or deferred status. The enclosure to that letter identified eight generic technical issues needing resolution to determine a licensee's communications capability regarding a SBO event. The following section specifically addresses each of these eight generic technical issues.

Generic Technical Issue 1 The staff identified that licensees need to discuss how the power for the equipment analyzed is expected to be available, and how the planned communications enhancements are expected to be maintained. The following areas were identified; A. A detailed description of how power will be maintained for(1) planned or potential enhancements to the communication links and (2) existing equipment analyzed to be available.

1. The number of replacement batteries expected to be needed for a 24-hour duration, per the Nuclear Energy Institute (NEI) 12-01 "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities".
2. Generator availability to charge batteries without offsite equipment for a duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3. A description of how ancillary equipment supports operations for a 24-hour duration (e.g., adequacy of fuel supplies for the generators; and the minimum number of battery chargers expected to be necessary).

VEGP Units 3 and 4 Response:

  • Handheld Satellite Telephones o Four batteries for each hand-held satellite phone will be maintained in a charged state. Each battery has an 8-hour capacity for a total battery capacity of 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> for each phone.

o . Satellite telephones can also be powered from 12-volt DC car adapters, if needed, o In addition, small man-portable propane generators will be procured and deployed as necessary to recharge batteries during a LSEE.

  • RAPIDCASE o The RAPIDCASE system contains a battery capable of providing an initial 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of power.

o Before this power supply is depleted, a small propane-powered generator will be connected to the system by on-shift personnel to extend the power supply. This generator will be small enough to be carried from its designated storage location to the RAPIDCASE by on-shift personnel, o Beyond the initial fuel load for these generators, VEGP Units 3 and 4 will either transfer communications capability to the RAPIDCOM trailer or refuel the portable generator indefinitely per a validated refueling plan.

  • RAPIDCOM o The RAPIDCOM system is equipped with an onboard 20-minute battery power supply to support initial startup.

Page 34 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment o Once deployed, the RAPIDCOM is self-powered by one of two 100% capacity generators located on board the mobile unit. The generators are powered by propane with sufficient fuel on board to last greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Inventory checks of all FLEX communications equipment, including spare batteries, is performed on a 6-month frequency. The following PMs will be revised as necessary to include the beyond-design-basis(BOB)communications equipment credited at VEGP Units 3 and 4 during a LSEE.

  • PM A2800R5079, Perform FLEX Inventory(FSB)
  • PM A2800R5080, Perform FLEX Inventory (Protected Area)

Generic Technical Issue 2 The use and function of the planned enhancements for the improvement of communications.

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

1. A discussion of whether each planned enhancement identified is only to be used for maintaining the communication link identified, or if it is expected to be shared among other communication links.
2. A general description of the planned enhancement and how the equipment will be integrated.
3. The title and general description of the procedure that will be developed and used by plant personnel to describe protocols for shared usage of communication capabilities.

VEGP Units 3 and 4 Response:

Section 4.0 of this Communications Assessment assesses the required emergency communications capabilities during a LSEE and provides a general description of the planned enhancements for the improvement of communications at VEGP Units 3 and 4. A summary of these planned enhancements is provided below:

  • Satellite Telephones o Sufficient satellite telephones will be procured and deployed enabling use by either unit's MCR or the TSC until either the RAPIDCASE or RAPIDCOM systems are deployed. Two of the handheld satellite phones will be located in each MCR, and one will be maintained in the TSC. Internal batteries and external AC/DC sources can be used to power these hand-held portable devices. However, operation of satellite phones physically within the MCR and TSC will not be available using the hand-held devices.

o A rapidly deployable communications kit, RAPIDCASE, and a mobile communication system, RAPIDCOM, will be procured and deployed which each have the capability to supply multiple satellite phone lines within the TSC and the MCR. The RAPIDCOM system will also supply a UHFA/HF capability supporting multiple radio stations in the TSC and in each MCR.

o The IRAPIDCASE will be expected to be deployed within six hours from the start of the extended loss of all AC power. These units will be stored in reasonably protected locations in both Units 3 and 4 which are expected to survive the initial LSEE. Specific locations are to be determined when allowed by the completion of construction activities.

Page 35 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment o The RAPIDCOM can be deployed within six hours after a debris path has been cleared.

  • Radios o Following a LSEE, the primary method for communicating by means of the site radio system will be in line-of-sight/talk-around mode. This mode would be available to communicate primarily outdoors by plant staff and operators; and to a limited degree, inside plant buildings.

o A mobile communication system, RAPIDCOM, will be procured and deployed which will supply a UHFA/HF capability supporting multiple radio stations in the TSC and in each MCR. The RAPIDCOM can be deployed within six hours after a debris path has been cleared.

  • Telephone/Page System o The telephone/page system is supplied with a two-hour Uninterruptible Power Supply (UPS)and will provide for initial notifications and directions to on-site personnel, the on-shift ERO personnel, and in-plant response teams for the initial period after the LSEE occurrence until AC power is restored, or alternative communications are available.

o In the event the telephone/page system is unavailable due to the event, a multi-faceted approach will be utilized to ensure onsite communications are maintained; If site-wide announcements are unable to be made following a LSEE, personnel onsite will be trained to rally at a pre-determined position. Runners will then be sent to these locations to provide further direction to all staff.

On-shift Nuclear Security Officers will make rounds throughout the Owner Controlled Area while making announcements via loudspeakers to communicate direction to individuals on the site.

The combination of these means will be capable of notifying essentially 100% of the plant staff within approximately 30 minutes of the LSEE.

VEGP Units 3 and 4 will revise the existing SMC procedure NMP-OS-019-369, Vogtle Unit C SIG-9, "Communications," describing the storage and use of site communications equipment available during the response to a LSEE. This procedure will describe the storage locations, storage requirements, and deployment steps necessary for equipment needed to support emergency communications at VEGP Units 3 and 4 following an event resulting in an extended loss of AC power and loss of normal on-site and off-site communications capabilities.

After the FLEX strategies have been developed, VEGP will review the strategies to ensure sufficient communications equipment is available and integrated to implement the strategies.

If necessary, integration of the planned enhancements will occur through the implementation of a formal change management process incorporating procedure development, training, equipment testing, implementation, and demonstration.

Generic Technical Issue 3 The protection of the new equipment purchased as a planned enhancement as well as the protection of existing communications equipment analyzed as being available.

Page 36 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment A. A discussion of how the existing equipment analyzed to be available and enhancements to these communication iinks as well as associated ancillary equipment will be stored in a manner that is protective from a iarge scaie natural event.

1. A description of pre-identified areas that are considered protective for existing equipment and whether new equipment will be stored in a similar location. The title and brief description of a procedure for new communications equipment storage is acceptable if this procedure is planned to be developed in the future; or a statement that this will be completed in alignment with NRG order EA-12-049.
2. Equipment stored offsite, should have an analysis of duration to set-up this equipment for use.
3. The analysis demonstrates that the existing equipment that is expected to be availabie wili be functional.

VEGP Units 3 and 4 Response:

VEGP Units 3 and 4 will revise existing procedure 91204-C,"Emergency Response Communications," which provides for periodic communications equipment inventory and operational checks for that equipment identified in the SNC SEP - VEGP Units 3 and 4 Annex.

VEGP will store portable communications equipment (e.g., handheld radios, satellite phones, RAPIDCASE/RAPIDCOM, and portable propane generators to recharge batteries) either in the MCRs, TSC, or other onsite locations that meets the requirements of NRC Order 12-049.

SNC has no pians to store any emergency communications equipment offsite.

Generic Technical Issue 4 The programmatic controis for the use of the new equipment purchased as a pianned enhancement.

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

1. A description of any credited manuai actions and their procedures.
2. A description of any maintenance for this equipment, inciuding operability testing,
3. A description of any periodic inventory checks.
4. A description of planned staff training.

VEGP Units 3 and 4 Response:

VEGP Units 3 and 4 will revise the existing SNC procedure NMP-OS-019-369, Vogtle Unit C SIG-9,"Communications," describing the storage and use of site communications equipment avaiiable during the response to a LSEE. This procedure will describe the storage locations, storage requirements, and depioyment steps necessary for equipment needed to support emergency communications at VEGP Units 3 and 4 following an event resulting in an extended loss of AC power and loss of normal on-site and off-site communications capabilities.

Inventory checks of all FLEX equipment, including the communications equipment is performed on a 6-month frequency. The foilowing PMs wili be revised as necessary to include the BDB communications equipment credited at VEGP Units 3 and 4 during a LSEE.

Page 37 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment

  • PM A2800R5079, Perform FLEX Inventory(FSB)
  • PM A2800R5080, Perform FLEX Inventory (Protected Area)

Current Lesson Plan V-IC-PP-07010, l&C FLEX Equipment Set-up will be revised as necessary to include VEGP Unit 3 and 4 BDB communications equipment. Training will be updated and presented for l&C technicians once the VEGP Unit 3 and 4 equipment is procured and deployed on the site.

Generic Technical Issue 5 A discussion on what assumptions are used as part of the Communications Assessment.

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

VEGP Units 3 and 4 Response; The assessment did not deviate from the assumptions within NE112-01.

Generic Technical issue 6 How plant personnel will be notified in the event of a large scale natural event that causes a loss of all AC power.

A. A description and title of the procedure for emergency notification of essentially all plant staff within 30 minutes [If applicable to the licensee Emergency Plan].

B. A description and title of the procedure for notification of emergency response organization staff (i.e., self-activation)[If applicable].

VEGP Units 3 and 4 Response:

SNC common procedure NMP-EP-142,"Emergency Notification," currently provides fleet-wide guidance on the performance of emergency notifications to on-shift personnel, the ERO, offsite authorities (State, local. Federal) and the public for declared emergencies. This procedure will be revised to include applicability to and specific guidance as needed for VEGP Units 3 and 4.

Generic Technical Issue 7 How communications will be maintained during the period of final implementation of the communication enhancements.

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

VEGP Units 3 and 4 Response:

No interim actions are needed since VEGP Units 3 and 4 are still completing construction.

Until the units are fully constructed and all ITAAC have been completed, there is no requirement for functional communications systems and equipment for use during an emergency event.

Generic Technical issue 8 Page 38 of 39

ND-19-0753 Enclosure Emergency Preparedness Communications Assessment Descriptions are needed regarding how communications will be maintained with the on-site and in-plant response teams and offsite response organizations if their communication links are not expected to be available.

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

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

VEGP Units 3 and 4 Response:

An evaluation using both deterministic and PRA criteria has determined that there are no critical human actions necessary for post-accident mitigation due to the predominant use of passive safety features in the AP1000 design. Therefore, there is a significantly reduced dependence on human actions following an event at VEGP Units 3 and 4, and the necessity for onsite communications between plant staff during a prolonged SBO, prior to the availability of off-site resources, is minimized.

Onsite communications using the communication system (EPS) will be available for a limited period of time (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />)following most scenarios of a LSEE. In the event that the EPS may not be available since reasonable protection is not assured in some scenarios due to location of key network components, satellite telephones (handheld, RAPIDCOM, and RAPIDCASE) will be procured and deployed to provide an alternate means of onsite communications. The RAPIDCOM system is also capable of supplying a UHPA/HP radio capability supporting multiple stations in the TSC and in each MGR. VEGP will primarily use the handheld radios and satellite phones, as well as the RAPIDCASE and RAPIDCOM systems to perform critical communications during and following an event that results in an extended loss of AC power.

VEGP will also use the Sound-Powered Telephone System for specific uses inside the power block of each unit if necessary. These phones do not rely on an electrical power supply and will be available for the entire period of post event activities.

The plant telephone/page system is equipped with battery backup and in most scenarios would remain available to provide the initial emergency declaration and direction announcement to the plant staff. In the unlikely event the telephone/page system is not available, a supplemental method for providing emergency notification to the plant staff will be developed to support emergency notification of essentially 100% of onsite plant staff within 30 minutes.

Several ITAAC specifically related to emergency communications capabilities and demonstration of their use exist which must be completed to support the Commission finding that all acceptance criteria are met prior to plant operation. Completion criteria for these ITAAC will ensure that installation and testing of the necessary communications capabilities as described in the facility design basis are completed prior to initial fuel load on each unit.

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