NRC Generic Letter 1991-14
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
- September 23, 1991 TO: ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION
PERMITS FOR NUCLEAR POWER PLANTS
SUBJECT: EMERGENCY TELECOMMUNICATIONS (GENERIC LETTER 91-14 )
The purpose of this Generic Letter is to alert reactor power plant licensees to the forthcoming NRC effort to implement an upgrade to its emergency will telecommunications system. Some level of licensee effort and cooperation be required for successful implementation of this program.
In the event of a serious emergency at a nuclear power reactor established site, the NRC
pathways are and considers it essential that certain communication response mission.
maintained in order for the agency to fulfill its emergency are NRC has identified seven communications functions (Enclosure 1) which an augmented essential, particularly in the early phases of an accident, until at response effort by NRC personnel and other Federal agencies is established the scene of the emergency.
Currently, the only communication function not conducted over(ENS), the public switched network (PSN) is the Emergency Notification System which is site and the handled over direct dedicated lines between each power reactor emergency NRC Operations Center. Experience has shown that the current communications network does not provide assured paths for the remaining mission, the essential lines of communications. Given its emergency response six essential NRC cannot afford to depend solely on the PSN for the remaining described in Enclosure 1. Although the overall design of communications paths the public network is intended to provide high reliability and alternate can routing, in the case of an emergency the overall traffic load in an atarea the readily exceed local switching capabilities and result in blockage local central office. This is what occurred during the incidents at Three Mile Island and at the Sequoyah Fuels Facility.
In addition to the above, numerous other problems have led the NRC to upgrade The most notable one is the aging its emergency telecommunications system.
and obsolescence of the equipment used for the ENS function.
viable Consequently, an in-depth analysis was undertaken in 1988 to determine terrestrial and alternatives to the current system. Various options involving satellite networks were examined. During 1990, a new communication (GSA)
alternative became available when the General Services Administration for provided the Federal Telecommunications System (FTS) 2000 network
2000
government use, including locations at licensee facilities. The FTSENS, but it network offers not only a lower cost and more reliable system than also provides a separate government network for all of the essential communication functions and it avoids the potential PSN blockage the anticipated during a major emergency. NRC has concluded that conversion to FTS 2000
network is a necessary step at this time to maintain assured and reliable of events communications during an emergency as well as for licensee reporting assessing the during normal operations. As a parallel effort, NRC is also
2000 network to determine if a risks associated with the sole use of the FTS
r_0 ,intand/or diverse communications pathway is needed.
c.910O9180197 27' -am
Generic Letter 91-14 -2 - September 23, 1991 The installation of FTS 2000 lines at licensee's facilities will begin in September 1991 and continue through March support may vary depending on various 1992. The degree of licensee describes the licensee efforts that may site specific factors. Enclosure 2 be which affect the required work. Following required, and the various factors system, the equipment presently used for installation of the FTS 2000
be removed after successful performance the ENS communication function will a sufficient period of time, currently of the new system is demonstrated over month. Enclosure 3 is the current scheduleanticipated to be approximately one at each site. Licensees will be contacted for the installation of FTS 2000
arrange for a mutually acceptable date. in advance of the scheduled time to lines to the site and in some cases to After installation of the FTS 2000
licensees will complete the remaining the offsite EOF, it is expected that installation effort as identified in Enclosure 2 within ninety days, however, those cases in which a plant outage would in extenuating circumstances, such as installation, up to six months will be be required to complete the permitted.
Licensees are being requested to make modifications to their facilities and procedures and thus this request is considered NRC procedures. The requested modifications a backfit in accordance with facilities are in compliance with NRC are needed to ensure that regulations
10 CFR 50, Appendix E, IV.E.9d. As discussed in 10 CFR 50.47(b) (6) and compliance exceptions, a full backfit in 10 CFR 50.109 (a)(4)(i) for analysis documented evaluation of the type described was not performed. A
performed (Enclosure 4), including a statement in 10 CFR 50.109 (a) (6) was reasons for the modification and the basis of the objectives of and the exception. for invoking the compliance Since this letter initiates no information OMB clearance number is required. gathering and requires no reply, no If you have any questions about this letter, contact listed below or the appropriate please contact the technical NRR Project Manager.
Ja G. Partlow Ass ciate Director for Projects Office of Nuclear Reactor Regulation Technical Contacts: T. Kellam, IRM
(301) 492-8000
T. Baldesi, IRM
(301) 492-7121 Enclosures:
1. Essential Emergency Communication Functions
2. Licensee Support for Upgrade to the Emergency Telecommunications Systems
3. Schedule for FTS 2000 Installations
4. Documented Evaluation
ENCLOSURE 1 ESSENTIAL EMERGENCY COMMUNICATION FUNCTIONS
1. Emergency Notification System (ENS): Initial notification by the licensee, as well as ongoing information on plant systems, status, and parameters.
2. Health Physics Network (HPN): Communication with the licensee on radiological conditions (in-plant and off-site) and meteorological conditions, as well as their assessment of trends and need for protective measures on-site and off-site.
3. Reactor Safety Counterpart Link (RSCL): Established initially with the base team, and then with the NRC site team representatives once they arrive at the site, to conduct internal NRC discussions on plant and equipment conditions separate from the licensee, and without interfering with the exchange of information between the licensee and NRC. This is the channel by which the NRC Operations Center supports NRC reactor safety personnel at the site. In addition, this link may also be used for discussion between the Reactor Safety Team Director and licensee plant management at the site.
4. Protective Measures Counterpart Link (PMCL): Established initially with the base team, and then with the NRC site team representatives once they arrive at the site, to conduct internal NRC discussions on radiological releases and meteorological conditions, and the need for protective actions separate from the licensee and without interfering with the exchange of information between the licensee and NRC. This is the channel by which the NRC Operations Center supports NRC protective measures personnel at the site, In addition, this link may also be used for discussion between the Protective Measures Team Director and licensee plant management at the site.
5. Emergency Response Data System (ERDS) Channel: This is the channel over which the raw reactor parametric data is transmitted from the site.
6. Management Counterpart Link (MCL): Established for any internal discussions between the Executive Team Director or Executive Team members and the NRC Director of Site Operations or top level licensee management at the site.
7. Local Area Network (LAN) Access: Established with the base team and the NRC site team for access to any of the products or services provided on the NRC Operations Center's local area network. This includes technical projections, press releases, status reports, E-Mail, and various computerized analytical tools.
ENCLOSURE 2 LICENSEE SUPPORT FOR UPGRADE TO
THE EMERGENCY TELECOMMUNICATIONS SYSTEM
1. Provide a point of contact and participate in the arrangements for the installation of the FTS 2000 lines.
2. Provide adequate capacity at the demarcation distribution frame for7¢ to
9 lines depending on the number of reactor units. For sites with an offsite Emergency Operations Facility (EOF), provide capacity for an additional 6 lines at the demarcation distribution frame serving the EOF.
3. Provide adequate internal wiring (not routed through any onsite switching system) for all FTS 2000 extensions in the control room, technical support center (TSC), and the EOF.
4. Provide cross-connect from the main distribution frame to any and all intermediate distribution frames and to the physical location associated with the FTS 2000 service being provided.
5. Provide RJ-1l Jacks for the FTS 2000 communications functions identiftie in Enclosure 1 at the appropriate locations in the control.-rotomiFt Siroi and EOF. Attached is a list of typical locations for FTS 2000
communications functions. .
6. Install the NRC provided telephone instruments at the appropriate locations as described herein.
7. Relocate, as appropriate, the FTS 2000 phone used for the Emergency Notification System (ENS) upon removal:of the old ENS equipment.
8. Participate in the test program upon completion of system installation.
9. Revise procedures as appropriate for the operation and use of the FTS
2000 system.
10. For those sites including offsite EOF's where sufficient spare facilities into the site are not available, the following support is required:
a. Provide space as necessary for line multiplexing equipment to be installed by AT&T and NRC contractor.
b. Provide guaranteed power to the equipment in accordance with the criteria in IE Bulletin 80-15.
ENCLOSURE 2 TYPICAL LOCATIONS FOR FTS 2000
COMMUNICATION FUNCTIONS
CONTROL ROOM
ENS (One extension per unit)
TSC/EOF*
NRC SPACE
LICENSEE SPACE
LAN-ACCESS
One phone line per reactor unit should be run to computer(s) which will provide data to the Emergencythe room(s) housing the System. Response Data
- For those EOFs which cannot be served as extensions
2000 service, a separate set of FTS 2000 lines will of the on-site FTS
EOFs will be bridged on to the various essential be provided. These emergency functions by calling into the NRC Operations Center. communication
ENCLOSURE 3 SCHEDULE FOR FTS 2000 INSTALLATION
Nov. 1991 Jan. 1992 Feb. 1992 Mar. 1992 Sept. 1991 Big Rock Point Beaver Valley Arkansas Davis-Besse Byron Fermi Cook Braidwood Browns Ferry Callaway Yogtle Brunswick Clinton Cal vert Cli ff s Ft. Calhoun Comanche Peak Diablo Canyon Catawba Millstone Ginna Dresden Cooper Monticello Harris Fitzpatrick Crystal River North Anna Maine Yankee Grand Gulf Duane Arnold Oconee South Texas Hatch Farley Oyster Creek Turkey Point Hope Creek Haddam Neck Palo Verde Indian Point (Con-Ed) Limerick Peach Bottom Indian Point (PASNY) Nine Mile Point Pilgrim Kewaunee Palisades Point Beach LaSalle Prairie Island Quad Cities McGuire River Bend Robinson Perry St. Lucie Salem Seabrook Summer Susquehanna Sequoyah WNP-2 Three Mile Island Surry Waterford Vermont Yankee Trojan Wolf Creek Yankee Rowe Zion San Onofre - FTS 2000 service previously installed. Items 3-9 of Enclosure 2 remain to be completed.
ENCLOSURE 4 Documented Evaluation EMERGENCY TELECOMMUNICATIONS GENERIC LETTER
Objectives:
the To ensure that power reactor facilities remain in compliance with E, IV.E.9d requirements of 10 CFR 50.47 (b)(6) and 10 CFR Part 50, Appendix regarding emergency telecommunications capabilities.
Reasons for Modifications:
to An upgrade to the NRC emergency telecommunications system is necessary provide a reliable and assured means to conduct the essential communications dedicated required during an emergency. The current system utilizes a single with the line (ENS) and the Public Switched Network (PSN) for communication with the licensee's emergency response facilities. The equipment associated PSN to ENS is rapidly deteriorating, and reliance cannot be placed on the in the provide communications paths due to the high probability of blockageemergency.
telephone company central office serving the site during a serious Island in Similar blockage was experienced during the accidents at Three Mile
1979 and the Sequoyah Fuel Facility in 1986.
Basis for Invokinq the Compliance Exception:
Appendix E,
Licensees are required by 10 CFR 50.47 (b) (6) and 10 CFR Part 50, ,
prompt communications among principal IV.E. 9d to have provisions for (a) from the response organizations, and (b) communications with NRC Headquarters and the nuclear power reactor control room, the technical support center,is clearly emergency operations facility. In addition, the use of the ENS
Since called for in numerous parts of the regulations (e.g., 10 CFR 50.72). due to the current ENS is on a dedicated line, it is not subject to blockage ENS was crowded public switching networks during an emergency. However, theInc. After initially designed by AT&T using equipment manufactured by WesCom, Tellabs, divestiture, WesCom sold the rights to this equipment and design to WesCom Inc. Tellabs no longer manufactures WesCom equipment and the existing increasingly unreliable. In addition equipment supporting the ENS is becoming to these equipment reliability concerns, NRC recently experienced at the communication problems during the agency's response to a 1990 event of Vogtle facility which raised further questions as to operational readiness ENS. After May 1992 NRC's contract with AT&T expires. GSA has mandated will not Federal agencies convert to FTS-2000 and, consequently, the contract can no be renewed. As a result, the ENS required explicitly by regulation to longer be practically maintained; therefore, licensees will be unable with for that communication link demonstrate compliance with the requirement that NRC in the absence of an acceptable alternative. The NRC has determined an acceptable alternative for ENS
FTS-2000 is sufficiently reliable to be (e.g.,
purposes; and it is less costly than the other available alternatives satellite link, microwave link, foreign exchange line, etc.)
-2 -
Installation of the Emergency Response Data System (ERDS)
August 13, 1991, amendment to 10 CFR 50.72. Installation is required by an at ten facilities who had implemented ERDS on a voluntary is already complete issuance of the regulation. Upgrading of ERDS, now required basis prior to already underway; the proposed action is consistent with by regulation, is the upgrade effort.
It has been previously determined that provision of five communications links (i.e., Reactor Safety Counterpart Linkother essential Physics Network (HPN), Protective Measures Counterpart Link (RSCL), Health Counterpart Link (MCL), and Operations Center Local Area (PMCL), Management Network Access Link (LAN)), in addition to the ENS and ERDS, is an acceptable to comply with the general requirement to establish reliablemeans for licensees communications with NRC. The essential communication needs emergency repeatedly addressed in previous Commission papers (SECY-87-290,have been SECY-91-149) and NUREG-0696, Functional Criteria for Emergency SECY-89-340,
Facilities. The staff has determined in connection with Response this proposed action that, in order to ensure the reliability of overall emergency capability and complete compatibility among the component communications system, the RSCL, HPN, PMCL, MCL, and LAN should also be parts of the overall FTS-2000. upgraded by use of Accordingly, the NRC has concluded that conversion to the a necessary step at this time to maintain assured and FTS 2000 network is reliable communications during an emergency as well as for licensee reporting of events operations. Therefore, in order to maintain continued complianceduring normal
50.47 (b)(6) and 10 CFR Part 50, Appendix E, IV.E. 9d, licensees with 10 CFR
to provide the modifications necessary to support installation are requested of the emergency telecommunications system upgrade. and operation
ENCLOSURE 5 LIST OF RECENTLY ISSUED GENERIC LETTERS
Generic Date of Letter No. __ Subject Issuance
- - - Issued
- - - - To
- - - - -
91-13 REQUEST FOR INFO RELATED 09/19/91 LICENSEES AND APPLI-
TO RESOLUTION OF GI-130, CANTS of Braidwood, Byron
"ESSENTIAL SERVICE WATER Catawba, Comanche Peak SYS. FAILURES AT MUTLI- Cook, Diablo, McGuire UNIT SITES " PURSUANT TO
1OCFR50.541f)
91-12 OPERATOR LICENSING NAT. 08/27/91 ALL PWR REACTOR
EXAMINATION SCHEDULE AND APPLICANTS FOR
AN OPERATING LICENSE
91-11 RESOLUTION OF GENERIC 07/18/91 ALL HOLDERS OF
ISSUES 48, "LCOs FOR CLASS OPERATING LICENSES
lE VITAL INSTRUMENT BUSES,"
and 49, "INTERLOCKS AND LCOs FOR CLASS 1E TIE BREAKERS"
PURSUANT TO 10CFR50.54(f)
91-10 EXPLOSIVES SEARCHES AT 07/08/91 TO ALL FUEL CYCLE
PROTECTED AREA PORTALS FACILITY LICENSEES
WHO POSSESS, USE,
IMPORT OR EXPORT
FORMULA QUANTITIES
OF STRATEGIC SPECIAL
NUCLEAR MATERIAL
88-20 INDIVIDUAL PLANT EXAMINATION 06/28/91 ALL HOLDERS OF
SUPP. 4 OF EXTERNAL EVENTS (IPEEE) OLs AND CPs FOR
FOR SEVERE ACCIDENT VULNERA- NUCLEAR POWER
BILITIES - 10 CFR 50.54 (f) REACTORS
91-09 MODIFICATION OF SURVEILLANCE 06/27/91 ALL HOLDERS OF
INTERVAL FOR THE ELECTRICAL OLs FOR BWRs PROTECTIVE ASSEMBLIES IN
POWER SUPPLIES FOR THE
91-08 REMOVAL OF COMPONENT LISTS 05/06/91 ALL HOLDERS OF OLs FROM TECHNICAL SPECIFICA- OR CPs FOR NUCLEAR
TIONS POWER REACTORS
91-07 GI-23 "REACTOR COOLANT 05/02/91 ALL POWER REACTOR
PUMP SEAL FAILURES" AND LICENSEES AND
ITS POTENTIAL IMPACT ON HOLDERS OF CPs STATION BLACKOUT
91-06 RESOLUTION OF GENERIC ISSUE 04/29/91 ALL HOLDERS OF OLs A-30, "ADEQUACY OF SAFETY-
RELATED DC POWER SUPPLIED
PURSUANT TO 10 CFR 50.54(f)
Generic Letter 91-14 -2 - September 23, 1991 The installation of FTS 2000 lines at licensee's facilities will begin in September 1991 and continue through March 1992. The degree of licensee support may vary depending on various site specific factors. Enclosure 2 describes the licensee efforts that may be required, and the various factors which affect the required work. Following installation of the FTS 2000
system, the equipment presently used for the ENS communication function will be removed after successful performance of the new system is demonstrated over a sufficient period of time, currently anticipated to be approximately one month. Enclosure 3 is the current schedule for the installation of FTS 2000
at each site. Licensees will be contacted in advance of the scheduled time to arrange for a mutually acceptable date. After installation of the FTS 2000
lines to the site and in some cases to the offsite EOF, it is expected that licensees will complete the remaining installation effort as identified in Enclosure 2 within ninety days, however, in extenuating circumstances, such as those cases in which a plant outage would be required to complete the installation, up to six months will be permitted.
Licensees are being requested to make modifications to their facilities and procedures and thus this request is considered a backfit in accordance with NRC procedures. The requested modifications are needed to ensure that facilities are in compliance with NRC regulations in 10 CFR 50.47(b) (6) and
10 CFR 50, Appendix E, IV.E.9d. As discussed in 10 CFR 50.109 (a)(4)(i) for compliance exceptions, a full backfit analysis was not performed. A
documented evaluation of the type described in 10 CFR 50.109 (a) (6) was performed (Enclosure 4), including a statement of the objectives of and the reasons for the modification and the basis for invoking the compliance exception.
Since this letter initiates no information gathering and requires no reply, no OMB clearance number is required.
If you have any questions about this letter, please contact the technical contact listed below or the appropriate NRR Project Manager.
James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Technical Contacts: T. Kellam, IRM DISTRIBUTION (W/ENCLS)
(301) 492-8000 Central files T. Baldesi, IRM NRC PDR
(301) 492-7121 -1RB R/F -
JRJolicoeur Enclosures:
1.- Essential Emergency Communication Functions
2. Licensee Support for Upgrade to thle Emergency Telecommunications Systems
3. Schedule for FTS 2000 InstallationIs
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