ML20022A060

Assessment of Communications in Response Request for Information for Vogtle Electric Generating Plant Units 3 and 4

ML20022A060
Person / Time
Site:	Vogtle
Issue date:	01/20/2020
From:	Cayetano Santos NRC/NRR/VPOB
To:
Tanny Santos Ex 7270
References
EPID L-2019-LRQ-0002
Download: ML20022A060 (8)

Text

SAFETY ASSESSMENT BY THE OFFICE OF NUCLEAR SECURITY AND INCIDENT RESPONSE ASSESSMENT OF COMMUNICATIONS IN RESPONSE TO REQUEST FOR INFORMATION DATED MARCH 12, 2012 SOUTHERN NUCLEAR OPERATING COMPANY, INC VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 DOCKET NOS.52-025 and 52-026

1.0 INTRODUCTION

By letter dated August 16, 2019 (Reference 1), Southern Nuclear Operating Company, Inc.,

(SNC), the licensee for Vogtle Electric Generating Plant (VEGP), Units 3 and 4 (currently under construction), provided an assessment of its communications capabilities in response to the U.S. Nuclear Regulatory Commissions (NRCs) letter dated March 12, 2012 (Reference 2),

request for information regarding the Near-Term Task Force (NTTF) Recommendation 9.3 on emergency preparedness communications. The NRC reviewed SNCs information to determine if the licensees assessment for communications was reasonable and if the existing systems, interim measures, and proposed enhancements will help to ensure that communication would be maintained during a large-scale natural event.

The assessment of the current communications systems requirements and equipment to be used during an emergency event is intended to identify any enhancements needed to ensure communications are maintained during and following a beyond design basis large-scale natural event. In this assessment it was assumed that a large-scale natural event causes: (1) a loss of all alternating current (ac) power; and (2) extensive damage to normal and emergency communications systems both onsite and in the area surrounding the site (i.e., within 25 miles of the site), consistent with the guidance endorsed by NRCs letter dated May 15, 2012 (Reference 3). No interim actions were identified as being needed since VEGP Units 3 and 4 are still in the process of completing construction and there are no requirements for functional communications systems and equipment for use during this period.

1.1 Background In Enclosure 5 of its letter dated March 12, 2012, the NRC requested that licensees provide an assessment of the current communications systems and equipment used during an emergency event to identify any enhancements that may be needed to ensure communications are maintained during a large-scale natural event and subsequent loss of ac power. Specifically, the licensees assessment should:

• Identify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies;

• Identify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies;

• Provide a description of any new communications system(s) or technologies that will be deployed based upon a large-scale natural event and damage to communications systems onsite and offsite; and

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

The letter also asked for licensees to:

• Describe any interim actions that have been taken or are planned to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete, and

• Provide a schedule of the time needed to implement the results of the communications assessment.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.54(f), addressees were requested to submit a written response to the information requests within 90 days. The NRCs letter dated March 12, 2012, also states that if an addressee cannot meet the requested response date, then the addressee must respond within 60 days of the date of the letter and describe the alternative course of action that it proposes to take, including any estimated completion date.

By letter dated May 9, 2012 (Reference 4), SNC committed to submitting their completed communications assessment and implementation schedule by May 20, 2015. Subsequently, by letter dated June 28, 2012 (Reference 5), SNC provided a supplement as a result of a public teleconference held on June 20, 2012, at which time the NRC requested clarification on the basis for the information provided in SNCs May 9, 2012 response. The clarification provided by SNC included information on the construction status of VEGP Units 3 and 4 and indicated that the alternative course of action aligned with the construction schedule at that time. SNC also indicated that the requested information would be provided prior to VEGP Unit 3 fuel load. The NRC staff found the proposed schedule acceptable by letter dated July 31, 2012 (Reference 6).

2.0 REGULATORY EVALUATION

The NRC staff reviewed SNCs responses to the March 12, 2012, request for information against the regulations and guidance described below.

2.1 Regulations Section 50.47, Emergency plans, of the 10 CFR, sets forth emergency planning requirements for nuclear power reactors. Specifically, 10 CFR 50.47(b) establishes the planning standards that the onsite and offsite emergency response plans must meet for NRC staff to make a finding

of reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency.

• Planning Standard 50.47(b)(6) requires that provisions exist for communications among response organizations to emergency personnel and to the public.

• Planning Standard 50.47(b)(8) requires that adequate emergency facilities and equipment to support emergency response are provided and maintained.

Section IV of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50 provides further requirements for the content of an applicants/licensees (onsite) emergency plan.

• Section IV.D.3 of Appendix E requires that a licensee have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency.Section IV.D.3 also requires that the design objective of the alert and notification system shall be to have the capability to essentially complete the initial alerting and initiate notification of the public within the plume exposure pathway emergency planning zone (EPZ) within approximately 15 minutes. In addition, this alerting and notification capability will include a backup method of public alerting and notification.

• Section IV.E.9 of Appendix E states that adequate provisions will be made and described for emergency facilities, including at least one onsite and one offsite communications system; each system shall have a backup power source. Where consistent with the function of the governmental agencies, these arrangements will include:

a. Provision for communications with contiguous State/local governments within the plume exposure pathway EPZ.

b. Provision for communications with Federal emergency response organizations.

c. Provision for communications among the nuclear power reactor control room, the onsite technical support center (TSC), and the emergency operations facility (EOF);

and among the nuclear facility, the principal State and local emergency operations centers (EOCs), and the field assessment teams.

d. Provisions for communications by the licensee with NRC Headquarters and the appropriate NRC Regional Office Operations Center from the nuclear power reactor control room, the onsite TSC, and the EOF.

2.2 Guidance The Nuclear Energy Institutes (NEI) 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communication Capabilities (Reference 7), provides a methodology for licensees to analyze their ability to perform critical communications during and after a large-scale natural event. NRC staff reviewed and endorsed NEI 12-01 as an acceptable method for licensees to use in responding to NRCs March 12, 2012, request for information.

The staff reviewed SNCs analyses against the assumptions and guidance within NEI 12-01, Sections 2.2, 2.4 and 4. These sections provide a discussion on the assumptions and criteria to be used for a communications assessment.

3.0 TECHNICAL EVALUATION

In its letter dated August 16, 2019, SNC submitted an assessment of communications, which assumed a large-scale natural event that would lead to an extended loss of all ac electrical power. The letter included a discussion of required communications links, primary and backup methods of communications, and any identified improvements. The letter also provided estimated completion dates and implementation milestones that supersede those contained in SNCs letters dated May 9, 2012, and June 28, 2012, but indicated that these dates are subject to change as the construction schedules for VEGP Units 3 and 4 evolve.

3.1 Communication Areas Reviewed 3.1.1 Communication Links VEGP Units 3 and 4 are currently under construction, and as such, have no emergency communications capabilities requirements during the construction phase. As such, SNC determined that many of the communications systems and equipment described in their emergency plan may not be currently available using the assumptions contained within NEI 12-01. However, certain existing onsite communications system equipment, such as the plant page/party line system (which allows for two-way communication) and sound powered phones, would be available under certain conditions for a discreet amount of time following a seismic, high wind, or flooding event. This system is still under buildout due to construction completion activities on each unit. The final location of communication equipment will generally be consistent with criterion contained within NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, (Reference 8).

As for new communications systems or technologies that will be deployed, SNC plans on purchasing a sufficient number of satellite telephones, two portable communications kits, and mobile communications systems. The portable satellite phones will be initially used as one of the key onsite methods for maintaining each offsite communication link with the communications kit supporting offsite communications following setup. The communications kit capabilities will help to re-establish cellular telephones onsite and provide for satellite voice communications.

Communications onsite will initially use combinations of the sound powered phones and the plant page/party line system. The sound powered phones, telephone/page, and private automatic branch exchange (PABX) telephones have been analyzed by SNC to be available in limited cases, in the event of a large-scale natural event. The telephone/page and PABX systems would be available for a limited period (e.g., 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) based on a battery backup availability time. Once the mobile communications system is deployed, it will have the capabilities to provide for satellite and radio communications for all units onsite, and for communications between onsite and offsite.

The NRC staff reviewed SNCs expected communications links within their communications assessment and considered whether it is reasonable that each communication link can be maintained after the implementation of all planned enhancements, in accordance with NEI 12-01. The portable satellite telephones, as well as the capabilities and availability of the

communications kit and mobile communications system, are expected to help maintain communications offsite and between emergency response facilities by their ability to function without infrastructure postulated to be damaged by a large-scale natural event. The sound powered phones will provide augmented communications capabilities with the plant page/party line system for communications in needed areas of the plant. Finally, the capabilities and availability of the mobile communications system provide an additional technology for maintaining onsite communications.

The NRC staff concludes that, since SNCs assessment for the availability of communications systems is reasonable, and planned enhancements are to be made for communications areas to help ensure reliability, SNCs interim measures and proposed enhancements will help to ensure that communications are maintained, consistent with the assumptions in NEI 12-01.

3.1.2 Equipment Location SNC has analyzed the survivability of their existing installed and planned equipment for large-scale natural events impacting VEGP Units 3 and 4 by crediting equipment located in areas that would likely survive the postulated event. Further, equipment locations were also analyzed to be protected against wind and flooding. Enhancements to equipment protection will be made by storing equipment in accordance with FLEX criteria, which includes the portable satellite phones, communications kits, and mobile communication systems. This FLEX criteria were also used to determine ancillary equipment storage locations, including the generators that will be used to support the planned enhancements. The specific locations for storage of equipment will be completed in alignment with FLEX criteria upon completion of construction.

NRC staff agrees that SNC has considered the equipment location and protection criteria contained within NEI 12-01. The NRC staff also agrees that all equipment discussed in Section 3.1.1 of this document has been analyzed to be available after a large-scale natural event, that actions will be taken for its protection or would be stored in a reasonably protected area from seismic, flooding, and high wind events, as discussed in NEI 12-01. The NRC staff also ensured that ancillary equipment, such as generators, would be protected from seismic, flooding, and high wind events. In addition, the staff considered SNCs analysis of communications assessment equipment survivability and proposed enhancements for equipment location to be consistent with NEI 12-01. This determination of equipment protection supports the conclusion that these measures will help to ensure communications equipment availability for a large-scale natural event.

3.1.3 Equipment Power and Fuel SNC has analyzed the availability of communications system power supplies following the loss of all ac power for VEGP Units 3 and 4, and has proposed a combination of batteries and generators to power site communications equipment. This will include satellite phones and plant page/party line systems, and the procurement of enough extra batteries for equipment that is battery powered. The site strategies will result in: (1) portable satellite phones having an adequate battery supply for operations for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using the vendors minimum battery durations; (2) a plant page/party line system that will rely on an uninterruptable power supply for initial site notifications; (3) a portable communications kit that will have a battery backup to last until the mobile communications system can be setup; and (4) a mobile communications system that will have an onboard generator. SNC expects that this equipment has power to support communications for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, based on assumptions for impeded site access.

SNC is planning on having these enhancements to the communication system power supplies completed during site construction, and prior to fuel load. These systems will be verified by future inspections and inspections, tests, analyses, and acceptance criteria (ITAAC) closures (as listed in the SNC Communications Assessment) by SNC prior to operation.

The NRC staff reviewed SNCs communications assessment for power supplies, and finds that it is reasonable that power for the existing equipment and proposed enhancements of the equipment, as listed in Section 3.1.1 of this document, would result in equipment availability for a 24-hour duration, based on the availability of extra batteries and generator fuel. Additionally, SNCs proposed enhancements are in accordance with NEI 12-01.

Based on this review, the staff finds that SNCs analysis of equipment power and proposed enhancements for equipment power is consistent with NEI 12-01. The available equipment power and fuel supports the conclusion that these measures will help to ensure communications equipment functionality for a large-scale natural event.

3.1.4 Procedures and Training SNC has confirmed that procedures for the shared use of equipment for different communication functions will be developed. Procedures for the deployment of the communications kit and mobile communications system will also be developed. Existing site procedures for the maintenance and operability testing of communications equipment are in place, and will be revised as necessary following construction. Inventory procedures will also be developed or revised, as necessary, for the communications equipment, batteries and battery chargers. Licensee staff will receive initial and continuing training on the communications equipment location and use, consistent with the site emergency plan and implementing procedures. Licensee staff training and the development of procedures are expected to be completed in alignment with the deployment of equipment.

The plant paging system will provide for initial notification to plant employees after a large-scale natural event. SNC will also develop procedures and will provide training for emergency response organization staff for mobilization due to major disturbances in the power grid. These site capabilities will activate the offsite emergency response organization and notify plant staff, as needed, following an event as outlined in NEI 12-01.

The NRC staff reviewed SNCs commitments on the planned quality assurance, maintenance of the equipment, and staff training on the use of this equipment, and determined that SNCs submittal is in accordance with NEI 12-01.

Based on its review, the NRC staff considers SNCs planned proceduralization of equipment use and licensee staff training to be consistent with NEI 12-01. This determination of equipment availability and functionality supports the staffs conclusion that these measures will help to ensure communications equipment functionality for a large-scale natural event, consistent with NEI 12-01.

4.0 CONCLUSION

As described above, the NRC staff reviewed SNCs assessment for communication and determined that SNCs assessment of existing equipment and proposed enhancements is in accordance with NEI 12-01. As such, the NRC staff concludes that SNCs assessment for communications is reasonable, and the proposed enhancements will help ensure that communications are maintained.

VEGP has ITAAC related to emergency communications capabilities that SNC must close prior to plant operation. These ITAAC confirm the functionality of both onsite and offsite communication capabilities. The NRC staff will verify the closure of these ITAAC to confirm emergency communications systems capabilities, as part of the ITAAC closure verification process, which may include inspection.

5.0 REFERENCES

1. SNC letter to NRC, Vogtle Electric Generating Plant - Units 3 and 4, Emergency Preparedness Communications Assessment Requested by NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident dated March 12, 2012, dated August 16, 2019, (ADAMS Accession No. ML19240A068).

2. NRC letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012, (ADAMS Accession No. ML12053A340).

3. NRC letter, U.S. Nuclear Regulatory Commission Review of NEI 12-01, Guideline For Assessing Beyond Design Basis Accident Response Staffing And Communications Capabilities, Revision 0, dated May 15, 2012, (ADAMS Accession No. ML12131A043).

4. SNC letter to NRC, 60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident, dated May 9, 2012 (Letter ND-12-0987), (ADAMS Accession No. ML12131A540).

5. SNC letter to NRC, Supplement to 60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident, dated June 28, 2012 (Letter ND-12-1364),

(ADAMS Accession No. ML121850029).

6. NRC letter, Vogtle Electric Generating Plant Units 3 and 4 - Review of 60-Day Response to a Request for Information Regarding Recommendation 9.3, of the Near-Term Task Force Related to the Fukushima Daiichi Nuclear Power Plant Accident, dated July 31, 2012, (ADAMS Accession No. ML12201B409).

7. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communication Capabilities, Revision 0, dated May 2012, (ADAMS Accession No. ML12125A412).

8. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 1, dated May 2012, (ADAMS Accession No. ML12143A232).