ML13127A198
| ML13127A198 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 05/24/2013 |
| From: | Kalyanam N Plant Licensing Branch IV |
| To: | Entergy Operations |
| Kalyanam N | |
| References | |
| TAC ME9991, TAC ME9992 | |
| Download: ML13127A198 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 24,2013 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802
SUBJECT:
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - SAFETY ASSESSMENT IN RESPONSE TO REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) - RECOMMENDATION 9.3 COMMUNICATIONS ASSESSMENT (TAC NOS. ME9991 AND ME9992)
Dear Sir or Madam:
By letter dated March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued a request for information pursuant to Section 50.54(f) to Title 10 of the Code of Federal Regulations (henceforth referred to as the 50.54(f) letter). The request was issued as a part of implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant. to the 50.54(f) letter contained specific requested information associated with the NRC's Near-Term Task Force Recommendation 9.3 for emergency preparedness communications. Specifically, the letter requested that licensees provide an assessment of the current communications systems and equipment used during an emergency event.
By letter dated October 31, 2012, Entergy Operations, Inc. (the licensee), responded to this request for Arkansas Nuclear One, Units 1 and 2. In response to NRC staff questions, the licensee provided additional information by letter dated February 20, 2013.
The NRC staff has reviewed the communications assessment for Arkansas Nuclear One, Units 1 and 2, and, as documented in the enclosed safety assessment, determined that the assessment for communications is reasonable, and the interim measures, analyzed existing systems, and proposed enhancements will help to ensure that communications are maintained.
Further, in coordination with the Near-Term Task Force Recommendation 4.2 (mitigating strategies), the NRC staff plans to follow up with the licensee to confirm that upgrades to the site's communications systems have been completed.
-2 If you have any questions, please contact me at (301) 415-1480 or via e-mail at kaly.kalyanam@nrc.gov.
Sincerely, N. Kaly Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368
Enclosure:
As stated cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY ASSESSMENT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REVIEW OF COMMUNICATIONS IN RESPONSE TO REQUEST FOR INFORMATION DATED MARCH 12,2012 ENTERGY OPERATIONS. INC.
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 DOCKET NOS. 50-313 AND 50-368
1.0 INTRODUCTION
By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information pursuant to Section 50.54(f) to Title 10 of the Code of Federal Regulations (10 CFR) (henceforth referred to as the 50.54(f) letter). The request was issued as a part of implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 5 to the 50.54(f) letter contained specific requested information associated with the NRC's Near-Term Task Force Recommendation 9.3 for emergency preparedness communications. Specifically, the letter requested that licensees provide an assessment of the current communications systems and equipment used during an emergency event.
By letter dated October 31,2012 (ADAMS Accession No. ML12305A534), as supplemented by letter dated February 20, 2013 (ADAMS Accession No. ML13053A193), Entergy Operations, Inc. (Entergy), the licensee for Arkansas Nuclear One, Units 1 and 2, provided an assessment of its communications capabilities in response to the NRC's request for information.
Within the licensee response letter, an assessment of the current communications systems and equipment to be used during an emergency event was performed to identify any enhancements needed to ensure communications are maintained during and following a beyond design basis large-scale natural event. In this assessment, it was assumed that a large-scale natural event causes: (1) a loss of all alternating current (ac) power, and (2) extensive damage to normal and emergency communications systems both onsite and in the area surrounding the site (i.e.,
within 25 miles of the site, consistent with the guidance endorsed by the NRC's letter dated May 15, 2012 1). Additionally, interim actions were identified by the licensee during the period of implementation of the planned improvements to the communications systems or procedures.
Skeen, D. L., U.S. Nuclear Regulatory Commission, letter to Susan Perkins-Grew, Nuclear Energy Institute, "U.S. Nuclear Regulatory Commission Review of NEI 12-01, 'Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,' Revision 0," dated May 2012," dated May 15, 2012 (ADAMS Accession No. ML12131A043).
Enclosure
-2 1.1 Background On March 12, 2012, the NRC issued a letter entitled "Request for I nformation Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident." In accordance with 10 CFR SO.S4(f), addressees were requested to submit a written response to the information requests within 90 days.
The 50.54(f) letter stated that if an addressee 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 11, 2012 (ADAMS Accession No. ML12132A227), the licensee committed to submitting its completed communications assessment and implementation schedule by October 31, 2012. By letter dated June 8, 2012 (ADAMS Accession No. ML12164A566), the licensee also provided a description of any interim actions (discussed in further detail in Section 3.0) that have been taken or are planned to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete. The NRC staff found the proposed schedule acceptable by letter dated July 26,2012 (ADAMS Accession No. ML12200A106). of the SO.S4(f) letter contained specific requested information associated with NRC's Near-Term Task Force Recommendation 9.3 for emergency preparedness communications. Specifically, the letter requested that licensees provide an assessment of the current communications systems and equipment used during an emergency event to identify any enhancements that may be needed to ensure communications are maintained during a large-scale natural event and subsequent loss of ac power. The licensee's assessment should:
- identify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies;
- identify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies;
- provide a description of any new communications system(s) or technologies that will be deployed based upon a large-scale natural event and extensive damage to normal and emergency communications systems both onsite and offsite; and
- provide a description of how the new and/or improved systems and power supplies will be able to provide for communications during a loss of all ac power.
The 50.54(f) letter also requested the licensees to:
- describe any interim actions that have been taken or are planned to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete; and
- provide an implementation schedule of the time needed to conduct and implement the results of the communications assessment.
- 3
2.0 REGULATORY EVALUATION
The NRC staff reviewed the licensee's responses to the 50.54(f) letter against the regulations and guidance described below.
2.1 Regulations Section 50.47, "Emergency plans," of 10 CFR Part 50, sets forth emergency plan requirements for nuclear power plant facilities.
Section 50.47(b) establishes the standards that the onsite and offsite emergency response plans must meet for NRC staff to make a positive finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency. Planning Standard (6) of this section requires that a licensee's emergency response plan contain provisions for communications among principal response organizations to emergency personnel and to the public. Planning Standard (8) requires that adequate emergency facilities and equipment to support emergency response are provided and maintained.
Section IV.O, "Notification Procedures," of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, requires that a licensee have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency. The design objective of the prompt public alert and notification system shall be to have the capability to complete the initial alerting and initiate notification of the public within the plume exposure pathway within about 15 minutes. This alerting and notification capability will include a backup method of public alerting and notification.
Section IV.E, "Emergency Facilities and Equipment," of Appendix E to 10 CFR Part 50, states that adequate provisions shall be made and described for emergency facilities including at least one onsite and one offsite communications system; and each system shall have a backup power source. These arrangements will include:
- a. Provision for communications with contiguous State/local governments within the plume exposure pathway emergency planning zone.
- b. Provision for communications with Federal emergency response organizations.
- c. Provision for communications among the nuclear power reactor control room, the onsite technical support center, and the emergency operations facility; and among the nuclear facility, the principal State and local emergency operations centers, and the field assessment teams.
- d. Provisions for communications by the licensee with NRC Headquarters and the appropriate NRC Regional Office Operations Center from the nuclear power reactor control room, the onsite technical support center, and the emergency operations facility.
- 4 2.2 Guidance Nuclear Energy Institute (NEI) 12-01, Revision 0, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," dated May 2012, presents a methodology for licensees to analyze their ability to perform critical communications during and after a large-scale natural event. NRC staff has previously reviewed NEI 12-01 (ADAMS Accession No. ML12131A043), and determined that it was an acceptable method for licensees to use in responding to the 50.54(f) letter.
The NRC staff reviewed the licensee's analyses against the assumptions and guidance within NEI 12-01, Sections 2.2, 2.4, and 4. These sections provide a discussion on the assumptions and criteria to be used for a communications assessment.
2.0 TECHNICAL EVALUATION
In its letter dated October 31, 2012, as supplemented by letter dated February 20, 2013, the licensee submitted its assessment of communications assuming a large-scale natural event, which would lead to an extended loss of all ac power. This letter included a discussion of required communications links, primary and backup methods of communications, and any identified improvements.
3.1 Communication Areas Reviewed 3.1.1 Communication Links Arkansas Nuclear One, Units 1 and 2, currently have communications capabilities with offsite response organizations (OROs), the NRC, between licensee emergency response facilities, with field and offsite monitoring teams, and with in-plant and offsite licensee emergency response organization staff. As part of its communications assessment, the licensee has determined that many of the communications equipment described in its emergency plan can be assumed to not be available. However, certain existing onsite communications system equipment such as the existing site radio system(s) would be available after implementation of planned enhancements, for the communication links listed above given a seismic, high wind, or flooding event.
As an interim measure prior to the implementation of all planned enhancements, the licensee has distributed satellite phones to the Technical Support Center (TSC). Additionally, the licensee has purchased additional radios and spare batteries for the site, which are staged within the TSC and other emergency response facilities. This purchased equipment will be used in conjunction with existing satellite phones and site radios until the final implementation of all planned enhancements. The radios are able to function without repeaters; however, the primary onsite repeater will have backup power. User aids will be stored with the satellite phones and there is an existing licensee staff familiarity with the radios. The satellite phones and radios are stored in hardened/cushioned cases for protection.
As the planned enhancement, the licensee plans to ensure that a portable satellite telephone or radio communications are available for each communication link outlined in Section 4 of NEI 12-01. Communications between licensee emergency response facilities will use both satellite phones and radios. Enhancements to equipment protection, such as anchoring equipment to prevent impacts from a seismic event, will be made to help ensure that the
-5 equipment is available following a large-scale natural event. The licensee is implementing planned improvements for communications with OROs, by ensuring each organization has a portable satellite phone. 2 Entergy will put these enhancements in place with licensee-approved procedures by October 2015.
The NRC staff has reviewed the licensee's expected communications links within its communications assessment. In reviewing the licensee's submittal, the NRC staff considered whether it is reasonable that each communication link can be maintained, after the implementation of all planned enhancements, in accordance with the NRC-endorsed guidance of NEI12-01. The portable satellite telephones, as well as radio communications 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 NRC staff concludes that since the licensee's assessment for the availability of communications systems is reasonable, and planned enhancements are to be made for communications areas to help ensure reliability, the licensee's interim measures and proposed enhancements will help to ensure that communications are maintained consistent with the assumptions in NRC-endorsed guidance of NEI 12-01.
3.1.2 Equipment Location Entergy has determined the survivability of its existing equipment for large-scale natural events by crediting equipment located in seismically analyzed buildings. The capacity of the equipment in its current configuration was evaluated in its ability to withstand the external hazards as identified in the NEI 12-01 guidance. These hazards include seismic, flooding, and high winds.
The licensee's evaluation was based on engineering judgment developed by a consensus of experienced engineers in structural design and construction using the guidance provided in Electric Power Research Institute (EPRI) NP-6041, "Nuclear Power Plant Seismic Margin." The 50.504(f) letter states, in part, that EPRI NP-6041 provides acceptable guidance for seismic protection walk downs.
The NRC staff reviewed the licensee's submittal and verified that the licensee has considered the equipment location and protection contained within the NRC's endorsed guidance of NEI 12-01. The NRC staff also verified that all equipment discussed in Section 3.1.1 of this document has been analyzed to be available after a large-scale natural event; 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 batteries would be protected from seismic, flooding, and high-wind events.
Based on this review, the NRC staff concludes the licensee's analysis of communications assessment equipment survivability and proposed enhancements for equipment location to be consistent with NRC endorsed guidance 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.
2 Radio communications are also expected to be available at offsite response organizations.
-6 3.1.3 Equipment Power and Fuel The licensee has analyzed the availability of its communications system power supplies following the loss of all ac power. The licensee has proposed a combination of batteries and uninterrupted power supplies (UPSs) to power site communications equipment, including the satellite phones and radios. The site strategies will result in: (1) each satellite phone will be provided for a 24-hour power supply capability through batteries; (2) radios will be provided for a 24-hour power supply capability through batteries; (3) UPSs will provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of back-up power for radio repeater systems; and (4) other radio system equipment power supplies will be analyzed to be in alignment with NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX)
Implementation Guide," dated August 21,2012 (ADAMS Accession No. ML12242A378).3 The NRC staff has reviewed the licensee's communications assessment for power supplies. In reviewing the submittal, the NRC staff concludes that it is reasonable that power for the existing equipment and proposed enhancement equipment, as listed in Section 3.1.1 of this document, would remain available for 24-hour duration, based on the availability of extra batteries and future alignment with FLEX strategies. Additionally, the licensee's interim measures and proposed enhancements are in accordance with NRC-endorsed guidance of NEI 12-01.
Based on this review, the NRC staff considers the licensee's analysis of equipment power and proposed enhancements for equipment power is consistent with NRC-endorsed guidance. This determination of available equipment power supports the conclusion that these measures will help to ensure communications equipment functionality for a large-scale natural event.
3.1.4 Proceduralization and Training The licensee has confirmed that there are sufficient reserves of equipment to minimize the need of multi-use equipment for different communication functions. The licensee plans to have procedures on revising existing site procedures for inventory checks and testing of the new portable satellite phones and the radios. The licensee's staff will be trained on equipment location and use of this communications equipment by October 2015.
General employee training procedures will be updated to include direction regarding actions to be taken by plant employees following the observation of a large-scale natural event should the public address system be unavailable. The licensee has procedures in place for emergency response organization self-activation due to major disturbances in the power grid. These site capabilities will activate the offsite emergency response organization and notify plant staff.
The NRC staff reviewed the licensee's commitments on the planned quality assurance and maintenance of the equipment and licensee staff training on the use of this equipment. The NRC staff concluded that the licensee's submittal is in accordance with the NRC-endorsed guidance of NEI 12-01.
3 On August 29,2012, NRC endorsed NEI 12-06 as a way to respond to NRC Order EA-12-049, "Order to Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012 (ADAMS Accession No. ML12054A735).
-7 Based on this review, the NRC staff concludes that the licensee's planned proceduralization of equipment use and licensee staff training to be consistent with NRC endorsed NEI12-01. This determination of equipment availability and functionality supports the conclusion that these measures will help to ensure communications equipment functionality for a large-scale natural event.
3.2 Regulatory Commitments In response to the 50.54(f) letter, by letter dated October 31, 2012, the licensee made the following regulatory commitment, which is applicable to this assessment and will be implemented prior to start-up from Refueling Outage 2R24 Fall 2015:
Enhancements identified within the assessment (Attachment 1) will be further developed as implementation progresses. Alternate approaches will be utilized if prudent (e.g., alternate/new technology, improved capability, cost savings, etc.).
These enhancement commitments are subject to change as a result of Diverse and Flexible Coping Strategies (FLEX) developments, advances in technology, and progress in the manner of addressing the need for these enhancements.
The NRC staff concludes that reasonable controls for the implementation and for the subsequent evaluation of the proposed changes pertaining to the above regulatory commitment is best provided by the licensee's administrative processes, including its commitment management program. The regulatory commitment above does not warrant the creation of regulatory requirements (items requiring prior NRC approval of subsequent changes).
3.0 CONCLUSION
The NRC staff has reviewed the licensee's communications assessment for communications with or among: OROs, the NRC, licensee emergency response facilities, field and offsite monitoring teams, and on-site and in-plant response teams. In reviewing the licensee's submittal, the NRC staff considered the factors outlined above, and determined that its assessment of existing equipment, proposed enhancements, and interim actions was in accordance with the NRC-endorsed guidance of NEI 12-01. The NRC staff concludes that the licensee's assessment for communications is reasonable, and the licensee's interim measures, analyzed existing systems, and proposed enhancements will help to ensure that communications are maintained. Further, in coordination with the Near-Term Task Force Recommendation 4.2 (mitigating strategies), the NRC staff plans to follow up with the licensee to confirm that upgrades to the site's communications systems have been completed.
Principal Contributor: Richard Chang Date: l\IIay 24, 2013
- 2 If you have any questions, please contact me at (301) 415-1480 or via e-mail at kaly.kalyanam@nrc.gov.
Sincerely, IRAJ N. Kaly Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368
Enclosure:
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