NRC Generic Letter 1991-14
UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555* September 23, 1991TO: ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTIONPERMITS FOR NUCLEAR POWER PLANTS
SUBJECT: EMERGENCY TELECOMMUNICATIONS (GENERIC LETTER 91-14 )The purpose of this Generic Letter is to alert reactor power plant licenseesto the forthcoming NRC effort to implement an upgrade to its emergencytelecommunications system. Some level of licensee effort and cooperation willbe required for successful implementation of this program.In the event of a serious emergency at a nuclear power reactor site, the NRCconsiders it essential that certain communication pathways are established andmaintained in order for the agency to fulfill its emergency response mission.NRC has identified seven communications functions (Enclosure 1) which areessential, particularly in the early phases of an accident, until an augmentedresponse effort by NRC personnel and other Federal agencies is established atthe scene of the emergency.Currently, the only communication function not conducted over the publicswitched network (PSN) is the Emergency Notification System (ENS), which ishandled over direct dedicated lines between each power reactor site and theNRC Operations Center. Experience has shown that the current emergencycommunications network does not provide assured paths for the remainingessential lines of communications. Given its emergency response mission, theNRC cannot afford to depend solely on the PSN for the remaining six essentialcommunications paths described in Enclosure 1. Although the overall design ofthe public network is intended to provide high reliability and alternaterouting, in the case of an emergency the overall traffic load in an area canreadily exceed local switching capabilities and result in blockage at thelocal central office. This is what occurred during the incidents at ThreeMile Island and at the Sequoyah Fuels Facility.In addition to the above, numerous other problems have led the NRC toits emergency telecommunications system. The most notable one is theand obsolescence of the equipment used for the ENS function.upgradeagingConsequently, an in-depth analysis was undertaken in 1988 to determine viablealternatives to the current system. Various options involving terrestrial andsatellite networks were examined. During 1990, a new communicationalternative became available when the General Services Administration (GSA)provided the Federal Telecommunications System (FTS) 2000 network forgovernment use, including locations at licensee facilities. The FTS 2000network offers not only a lower cost and more reliable system than ENS, but italso provides a separate government network for all of the essentialcommunication functions and it avoids the potential PSN blockage anticipatedduring a major emergency. NRC has concluded that conversion to the FTS 2000network is a necessary step at this time to maintain assured and reliablecommunications during an emergency as well as for licensee reporting of eventsduring normal operations. As a parallel effort, NRC is also assessing therisks associated with the sole use of the FTS 2000 network to determine if ar_0 ,int and/or diverse communications pathway is needed.c.910O9180197 27' -am Generic Letter 91-14-2 -September 23, 1991The installation of FTS 2000 lines at licensee's facilities will begin inSeptember 1991 and continue through March 1992. The degree of licenseesupport may vary depending on various site specific factors. Enclosure 2describes the licensee efforts that may be required, and the various factorswhich affect the required work. Following installation of the FTS 2000system, the equipment presently used for the ENS communication function willbe removed after successful performance of the new system is demonstrated overa sufficient period of time, currently anticipated to be approximately onemonth. Enclosure 3 is the current schedule for the installation of FTS 2000at each site. Licensees will be contacted in advance of the scheduled time toarrange for a mutually acceptable date. After installation of the FTS 2000lines to the site and in some cases to the offsite EOF, it is expected thatlicensees will complete the remaining installation effort as identified inEnclosure 2 within ninety days, however, in extenuating circumstances, such asthose cases in which a plant outage would be required to complete theinstallation, up to six months will be permitted.Licensees are being requested to make modifications to their facilities andprocedures and thus this request is considered a backfit in accordance withNRC procedures. The requested modifications are needed to ensure thatfacilities are in compliance with NRC regulations in 10 CFR 50.47(b) (6) and10 CFR 50, Appendix E, IV.E.9d. As discussed in 10 CFR 50.109 (a)(4)(i) forcompliance exceptions, a full backfit analysis was not performed. Adocumented evaluation of the type described in 10 CFR 50.109 (a) (6) wasperformed (Enclosure 4), including a statement of the objectives of and thereasons for the modification and the basis for invoking the complianceexception.Since this letter initiates no information gathering and requires no reply, noOMB clearance number is required.If you have any questions about this letter, please contact the technicalcontact listed below or the appropriate NRR Project Manager.Ja G. PartlowAss ciate Director for ProjectsOffice of Nuclear Reactor RegulationTechnical Contacts: T. Kellam, IRM(301) 492-8000T. Baldesi, IRM(301) 492-7121
Enclosures:
1. Essential Emergency Communication Functions2. Licensee Support for Upgrade to the EmergencyTelecommunications Systems3. Schedule for FTS 2000 Installations4. Documented Evaluation ENCLOSURE 1ESSENTIAL EMERGENCY COMMUNICATION FUNCTIONS1. Emergency Notification System (ENS): Initial notification by thelicensee, as well as ongoing information on plant systems, status, andparameters.2. Health Physics Network (HPN): Communication with the licensee onradiological conditions (in-plant and off-site) and meteorologicalconditions, as well as their assessment of trends and need forprotective measures on-site and off-site.3. Reactor Safety Counterpart Link (RSCL): Established initially with thebase team, and then with the NRC site team representatives once theyarrive at the site, to conduct internal NRC discussions on plant andequipment conditions separate from the licensee, and without interferingwith the exchange of information between the licensee and NRC. This isthe channel by which the NRC Operations Center supports NRC reactorsafety personnel at the site. In addition, this link may also be usedfor discussion between the Reactor Safety Team Director and licenseeplant management at the site.4. Protective Measures Counterpart Link (PMCL): Established initially withthe base team, and then with the NRC site team representatives once theyarrive at the site, to conduct internal NRC discussions on radiologicalreleases and meteorological conditions, and the need for protectiveactions separate from the licensee and without interfering with theexchange of information between the licensee and NRC. This is thechannel by which the NRC Operations Center supports NRC protectivemeasures personnel at the site, In addition, this link may also be usedfor discussion between the Protective Measures Team Director andlicensee plant management at the site.5. Emergency Response Data System (ERDS) Channel: This is the channel overwhich the raw reactor parametric data is transmitted from the site.6. Management Counterpart Link (MCL): Established for any internaldiscussions between the Executive Team Director or Executive Teammembers and the NRC Director of Site Operations or top level licenseemanagement at the site.7. Local Area Network (LAN) Access: Established with the base team and theNRC site team for access to any of the products or services provided onthe NRC Operations Center's local area network. This includes technicalprojections, press releases, status reports, E-Mail, and variouscomputerized analytical tool ENCLOSURE 2 LICENSEE SUPPORT FOR UPGRADE TOTHE EMERGENCY TELECOMMUNICATIONS SYSTEM1. Provide a point of contact and participate in the arrangements for theinstallation of the FTS 2000 lines.2. Provide adequate capacity at the demarcation distribution frame for7¢ to9 lines depending on the number of reactor units. For sites with anoffsite Emergency Operations Facility (EOF), provide capacity for anadditional 6 lines at the demarcation distribution frame serving theEOF.3. Provide adequate internal wiring (not routed through any onsiteswitching 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 allintermediate distribution frames and to the physical location associatedwith the FTS 2000 service being provided.5. Provide RJ-1l Jacks for the FTS 2000 communications functions identiftiein Enclosure 1 at the appropriate locations in the control.-rotomiFt Siroiand EOF. Attached is a list of typical locations for FTS 2000communications functions. .6. Install the NRC provided telephone instruments at the appropriatelocations as described herein.7. Relocate, as appropriate, the FTS 2000 phone used for the EmergencyNotification 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 FTS2000 system.10. For those sites including offsite EOF's where sufficient sparefacilities into the site are not available, the following support isrequired:a. Provide space as necessary for line multiplexing equipment to beinstalled by AT&T and NRC contractor.b. Provide guaranteed power to the equipment in accordance with thecriteria in IE Bulletin 80-1 ENCLOSURE 2 TYPICAL LOCATIONS FOR FTS 2000COMMUNICATION FUNCTIONSCONTROL ROOMENS (One extension per unit)TSC/EOF*NRC SPACE LICENSEE SPACEENS ENSHPN HPNRSCLPMCLMCLLAN-ACCESSERDSOne phone line per reactor unit should be run to the room(s) housing thecomputer(s) which will provide data to the Emergency Response DataSystem.* For those EOFs which cannot be served as extensions of the on-site FTS2000 service, a separate set of FTS 2000 lines will be provided. TheseEOFs will be bridged on to the various essential emergency communicationfunctions by calling into the NRC Operations Cente ENCLOSURE 3SCHEDULE FOR FTS 2000 INSTALLATIONSept. 1991ByronCookYogtleNov. 1991Big Rock PointBraidwoodBrunswickComanche PeakGinnaHarrisMaine YankeeSouth TexasTurkey PointJan. 1992Beaver ValleyBrowns FerryClintonDiablo CanyonDresdenFitzpatrickGrand GulfHatchHope CreekIndian Point (Con-Ed)Indian Point (PASNY)KewauneeLaSalleMcGuirePerrySeabrookSequoyahSurryTrojanFeb. 1992ArkansasCallawayCal vert Cli ff sCatawbaCooperCrystal RiverDuane ArnoldFarleyHaddam NeckLimerickNine Mile PointPalisadesPrairie IslandRiver BendSt. LucieSummerWNP-2WaterfordWolf CreekZionMar. 1992Davis-BesseFermiFt. CalhounMillstoneMonticelloNorth AnnaOconeeOyster CreekPalo VerdePeach BottomPilgrimPoint BeachQuad CitiesRobinsonSalemSusquehannaThree Mile IslandVermont YankeeYankee RoweSan Onofre -FTS 2000 service previously installed.remain to be completed.Items 3-9 of Enclosure 2 ENCLOSURE 4Documented EvaluationEMERGENCY TELECOMMUNICATIONS GENERIC LETTERObjectives:To ensure that power reactor facilities remain in compliance with therequirements of 10 CFR 50.47 (b)(6) and 10 CFR Part 50, Appendix E, IV.E.9dregarding emergency telecommunications capabilities.Reasons for Modifications:An upgrade to the NRC emergency telecommunications system is necessary toprovide a reliable and assured means to conduct the essential communicationsrequired during an emergency. The current system utilizes a single dedicatedline (ENS) and the Public Switched Network (PSN) for communication with thelicensee's emergency response facilities. The equipment associated with theENS is rapidly deteriorating, and reliance cannot be placed on the PSN toprovide communications paths due to the high probability of blockage in thetelephone company central office serving the site during a serious emergency.Similar blockage was experienced during the accidents at Three Mile Island in1979 and the Sequoyah Fuel Facility in 1986.Basis for Invokinq the Compliance Exception:Licensees are required by 10 CFR 50.47 (b) (6) and 10 CFR Part 50, Appendix E,IV.E. 9d to have provisions for (a) prompt communications among principal ,response organizations, and (b) communications with NRC Headquarters from thenuclear power reactor control room, the technical support center, and theemergency operations facility. In addition, the use of the ENS is clearlycalled for in numerous parts of the regulations (e.g., 10 CFR 50.72). Sincethe current ENS is on a dedicated line, it is not subject to blockage due tocrowded public switching networks during an emergency. However, the ENS wasinitially designed by AT&T using equipment manufactured by WesCom, Inc. Afterdivestiture, WesCom sold the rights to this equipment and design to Tellabs,Inc. Tellabs no longer manufactures WesCom equipment and the existing WesComequipment supporting the ENS is becoming increasingly unreliable. In additionto these equipment reliability concerns, NRC recently experiencedcommunication problems during the agency's response to a 1990 event at theVogtle facility which raised further questions as to operational readiness ofENS. After May 1992 NRC's contract with AT&T expires. GSA has mandatedFederal agencies convert to FTS-2000 and, consequently, the contract will notbe renewed. As a result, the ENS required explicitly by regulation can nolonger be practically maintained; therefore, licensees will be unable todemonstrate compliance with the requirement for that communication link withNRC in the absence of an acceptable alternative. The NRC has determined thatFTS-2000 is sufficiently reliable to be an acceptable alternative for ENSpurposes; and it is less costly than the other available alternatives (e.g.,satellite link, microwave link, foreign exchange line, etc.)
-2 -Installation of the Emergency Response Data System (ERDS) is required by anAugust 13, 1991, amendment to 10 CFR 50.72. Installation is already completeat ten facilities who had implemented ERDS on a voluntary basis prior toissuance of the regulation. Upgrading of ERDS, now required by regulation, isalready underway; the proposed action is consistent with the upgrade effort.It has been previously determined that provision of five other essentialcommunications links (i.e., Reactor Safety Counterpart Link (RSCL), HealthPhysics Network (HPN), Protective Measures Counterpart Link (PMCL), ManagementCounterpart Link (MCL), and Operations Center Local Area Network Access Link(LAN)), in addition to the ENS and ERDS, is an acceptable means for licenseesto comply with the general requirement to establish reliable emergencycommunications with NRC. The essential communication needs have beenrepeatedly addressed in previous Commission papers (SECY-87-290, SECY-89-340,SECY-91-149) and NUREG-0696, Functional Criteria for Emergency ResponseFacilities. The staff has determined in connection with this proposed actionthat, in order to ensure the reliability of overall emergency communicationscapability and complete compatibility among the component parts of the overallsystem, the RSCL, HPN, PMCL, MCL, and LAN should also be upgraded by use ofFTS-2000.Accordingly, the NRC has concluded that conversion to the FTS 2000 network isa necessary step at this time to maintain assured and reliable communicationsduring an emergency as well as for licensee reporting of events during normaloperations. Therefore, in order to maintain continued compliance with 10 CFR50.47 (b)(6) and 10 CFR Part 50, Appendix E, IV.E. 9d, licensees are requestedto provide the modifications necessary to support installation and operationof the emergency telecommunications system upgrad ENCLOSURE 5LIST OF RECENTLY ISSUED GENERIC LETTERSGeneric Date ofLetter No. __ Subject Issuance Issued To- ------------91-1391-1291-1191-10REQUEST FOR INFO RELATEDTO RESOLUTION OF GI-130,"ESSENTIAL SERVICE WATERSYS. FAILURES AT MUTLI-UNIT SITES " PURSUANT TO1OCFR50.541f)OPERATOR LICENSING NAT.EXAMINATION SCHEDULERESOLUTION OF GENERICISSUES 48, "LCOs FOR CLASSlE VITAL INSTRUMENT BUSES,"and 49, "INTERLOCKS AND LCOsFOR CLASS 1E TIE BREAKERS"PURSUANT TO 10CFR50.54(f)EXPLOSIVES SEARCHES ATPROTECTED AREA PORTALSINDIVIDUAL PLANT EXAMINATIONOF EXTERNAL EVENTS (IPEEE)FOR SEVERE ACCIDENT VULNERA-BILITIES -10 CFR 50.54 (f)MODIFICATION OF SURVEILLANCEINTERVAL FOR THE ELECTRICALPROTECTIVE ASSEMBLIES INPOWER SUPPLIES FOR THEREACTOR PROTECTION SYSTEMREMOVAL OF COMPONENT LISTSFROM TECHNICAL SPECIFICA-TIONSGI-23 "REACTOR COOLANTPUMP SEAL FAILURES" ANDITS POTENTIAL IMPACT ONSTATION BLACKOUTRESOLUTION OF GENERIC ISSUEA-30, "ADEQUACY OF SAFETY-RELATED DC POWER SUPPLIEDPURSUANT TO 10 CFR 50.54(f)09/19/9108/27/9107/18/9107/08/9106/28/9106/27/9105/06/9105/02/9104/29/91LICENSEES AND APPLI-CANTS of Braidwood, ByronCatawba, Comanche PeakCook, Diablo, McGuireALL PWR REACTORAND APPLICANTS FORAN OPERATING LICENSEALL HOLDERS OFOPERATING LICENSESTO ALL FUEL CYCLEFACILITY LICENSEESWHO POSSESS, USE,IMPORT OR EXPORTFORMULA QUANTITIESOF STRATEGIC SPECIALNUCLEAR MATERIALALL HOLDERS OFOLs AND CPs FORNUCLEAR POWERREACTORSALL HOLDERS OFOLs FOR BWRsALL HOLDERS OF OLsOR CPs FOR NUCLEARPOWER REACTORSALL POWER REACTORLICENSEES ANDHOLDERS OF CPsALL HOLDERS OF OLs88-20SUPP. 491-0991-0891-0791-06 Generic Letter 91-14-2 -September 23, 1991The installation of FTS 2000 lines at licensee's facilities will begin inSeptember 1991 and continue through March 1992. The degree of licenseesupport may vary depending on various site specific factors. Enclosure 2describes the licensee efforts that may be required, and the various factorswhich affect the required work. Following installation of the FTS 2000system, the equipment presently used for the ENS communication function willbe removed after successful performance of the new system is demonstrated overa sufficient period of time, currently anticipated to be approximately onemonth. Enclosure 3 is the current schedule for the installation of FTS 2000at each site. Licensees will be contacted in advance of the scheduled time toarrange for a mutually acceptable date. After installation of the FTS 2000lines to the site and in some cases to the offsite EOF, it is expected thatlicensees will complete the remaining installation effort as identified inEnclosure 2 within ninety days, however, in extenuating circumstances, such asthose cases in which a plant outage would be required to complete theinstallation, up to six months will be permitted.Licensees are being requested to make modifications to their facilities andprocedures and thus this request is considered a backfit in accordance withNRC procedures. The requested modifications are needed to ensure thatfacilities are in compliance with NRC regulations in 10 CFR 50.47(b) (6) and10 CFR 50, Appendix E, IV.E.9d. As discussed in 10 CFR 50.109 (a)(4)(i) forcompliance exceptions, a full backfit analysis was not performed. Adocumented evaluation of the type described in 10 CFR 50.109 (a) (6) wasperformed (Enclosure 4), including a statement of the objectives of and thereasons for the modification and the basis for invoking the complianceexception.Since this letter initiates no information gathering and requires no reply, noOMB clearance number is required.If you have any questions about this letter, please contact the technicalcontact listed below or the appropriate NRR Project Manager.James G. PartlowAssociate Director for ProjectsOffice of Nuclear Reactor RegulationTechnical Contacts:T. Kellam, IRM(301) 492-8000T. Baldesi, IRM(301) 492-7121IR eJRJoliOS/>ffi/
Enclosures:
1.- Essential Emergency Communication2. Licensee Support for Upgrade to thTelecommunications Systems3. Schedule for FTS 2000 Installation4. Documented Evaluation§ OE0D IR F A:AEOD IRB:Y A:AEODi oeur 6&RFPriebe W0Iejsman'91 ms /-./9 I 91DISTRIBUTION (W/ENCLS)Central filesNRC PDR-1RB R/F -JRJolicoeurFunctionsle EmergencyIsD:D AEOD JJ:DCTS TGC 6 bANRR:ADPR jRLSj sard FGKruzic STreb P JGPartlogU'///91 -91 91+1910949/91