Emergency Telecommunications (Generic Letter 91-14)

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 
telecommunications system.  Some level of licensee effort and cooperation 
will be required for successful implementation of this program.

In the event of a serious emergency at a nuclear power reactor site, the NRC 
considers it essential that certain communication pathways are established 
and maintained in order for the agency to fulfill its emergency response 
mission.  NRC has identified seven communications functions (Enclosure 1) 
which are essential, particularly in the early phases of an accident, until 
an augmented response effort by NRC personnel and other Federal agencies is 
established at the scene of the emergency.

Currently, the only communication function not conducted over the public 
switched network (PSN) is the Emergency Notification System (ENS), which is 
handled over direct dedicated lines between each power reactor site and the 
NRC Operations Center.  Experience has shown that the current emergency 
communications network does not provide assured paths for the remaining 
essential lines of communications.  Given its emergency response mission, 
the NRC cannot afford to depend solely on the PSN for the remaining six 
essential communications paths described in Enclosure 1.  Although the 
overall design of the public network is intended to provide high reliability 
and alternate routing, in the case of an emergency the overall traffic load 
in an area can readily exceed local switching capabilities and result in 
blockage at the 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 its emergency telecommunications system.  The most notable one is 
the aging and obsolescence of the equipment used for the ENS function.

Consequently, an in-depth analysis was undertaken in 1988 to determine 
viable alternatives to the current system.  Various options involving 
terrestrial and satellite networks were examined.  During 1990, a new 
communication alternative became available when the General Services 
Administration (GSA) provided the Federal Telecommunications System (FTS) 
2000 network for government use, including locations at licensee facilities.  
The FTS 2000 network offers not only a lower cost and more reliable system 
than ENS, but it also provides a separate government network for all of the 
essential communication functions and it avoids the potential PSN blockage 
anticipated during a major emergency.  NRC has concluded that conversion to 
the FTS 2000 network is a necessary step at this time to maintain assured 
and reliable communications during an emergency as well as for licensee 
reporting of events during normal operations.  As a parallel effort, NRC is 
also assessing the risks associated with the sole use of the FTS 2000 
network to determine if a redundant and/or diverse communications pathway is 
needed. 
.

                                     - 2 -


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
                  (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
                                                  Page 1 of 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 for 7 
     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-11 jacks for the FTS 2000 communications functions 
     identified in Enclosure 1 at the appropriate locations in the control 
     room, TCS, 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
                                        Page 2 of 2
                                                  

                         TYPICAL LOCATIONS FOR FTS 2000
                             COMMUNICATION FUNCTIONS

                                  CONTROL ROOM


ENS (One extension per unit)

                         TSC/EOF*

     NRC SPACE                          LICENSEE SPACE
     
     ENS                                     ENS
     HPN                                     HPN
     RSCL
     PMCL
     MCL
     LAN-ACCESS

                           ERDS

One phone line per reactor unit should be run to the room(s) housing the 
computer(s) which will provide data to the Emergency Response Data    
System.






*    For those EOFs which cannot be served as extensions of the on-site FTS     
     2000 service, a separate set of FTS 2000 lines will be provided.  These 
     EOFs will be bridged on to the various essential emergency 
     communication functions by calling into the NRC Operations Center. 
     .     

ENCLOSURE 3

                      SCHEDULE FOR FTS 2000 INSTALLATION


Sept. 1991

Byron
Cook

Vogtle
.

Nov. 1991

Big Rock Point
Braidwood
Brunswick
Comanche Peak
Ginna
Harris
Maine Yankee
South Texas
Turkey Point
.

Jan. 1992

Beaver Valley
Browns Ferry
Clinton
Diablo Canyon
Dresden
Fitzpatrick
Grand Gulf
Hatch
Hope Creek
Indian Point (Con-Ed)
Indian Point (PASNY)
Kewaunee
LaSalle
McGuire
Perry
Seabrook
Sequoyah
Surry
Trojan
.

Feb. 1992

Arkansas
Callaway
Calvert Cliffs
Catawba
Cooper
Crystal River
Duane Arnold
Farley
Haddam Neck
Limerick
Nine Mile Point
Palisades
Prairie Island
River Bend
St. Lucie
Summer
WNP-2
Waterford
Wolf Creek
Zion
.

Mar. 1992

Davis-Besse
Fermi
Ft. Calhoun
Millstone
Monticello
North Anna
Oconee
Oyster Creek
Palo Verde
Peach Bottom
Pilgrim
Point Beach
Quad Cities
Robinson
Salem
Susquehanna
Three Mile Island
Vermont Yankee
Yankee Rowe
__________________
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:

To ensure that power reactor facilities remain in compliance with the 
requirements of 10 CFR 50.47 (b)(6) and 10 CFR Part 50, Appendix E, IV.E.9d 
regarding emergency telecommunications capabilities.

Reasons for Modifications:

An upgrade to the NRC emergency telecommunications system is necessary to 
provide a reliable and assured means to conduct the essential communications 
required during an emergency.  The current system utilizes a single 
dedicated line (ENS) and the Public Switched Network (PSN) for communication 
with the licensee's emergency response facilities.  The equipment associated 
with the ENS is rapidly deteriorating, and reliance cannot be placed on the 
PSN to provide communications paths due to the high probability of blockage 
in the telephone company central office serving the site during a serious 
emergency.  Similar blockage was experienced during the accidents at Three 
Mile Island in 1979 and the Sequoyah Fuel Facility in 1986.

Basis for Invoking 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 
the nuclear power reactor control room, the technical support center, and 
the emergency operations facility.  In addition, the use of the ENS is 
clearly called for in numerous parts of the regulations (e.g., 10 CFR 
50.72).  Since the current ENS is on a dedicated line, it is not subject to 
blockage due to crowded public switching networks during an emergency.  
However, the ENS was initially designed by AT&T using equipment manufactured 
by WesCom, Inc.  After divestiture, WesCom sold the rights to this equipment 
and design to Tellabs, Inc.  Tellabs no longer manufactures WesCom equipment 
and the existing WesCom equipment supporting the ENS is becoming 
increasingly unreliable.  In addition to these equipment reliability 
concerns, NRC recently experienced communication problems during the 
agency's response to a 1990 event at the Vogtle facility which raised 
further questions as to operational readiness of ENS.  After May 1992 NRC's 
contract with AT&T expires.  GSA has mandated Federal agencies convert to 
FTS-2000 and, consequently, the contract will not be renewed.  As a result, 
the ENS required explicitly by regulation can no longer be practically 
maintained; therefore, licensees will be unable to demonstrate compliance 
with the requirement for that communication link with NRC in the absence of 
an acceptable alternative.  The NRC has determined that FTS-2000 is 
sufficiently reliable to be an acceptable alternative for ENS purposes; 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 an 
August 13, 1991, amendment to 10 CFR 50.72.  Installation is already 
complete at ten facilities who had implemented ERDS on a voluntary basis 
prior to issuance of the regulation.  Upgrading of ERDS, now required by 
regulation, is already underway; the proposed action is consistent with the 
upgrade effort.

It has been previously determined that provision of five other essential 
communications links (i.e., Reactor Safety Counterpart Link (RSCL), Health 
Physics Network (HPN), Protective Measures Counterpart Link (PMCL), 
Management Counterpart Link (MCL), and Operations Center Local Area Network 
Access Link (LAN)), in addition to the ENS and ERDS, is an acceptable means 
for licensees to comply with the general requirement to establish reliable 
emergency communications with NRC.  The essential communication needs have 
been repeatedly addressed in previous Commission papers (SECY-87-290, 
SECY-89-340, SECY-91-149) and NUREG-0696, Functional Criteria for Emergency 
Response Facilities.  The staff has determined in connection with this 
proposed action that, in order to ensure the reliability of overall 
emergency communications capability and complete compatibility among the 
component parts of the overall system, the RSCL, HPN, PMCL, MCL, and LAN 
should also be upgraded by use of FTS-2000.

Accordingly, the NRC has concluded that conversion to the FTS 2000 network 
is a necessary step at this time to maintain assured and reliable 
communications during an emergency as well as for licensee reporting of 
events during normal operations.  Therefore, in order to maintain continued 
compliance with 10 CFR 50.47 (b)(6) and 10 CFR Part 50, Appendix E, IV.E. 
9d, licensees are requested to provide the modifications necessary to 
support installation and operation of the emergency telecommunications 
system upgrade.