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.
.
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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.
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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.
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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.
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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.
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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.)
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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.
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