RenewalHeadset NUC

0257-EX-RR-2008 Text Documents

Florida Power and Light Company

2008-12-11ELS_95145

EXHIBIT TO EXPERIMENTAL LICENSE RENEWAL APPLICATION

A. Background.

During the spring time of 2007, the Nuclear Energy Institute (“NEI”), the Utilities Telecoms
Council (“UTC”), Maximum Service Television (“MSTV”), the National Association of
Broadcasters (“NAB”), and the Society of Broadcasters (“SBE”) agreed to a Consensus Plan
through which the nuclear plants were permitted to continue to use certain communications
equipment, subject to certain power restrictions, geographic limitations, frequency coordination
and FCC reporting requirements (the “Consensus Plan”).

The FCC issued experimental licenses to the nuclear plants beginning in the summer of 2007
(the “Experimental Licenses”). These Experimental Licenses have been operated consistent with
the Consensus Plan but will expire on February 17, 2009. Applicant seeks to renew its
Experimental License.

As also described in the original application for Experimental License, communication inside
and around a nuclear reactor is a great challenge, not only because the walls can range in width
from 4 inches to 4 feet of concrete and the built-in shielding of the reactor dome tends to serve as
a deflector of certain wireless communications, but also because the need for reliable and
effective communication is so critical. Under Nuclear Regulatory Commission (“NRC”) rules,
licensed plants have the regulatory and licensing obligation to “make every reasonable effort to
maintain exposure to radiation as far below NRC-established dose limits as is practical . . . (see
10 C.F.R. § 20.1003 et seq.) in order to protect plant workers from harmful doses of radiation
(e.g., while they perform safety and maintenance operations in and around the nation’s nuclear
plants).

The commercial nuclear industry’s use of certain Telex wireless intercom equipment (the
“Equipment”) serves the twin objectives of effective communication and facilitating protection
of workers from unhealthy levels of radiation by providing communications features (wireless,
hands-free, full duplex/multi-user, reliable, no “call drops,” no background noise, no inadvertent
actuation, uninterrupted voice transmission, ease of use, and durability) that permit plant workers
to efficiently conduct routine maintenance as well as activities required to be performed in an
“outage” (when used (irradiated) fuel is replaced with fresh (non-irradiated) fuel and the used
fuel is carefully moved to storage facilities). That is, the Equipment directly contributes to the
protection of the health and safety of plant workers, as efficiencies gained from its use limit
nuclear plant workers’ occupational exposure.

B. Proposed Experiments.

The plants intend to continue to conduct experiments using the Equipment, as well as other
equipment that may serve as alternatives to the Equipment, through which they will establish a
series of situational communications objectives within and around the plant and track the
operating performance benchmarks for each objective. As previously reported by NEI, UTC and
the plants in their License Reports, at least five (5) different types of alternative equipment
during the license term, however, no suitable alternative equipment is currently available.

Error! Unknown document property name.

The specific objectives to be accomplished:

1. Continued efforts to prioritize the operating features of the Equipment in order to
inform our RFP on replacement equipment.

2. Continued efforts to establish performance benchmarks and power matrix in order to
inform our RFP.

3. Continued efforts to evaluate new equipment entrants against the priorities and
benchmarks established using the Equipment.

4. Creation of best practices generally for communicating in and around the nuclear
plants, both with the Equipment and other equipment and methods.

5. Of particular interest is the simultaneous operation in many of the plants of the
Equipment (together with all potential replacement equipment) and the electronic
dosimeters, most of which operate at 2.4 GHz. Electronic dosimeters are worn by
many plant employees while they participate in operations involving exposure to
radiation. The dosimeter device measures the dose in real time and transmits the
readings back to the communications control center, which is also the venue from
which the safety experts communicate, via the Equipment, with the plant employees.
In fact, it is often the case that the communication via the Equipment is to instruct the
plant worker to move one way or another, in order to avoid areas where the dosimeter
indicates there exist high doses of radiation.

While the simultaneous use of the Equipment with the 2.4 GHz dosimeter devices has
not caused interference to either device (or, worse, caused one or both to shut down),
the experiment will allow certain plants to test other equipment operating at the 2.4
GHz band to evaluate whether it can operate simultaneously with the dosimeter
device. It will be important to experiment on the best practices for such simultaneous
operation and to determine, as best one can, how far apart on the spectrum chart these
often simultaneous transmissions must be, in order to avoid interference/shut-down.

C. Continuing Need.

The plants need to continue conducting experiments comparing the Equipment and potential
replacement equipment against a series of situational communications objectives within and
around the plant. This program of experimentation continues to contribute to the development,
extension, expansion and utilization of the radio frequency because there has not previously been
a full study of best communications practices inside and around nuclear plants. Continued
authorization of the Equipment will allow the plants to further their research and development of
best practices. This fact, together with the NRC mandates and the compelling desire to protect
plant workers from unhealthy doses of radiation, will contribute to the development of
alternative equipment that may be capable of operating under Part 90 and meeting the plants’
safety and communications needs. Continued authorization of the Equipment will allow the
plants to further their objectives as plant equipment changes.

Error! Unknown document property name.

Error! Unknown document property name.

Document Created: 2008-12-11 11:56:58
Document Modified: 2008-12-11 11:56:58

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC