Text

Proposed Emergency Plan Revision, Relocation of the Technical Support Center
	ML23013A195
Person / Time
Site:	North Anna
Issue date:	01/13/2023
From:	James Holloway; Virginia Electric & Power Co (VEPCO)
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	22-036
	Download: ML23013A195 (1)
	v • d • e

VIRGINIA E LECTRIC AND P OWER COMPANY RICHMOND, V IRGINIA 23261 January 13, 2023 10 CFR 50.54(q) 10 CFR 50.90 U.S. Nuclear Regulatory Commission Serial No.: 22-036 Attention: Document Control Desk NRA/GDM: RO Washington, DC 20555-0001 Docket Nos.: 50-338/339 License Nos.: NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 PROPOSED EMERGENCY PLAN REVISION - RELOCATION OF TH E TEC HNICAL SUPPORT CENTER Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion Energy Virginia) is submitting a license amendment request (LAR) to revise the North Anna Power Station (NAPS) Units 1 and 2 Emergency Plan. Specifically, the proposed change will relocate the Technical Support Center (TSC) from its current location adjacent to the Main Control Room (MCR) to the building outside the Protected Area (PA) previously used as the site Local Emergency Operations Facility (LEOF). This building is physically connected to the Simulator Building and on the grounds of the North Anna Training Center. Relocating the TSC will enable Dominion Energy Virginia to provide more effective technical support during an emergency because the relocated facility contains an equivalent floor space and incorporates enhanced human factors design considerations. In addition, relocating the TSC outside the PA will improve the timeliness of TSC activation for emergency events that occur during non-standard working hours, while maintaining the capability to promptly activate the TSC during normal working hours. Technical and functional analyses of the continuing TSC capabilities is described in Attachment 1. These analyses demonstrate that the relocated TSC continues to meet the functional capabilities of NUREG-0696, Functional Criteria for Emergency Response Facilities, and NUREG-0737, Supplement 1, Clarification of TM/ Action Plan Requirements.

Because the future TSC will be located outside the PA and is greater than a two-minute walk to the MCR, the proposed change is considered a reduction in Emergency Plan effectiveness as defined in 10 CFR 50.54(q)(1 )(iv). In accordance with 10 CFR 50.54(q)(4), changes to the emergency plan that reduce effectiveness of the plan may not be implemented without prior Nuclear Regulatory Commission (NRC) approval.

Therefore, the proposed change is being submitted as an LAR in accordance with 10 CFR 50.90. A description and assessment of the proposed change are provided in . The marked-up NAPS Emergency Plan pages indicating the proposed change are provided in Attachment 2.

Dominion Energy Virginia has evaluated the proposed amendment and determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92. The basis for this determination is included in Attachment 1. Dominion Energy Virginia has

Serial No.: 22-036 Docket Nos.: 50-338/339 Page 2 of 3 also determined that operation with the proposed change will not result in any significant increase in the quantity of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9), and, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change.

In accordance with 10 CFR 50.91, Dominion Energy Virginia is notifying the Commonwealth of Virginia of this LAR by transmitting a copy of this letter to the designated state official.

NRC approval of the LAR is requested by January 15, 2024. Should you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.

Respectfully, James E. Holloway Vice President - Nuclear Engineering and Fleet Support Commitments contained in this letter: None.

Attachments

1. Description and Assessment of the Proposed Change

2. Marked-Up NAPS Emergency Plan Pages COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by James E. Holloway, who is Vice President - Nuclear Engineering and Fleet Support, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this } 3+h day of } lttt ua ~y ,2023.

My Commission Expires: 1.2./.31/~+

CRAIG D SLY Notary Public Commonwealth of Virginia Reg. # 7518653 Notary Public My Commission Expires December 31, 20:j

Serial No.: 22-036 Docket Nos.: 50-338/339 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission - Region II Attn: Regional Administrator Marquis One Tower 245 Peachtree Center Avenue, NE., Suite 1200 Atlanta, Georgia 30303-1257 Mr. G. Edward Miller NRC Senior Project Manager - North Anna Power Station U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. L. John Klos NRC Project Manager - Surry Power Station U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 NRC Senior Resident Inspector North Anna Power Station State Health Commissioner Virginia Department of Health James Madison Building - 7th floor 109 Governor Street, Suite 730 Richmond, Virginia 23219

Serial No.22-036 Docket Nos.: 50-338/339 NAPS TSC Relocation LAR Attachment 1 DESCRIPTION AND ASSESSMENT OF TH E PROPOSED CHANGE Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station Units 1 and 2

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 1 of 30 Table of Contents 1.0

SUMMARY

DESCRIPTION ...................................................................................2 2.0 DETAILED DESCRIPTION ....................................................................................2

2.1 PROPOSED CHANGE

.......................................................................................2 2.2 REASON FOR THE PROPOSED CHANGE ......................................................3 2.3 NAPS EMERGENCY PLAN BACKGROUND .....................................................3 3.0 TECHN ICAL EVALUATION ..................................................................................5

3.1 TECHNICAL ANALYSIS

.....................................................................................5 3.1.1 FUNCTION ..................................................................................................5 3.1.2 LOCATION ..................................................................................................6 3.1.3 STAFFING AND TRAINING ........................................................................6 3.1.4 SIZE ........................ .....................................................................................8 3.1.5 STRUCTURE...............................................................................................9 3.1.6 HABITABILITY ........................................................................................... 10 3.1.7 COMMUNICATIONS ................................................................................. 14 3.1.8 TSC POWER SUPPLIES .......................................................................... 15 3.1.9 TECHNICAL DATA, DATA SYSTEMS, AND DATA SYSTEM EQUIPM ENT

...................................................................................................................16 3.1.10 RECORDS AVAILABILITY AND MANAGEMENT ..................................... 18

3.2 CONCLUSION

S ...............................................................................................19

4.0 REGULATORY EVALUATION

............................................................................19 4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA ........................... 19 4.2 PRECEDENT....................................................................................................25 4.3 NO SIGNIFICANT HAZARDS CONSIDERATIONS DETERMINATION ........... 25

4.4 CONCLUSION

..................................................................................................27

5.0 ENVIRONMENTAL CONSIDERATION

...............................................................27

6.0 REFERENCES

....................................................................................................28

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 2 of 30 1.0

SUMMARY

DESCRIPTION Virginia Electric and Power Company (Dominion Energy Virginia) proposes a revision to the North Anna Power Station (NAPS) Units 1 and 2 Emergency Plan to relocate the Technical Support Center (TSC) from its current location adjacent to the Main Control Room (MCR) to the building outside the Protected Area (PA) previously used as the site Local Emergency Operations Facility (LEOF). This change proposes alternative means of performing TSC functions than those identified in the NUREG-0696 [Reference 1] and NUREG-0737, Supplement 1 [Reference 2], guidance related to facility location.

Specifically, the affected TSC functions include:

the TSC will be located near the MCR to facilitate face-to-face communications between the TSC and control room personnel,

the walking time from the TSC to the MCR does not exceed two minutes,

there will be no major security barriers between the two facilities, and

the TSC is located within the site protected area so as to facilitate necessary interaction with MCR, OSC, EOF, and other personnel involved with the emergency.

The change to TSC location is considered a reduction in Emergency Plan effectiveness as defined in 10 CFR 50.54(q)(1)(iv) [Reference 3]. In accordance with 10 CFR 50.54(q)(4) [Reference 3], changes to a licensee's emergency plan that reduce the effectiveness of the plan may not be implemented without prior Nuclear Regulatory Commission (NRC) approval and are being submitted as a license amendment request (LAR) in accordance with 10 CFR 50.90 [Reference 4].

2.0 DETAILED DESCRIPTION 2.1 Proposed Change The proposed change to the Emergency Plan is briefly detailed below, and the justification for the change is provided in Section 3.1. The specific wording changes are provided in as marked-up Emergency Plan pages.

a. Section 1.0, "Definitions," revised the details on TSC location to reflect the proposed change.

b. Section 7.1.3, "Technical Support Center," revised to reflect the new location of the TSC.

c. Section 7.2.1.4, "Sound Powered Telephone System," deleted in accordance with the proposed change.

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 3 of 30

d. Table 7.1, "ERF Communications," revised the list to remove reference to sound powered phones in accordance with the proposed change.

2.2 Reason for the Proposed Change NAPS is seeking to extend plant operation to 80 years under Subsequent License Renewal (SLR). In support of this effort, the station is modernizing the MCR, and a new digital platform is planned for installation as part of SLR to achieve that objective. The new Non-Safety Related (NSR) Controls Platform requires a centralized location within the PA to interface with the plant's various systems. The existing TSC has been selected as the centralized location for the new Non-Safety Controls Platform due to its close proximity to the MCR and the existing Plant Computer System (PCS). To support this activity, NAPS proposes relocation of the TSC to the location formerly used for the LEOF.

The proposed facility will be functionally equivalent to the existing TSC. It will be equivalent in size to the existing TSC, and the existing TSC layout will be replicated for ease of transition to the new facility. The new facility will support additional video display capabilities to enhance intra-facility data and information sharing. The proposed TSC will also provide enhanced power capabilities with a dedicated diesel generator backup with auto transfer on loss of normal power that works in conjunction with an Uninterruptible Power Supply (UPS) to ensure continuity of TSC operations. Because the sound powered telephone system is not capable of communicating over long distances, and the TSC will be located outside the PA, the TSC will no longer rely on a sound powered telephone system for back-up emergency communications. Details associated with the revised TSC location, and a functional analysis of design and functions associated with the TSC as prescribed in NUREG-0654, Revision 1 (Reference 5), NUREG-0696, Revision 1 (Reference 1), and NUREG-0737, Supplement 1, (Reference 2) are provided in Section 3.1.

2.3 NAPS Emergency Plan Background The NAPS Emergency Plan was preliminarily approved in NUREG-0053, Safety Evaluation Report related to the operation of North Anna Power Station Units 1 and 2, dated June 1976 (Reference 6).

The NAPS Emergency Plan was approved in NUREG-0053, Supplement 2, dated August 1976 (Reference 7).

The NAPS Emergency Plan was approved in NUREG-0053, Safety Evaluation Report related to the operation of North Anna Power Station, Unit 2, Supplement 11, dated August 1980 (Reference 8). The SER addressed the interim location for the TSC and approved the use of the sound powered telephone system for communications in the TSC.

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 4 of 30 The NAPS Emergency Plan, Revision 0, dated July 22, 1982, which implemented recommended corrective actions resulting from a February 1982 NRC emergency preparedness appraisal, identified an interim TSC in the Records Building and included a description of the sound powered telephone system (Reference 9).

On May 10, 1983, the NRC issued a letter acknowledging completion of NUREG-0737 TMI Action items including establishment of the interim TSC (Reference 10).

On May 25, 1987, the NRC issued a letter acknowledging completion of NUREG-0737 TMI Action items including establishment of the TSC (Reference 11 ).

The NAPS Emergency Plan, Revision 10, dated May 15, 1986, (Reference 12) implemented the reference to the permanent TSC that was established adjacent to the control room in accordance with NUREG-0696. This revision also changed information related to the sound powered telephone system and added Table 7.1, ERF Communications.

NAPS Emergency Plan, Revision 12, dated October 2, 1989, (Reference 13) implemented the Emergency Response Facility Computer System (ERFCS).

NAPS Emergency Plan, Revision 14, dated August 31, 1992, (Reference 14) implemented an augmentation goal of 60 minutes for the Core and Thermal Hydraulics Engineer position in the TSC as approved by the NRC in a letter dated May 18, 1990 (Reference 15).

NAPS Emergency Plan, Revision 18, dated January 3, 1996, (Reference 16) established augmentation goals of 45 and 60 minutes as approved by the NRC in a letter dated December 12, 1995 (Reference 17).

NAPS Emergency Plan, Revision 27, dated December 18, 2002, (Reference 18) implemented the PCS that replaced the ERFCS.

NAPS Emergency Plan, Revision 48, dated May 1, 2019, (Reference 19) implemented a Corporate Emergency Response Center (CERC) to replace the onsite LEOF for NAPS as approved by NRC SER dated February 27, 2019 (Reference 20). This revision provided the opportunity for re-purposing the onsite LEOF.

Revision 52 is the current version of the NAPS Emergency Plan (Reference 21).

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 5 of 30

3.0 TECHNICAL EVALUATION

3.1 Technical Analysis

3. 1. 1 Function NUREG-0696 (Reference 1), Section 2.1, requires that the onsite Technical Support Center (TSC) provide for the following functions:

Provide plant management and technical support to the plant operations personnel during emergency conditions;

Relieve the reactor operators of peripheral duties and communications not directly related to reactor system manipulations;

Prevent congestion in the control room; and

Perform EOF functions for the Alert emergency class, the Site Area Emergency class, and the General Emergency class until the EOF is functional.

These criteria are also cited in NUREG-0737, Supplement 1 (Reference 2), Section 8.2.1.a.

a. Revision 10 of the NAPS Emergency Plan (Reference 12) identified a TSC located in an area adjacent to the Control Room for the staffing of support positions in response to a significant emergency event. The support positions included a Station Emergency Manager, Operations, Engineering, and Communications personnel. The TSC staff was responsible for relieving Control Room personnel of communications and emergency response actions and performed these actions until the LEOF was activated.

b. Revision 52 of the NAPS Emergency Plan (Reference 21) maintains the location and functions specified in Revision 10 in accordance with NUREG-0696 (Reference 1).

c. The proposed change relocates the TSC to the building previously used to house the LEOF. From the proposed TSC, the NAPS ERO will provide plant management and technical support to plant operations personnel during emergency conditions; relieve reactor operators of peripheral duties and communications not directly related to reactor system manipulations; prevent congestion in the control room; and perform TSC functions as described in NUREG-0696 (Reference 1), NUREG-0737 Supplement 1 (Reference 2), and Revision 52 of the NAPS Emergency Plan (Reference 21). Times for assuming TSC functions are not impacted by the proposed change and are addressed in Section 3.1.3. As a result, the proposed change does not adversely impact the TSC function.

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 6 of 30 3.1.2 Location NUREG-0696 (Reference 1), Section 2.2, states that the TSC be located as close as possible to the MCR with no major security barriers between the TSC and MCR, and within two minutes walking time between the TSC and MCR. The stated purpose for this location was to facilitate face-to-face communications between the TSC and MCR to ensure effective communications and access to MCR information not available on the TSC data system. NUREG-0737, Supplement 1 (Reference 2), Section 8.2.1.b, references the need to locate the facility within the protected area to facilitate interaction with MCR, OSC, EOF and other personnel involved with the emergency.

a. Revision 10 of the NAPS Emergency Plan (Reference 12) identified the location of the permanent TSC as an area adjacent to the Control Room.

b. Revision 52 of the NAPS Emergency Plan (Reference 21) maintains the original location of the TSC.

c. The proposed change relocates the TSC to the building previously used to house the LEOF. This building is physically connected to the Simulator Building and on the grounds of the North Anna Training Center. This location is outside the PA boundary and greater than a two-minute walk from the MCR. While the proposed location of the new facility does not allow for direct face-to-face communications between the Shift Manager/Station Emergency Manager in the MCR and the Station Emergency Manager in the TSC, adequate communications capability in the form of dedicated phone lines and use of inter-facility communicator positions ensures continued and effective communication is maintained. In addition, the plant data needed for emergency response provided to the MCR via the PCS is available on TSC workstations, which obviates the need for TSC personnel to be physically present in the MCR to obtain data. The communications and plant data capabilities are discussed in sections 3.1.7 and 3.1.9, respectively. The site currently demonstrates the effectiveness of this communication and data capability during emergency plan drills and exercises using the North Anna Simulator MCR and the existing TSC, which are currently separated by the same distance as the MCR and the proposed TSC.

This process has been the subject of numerous NRC inspections and has not resulted in observation of a performance deficiency. As a result, the relocation of the TSC to the new location continues to meet the intent of the guidance in NUREG-0696 (Reference 1) and NUREG-0737, Supplement 1 (Reference 2).

3.1.3 Staffing and Training NUREG-0696 (Reference 1), Section 2.3, guidelines state that, upon activation, designated personnel shall report directly to the TSC and achieve full functional operation within 30 minutes. The Licensee-designated TSC staff shall consist of sufficient technical, engineering, and senior designated licensee officials to provide the needed support to the control room during emergency conditions. This guidance further directs that these

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 7 of 30 personnel have the requisite training and proficiency to perform their assigned roles.

NUREG-0737, Supplement 1 (Reference 2), Section 8.2.1.j, reiterates the TSC staffing guidance but changed the TSC staffing time requirement to 60 minutes.

a. Revision 10 of the Emergency Plan (Reference 12) established an augmentation goal of 60 minutes for the TSC and established a training program for ERO personnel to include the TSC staff.

Revision 14 of the Emergency Plan (Reference 14) established an augmentation goal of 60 minutes for the Core and Thermal Hydraulics Engineer position in the TSC.

Revision 48 of the Emergency Plan (Reference 19) established an augmentation goal of 45 and 60 minutes for mechanical maintenance support in the OSC and was approved by NRC SER dated December 12, 1995 (Reference 17). This SER also reaffirmed the existing TSC augmentation goal of 60 minutes. This revision identified TSC positions such as Station Emergency Manager (SEM), Operations, Engineering, Radiation Protection, and Communications personnel responsible for provision of senior management, engineering, and technical support.

b. Revision 52 of the Emergency Plan (Reference 21) maintains the TSC augmentation goal of 60 minutes established in Revision 48 of the Emergency Plan (Reference 19) and continues to provide staffing of senior management, engineering, and technical positions, and a training program for the TSC staff.

c. The proposed change maintains the existing TSC ERO staffing levels, TSC ERO augmentation response times, and TSC ERO training such that there is no impact on the timeliness of TSC activation or transfer of responsibilities from the MCR to the TSC. The proposed change relocates the TSC to the building previously used to house the LEOF. This building is physically connected to the Simulator Building on the grounds of the North Anna Training Center. The majority of personnel who hold TSC response positions are typically stationed in the Technical Services Building just outside the PA boundary. The travel time walking from the Technical Services Building to the current TSC is approximately six (6) minutes, whereas the travel time from the Technical Services Building to the proposed TSC location is 5-6 minutes and does not require traversing through security facilities as currently required. As a result, response times for TSC responders during dayshift hours would be comparable to the response times currently demonstrated in drills and exercises. The new location also provides for improved off-hours staffing capability as responders would report directly to the TSC without having to pass through security access controls for entry into the PA.

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 8 of 30 3.1.4 Size NUREG-0696 (Reference 1) guidelines for the sizing of the TSC state that it:

Be large enough to provide working space, without crowding, for the maximum level of occupancy with a working space of 75 square feet per person;

Provide working space sized for a minimum of 25 persons, including 20 persons designated by the licensee and five NRC personnel;

Provide space for the TSC data system equipment to include space to access the data and perform maintenance activities on the equipment when needed;

Provide access to communications equipment by all TSC personnel who need communications capabilities to perform their functions; and

Provide a separate room adequate for at least three persons to be used for private NRC consultations.

NUREG-0737, Supplement 1 (Reference 2), also states the facility should be sufficient to accommodate NRC and licensee personnel, equipment, and documentation, and be designed such that good human factors engineering principles are considered.

a. Revision 10 of the Emergency Plan (Reference 12) identified that the TSC contained approximately a total of 4,200 square feet, including space for mechanical and electrical equipment, and was able to accommodate 25 persons for emergency response. Approximately 1,800 square feet were usable for TSC functions. The TSC contained a complete controlled set of drawings, technical manuals, and other records that were properly stored and accessible and included required access to plant records.

b. The current Emergency Plan, Revision 52, maintains the description of the TSC.

c. The proposed TSC provides approximately 1,900 square feet of operating space for TSC personnel which assures a minimum of 75 square feet of working space for 25 persons. The proposed TSC layout replicates the layout of the existing facility and will consist of a TSC Operations Floor, separate rooms for Operations Support, Technical Support, Dose Assessment, and NRC personnel. It will also include a breakroom and bathroom facilities to support long term operation of the facility. A library space is provided with adequate space for the storage of plant records and historical data. The design of the facility provides a standard commercial level of ergonomic and comfort features for workspace efficiency. The new facility arrangement provides adequate space to support maintenance of TSC data and communications systems and equipment and will include an equipment room for housing the TSC support systems/equipment to include LAN and communications network switches. The

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 9 of 30 communications links and data system capabilities are described below in sections 3.1.7 and 3.1.9, respectively.

The operational space of the proposed facility is equivalent to that of the existing TSC, provides functionally equivalent working space and accommodations, and is consistent with the guidance provided in NUREG-0696 (Reference 1) and NUREG-0737, Supplement 1 (Reference 2).

3.1.5 Structure NUREG-0696 (Reference 1) states that the TSC complex must be able to withstand the most adverse conditions reasonably expected during the design life of the plant including earthquakes, high winds (other than tornadoes), and floods. However, the TSC need not meet seismic Category I criteria or be qualified as an engineered safety feature (ESF).

Normally, a well-engineered structure will provide adequate capability to withstand earthquakes. Winds and floods with a 100-year-recurrence frequency are acceptable as a design basis. NUREG 0737, Supplement 1 (Reference 2), identifies that the structure should be built in accordance with the Uniform Building Code (UBC).

a. The structural design for the original TSC, implemented in Revision 10 of the Emergency Plan (Reference 12), was consistent with the codes, standards, and regulatory requirements and existing station criteria for general structural design in accordance with the 1979 UBC requirements. The original TSC was designed in accordance with NUREG-0696 (Reference 1) which did not include a requirement to design the TSCs in accordance with the UBC. The TSC construction was completed using the BOCA code based on the guidance provided in NUREG-0737, Supplement 1 (Reference 2), Section 3.7, which allowed for previous work done in good faith.

Relative to flooding, the maximum postulated flood level for the west side of the plant is 267 ft mean sea level (MSL). The TSC was located adjacent to the MCR with the MCR located at 273 ft MSL, which is above the 267 ft MSL flood level specified in the UFSAR (Reference 22).

b. The current TSC structure maintains the Emergency Plan Revision 10 (Reference 12) description.

c. The proposed location for the TSC is in the building that formerly housed the LEOF.

The LEOF was previously determined to meet the ERF requirements for an Emergency Operations Facility (EOF) as documented by NRC letter dated May 25, 1987 (Reference 11 ). This building was engineered and designed in accordance with the BOCA code (Reference 23) which was the uniform building code used by Virginia at the time it was designed. As referenced above, NUREG-0737, Supplement 1 (Reference 2), directs the use of the UBC. The LEOF structure is made of a 12-inch thick reinforced concrete roof, 12-inch exterior masonry walls with horizontal joint reinforcement, and a 5-inch slab on grade. A review of this design determined that, due to the thickness and reinforcement of the walls and slab floor, the structure

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 10 of 30 exceeds the UBC requirements in place at the time of LEOF construction and can withstand the applicable loading. This as-designed building will withstand the 100-year wind speeds as described in the UFSAR (Reference 22). The proposed location has a finished floor elevation of 270 feet, which is above the maximum UFSAR (Reference 22) flood level discussed above. Based on the design of the former LEOF building, the proposed location of the TSC is consistent with the TSC structural guidance provided in NUREG-0696 (Reference 1) and NUREG-0737, Supplement 1 (Reference 2).

3. 1. 6 Habitability NUREG-0696 (Reference 1) states the TSC is to provide direct management and technical support to the control room during an accident and shall have the same radiological habitability as the control room under accident conditions. It also states that a TSC have a ventilation system that includes high-efficiency particulate air (HEPA) and charcoal filters as needed, as a minimum. This ventilation system need not be seismic Category I qualified, redundant, instrumented in the control room, or automatically activated to fulfill its role. NUREG-0696 (Reference 1) states that sufficient potassium iodide (Kl) shall be provided for use by TSC personnel. Radiation monitoring systems shall be provided in the TSC and detectors shall be able to distinguish the presence or absence of radioiodines at concentrations as low as 10-7 microcuries/cc. Equipment that protects personnel shall be provided in the TSC for the staff who must travel between the TSC and the control room or the EOF under adverse radiological conditions. Protective equipment also shall be provided to allow TSC personnel to continue to function during the presence of low-level airborne radioactivity or radioactive surface contamination.

Anti-contamination clothing and respiratory protective gear are examples of equipment that shall be provided. NUREG-0737 (Reference 24) provides guidance that the TSC is to be considered an area requiring continuous occupancy and is subject to the continuous occupancy dose requirements to include <15 mrem/hr (averaged over 30 days).

NUREG-0737, Supplement 1 (Reference 2), describes the need for the TSC to be environmentally controlled to provide temperature and humidity appropriate for personnel and equipment and for the provision of radiological protection and monitoring equipment necessary to assure that radiation exposure to any person working in the TSC would not exceed 5 rem whole body for the duration of the emergency.

a. The original TSC as implemented in Revision 10 of the Emergency Plan (Reference 12) was designed and constructed consistent with NUREG-0696 (Reference 1) to include the following:

Shielding and Ventilation The current NAPS Emergency Plan states that the construction of the facility walls and design of the ventilation system are such that the whole body and thyroid doses received by occupants of the TSC are below General Design Criterion 19 limits.

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 11 of 30 Radiological Monitoring The current TSC design provides a radiation monitoring system (RMS) meeting the requirements of NUREG-0696 (Reference 1) to provide continuous indication of the dose rate and airborne radioactivity in the TSC during an emergency, as well as alerting personnel of adverse conditions. The RMS consists of a Mirion ABPM201 L for monitoring airborne particulate, a Mirion IM201 L for monitoring airborne iodine, a Mirion NGM204L for monitoring airborne noble gases and radioactivity, and two Mirion DRM-2 area radiation monitors. These monitors have the capability to detect iodine at concentrations as low as 10-7 µci/cc. Each monitor provides both audible and visual alarm indication. Area radiation monitors were mounted on the walls at either end of the TSC. These monitors have an analog display and provide audible and visual alarms.

Protective Equipment The current TSC, as described in Revision 52 of the Emergency Plan (Reference 21),

contains an emergency kit that provides respirators, protective clothing, and portable radiation monitors. Thyroid blocking agents are maintained onsite for use as needed.

b. Habitability in the current TSC is maintained as described in Revision 10 of the Emergency Plan (Reference 12).

c. The proposed TSC is designed to meet habitability requirements in accordance with NUREG-0696 (Reference 1), NUREG-0737 (Reference 24), and NUREG-0737, Supplement 1 (Reference 2). Details on each element associated with facility habitability are outlined below.

Shielding The design of the proposed TSC includes adequate shielding to provide radiological protection of the occupants of the facility consistent with the requirements of NUREG-0696 (Reference 1) and NUREG-0737, Supplement 1 (Reference 2). As discussed above, the proposed location for the new TSC is in the building formerly used for the LEOF. The construction of this building consists of a 12-inch thick reinforced concrete roof, 12-inch thick exterior masonry walls with horizontal joint reinforcement, and a 5-inch slab on grade. The TSC ventilation system filter bank will be located in the penthouse of the new facility in an unoccupied space that is separated from ground level by a 12-inch thick concrete slab. An existing hatch between the penthouse and the ground level of the new TSC (occupied space) will be permanently sealed with a 12-inch concrete plug to prevent radiation exposure to the occupied TSC space below.

A Loss of Coolant Accident (LOCA) dose calculation was completed to determine the ability of the proposed TSC shielding and ventilation design to meet the specified occupancy dose requirements. Results of this calculation are described below.

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 12 of 30 Ventilation The ventilation system for the proposed TSC is designed to meet the requirements of NUREG-0696 (Reference 1) and NUREG-0737, Supplement 1 (Reference 2). Upon facility activation, the ventilation system will be manually placed in emergency operating mode via a hand switch. When placed in emergency operating mode, bubble tight motor operated dampers will align makeup air through a filtration system and deenergize exhaust fan circuits. The filter bank consists of a HEPA filter in series with a high efficiency gas absorption (HEGA) filter with a nominal flow rate of 1000 cfm. The HEPA filter removes particulate radioactive air contaminants, and the HEGA removes remaining pollutants such as iodine compounds. The HEGA filter temperature is monitored by a heat detector. If a flame is detected, the CO2 Suppression system floods CO2 into the duct mounted filter housing to extinguish the flame. The humidity of the makeup air stream is controlled via a sensor and electric duct heater. During emergency operation, the exhaust fans will be de-energized and isolated via dampers enabling the building's static pressure controller to modulate the filter fan speed to maintain the conditioned space at 0.125 inches water gauge (WG) relative to the outside air pressure to prevent infiltration of outside air. The ventilation system design has been suitably sized to provide heating and cooling that is capable of maintaining facility temperature at approximately 75 °F dry bulb +/- 3 °F during the summer and 72 °F dry bulb +/- 3 °F during the winter. The ventilation system is provided with an alarm function that will alert TSC staff of a component failure in the Emergency HVAC system. A LOCA dose calculation was completed to determine the ability of the proposed TSC shielding and ventilation design to meet the specified occupancy dose requirements. Results of this calculation are described below.

Radiological Monitoring The proposed TSC will be provided with radiation monitoring to provide continuous indication of the dose rate and airborne radioactivity in the TSC during an emergency, as well as alerting personnel of adverse conditions as required per NUREG-0696 (Reference 1). The RMS consists of a Mirion radiation monitor to detect airborne radioactivity, and two Mirion DRM-2 general area radiation monitors. The Mirian radiation monitor will include a particulate, an iodine, and a noble gas detector and will be able to distinguish the presence or absence of radioiodines at concentrations as low as 10-7 µci/cc. The monitor will be located in the Dose Assessment Room and will continuously sample the facility atmosphere from locations throughout the TSC and provide an audible alarm to alert TSC personnel of adverse conditions. The two Mirion DRM-2 general area radiation monitors will be wall mounted at separate locations on the TSC Operation Floor and will provide an audible alarm to alert TSC personnel of adverse conditions.

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 13 of 30 Protective Equipment As discussed above, the proposed location for the TSC is outside the PA and greater than two minutes walking distance from the MCR. Improvements in voice and data communications capabilities obviates the need for direct face-to-face communi-cations. Therefore, protective clothing to support personnel travel between the TSC and MCR is not necessary. However, protective clothing to support TSC personnel will be maintained in the TSC emergency kit. As described above, the TSC ventilation system will provide the facility protection from postulated releases, and continuous airborne and area radiation monitoring will provide the facility with early warning of changing radiological conditions in the facility. In addition, Emergency Plan Implementing Procedures (EPIPs) direct monitoring of emergency response facilities (ERFs) following an Alert classification when Radiation Protection responders are available. EPIPs establish access control and personnel monitoring for entering the ERFs to prevent contamination of the ERFs. EPIPs also provide guidance for issuance of respiratory protection and protective clothing in the ERFs should survey results indicate the need for such protective equipment. As provided in the current Emergency Plan, thyroid blocking agents will continue to be maintained onsite for use as needed. This approach ensures the protection of the TSC staff consistent with the intent of NUREG-0696 (Reference 1) and NUREG-0737, Supplement 1 (Reference 2).

LOCA Dose Calculation A dose calculation was completed to determine the dose consequences from a LOCA with a release to the environment to personnel in the proposed TSC to ensure the projected dose to the TSC as a consequence of the design basis accident would be less than the dose limit of 5 rem TEDE. The calculation was performed using the RADTRAD-NAI, MicroShield, MicroSkyshine, and MCNP5 computer codes.

Calculation inputs include the atmospheric dispersion factor (X/Q) for the proposed TSC location, site specific source terms, and LOCA dose components to include containment leakage, emergency core cooling system (ECCS) leakage, refueling water storage tank (RWST) leakage, containment direct shine, containment sky shine, cloud shine, and TSC ventilation system filter shine. The ventilation and shielding designs discussed above were used to determine the projected dose for the occupants of the facility. Personnel are assumed to occupy the TSC for the duration of the event. This is conservative as personnel would not be expected to arrive at the TSC until after the initiation of the accident and would work in rotating shifts over the thirty-day scenario duration rather than any one individual remaining inside the TSC for the duration of the event. Using this conservative assumption of continuous occupancy by an individual for the duration of the event, the LOCA dose calculation for the proposed TSC indicates the projected dose to TSC occupants to be less than the 5 rem requirement specified in NUREG-0696 (Reference 1) and NUREG-0737, Supplement 1 (Reference 2).

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 14 of 30 Conclusion The habitability capabilities of the proposed TSC as described above provide for the radiological protection of TSC personnel consistent with the guidance provided in NUREG-0696 (Reference 1) and NUREG-0737, Supplement 1 (Reference 2).

3. 1. 7 Communications NUREG-0696 (Reference 1) guidance states that the TSC have reliable voice communications to the control room, the OSC, EOF, State and Local agencies, and the NRC. Communications facilities shall include means for reliable primary and backup communications. The TSC voice communications may include private telephones, commercial telephones, radio networks, and intercommunication systems as appropriate to accomplish the TSC functions during emergency operating conditions. The TSC communications system shall include designated telephones for use by NRC personnel; dedicated telephones for management communications with direct access to the MCR, OSC, and EOF; telephones that provide access to onsite and offsite locations; intercommunications systems between work areas of the TSC; communications to mobile monitoring teams; and communications to state and local agencies.

NUREG-0737, Supplement 1 (Reference 2), states that reliable voice and data communications with the MCR and EOF and reliable voice communications with the OSC, NRC, and State and Local agencies be provided.

a. Revision 12 of the Emergency Plan (Reference 13) identified several communications systems available to TSC personnel for communications with the Control Room, OSC, EOF, and NRC. These included commercial telephones, County and State notification loop (lnstaphone), NRC ringdown (ENS), inter-facility ring down lines, private branch exchange (PBX), General Office off premises exchange (OPX), public address intercom system, sound powered telephone system, and UHF radio.

b. The current revision of the Emergency Plan (Reference 21) continues to maintain the location and the communications systems available to TSC personnel with the exception of replacing the lnstaphone system for notifying County and State agencies with the new Dominion Energy Emergency Notification System (DEENS). The communications capabilities available in the TSC include dedicated voice communications to the Control Room, OSC, CERC, VEOC, Primary Remote Assembly Area, Security Shift Supervisor, and Radiation Protection Supervisor; DEENS; Station PBX; OPX lines; commercial lines; public address intercom; radio system; and NRC lines (ENS, HPN, RSCL, PMCL, MCL, LAN).

c. The proposed TSC will replicate the communications capabilities provided in the existing TSC, with the exception of the sound powered telephone system as discussed above, providing reliable communications with the MCR, OSC, onsite personnel, mobile monitoring teams, CERC, Offsite Response Organizations (OROs), and the

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 15 of 30 NRC. The proposed TSC will include those communications capabilities currently in use to support engineering assessment activities, including damage control team planning and preparation as required by NUREG-0696 (Reference 1) and 0737, Supplement 1 (Reference 2), guidance.

Elimination of the sound powered telephone system in the TSC is acceptable because sound powered phones are typically used by operations for startup, shutdown, testing, and maintenance, as well as fire response. These are not typically used for TSC emergency response activities. Other communications links such as public address, PBX, radios, etc., are used by the TSC to communicate with personnel in the field.

The sound powered phone system was considered a back-up system to be used in the event one of the other systems was unavailable. The proposed communication system continues to meet NUREG-0696 (Reference 1) requirements for redundancy and reliability.

3. 1. 8 TSC Power Supplies NUREG-0696 (Reference 1) states that TSC electrical equipment load shall not degrade the capability or reliability of any safety-related power source. Circuit transients or power-supply failures and fluctuations shall not cause a loss of any stored data vital to the TSC functions. Sufficient alternate or backup power sources shall be provided to maintain continuity of TSC functions and to immediately resume data acquisition, storage, and display of TSC data if loss of the primary TSC power sources occurs. TSC power supplies need not meet safety-grade or Class 1E requirements.

a. The original TSC location was implemented in Revision 10 of the Emergency Plan (Reference 12). The TSC power supply design included a 480 VAC motor control center (MCC), MCC-1 G3-1, which fed the 480 VAC loads required for the TSC. The UPS was fed directly from 480V Bus 1G3. The UPS powers the emergency lighting and the essential computer and monitoring loads. This arrangement provided a power source to the TSC MCC from either 480 VAC Bus 1G3 or 480 VAC Bus 2G2, which in turn were powered from Reserve Station Service Transformer (RSST) B and Station Service Transformer (SST) C, respectively.

In 2012, a design change was implemented to provide an additional power supply to the TSC MCC and TSC UPS from a portable diesel generator (1-EP-GEN-TSC-1 ). This design change allowed the TSC MCC and the TSC UPS to be powered from the portable diesel generator via a docking station to either MCC 1G3-1 or UPS distribution panel 1-EP-CB-135 in the event the normal or alternate power supplies were unavailable.

In 2013, a design change was implemented that provided additional redundancy to the normal power supplies for the TSC. 480 Volt Bus 1G3 may be ultimately powered from either RSST B (Normal Source) or RSST A (Alternate Source) and 480 Volt Bus 2G2 may be powered from either RSST C (Normal Source) or RSST A (Alternate Source).

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b. The current TSC maintains the power arrangement described above.

c. The proposed TSC power distribution system consists of normal power from utility power, backup power from a dedicated 200kW/312.5KVA diesel generator, and a 50 KVA UPS with a 15-minute battery. During normal operation, TSC electrical loads are powered from utility power through an automatic transfer switch (ATS). Power is then distributed to a 480-277V main distribution panel, two 480-277V sub panels fed from the main distribution panel, and a 30 KVA 408-208/120V transformer and downstream 208/120V sub panel. The main distribution panel also feeds a 50 KVA UPS with an internal 480V - 208/120V transformer to supply power to a 208/120V critical devices panel. In the event the normal utility power is lost, the ATS will automatically start the backup diesel generator and repower the TSC electrical distribution system. During the time in which the diesel generator is starting and has yet to reach full speed and frequency, the UPS continues to power critical loads through its batteries. The 50 KVA UPS provides 15 minutes of power to critical TSC loads during the time the TSC power distribution system is transitioning to the backup diesel generator. The 50 KVA UPS module has an internal 480V - 208/120V transformer and supplies power to 208/120V critical devices and does not backfeed any 480V systems or panels. In the event off-site power is lost and the diesel generator is inoperable, a secondary diesel generator can be connected to the 480V main distribution panel through a generator quick connect switchboard located outside of the building. Emergency lighting for the TSC Operations Floor and the NRC Communications Room are powered by the 50 KVA UPS. Additional emergency lights and exit signs throughout the TSC are powered by stand-alone emergency lighting battery units. Therefore, the proposed design continues to meet the NUREG-0696 (Reference 1) guidance.

3.1.9 Technical Data, Data Systems, and Data System Equipment NUREG-0696 (Reference 1), Sections 2.8 and 2.9, state that the TSC technical data system and equipment shall receive, store, process, and display information acquired from different areas of the plant as needed to analyze plant conditions and perform the TSC function. The instrumentation data system equipment and power supplies need not be safety-grade or Class 1-E qualified. As a minimum, the set of Type A, B, C, D, and E variables specified in Regulatory Guide 1.97, Rev. 2, "Instrumentation for Light-Water-cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident" (Reference 25), shall be available for display and printout in the TSC. At least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of pre-event and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of post-event data shall be recorded.

Capacity to record at least two weeks of additional post-event data with reduced time resolution shall be provided . Archival data storage and the capability to transfer data between active memory and archival data storage without interrupting TSC data acquisition and displays shall be provided for all TSC data. A sufficient number of data display and printout devices shall be provided in the TSC to allow all TSC personnel to perform their assigned tasks with unhindered access to data to include plant systems

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 17 of 30 variables, in-plant radiological variables, meteorological information, and offsite radiological information. Sufficient alternate or backup power sources shall be provided to maintain continuity of TSC functions and to immediately resume data acquisition, storage, and display of TSC data if loss of the primary TSC power sources occurs. The total TSC data system reliability shall be designed to achieve an operational unavailability goal of 0.01 (1 %) during all plant operating conditions above cold shutdown. The design of the TSC data system equipment shall incorporate human factors engineering with consideration for both operating and maintenance personnel.

NUREG-0737, Supplement 1 (Reference 2), Section 8.2.1. h, states that the TSC be capable of reliable data collection, storage, analysis, display, and communication sufficient to determine site and regional status, determine changes in status, forecast status, and take appropriate actions. The following variables shall be available in the TSC: The variables in the appropriate Table 1 or 2 of Regulatory Guide 1.97 (Reference

25) that are essential for performance of TSC functions; and the meteorological variables in Regulatory Guide 1.97 {Reference 25) for site vicinity and National Weather Service data available by voice communication for the region in which the plant is located.

Principally, those data must be available that would enable evaluating incident sequence, determining mitigating actions, evaluating damages, and determining plant status during recovery operations.

a. The original NAPS ERFCS was implemented in Revision 12 of the Emergency Plan (Reference 13). ERFCS provided plant monitoring, data acquisition, and critical plant data in the form of real-time status displays. ERFCS monitors were located in the Control Room, TSC, LEOF, and CERC. Signal inputs for most components monitored by the ERFCS were taken from instrument terminals in the Control Room. The ERFCS includes the Safety Parameter Display System {SPDS), Emergency Response Guidelines {ERGs), process and instrument displays {P&IDs), pressure-temperature plant displays, and radiation and meteorological {RAD/MET) displays.

Monitor displays were continuously updated by the computer systems as they collected and processed parametric data from the various plant sensors.

Revision 27 of the Emergency Plan {Reference 18) reflected implementation of a design change that replaced the ERFCS with the PCS. As described in Revision 27 of the Emergency Plan {Reference 18), the PCS provides plant monitoring, data acquisition, and critical plant data in the form of real-time status displays for the purpose of making a rapid evaluation of the reactor plant's safety status. PCS monitors are strategically located in areas including the Control Room, TSC, and CERC. The PCS includes the SPDS, ERGs, P&IDs, and pressure-temperature plant displays. Monitor displays are continuously updated by the computer system as they collect and process parametric data from the various plant sensors. The PCS processes inputs from plant sensors and distributes information to the Control Room and TSC. Secure links on the station LAN and corporate Wide Area Network {WAN) provide data to designated LAN/WAN-connected PCs, which have the appropriate software and security level for access, including the CERC. The PCS design provides

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 18 of 30 system reliability to achieve an operational unavailability goal of 0.01 (1 %) during all plant operating conditions above Cold Shutdown.

b. The current revision of the Emergency Plan (Reference 21) maintains the PCS described in Revision 27 of the Emergency Plan (Reference 18).

c. The proposed PCS design and data capabilities remain unchanged by the proposed TSC relocation. The only identified change from analog to digital is the differential pressure indication on the HVAC system. Plant status information displays associated with form and function of the TSC will remain digital, and the layout of the proposed TSC facility is being replicated to the extent possible. A detailed human factors evaluation of the proposed TSC was performed to the requirements of NUREG-0711, Human Factors Engineering Program Review Model (Reference 34), and was determined to be in compliance. As stated above, the current TSC receives PCS data via dedicated PCS terminals and secure LAN connections. The proposed TSC will not contain the dedicated PCS hardware but will continue to use PCS data in the same way as the existing TSC via workstations connected to the Station LAN via secure connections. The level 2 connection is achieved through LAN switches inside the new TSC that are powered from the TSC normal and backup power system described above. The TSC LAN switches have two fiber uplink ports connected to the Administrative Building Computer Room network which is powered from utility power and backed up by a UPS and a dedicated diesel generator. This arrangement is functionally equivalent to the existing TSC with respect to the data provided, means of access, method of presentation, and system reliability such that the TSC will continue to be provided with the required data inputs, data storage, data retrieval, and data trending capabilities to evaluate incident sequence, determine mitigating actions, evaluate damage, determine plant status during recovery operations, and perform the TSC function in accordance with the requirements of NUREG-0696 (Reference 1) and NUREG-0737, Supplement 1 (Reference 2).

3. 1. 10 Records Availability and Management NUREG-0696 (Reference 1), Section 2.10, specifies the TSC shall have a complete and up-to-date repository of plant records and procedures at the disposal of TSC personnel to aid in their technical analysis and evaluation of emergency conditions to include plant technical specifications, plant operating procedures, emergency operating procedures, Final Safety Analysis Report, plant operating records, plant operations reactor safety committee records and reports, records needed to perform the functions of the EOF when it is not operational, and up-to-date, as-built drawings, schematics, and diagrams.

NUREG-0737, Supplement 1 (Reference 2), Section 8.2.1.i, states the TSC be provided with accurate, complete and current plant records (drawings, schematic diagrams, etc.)

essential for evaluation of the plant under accident conditions.

a. Revision 10 of the Emergency Plan (Reference 12) identified records availability that included a complete set of controlled drawings, technical manuals, and other records.

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b. Revision 52 of the Emergency Plan (Reference 21) maintains this wording with additional specification that selected manuals, procedures, drawings, and other documents as approved by the Facility Safety Review Committee be controlled copies.

c. The proposed TSC location will maintain the records availability described in Revision 52 of the Emergency Plan (Reference 21).

3.2 Conclusions The proposed change provides a TSC that is consistent with the guidance of NUREG-0696 (Reference 1) and NUREG-0737, Supplement 1 (Reference 2), and maintains the existing emergency response capabilities of the NAPS Emergency Plan. Therefore, the proposed change continues to ensure the NAPS Emergency Plan will meet 10 CFR 50.54(q)(2) (Reference 3), the requirements of 10 CFR 50, Appendix E (Reference 26), and the planning standards of 10 CFR 50.47(b) (Reference 27).

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Req uirements/Criteria

1. Title 10 Code of Federal Regulations, Part 50.47(b){8)

(b) The onsite and, except as provided in paragraph (d) of this section, off-site emergency response plans for nuclear power reactors must meet the following standards:

8. Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

The existing NAPS Emergency Plan includes onsite and off-site emergency response plans that meet the requirements listed above. This LAR proposes to relocate the existing TSC to the building outside of the plant PA and within the plant Owner Controlled Area (OCA) previously used as the LEOF. The NAPS Emergency Plan will continue to meet 10 CFR 50.47(b) (Reference 26).

2. Title 10 Code of Federal Regulations, Part 50.54(q), "Emergency Plans" Relevant portions as follows:

(q) Emergency Plans.

(1)(iv) Reduction in effectiveness means a change in an emergency plan that results in reducing the licensee's capability to perform an emergency planning function in the event of a radiological emergency.

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 20 of 30 (2) A holder of a license under this part, or a combined license under part 52 of this chapter after the Commission makes the finding under§ 52. 103(g) of this chapter, shall follow and maintain the effectiveness of an emergency plan that meets the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of§ 50.47(b).

(4) The changes to a licensee's emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRG. A licensee desiring to make such a change after February 21, 2012, shall submit an application for an amendment to its license. In addition to the filing requirements of§§ 50. 90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompanied by a forwarding Jetter identifying the change, the reason for the change, and the basis for concluding that the licensee's emergency plan, as revised, will continue to meet the requirements in Appendix E to this part and, for nuclear power reactor licensees, the planning standards of§ 50.47(b).

The existing NAPS Emergency Plan meets the planning standards of 10 CFR 50.47(b) (Reference 27) and 10 CFR 50, Appendix E (Reference 26),

as required by 10 CFR 50.54(q)(2) (Reference 3). This LAR proposes to re-locate the existing TSC to the building outside of the plant PA and within the plant OCA previously used as the LEOF. These proposed changes are considered a reduction in effectiveness as defined in 10 CFR 50.54(q)(1)(iv)

(Reference 3) and require submittal for NRG approval based on 10 CFR 50.54(q)(4) (Reference 3). Therefore, Dominion Energy Virginia is submitting this LAR pursuant to 10 CFR 50.90 (Reference 4).

The NAPS Emergency Plan will continue to meet the requirements of 10 CFR 50.54(q)(2) (Reference 24) by maintaining the effectiveness of the Emergency Plan such that it meets the requirements of 10 CFR 50, Appendix E (Reference 26), and the planning standards of 10 CFR 50.47(b)

(Reference 27).

3. Title 10 Code of Federal Regulations. Part 50. Appendix A, General Design Criteria (GDC). Criterion 19 Criterion 19-A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.

Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 21 of 30 receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident.

GDC-19, as noted in 10 CFR 50, Appendix A (Reference 28), applies specifically to Control Room requirements and does not address TSC design parameters. The NAPS Control Room design meets GDC-19 as outlined in the site's Updated Final Safety Analysis Report. The link between TSC design and GDC-19 is found in NUREG-0737 (Reference 24) and NUREG-0696 (Reference 1).

4. 10 CFR 50, Appendix E, Section IV, "Content of Emergency Plans" E. Emergency Facilities and Equipment Adequate provisions shall be made and described for emergency facilities and equipment including:

8.a.(i) Licensed onsite technical support center and emergency operations facility from which effective direction can be given and effective controls can be exercised during an emergency.

The existing NAPS Emergency Plan includes a description of the organization, including definition of authorities, responsibilities, and duties of individuals. The current Emergency Plan is in compliance with 10 CFR 50, Appendix E.IV.E.8 (Reference 26). This LAR proposes to relocate the existing TSC to the building outside of the plant PA and within the plant OCA previously used as the LEOF.

The proposed changes to the NAPS Emergency Plan will continue to describe the emergency facilities onsite. Therefore, the requirements of 10 CFR 50, Appendix E (Reference 26), continue to be met with the proposed changes.

5. NUREG-0654/FEMA-REP-1, Revision 1: "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" Relevant portions as follows:

H. Emergency Facility and Equipment Planning Standard Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Evaluation Criteria

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1. Each licensee shall establish a Technical Support Center and an onsite operations support center (assembly area) in accordance with NUREG-0696, Revision 1.

NUREG-0654/FEMA-REP-1, Revision 1 (Reference 5), directs the licensee to establish a Technical Support Center in accordance with NUREG-0696 (Reference 1) which in turn provides general guidance concerning the functional criteria for the ERFs and the integrated support these facilities provide to the control room. The current NAPS Emergency Plan (Reference 19), Section 7, identifies the ERFs used at NAPS and meets the intent of NUREG-0696 (Reference 1). This LAR proposes an alternative approach to NUREG-0696 (Reference 1), Section 2.2, with the relocation of the TSC to the building outside of the plant PA and within the plant OCA previously used as the LEOF. A detailed review of the proposed changes against NUREG-0696 (Reference 1) functional criteria was completed and demonstrated that the proposed changes to the NAPS Emergency Plan continue to meet the intent of NUREG-0696 (Reference 1) and therefore meet the intent of NUREG-0654/FEMA-REP-1 (Reference 5).

6. NUREG-0696, "Functional Criteria for Emergency Response Facilities" NUREG-0696 (Reference 1), Section 1.3.1, describes the TSC, in part:

The technical support center (TSC) is an onsite facility located close to the control room that shall provide plant management and technical support to the reactor operating personnel located in the control room during emergency conditions. It shall have technical data displays and plant records available to assist in the detailed analysis and diagnosis of abnormal plant conditions and any significant release of radioactivity to the environment. The TSC shall be the primary communications center for the plant during an emergency. A senior official, designated by the licensee, shall use the resources of the TSC to assist the control room operators by handling the administrative items, technical evaluations, and contact with offsite activities, relieving them of these functions.

NUREG-0696 (Reference 1), Section 2, provides a detailed description of the TSC design elements and capabilities to include:

Section 2.1, Function

Section 2.2, Location

Section 2.3, Staffing and Training

Section 2.4, Size

Section 2.5, Structure

Section 2.6, Habitability

Section 2.7, Communications

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Section 2.8, Instrumentation, Data System Equipment, and Power Supplies

Section 2.9, Technical Data and Data System

Section 2.10, Records Availability and Management NUREG-0696 (Reference 1) provides general guidance concerning the functional criteria for the ERFs and on the integrated support these facilities provide to the control room. The current NAPS Emergency Plan (Reference 21), Section 7, identifies the ERF's used at NAPS and meets the intent of NUREG-0696 (Reference 1). This LAR proposes an alternative approach to NUREG-0696 (Reference 1), Section 2.2, with the relocation of the TSC to the building outside of the plant PA and within the plant OCA previously used as the LEOF. A detailed review of the proposed changes against NUREG-0696 (Reference 1) functional criteria was completed and demonstrated that the proposed changes to the NAPS Emergency Plan continue to meet the intent of NUREG-0696 (Reference 1).

7. NUREG-0737, Supplement 1, "Clarification of TMI Action Plan Requirements" Relevant portions as follows:

NUREG-0737 (Reference 24), Section 11.B.2, states in part:

"This requirement was originally issued by letters to all operating nuclear power plants, dated September 13 and October 30, 1979, and was incorporated into NUREG-0660. Significant changes in requirements or guidance are: Allows averaging over 30 days of the dose rate criteria for areas requiring continuous occupancy and that the control room and technical support center should be considered areas requiring continuous occupancy. This ensures that the dose rate criteria is applied correctly to these areas."

°'reas Requiring Continuous Occupancy: <15 mremlhr (averaged over 30 days). These areas will require full-time occupancy during the course of the accident. The control room and onsite technical support center are areas where continuous occupancy will be required. The dose rate for these areas is based on the control room occupancy factors contained in SRP 6.4."

NUREG-0737 (Reference 24) provides guidance concerning the occupancy dose criteria for the ERFs. This LAR proposes to relocate the existing TSC to the building outside of the plant PA and within the plant OCA previously used as the LEOF. A detailed review of the proposed changes against NUREG-0737 (Reference 24) occupancy dose criteria was completed and demonstrated that the proposed changes to the NAPS Emergency Plan continue to meet the intent of NUREG-0737 (Reference 24).

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8. NUREG-0737, Supplement 1, "Clarification of TMI Action Plan Requirements" Section 8.2.1, Requirements, states in part:

a. The TSC is the onsite technical support center for emergency response.

When activated, the TSC is staffed by predesignated technical, engineering, senior management, and other licensee personnel, and five pre-designated NRG personnel. During periods of activation, the TSC will operate uninterrupted to provide plant management and technical support to plant operations personnel, and to relieve the reactor operators of peripheral duties and communications not directly related to reactor system manipulations. The TSC will perform EDF functions for the Alert Emergency class and for the Site Area Emergency class and General Emergency class until the EDF is functional.

The TSC will be:

b. Located within the site protected area so as to facilitate necessary interaction with control room, DSC~ EDF and other personnel involved with the emergency.

c. Sufficient to accommodate and support NRG and licensee predesignated personnel, equipment and documentation in the center.

d. Structurally built in accordance with the Uniform Building Code

e. Environmentally controlled to provide room air temperature, humidity and cleanliness appropriate for personnel and equipment.

f. "The TSC will be provided with radiological protection and monitoring equipment necessary to assure that radiation exposure to any person working in the TSC would not exceed 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident."

g. Provided with reliable voice and data communications with the control room and EDF and reliable voice communications with the DSC, NRG Operations Centers and state and local operations centers.

h. Capable of reliable data collection, storage, analysis, display and communication sufficient to determine site and regional status, determine changes in status, forecast status and take appropriate actions. The following variables shall be available in the TSC .... Principally those data must be available that would enable evaluating incident sequence, determining mitigating actions, evaluating damages and determining plant status during recovery operations.

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i. Provided with accurate, complete and current plant records (drawings, schematic diagrams, etc.) essential for evaluation of the plant under accident conditions.

j. Staffed by sufficient technical, engineering, and senior designated licensee officials to provide needed support, and be fully operational within-approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after activation.

k. Designed taking into account good human factors engineering principles.

NUREG-0737, Supplement 1 (Reference 2), provides general guidance concerning the functional criteria for the ERFs and on the integrated support these facilities provide to the control room. This LAR proposes an alternative approach to NUREG-0737, Supplement 1 (Reference 2), Section 8.2.1.b, with the relocation of the TSC to the building outside of the plant PA and within the plant OCA previously used as the LEOF. A detailed review of the proposed changes against NUREG-0737, Supplement 1 (Reference 2), functional criteria was completed and demonstrated that the proposed changes to the NAPS Emergency Plan continue to meet the intent of NUREG-0737, Supplement 1 (Reference 2).

4.2 Precedent The proposed NAPS Emergency Plan changes are similar to changes approved for other licensees including Three Mile Island (ML023460148) (Reference 29), Clinton (ML070540270) (Reference 30), and D.C. Cook (ML18249A019) (Reference 31). The proposed change is also similar to changes proposed, and currently under NRC review, for Surry Power Station (ML22322A182) (Reference 35). Furthermore, the proposed NAPS Emergency Plan changes and evaluation documented in this submittal continue to meet the standards of 10 CFR 50.47(b) (Reference 27) and the requirements of 10 CFR 50, Appendix E (Reference 26).

4.3 No Significant Hazards Considerations Determination In accordance with the requirements of 10 CFR 50.90, Virginia Electric and Power Company (Dominion Energy Virginia) requests an amendment to facility Renewed Facility Operating Licenses DPR-32 and DPR-37 for North Anna Power Station (NAPS) Units 1 and 2, respectively, to revise the NAPS Emergency Plan. Dominion Energy Virginia proposes to relocate the TSC described in the NAPS Emergency Plan to the building formerly used for the Local Emergency Operations Facility (LEOF) located outside of the Protected Area (PA) and within the Owner Controlled Area (OCA).

Dominion Energy Virginia has evaluated the proposed amendment against the standards in 10 CFR 50.92 and has determined that the operation of NAPS in accordance with the

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 26 of 30 proposed amendment presents no significant hazards. The Dominion Energy Virginia evaluation against the criteria in 10 CFR 50.92 is provided below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change in TSC location has no effect on normal plant operation or any accident initiator or precursor and does not impact the function of plant structures, systems, or components (SSCs). The proposed change does not alter or prevent the ability of the Emergency Response Organization to perform its intended functions to mitigate the consequences of an accident or event.

Therefore, the proposed Emergency Plan changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not impact the accident analysis. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions.

The proposed change does not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis. The proposed change does not alter or prevent the ability of the Emergency Response Organization to perform its intended functions to mitigate the consequences of an accident or event.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change is associated with the relocation of the TSC and does not impact operation of the plant or its response to transients or accidents. The change does not affect the

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 27 of 30 Technical Specifications. The proposed change does not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed change. Safety analysis acceptance criteria are not affected by this proposed change.

The revised Emergency Plan will continue to provide the necessary response facilities with the proposed change. Therefore, the proposed change is determined to not adversely affect the ability to meet 10 CFR 50.54(q)(2), the requirements of 10 CFR 50, Appendix E, or the emergency planning standards as described in 10 CFR 50.47(b).

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

4.4 Conclusion Dominion Energy Virginia has evaluated the proposed change against the applicable regulatory requirements and acceptance criteria. The proposed NAPS Emergency Plan change continues to assure that regulatory requirements and emergency planning standards associated with emergency response are met.

Based on the above evaluation, Dominion Energy Virginia has determined that operation of the facility in accordance with the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92(c) (Reference 32) in that it does not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

5.0 ENVIRONMENTAL CONSIDERATION

Dominion Energy Virginia has determined the proposed change would not revise a requirement with respect to installation or use of a facility or component located within the restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, or (ii) authorize a significant change in the types or a significant increase in the amounts of any effluent that may be released off-site, or (iii) result in a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(9) (Reference 33). Therefore, Dominion Energy Virginia concludes that pursuant to 10 CFR 51.22(b) (Reference 33), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 28 of 30

6.0 REFERENCES

1. NUREG-0696, "Functional Criteria for Emergency Response Facilities - Final Report," February 1981. (ADAMS Accession No.: ML051390358)

2. NUREG-0737, Supplement 1, "Clarification of TMI Action Plan Requirements, Requirements for Emergency Response Capabilities," January 1983. (ADAMS Accession No.: ML102560009)

3. Title 10 Code of Federal Regulations Part 50.54(q), Emergency Plans.

4. Title 10 Code of Federal Regulations Part 50.90, Application for Amendment of License, Construction Permit, or Early Site Permit.

5. NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plant," Revision 1, November 1980. (ADAMS Accession No.:

ML040420012)

6. NUREG-0053, "Safety Evaluation Report related to the operation of North Anna Power Station, Units 1 and 2, June 1976. (ADAMS Accession No.: ML19296A606)

7. NUREG-0053, "Safety Evaluation Report related to the operation of North Anna Power Station, Units 1 and 2, Supplement No. 2, August 1976. (ADAMS Accession No.: ML19290C376)

8. NUREG-0053, "Safety Evaluation Report related to the operation of North Anna Power Station, Units 1 and 2, Supplement No. 11, August 1980. (ADAMS Accession No.: ML19331C408)

9. North Anna Power Station Emergency Plan, Revision 0, July 22, 1982.

10. NRC letter dated, May 10, 1983, "NUREG-0737 Item 111.A.2.1 Emergency Plan Upgrade to Meet Rule." (ADAMS Accession No.: ML20076C761)

11. NRC letter dated, May 25, 1987, "Emergency Response Capability, North Anna Power Station, Units No. 1 and No. 2." (ADAMS Accession No.: ML20214L072)

12. North Anna Power Station Emergency Plan, Revision 10, May 15, 1986.

13. North Anna Power Station Emergency Plan, Revision 12, October 2, 1989.

14. North Anna Power Station Emergency Plan, Revision 14, August 31, 1992.

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 29 of 30

15. NRC letter dated May 18, 1990, "Surry and North Anna Proposed Emergency Plan Changes." (ADAMS Accession No.: ML20043D253)

16. North Anna Power Station Emergency Plan, Revision 18, January 3, 1996.

17. NRC letter dated, December 12, 1995, "Review of Proposed Cost Beneficial Licensing Action Request for Emergency Plan Changes for North Anna Power Station." (ADAMS Accession No.: ML20095E537)

18. North Anna Power Station Emergency Plan, Revision 27, December 18, 2002.

19. North Anna Power Station Emergency Plan, Revision 48, May 1, 2019.

20. NRC letter dated February 27, 2019, "North Anna Power Station, Unit Nos. 1 and 2, and Surry Power Station, Unit Nos. 1 and 2 - Issuance of Amendment Nos. 281, 264, 294, and 294 to Consolidate Emergency Operations Facilities and Associated Emergency Plan Changes." (ADAMS Accession No.: ML19031B227)

21. North Anna Power Station Emergency Plan, Revision 52, October 30, 2020.

22. North Anna Power Station Updated Final Safety Analysis Report, Revision 57.02, December 15, 2021.

23. Building Officials Code Administrators International Code, dated 1979.

24. NUREG-0737, Final Report, "Clarification of TMI Action Plan Requirements,"

November 1980. (ADAMS Accession No.: ML051400209)

25. Regulatory Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Revision 2, December 1980. (ADAMS Accession No.: ML060750525)

26. Title 10 Code of Federal Regulations, Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities."

27. Title 10 Code of Federal Regulations, Part 50.47, Emergency Plans.

28. Title 10 Code of Federal Regulations, Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants."

29. NRC letter dated December 10, 2002, "Three Mile Island Nuclear Station, Unit 1 (TMl-1), Relocation of the Technical Support Center (TSC) (TAC No. MB5210)."

(ADAMS Accession No.: ML023460148)

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 1 Page 30 of 30

30. NRG letter dated March 12, 2007, "Clinton Power Station, Unit No. 1 - Relocation of the Technical Support Center (TAC NO. MD2468)." (ADAMS Accession No.:

ML070540270)

31. NRG letter dated November 13, 2018, "Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2 - Issuance of Amendment Nos. 341 and 323 RE: Technical Support Center Relocation (EPID L-2017-LLA-0375)." (ADAMS Accession No.: ML18249A019)

32. Title 10 Code of Federal Regulations, Part 50.92, Issuance of Amendment.

33. Title 10 Code of Federal Regulations, Part 51.22, Criterion for Categorical Exclusion; Identification of Licensing and Regulatory Actions Eligible for Categorical Exclusion or Otherwise not Requiring Environmental Review.

34. NUREG-0711, "Human Factors Engineering Program," Revision 3, November 2012. (ADAMS Accession No.: ML22324A013)

35. Letter from Virginia Electric and Power Company to USNRC dated November 18, 2022, "Virginia Electric and Power Company, Surry Power Station Units 1 and 2, Proposed Emergency Plan Revision, Relocation of the Technical Support Center." (ADAMS Accession No.: ML22322A182)

Serial No.22-036 Docket Nos.: 50-338/339 Attachment 2 MARKED-UP NAPS EMERGENCY PLAN PAGES Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station Units 1 and 2

NAEP Page 1.5 Revision ~ XX

the public. Any releases are not expected to result in exposure levels which exceed Environmental Protection Agency Protective Action Guideline exposure levels beyond the site boundary.

Station Emergency Manager (SEM) - Designated onsite individual having the responsibility and authority for implementing the North Anna Emergency Plan.

Technical Support Center -A facility located adjacent to the Unit 1 Control Room Training Building which will be the central control center for the onsite emergency response organization after the on shift staff has been augmented.

Thyroid Committed Dose Equivalent (CDE) - Radiation exposure to the thyroid through inhalation or ingestion of radioactive material assuming a 50 year exposure period from uptake.

Total Effective Dose Equivalent (JEDE) - The sum of external and internal dose.

NAEP Page 7.3 Revision ~ XX 7.0 EMERG ENCY FACILITIES AND EQUIPMENT The facilities required in the implementation of the Emergency Plan consist of the Control Room (shared for both Unit 1 and 2), the Operational Support Center (OSC), the Technical Support Center (TSC),

and the Corporate Emergency Response Center (CERC). These facilities were designed to meet the intent of the guidance in NUREG-0696 and the clarification in NUREG-0737 Supplement 1. In addition, a Joint Information Center (JIC) and a Local Media Center (LMC) are required for the implementation of the Emergency Plan. A description of each is given below.

7.1 EMERG ENCY RESPONSE FACILITIES 7.1.1 Control Room The Control Room of the affected unit(s) shall be the initial location for command and control of the emergency response effort. All controls and instrumentation needed to diagnose plant conditions and to take immediate actions to place the affected unit(s) in a safe condition are available in the Control Room. Within the Control Room, the Station Emergency Manager has access to the information needed to classify the emergency. Redundant communication systems are also available in the Control Room to make the required onsite and offsite notifications. The Control Room has the required shielding and ventilation system to remain habitable during the emergency. Access to the Control Room shall be limited to those individuals responsible for carrying out assigned emergency response tasks plus other technical advisors, as necessary.

7.1.2 Operational Su pport Center The Work Control Center is designated as the Operational Support Center (OSC). The OSC is not designed to remain habitable under all projected emergency conditions; however, implementing procedures make provisions for relocating the OSC as needed, based on ongoing assessments of plant conditions and facility habitability. The Maintenance Building, 3rd Floor, and the Unit One Emergency Switchgear Room are designated as Alternate OSCs. Augmenting Station operations personnel will report to the primary OSC until instructed by the Shift Manager/SEM to perform a required emergency function. The OSC is also the designated reporting location for the Fire Brigade, the First Aid Team, the Damage Control Team, and the Search and Rescue Team.

7.1.3 Technical Support Center The Technical Support Center is located adjacent to the Unit 1 Control Room Training Building, and its alternate location is the Control Room. Emergency response personnel will assemble at the primary TSC unless otherwise instructed by the Station Emergency Manager. The primary location contains controlled copies of selected manuals, procedures, drawings, and other documents as approved by the Facility Safety Review Committee. Information about plant conditions is available via real time data displays from the Plant Computer System (PCS). Dedicated phone line communications would also be established with the Control Room to keep TSC personnel knowledgeable on current operating evolutions and to provide consultation and recommendations to the Control Room staff.

The construction of the facility walls and design of the ventilation system are such that the whole body and thyroid doses received by occupants of the TSC are below General Design Criteria 19 limits. Radiation

NAEP Page 7.5 Revision ~ XX 7.2 COMMUNICATIONS SYSTEMS The station communications system is designed to provide redundant means to communicate with all essential areas of the station associated with North Anna Units 1 and 2 and to essential locations remote from the station during normal operation and under accident conditions. Communication systems vital to Units 1 and 2 operation and safety are designed so that failure of one component would not impair the reliability of the total communications system. This is accomplished within the Station by using diverse systems and designated personnel.

7.2.1 Communications Systems Within the Station The systems which provide for communications within the Station are discussed below.

7.2.1.1 Public Address and Intercom System A five channel public address and intercom system (Gai-Tronics System) is installed in the Station.

The system power is supplied from a power supply which will maintain the system in an operational condition in the event of a normal station service power failure. Zones are provided within that Station to insure operability of a major portion of the system should equipment in a zone become inoperative. Loudspeaker and paging phone stations are located throughout the Station. The coverage of the loudspeakers permits broadcasts to be heard throughout the station. A visual indicator has been installed in those areas where evaluation of NRC Bulletin 79-18, Audibility Problems Encountered on Evacuation of Personnel from High-Noise Areas, identified noise levels which might exceed the volume of the loudspeakers. In the event of an emergency, the system is used to alert Station personnel of any emergency situation and to direct emergency response actions required of on-site personnel.

7.2.1.2 Radio Communications System (Onsite)

An Ultra-High Frequency (UHF) two-way radio trunking system is provided at the Station consisting of base stations/repeaters, mobile units installed in emergency vehicles, and hand-held portable radios. The radio trunking system provides redundancy and independent emergency backup equipment for designated station functions.

7.2.1.3 Private Branch Telephone Exchange (PBX)

A Private Branch Telephone Exchange (PBX) is installed at the Station. The PBX switching equipment is physically located in the PBX Building and is connected to a commercial telephone exchange in Mineral, Virginia. Backup battery power is provided to maintain the system operable 6 to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months following the loss of AC. power.

7.2.1.4 Sound Powered Telephone S'{stem A soun(I powere(I telephone communications system is installed which seP1es t>lorth Anna Units 1 and 2. This system is a m1,1ltiple channel system connecting selected opeFating areas of the plant.

Headsets consisting of an earphone and microphone are connected to a tv10 wire channel for direct communication between persons in (lifferent areas. Operation of this system is not (lepen(lent on the availability of the electrical power system. D1,1ring an emergency, the system 'Noul(I pro11i(le an alternate means of relaying messages.

NAEP Page 7.12 Revision ~ XX TABLE 7.1 ERF COMMUNICATIONS Control Room

1. Dedicated voice communications to TSC, OSC, Security, System Operator, VEOC

2. Dominion Energy Emergency Notification System {DEENS} to State and Country EOCs

3. Station PBX Phones

4. OPX Phone {General Office Network}

5. Radio System

6. NRC Emergency Notification System {ENS}

7. Commercial Phones {Independent of Station PBX}

8. Public Address/Intercom {Gai-tronics}

9. Sound Powered System

10. Emergency Response Data System {ERDS} Channel Technical Support Center (JSC)

1. Dedicated voice communications to Control Room, OSC, CERC, Security, Primary Remote Assembly Area, VEOC

2. Dominion Energy Emergency Notification System {DEENS} to State and County EOCs

3. Commercial Phones {Independent of Station PBX}

4. Radio System

5. Station PBX Phones

6. OPX Phone {General Office Network}

7. NRC Emergency Notification System {ENS}

8. Public Address/Intercom {Gai-tronics}

9-: Smma Po'i't'eFea System 9.4-G. NRC Health Physics Network {HPN}

10.44-:- NRG Reactor Safety Counterpart Link {RSCL}

11.4-2:- NRC Protective Measures Counterpart Link {PMCL}

12.~ NRC Emergency Response Data System {ERDS} Channel 13.44.- NRG Management Counterpart Link {MCL}

14.4-&.. NRC Local Area Network {LAN} Access Operational Support Center

1. Public Address/Intercom {Gai-Tronics}

2. Station PBX Phone

3. Dedicated voice communications to TSC, Control Room, HP

v t e Letter Sequence Request
EPID:L-2023-LLA-0006, Proposed Emergency Plan Revision, Relocation of the Technical Support Center (Open)
Initiation Request Acceptance Administration Questions Answers Results Approval, Approval Other: ML23223A040
MONTHYEAR2023-12-07 [Table View]

ML23013A195

Text

SUMMARY

2.1 PROPOSED CHANGE

3.1 TECHNICAL ANALYSIS

3.2 CONCLUSION

4.0 REGULATORY EVALUATION

4.4 CONCLUSION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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