ML23159A233

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License Amendment Request - Emergency Response Organization Augmentation Time Change, Emergency Operations Facility Relocation and Other Emergency Plan Changes
ML23159A233
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 06/08/2023
From: James Holloway
Dominion Energy South Carolina
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
22-249
Download: ML23159A233 (1)


Text

Dominion Energy Sout h Carolina, Inc.

5000 Domin ion Bou levard, Glen Al len, VA 23060 ~ Dominion Dominion En ergy.com June 8, 2023

iiiiiii" Energy~

Attn: Document Control Desk Serial No.: 22-249 U.S. Nuclear Regulatory Commission NRA/YG: RO Washington, DC 20555-0001 Docket No.: 50-395 License No.: NPF-12 DOMINION ENERGY SOUTH CAROLINA (DESC)

VI RG IL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 LICENSE AMENDMENT REQUEST - EMERGENCY RESPONSE ORGAN IZATION (ERO) AUGMENTATION TIME CHANGE, EMERGENCY OPERATIONS FACILITY RELOCATION AND OTHER EMERGENCY PLAN CHANGES Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR Part 50.54(q)(4), Part 50 Appendix E,Section IV. E.8.b, and Part 50.90), Dominion Energy South Carolina (DESC) is hereby submitting a License Amendment Request for Virgil C.

Summer Nuclear Station (VCSNS) Unit 1.

The proposed amendment would modify the VCSNS Emergency Plan by:

(1) Extending Emergency Response Organization (ERO) Augmentation Times to 60 or 90 minutes from 30 or 60 minutes depending on specific ERO positions.

(2) Relocating the Emergency Operations Facility (EOF) and the Joint Information Center (JIC) from Ballentine, South Carolina and West Columbia, South Carolina to the Dominion Energy Corporate Emergency Response Center (CERC) in Glen Allen, Virginia.

(3) Adding a definition for "facility activation" criteria to align with command-and-control functions in the Technical Support Center (TSC), Operational Support Center (OSC), and Corporate Emergency Response Center (CERC).

(4) Revising the minimum staffing definition for the Emergency Response Facilities (ERF) to align with new facility activation criteria.

(5) Extending facility activation requirements to 90 minutes after declaration of an Alert or higher classification.

(6) Reorganizing the VCSNS Emergency Plan Table B-1a based on emergency preparedness functions.

(7) Reducing the classification level at which dispatch of Offsite Survey Teams is required from a Site Area Emergency (SAE) to an Alert.

(8) Removing references to chemistry, maintenance, firefighting, first aid/rescue, site access control and personal accountability functions being on-shift from Table B-1a.

Serial No.22-249 Docket No. 50-395 Page 2 of 4 to this letter provides a description and assessment of the proposed changes. Attachment 2 provides the current VCSNS Emergency Plan marked-up to show the proposed changes. Attachment 3 provides the revised (clean) VCSNS Emergency Plan pages. Attachment 4 provides a Table B-1 comparative chart. Attachment 5 provides the ERO position impact summary. Attachment 6 provides the No Significant Hazards Consideration for this proposed amendment. Attachment 7 provides the offsite response organization concurrence letters. Attachment 8 provides a list of references.

DESC requests approval of the proposed license amendment by May 31, 2024, with a 180-day implementation period.

In accordance with 10 CFR 50.91, "Notice for Public Comment; State Consultation," a copy of this application, with attachments, is being provided to the designated South Carolina State Official.

Should you have any questions, please contact Yan Gao at (804)-273-2768.

Respectfully,

~ Mr James E. Holloway Vice President - Nuclear Engineering and Fleet Support Commitments made in this letter: None.

COMMONWEAL TH 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 Dominion Energy South Carolina, Inc. 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 i+h day of Jun-. . 2023.

My Commission Expires: -;rQY'\'-1,Cl'tf 31, 2021.(

Kathryn Hill Barret Notary Public Commonwealth of Virginia Reg. No. 7905256

' M~ Commission Expires January 31, 2024

Serial No.22-249 Docket No. 50-395 Page 3 of 4 ATTACHM ENTS

1. Description and Assessment
2. Current VCSNS Emergency Plan Pages Mark-up
3. Revised (Clean) VCSNS Emergency Plan Pages
4. Table B-1 Comparative Chart
5. ERO Position Impact Summary
6. No Significant Hazards Consideration Justification
7. Offsite Response Organization Concurrence Letters
8. References

Serial No.22-249 Docket No. 50-395 Page 4 of 4 cc: U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. G. Edward Miller NRC Senior Project Manager 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 V.C. Summer Nuclear Station Ms. Robin S. Mark Bureau of Environmental Health Services South Carolina Department of Health and Environmental Control 8500 Farrow Road - Building 17 Columbia, SC 29203 Mr. G. J. Lindamood Santee Cooper - Nuclear Coordinator 1 Riverwood Drive Moncks Corner, SC 29461

Serial No.22-249 Docket No. 50-395 ATTACHMENT 1 DESCRIPTION AND ASSESSMENT Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Dominion Energy South Carolina, Inc. (DESC)

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 1 of 59 TABLE OF CONTENTS

1.0 DESCRIPTION

............................................................................................................................................. 3 1.1

SUMMARY

DESCRIPTION OF PROPOSED CHANGES ...................................................................................................3

1.2 DESCRIPTION

OF PROPOSED CHANGES ..................................................................................................................6

2.0 TECHNICAL ANALYSIS

.............................................................................................................................. 14 2.1 PLANT SYSTEMS ..............................................................................................................................................15 2.1.1 Emergency Core Cooling Systems (ECCS) ...............................................................................................15 2.1.2 Plant Computer System ..........................................................................................................................16 2.1.3 Dose Assessment....................................................................................................................................17 2.2 TRAINING IMPROVEMENTS ................................................................................................................................18 2.2.1 Operations Training ...............................................................................................................................18 2.2.2 Shift Technical Advisor (STA) Training....................................................................................................19 2.3 PROCEDURE/PROCESS IMPROVEMENTS ...............................................................................................................19 2.3.1 Emergency Operating Procedures (EOPs) / Abnormal Operating Procedures (AOPs) ...........................19 2.3.2 Emergency Plan Implementation Procedures ........................................................................................20 2.3.3 Beyond Design Basis ..............................................................................................................................20 2.3.4 Procedure/Process Improvement Validation .........................................................................................21 2.3.4.1 Performance Based Procedure Analysis........................................................................................................ 21 2.3.4.2 Beyond Design Bases Analysis....................................................................................................................... 22 2.4 TECHNICAL

SUMMARY

.....................................................................................................................................23 3.0 FUNCTIONAL ANALYSIS ........................................................................................................................... 23 3.1 PLANT OPERATIONS AND ASSESSMENT OF OPERATIONAL ASPECTS ...........................................................................24 3.2 EMERGENCY DIRECTION AND CONTROL (COMMAND AND CONTROL, EMERGENCY CLASSIFICATION) ................................24 3.3 NOTIFICATION/COMMUNICATION FUNCTION .......................................................................................................27 3.4 RADIOLOGICAL ACCIDENT AND SUPPORT OF OPERATIONAL ACCIDENT ASSESSMENTS FUNCTION (DOSE ASSESSMENTS/PROJECTIONS, FIELD MONITORING TEAMS, RADIATION PROTECTION) ..................................................28 3.5 PLANT SYSTEM ENGINEERING, REPAIR AND CORRECTIVE ACTIONS FUNCTIONS ............................................................31 3.6 PROTECTIVE ACTIONS (IN-PLANT) FUNCTION .......................................................................................................33 3.7 FIREFIGHTING FUNCTION ..................................................................................................................................33 3.8 RESCUE OPERATIONS AND FIRST-AID FUNCTION ...................................................................................................34 3.9 SITE ACCESS CONTROL AND PERSONNEL ACCOUNTABILITY FUNCTION........................................................................34 3.10 ASPECTS ASSOCIATED WITH EOF RELOCATION ......................................................................................................35 3.10 (a) Proposed Changes .............................................................................................................................35 3.10 (b) Reason for the Proposed Changes .....................................................................................................38 3.10 (c) VCSNS Emergency Plan Background ..................................................................................................39 3.10.1 Functions ...........................................................................................................................................39 3.10.2 Location, structure, and habitability .................................................................................................44 3.10.3 Staffing and training..........................................................................................................................44 3.10.4 Size.....................................................................................................................................................45 3.10.5 Radiological Monitoring ....................................................................................................................48 3.10.6 Communications ................................................................................................................................48

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 2 of 59 3.10.7 Instruments, data system equipment, and power supplies ...............................................................49 3.10.8 Technical data and data system ........................................................................................................49 3.10.9 Records availability and management ..............................................................................................50

4.0 CONCLUSION

S ......................................................................................................................................... 50

5.0 REGULATORY ANALYSIS

.......................................................................................................................... 52 5.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA .............................................................................................52 5.2 APPLICABLE REGULATORY GUIDANCE ..................................................................................................................57 5.3 PRECEDENTS ..................................................................................................................................................58 5.4 NO SIGNIFICANT HAZARDS CONSIDERATION .........................................................................................................59

5.5 CONCLUSION

..................................................................................................................................................59

6.0 ENVIRONMENTAL CONSIDERATION

........................................................................................................ 59

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 3 of 59 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The VSCNS Emergency Plan, was originally reviewed and approved by the NRC as meeting the requirements established in NUREG-0654, Revision 1, [8.3] as documented by NRC Safety Evaluation Report (SER), dated January 1982 [8.4].

VCSNS has four Emergency Response Facilities (ERFs) augmenting the on-shift staff:

the TSC, the OSC, the EOF, and the Joint Information Center (JIC). During an emergency, the Shift Manager initially assumes emergency response command and control as the Interim Emergency Director (IED) until relieved by the Emergency Director.

VCSNS uses four standard levels of emergency classification as described in NUREG-0654, Revision 1, [8.3]. At the Alert or higher emergency classification levels, the TSC and OSC are activated. The EOF and JIC are activated at the Site Area Emergency or higher classification.

1.1 Summary Description of Proposed Changes Dominion Energy South Carolina (DESC) proposes revisions to the Virgil C. Summer Nuclear Station (VCSNS), Unit 1, Radiation Emergency Plan/Emergency Plan. The proposed change items are summarized below:

  • Extension of Emergency Response Organization (ERO) augmentation response times from 30 and 60 minutes to 60 minutes for support roles and 90 minutes for roles performing relief functions.
  • Extension of facility activation requirements for the Technical Support Center (TSC) and Operational Support Center (OSC) from 60 minutes to 90 minutes.
  • Addition of definition for facility activation criteria.
  • Reduction of the Emergency Action Level (EAL) classification at which the Offsite Survey Teams are dispatched from Site Area Emergency (SAE) to Alert.
  • Relocation of administrative positions from the VCSNS Emergency Plan to implementing procedures.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 4 of 59

  • Replacing the Emergency Operations Facility (EOF) and Joint Information Center (JIC) with the Corporate Emergency Response Center (CERC)
  • Generic ERO staff position title updates For the proposed changes, the following key points are further noted:

(1) Extension of facility activation requirements for the TSC and OSC from 60 minutes to 90 minutes following declaration of an emergency event classified as an Alert or higher The proposed change extends the facility activation timeframe for the TSC and OSC from 60 to 90 minutes, requiring performance of command-and-control activities by Control Room personnel for an additional 30 minutes. The process for transfer of command-and-control functions is outlined in Part 2, Section B of the proposed VCSNS Emergency Plan.

Provision of augmented staff to perform support functions for this 30-minute period is discussed in Section 3.0 of this attachment.

(2) Extension of the augmentation time for Emergency Response Organization (ERO) members from 30 and 60 minutes to 60 and 90 minutes The proposed change revises the VCSNS Emergency Plan by extending response timeframes for the augmented ERO. The additional time allows personnel previously precluded from assignment to the ERO as immediate responders due to significant commute times to fill augmented ERO positions. Extending augmentation times and reducing the number of augmented ERO positions increases the number of personnel eligible for assignment. The proposed change will not be applied as permission to delay response to an event.

In order to justify a 90-minute response time for certain VCSNS augmented resources, an analysis of site procedures and their bases was completed. The analysis evaluated event diagnostic/trouble shooting activities that would need to be performed by on-shift resources to address loss of critical safety functions for the first 90 minutes after an event.

The analysis also evaluated equipment failures in order to establish the sequence of actions taken in scenarios where procedure actions alone were not successful in the first 90 minutes after event initiation. The results of this analysis are included in Section 2.3 of this attachment.

The diverse and redundant nature of the Emergency Core Cooling System (ECCS) obviates the need for maintenance activities as part of the initial response to an event.

As a result, the proposed change removes references to performance of maintenance activities during the initial response to an event. The proposed change does not affect the requirements related to performance of maintenance activities after the first 90 minutes from declaration of an event. Details associated with the ECCS are addressed in Section 2.1.1 of this attachment.

The proposed changes credit technological advances, enhanced capabilities to restore safety functions, and other strategies to extend the augmentation response times.

Examples include the use of installed safety and non-safety systems and applicable Beyond Design Basis strategies. The credited strategies will continue to ensure actions

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 5 of 59 can be taken by on-shift resources to initiate troubleshooting and repairs of safety functions, and that extending the augmentation response times for TSC and OSC positions to 90 minutes will continue to ensure effective and timely emergency response.

(3) Revised definition of minimum staff and facility activation in the Emergency Response Facilities (ERFs) to align with new fleet standard criteria The proposed change revises the use of the term facility activation as it relates to Emergency Response Facility (ERF) readiness to accept emergency response functions and standardizes the facility activation criteria to better align with NRC guidance. The proposed change defines facility activation criteria to clearly identify the positions which must be filled in the TSC, OSC and CERC so that transfer of command-and-control functions (Classification, Notification, Protective Action Recommendations, Dose Assessment, Emergency Exposure Authorization) from the Control Room can be completed and on-shift personnel can be relieved of these duties. For the OSC, activated corresponds to the positions required to transfer oversight of in-plant teams from the Control Room. Revised figures have been added to the VCSNS Emergency Plan that delineate positions associated with facility activation. This change allows for the transfer of command-and-control functions from the control room in advance of 90 minutes when minimum staff positions are filled. Details associated with the revised ERO, and key responsibilities and tasks as identified in NUREG-0654, Revision 1, [8.3] and NUREG-0654, Revision 2, [8.1] Table B-1, are included in Section 3.0 of this attachment.

(4) Reorganization of Table B-1a based on EP functions to better align to NUREG-0654, Revision 2, [8.1], Table B-1 guidance NUREG-0654, Revision 2, [8.1] Table B-1, placed greater focus on EP functions performed by Plant Operations personnel. In this proposed change, only plant Operations personnel performing the EP functions of Classification, Notification, Core Damage Assessment, and on-shift ERO oversight are in included in Table B-1a. On-shift staffing requirements for Operations personnel is specified in VCSNS TS 6.2.2, Unit Staff. Other changes to the table include revisions of functional area descriptions to align with NUREG-0654, Revision 2 [8.1], Table B-1 and inclusion of positions required for activation of the TSC, OSC and EOF.

(5) Change to the classification level at which dispatch of Offsite Survey Teams is required from a Site Area Emergency (SAE) to an Alert or higher The current VCSNS Emergency Plan requires staffing of personnel for one (1) Offsite Field Monitoring Team (FMT) at 40 minutes, and a second Offsite Field Monitoring Team at 60 minutes, following the declaration of a Site Area Emergency or higher classification.

Dispatch of FMTs occurs at the declaration of a Site Area Emergency or higher. This proposed change revises the title of the environmental monitoring function to Offsite Monitoring Teams and revises the requirement for the dispatch of the teams from declaration of a Site Area Emergency to declaration of an Alert or higher classification.

Additionally, the proposed change combines the Onsite (out-of-plant) and In-Plant survey functions and extends the response time for RP qualified individuals performing these surveys from 30 minutes and 60 minutes to 60 minutes and 90 minutes, respectively.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 6 of 59 (6) Removal of references to chemistry, maintenance, firefighting, first aid/rescue, and site access control and personal accountability functions on-shift from Table B-1a Th proposed change removes VCSNS Emergency Plan references to positions performing non-EP functions in accordance with NUREG-0654, Revision 2, [8.1] Table B-1, Note iii. These positions are governed and maintained as required by TSs, the Fire Protection Plan, and site procedures. Reference to these positions/functions are also removed from other parts of the proposed VCSNS Emergency Plan as identified in of this submittal.

(7) Relocating the current VCSNS EOF and JIC to the Dominion Energy Corporate Emergency Response Center (CERC)

Dominion Energy purchased Virgil C. Summer Nuclear Station (VCSNS) in 2019.

Dominion Energy uses a Corporate Emergency Response Center (CERC) which currently functions as the consolidated emergency operations facility for North Anna Power Station (NAPS) and Surry Power Station (SPS). The proposed change would relocate the current EOF and JIC to the Dominion Energy CERC, located near Richmond Virginia. The proposed relocation of the VCSNS EOF and JIC is expected to have the following positive effects on VCSNSs emergency response capability:

Increased number of site ERO members available for assignment to other positions in the TSC and the Operational Support Center (OSC)

Increased efficiency due to using common practices and procedures in a single facility Enhanced availability of emergency response personnel due to EOF location being away from the reactor site which could be affected by a large-scale external event, hostile action, or radioactivity release The straight-line distance from the VCSNS TSC to the current EOF is 12 miles and the straight-line distance from VCSNS to the CERC is 312 miles. Moving the EOF to the CERC will not adversely affect the functional capabilities of the EOF. The current EOF site will retain its functionality as an alternative facility as prescribed by 10 CFR Part 50, Appendix E, Section IV.E.8.d.

In addition, a near-site facility for use by NRC and offsite responders close to the nuclear power reactor site will be located at the current Nuclear Operations Building.

1.2 Description of Proposed Changes A description of each of the proposed changes is presented in Table 1.2 - 1. Specific wording of each change is identified in Attachments 2 and 3 of this submittal.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 7 of 59 Table 1.2 - 1 Descriptions of Proposed Changes Change Section Description No.

1 Part 1, Changed title of Interim Emergency Director to Interim Station Emergency Section H Manager to align with Dominion fleet standard ERO.

2 Part 2, Realigned definitions of onsite and offsite ERO responsibilities, removed Section references to source departments for ERO positions, removed references to A.1.b Firefighting, First Aid and Security and realigned responsibilities for the Onsite ERO in accordance with the proposed change.

3 Part 2, Changed title of EOF Manager to Corporate Response Manager (CRM),

Section removed references to source departments for ERO positions and realigned A.1.b.2) responsibilities for Offsite ERO in accordance with the proposed change.

4 Part 2, Deleted reference to Emergency Public Information Organization (EPIO) as this Section organization is combined with the CERC response under the proposed change.

A.1.b.3) 5 Part 2, Deleted reference to Innsbrook Corporate Support Center (ICSC) as ICSC Section function will be performed at the CERC under the proposed change.

A.1.b.4) 6 Part 2, Deleted reference to the Emergency Control Officer as this position is replaced Section with the CERC Corporate Response Manager under the proposed change.

A.1.c.

7 Part 2, Removed references to fire protection, security and emergency preparedness Section and revised ED to SEM in accordance with the proposed change. Also A.4 revised Radiation Protection to Radiation Protection/Chemistry to align with the site organizational structure.

8 Part 2, Updated ERO position titles in accordance with the proposed change.

Section A.5 9 Part 2, Revised Figure A-2 to replace reference to the EOF and JIC with the CERC in Figure A-2 accordance with the proposed change.

10 Part 2, Removed details related to initial response phase as this is governed by the Section augmentation process outlines in Table B-1a. Removed references to B.1 operations, security, chemistry, fire brigade and medical response to align EP with NUREG-0654, Revision 2, Table B-1 positions. Revised ERO position tiles to align with Dominion fleet standards. Revised Radiation Protection to Radiation Protection/Chemistry to align with the site organizational structure.

11 Part 2, Revised position titles to align with Dominion fleet standards, removed Section references to activities associated with the Control Room, TSC and EOF as B.2 these duplicate responsibilities discussed in Section B.5.

12 Part 2, Revised position titles to align with Dominion fleet standards, added figure Section depicting process and flow for transfer of command-and-control functions B.3 between facilities and removed references to command-and-control transfer process as this is described in site procedures.

13 Part 2, Revised list of non-delegable duties to align with command-and-control Section functions as outlined in the figure in Section B.3, revised ERO position titles to B.4 align with Dominion fleet standards and removed references to CSD and ICSC in accordance with the proposed change.

14 Part 2, Revised to remove reference to Annex 1, Table 2-1 and Part 2, Section B-1 Section which are deleted as part of the proposed change, removed references to Onsite B.5 and Offsite ERO and the EPIO in accordance with the proposed change.

15 Part 2, Revised list of ERO positions to align with proposed changes and NUREG-0654, Section Revision 2, Table B-1 guidance, revised response times and added reference B.5.a to the Alternative Facility in accordance with the proposed change.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 8 of 59 Table 1.2 - 1 Descriptions of Proposed Changes Change Section Description No.

16 Part 2, Revised position titles to align with Dominion fleet standards, removed reference Section to operational duties performed outside of the EP in accordance with NUREG-B.5.a.1) 0654, Revision 2.

17 Part 2, Revised position titles to align with Dominion fleet standards.

Section B.5.a.2) 18 Part 2, Deleted reference to Emergency Preparedness Advisor as this position is not Section included in the proposed Emergency Plan. Activities previously performed by B.5.a.3) this position are performed by the State/Local Communicator in the TSC in accordance with the proposed change.

19 Part 2, Renumbered and revised position titles to align with Dominion fleet standard Section ERO.

B.5.a.3) 20 Part 2, Added description of new ERO positions in accordance with the proposed Section change.

B.5.a.4) through B.5.a.7) 21 Part 2, Renumbered and revised titles to align with Dominion fleet standard ERO.

Section B.5.a.8) through B.5.a.13) 22 Part 2, Added description of Radiation Protection Supervisor ERO position in Section accordance with the proposed change.

B.5.a.14) 23 Part 2, Revised titles to align with Dominion fleet standard ERO.

Section B.5.a.15) 24 Part 2, Replaced Security Lead position with the Emergency Security Director (B.5.a.7)

Section and relocated to the TSC.

B.5.a.12) 25 Part 2, Replaced references to Offsite ERO with CERC, revised reference for facility Section activation to Alert from Site Area Emergency, updated ERO position titles, B.5.b. removed reference to EPIO and replaced with a reference to the Joint Information System (JIS) as a function of the CERC.

26 Part 2, Revised section to reflect new position title and associated responsibilities in Section order to align with Dominion fleet standard ERO.

B.5.b.1) 27 Part 2, Revised and renumbered EOF Manager title to Technical Support Manager Section to reflect new position title and associated responsibilities in order to align with B.5.b.2) Dominion fleet standard ERO.

28 Part 2, Deleted Plant Engineering Advisor position to align with Dominion fleet Section standard ERO.

B.5.b.3) 29 Part 2, Revised and renumbered Offsite Radiological Monitoring Coordinator to Section Radiological Assessment Coordinator and revised description to align with B.5.b.4) Dominion fleet standard ERO.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 9 of 59 Table 1.2 - 1 Descriptions of Proposed Changes Change Section Description No.

30 Part 2, Added the Accident Assessment Team description to align with Dominion fleet Section standard ERO. This description replaces the Dose Assessor function as B.5.b.4) described in the current Plan.

31 Part 2, Revised and renumbered Communications Coordinator title to Operations Section Support Coordinator and associated description to align with Dominion fleet B.5.b.5) standard ERO.

32 Part 2, Added Operations Support Team at the CERC. This Team is responsible for Section tracking plant conditions and transmitting notification to State and local B.5.b.6) governments.

33 Part 2, Deleted State/County Communicator description as this position is Section incorporated into the Operations Support Team at the CERC.

B.5.b.8) 34 Part 2, Deleted Plant Security Advisor position. Security functions will be performed Section by site security personnel in accordance with the Site Security Plan.

B.5.b.9) 35 Part 2, Revised and renumbered General Services Coordinator position with Section Resource Support Manager to align with Dominion fleet standard ERO.

B.5.b.7) 36 Part 2, Added Resource Support Team description to align with Dominion fleet Section standard ERO.

B.5.b.8) 37 Part 2, Added Nuclear News Manager to align with Dominion fleet standard ERO.

Section B.5.b.9) 38 Part 2, Added News Team to align with Dominion fleet standard ERO.

Section B.5.b.10) 39 Part 2, Renumbered and revised work location for Chief Technical Spokesperson and Section removed reference to activities for coordinating with Public Information Officers.

B.5.b.11) 40 Part 2, Added Media Briefing Support Team description to CERC staff to align with Section Dominion fleet standard ERO.

B.5.b.12) 41 Part 2, Deleted Emergency Joint Public Information Center Organization (EPIO) as Section this function is incorporated into the CERC in accordance with the proposed B.5.c. change.

42 Part 2, Deleted Joint Information Coordinator, Technical Briefer and Corporate Section Support Director (CSD) positions to align with Dominion fleet standard ERO.

B.5.c.2),

3) and 4) 43 Part 2, Removed reference to Annex1 Table 2-1 and revised reference to Section B-Section 1 to read Section B as this section of the VCS Plan is being deleted under the B.6 proposed change.

44 Part 2, Overall ERO Command Structure is deleted and replaced with the TSC Figure B- Organization in accordance with the proposed change.

1a 45 Part 2, Onsite Emergency Response Organization is deleted and replaced by the new Figure B- Figure B-1a, TSC Organization and new Figure B-1b, OSC Organization in 1b accordance with the proposed change.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 10 of 59 Table 1.2 - 1 Descriptions of Proposed Changes Change Section Description No.

46 Part 2, Offsite Emergency Response Organization, deleted and replaced with the Figure B- CERC Organization in accordance with the proposed change.

1c 47 Part 2, Emergency Public Information Organization is deleted. This organization is Figure B- replaced by the CERC in accordance with the proposed change.

1d 48 Part 2, Staffing Requirements for the VCSNS ERO, deleted current table and replaced Table B- with revised table in accordance with the proposed change.

1a 49 Part 2, Removed reference to facility accommodation detail to align with EP structure Section for other Dominion sites.

C.1.c 50 Part 2, Revised to identify the near site location available for use by offsite response Section personnel.

C.2.a 51 Part 2, Revised ERO position titles in accordance with the proposed change and Section revised NRC notification requirement to more closely align to 10 CFR 50.72.

D.1.a 52 Part 2, Revised ERO position titles in accordance with the proposed change and Section revised NRC notification requirement to more closely align to 10 CFR 50.72.

D.1.b Removed reference to classification by the Shift Manager as this statement is not material to the classification level.

53 Part 2, Removal of reference to actions completed by the ED as these are not material Section to the classification level and removal of reference to Emergency Public D.1.c Information Organization in accordance with the proposed change.

54 Part 2, Removal of reference to actions completed by the ED as these are not material Section to the classification level.

D.1.d 55 Part 2, Revised ERO position titles in accordance with the proposed change and Section removed reference to the Recovery/Termination Checklist as this is described D.1.f in site procedures.

56 Part 2, Revised ERO position titles in accordance with the proposed change and Section replaced references to classification level with Recovery Phase.

D.1.g 57 Part 2, Deleted ECO since this position is eliminated in accordance with the proposed Section changes. This change also specifies that the Shift Manager remains solely D.1.h responsible for implementation of the Emergency Plan.

58 Part 2, Revised to reflect changes to ERO activation process at the Alert classification.

Section E.2.a 59 Part 2, Revised to delete reference to EMNet communication system, changed Section reference from the EOF to the CERC, and revised the description of general F.1.a backup communications capabilities in accordance with the proposed changes.

60 Part 2, Revised to replaced EOF with CERC in accordance with the proposed Section change.

F.1.b-d 61 Part 2, Removed EOF reference to use of PBX system.

Section F.1.b-d.1)

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 11 of 59 Table 1.2 - 1 Descriptions of Proposed Changes Change Section Description No.

62 Part 2, Deleted reference to EMNet system for state/local notification. An ORO Section notification system is referenced in Section L of the proposed change.

F.1.b-d.2) 63 Part 2, Renumbered and removed reference to JIC lines as these are not included as Section part of the communication system with the CERC.

F.1.b-d.2) 64 Part 2, Renumbered and replaced EOF reference with CERC in accordance with the Section proposed change.

F.1.b-d.4) and 5) 65 Part 2, Replaced references to EOF with CERC in accordance with the proposed Section change.

F.1.f 66 Part 2, Notification Scheme revised to replace EOF with CERC, updated position Figure F-1 titles and removed reference to full augmentation in accordance with the proposed change.

67 Part 2, ERF Communications Matrix revised to replace EOF with CERC and removed Figure F-2 reference to JIC as this is now included in the CERC facility and revised position titles in accordance with the proposed change.

68 Part 2, NRC Communications for Nuclear Response revised to replace EOF with Figure F-3 CERC in accordance with the proposed change.

69 Part 2, Removed reference to EPIO in accordance with the proposed change.

Section G.1 70 Part 2, Replaced reference to ICSC with CERC and added summary description Section related to news releases.

G.3.a 71 Part 2, Deleted description of JICEPI Organization in accordance with the proposed Section change.

G.3.a.1) 72 Part 2, Deleted description of the JIC. New description included in Section H.2. in Section accordance with the proposed change.

G.3.a.2) 73 Part 2, Deleted description of JIC staffing. Staffing described in Section H.2 and Section Section B, Figure B-1c.

G.4.a 74 Part 2, Replaced reference to Media and Rumor Control Monitor positions and added Section reference to Dominion Energy public information personnel as this group G.4.b performs these functions under the proposed change.

75 Part 2, Replaced EOF and JIC with CERC.

Section H 76 Part 2, Revised activation criteria for TSC and OSC, updated ERO position titles.

Section H.1 77 Part 2, Revised position title and replaced EOF and JIC with CERC.

Section H.1.a.

78 Part 2, Revised scope of emergency response actions from within the Protected Area Section to onsite to better reflect TSC responsibilities and replaced EOF and JIC with H.1.b. CERC

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79 Part 2, Updated position titles and removed reference to the location of the backup OSC Section being located in the building that houses the EOF in accordance with the H.1.c. proposed change.

80 Part 2, Revised to replace the Emergency Operations Facility description with that of Section the Corporate Emergency Response Center in accordance with the proposed H.2 change.

81 Part 2, Removed description of JIC. The JIC is an area within the CERC under the Section proposed change as described in Section H.2.

H.3 82 Part 2, Renumbered and added description of Alternative Facility.

Section H.3 83 Part 2, Renumbered and added description of the location for offsite agency Section coordination based on use of the CERC instead of the EOF in accordance with H.4 the proposed change.

84 Part 2, Renumbered and revised to remove note referencing NUREG-0654, Revision Section 1, Criterion II.B.5 based on proposed transition to NUREG-0654, Revision 2, H.6 standards. Revised section to reflect facility activation at the Alert or higher classification and remove description of JIC and ICSC staffing in accordance with the proposed change.

85 Part 2, Renumbered and revised reference to EOF with CERC in accordance with the Section proposed change.

H.7 and H.8 86 Part 2, Renumbered step, removed reference to EOF, and removed parenthetical Section reference that does not apply to the OSC.

H.11 87 Part 2, Renumbered and replaced reference to Emergency Operations Facility with Section Corporate Emergency Response Center and removed reference to H.13 flashlights/batteries as these are not required at the CERC. Updated reference to maps and drawing to account for electronic access to these items. Changed reference to a Dose Assessment Computer to Dose Assessment Capability.

88 Part 2, Revised to remove reference detail to align with other reference formats within Section I.2 the document.

89 Part 2, Replaced reference to EOF with CERC in accordance with the proposed Section I.5 change.

90 Part 2, Revised to reflect removal of requirement for onsite, 24-hour environmental Section I.8 survey capability and dispatch of Field Teams at the Alert rather than the Site Area Emergency classification.

91 Part 2, Revised ERO position titles to align with Dominion fleet standard ERO.

Section J.2, J.4 and J.5 92 Part 2, Revised department and position titles in accordance with the proposed change.

Section J.6 93 Part 2, Updated position titles and revised to reflect ability to develop protective action Section recommendations in the TSC if the CERC is unavailable.

J.7

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94 Part 2, PAR Flowchart, Note 2, replaced reference to EOF with CERC in accordance Figure J-2 with the proposed change.

95 Part 2, Revised ERO position titles to align with Dominion fleet standard ERO and Section K department titles in accordance with the proposed change.

96 Part 2, Revised department title in accordance with the proposed change.

Section L.1 97 Part 2, Deleted section referencing First Aid as this program is managed outside of the Section VSCNS EP.

L.2 98 Part 2, Revised and renumbered to replace reference to EMNet with generic ORO Section notification system reference to remove EP obsolescence issues as well as L.2 department title changes in accordance with the proposed change.

99 Part 2, Revised ERO position titles to align with Dominion fleet standard ERO in Section accordance with the proposed change.

M.1.a and b

100 Part 2, Recovery Organization description to align with CERC processes, replaced Section department titles and removed positions descriptions now discussed in Figure M.2 M-1.

101 Part 2, Inserted organizational figure for example Recovery Organization to align with Figure M- the Dominion standard for event response.

1 102 Part 2, Removed reference to communication between the EOF and JIC as both of Section these functions are maintained as part of the CERC in accordance with the N.2.b proposed change.

103 Part 2, Removed reference to fire drills as these are managed outside of the VCSNS Section Emergency Plan.

N.2.c 104 Part 2, Renumbered and removed reference to the EOF and the JIC as these are Section incorporated into the CERC in accordance with the proposed change.

N.2.f 105 Part 2, Removed section related to First Aid Response as this function is managed Section outside the VCSNS Emergency Plan.

O.3 106 Part 2, Renumbered and revised to remove the reference to the EPIO in accordance Section with the proposed change.

O.3 107 Part 2, Renumbered and revised ERO position titles to align with Dominion fleet Section standard ERO.

O.3.a 108 Part 2, Replaced reference to EMNet with ORO notification system to remove Section potential Plan obsolescence issues.

O.3.b.

109 Part 2, Revised department title in accordance with the proposed change.

Section O.3.c 110 Part 2, Renumbered and removed references to Police, Security, Fire Brigade, Section Operations and Chemistry activities as these are governed outside of the O.3.d-h

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VCSNS EP. Revised department titles in accordance with the proposed change.

111 Part 2, Renumbered and removed references to EPIO Personnel as they are Section incorporated into the CERC in accordance with the proposed change.

O.3.i 112 Annex 1, Deleted section as this information duplicates information included in Part 2 of Section 2 the VCSNS Emergency Plan.

113 Annex 1, Updated to reflect titles and activation time changes. Removed reference to first Section aid, search, and rescue in accordance with the proposed change.

4.C 114 Annex 1, Deleted section. Laboratories will be maintained by site chemistry department Section D as required by site Technical Specifications.

115 Annex 1, Deleted section. First Aid program elements are maintained by the Operations Section E Department and described in operations procedures.

116 Annex 1, Replaced EOF reference with CERC in accordance with the proposed change.

Section 4.2 117 Appendix Revised definitions associated with facility and position changes in accordance 4 with the proposed change.

2.0 TECHNICAL ANALYSIS

This section discusses plant system, design and reliability and technological changes in dose assessment, procedures and training which have been completed to better support on-shift functions and ease operator burden. An on-shift analysis utilizing NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities,

[8.27] methodology determined that the proposed changes did not result in conflicting duties for on-shift personnel. Crediting diverse and redundant ECCS design, defense in depth capability through use of non-safety systems, Beyond Design Basis strategies, and the results of an analysis of troubleshooting and repair/corrective action procedures supports extension of augmented response times to 60 minutes and 90 minutes and is a reasonable and prudent means to ensure that no degradation or loss of function results from the proposed changes.

Regarding the proposed EOF relocation, NUREG-0696, Functional Criteria for Emergency Response Facilities, [8.9] describes the facilities and systems that nuclear power plant licensees can use to improve emergency response to accidents, such as the EOF, TSC, and OSC. NRC Interim Staff Guidance (ISG) NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, [8.7] also provides guidance on the functional criteria for ERFs and on the integrated support these facilities provide to the Main Control Room (MCR). These documents describe an acceptable method for complying with the requirements of 10 CFR 50, Appendix E, Section IV.E.8.

Section 3.10 below utilizes the guidance in NUREG-0696, [8.9] to demonstrate the acceptability of the CERC for use as the VCSNS EOF/JIC. Attachment 2 and 3 contain

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 15 of 59 the affected VCSNS Emergency Plan mark-up and clean pages associated with the proposed changes .

2.1 Plant Systems 2.1.1 Emergency Core Cooling Systems (ECCS)

VCSNS UFSAR, Chapter 3, provides discussion on how VCSNS conforms to Appendix A to Part 50, General Design Criteria for Nuclear Power Plants. This includes conformance with General Design Criterion (GDC) 35 which states:

A system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented, and (2) clad metal-water reaction is limited to negligible amounts.

Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to ensure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

The VCSNS ECCS utilizes abundant cooling water that is available to the core at a rate sufficient to maintain the core geometry and assure that the post-accident clad metal-water reaction is limited to less than 1%. The design is adequate to ensure performance of the required safety functions even with the loss of a single component, assuming electric power is available from either the offsite or the onsite electric power sources.

Relative to emergency power for ECCS, Section 3.1.2.2 of the VCSNS UFSAR describes the VCSNS electrical power system conformance with GDC 17, which states:

An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed and located so as to minimize to the extent practical the likelihood

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 16 of 59 of their simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

To conform to this GDC, VCSNS employs onsite and offsite power systems that can independently supply the electric power required for the operation of safety-related systems. The onsite power required to operate Engineered Safety Features (ESF)

System equipment is supplied by two diesel generators. The offsite power required to operate safety-related systems is supplied by two independent sources, one from the 230 kV system and one from the 115 kV system. Each source supplies total power requirements for either one or both of the redundant and independent power distribution systems for the ESF Systems.

Normal ESF operating status and deviations from this status, including the ECCS and associated power sources, is controlled by the VCSNS Technical Specifications.

System performance is tracked and trended by the site and has demonstrated a high degree of reliability. System health requirements are maintained, based on NRC Performance Indicators for system availability and functional failures, which are an integral part of the Reactor Oversight Process (ROP). Additionally, safety-system reliability is driven by Maintenance Rule performance criteria.

The robust ECCS capability, performance, reliability, and protection against single point failures provides the basis for removal of maintenance personnel from on-shift.

2.1.2 Plant Computer System Through the 1980s and 1990s, multiple computer system upgrades have taken place at VCSNS. These upgrades include replacement of the P2500 Computer with the Integrated Plant Computer System (IPCS) which was capable of real-time data collection and monitoring, and a reporting system that acquired data from plant instruments and other plant computer subsystems. The data generated by the IPCS was displayed in the MCR, TSC, and EOF and interfaced with the Data Display System (DDS) computer for use on the local network.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 17 of 59 In 2004, IPCS was replaced with a Windows PC based system. This change increased computing power and computer memory, and includes a system storage capacity to allow for more effective display of information.

Benefits of the upgraded system include:

  • Graphing and trending capabilities
  • Historical data recording and retrieval through the Database Display System (DDS)
  • Design provides for a high degree of reliability through use of redundant system processes
  • Uninterruptable Power Supplies are installed on Plant Computer servers 2.1.3 Dose Assessment For on-shift dose assessors, an automatic data feed from the Integrated Plant Computer System (IPCS) to the dose projection software is normally used to auto-populate the radiological and meteorological data for performing dose projections. In addition, specifically designed displays on the IPCS have been developed that obtain and monitor the necessary plant, radiological effluent, area radiation monitor, and meteorological information for assessing release status and for manual entry of relevant data for performing dose projections.

Previous on-shift dose assessment Previous primary dose assessment capability during the early 1980s was based on Emergency Assessment and Response System (EARS). EARS was installed on a limited number of HP 9845 computers, including one in the TSC and one in the EOF. The dose calculation of whole body and child thyroid dose used a segmented gaussian plume model. Requiring manual input, source term was calculated from post-accident sample analysis, grab samples, plant vent monitor, containment purge monitor, main steam line monitors, containment leakage information, and FSAR based default assumptions. A manual back-up calculation method was provided for cases where the EARS was not available. Dose Assessment originating from on-shift Control Room personnel was based on nomograms. In 1988, EARS was replaced with the Emergency Dose Assessment Program (EDAP). EDAP used a straight line gaussian plume model, requiring manual input of radiation monitor and meteorological data. Source term mixture was based on FSAR accident analysis assumptions. Capability for dose assessment using back calculation of field team surveys and analysis was also provided.

During 2009, the Meteorological Information and Dose Assessment System (MIDAS-NU),

a Windows based PC application, was approved for use on site. Calculated dose rates and integrated dose for whole body and adult thyroid were based on plume shine, ground shine, and inhalation, and provided ingestion pathway dose out to fifty miles. The dose

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 18 of 59 calculation utilized source term from FSAR design bases accident analysis descriptions.

The MIDAS-NU dose model utilized two dispersion models. The first model was based on a time dependent variable trajectory Gaussian plume model that enables the plume direction and location to vary every fifteen minutes as weather conditions change. The second model, used for back calculation from field measurements, was simplified, estimating transport and dispersion in a uniform wind field with no changes in wind speed or direction. This software provided capability for automatic input of basic meteorological data and radiological data from the plant computer system or manual input by the user.

Additional data was input by the user to complete the dose assessment calculation.

MIDAS-NU ran on PCs located in the HP Count Room, EOF and TSC adjacent to the Control Room.

Current on-shift dose assessment In 2014, VCSNS implemented an upgrade to MIDAS-NU. The upgrade included use of an event tree to determine isotopic mixtures used in dose calculations based on NUREG-1228, [8.21] and RTM-96, [8.22] guidance as well as the capability to project dose for multiple accidents. Additionally, the use of an automatic feature for auto-collection of meteorological and radiation monitor data was implemented.

MIDAS-NU software is periodically tested and provided, at a minimum, on dedicated workstations in the HP Count Room, EOF, and the TSC adjacent to the Control Room to ensure dose assessment capability. In addition, MIDAS-NU software can be run from any computer that has been loaded with the MIDAS-NU software. Meteorological and radiation monitor data is automatically retrieved from the plant computer or input manually if data is not available from the plant computer or is suspect. If manual entry of data is required, the data can be obtained from specialized MIDAS displays on the plant computer. Event Tree selections utilizing drop-down menus allow the user to select or modify the mix of isotopes being released from the plant based on selections that address plant conditions and mitigating system status. This dose assessment process is utilized by on-shift and augmented responders. The automated input of meteorological and radiological data into the MIDAS software, in conjunction with the menu driven data input methodology, supports performance of timely and accurate dose projections by the on-shift and augmented dose assessors.

2.2 Training Improvements 2.2.1 Operations Training Training is used to strategically drive and sustain improved performance at VCSNS and is administered through the application of the Systematic Approach to Training (SAT) to ensure that accredited training is conducted in accordance with industry-accepted standards in INPO ACAD-02-001, [8.25] The Objectives and Criteria for Accreditation of Training in the Nuclear Power Industry.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 19 of 59 A dynamic reference plant simulator is used during Operations Training to provide hands-on experience and practice in the operation of the nuclear control room during normal, abnormal, and emergency plant conditions. The site training procedures describe the conduct of crew-specific simulator training. Evaluation scenarios are designed to be realistic and provide an opportunity for performance evaluation during a wide range of plant operating conditions including emergency conditions that require implementation of the stations Emergency Plan. The proficiency of the control room team is evaluated in the areas of critical task performance, prioritization of activities, communications, accident mitigation, event classification, teamwork, and communications.

2.2.2 Shift Technical Advisor (STA) Training The STA performs independent assessments of plant parameters, monitors status trees, provides recommendations on appropriate corrective actions to restore plant parameters to acceptable values and assesses whether core damage has occurred or appears imminent. The STA also assists the Shift Manager with operability, risk and reportability determinations. The Shift Technical Advisor (STA) training program was developed to train the STA as an advisor to the control room team in accordance with the guidelines of NUREG-0737 [8.23]. In 1990, INPO developed additional training guidelines as detailed in INPO 90-003, [8.32] Guidelines for Training and Qualifications of Shift Technical Advisors. In 2014, INPO issued updated STA Training Guidance, INPO ACAD 14-002,

[8.33] Guidelines for Training and Qualifications of Shift Technical Advisors, which incorporated industry experience and addressed the STA role in Beyond Design Basis strategies. The site training procedure describes the content of simulator training for the role of the STA.

2.3 Procedure/Process Improvements VCSNS utilizes emergency response and supporting procedures developed in accordance with NUREG-0737, [8.23] and 0737, Supplement 1 [8.24]. The development process was based on direct analysis of accidents and transients. The conditions directed by NUREG-0737, [8.23] included needs analyses based on events contained in the Final Safety Analysis Report, loss of instrumentation busses, and natural phenomena such as earthquakes, floods, and tornadoes.

2.3.1 Emergency Operating Procedures (EOPs) / Abnormal Operating Procedures (AOPs)

VCSNS EOPs have been improved through incorporation of internal operating experience and industry initiatives since the original emergency plan approval. Current EOPs use a symptom-based approach that demands less assessment and interpretation of plant conditions by the operating crews. The EOPs interface with the Integrated Plant Computer System (IPCS) allows for electronic monitoring of Critical Safety Function Status Trees (CSFSTs) which graphically display plant conditions relative to limits or required actions and provides a recommendation regarding which EOP applies. Overall,

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 20 of 59 the improvements made to EOP procedures greatly reduce the operators reliance on the emergency response organization during the initial phases of any event.

The current EOP/AOP procedures support a broad range of events within the design basis and the current event response procedures were developed in accordance with NUREG-0899, [8.26] Guidelines for the Preparation of Emergency Operating Procedures. These procedures implement a function-based program to assist in mitigating the consequences of a broad range of accidents and equipment failures.

These procedures are indication based and direct the Operations crew through a sequence to determine equipment availability to maintain the plant in a safe condition regardless of the specific event.

2.3.2 Emergency Plan Implementation Procedures In 2009, VCSNS updated the classification methodology to NEI 99-01, Revision 5 [8.28].

VCSNS further updated EALs in 2015 to NEI 99-01, Rev 6 [8.29]. These EALs were approved by the NRC via letter dated April 13, 2015 [8.6]. The current VCSNS EALs contain guidance that has simplified the classification process, including the use of an overview matrix of EAL initiating conditions and threshold values that streamlines the process of evaluating EALs against plant conditions. The current EALs allow the on-shift operators to focus on event mitigating actions without the aid of the emergency response organization during the initial phases of any event. Additionally, IPCS includes visual and audible alarm indications for Radiation Monitors that correspond to EAL criteria.

2.3.3 Beyond Design Basis The Beyond Design Basis measures provide additional capabilities supporting the on-shift staff based on the assumption that the site could be isolated for up to six hours.

VCSNS has developed BDB and FLEX Strategies in accordance with NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, [8.30] in order to provide protection against a broad range of extreme external hazards. Site specific assessments of a broad spectrum of possible external hazards were completed in accordance with Appendix B of NEI 12-06, [8.30]. The strategies resulting from the site-specific assessments provided greater diversity and flexibility to cope with a wider range of potential damage states.

The FLEX procedures utilize the pre-developed engineering strategies from the NEI 12-06, [8.30] assessment to provide alternate core cooling designed for use by the minimum administrative level staff with the assumption that the site will be inaccessible for up to six hours. The FLEX procedures have been validated using the minimum administrative level staff established to meet the requirements of NEI 12-01, Guideline for Assessing Beyond Design Basis (BDB) Response Staffing and Communications Capabilities. [8.31] The proposed on-shift staffing described in this LAR will not impact the established minimum administrative level staffing. Additionally, a detailed procedural analysis supporting the

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 21 of 59 proposed changes in this LAR confirmed the diagnostic steps in the EOPs can be performed by the proposed on-shift staff.

Sample scenarios evaluated during the staffing analyses included a large break loss of cooling accident (LBLOCA) and station blackout (SBO) with extended loss of AC power.

The scenarios assumed that the event occurred during off-hours with only on-shift staff available for response.

For the LBLOCA event there is a loss of offsite power with emergency diesels available and the initiation of safety injection (SI). The response by Operations during the first 90 minutes via EOPs is to address the SI through implementation of manual actions and transition to FRP FR-P.1, Response to Imminent Pressurized Thermal Shock Condition, with monitoring of critical safety function status. The FRP provides the steps needed to effectively integrate the strategy.

Further supporting the on-shift staffing analysis meeting the requirements of NEI 12-01,

[8.31] DESC validated the ability of the isolated on-shift staff to implement strategies and documented in a detailed FLEX Validation Technical Report, [8.34] and in accordance with the requirements of NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Appendix E [8.30]. The validation was intended to provide reasonable confidence that required tasks, manual actions and decisions for FLEX strategies are feasible and can be executed within the constraints identified in the Overall Integrated Plan (OIP) / Final Integrated Plan (FIP) for Order EA-12-049 [8.35].

The detailed procedural analysis performed for this submittal, the on-shift staffing analyses performed to validate FLEX strategies, and the detailed FLEX Validation Technical Report [8.34] performed by DESC provides reasonable assurance that the diagnostic aspects of troubleshooting necessary to ensure the plant is maintained in a safe condition can be performed by the proposed on-shift staff during the first 90 minutes after an emergency declaration of an Alert or higher.

2.3.4 Procedure/Process Improvement Validation VCSNS performed detailed procedural analyses to validate the effectiveness of the proposed procedural changes identified to support the request for extended augmentation times.

2.3.4.1 Performance Based Procedure Analysis A performance-based analysis of applicable procedures and their bases was completed to provide the technical justification described in RIS 2016-10 [8.2]. This analysis included VCSNS emergency response and supporting procedures to determine if additional personnel resources, beyond the proposed on-shift staff, were required to support any plant and radiological response actions during the first 90 minutes after an emergency declaration of an Alert or higher.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 22 of 59 The procedure analysis demonstrated on-shift personnel were able to perform required diagnostic activities for the first 90 minutes. The applicability to the specific functions addressed in NUREG-0654, Revision 2, [8.1] are addressed individually in Section 3, Functional Analysis.

2.3.4.2 Beyond Design Bases Analysis NEI 12-01 [8.31] Guideline for Assessing Beyond Design Basis Response Staffing and Communications Capabilities The proposed on-shift staffing described in this LAR will not impact the established minimum administrative level staffing used in the NEI 12-01, Guideline for Assessing Beyond Design Basis (BDB) Response Staffing and Communication Capabilities [8.31]

assessment, and the capability for successful implementation of FLEX strategies is maintained.

FLEX Validation Technical Report VC-Report-000-TR00080-007 [8.34]

As discussed in Section 2.3.3, DESC validated the ability of the isolated on-shift staff to implement strategies as documented in a detailed FLEX Validation Technical Report,

[8.34] and in accordance with the requirements of NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Appendix E [8.30]. The validation was intended to provide reasonable confidence that required tasks, manual actions and decisions for FLEX strategies are feasible and can be executed within the constraints identified in the Overall Integrated Plan (OIP) / Final Integrated Plan (FIP) for Order EA-12-049 [8.35].

The validation process was focused on assuring confidence in the reliability of the actions required. The validation process included specific analysis of actions requiring initiation within the six-hour period when the site is anticipated to be inaccessible. The validation process included:

  • Simulated Scenario - A timed validation method using a simulator or mock-up to validate a decision or action in a procedure/guideline.
  • In-plant Timed Walkthroughs and/or Timed Demonstrations - A timed validation method where procedure/guideline performance is simulated by walking through the procedure/guideline steps at the locations specified in the procedure/guideline and/or by demonstrating the action through the physical deployment of equipment, if appropriate.

No manipulation of installed plant equipment is required.

  • Reasonable Judgment - A validation method used to estimate the time required to accomplish a portion of a Timed Sensitive Action (TSA), where Simulator and In-plant Timed Walkthrough methods are not practicable for the task to be performed due to safety of plant/personnel concerns. If used, Level A reasonable judgment should be based on prior performance of similar tasks or evaluations. A TSA cannot be validated solely with Level A Reasonable Judgment.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 23 of 59 Equipment necessary to accomplish each FLEX strategy was deployed from its storage location and staged at its designated staging point. Any connectivity challenges were identified in the Stations corrective action program and were resolved prior to the required NRC Order compliance date.

The FLEX Validation Technical Report [8.34] demonstrated, with reasonable confidence, the stations ability to execute individual FLEX strategies. Each validation demonstrated the ability to execute individual FLEX strategies with sufficient margins to respond to unforeseen challenges.

2.4 Technical Summary The sections under 2.0 described the following:

  • The improved on-shift processes
  • Diverse and redundant ECCS design
  • Improved access to plant information due to improvements in the Plant Computer System
  • Improvements in dose assessment capabilities
  • Enhanced training for on-shift staff
  • Procedural/process improvements
  • Development and deployment of Beyond Design Basis processes In summary, this LAR concludes that VCSNS defense in depth capability is sufficient to support the extension of plant augmentation times. Plant system design and reliability, improvements to software, training, and procedures, and the development and implementation of beyond design basis strategies have reduced burden on on-shift staff in responding to potential emergencies. Analyses of procedures and required staff responses, including the validation of FLEX strategies in accordance with NEI 12-06, Appendix E [8.30] requirements, supports the extension of augmented response times and confirms that on-shift personnel will remain capable of implementing response strategies without conflicts in on-shift assignments. These analyses ensure that the diagnostic aspects of troubleshooting necessary to ensure the plant is maintained in a safe condition can be performed by the on-shift staff until augmented.

3.0 FUNCTIONAL ANALYSIS The functional analysis evaluates the effect of extending augmentation times on the ability of on-shift staff to perform the major tasks for the major functional areas described in the VCSNS Emergency Plan. The functional analysis demonstrates that no degradation or loss of function would occur as a result of the proposed changes.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 24 of 59 The results of the function analysis for the major EP functional areas as described in NUREG-0654, Revision 1, [8.3] and Revision 2, [8.1] Table B-1 are provided below. In addition, NUREG-0696, [8.9] as updated by NSIR/DPR-ISG-01, [8.7] Emergency Planning for Nuclear Power Plants, provides guidance for complying with 10 CFR 50, Appendix E, Section IV.E.8. The information provided below addresses this guidance to demonstrate acceptability of the proposed EOFs attributes with respect to VCSNS.

In general, the analysis is organized in three parts to provide details related to each of the areas:

VCSNS Emergency Plan, Revision 5 The current VCSNS Emergency Plan The proposed VCSNS Emergency Plan 3.1 Plant Operations and Assessment of Operational Aspects NUREG-0654, Revision 1, [8.3] assumes the function of plant operations and assessment of operational aspects is performed by on-shift staff throughout the emergency. NUREG-0654, Revision 2, [8.1] replaced the Plant Operations and Assessment of Operational Aspects Major Functional Area with Command and Control and Emergency Classifications. Revision 2 placed greater focus on EP Functions performed by plant Operations personnel.

In the proposed change, only plant Operations personnel performing EP functions of classification, notification, core damage assessment and on-shift ERO oversight are included in Table B-1a. On-shift staffing of Operations personnel is maintained under VCSNS Technical Specification (TS) 6.2.2, Unit Staff. This change is aligned with NUREG-0654, Revision 2, [8.1] Table B-1, as noted in the Table B-1 Comparative Chart, provided in Attachment 4.

3.2 Emergency Direction and Control (Command and Control, Emergency Classification)

NUREG-0654, Revision 1, [8.3] guidance indicates that the on-shift Emergency Coordinator assumes this function as a collateral duty where responsibility for overall direction of facility response may be transferred after ERFs are activated. NUREG-0654, Revision 1, [8.3] also has a position responsible for evaluation of plant conditions and classification recommendations as an ancillary duty. NUREG-0654, Revision 2, [8.1]

identifies a position responsible for overall command and control of the Emergency Response Organization (ERO), Emergency Action Level (EAL) approval and authorization of personnel dose extensions.

In Revision 5 of the VCSNS Emergency Plan, the Shift Supervisor would assume the duties of Interim Emergency Director and would be responsible for emergency response efforts until relieved. Activation of the TSC and OSC was initiated at an Alert

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 25 of 59 or higher classification and activation of the EOF at the Site Area Emergency (SAE) or higher classification. Augmentation capability to support on-shift staff within 30 and 60 minutes was established. In Revision 65 of the VCSNS Emergency Plan, the Shift Supervisor (SS) position was renamed Shift Manager (SM).

The current VCSNS Emergency Plan maintains the Revision 5 augmentation times and transition of event responsibilities from the Control Room to the TSC at the Alert classification, and subsequently to the EOF upon declaration of a Site Area Emergency or higher classification. The Shift Manager assumes the duties of Interim Emergency Director and is responsible for emergency response efforts until relieved. Activation of the TSC and OSC are initiated at an Alert or higher classification and the EOF at a Site Area Emergency (SAE) or higher classification. Augmentation capability to support on-shift staff within 30 and 60 minutes is required to be established.

The proposed change revises the title of Interim Emergency Director (IED) to Interim Station Emergency Manager (ISEM) to align with Dominion standard ERO titles and maintains event classification as a responsibility of this position. The ISEM also has responsibility for staffing of the TSC and OSC at an Alert or higher classification. The proposed change extends TSC Station Emergency Manager (SEM) and Emergency Operations Manager response times from 60 minutes to 90 minutes. The change also replaces the existing 60-minute EOF response time at a SAE or higher classification with 90-minute response time at the Corporate Emergency Response Center (CERC) at an Alert or higher classification.

Classification The proposed change extends the timeframe for event classification by the SM/ISEM by 30 minutes. The procedure analysis demonstrated that oversight of the plant is maintained by the Unit Shift Supervisor, allowing the SM/ISEM to maintain focus on event classification. Additionally, the proposed change maintains the Shift Technical Advisor (STA) position for performance of the core damage assessment function and providing support to the SM/ISEM in performing the classification function. The availability of the Unit Shift Supervisor and the STA position provides the support needed to allow the SM/ISEM to perform the Classification function for the first 90 minutes after an event without conflicts.

Command and Control The proposed change impacts the command-and-control function by adding a definition of facility activation for the TSC, OSC and CERC. The proposed change also extends the time during which responsibility for oversight of on-shift ERO and event command and control functions, including PAR development and authorization of personnel dose extensions, will be performed by the SM/ISEM by 30 minutes.

The NRC Emergency Communicator continues to be augmented at 60 minutes and reports to the Control Room to support performance of the Notification/Communication function until it is transferred to the CERC. Likewise, the Dose Assessment Team Leader is augmented at 60 minutes to support the dose assessment function, along with three

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 26 of 59 (3) RP qualified individuals and one (1) Offsite Monitoring Team that provide support for the radiological assessment functions, as described in section 3.4.

Upon activation of the TSC, OSC and CERC at an Alert or higher classification, typical transfer of State/local Notification and Protective Action Recommendation functions will occur from the Control Room to the CERC while event Classification, Federal Notification and Emergency Exposure Authorization functions transfer from the Control Room and to the TSC. Responsibility for oversight of the ERO in the plant transitions from the Control Room to the OSC.

The proposed change defines facility activation and clearly identifies the positions which must be filled in the TSC, OSC and CERC so that transfer of command-and-control functions (Classification, Notification, Protective Action Recommendations, Dose Assessment, Emergency Exposure Authorization) from the Control Room can be completed and on-shift personnel can be relieved of these duties. For the OSC, activated corresponds to the positions responsible for oversight of on-shift ERO once transferred from the Control Room.

The proposed definition for facility activation is based on responder availability to perform response actions in each facility and identifies the following required minimum staff positions associated with command and control as noted in revised VCSNS Emergency Plan Figures B-1a, B-1b, and B-1c:

  • Station Emergency Manager (TSC)
  • Emergency Operations Director (TSC)
  • Radiological Assessment Director (TSC)
  • Dose Assessment Team Leader (TSC)
  • Reactor Engineer (TSC)
  • NRC Emergency Communicator (TSC)
  • State/local Communicator (TSC)
  • Technical Support Manager (CERC)
  • Radiological Assessment Coordinator (CERC)
  • Operations Support Coordinator (CERC)
  • Dose Assessor (CERC)
  • State/local Communicator (CERC)

This change allows for the transfer of command-and-control functions from the Control Room in advance of 90 minutes if minimum staff positions are filled. The availability of the on-shift dose assessor and communicator to support Notification, PAR and exposure control for 60 minutes until augmented, and the additional oversight support provided by

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 27 of 59 the Dose Assessment Team Leader within 60 minutes of an Alert or higher classification, enables performance of command-and-control functions by the SM/ISEM for the initial 90 minutes after an event. This definition continues to be aligned with NSIR/DPR-ISG-01 guidance [8.7].

3.3 Notification/Communication Function Per NUREG-0654, Revision 1, [8.3] the Notification/Communication function included major tasks to notify licensee, state, local and federal personnel and maintain communications. NUREG-0654, Revision 2, [8.1] Table B-1, maintains the function as described in NUREG-0654, Revision 1 [8.3].

Licensee Notification Revision 5 of the VCSNS Emergency Plan identified notification of licensee off duty personnel as a responsibility of the Shift Supervisor/Interim Emergency Director (SS/IED).

This notification was completed at an Alert or higher classification or when deemed necessary by the SS/IED. In Revision 65, the title of the Shift Supervisor was changed to Shift Manager (SM).

The current VCSNS Emergency Plan maintains the Revision 5 responsibility for ERO notification at an Alert or higher classification.

For the proposed change, there are no revisions to the performance of ERO notification function.

State, Local and Federal Notification In Revision 5 of the VCSNS Emergency Plan, state/local and federal notifications were performed by an on-shift individual and augmented by one (1) responder at 30 minutes and two (2) additional 60-minute responders. Through Revision 67, two (2) additional 60-minute responders were added to the augmented response. The addition of the two additional responders was the result of an observation during a 2014 NRC Inspection that identified the notification duty for completion of the Emergency Notification Form (ENF) by Emergency Planning Representatives in the ERO was not described in the VCSNS Emergency Plan.

The current VCSNS Emergency Plan maintains the on-shift and augmented organization for the state/local and federal notification functions as described in Revision 67 with one (1) responder at 30 minutes and four (4) additional 60-minute responders.

The proposed change maintains the on-shift resource for performance of state/local and federal notification functions, and augmented support at 60 minutes by the NRC Emergency Communicator. The proposed change extends the augmentation time of the State/Local Communicator in the CERC to 90 minutes. The NRC Emergency Communicator initially reports to the Control Room to provide support for the on-shift notification function and then transitions to the TSC upon activation of the facility at 90

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 28 of 59 minutes. Performance of the Notification function was validated during the OSA to ensure there were no conflicting duties for on-shift personnel as a result of the proposed changes.

Additionally, the proposed change revises the responsibilities of the State/Local Communicator in the TSC to include completion of the Emergency Notification Form (ENF), if the CERC is unavailable, and removes the EP Advisor position from this facility.

This change aligns with Dominion TSC organizational staffing.

The use of the on-shift resource for performance of notification activities for the first 60 minutes until augmented by the NRC Emergency Communicator ensures there is no loss of capability resulting from extending this on-shift responsibility for an additional 30 minutes. The proposed change is aligned with NUREG-0654, Revision 2, [8.1] staffing for the 60-minute augmented response time for this function.

3.4 Radiological Accident and Support of Operational Accident Assessments Function (Dose Assessments/Projections, Field Monitoring Teams, Radiation Protection)

Per NUREG-0654, Revision 1, [8.3] the Radiological Accident Assessment and Support of Operational Accident Assessment functional area includes the Emergency Operations Facility (EOF) Director; Offsite Dose Assessment; Offsite, In-Plant and On-site (Out-of-plant) surveys; and Chemistry/Radiochemistry major tasks. NUREG-0654, Revision 2,

[8.1] Table B-1 changed the functions associated with radiological accident assessment to address radiological aspects only.

EOF Director Major Task Revision 5 of the VCSNS Emergency Plan included simultaneous staffing of the TSC and OSC at an Alert or higher classification with the EOF activated at a SAE or higher classification. Initial direction and coordination of onsite emergency operations functions transitioned from the SS/IED in the Control Room to the ED in the TSC and subsequently to the Emergency Control Officer (ECO) at the EOF. Details regarding Direction and Control of Emergencies are discussed in Section 3.2 of this Attachment.

Offsite Dose Assessment Major Task In Revision 5 of the VCSNS Emergency Plan, performance of dose assessment on-shift was not specifically addressed. Initial performance of dose assessment was completed by the 30-minute responder. Two (2) EOF dose assessment positions responding at 60-minutes were added to the VCSNS Emergency Plan in Revision 60 as part of the Unit 2 and Unit 3 Combined Operating License Application (COLA). In Revision 62, responsibility for performance of dose assessment by on-shift personnel was added to the VCSNS Emergency Plan, as noted in the VCSNS On-Shift Staffing Assessment.

The current VCSNS Emergency Plan maintains the Revision 62 on-shift and augmented dose assessment responsibilities, with initial performance of dose

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 29 of 59 assessment being completed by on-shift personnel and by a 30-minute responder. Two (2) EOF dose assessment positions respond at 60-minutes.

The proposed change maintains responsibility for the on-shift dose assessment function as an ancillary duty of an RP qualified individual. The proposed change extends the 30-minute response time to 60-minutes for the augmented Dose Assessment Team Lead position and extends the remaining 60-minute response time for other dose assessment positions to 90-minutes. The Dose Assessment Team Lead serves in a support role for on-shift staff performing of dose assessment and providing oversight of RP qualified individuals responding at 60-minutes.

Radiological dose assessment has benefited from technological advances, as described in Section 2.1.3 of this attachment, that make it simpler and less time consuming. Recent improvements in dose assessment capability have resulted from the implementation of the MIDAS computer code, which includes an expanded isotopic library, enhanced user interface and additional output reporting capabilities. These improvements provide additional support for extending performance of this function by the on-shift dose assessor by 30 minutes.

Given the technical improvements in dose assessment capabilities, performance of this function by on-shift staff for the first 60 minutes after an event does not result in conflicts in the performance of on-shift responsibilities and is aligned with NUREG-0654, Revision 2, [8.1] Table B-1 guidance.

Offsite Surveys Major Task In Revision 5 of the VCSNS Emergency Plan, Offsite Surveys were initiated at an SAE or higher classification by two (2) 40-minute and two (2) 60-minute augmented responders.

The current VCSNS Emergency Plan maintains the Revision 5 requirements for staffing of augmented resources at 40 minutes (with two (2) 40-minute augmented responders) and 60 minutes (with two (2) 60-minute augmented responders) and dispatch of offsite monitoring teams after declaration of an SAE or higher classification.

In the proposed change, dispatch of the two (2) Offsite Monitoring Teams (OMTs) is extended by 20 minutes and 30 minutes respectively and occurs at an Alert or higher classification rather than at an SAE or higher classification. The dispatch of OMTs at an Alert or higher classification, combined with improvements in monitoring capability as provided by the IPCS discussed in Section 2.1.2 and the use of updated dose assessment software as described in Section 2.1.3 of this attachment, provides the means for tracking potential radioactive releases in the early stages of an event and serves as the basis for extending the augmentation response times from 40 minutes and 60 minutes to 60 minutes and 90 minutes. The proposed change is aligned with NUREG-0654, Revision 2, [8.1] Table B-1 staffing for the environmental monitoring function.

Onsite (out-of-plant) and In-Plant Surveys Major Task

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 30 of 59 Revision 5 of the VCSNS Emergency Plan identified one (1) 30-minute and one (1) 60-minute augmented responder who were responsible for performance of Onsite (out-of-plant) surveys. An on-shift HP Specialist was responsible for performance of In-plant surveys, augmented by one (1) 30-minute and one (1) 60-minute responder.

The current VCSNS Emergency Plan maintains the Revision 5 requirement for performance of on-shift and augmented Onsite (out-of-plant) and In-plant surveys with one (1) 30-minute and one (1) 60-minute augmented responder responsible for performance of Onsite (out-of-plant) surveys. An on-shift HP Specialist is responsible for performance of In-plant surveys, augmented by one (1) 30-minute and one (1) 60-minute responder.

The proposed change aligns the Onsite (out-of-plant) and In-plant functions and provides for augmented response by three (3) RP qualified individuals at 60-minutes and three (3) additional RP qualified individuals at 90-minutes at an Alert or higher classification.

Improvements in technology allow for remote monitoring of plant radiological conditions in key areas by on-shift RP qualified personnel. This remote monitoring network provides for easy access to plant area radiation data and allows on-shift RP qualified personnel to quickly provide radiological information to the ISEM/SM, including changes in radiological conditions that could impact response activities. The improvements have reduced the burden on on-shift personnel to acquire this information while ensuring dose savings for a spectrum of incidents with the potential to produce offsite dose in exceedance of Federal Protective Action Guidelines (PAGs).

The RP qualified individual, while monitoring in-plant conditions, is also able to track and trend radiological conditions in most key areas. Access to this information reduces the number of physical surveys needed in the plant prior to the arrival of augmented resources.

As a result, extending augmented response times from 40 minutes and 60 minutes to 60 minutes and 90 minutes does not adversely impact radiological monitoring capability and is aligned with NUREG-0654, Revision 2, [8.1] Table B-1 guidance.

Chemistry/Radiochemistry Major Task Revision 5 of the VCSNS Emergency Plan did not address performance of on-shift chemistry functions. Initial performance of chemistry functions was performed by one (1) 40-minute and one (1) 60-minute augmented responder. In Revision 26, an on-shift Chemistry position was added to the Staffing Requirements to better align the VCSNS Emergency Plan with NUREG-0654, Revision 1, [8.3] Table B-1.

The current VCSNS Emergency Plan maintains the Revision 26 requirement for one (1) on-shift Chemistry Technician as well as augmentation by one (1) additional Chemistry Technician at 60 minutes.

The proposed change removes the Chemistry position and references to performance of chemistry sampling from the VCSNS Emergency Plan as sampling

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 31 of 59 activities are controlled and governed by other station processes and requirements not associated with the emergency plan. Chemistry sampling results will continue to be used to inform emergency classification decisions as before. These changes are aligned with the guidance contained in NUREG-0654, Revision 2, [8.1] Table B-1.

3.5 Plant System Engineering, Repair and Corrective Actions Functions Per NUREG-0654, Revision 1, [8.3] the Plant System Engineering, Repair and Corrective Actions functional area includes Technical Support and Repair and Corrective Actions Major Tasks. NUREG-0654, Revision 1, [8.3] Table B-1 notes that Mechanical Maintenance/Radwaste Operator and Electrical Maintenance/Instrument and Control Technician expertise may be provided by shift personnel assigned other functions.

Technical Support Major Task Revision 5 of the VCSNS Emergency Plan included a Shift Technical Advisor (STA) position who advised the Shift Supervisor on operations activities and provided engineering support prior to staffing of the TSC. The position was augmented at 30 minutes by the Core Engineer and at 60 minutes by a Mechanical and Electrical Engineer.

In Revision 26, the 30-minute response time for the Core Engineer was revised such that the Core Damage Assessment (CDA) function remained with the STA until the Core Engineer arrived. The change was approved by NRC Region II Letter, dated August 21, 1990 [8.8].

The current VCSNS Emergency Plan maintains the Revision 26 augmentation time as approximately 30 minutes for the Core Engineer position. Augmentation time of the Mechanical and Electrical Engineer remains unchanged at 60 minutes. The Core Damage Assessment (CDA) function remains with the Shift Technical Advisor (STA) until the Core Engineer arrives.

The proposed change maintains performance of the core/thermal hydraulics function as the responsibility of the STA on-shift and extends the response time of TSC Reactor Engineer, from approximately 30 minutes to 90 minutes and extends the Mechanical Engineer and Electrical Engineer response times from 60 to 90 minutes. To ensure continued performance of the Core Damage Assessment (CDA) function for the first 90 minutes after the declaration of an emergency event classified as an Alert or higher, the site will implement provision of access to, and training of, the on-shift STA with core damage assessment capability that is functionally equivalent to that used by the Reactor Engineer in the TSC.

As discussed in Section 2.3.3 and 2.3.4.2, the FLEX Validation Technical Report [8.34]

demonstrated, with reasonable confidence, the stations ability to execute individual FLEX strategies. Each validation plan demonstrated ample margin to accomplish the strategy with sufficient margin to respond to unforeseen challenges.

The combination of indication-based Emergency Operating Procedures and application of Beyond Design Basis and FLEX strategies eliminate the need for Electrical or

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 32 of 59 Mechanical Engineering resources prior to the proposed augmentation times. This conclusion has been validated via the detailed procedural analysis conducted to support this proposed change and is further supported by on-shift staffing analyses.

Repair and Corrective Actions Major Task Revision 5 of the VCSNS Emergency Plan included Mechanical Maintenance and Instrument and Control (I&C) Technician on-shift positions. These positions were augmented by an I&C Technician at 40 minutes, and one (1) Mechanical Maintenance, one (1) Radwaste Operator, two (2) Electrical Maintenance and one (1) additional I&C Technician at 60 minutes after an Alert or higher classification. In Revision 27, an Electrical Maintenance position was added as a 30-minute responder and removed from the 60-minute response column. This change was made to better align 30-minute and 60-minute augmented response with NUREG-0654, Revision 1, [8.3] Table B-1. In Revision 62, one Electrical Maintenance and one Mechanical Maintenance position were added to the on-shift staffing. This change was the result of completion of the NEI 10-05

[8.27] On-Shift Staffing Analysis.

The current VCSNS Emergency Plan maintains the Revision 62 on-shift and 30-minute and 60-minute augmented response at an Alert or higher classification. On-shift staff includes one (1) Electrical, two (2) Mechanical Maintenance, and one (1) Instrument and Control (I&C) Technician positions. These positions are augmented by one (1)

Electrical Maintenance position as a 30-minute responder, one (1) I&C Technician as a 40-minute responder, and one (1) Mechanical Maintenance, one (1) Radwaste Operator, one (1) Electrical Maintenance and one (1) additional I&C Technician as 60-minute responders at an Alert or higher classification.

The proposed change removes the reference to performance of maintenance activities by on-shift personnel and revises the augmented response to include one (1)

Electrical Maintenance, one (1) Mechanical Maintenance, and one (1) I&C Maintenance responder at 90 minutes.

As discussed in Section 2.3.3 and 2.3.4.2, the FLEX Validation Technical Report [8.34]

demonstrated, with reasonable confidence, the stations ability to execute individual FLEX strategies. Each validation plan demonstrated ample margin to accomplish the strategy with sufficient margin to respond to unforeseen challenges.

The detailed procedural analysis performed for this submittal, supported by the on-shift staffing analyses performed to validate FLEX strategies and the detailed FLEX Validation Technical Report [8.34] performed by DESC, ensure that the diagnostic aspects of troubleshooting necessary to ensure the plant is maintained in a safe condition can be performed by the proposed on-shift staff until augmented.

The combination of the indication-based Emergency Operating Procedures and the application of Beyond Design Basis and FLEX strategies eliminate the need for Electrical or Mechanical Maintenance Technician resources prior to the proposed augmentation times. This conclusion has been validated via the detailed procedural analysis conducted to support this proposed change and is further supported by on-shift staffing analyses.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 33 of 59 3.6 Protective Actions (In-Plant) Function Per NUREG-0654, Revision 1, [8.3] the Protective Actions functional area includes the Radiation Protection major task (specifically Access Control), HP Coverage for repair and corrective actions, search and rescue, first aid and firefighting, personnel monitoring, and dosimetry. NUREG-0654, [8.3] Table B-1 notes that HP Technician expertise may be provided by shift personnel assigned other functions. NUREG-0654, Revision 2, [8.1]

Table B-1 combined the Protective Action function with the Radiation Protection function.

Revision 5 of the VCSNS Emergency Plan provided for performance of in-plant protective actions as an ancillary duty of the on-shift HP Specialist. The in-plant protective action function was augmented by one (1) additional HP Specialist at 30 minutes and two (2) additional HP Technicians at 60 minutes.

In Revision 26, an additional on-shift position and a 30-minute response position was added in support of this function. The change was made to better align the site on-shift and augmented response with NUREG-0654, Revision 1, [8.3] Table B-1.

The current VCSNS Emergency Plan maintains the on-shift and augmented RP response as stated in Revision 26 of the VCSNS Emergency Plan. It provides in-plant protective actions as an ancillary duty of the on-shift HP Specialists. These positions are augmented by two (2) additional HP Technicians at 30 minutes and two (2) additional HP Technicians at 60 minutes.

The proposed change combines the Protective Action and Radiological Assessment functions and utilizes the two (2) on-shift RP qualified individuals for performance of these tasks as noted in NUREG-0654, Revision 2, [8.1] Table B-1 and extends the response time for additional RP qualified individuals from 30 and 60 minutes to 60 minutes and 90 minutes after declaration of an Alert or higher classification.

The performance of access control and dosimetry activities are primarily completed using self-reading dosimeters (SRDs) which are obtained prior to entry into radiologically controlled areas (RCA). The type used is an alarming electronic dosimeter (ED).

Radiation work permits (RWP), including one specifically for use by Operations during radiological emergencies, establish the necessary preset alarms for the SRDs. The access control system provided at the RCA is used by individuals to log into the RCA, verify SRD operation, check for errors, and ensure the SRD has been calibrated.

Additionally, the system provides the user an opportunity to verify RWP setpoints and ensures appropriate dose margin. The proposed changes are aligned with NUREG-0654, Revision 2, [8.1] Table B-1 guidance.

3.7 Firefighting Function The Firefighting Function is not identified as an EP Function in NUREG-0654, Revision 2

[8.1].

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 34 of 59 Per NUREG-0654, Revision 1, [8.3] the Firefighting functional area is addressed by use of a Fire Brigade and managed in accordance with site Technical Specifications.

NUREG-0654, Revision 2, [8.1] Table B-1 does not address the firefighting function as this is performed under the site Fire Protection Plan.

In Revision 5, of the VCSNS Emergency Plan, Fire Fighting response by on-shift personnel was the responsibility of the Fire Brigade in accordance with site Technical Specifications. Augmented support was provided by offsite resources and was available as needed.

The current VCSNS Emergency Plan maintains the Revision 5 requirement for on-shift Fire Brigade members in accordance with site Technical Specifications, as well as augmentation by local fire firefighting support resources.

The proposed change removes the reference to the Firefighting function in Table B-1a as this is addressed under the VCSNS Fire Protection Program. This change is aligned with the guidance provided in NUREG-0654, Revision 2, [8.1] Table B-1.

3.8 Rescue Operations and First-Aid Function The Rescue Operations and First-Aid Function is not identified as an EP Function in NUREG-0654, Revision 2 [8.1].

NUREG-0654, Revision 1, [8.3] Table B-1 notes that this function may be provided by shift personnel assigned other functions. NUREG-0654, Revision 2, [8.1] Table B-1 removed rescue operations and first aid as these tasks are outside the purview of the VCSNS Emergency Plan.

Revision 5 of the VCSNS Emergency Plan provided for first-aid treatment of injured personnel by qualified on-shift personnel as an ancillary duty. Search and rescue activities were performed by first-aid and fire brigade personnel.

The current VCSNS Emergency Plan maintains this commitment through the use of on-shift First-Aid Responders. First-aid treatment for injured personnel is provided by qualified on-shift personnel as an ancillary duty. Search and rescue activities are performed by first-aid and fire brigade personnel.

The proposed change removes the reference to the Rescue Operations and First-Aid function in Table B-1a as this is a responsibility of the site Operations and is maintained in accordance with Operations procedures. This change is consistent with guidance provided in NUREG-0654, Revision 2, [8.1] Table B-1.

3.9 Site Access Control and Personnel Accountability Function The Site Access Control and Personnel Accountability Function is not identified as an EP Function in NUREG-0654, Revision 2 [8.1].

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 35 of 59 NUREG-0654, Revision 1, [8.3] the Site Access Control and Personnel Accountability functional area is addressed by Security personnel in accordance with the Site Security Plan.

Revision 5 of the VCSNS Emergency Plan provides for on-shift Security responders in accordance with the Site Security Plan.

The current VCSNS Emergency Plan maintains the Revision 5 requirement and provides for on-shift Security responders in accordance with the Site Security Plan.

The proposed change removes the reference to the Site Access Control and Personal Accountability function in Table B-1a as this is addressed in the Site Security plan. This change is aligned with guidance provided in NUREG-0654, Revision 2, [8.1]

Table B-1.

3.10 Aspects associated with EOF relocation This change proposes relocation of the existing VCSNS EOF and JIC (in South Carolina) to the Dominion Energy CERC facility in Virginia, abbreviated as the CERC. The CERC will contain both the EOF and the JIC functions. As specified in NUREG-0696, [8.9] the CERC is the location where the Corporate Emergency Director will direct a staff in evaluating and coordinating the overall company activities involved with an emergency.

Activation of the CERC is mandatory upon declaration of an Alert or higher Emergency Classification Level (ECL).

3.10 (a) Proposed Changes The current VCSNS Emergency Plan describes the emergency response centers with the following details in Part 2, Section H.2, Emergency Operation Facility, which states:

The EOF is the location where the ECO will direct a staff in evaluating and coordinating the overall company activities involved with an emergency. Activation of the EOF is mandatory upon declaration of a Site Area Emergency or higher classification. The EOF is located in Richland County near the intersection of Bickley Road and SC Hwy 176 and is outside the 10 Mile Emergency Planning Zone and greater than 10 miles from the Technical Support Center (TSC). The EOF provides for:

  • Management of overall emergency response
  • Performance of the non-delegable emergency notification and PAR development and notification functions when in command and control
  • Notification of appropriate corporate and station management
  • Coordination of offsite radiological and environmental assessments
  • Determination of recommended public protective actions
  • Management of recovery operations from an Alert or higher classification

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 36 of 59

  • Coordination of emergency response activities with federal, state, and county agencies The EOF was designed with the following considerations:
  • The EOF is provided with access limiting devices when not in use and assigned security personnel during activation to ensure that only authorized personnel are permitted to enter the facility.
  • The location provides optimum functional and availability characteristics for carrying out overall strategic direction of VCSNS emergency and support operations, determination of public protective actions to be recommended to offsite officials, and coordination with federal, state, and county agencies.
  • It is of sufficient size to accommodate about 50 people including NRC representatives.
  • It meets the criteria of NUREG-0696, Functional Criteria for Emergency Response Facilities regarding location, structure, habitability, size, communications, instrumentation, data system equipment, power supplies, technical data, records availability, and management. The EOF power is backed with an emergency diesel generator and has an uninterruptable power source to maintain loads during the transfer between power sources.
  • It is equipped with reliable voice communications capabilities to the TSC, the Control Room, the NRC, and the state and county EOCs. In addition, the EOF has facsimile, computer transmission, and electronic transfer capabilities.
  • Equipment is provided to gather, store, and display data needed in the EOF to analyze and exchange information on plant conditions with the station. The EOF technical data system receives, stores, processes, and displays information sufficient to perform assessments of the actual and potential onsite and offsite environmental consequences of an emergency condition.
  • The EOF has ready access (either through hard copies or electronic media) to plant records, procedures, and emergency plans needed for effective overall management of VCSNS emergency response resources.
  • It is designed to support a remote TSC and remote OSC in the event of an emergency which limits access to the site.

The proposed VCSNS Emergency Plan, which is provided in Attachment 2 and 3, includes the following details:

Part 2, Section H.2, Corporate Emergency Response Center, states:

The CERC is the consolidated emergency operations facility (EOF) and Joint Information Center (JIC) for VC Summer Nuclear Station, North Anna Power Station and Surry Power Station. The CERC is located at the Innsbrook Technical Center in Glen Allen, Virginia.

The facility provides workstations for Corporate, Federal and State officials who may be

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 37 of 59 assembled at this location. This facility is the designated central location point for the receipt and analysis of all field monitoring data and the coordination of sample media.

Plant data is available from the PCS. The Meteorological Information and Dose Assessment System (MIDAS) is used to estimate offsite doses. Official company statements to the media are made from a designated location at the CERC utilizing a collaborative platform by the Chief Technical Spokesperson. These company statements are prepared at the CERC.

Part 2, Section H.3, Alternative Facility When Under Threat of Experiencing a Hostile Action, states:

The VC Summer facility located at 113 Ballentine Crossing Lane, Irmo SC serves as the Alternative Facility for emergency response staff if the site is under threat of or experiencing a hostile action. This location has the capability to communicate with the CERC, control room and plant security. The CERC has the capability to perform offsite notifications. The staff at the Alternative Facility, working with the CERC organization, provides capability for engineering assessment activities, including damage control team planning and preparation.

Part 2, Section H.4, Location for Offsite Agency Coordination, states:

The V.C. Summer Nuclear Operations Building (NOB) is the location made available for the NRC and other offsite agency staff to interact face-to-face with emergency response personnel entering and leaving the nuclear power reactor site. This area provides a conference area with whiteboards, separate areas suitable for briefing and debriefing response personnel, telephones, site contacts lists, computers with internet access, access to a copier and office supplies, and access to plant data and radiological information. These provisions exist because the CERC is located more than 25 miles from the TSC.

Dominion Energy plans to conduct a drill requiring CERC activation to demonstrate VCSNS ERO capability. The drill will be conducted prior to implementation of this amendment request.

The scope of the drill will require coordination of response efforts for events occurring at VCSNS, specifically:

  • Staffing and activation of the facility within 90 minutes for an Alert or higher emergency classification,
  • Management of overall licensee emergency response,
  • Coordination of radiological and environmental assessment,
  • Determination of recommended public protective actions,
  • Coordination of event, plant, and response information provided to public information staff for dissemination to the media and public,

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  • Coordination of emergency response activities with Federal, State, and local authorities,
  • Obtaining and displaying key plant data and radiological information for VCSNS, and
  • Analyzing plant technical information and providing technical briefings on event conditions and prognosis to licensee staff and offsite agency responders for VCSNS.

This drill may be observed by NRC staff and representatives of the Federal Emergency Management Agency (FEMA). Offsite response agencies will be invited to participate or observe. Logistic arrangements will be coordinated with these organizations separately.

3.10 (b) Reason for the Proposed Changes On January 1, 2019, Dominion Energy South Carolina (DESC) purchased South Carolina Electric and Gas Company (SCEG) which previously owned the Virgil C. Summer Nuclear Station (VCSNS). Corporate governance and support of VCSNS was transferred to the DESC headquarters located in Richmond, Virginia. DESC uses a Corporate Emergency Response Center (CERC) which functions as the consolidated emergency operations facility for North Anna Power Station (NAPS) and Surry Power Station (SPS). The proposed relocation of the VCSNS EOF is expected to have the following positive effects on VCSNS emergency response capability:

  • Increased pool of site ERO members available for assignment to other positions in the TSC and the Operational Support Center (OSC)
  • Increased efficiency using common practices and procedures in a single facility; and
  • Enhanced availability for emergency response by relocating the EOF away from a reactor site that could be affected by a large-scale external event, hostile action, or radioactivity release.

The greater distance of the CERC from VCSNS does not impede implementation of CERC functions by VCSNS or the NRC. Offsite response organization (ORO) plans provide for CERC interface from their respective emergency operations centers (EOCs),

primarily the South Carolina State EOC/Joint Information Center (JIC), although a representative may be sent to the CERC. The Chief Technical Spokesperson at the CERC is responsible for providing media briefings and news information to the media. At the Site Area Emergency level and above, VCSNS personnel are assigned as liaisons to the state of South Carolina, Lexington County, Richland County, Newberry County, and Fairfield County EOCs, when they are activated. Thus, the location of the proposed EOF does not impede ORO mobilization. Likewise, the time for the NRC Region II Incident Response Site Team to arrive at the CERC should be the same as that needed to travel to the existing Dominion Energy CERC to respond at an event at other Dominion nuclear power plants located in Virginia.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 39 of 59 3.10 (c) VCSNS Emergency Plan Background Revision 2 of the VCSNS Emergency Plan, dated October 1980, established an interim EOF located in an Administrative Office Complex approximately 1000 feet west of the VCSNS reactor building. Safety Evaluation Report (SER) NUREG-0717, Safety Evaluation Report Related to the Operation of Virgil C. Summer Nuclear Station, Unit 1, Supplement 2, dated May 1981, [8.17] approved the location of the interim EOF and discussed an alternate EOF at the Parr facility approximately 2 miles from the reactor building. The SER also notes commitments regarding emergency response facilities.

Revision 5 of the VCSNS Emergency Plan, dated October 1981, provided updates prior to initial licensing that satisfied remaining open items related to meteorological and dose assessment capability regarding emergency preparedness for VCSNS. Revision 5 did not affect information related to the EOF. Safety Evaluation Report (SER) NUREG-0717, Safety Evaluation Report Related to the Operation of Virgil C. Summer Nuclear Station, Unit 1, Supplement 3, dated January 1982, [8.18] approved the VCSNS Emergency Plan, Revision 5.

NRC letter dated August 5, 1983, [8.19] approved VCSNC Radiation Emergency Plan, Revision 9, which implemented the EOF in the training center.

Revision 58 of the VCSNS Emergency Plan implemented the current EOF location at 113 Ballentine Crossing Lane in Ballentine, South Carolina.

3.10.1 Functions (1) Management of overall licensee emergency response Operation of the CERC will not significantly alter the overall approach to emergency response at VCSNS. The Corporate Response Manager, who is in overall command and control of the Dominion Energy ERO, is the individual authorized to request assistance and resources from responding organizations.

Once it assumes responsibilities, the CERC will be the primary facility for offsite Protective Action Recommendation (PAR) development and notification of designated offsite agencies. Responsibility for event classification, NRC notifications using ENS, and emergency exposure controls will remain in the TSC.

The CERC staff has successfully demonstrated the ability to manage emergency response in several evaluated exercises and numerous drills and exercises during which offsite emergency response organizations have observed and/or participated.

Participants have included representatives from the State of Virginia in support of SPS and NAPS emergency responses. DESC has procedures and practices in place for emergency management that will continue to be used after the proposed relocation and consolidation of the VCSNS EOF and JIC at the CERC. While revisions to some EOF-related procedures are anticipated, the consolidation will not alter or adversely affect the overall approach to the emergency response.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 40 of 59 (2) Coordination of radiological and environmental assessment The CERC will coordinate field team activities and perform dose assessments. Offsite environmental monitoring is performed by field monitoring team personnel under the direction of the Dose Assessment Team Leader in the TSC or the Accident Assessment Team in the CERC. The CERC Radiological Assessment Coordinator directs field team radio operator activities and dispatches Offsite Field Team members. VCSNS FMT activities are coordinated with environmental monitoring efforts performed by teams directed by the state of South Carolina.

The ability of the CERC to coordinate field activities and perform dose assessments has been successfully demonstrated in previous drills and exercises for other Dominion nuclear stations.

Communication and dose assessment capabilities are discussed in Section 3.10.6 and 3.10.8 below.

(3) Determination of recommended public protective actions The ERO staff in the CERC will develop and provide PARs to offsite agencies based upon plant conditions or dose projections. The responsibility for PAR development will be assigned to the CERC Technical Support Manager.

Once approved, and upon implementation of the proposed changes to relocate and consolidate the VCSNS EOF/JIC, the CERC staff will continue to make Protective Action Recommendations (PARs) to offsite agencies based upon VCSNS plant conditions or dose projections. Procedures with plant-specific guidance will continue to be used in making PARs. To address differences in the development of PARs associated with SPS, and NAPS from VCSNS, the appropriate CERC personnel will receive additional training on VCSNS-specific PAR determinations prior to implementing the changes in support of EOF/JIC relocation and consolidation efforts.

(4) Notification of offsite agencies Upon activation of the CERC, the ERO staff will make notifications to State, and local agencies for VCSNS. These notifications include initial emergency classification level (ECL) declarations, upgrades in the ECL, issuance of or change to PARs, and follow-up notifications. The CERC has enough workstations and personnel designated to communicate with offsite agencies to support communications for more than one site during concurrent activation. Primary and back-up communication methods will be available. Communication capabilities and methods are further described in Section 3.10.6 below.

(5) Coordination of event, plant, and response information provided to public information staff for dissemination to the media and public The ERO staff in the CERC will provide event, plant, and response information to the Chief Technical Spokesperson and the Media Briefing Support Team. The Chief Technical Spokesperson will provide media and news information to the media.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 41 of 59 (6) Staffing and activation of the facility within time frames and at emergency classification levels defined in the licensee emergency plan Staffing for the CERC is addressed in the proposed VCSNS Emergency Plan (Attachment 2 of this submittal), Table B-1a, Staffing Requirements for the VCSNS ERO, and Figure B-1c, CERC Organization. Sections 3.2 through 3.4 above provide justification for EOF functions of command and control, communications, and management and performance of dose assessments and projections.

The CERC will be activated within 90 minutes following the declaration of an Alert or higher classification. Justification for this time frame is provided in Section 2.0.

(7) Coordination of emergency response activities with Federal, State, tribal, and local agencies The NRC is notified via ENS immediately after notification of the designated offsite agencies listed in the site annex, but not later than one hour after the time one of the ECLs is declared, as required by 10 CFR 50.72(a)(ii)(3). Follow-up NRC notifications are made in accordance with 10 CFR 50.72(c). Responsibility for these notifications is transferred from the VCSNS Main Control Room (MCR) to the TSC where it remains for the duration of the event response. In addition, the TSC and the CERC have the capability of establishing Health Physics Network (HPN) communications with the NRC when requested.

If an incidents severity or uncertainty warrants entry into the NRC expanded activation emergency response mode, it is anticipated an NRC Region II site team may be dispatched to interface with their counterparts in the CERC and elsewhere, e.g., site TSC, South Carolina EOC. Arrangements meeting the 10 CFR 50.47(b)(3) emergency planning standard for accommodating responding organizations exist at the CERC, including a separate conference room in the CERC for the NRC Region II site team. The establishment of a near-site response location for the NRC is described below.

The state and county agencies listed in the VCSNS Emergency Plan are notified within 15 minutes of the initial ECL declaration and ECL upgrades. Interface between the CERC and OROs is primarily via the CERC. The Corporate Response Manager has overall responsibility for providing the interface between VCSNS and outside organizations. As indicated above, field monitoring team activities are coordinated with environmental monitoring efforts performed by teams directed by the state of South Carolina.

(8) Locating NRC and offsite agency staff closer to a site if the EOF is greater than 25 miles from the site 10 CFR 50, Appendix E, Section IV.b, stipulates the following:

"For an emergency operations facility located more than 25 miles from a nuclear power reactor site, provisions must be made for locating NRC and offsite responders closer to the nuclear power reactor site so that NRC and offsite responders can interact face-to-face with emergency response personnel entering and leaving the nuclear power reactor site. Provisions for locating NRC and offsite responders closer to a nuclear power reactor

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 42 of 59 site that is more than 25 miles from the emergency operations facility must include the following:

(1) Space for members of an NRC site team and Federal, State, and local responders.

(2) Additional space for conducting briefings with emergency response personnel.

(3) Communication with other licensee and offsite emergency response facilities.

(4) Access to plant data and radiological information; and (5) Access to copying equipment and office supplies..."

NSIR/DPR-ISG-01 [8.7] also provides a description of the facilities and capabilities that the EOF shall have, including provisions for a near-site facility as follows:

"Locating NRC and offsite agency staff closer to a site if the EOF is greater than 25 miles from the site. Minimum provisions at this location should include the following items:

conference area with whiteboards, separate areas suitable for briefing and debriefing response personnel, telephones, site ERO telephone contact lists, computers with internet access, access to a copier and office supplies, and radiation monitoring capability" The habitability criteria in Table 2 were retained since the criteria apply only to a primary EOF located within 10 miles of the TSC.

As part of implementation of the proposed change, DESC will make provisions available at the VCSNS Nuclear Operations Building (NOB), so NRC and offsite responders can interact face-to-face with emergency response personnel entering and leaving the nuclear power reactor site.

This location will include space for members of an NRC site team and federal responders; additional space for conducting briefings with emergency response personnel; communication capabilities with other licensee and offsite emergency response facilities; access to plant data and radiological information; and access to copying equipment and office supplies. This location is described in Part 2, Section H.4 of the proposed VCSNS Emergency Plan (Attachment 2).

(9) Obtaining and displaying key plant data and radiological information for each unit or plant the EOF serves The CERC will have the capability to access key plant parameters from VCSNS. The data acquired from VCSNS can be displayed on screens in the CERC. Screens are available such that information from more than one site can be displayed. See Sections 3.10.7 and 3.10.8 for details.

(10) Analyzing plant technical information and providing technical briefings on event conditions and prognosis to licensee staff and offsite agency responders for each type of unit or plant

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 43 of 59 The CERC has the capability to access key plant parameters from VCSNS as described in Sections 3.10.7 and 3.10.8. Knowledge of these parameters allows the CERC staff to assess the severity of an accident, project the accidents course, and provide DESC/VCSNS management with information needed for mitigation, recovery, and PARs.

The ERO staff in the CERC includes members who are technically qualified to analyze relevant information from the plant information systems. The CERC is equipped to accommodate licensee staff and offsite agency responders technical briefings. The CERC has enough workstations to monitor conditions at more than one site simultaneously, and it is equipped with sufficient conference rooms for licensee staff and offsite agency responders technical briefings. Telephone conferencing capability is available for briefing responders not located in the CERC.

(11) Effectively responding to and coordinating response efforts for events occurring simultaneously at more than one site for a consolidated EOF DESC will maintain the ability of the CERC to support simultaneous events for at least two (2) sites. The CERC is capable of monitoring and analyzing events at VCSNS and other Dominion sites simultaneously. Enough workstations are available for data retrieval and the facility has adequate display capability to simultaneously present this information to the CERC staff. In addition, the capability is provided to support communications to offsite agencies for more than one event. The ERO augmentation process provides sufficient staff in the event that more than one station is in an ECL requiring CERC activation. When the ERO call-out system is activated, all ERO members are notified to establish adequate coverage of ERO positions at their designated ERFs. With regard to staffing the CERC, ERO personnel at the DESC corporate office, the same location as the CERC, are required to promptly report to their assigned ERF upon activation. Excess personnel that respond may be assigned support responsibilities or be designated as a relief shift.

The CERC currently assumes the functions discussed above for SPS and NAPS during drills, exercises, and actual emergencies. The ERO personnel assigned to the CERC are experienced in the management of emergency response. Also, an advantage of being located near the DESC corporate offices in Innsbrook, Virginia, is that the CERC ERO staff includes the expertise of DESC corporate personnel. This includes important groups such as Fleet Emergency Preparedness, Corporate Engineering, Safety Analysis, and Probabilistic Risk Assessment as well as other individuals with a wide range of expertise.

The CERC staff will receive training on the applicable characteristics of VCSNS prior to implementation of the proposed changes to relocate and consolidate the VCSNS CERC.

This training will include instruction on the reactor technologies involved related to VCSNS, differences in the radiological and environmental characteristics of the newly added station, and the determination of PARs. In addition, as with the other stations currently using the CERC, periodic training will be provided in accordance with the DESC Emergency Preparedness Emergency Response Organization (ERO) Training and Qualification Program requirements to maintain proficiency in release path determination, PAR determination, and dose assessment.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 44 of 59 Because SPS and NAPS have utilized the consolidated CERC for many years, the CERC staff is experienced in the coordination of emergency response activities with offsite agencies. DESC does not anticipate any adverse impacts associated with coordinating emergency response functions and capabilities after VCSNS is included at the CERC facility.

3.10.2 Location, structure, and habitability The CERC is located in Dominions Innsbrook Technical Center (ITC) at 5000 Dominion Boulevard, Glen Allen, Virginia. The straight-line distance from this location to the VCSNS TSC is 312 miles.

The CERC meets the intent of the guidance in NUREG-0696 [8.9] that the building be well-engineered for the design life of plant. The building is designed to withstand wind speeds up to 120 mph. The building is capable of withstanding wind loads and live loads equal to or greater than those specified in the BOCA National Building Code/1981 [8.20].

The building is in a minimal flood hazard zone which is outside the 500-year flood zone

[8.36].

There are no specific NUREG-0696 [8.9] habitability criteria for an EOF located more than 10 miles from a nuclear station and a back-up facility is not required. The CERC is greater than 10 miles from VCSNS. Thus, CERC functions would not be interrupted during radiation releases where it is necessary to recommend protective actions for the public to offsite officials.

Access to the ITC is continually controlled by a security service. The main entrance to the CERC is controlled by a monitored electronic card reader that allows entry to authorized personnel only. When the CERC is activated, these doors may be placed in a mode that allows general access.

3.10.3 Staffing and training Incorporating the VCSNS EOF/JIC into the CERC will not adversely affect the ability of the CERC to be staffed in a timely manner. The facility will be staffed with experienced personnel from the DESC Corporate office in Innsbrook, Virginia. The CERC staff has demonstrated its ability to staff the CERC in a timely fashion after an event declaration requiring activation during augmentation drills. The CERC staff currently includes personnel to manage overall licensee emergency response, coordinate radiological and environmental assessment, determine recommended public protective actions, and interface with offsite officials. These functions will continue to be performed after the implementation of the proposed relocation and consolidation efforts.

The CERC staff is currently proficient in emergency response for SPS and NAPS. The CERC staff will receive VCSNS-specific training on release in progress determination, release paths, dose assessment, and PAR determination prior to implementation of the changes supporting the relocation and consolidation of the EOF/JIC. The CERC staff will

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 45 of 59 be trained in the emergency response for VCNS in accordance with the VCSNS Emergency Plan.

This training is similar to SPS and NAPS training. Key decision makers will attend VCSNS-specific training as required based on their prior experience and training. Proper response to a VCSNS emergency will be within the capabilities of the CERC staff.

Transferring EOF functions to the CERC will allow VCSNS to better focus station resources on site accident management.

The ERO staff for the CERC is described in Part 2, Section B.5.b of the proposed VCSNS Emergency Plan, and the training program is described in Part 2, Section O. Training for key ERO members supporting VCSNS and other Dominion stations will include station-specific differences related to their roles, e.g., technical data display systems, plume exposure pathway risk jurisdictions, release pathways, station ingress and egress routes, and evacuation time estimates.

3.10.4 Size The total usable space of the CERC is approximately 5987 square feet. Based on the 75 square foot per person guidance of NUREG-0696, [8.9] this provides enough space for approximately 80 individuals. The expected number of EOF personnel during a dual-station event, including offsite agency responders, will be less than 60.

Space is allocated for accident assessment, radiation assessment and offsite monitoring, offsite communications, command and control, conferences, an NRC team, and administrative support. Space is sufficient for service of equipment and displays. Phones and special communications equipment are provided as needed throughout the facility at personnel workstations. Individuals needing access to plant data are provided access via personal computers (PCs). Space is provided for ready access to functional displays of data through the use of computer monitors and video display monitors.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 46 of 59 Figure 3.10.4 - 1 Proposed CERC Layout

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 47 of 59 Table 3.10.4 - 1 Description of Proposed CERC Layout Area Description Command Main area (approximately 46 ft x 55 ft) with tables for NAPS, SPS, and VCSNS Center designated for management, intra-facility communications and plant parameter monitoring, common tables for logistics and external affairs functions, table for federal and state representatives, and tables for observers.

Computer Houses Information Technology server equipment, power strips and communications Room connections (approximately 12 ft x 14 ft).

Federal Office area (approximately 15 ft x 20 ft) with conference table, electrical outlets, Agencies communications network ports, and screen connection(s). Chairs, a speaker phone, dry erase board, and networked display screen are also in this office area.

Administrative Office area (approximately 14 ft x 17 ft) with location-specific procedures, reference Support materials and administrative supplies, and multi-function device copier/scanner/printer Administrative Office area (approximately 7 ft x 14 ft) for use as needed Area Dose Office areas (approximately 16 ft x 28 ft) designated for NAPS SPS, and VCSNS.

Assessment Provided in this area are:

(2 rooms)

  • Networked display screens
  • Multi-function device copier/scanner/printer
  • Computers Public Affairs Office area (approximately 20 ft x 30 ft) with:
  • Multi-function scanner/printer
  • Networked display screens
  • Dry erase board
  • Computers
  • TVs State Office area (approximately 15 ft x 20 ft) with conference table having AC plug-ins, power Agencies strips and screen connection. Chairs, speaker phone, dry erase board, and networked display screen are also provided in this office area.

Briefing Room Office area (approximately 20 ft x 22 ft) with:

  • Dry erase board
  • Networked display screen
  • Tables and Chairs

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 48 of 59 3.10.5 Radiological Monitoring The CERC is greater than 10 miles from the VCSNS. Consequently, the habitability criteria described in NUREG-0696, [8.9] Section 4.2, Table 2, are not applicable.

3.10.6 Communications The CERC has reliable voice communication to North Anna Power Station (NAPS), Surry Power Station (SPS), and VCSNS Main Control Rooms, TSCs, the NRC, State and local emergency operations centers, nuclear steam supply system (NSSS) suppliers, the Federal Emergency Management Agency, and the US Department of Energy. The existing communications systems include:

  • Dominion Energy Virginia (DEV) and DESC installed telephone system (to manage licensee emergency response resources and communications with NAPS, SPS, and VCSNS TSCs) with access to the DEV and DESC internal phone system, public switched network, and long distance.
  • NAPS, SPS, and VCSNS Dominion Energy Emergency Notification System (for providing emergency notifications to State and site-specific risk jurisdiction 911 Centers/EOCs).
  • Radio systems for communication with NAPS, SPS, and VCSNS field monitoring teams will be available to coordinate radiological monitoring.
  • NRC Emergency Telecommunications System telephones (Emergency Notification System, Health Physics Network, Protective Measures Counterpart Link, Reactor Safety Counterpart Link, Management Counterpart Link, and local area network connections are provided by the DEV and DESC communications infrastructure).
  • Scanning (e-mail) transmission capability The emergency communications systems at the CERC are designed to ensure the reliable, timely flow of information between all parties having an emergency response role. The emergency communications system permits simultaneous communications from the Station or CERC to the site-specific risk jurisdiction 911 Centers/local EOCs and the State of South Carolina EOC on a 24-hour per day basis.

Existing commercial telephone service will serve as the designated back-up means of communications in the event of an emergency communication system failure. DEV and DESC have telecommunications capabilities that can provide access to long-distance networks without having to go through a local telephone company switch. An Enterprise Transport Network provides Wide Area Network (WAN) connectivity, dedicated voice communication phone and radio control circuits between station emergency response facilities and the CERC, the Commonwealth of Virginia Emergency Operations Center (VEOC), and the South Carolina Emergency Operations Center. Telephones are provided for the respective federal and state representatives. Multifunction machines are

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 49 of 59 available in the CERC to support the transmission of information between the emergency response facilities and state, local, and federal authorities.

3.10.7 Instruments, data system equipment, and power supplies Data acquisition for the CERC is achieved through a secure connection to the plant computer servers. The CERC has access to displays that are representative of the displays in the Control Room via the DEV Wide and Local Area Networks (WAN and LAN). DEV has established an availability goal for the LAN/WAN that exceeds the 0.01 unavailability goal identified in NUREG-0696 [8.9]. The CERC has access to the same data points that are available to the Operators in the Control Room and emergency responders in the TSCs, including the SPDS data points. The video display system in the CERC will display the graphics on screens in the Command Center area.

Two utility circuits feed the Innsbrook Technical Center (ITC) where the CERC is located.

Primary power is provided by commercial power. Electrical outlets, heating, ventilation, and air conditioning (HVAC), lighting fixtures, and the wiring closet that supports both the voice and data communications in the CERC have back-up power available. Thus, a loss of commercial power would not impact voice or data communications equipment in the CERC. The DEV telecommunications infrastructure supporting the CERC functions, including, but not limited to, fiber optic transmission equipment, telephone switching equipment and data network routers, is configured to operate from at least one, and usually multiple, back-up power sources in the event of a loss of commercial power.

These back-up sources include generator, DC battery and uninterruptable power supply (UPS) systems.

The workstations and related LAN/WAN equipment require AC power to operate. A loss of AC power to the equipment, located at numerous locations throughout the DEV system, will cause a loss of this capability. The LAN equipment housed within the CERC is provided with back-up power. The core network equipment in the ITC is also provided with back-up power.

Since the CERC is located offsite, its electrical equipment loads will not affect any safety related power source. Loss of primary commercial power would not cause loss of any stored data vital to EOF functions. Historical data from the site will be accessible from a historical database. This information can be accessed by the CERC, as needed once power is restored to the LAN.

3.10.8 Technical data and data system The CERC will have the capability to receive, store, process, and display information needed to perform assessments of actual and potential offsite environmental consequences during an emergency at NAPS, SPS, and VCSNS. A proxy server will allow the display of data points that cover Type A, B, C, D, and E variables discussed in NUREG-0696, [8.9] Section 4.8. In addition, the meteorological variables required for dose assessment will be made available through the proxy server. This data will also be

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 50 of 59 accessible from a historical database. The CERC dataset includes radiological, meteorological, and other environmental data as needed to:

  • Assess environmental conditions
  • Coordinate radiological monitoring activities, and
  • Recommend implementation of offsite emergency plans Offsite dose assessment is performed for NAPS, SPS, and VCSNS using the Meteorological Information and Dose Assessment System (MIDAS). MIDAS is a computer software program intended for use at nuclear generating stations and other emergency response facilities in the event of an actual or potential release of airborne radioactivity to the environment at levels warranting declaration of an emergency specified in the NAPS, SPS, and VCSNS Emergency Plan.

3.10.9 Records availability and management Key reference materials for NAPS, SPS, and VCSNS will be maintained in the CERC. In addition, station design documentation, plant drawings, procedures, etc., are available electronically via the local area network connection.

Examples of the above include:

  • Plant Technical Specifications - accessed electronically
  • Plant operating procedures - accessed electronically
  • Emergency operating procedures - accessed electronically
  • Final Safety Analysis Reports - accessed electronically
  • Offsite population distribution data - accessed electronically
  • Evacuation plans - accessed electronically
  • Drawings - accessed electronically

4.0 CONCLUSION

S The proposed changes continue to support the functional areas of the VCSNS Emergency Plan, continue to ensure the protection of the health and safety of the public and site personnel, and will not present a significant burden to on-shift personnel.

Elimination of on-shift Maintenance positions and extending augmented response times, given the diverse and redundant capabilities of plant systems and the results of the

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 51 of 59 procedure analysis, do not adversely affect the sites ability to respond to an event and do not delay performance of maintenance functions.

Re-alignment and extension of RP staffing augmentation response times from a total of 8 RP individuals at 30 and 60 minutes to a total of 6 RP qualified individuals at 60 and 90 minutes for the in-plant, onsite (out-of-plant), and protective action functions as described in NUREG-0654, Revision 2, [8.1] Table B-1, does not adversely affect the performance of radiological assessment or protective action functions associated with event response.

DESC has incorporated new technologies in installed in-plant monitoring capability and the use of telemetry ensures the emergency response functions identified in the VCSNS Emergency Plan will continue to be performed in a timely manner. The proposed changes do not result in a reduced capability to effectively respond to an emergency.

The proposed change extends the times at which the offsite sampling teams are dispatched by 30-minutes; however, sampling teams will be dispatched at an Alert or higher classification rather than at a Site Area Emergency or General Emergency.

Initiation of environmental sampling at a lower classification will continue to support timely performance of the function even with the extended dispatch time.

Removal of references to chemistry positions not performing EP functions and removal of chemistry activities controlled and governed by other station processes and requirements not associated with the emergency plan is aligned with NRC guidance.

Similarly, removal of references to admin/support positions are included in the proposed change. These positions and functions will be maintained in the VCSNS Emergency Plan Implementing Procedures (EPIPs).

The implementation of FLEX strategies utilizing pre-engineered responses and pre-staged equipment demonstrated, as shown in the FLEX Validation Technical Report

[8.34], that on-shift personnel are able to initiate diagnostic activities for the first 90 minutes. Additionally, there will be no technical support or corrective actions activities requiring additional mechanical or electrical engineering or maintenance expertise during the 90-minute timeframe once the identified procedure revisions and training are completed. The result of the FLEX Validation Technical Report [8.34] provides the bases for extension of augmented response to 60 and 90 minutes with no resulting conflicts in performance of on-shift tasks.

The proposed relocation of the VCSNS EOF and JIC to the Dominion Energy CERC continues to provide adequate emergency facilities and equipment for supplying direction and exercising control during an emergency.

Therefore, the proposed augmentation time changes and the use of the CERC for the EOF and JIC will continue to ensure the VCSNS Emergency Plan meets 10 CFR 50.54(q)(2), the requirements of 10 CFR 50, Appendix E, and the planning standards of 10 CFR 50.47(b).

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 52 of 59

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.47(b) specifies the planning standards that the onsite and offsite emergency response plans must meet for NRC staff to make a finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Specifically, 10 CFR 50.47(b)(1) states: (1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

10 CFR 50.47(b)(2) states: (2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and Off-site support and response activities are specified.

The existing VCSNS Emergency Plan includes onsite and offsite emergency response plans that meet the requirements listed in 10 CFR 50.47(b)(1) and (2). This LAR proposes to remove maintenance personnel from on-shift, extend staff augmentation response times from 30/40/60 minutes to 60/90 minutes, and relocate the VCSNS EOF and JIC to CERC. The VCSNS Emergency Plan will continue to have onsite and offsite emergency response plans that meet 10 CFR 50.47(b).

10 CFR 50.47(b)(3) requires that arrangements to accommodate State and Local staff at the licensee's EOF have been made. Compliance with this requirement is discussed in Section 3.10.1.(7) above.

10 CFR 50.47(b)(8) requires that adequate emergency facilities and equipment to support the emergency response are provided and maintained. Following approval and implementation of the proposed changes involving the relocation and consolidation of VCSNS EOF/JIC, VCSNS will still have an EOF from which effective direction can be given and effective control can be exercised during an emergency. Furthermore, the CERC meets the EOF criteria in NUREG-0696, [8.9] as discussed in this attachment.

10 CFR 50.47(b)(9) requires that adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use. This requirement is encompassed in the EOF criteria in NUREG-0696, [8.9] as discussed in this attachment.

Section 4 of NUREG-0696 [8.9] provides guidance on the overall criteria for the EOF:

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 53 of 59

  • Functions
  • Location, structure, and habitability
  • Staffing and training
  • Size
  • Radiological monitoring
  • Communications
  • Instrumentation, data system equipment, and power supplies
  • Technical data and data system
  • Records availability and management Compliance with these criteria, as applicable to the proposed change, is discussed in Section 3.10.1 - 3.10.9 above.

NUREG-0696 [8.9] expands on the Function criteria by providing the following requirements (this is the expanded list included in NSIR/DPR-ISG-01 [8.7]):

  • Management of overall licensee emergency response
  • Coordination of radiological and environmental assessment
  • Determination of recommended public protective actions
  • Notification of offsite agencies
  • Coordination of event, plant, and response information provided to public information staff for dissemination to the media and public
  • Staffing and activation of the facility within time frames and at emergency classification levels defined in the licensee emergency plan
  • Coordination of emergency response activities with Federal, State, tribal, and local agencies
  • Locating NRC and offsite agency staff closer to a site if the EOF is greater than 25 miles from the site
  • Obtaining and displaying key plant data and radiological information for each unit or plant the EOF serves
  • Analyzing plant technical information and providing technical briefings on event conditions and prognosis to licensee staff and offsite agency responders for each type of unit or plant
  • Effectively responding to and coordinating response efforts for events occurring simultaneously at more than one site for a consolidated EOF.

Compliance with each of these items is discussed in Section 3.10.1 above.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 54 of 59 NRC Interim Staff Guidance NSIR/DPR-ISG-01 [8.7] provides information for addressing Emergency Planning requirements for nuclear power plants. This guidance is based on changes to Emergency Planning regulations in 10 CFR 50.47 and 10 CFR 50, Appendix E, that were published in the Federal Register on November 23, 2011 (76FR72560). This ISG identified several areas for potential Emergency Planning program improvement and increased clarity based on experience gained from Emergency Planning program implementation since the TMI accident, recent technological advances, and lessons learned from actual events, drills, and exercises. The ISG recognized that previous regulatory standards did not address the capabilities and functional requirements for a consolidated EOF, such as capabilities for handling simultaneous events at two or more sites or providing for NRC and offsite officials to relocate to a facility nearer the site if they desire when an EOF is located at a substantial distance from a site. The NRC revised regulations and provided associated guidance to reflect a performance-based approach for EOFs. The regulations and guidance provide functional requirements for these facilities, thus ensuring that the necessary capabilities are in place to protect public health and safety.

10 CFR 50.54(q), Emergency Plans, states:

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

(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 NRC. 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 letter 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 VCSNS Emergency Plan meets the planning standards of 10 CFR 50.47(b) and 10 CFR 50, Appendix E as required by 10 CFR 50.54(q)(2). This LAR proposes to remove maintenance personnel from shift and extend staff augmentation response times from 30/40/60 minutes to 60/90 minutes. The proposed changes are considered a reduction in effectiveness as defined in 10 CFR 50.54(q)(1)(iv) and require prior approval by the NRC in accordance with 10 CFR 50.54(q)(4). Therefore, DESC is submitting this LAR pursuant to 10 CFR 50.90.

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 55 of 59 The VCSNS Emergency Plan will continue to meet the requirements of 10 CFR 50.54(q)(2) by maintaining the effectiveness of the Emergency Plan such that it meets the requirements of 10 CFR 50, Appendix E and the planning standards of 10 CFR 50.47(b).

10 CFR 50, Appendix E.IV states:

A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

A.9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

The existing VCSNS Emergency Plan includes a description of the organization, including definition of authorities, responsibilities, and duties of individuals. The current VCSNS Emergency Plan (Revision 74) complies with 10 CFR 50, Appendix E.IV.A.9. This LAR proposes to remove maintenance personnel from shift and extend staff augmentation response times from 30/40/60 minutes to 60/90 minutes. A staffing analysis has been performed to demonstrate continued compliance with 10 CFR 50, Appendix E.IV.A.9.

The staffing analysis supports acceptability of the proposed increase in staff augmentation times. The proposed changes to the VCSNS Emergency Plan will continue to describe the authorities, responsibilities, and duties of these individuals. Therefore, with the changes proposed in the LAR, the requirements of 10 CFR 50, Appendix E continue to be met.

10 CFR 50 Appendix E Section IV, Part E states, in part:

Adequate provisions shall be made and described for emergency facilities and equipment, including:

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

8.b. For a nuclear power reactor licensees emergency operations facility required by paragraph 8.a of this section, either a facility located between 10 miles and 25 miles of the nuclear power reactor site(s), or a primary facility located less than 10 miles from the nuclear power reactor site(s) and a backup facility located between 10 miles and 25 miles of the nuclear power reactor site(s). An emergency operations facility may serve more than one nuclear power reactor site. A licensee desiring to locate an emergency operations facility more than 25 miles from a nuclear power reactor site shall request prior Commission approval by submitting an application for an amendment to its license. For an emergency operations facility located more than 25 miles from a nuclear power reactor

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 56 of 59 site, provisions must be made for locating NRC and offsite responders closer to the nuclear power reactor site so that NRC and offsite responders can interact face-to-face with emergency response personnel entering and leaving the nuclear power reactor site.

Provisions for locating NRC and offsite responders closer to a nuclear power reactor site that is more than 25 miles from the emergency operations facility must include the following:

(1) Space for members of an NRC site team and Federal, State, and local responders.

(2) Additional space for conducting briefings with emergency response personnel.

(3) Communication with other licensee and offsite emergency response facilities.

(4) Access to plant data and radiological information, and (5) Access to copying equipment and office supplies.

8.c. By June 20, 2012, for a nuclear power reactor licensees emergency operations facility required by paragraph 8.a of this section, a facility having the following capabilities:

(1) The capability for obtaining and displaying plant data and radiological information for each reactor at a nuclear power reactor site and for each nuclear power reactor site that the facility serves.

(2) The capability to analyze plant technical information and provide technical briefings on event conditions and prognosis to licensee and offsite response organizations for each reactor at a nuclear power reactor site and for each nuclear power reactor site that the facility serves; and (3) The capability to support response to events occurring simultaneously at more than one nuclear power reactor site if the emergency operations facility serves more than one site.

The proposed EOF location change to the CERC will result in a more than 25 miles relocation. The CERC will meet all the requirements stated in 10 CFR 50, Appendix E, Section IV, Part E.

NUREG-0654/FEMA-REP-1, Revision 1 Section II.B.5, states, in part:

Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift staffing levels shall be as indicated in Table B-1.

The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.

NUREG-0654, Revision 1, [8.3] and NUREG-0654, Revision 2, [8.1] provide general guidance concerning the onsite emergency organization and allow licensees some flexibility in the number of on-shift staff required by EPs for response to emergency

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 57 of 59 events. NUREG-0654, Revision 1, [8.3] guidance recommends that there be, in addition to on-shift personnel, 30-minute and 60-minute responders. NUREG-0654, Revision 2,

[8.1] Table B-1 provides for augmented response times of 60 and 90 minutes. The augmented ERO responders assume many managerial, engineering, and administrative duties from the on-shift personnel, allowing on-shift personnel to focus more fully on plant operations. NUREG-0654, Revision 2, [8.1] also provides guidance that augmentation time be measured from the declaration of the emergency. The current VCSNS Emergency Plan staffing in Table B-1a meets the intent of NUREG-0654, Revision 1, [8.3]

Table B-1. This LAR proposes to remove maintenance personnel from shift and extend staff augmentation response times from 30/40/60 minutes to 60/90 minutes. The proposed changes have been evaluated using a staffing analysis performed to verify compliance to 10 CFR 50, Appendix E.IV.A.9 requirements. The proposed changes to the VCSNS Emergency Plan meet the intent of NUREG-0654, Revision 2, [8.1] Table B-

1. In addition, NUREG-0654, Revision 2, [8.1] established evaluation criteria related to EOF under applicable planning standards.

NUREG-0696 NUREG-0696 [8.9] provides compliance criteria for the EOF in various categories. The CERC will comply with these criteria as defined in NUREG-0696 [8.9]. In addition, the CERC will comply with the guidance stated in Section IV of NSIR/DPR-ISG-01 [8.7] for a performance-based approach for evaluating changes to a consolidated EOF.

5.2 Applicable Regulatory Guidance Revision 2 to NUREG-0654/FEMA, [8.1] [Federal Emergency Management Agency]-

REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, establishes evaluation criteria related to the EOF under applicable planning standards.

NUREG-0696, [8.9] Functional Criteria for Emergency Response Facilities, provides criteria for the NRC staff to use in evaluating whether an applicant or licensee meets the requirements in paragraph IV.E.8 of Appendix E to 10 CFR Part 50. Section 4, Emergency Operations Facility, of NUREG-0696 [8.9] provides compliance criteria for the EOF in the following categories:

  • Functions (section 4.1)
  • Location, Structure, and Habitability (section 4.2)
  • Staffing and Training (section 4.3)
  • Size (section 4.4)
  • Radiological Monitoring (section 4.5)
  • Communications (section 4.6)
  • Instrumentation, Data System Equipment, and Power Supplies (section 4.7)

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  • Technical Data and Data System (section 4.8)
  • Records Availability and Management (section 4.9)

The Office of Nuclear Security and Incident Response (NSIR)/Division of Preparedness and Response (DPR) Interim Staff Guidance (ISG) document, NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants, dated November 2011 [8.7]

supplements NUREG-0696 [8.9] and in Section IV.I provides a performance-based approach for evaluating changes to a consolidated EOF.

5.3 Precedents This proposed VCSNS Emergency Plan staff augmentation related changes are similar to changes approved for other licensees, including:

In addition, NRC has approved several consolidated EOFs located more than 25 miles from stations they support. The proposed VCSNS EOF consolidation is similar to changes approved by the NRC for other licensees. For instance,

  • Xcel Energy Request for Emergency Operations Facility Consolidation and Relocation to replace the existing Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant EOFs, and their common backup EOF, with a consolidated EOF centrally located in the Xcel Energy headquarters, located in Minneapolis, NM [8.37]
  • For Dominion Energy North Anna and Surry Power Stations, approved on February 27, 2019, [8.10]
  • For Southern Nuclear Operating Companys Edwin I. Hatch Nuclear Plant, Joseph M. Farley Nuclear Plant, and Vogtle Electric Generating Plant [8.11]

Serial No.22-249 Docket No. 50-395 Attachment 1: Page 59 of 59 During the past decade, NRC approved addition of plants to previously approved consolidated EOFs, including

  • William States Lee III Nuclear Station [8.12]
  • Brunswick, Robinson and Sheron Harris for Duke Energys Charlotte EOF in Charlotte, North Carolina [8.12, 8.13],
  • Calvert Cliffs for the Exelon Mid-Atlantic EOF in CoatesviIle, Pennsylvania [8.14]
  • Southern Nuclear Operating Companys EOF [8.15] and River Bends backup EOF

[8.16]

5.4 No Significant Hazards Consideration The no significant hazards consideration is presented in Attachment 6.

5.5 Conclusion In conclusion, DESC has evaluated the proposed changes against the applicable regulatory requirements and acceptance criteria. The proposed VCSNS Emergency Plan changes continue to assure that regulatory requirements and emergency planning standards associated with emergency response are met.

Based on the considerations discussed above, DESC has determined that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the NRCs regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

DESC has determined that the proposed change would change a requirement with respect to installation or use of a facility or component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, or (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) 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). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Serial No.22-249 Docket No. 50-395 ATTACHMENT 2 CURRENT VCSNS EMERGENCY PLAN PAGES MARK-UP Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Dominion Energy South Carolina, Inc. (DESC)

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Serial No.22-249 Docket No. 50-395 ATTACHMENT 3 REVISED (CLEAN) VCSNS EMERGENCY PLAN PAGES Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Dominion Energy South Carolina, Inc. (DESC)

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Serial No.22-249 Docket No. 50-395 ATTACHMENT 4 TABLE B-1 COMPARATIVE CHART Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Dominion Energy South Carolina, Inc. (DESC)

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Serial No.22-249 Docket No. 50-395 ATTACHMENT 5 ERO POSITION IMPACT

SUMMARY

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Serial No.22-249 Docket No. 50-395 ATTACHMENT 6 NO SIGNIFICANT HAZARDS CONSIDERATION JUSTIFICATION Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Dominion Energy South Carolina, Inc. (DESC)

Serial No.22-249 Docket No. 50-395 Attachment 6: Page 1 of 3 NO SIGNIFICANT HAZARDS CONSIDERATION JUSTIFICATION Description of Amendment Request:

The proposed amendment would modify the VCSNS Emergency Plan by:

(1) Extending Emergency Response Organization (ERO) Augmentation Times to 60 or 90 minutes from 30 or 60 minutes depending on specific ERO positions.

(2) Relocating the Emergency Operations Facility (EOF) and the Joint Information Center (JIC) from Ballentine, South Carolina and West Columbia, South Carolina to the Dominion Energy Corporate Emergency Response Center (CERC) in Glen Allen, Virginia.

(3) Adding a definition for facility activation criteria to align with command-and-control functions in the Technical Support Center (TSC), Operational Support Center (OSC), and Corporate Emergency Response Center (CERC).

(4) Revising the minimum staffing definition for the Emergency Response Facilities (ERF) to align with new facility activation criteria.

(5) Extending facility activation requirements to 90 minutes after declaration of an Alert or higher classification.

(6) Reorganizing the VCSNS Emergency Plan Table B-1a based on emergency preparedness functions.

(7) Reducing the classification level at which dispatch of Offsite Survey Teams is required from a Site Area Emergency (SAE) to an Alert.

(8) Removing references to chemistry, maintenance, firefighting, first aid/rescue, site access control and personal accountability functions being on-shift from Table B-1a.

Basis for proposed no significant hazards consideration:

Dominion Energy South Carolina (DESC) has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below:

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

Response: No.

The proposed changes, have no effect on normal plant operation or on any accident initiator or precursor. The proposed changes do not impact the function of plant structures, systems, or components (SSCs). The proposed changes do not alter or prevent the ERO from performing its intended functions to mitigate the consequences of an accident or event. The ability of the ERO to adequately respond to radiological

Serial No.22-249 Docket No. 50-395 Attachment 6: Page 2 of 3 emergencies has been demonstrated as acceptable through a staffing analysis as required by 10 CFR 50, Appendix E.IV.A.9.

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 changes do 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 changes do not introduce failure modes that could result in a new accident. The proposed increases to the staff augmentation response times in the VCSNS Emergency Plan and the relocation of the EOF and JIC have been demonstrated to be acceptable through a staffing analysis as required by 10 CFR 50, Appendix E.IV.A.9 and a detailed functional analysis. The proposed changes do not alter or prevent the ERO from to performing its intended functions to mitigate the consequences of an accident or event.

Therefore, the proposed changes do 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 the 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 changes are associated with the VCSNS Emergency Plan staffing, EOF and JIC relocation and other administrative items, as described in the description section. The proposed changes do not impact operation of the plant or its response to transients or accidents. The changes do not affect the Technical Specifications (TS). The proposed changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes. The revised VCSNS Emergency Plan will continue to provide the necessary response staff. A staffing analysis and a functional analysis were performed for the proposed changes on the timeliness of performing major tasks for the functional areas of the VCSNS Emergency Plan. These analyses concluded that extensions to staff augmentation times and the relocation of EOF would not significantly affect the ability to perform the required Emergency Plan tasks. Therefore, the proposed changes are determined to not adversely affect the ability to meet 10 CFR 50.54(q)(2), the requirements of 10 CFR 50, Appendix E, the emergency planning standards as described in 10 CFR 50.47 (b)

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Serial No.22-249 Docket No. 50-395 Attachment 6: Page 3 of 3 Based on above, DESC concludes that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

Serial No.22-249 Docket No. 50-395 ATTACHMENT 7 OFFSITE RESPONSE ORGANIZATION CONCURRENCE LETTERS Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Dominion Energy South Carolina, Inc. (DESC)

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Serial No.22-249 Docket No. 50-395 ATTACHMENT 8 REFERENCES Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Dominion Energy South Carolina, Inc. (DESC)

Serial No.22-249 Docket No. 50-395 Attachment 8: Page 1 of 3 8.1 ADAMS Accession No. ML19347D139, NUREG-0654/FEMA-REP-1, Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, December 2019 8.2 ADAMS Accession No. ML16124A002, NRC Regulatory Issue Summary (RIS) 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, August 5, 2016 8.3 ADAMS Accession No. ML040420012, 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, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, November 1980 8.4 ADAMS Accession No. ML20040B267, NRC Letter to South Carolina Electric and Gas Company, NUREG-0717, Supplement No. 3, Safety Evaluation Report related to the operation of Virgil C. Summer Nuclear Station Unit 1, January 1982 8.5 ADAMS Accession No. ML082970276, NRC Letter to South Carolina Electric & Gas Company, Virgil C. Summer Nuclear Station, Unit No. 1, Safety Evaluation for Emergency Action Levels, December 15, 2008 8.6 ADAMS Accession No. ML15063A355, NRC Letter to South Carolina Electric & Gas Company, Virgil C. Summer Nuclear Station, Unit 1 - Issuance of Amendment to Revise Emergency Action Levels to a Scheme Based on NEI 99-01, Revision 6, April 12, 2015 8.7 ADAMS Accession No. ML113010523, NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants, Revision 0, November 2011 8.8 ADAMS Accession No. ML20062B392, NRC RII Letter to South Carolina Electric &

Gas Company, Response to Supporting Information Addressing Core Technical Support Augmentation Time in Revision 26 of Virgil C. Summer Radiation Emergency Plan, August 21, 1990 8.9 ADAMS Accession No. ML051390358, NUREG-0696, Functional Criteria for Emergency Response Facilities - Final Report, February 1981 8.10 ADAMS Accession No. ML19031B227, NRC Letter to Virginia Electric and Power Company,

Subject:

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 (EPID L-2018-LLA-0014), February 27, 2019 8.11 ADAMS Accession No. ML043350484, NRC Letter to Southern Nuclear Operating Company, Inc.,

Subject:

Emergency Operations Facility (EOF) Relocation and Consolidation to the Southern Nuclear Corporate EOF (TAC Nos. MC1056, MC1058, MC1059, MC1060, and MC1061), April 6, 2005

Serial No.22-249 Docket No. 50-395 Attachment 8: Page 2 of 3 8.12 ADAMS Accession No. ML16160A414, Final Safety Evaluation Report for Combined Licenses for William States Lee III Nuclear Station Units 1 and 2, August 2016 8.13 ADAMS Accession No. ML17188A387, Brunswick Steam Electric Plant, Units 1 and 2; Shearon Harris Nuclear Power Plant, Unit 1; H.B. Robinson Steam Electric Plant Unit No. 2; and Oconee Nuclear Station, Units 1, 2 and 3 - Issuance of Amendments to Consolidate Emergency Operations Facilities and Associated Emergency Plan Changes (CAC Nos. MF7650, MF7651, MF7652, MF7653, MF7654, MF7655, MF7656, MF7657, MF7658, MF7659, and MF7660), August 21, 2017 8.14 ADAMS Accession No. ML19165A247, Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Issuance of Amendment Nos. 330 and 308, Re: Relocation and Consolidation of the Emergency Operations Facility and Joint Information Center for the Calvert Cliffs Nuclear Power Plant (EPID L-2018-LLA-0241), August 26, 2019 8.15 ADAMS Accession No. ML18183A073, Joseph M. Farley Nuclear Plant, Units 1 and 2: Edwin I. Hatch Nuclear Plant, Units 1 and 2, and Vogtle Electric Generating Plant, Units 1, 2, 3 and 4; Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility (CAC Nos. MG0188, MG0189, MG0190, MG0191, MG0192, MG0193, MG0194, and MG0195; EPID L-2017-LLA-0293), July 26, 2018 8.16 ADMAS Accession Nos. ML12240A1890 and ML12269A263, River Bend Station, Unit 1 - Issuance of Amendment Related to the Relocation of the Backup Emergency Operations Facility (TAC No. ME7181), September 24, 2012, with correction October 9, 2012 8.17 ADMAS Accession No. ML20004E346, NUREG-0717, Safety Evaluation Report related to the operation of Virgil C. Summer Nuclear Station, Unit 1 - Supplement 2, May 1981 8.18 ADAMS Accession No. ML20040B267, NUREG-0717, Safety Evaluation Report related to the operation of Virgil C. Summer Nuclear Station, Unit 1 - Supplement 3, January 1982 8.19 ADAMS Accession No. ML20076L733, NRC Letter to South Carolina Electric and Gas Company,

Subject:

Docket No. 50-395, August 5, 1983 8.20 Building Officials Code Administrators National Building Code, 1981 8.21 ADAMS Accession No. 6822946, NUREG-1228, Source Term Estimation During Incident Response to Severe Nuclear Power Plant Accidents, October 1988 8.22 ADAMS Accession No. ML091980341, NUREG/BR-0150 Vol. 1, Rev. 4, RTM-96 Response Technical Manual, March 1996 8.23 ADAMS Accession No. ML051400209, NUREG-0737, Clarification of TMI Action Plan Requirements, November 1980

Serial No.22-249 Docket No. 50-395 Attachment 8: Page 3 of 3 8.24 ADAMS Accession No. ML10256009, NUREG-0737, Clarification of TMI Action Plan Requirements, Supplement No. 1, January 1983 8.25 National Academy document, ACAD 02-001, The Objectives and Criteria for Accreditation of Training in the Nuclear Power Industry 8.26 ADAMS Accession No. ML102560007, NUREG-0899, Guidelines for the Preparation of Emergency Operating Procedures, August 1982 8.27 ADAMS Accession No. ML111751698, NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, June 2011 8.28 ADAMS Accession No. ML080450149, NEI 99-01, Rev. 5, Methodology for Development of Emergency Action Levels, February 2008 8.29 ADAMS Accession No. ML12326A805, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-passive Reactors, November 2012 8.30 ADAMS Accession No. ML16005A625, NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Rev. 2, December 2015 8.31 ADAMS Accession No. ML12125A412, NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Rev.

0, May 2012 8.32 INPO 90-003, Guidelines for the Training and Qualification of Shift Technical Advisors 8.33 ADAMS Accession No. ML15356A842, ACAD 14-002, National Academy for Nuclear Training, Guidelines for Shift Manager Selection, Training and Qualification of Shift Technical Advisors, August 2014 8.34 VCSNS FLEX Validation Technical Report, TR00080-007: Reference 50 in ADAMS Accession No. ML16307A390, VCSNS Report of Full Compliance and Final Integrated Plan, October 31, 2016, and in reference section of ML18100A270, NRC Team Inspection Report 05000395/2018011, April 10, 2018 8.35 ADAMS Accession No. ML12054A735, NRC Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, March 12, 2012 8.36 FEMAs National Flood Hazard Layer (NFHL) Viewer (arcgis.com) 8.37 ADAMS Accession No. ML22357A100, Safety Evaluation Report, Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant, Units 1 and 2 - Issuance of Amendments Re: Standard Emergency Plan and Consolidated Emergency Operations Facility (EPID L-2021-LLA-0210), March 31, 2023