ML24054A014

Issuance of Amendment Nos. 297 and 280, and Surry Power Station Unit Nos. 1 and 2, Issuance of Amendment Nos. 317 and 317, to Change Emergency Plan Staff Augmentation Times

ML24054A014
Person / Time
Site:	Surry, North Anna
Issue date:	04/22/2024
From:	Geoffrey Miller Plant Licensing Branch II
To:	Stoddard D Southern Nuclear Operating Co
Miller G
References
EPID L 2022 LLA 0166
Download: ML24054A014 (1)

Text

April 22, 2024

Mr. Eric S. Carr Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 ISSUANCE OF AMENDMENT NOS. 297 AND 280; AND SURRY POWER STATION, UNIT NOS. 1 AND 2, ISSUANCE OF AMENDMENT NOS. 317 AND 317, TO CHANGE EMERGENCY PLAN STAFF AUGMENTATION TIMES (EPID L-2022-LLA-0166)

Dear Mr. Carr:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment Nos. 297 and 280 to Renewed Facility Operating License Nos. NPF-4 and NPF-7 for the North Anna Power Station (North Anna), Unit Nos. 1 and 2, and Amendment Nos. 317 and 317 to Renewed Facility Operating License Nos. DPR-32 and DPR-37 for the Surry Power Station (Surry), Unit Nos. 1 and 2, respectively. The amendments revise the license in response to your application dated November 7, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22312A550), as supplemented by letters dated March 30, 2023 (ML23089A354), October 12, 2023 (ML23285A066) and February 5, 2024 (ML24036A318).

These amendments revise the North Anna and Surry Emergency Plan to change the staff augmentation times as described in their submittal and associated supplements.

E. Carr

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

G. Edward Miller, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-338, 50-339, 50-280, and 50-281

Enclosures:

1. Amendment No. 297 to NPF-4

2. Amendment No. 280 to NPF-7

3. Amendment No. 317 to DPR-32

4. Amendment No. 317 to DPR-37

5. Safety Evaluation

cc: Listserv

VIRGINIA ELECTRIC AND POWER COMPANY

DOCKET NO. 50-338

NORTH ANNA POWER STATION, UNIT NO. 1

AMENDMENT TO RENEWED FA CILITY OPERATING LICENSE

Amendment No. 297 Renewed License No. NPF-4

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Virginia Electric and Power Company (the licensee) dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

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2. Accordingly, by Amendment No. 297, Renewed Facility Operating License No. NPF-4 is hereby amended to authorize revision to the Emergency Plan for the North Anna Power Station, Unit 1, as set forth in the Virginia Electric and Power Company application dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION

Andrea D. Veil, Director Office of Nuclear Reactor Regulation

Date of Issuance: April 22, 2024 VIRGINIA ELECTRIC AND POWER COMPANY

DOCKET NO. 50-339

NORTH ANNA POWER STATION, UNIT NO. 2

AMENDMENT TO RENEWED FA CILITY OPERATING LICENSE

Amendment No. 280 Renewed License No. NPF-7

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Virginia Electric and Power Company (the licensee) dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

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2. Accordingly, by Amendment No. 280, Renewed Facility Operating License No. NPF-7 is hereby amended to authorize revision to the Emergency Plan for the North Anna Power Station, Unit 2, as set forth in the Virginia Electric and Power Company application dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION

Andrea D. Veil, Director Office of Nuclear Reactor Regulation

Date of Issuance: April 22, 2024 ATTACHMENT

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2

LICENSE AMENDMENT NO. 297 TO

RENEWED FACILITY OPERATING LICENSE NO. NPF-4

DOCKET NO. 50-338

AND

LICENSE AMENDMENT NO. 280 TO

RENEWED FACILITY OPERATING LICENSE NO. NPF-7

DOCKET NO. 50-339

Replace the following pages of the Licenses and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages

License License License No. NPF-4, page 3 License No. NPF-4, page 3 License No. NPF-7, page 3 License No. NPF-7, page 3

TSs TSs N/A N/A

- 3 -

(2) Pursuant to the Act and 10 CFR Part 70, VEPCO to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report;

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, VEPCO to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;

(4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, VEPCO to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material, without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or component; and

(5) Pursuant to the Act and 10 CFR Parts 30 and 70, VEPCO to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I; Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level

VEPCO is authorized to operate the North Anna Power Station, Unit No. 1, at reactor core power levels not in excess of 2940 megawatts (thermal).

(2) Technical Specifications

Technical Specifications contained in Appendix A, as revise d through Amendment No. 297 are hereby incorporated in the renewed license. Th e licensee shall operate the facility in accordance with the Technical Specifications.

NORTH ANNA - UNIT 1 Renewed License NPF-4 Amendment No. 297

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(3) Pursuant to the Act and 10 CFR Part s 30, 40, and 70, VEPCO to receive possess, and use at any time any byproduct, source, and spec ial nuclear material as sealed neutron sources for reactor startup, sealed sources fo r reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as requir ed;

(4) Pursuant to the Act and 10 CFR Part s 30, 40, and 70, VEPCO to receive, possess, and use in amounts as required any byproduct, sour ce, or special nuclear material, without restriction to chemical or physical f orm, for sample analysis or instrument calibration or associated with radioactive apparat us or component; and

(5) Pursuant to the Act and 10 CFR Part s 30, 40, and 70, VEPCO to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations as set f orth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to th e additional conditions specified or incorporated below:

(1) Maximum Power Level

VEPCO is authorized to operate the facility at steady state reactor core power levels not in excess of 2940 megawatts (thermal).

(2) Technical Specifications

The Technical Specifications contained in Appendix A, as revised through Amendment No. 280 are hereby incorporated in the renewed license. Th e licensee shall operate the facility in accordance with the Technical Specifications.

(3) Additional Conditions

The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following t he insurance of the condition or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the rene wed license supported by a favorable evaluation by th e Commission:

a. If VEPCO plans to remove or to make significant changes in t he normal operation of equipment that controls the amount of radioactivity in effluen ts from the North Anna Power Station, the

NORTH ANNA - UNIT 2 Renewed License NPF-7 Amendment No. 280 VIRGINIA ELECTRIC AND POWER COMPANY

DOCKET NO. 50-280

SURRY POWER STATION, UNIT NO. 1

AMENDMENT TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE

Amendment No. 317 Subsequent Renewed License No. DPR-32

1. The Nuclear Regulatory Commission (NRC, the Commission) has found t hat:

A. The application for amendment by Virginia Electric and Power Company (the licensee) dated November 7, 2022, as supplemented by lette rs dated March 30, 2023, October 12, 2023, and February 5, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the healt h and safety of the public, and (ii) that such activities will be conducted in compliance with th e Commission's regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 3

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2. Accordingly, by Amendment No. 317, Subsequent Renewed Facility Operating License No. DPR-32 is hereby amended to authorize revision to the Emergency Plan for the Surry Power Station, Unit 1, as set forth in the Virginia Electric and Power Company application dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION

Andrea D. Veil, Director Office of Nuclear Reactor Regulation

Date of Issuance: April 22, 2024 VIRGINIA ELECTRIC AND POWER COMPANY

DOCKET NO. 50-281

SURRY POWER STATION, UNIT NO. 2

AMENDMENT TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE

Amendment No. 317 Subsequent Renewed License No. DPR-37

1. The Nuclear Regulatory Commission (NRC, the Commission) has found t hat:

A. The application for amendment by Virginia Electric and Power Company (the licensee) dated November 7, 2022, as supplemented by lette rs dated March 30, 2023, October 12, 2023, and February 5, 2024, complies with the standar ds and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the healt h and safety of the public, and (ii) that such activities will be conducted in compliance with th e Commission's regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 4

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2. Accordingly, by Amendment No. 317, Subsequent Renewed Facility Operating License No. DPR-37 is hereby amended to authoriz e revision to the Emergency Plan for the Surry Power Station, Unit 2, as set forth in the Virginia Electric and Power Company application dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION

Andrea D. Veil, Director Office of Nuclear Reactor Regulation

Date of Issuance: April 22, 2024 ATTACHMENT

SURRY POWER STATION, UNIT NOS. 1 AND 2

LICENSE AMENDMENT NO. 317

TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NO. DPR-32

DOCKET NO. 50-280

AND

LICENSE AMENDMENT NO. 317

TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NO. DPR-37

DOCKET NO. 50-281

Replace the following pages of the Licenses and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages

License License License No. DPR-32, page 3 License No. DPR-32, page 3 License No. DPR-37, page 3 License No. DPR-37, page 3

TSs TSs N/A N/A

3. This subsequent renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A. Maximum Power Level

The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2587 megawatts (thermal).

B. Technical Specifications

The Technical Specifications contained in Appendix A, as revised through Amendment No. 317 are hereby incorporated in the subsequent renewed license.

The licensee shall operate the facility in accordance with the Technical Specifications.

C. Reports

The licensee shall make certain reports in accordance with the requirements of the Technical Specifications.

D. Records

The licensee shall keep facility operating records in accordance with the requirements of the Technical Specifications.

E. Deleted by Amendment 65

F. Deleted by Amendment 71

G. Deleted by Amendment 227

H. Deleted by Amendment 227

Surry - Unit 1 Subsequent Renewed License No. DPR-32 Amendment No. 317

3. This subsequent renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A. Maximum Power Level

The licensee is authorized to operate the facility at steady state reactor core power Levels not in excess of 2587 megawatts (thermal).

B. Technical Specifications

The Technical Specifications contained in Appendix A, as revised through Amendment No. 317 are hereby incorporated in this subsequent renewed license.

The licensee shall operate the facility in accordance with the Technical Specifications.

C. Reports

The licensee shall make certain reports in accordance with the requirements of the Technical Specifications.

D. Records

The licensee shall keep facility operating records in accordance with the Requirements of the Technical Specifications.

E. Deleted by Amendment 54

F. Deleted by Amendment 59 and Amendment 65

G. Deleted by Amendment 227

H. Deleted by Amendment 227

Surry - Unit 2 Subsequent Renewed License No. DPR-37 Amendment No. 317 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

RELATED TO

AMENDMENT NO. 297

TO RENEWED FACILITY OPERATING LICENSE NO. NPF-4

AMENDMENT NO. 280

TO RENEWED FACILITY OPERATING LICENSE NO. NPF-7

AMENDMENT NO. 317

TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NO. DPR-32

AMENDMENT NO. 317

TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NO. DPR-37

VIRGINIA ELECTRIC AND POWER COMPANY

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2

DOCKET NOS. 50-338 AND 50-339

SURRY POWER STATION, UNIT NOS. 1 AND 2

DOCKET NOS. 50-280 AND 50-281

1.0 INTRODUCTION

By application dated November 7, 2022 (Reference 1), as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024 (References 2, 3 and 4, respectively),

Virginia Electric and Power Company (doing business as Dominion Energy Virginia, hereafter referred to as Dominion) submitted a license amendment request (LAR) for Commission review and approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR) for changes to the Emergency Plans for North Anna Power Station, Units 1 and 2 (North Anna) and Surry Power Station, Units 1 and 2 (Surry). The licensees LAR proposes the following changes:

Enclosure 5

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Extension of facility activation time requirements for the Technical Suppor t Center (TSC), Operational Support Center (OSC), and Corporate Emergency Response Center (CERC) to 90 minutes; Extension of the augmentation time for Emergen cy Response Organization (ERO) members to 90 minutes; Redefinition of minimum staff posit ions in the Emergency Response Facilities (ERFs) to align with new facilit y activation criteria; Addition of a definition for facility activation criteria to align with command-and control functions in the TSC, OSC, and CERC; Aligning required ERO on-shift personnel with revised regulat ory guidance; Removal of administrative positions to non-emergency response procedures; and Removal of the Local Media Center (LMC) at each station as an ERF.

In its letter dated November 7, 2022, the licensee states that:

The changes in staff augmentation response times and reductions in the number of augmented ERO positions are considered a reduction in Emergency Plan effectiveness as defined in 10 CFR 50.54(q)(1)(iv). In accordance with 10 CFR 50.54(q)(4), changes to a licensee's emergency plan that reduce the effectiveness of the plan may not be implemented without prior NRC approval and are required to be submitted for approval as a license amendment request (LAR) in accordance with 10 CFR 50.90.

The supplemental letters dated March 30, 2023, October 12, 2023, and February 5, 2024, provided additional information that clarified the application, but did not expand the scope of the application as originally noticed nor change the U.S. Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register (FR) on December 27, 2022 (87 FR 79359).

2.0 REGULATORY EVALUATION

The NRC staff considered the following regulatory requirements and guidance during its review of the proposed changes.

2.1 Regulatory Requirements

The planning standards in 10 CFR 50.47(b) establish the requirements that the onsite and offsite emergency response plans must meet for the NRC staff to make a finding that there is reasonable assurance that the licensee can, and will, take adequate protective measures in the event of a radiological emergency. The capabilities of on-shift and augmented ERO staffing are addressed under the following regulations:

Regulations in 10 CFR 50.47(b)(2) states, On-shift facility licensee responsibilities for emergency respo nse are unambiguously defined, ade quate staffing to provide initial facility accident response in key functional area s is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite su pport and response activities are specified.

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Regulations in 10 CFR 50.47(b)(9), states, Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite cons equences of a radiological emergency condition are in use.

Regulations in 10 CFR 50.47(b)(11), states, in part, Means for controllin g radiological exposures, in an emergency, are established for emergency workers.

Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV, Part A, Organization, states, in pa rt, The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigne d to the licensees emergency organization.

2.2 Guidance

Regulatory Guide (RG) 1.101, Revision 6, Emergency Response Planning and Preparedness for Nuclear Power Reactors, June 2021 (Reference 5), endorses 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, (hereafter referred to NUREG-0654)

December 2019 (Reference 6), which provides spec ific acceptable criteria for complying with the planning standards set forth in 10 CFR 50.47.

Guidance in NUREG-0654, Revis ion 2, Evaluation Criteria II.B, Emergency Response Organization, addresses planning standard 10 CFR 50.47(b)(2). Evaluation Criterion II.B.1.a specifies the site-specific emergency response organization (ERO) is developed. In addition, Evaluation Criterion II.B.3, states:

A table is developed depicting the site-specific on-shift staffing plan, as well as the ERO staffing augmentation plan. Table B-1, Emergency Response Organization (ERO)

Staffing and Augmentation Plan, provides a model for licensees to consider.

The NRCs Office of Nuclear Security and Inci dent Response (NSIR), Division of Preparedness and Response (DPR), Interim Staff Guidance (ISG), document - NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants, November 2011 (Reference 7), provides updated guidance information to address emergency planning requirements for nuclear power plants. Specifically, NSIR/DPR-ISG-01 was dev eloped to address the assignment of tasks or responsibilities to on-shift ERO personnel that would potentially overburden them and prevent the timely performance of their emergency plan functions. The ISG also addresses the Nuclear Energy Institute (NEI) document NEI 10-05, Revision 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, June 2011 (Reference 8), which was developed to establish a standard methodology for licensees to conduct analyses of the ability of on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency for an operating power reactor. The ISG states that NEI 10-05 provides an acceptable methodology for the purpose of performing the required staffing analysis.

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Regulatory Issue Summary 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (Reference 9), provides examples of the scope and detail of information that should be provided in license amendment requests related to ERO staffing and augmentation to facilitate the NRC staffs review.

The North Anna and Surry Emergency Plans are functionally identical. Because of the similarity of these emergency plans, this safety evaluation will refer to these plans collectively as the North Anna and Surry Emergency Plans. Dominion states that the proposed changes to the Emergency Plans meet the intent of NUREG-0654, Revision 2, Table B-1 (i.e., continues to cover the emergency functional areas in Table B-1). The proposed ERO staffing plan was evaluated by the NRC staff using the functi onal area analysis of NUREG-0654, Revision 2.

3.0 TECHNICAL EVALUATION

In its application dated November 7, 2022, as su pplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion provided justifications for the proposed North Anna and Surry Emergency Plan changes. The NRC staffs technical evaluation of the proposed changes is detailed below.

3.1 Major Functional Areas

The current North Anna and Surry Emergency Plans describ e the ERO as consisting of personnel staffing in the following emergency response facilities:

Control Room, TSC, OSC, CERC, Joint Information Center (JIC), and LMC.

The proposed changes to the North Anna and Surry Emergency Plans would extend the facility activation times following the declaration of an Alert or greater emergency classification as follows: (1) extend the TSC and OSC activation time from 60 minutes to 90 minutes with the exception of one mechanical maintenance technician and one electrical maintenance technician being activated at 60 minutes; and (2) extend the CERC activation and JIC staffing times from 75 minutes to 90 minutes.

3.1.1 Command and Control

The purpose of the ERO Command and Control function is to: (1)provide overall ERO command and control, until relieved; (2)approve emergency action level (EAL) classifications and/or protective action recommendations (PARs), until relieved; and (3) authorize personnel dose extensions, until relieved. The Shift Manager is the on-shift individual who will initially perform the ERO Command and Control function. The licensee provided its analysis of the Command-and-Control function in Section 3.2.2, Emergency Direction and Control (Command and Control, Emergency Classification), in the LAR enclosures for North Anna and Surry.

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The current North Anna and Surry Emergency Plans staffing for command and control is consistent with the NUREG-0654, Table B-1, with one difference. Dominion provides command and control augmentation at the TSC within 60 minutes of an Alert or greater emergency classification and at the CERC within 75 minutes of an Alert or greater emergency classification.

The CERC augmentation within 75 minutes of an Alert or greater emergency classification is different from the NUREG-0654, Table B-1, that provides for CERC augmentation within 60 minutes of the declaration of a Site Area Emergency or greater emergency classification.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to extend the ERO augmentation time for the TSC and CERC, which provide relief and augmentation for the command and control function, from within 60 minutes and 75 minutes, respectively, to within 90 minutes of an Alert or greater emergency classification. Dominion states that the two Unit Supervisors (Senior Reactor Operators) noted in the proposed North Anna and Surry Table 5.1 provide Control Room oversight and direct plant operations as required by Technical Specifications. The Operations Shift Manager, who is the third Senior Reactor Operator, provides emergency preparedness (EP) command and-control functions, including event classification and oversight of event response. The on-shift operations staff administrative requirements for North Anna and Surry exceed the number of senior operators required by 10 CFR 50.54(m) and site Technical Specifications. The proposed change will maintain shift staffing consistent with the existing administrative procedures.

Dominion further states that the North Anna and Surry staffing plans allow for separation of responsibilities between performance of the Operations Shift Manager and Station Emergency Manager (SEM) functions. The individual performing the Shift Manager role prior to an event assumes SEM responsibilities at the onset of the event, and a Unit Supervisor assumes the responsibilities of the Operations Shift Manager. This change in roles relieves the Unit Supervisor, who is performing Operations Shift Manager oversight and controlling unit operation, of the collateral duties of the SEM function. The Dominion Fleet Procedure for Conduct of Operations currently provides for this transition of responsibilities. The only authority the Unit Supervisor does not assume from the Operations Shift Manager is approval of actions in accordance with 10 CFR 50.54(x) and overall event supervision. SEM activities are also supported by other on-shift resources such as the Shift Technical Advisor (STA), security personnel, and the Emergency Communicator. Therefore, the licensee states that the proposed approach continues to ensure adequate relief of the collateral duties of the SEM function for the acting Operations Shift Manager.

The NRC staff reviewed the proposed changes re lated to emergency direction and control and found them acceptable based on the information discussed above. With the proposed changes, the North Anna and Surry Emergency Plans will have additional on-shift staffing that provides for the individual performing the Shift Manager role prior to an event assuming SEM responsibilities at the onset of the event, and an on-shift Unit Supervisor assuming the responsibilities of the Operations Shift Manager at the beginning of the event until relieved by the SEM in the TSC and Technical Support Manager in the CERC within 90 minutes of an Alert or greater emergency classification.

Based on the above, the NRC staff has determined that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Command-and-Control function.

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3.1.2 Communications

The purpose of the Communications function is to communicate EAL and PAR classifications to Offsite Response Organization (OROs) and the NRC, until relieved. The licensee provided its analysis of the communications function in Section 3.2.3, Notification/Communication Function, in the LAR enclosures for North Anna and Surry. The current Dominion staffing for the Communications function is consistent with the NUREG-0654, Table B-1, with two differences. The first difference is that the current North Anna and Surry Emergency Plans provide two on-shift communicators instead of the one on-shift communicator in NUREG-0654, Table B-1. The second difference is that the Emergency Communicator at the CERC will be available within 75 minutes of an Alert or greater emergency classification, while NUREG-0654, Table B-1, provides for CERC staffing of one communicator within 90 minutes of an Alert or greater emergency classification.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to extend the TSC communicator response times from the current 60 minutes to 90 minutes from a declaration of an Alert or greater emergency classification and the CERC communicator response time from within 75 minutes of an Alert or greater emergency classification to within 90 minutes of an Alert or greater emergency classification. Because the North Anna and Surry Emergency Plans will continue to provide two dedicated on-shift communicators to perform communications with the ORO and the NRC, extending the augmentation by two communicators at the TSC and one communicator at the CERC to within 90 minutes of an Alert or greater emergency classification has no impact to the performance of the communications function. Therefore, NRC staff finds the proposed changes to extend the augmentation response time of the TSC and CERC communicators acceptable.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for communications.

3.1.3 Radiation Protection

The purpose of the Radiation Protection (RP) func tion is to: (1) provide qualified RP coverage for responders accessing potentially unknown radiological environments during emergency conditions; (2) provide in-plant surveys; and (3) control dosimetry and radiologically controlled area access. Dominion provided its analysis of the RP Function in Section 3.2.6, Protective Actions (In-Plant) Function), in the LAR enclosures for North Anna and Surry.

The current Dominion staffing for the RP f unction is consistent with the NUREG-0654, Table B-1, with two differences. The first difference relates to the current ERO RP augmentation time, which for North Anna is four RP technicians within 45 minutes and four additional RP technicians within 60 minutes of the declaration of an Alert or greater emergency classification, and for Surry is eight RP technicians within 60 minutes of the declaration of an Alert or greater emergency classification. NUREG-0654, Table B-1, on the other hand, provides for augmenting with three RP technicians within 60 minutes of a declaration of an Alert or greater emergency classification and an additional three RP technicians within 90 minutes of a declaration of an Alert or greater emergency classification. The second difference is that Dominion currently provides alternate on-shift staffing for the RP function. The current Dominion on-shift RP staffing provides three on-shift RP technicians, one of whom is designated to perform out-of-plant surveys, while the NUREG-0654 Table B-1 provid es for two on-shift RP technicians.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to maintain the number of on-shift RP technicians at three, reduce the number of augmenting RP technicians from eight to six, and extend the augmentation response times for the RP technicians to within 90 minutes of a declaration of an Alert or greater emergency cla ssification. In response to NRC staff request for additional information (RAI) and an NRC audit dated July 10-11, 2023 (audit), Dominion provided supplemental letters dated March 30, 2023, and October 12, 2023, that provided addition information regarding the on-shift RP capabilities. The primary RP capability supporting the proposed RP related changes is the current Dominion RP coverage methodology that was demonstrated during the audit and described in the supplemental letter dated October 12, 2023.

During the NRC audit, Dominion demonstrated its current RP coverage process. This method of RP coverage includes the following key elements that exceed what was assumed in the guidance:

Plant personnel use this methodology during normal plant operations; RP personnel can remotely monitor dose rates at the work location; RP personnel can remotely monitor dose received by workers; RP personnel can use radios to communicate directly with workers; RP personnel can issue equipment to support this RP methodology to address emergent priority work in radiological areas; RP personnel are provided an intuitive interface that uses color coding to support providing RP coverage for multiple radiation workers; and This interface is available on laptop computers that could be used by a single RP technician whether that technici an was performing dose assessment in the control room or located at the RP office.

The proposed North Anna and Surry Emergency Plans include three on-shift RP technicians.

Because Dominion has three on-shift RP technicians with the augmented RP coverage capability with the above elements, the NRC staff has determined that Dominion could perform the dose assessment and radiation protection functions in addition to performing on-site (out-of-plant) surveys, if needed. The NRC staff has determined that the additional one on-shift RP technician (in excess of the two on-shift RP technicians provided in NUREG-0654 Table B-1) and the augmented RP coverage capability also justifies the reduction of the augmenting RP technicians from a total of eight to six within 90 minutes of a declaration of an Alert or greater emergency classification.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for RP.

3.1.4 Supervision of Radiation Protection Staff and Site RP

The purpose of the supervision of RP staff and site RP function is to: (1) evaluate and assess plant and offsite radiological data in the development of onsite protective actions and offsite PARs, until relieved; (2) recommend onsite protective actions and offsite PARs to the applicable decision-maker, until relieved; (3) direct all RP activities, including radiological field assessment team direction, until relieved; and (4) provide relevant information to applicable communicators who are communicating offsite PARs to OROs, until relieved.

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The current Dominion staffing for the RP function, which includes RP supervision, is consistent with the NUREG-0654 Table B-1 with two differences. The first difference is that Dominion currently has Health Physics & Chemistry (Radiological Assessment Coordinator) respond to the CERC to perform within 75 minutes of the declaration of an Alert or greater emergency classification to conduct radiological assessm ent activities, while the NUREG-0654, Table B-1, provides for one RP Coordinator in the TSC within 60 minutes of a declaration of an Alert or greater emergency classification, and an additional RP Manager respond to the EOF within 90 minutes of a Site Area Emergency or greater emergency classification. The second difference is that the North Anna and Surry Emergency Plans currently have a third RP technician who is the senior RP representative onsite who will provide radiological dose assessment and provide for oversight of the on-shift RP technicians until relieved by the Radiological Assessment Director who would respond to the TSC within 45/60 minutes (North Anna/Surry, respectively) of an Alert or greater emergency classification.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to extend the augmentation ERO response time for the Health Physics & Chemis try (Radiological Assessment Coordinator) and the RP Manager to within 90 minutes of a declaration of an Alert or greater emergency classification. Additionally, the proposed Table 5. 1, Minimum Shift Manning Requirements, of the North Anna and Surry Emergency Plans have been modified with the additional position of RP Coordinator that would respond to the OSC within 90 minutes of an Alert or greater emergency classification. Dominion further provides that the on-shift RP technician assigned to dose assessment provides oversight for the two RP technicians as needed.

Because the current North Anna and Surry Emergency Plans identify a dedicated on-shift RP technician as responsible to perform dose assessment and provides for oversight of the on-shift RP technicians until augmented by the Radiologic al Assessment Coordinator at the CERC, the Radiological Assessment Director at the TSC, and the additional position of RP Coordinator at the OSC when those facilities are staffed, the changes as described above to the RP supervision are acceptable.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for supervision of RP.

3.1.5 Dose Assessments/Projections

The purpose of the Dose Assessments/Projections function is to perform dose assessments/projections and provide input to the appliable PAR decision-maker until relieved.

Dominion provided its analysis of the dose assessm ents/projections function in Section 3.2.4, Radiological Accident Assessment and Support of Operational Accident Assessment Function (Dose Assessments/Projections, Field Monitoring Teams, Radiation Protection), in the LAR enclosures for North Anna and Surry.

The current Dominion staffing for the Dose Assessment function is consistent with the NUREG-0654, Table B-1, except for providing a dedicated on-shift dose assessor vice an individual that can perform dose assessment and other collateral duties, provided those duties would not be beyond the capability of the individual at any given time. Dominion currently transfers dose assessment directly from the on-shift dose assessor to the TSC within 60 minutes and subsequently to the CERC within 75 minutes of an Alert or greater emergency classification. Dominion currently staffs one Dose Assessment Team Leader at the TSC within

60 minutes and one Dose Assessor at the CERC within 75 minutes of an Alert or greater emergency classification.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to extend the ERO augmentation response times for TSC dose assessment from 60 minutes and CERC dose assessment from 75 minutes to both being within 90 minutes of an Alert or greater emergency classification. The proposed North Anna and Surry Emergency Plans would continue to provide an on-shift dose assessor who would be augmented by TSC or CERC dose assessment personnel within 90 minutes of an Alert or greater emergency classification. Dominion further states that radiological dose assessment has benefited from technological advances that make it simpler and less time consuming. Improvements in dose assessment capability have resulted from the implementation of MIDAS [Meteorological In formation Dose Assessment System] which includes an expanded isotopic library, enhanced user interface and additional output reporting capability. These improvements provide additional support for the extended performance time of this function by the on-shift dose assessor. Additionally, the procedure used by the on-shift dose assessor is identical to that used by the dose assessor in the TSC and CERC resulting in maintained capability for performance of the dose assessment function during the extended response time.

Because Dominion would continue to provide a dedicated RP technician on-shift to perform dose assessment capability until augmented and the RP technician is assisted by the augmented dose assessment tools, the NRC sta ff finds the proposed changes described above to TSC and CERC dose assessment ERO staffing acceptable.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for dose assessments and projections.

3.1.6 Emergency Classifications

The purpose of the emergency classification function is to evaluate plant conditions and recommend emergency classifications, until reli eved. Dominion provided its analysis of the emergency classifications function in Section 3.2.2, Emergency Direction and Control (Command and Control, Emergency Classification), of the LAR enclosures for North Anna and Surry.

NUREG-0654, Table B-1, recommends an emergency classification advisor to perform this function on-shift and clarifies that: Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time. Additionally, Table B-1 recommends that the on-shift emergency classification advisor be augmented by a second emergency classification advisor in the TSC within 60 minutes of the declaration of an Alert or greater emergency classification.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion states that neither the current nor proposed North Anna and Surry Emergency Plans includes a designated individual to perform the Emergency Classifications Function. As proposed, the North Anna and Surry Emergency Plans would continue to have the Shift Manager perform the Emergency Classifications Function until relieved by the SEM at the TSC. Because Dominion will continue to have the same individuals

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perform emergency classifications as in the current North Anna and Surry Emergency Plans, which ensures that these responsible individuals have the capability to make timely and accurate declarations, there is no change in the capability to perform emergency classifications.

Because Dominion is not proposing a change to their currently approved emergency classification capability, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for emergency classifications.

3.1.7 Engineering

The purpose of the engineering function is to provide engineering coverage related to core/thermal-hydraulics, electrical/instrumentation and control (I&C), and mechanical systems and equipment, until relieved. Dominion provided its analysis of the engineering function in Section 3.2.5, Plant System Engineering, Repair and Corrective Actions Function, in attachment 1 of the November 7, 2022, LAR for North Anna, and Surry.

The NUREG-0654, Table B-1, recommends that one electrical/instrumentation and control engineer, one mechanical engineer, and one core/thermal-hydraulics engineer provide augmentation within 60 minutes of a declaration of an Alert or greater emergency classification.

The core/thermal-hydraulics engineer shift engineering function is to evaluate reactor conditions and can be performed by personnel assigned other responsibilities if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time.

Dominion has an individual with shift technical advisor expertise that can satisfy the on-shift responsibilities for evaluating reactor conditions until augmented by a core/thermal hydraulics engineer. Dominion provides augmentation by one electrical/instrumentation and control engineer, one mechanical engineer, and one core/thermal-hydraulics engineer within 60 minutes of a declaration of an Alert or greater emergency classification. The current staffing for the Engineering function is consistent with the NUREG-0654, Table B-1.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to extend the augmentation response time of the TSC, including the TSC engineering staff, from the current 60 minutes to within 90 minutes of a declaration of an Alert or greater emergency classification. The licensee stated, the site will implement provision of access to and training of the STA on-shift with core damage assessment capability that is functionally equivalent to that used by the Reactor Engineer in the TSC. The additional training provided to the STA ensures that the on-shift STA can perform the reactor engineer function for the proposed response times.

Dominion proposes to have one mechanical technician and one electrical technician respond within 60 minutes of a declaration of an Alert or greater emergency classification. These resources report to the OSC and will act under the direction of the SEM until the OSC is activated. The maintenance response will obtain plant status information from the plant computer system (PCS) and assess any equipment failures occurring during the event in order to initiate troubleshooting.

Dominion further provides that troubleshooting activities are implemented in accordance with Dominion Energy Nuclear Fleet Procedure MA-AA-103, Conduct of Troubleshooting and are

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performed by Operations and Maintenance. The overall process performed by the various involved departments can be summarized as:

1. Operations provides initial assessment and gathering of inform ation;

2. Maintenance, using the data provided by Operations and working with inpu t from Engineering, as needed, initiate recovery/repair plans for restoration; and

3. If the initial maintenance actions are unsuccessful in identifying and reso lving the cause of the equipment malfunction, then full en gagement from Engineering and a more formal troubleshooting process is entered.

The NRC staff concludes that the proposed TSC augmentation at 90 minutes is acceptable because the mechanical and electrical maintenance technicians respond within 60 minutes to initiate the troubleshooting process under the direction of the SEM and the licensee is providing additional training to the on-shift STA to ensure that the STA can perform the reactor engineer function until TSC augmentation. Therefore, the licensee retains the ability to conduct troubleshooting/evaluation of these systems/equipment and support the development of repair plans, if necessary, until the engineering support in the TSC is augmented at 90 minutes.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for engineering.

3.1.8 Security

Site-specific Security Plans provide on-shift security staffing that support emergency response until augmented by an individual that would coordinate security-related activities and information with the Emergency Coordinator [Emergency Director].

Dominion provided its analysis of the Security function in Section 3.2.9, Site Access Control and Personnel Accountability Function (Not Applicable), in the November 7, 2022, letter.

NUREG-0654, Table B-1, recommends the on-shift secu rity function to be provided by security staffing per the site-specific security pl an. NUREG-0654, Table B-1, recommends that the on-shift security staffing be augmented by a security liaison in the TSC within 60 minutes of the declaration of an Alert or greater emergency classification to coordinate security-related activities and information with the emergency coordinator [station emergency manager]. The currently NRC-approved North Anna and Surry Emergency Plans state that the on-shift Security Team will maintain personnel accountability, site access control, and maintain liaison and communications with local law enforcement agencies in accordance with procedural guidelines or when directed by the station emergency manager.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to remove the Site Access Control and Personnel Accountability functional area from Table 5.1 of the North Anna and Surry Emergency Plans and revise to Emergency Administrative Director position to focus on security.

The revision to the Emergency Administrative Director includes changing the position title to Emergency Security Director, removing administrative responsibilities, and adding a responsibility to act as the liaison between site Security and the TSC while retaining responsibility to direct Security activities. Because the Dominion sites would continue to rely on on-shift staffing per site-specific Security Plans while maintaining an augmenting individual to

act as the liaison between site Security and the TSC while retaining responsibility to direct Security activities, the NRC staff determined the proposed changes are acceptable.

Dominion did not propose changes that would alter the on-shift or augmented minimum staff related to the security function. As such, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for security.

3.1.9 Repair Team Activities

The intent of the Repair Team Activities function is to provide support for emergency core cooling system (ECCS), event mitigation, and equipment repair. Dominion provided its analysis of Repair Team Activities in Section 3.2.5, Plant System Engineering, Repair and Corrective Actions Function [Engineering, Repair Team Activities], in Enclosure 1 of the LAR enclosure, for each of the sites.

NUREG-0654, Table B-1, does not include on-shift staffing and recommends that the following augmenting maintenance personnel should respond to the OSC to support Repair Team activities:

One electrician and one mechanic within 60 minutes of the declaration of an Alert or greater emergency classification to provide support for emergency core cooling system equipment, event mitigation, and equipment repair, and One I&C technician within 90 minutes of the declaration of an Alert or greater emergency classification to assist with logic manipulation, support event mitigation and equipment repair, and support digital I&C, if applicable.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion states that the current North Anna and Surry Emergency Plans identify one mechanic and one electrician normally being on shift on a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per day, 7 day per week basis with augmentation by one electrician and one I&C technician within 45 minutes and two mechanics, one electrician, and one I&C technician within 60 minutes of an Alert or greater emergency classification.

Dominion proposes to remove the on-shift maintenance positions and would have one mechanical technician and one electrical technician respond within 60 minutes of a declaration of an Alert or greater emergency classification. These resources report to the OSC and will act under the direction of the SEM until the OSC is activated. The maintenance response will obtain plant status information from the PCS and assess any equipment failures occurring during the event in order to initiate troubleshooting. Additionally, Dominion proposes to have one I&C technician respond within 90 minutes of a declaration of an Alert or greater emergency classification.

The current North Anna and Surry ECCS consists of a passive system of accumulators that do not require any external signals or source of power for their operation to cope with the short-term cooling requirements of large reactor coolant pipe breaks. Two independent pumping systems, each capable of the required emergency cooling, are provided for small-break protection and to keep the core submerged after the accumulators have discharged following a large break. Adequate design provisions ensure the performance of the required safety functions even with the loss of a single component, assuming the electric power is available from either the offsite or the onsite electric power sources.

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Additionally, North Anna and Surry employs onsite and offsite power systems that can independently supply the electric power required for the operation of safety-related systems.

Dominion states that crediting the robust ECCS capability and protection against single point failures provides the basis for removal of electrical and mechanical maintenance personnel from on shift.

The NRC staff finds the availability of on-shift operators with the knowledge, skills, and abilities, to perform all tasks that may be required to implement the North Anna and Surry abnormal operating procedures and emergency operating procedures, the redundant and diverse ECCS design, and the proposed augmenting maintenance personnel supports the proposed elimination of the on-shift repair team staffing and changes to the augmentation time for the OSC repair and corrective actions personnel. In addition, the NRC staff determined that with the proposed change the staffing requirements for the repair and corrective action personnel in the North Anna and Surry Emergency Plans would be consistent with the guidance in NUREG-0654, Table B-1.

Based on the above, the NRC staff has determined that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Repair and Corrective Actions function.

3.1.10 Supervision of Repair Team Activities

The Dominion provided its analysis of Supervision of Repair Team Activities in Section 3.2.5, Plant System Engineering, Repair and Corrective Actions Function, in Enclosure 1 of the LAR enclosure, for each of the sites.

NUREG-0654, Table B-1, recommends a lead OSC supervisor to staff the OSC within 60 minutes, with a mechanical supervisor, electrical supervisor, and I&C supervisor (who may be combined with the electrical supervisor) to staff the OSC within 90 minutes from the declaration of an Alert or greater emergency cl assification for supervision of repair team activities.

The current North Anna and Surry Emergency Plans identify one Electrical Coordinator, one Mechanical Coordinator, and one Instrument Coordinator (collectively, maintenance coordinators) who are not identified as positions necessary for facility activation on Figure 5.5.b Operational Support Center Organization. The current Table 5.1 does not include maintenance coordinators as augmented positions. As such, the current North Anna and Surry Emergency Plans do not have an augmentation time for the maintenance coordinators. In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to add one OSC Coordinator, one Electrical Coordinator, one Mechanical Coordinator, and one I&C [Instrument] Coordinator to Table 5.1 as required augmentation positions with a response time of 90 minutes of an Alert or greater emergency classification. Additionally, in its letter dated February 5, 2024, Dominion stated that it was revising the North Anna and Surry Emergency Plans to reflect one electrician and one mechanic responding to the site within 60 minutes of an Alert or greater classification. These resources report to the OSC and will act under the direction of the SEM until the OSC is activated; therefore, it is not necessary for the lead OSC supervisor to staff the OSC within 60 minutes as provided in the guidance of NUREG-0654, Table B-1. Also, the proposed North Anna and Surry Emergency Plans would include the maintenance coordinators as required positions within 90 minutes of an Alert or greater emergency cl assification, consistent with NUREG-0654,

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Revision 2. Therefore, the NRC staff finds the proposed changes to the Supervision of Repair Team Activities functional area acceptable.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for supervision of Repair Team activities.

3.1.11 Field Monitoring Teams

Dominion provided its analysis for the field monitoring teams in Section 3.2.4, Radiological Accident Assessment and Support of Operat ional Accident Assessment Function (Dose Assessments/Projections, Field Monitoring Teams, Radiation Protection), in the LAR enclosures for North Anna and Surry.

NUREG-0654, Table B-1, recommends one onsite field monitoring team (FMT) and two offsite FMTs as minimum staff. Each FMT would consist of one driver and one qualified individual (i.e., field monitor) to assess the area for radiation and contamination. The field monitors for the offsite FMTs would also provide radioactive plume tracking. The onsite FMT and one offsite FMT are recommended to be staffed within 60 minutes and the second offsite FMT is recommended to be staffed within 90 minutes from the declaration of an Alert or greater emergency classification.

Currently, Dominion has one dedicated on-site RP technician, or other trained personnel, available to perform offsite and onsite (out-of-plant) surveys. Dominion currently has one offsite FMT leader and one FMT team member respond within 45 minutes with one additional offsite FMT leader and one FMT team member respond within 60 minutes of a declaration of an Alert or greater emergency classification. In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to extend the offsite FMT response to within 90 minutes of a declaration of an Alert or greater emergency classification.

The proposed North Anna and Surry Emergency Plans would have three on-site RP technicians. Additionally, Dominion would have two offsite FMTs respond within 90 minutes of a declaration of an Alert or greater emergency classi fication. Additionally, the LAR specifies that the performance of Onsite (out-of-plant) Survey is the area between site buildings and the Protected Area (PA) fence. Because the proposed North Anna and Surry Emergency Plans has on-shift capability to perform on-site (out-of-plant) surveys as a means of early identification of releases and provide data inputs to dose assessment, with augmentation by two FMTs within 90 minutes of a declaration of an Alert or greater emergency classification, the NRC finds the proposed changes to the field monitoring are acceptable.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for field monitoring.

3.1.12 Media Information

The purpose of the function of providing information to the media is to manage and coordinate information related to the event.

NUREG-0654, Table B-1, recommends that JIC staff address media inquiries within 60 minutes

of the declaration of an Alert or greater emergency classification but notes that this function does not need to be performed at the TSC or OSC. The NUREG-0654 Table B-1 further recommends additional staff to perform JIC-related tasks within 60 minutes of the declaration of a Site Area Emergency or greater emergency cl assification. For the JIC, the NUREG-0654, Table B-1, notes: Emergency response facility activation timing is not the concern; it is whether the facility staff is performing the stated func tion(s) within the time specified. NUREG-0654, Table B-1, does not specify an on-shift capability and does not identify specific staff positions for the minimum staff.

The current North Anna and Surry Emergency Plans have a Chief Technical Spokesperson available within 75 minutes of a declaration of an Alert or greater emergency classification. The Chief Technical Spokesperson reports to the Corporate Response Manager. The JIC is currently staffed in accordance with the Commonwealth of Virginia Radiological Emergency Response Plan.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposes to replace the term activated for the JIC with staffed as there are no command-and-control functions associated with these facilities. Because NUREG-0654, Table B-1, does not specify an on-shift capability and does not identify specific staff positions for the minimum staff, the NRC staff finds the proposed change acceptable.

In its letter dated November 7, 2022, Dominion states that one of the changes to this functional area is the removal of reference to the LMC. It further states,

The location will continue to be available as the Near-Site Location for Offsite Agency Coordination, as described in Section 7.1.7 of the North Anna Emergency Plan, and public information will continue to be issued from the JIC.

Because the function will continue to be perform ed at the Near-Site Location for Offsite Agency Coordination, the NRC staff finds the proposed change to be a non-substantive change and is, therefore, acceptable.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for media information.

3.1.13 Information Technology

The purpose of the information technology (IT) function is to provide support for computer-based equipment if relied upon to perform emergency plan functions.

NUREG-0654, Table B-1, states that IT staff is only required to be described in the emergency plan if critical digital assets are identified per 10 CFR 73.54 [Protection of digital computer and communication systems and networks]. NUREG-0654, Table B-1, recommends an IT lead staff the TSC within 90 minutes of the declaration of an Alert or greater emergency classification and that another IT lead staff the CERC/JIC within 60 minutes of the declaration of a Site Area Emergency or General Emergency classification.

The current North Anna and Surry Table 5.1 do not include IT personnel; however, the current North Anna and Surry Emergency Plans state that the Resource Support Team will provide

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logistical and administrative support, including development of long-term staffing plans and acquiring supplemental staff as appropriate (e.g., Telecommunications, Information Technology, etc.). Dominion is not proposing a change to the Information Technology Function.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for information technology.

3.1.14 Plant Operations and Assessment of Operational Aspects

NUREG-0654, Table B-1, does not include the Plant Operations and Assessment of Operational Aspects Function. Note viii to the NUREG-0654, Table B-1, further states, The number of operations staff, security force staff, or fire brigade staff on-shift is controlled by the site-specific Technical Specifications or other licensing documents.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to remove the Plant Operations and Assessment of Operational Aspects Function from the North Anna and Surry Emergency Plans. Dominion stated in Section 3.2.1, Plant Operations and Assessment of Operational Aspects, that in the proposed change, only Operations personnel performing EP functions of Classification, Notification, Core Damage Assessment, and on-shift ERO oversight are included in Table 5.1. On-shift staffing of operations personnel is maintained under documents outside of the Emergency Plan. Since operations staffing is controlled by site-specific documents, the NRC staff has determined that the proposed change is acceptable.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.

3.1.15 Firefighting Function

NUREG-0654 Table B-1 does not include the Plant Operations and Assessment of Operational Aspects Function. Note viii to the NUREG-0654 Table B-1 further states, The number of operations staff, security force staff, or fire brigade staff on-shift is controlled by the site-specific Technical Specifications or other licensing documents.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to remove the Fire Fighting function from the North Anna and Surry Emergency Plans. Dominion stated in Section 3.2.7, Firefighting Function (Not Applicable), that the proposed change removes the reference to the Firefighting function in Table 5.1 as this is addressed under the North Anna and Surry Technical Requirements Manuals. The NRC staff has determined that the proposed change is acceptable because the Fire Fighting function is not i dentified as a functional area in the NUREG-0654 Table B-1 and is controlled by the other licensing documents.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.

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3.1.16 Rescue Operations and First Aid Function

NUREG-0654, Table B-1, does not include the Plant Operations and Assessment of Operational Aspects Function. Note viii to the NUREG-0654 Table B-1 further states, The number of operations staff, security force staff, or fire brigade staff on-shift is controlled by the site-specific Technical Specifications or other licensing documents.

In its letter dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, Dominion proposed to remove the Rescue Operations and First Aid function from the North Anna and Surry Emergency Plans. Dominion stated in Section 3.2.8, Rescue Operations and First Aid Function (Not Applicable), in the November 7, 2022, that the proposed change removes the reference to the Rescue Operations and First Aid function in Table 5.1 as this is a responsibility of the Fire Brigade and is maintained in accordance with the site Fire Protection Plan. The NRC staff has determined that the proposed change is acceptable because the Rescue Operations and First Aid function is not identified as a functional area in the NUREG-06 54, Table B-1, and is controlled by the other licensing documents.

Based on the above, the NRC staff concludes that the proposed North Anna and Surry Emergency Plans will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.

3.2 Summary

The NRC staff performed a technical and regulator y review of the proposed changes to the North Anna and Surry Emergency Plans. Based on this review, the NRC staff finds that the North Anna and Surry Emergency Plans, as changed, continues to meet the planning standards of 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 and provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Therefore, the NRC sta ff concludes that the proposed North Anna and Surry Emergency Plans changes, as described in the application dated November 7, 2022, as supplemented by letters dated March 30, 2023, October 12, 2023, and February 5, 2024, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Commonwealth of Virginia official was notified of the proposed issuance of the amendments on March 5, 2024. On March 5, 2024, the State official confirmed that the Commonwealth of Virginia had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change administrative procedures or requ irements relating to the licensee's organization and management. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10)(ii). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

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6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, 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) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Letter from J. E. Holloway, Virginia Electric and Power Company, to U.S. Nuclear Regulatory Commission, Virginia Electric and Power Company (Dominion Energy Virginia), North Anna Units 1 and 2, Surry Power Station Units 1 and 2, Pr oposed License Amendment Request to Revise Emergency Plan Staff Augmentation Times, dated November 7, 2022 (Agencywide Docu ments Access and Management System (ADAMS) Accession No. ML22312A550).

2. Letter from J. E. Holloway, Virginia Electric and Power Co mpany, to U.S. Nuclear Regulatory Commission, Virginia Electric and Power Company (Dominion Energy Virginia), North Anna Units 1 and 2, Surry Power Station Units 1 and 2, Response to Request for Additional Information Regarding Proposed License Amendment Request to Revise Emergency Plan Staff Augmentation Times, dated March 30, 2023 (ML23089A354).

3. Letter from J. E. Holloway, Virginia Electric and Power Company, to U.S. Nuclear Regulatory Commission, Virginia Electric and Power Comp any (Dominion Energy Virginia), North Anna Units 1 and 2, Surry Power Station Units 1 and 2, Response to Second Request for Additional Infor mation Regarding Proposed License Amendmen t Request to Revise Emergency Plan Staff Augmentation Times, dated October 12, 20 23 (ML23285A066).

4. Letter from J. E. Holloway, Virginia Electric and Power Company, to U.S. Nuclear Regulatory Commission, Virginia Electric and Power Company (Dominion Energy Virginia), North Anna Power Station, Units 1 and 2, and Surry Power Station, Units 1 and 2, Supplemental Response to Second Request for Additional Information Regarding Proposed License Request to Revise Emergency Plan Staff Augmentation Times, dated February 5, 2024 (ML24036A318).

5. U.S. Nuclear Regulatory Commission, Regulatory Guide (RG) 1.101, Revision 6, Emergency Response Planning and Preparedness for Nuclear Power Reactors, Ju ne 2021 (ML21111A090).

6. U.S. Nuclear Regulatory Commission, NUREG-0654/FEMA-REP-1, Re vision 2, Criteria for Preparation and Evaluation of Radiologica l Emergency Response Plan s and Preparedness in Support of Nuclear Power Plants, December2019 (ML19347D139).

7. U.S. Nuclear Regulatory Commission, NSIR/DPR-ISG-01, Revision 0, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, November2011 (ML113010523).

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8. Nuclear Energy Institute, NEI 10-05, Revision 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, June 2011 (ML111751698).

9. U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (ML16124A002).

Principal Contributor: M. Norris R. Hoffman

Date: April 22, 2024

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