ML24158A388
| ML24158A388 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/31/2024 |
| From: | Bryant J, Geoffrey Miller Plant Licensing Branch II |
| To: | Carr E South Carolina Electric & Gas Co |
| Miller, GE | |
| References | |
| EPID L-2023-LLA-0083 | |
| Download: ML24158A388 (1) | |
Text
July 31, 2024
Eric S. Carr Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd.
Glen Allen, VA 23060-6711
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 ISSUANCE OF AMENDMENT NO. 226 TO CHANGE EMERGENCY PLAN STAFF AUGMENTATION TIMES AND RELOCATE THE EMERGENCY OPERATIONS FACILITY (EPID L-2023-LLA-0083)
Dear Eric Carr:
The U.S. Nuclear Regulatory Commission (NRC, or the Commission) has issued the enclosed Amendment No. 226 to Renewed Facility Operating License No. NPF-12 for the Virgil C.
Summer Nuclear Station, Unit 1. The amendment revises the license in response to your application dated June 8, 2023 (Agencywide Docu ments Access and Management System (ADAMS) Accession No. ML23159A233), as supplemented by letters dated October 31, 2023 (ML23304A257), March 26, 2024 (ML24087A218), and May 20, 2024 (ML24141A282).
The amendment revises the Virgil C. Summer Nuclear Station Emergency Plan to change the staff augmentation times and relocate the emergency operations facility as described in its submittal and associated supplements.
E. Carr
A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
G. Edward Miller, Project Manager Plant Licensing Branch II-I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket No. 50-395
Enclosures:
- 1. Amendment No. 226 to NPF-12
- 2. Safety Evaluation
cc: Listserv
DOMINION ENERGY SOUTH CAROLINA, INC.
SOUTH CAROLINA PUBLIC SERVICE AUTHORITY
DOCKET NO. 50-395
VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1
AMENDMENT TO RENEWED FACI LITY OPERATING LICENSE
Amendment No. 226 Renewed License No. NPF-12
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment to the Virgil C. Summer Nuclear Station, Unit No. 1 (the facility), Renewed Facility Operating License No. NPF-12, filed by the Dominion Energy South Carolina, Inc. (the licensee), dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations 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 public health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations as set forth in 10 CFR Chapter I;
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
- 2. Accordingly, by Amendment No. 226, Renewed Facility Operating License No. NPF-12 is hereby amended to authorize revision to the Emergency Plan for the Virgil C. Summer Nuclear Station, Unit No. 1, as set forth in the Dominion Energy South Carolina application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024.
- 3. This license amendment is effective as of its date of issuance and shall be implemented no later than February 28, 2025.
FOR THE NUCLEAR REGULATORY COMMISSION
Andrea D. Veil, Director Office of Nuclear Reactor Regulation
Date of Issuance: July 31, 2024
VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1
ATTACHMENT TO LICENSE AMENDMENT NO. 226
RENEWED FACILITY OPERATING LICENSE NO. NPF-12
DOCKET NO. 50-395
Replace the following pages of the renewed facility operating license with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Page Insert Page
License License Page 3 Page 3
Technical Specifications Technical Specifications N/A N/A
(3) DESC, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage amounts required for reactor operation, as described in the Final Safety Analysis Report, as amended through Amendment No. 33;
(4) DESC, pursuant to the Act and 10 CFR Part 30, 40 and 70 to receive, possess and use at any time byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed neutron sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;
(5) DESC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, 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 of components; and
(6) DESC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as m[a]y 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 C ommissions regulations set forth 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 the additional conditions specified or incorporated below:
(1) Maximum Power Level
DESC is authorized to o perate the facility at reactor core power levels not in excess of 2900 megawatts thermal in accordance with the conditions specified herein and in Attachment 1 to this renewed license.
The preoccupation tests, startup tests and other items identified in Attachment 1 to this renewed license shall be completed as specified.
Attachment 1 is hereby incorporated into this renewed license.
(2) Technical Specifications and Environmental Protection Plant
The Technical Specifications contained in Appendix A, as revised through Amendment No. 226, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. Dominion Energy South Carolina, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
Renewed Facility Operating License No. NPF-12 Amendment No. 226 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO. 226 TO
RENEWED FACILITY OPERATING LICENSE NO. NPF-12
DOMINION ENERGY SOUTH CAROLINA, INC.
VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1
DOCKET NO. 50-395
1.0 INTRODUCTION
By application dated June 8, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23159A233), as supplemented by letters dated October 31, 2023 (ML23304A257), March 26, 2024 (ML24087A218), and May 20, 2024 (ML24141A282),
Dominion Energy South Carolina (DESC) 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 the changes to the Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Emergency Plan. DESC proposes the following changes:
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 to 90 minutes; Reorganization of Table B-1a staffing based on emergency preparedness functions to align to NUREG-0654, Revision 2 (ML19347D139), Table B-1 guidance; Reduction of the emergency classification level at which the Offsite Survey Teams are dispatched from a Site Area Emergency to an Alert; Removal of references to activities managed by processes outside of the VCSNS Emergency Plan; Relocation of administrative positions from the VCSNS Emergency Plan to implementing procedures; and Adding a definition for facility activation criteria, redefining minimum staff positions, and updating generic ERO staff position titles.
DESC also proposes to relocate the existing VCSNS Emergency Operations Facility (EOF), and Joint Information Center (JIC) to the Dominion Energy Corporate Emergency Response Center (CERC) located in Glen Allen, Virginia. Prior Nu clear Regulatory Commission (NRC) approval is
Enclosure 2
needed before locating an EOF greater than 25 miles from a nuclear power reactor site pursuant to 10 CFR Part 50, Appendix E, Section IV.E.8.b.
In its LAR letter dated June 8, 2023, the licensee states that:
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.
The supplemental letters dated October 31, 2023, March 26, 2024, and May 20, 2024, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on September 5, 2023 (88 FR 60717).
2.0 REGULATORY EVALUATION
The NRC staff considered the following regulator y requirements and guidanc e 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. Regulations applicable to the changes requested include:
The regulations in 10 CFR 50.47(b)(1), state, 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.
The regulations in 10 CFR 50.47(b)(2), state, 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 offsite support and response activities are specified.
The regulations in 10 CFR 50.47(b)(3), state, Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.
The regulations in 10 CFR 50.47(b)(6), state, Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.
The regulations in 10 CFR 50.47(b)(7), state, in part, the principal points of contact with the news media for dissemination of information during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established.
The regulations in 10 CFR 50.47(b)(8), state, Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
The regulations in 10 CFR 50.47(b)(9), state, Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
The regulations in 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV.A, Organization, state, in part, The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization[.]
Paragraph IV.E.8.a(i) of Appendix E to 10 CFR Part 50, specifies the requirement for 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.
Paragraph IV.E.8.b of Appendix E to 10 CFR Part 50 states, in part:
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 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[.]
Paragraph IV.E.8.c of Appendix E of 10 CFR Part 50 establishes the minimum capabilities for an EOF.
2.2 Guidance
Regulatory Guide (RG) 1.101, Revision 6, Emergency Planning and Preparedness for Nuclear Power Reactors, June 2021 (ML21111A090), 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, which provides specific acceptable criteria for complying with the planning standards set forth in 10 CFR 50.47.
NUREG-0654, Revision 2, Evaluation Criteria II.B, Emergency Response Organization addresses planning standard 10 CFR 50.47(b)(2). Evaluation Criterion II.B.1.a states, in part, The site-specific emergency response organization (ERO) is developed. Evaluation Criterion II.B.2.a states, The functional responsibilities assigned to the ERO are established and the responsibilities that may not be delegated to other members of the ERO are clearly specified in the emergency plan. 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 (ML113010523), 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 (ML111751698), 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.
Regulatory Issue Summary 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (ML16124A002), 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.
NUREG-0696, Functional Criteria for Emergency Response Facilities, February 1981 (ML051390358) describes the facilities and system s to be used by nuclear power plant licensees to improve responses to emergencies.
NUREG-0737, Supplement 1, Clarification of TMI [Three Mile Island] Action Plan Requirements - Requirements for Emergency Response Capability, January 1983 (ML102560009) provided additional clarification for emergency response facilities.
3.0 TECHNICAL EVALUATION
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC provided justifications for the proposed VCSNS Emergency Plan changes. The NRC staffs technical evaluation of the proposed changes is detailed below.
For this safety evaluation the terms Radiation Protection (RP) and Health Physics (HP) are used interchangeably.
3.1 Major Functional Areas
The current VCSNS Emergency Plan describes the ERO as consisting of personnel staffing in the following emergency response facilities:
Control Room, TSC, OSC, EOF, and Joint Information Center (JIC).
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 (SM) 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, Emergency Direction and Control (Command and Control, Emergency Classification), in LAR Attachment 1, Description and Assessment, for VCSNS.
NUREG-0654, Table B-1 recommends that the TSC be staffed with an Emergency Coordinator within 60 minutes of an Alert or greater emergency classification level and an Emergency Director in the EOF within 60 minutes of declaring a Site Area Emergency or greater emergency classification level.
The current VCSNS Emergency Plan staffing for Command and Control is consistent with the NUREG-0654 Table B-1. The current VCSNS Emergency Plan provides one Emergency Coordinator and one Classification Advisor within 60 minutes of an Alert or greater emergency classification level. The current VCSNS Emergency Plan provides Command and Control augmentation at the TSC within 60 minutes of an Alert or greater emergency classification level
and at the EOF within 60 minutes of a Site Ar ea Emergency or greater emergency classification level.
DESC has proposed to relocate the existing VCSNS EOF to the Dominion Energy Corporate Emergency Response Center (CERC) located in Glen Allen, Virginia. Additionally, DESC proposed to change the activation time of the VCSNS EOF from within 60 minutes from the declaration of a Site Area Emergency or greater emergency classification level to activation of the Dominion Energy CERC within 90 minutes of an Alert or greater emergency classification level.
Based on the assumed reactor accident sequence progression, activating within 90 minutes of the Alert classification should generally be more timely than activating within 60 minutes of a Site Area Emergency classification. Therefore, t he NRC finds that activation of the CERC within 90 minutes from an Alert or greater emer gency classification level is acceptable.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to extend the ERO augmentation time for the Command and Control function in the TSC from within 60 minutes to within 90 minutes of an Alert or greater emergency classification level. DESC further proposed to change the ERO augmentation time for the Command and Control function in the EOF from within 60 minutes of a Site Area Emergency or greater classification level to (in the CERC) within 90 minutes of an Alert or greater emergency classification level. As stated above, DESC proposed to move the EOF functions to the CERC. The licensee stated that on-shift staffing includes an SM that assumes the duties of Interim Emergency Director and is responsible for emergency response efforts until relieved.
DESC proposes to revise the title of Interim Emergency Director to Interim Station Emergency Manager (ISEM) to align with Dominion standard ERO titles and maintains event classification as a responsibility of this position. The SM/ISEM also has responsibility for staffing of the TSC and OSC at an Alert or greater emergency classification level. The proposed change extends the response time for the TSC Station Emergency Manager from within 60 minutes to within 90 minutes of an Alert or greater emergency cla ssification level. DESC further proposes to change the Technical Support Manager response time in the EOF from within 60 minutes of a Site Area Emergency or greater classification level to (in the CERC) within 90 minutes of an Alert or greater emergency classification level. The proposed change extends the timeframe for relief for the SM/ISEM for the event classification function by 30 minutes by assigning support for the SM/ISEM for performing classifications by the Shift Technical Advisor (STA) position.
The NRC staff finds that the support provided by the STA in performing the event classification function reduces the burden of the SM/ISEM for event classifications and changes the response times for augmentation (1) by the TSC Station Emergency Manager from within 60 minutes to within 90 minutes of an Alert or greater emergency classification level and (2) by the Technical Support Manager in the EOF from within 60 minutes of a Site Area Emergency or greater classification level to (in the CERC) within 90 minutes of an Alert or greater emergency classification level.
DESC proposes to staff the Dose Assessment Team Leader position within 60 minutes of an Alert or greater emergency classification level. The Dose Assessment Team Leader serves in a support role for on-shift staff performing dose assessment, and oversight of on-shift and augmented 60-minute RP Technicians. The RP Supervision and dose assessment functions are discussed in Sections 3.1.4 and 3.1.5 of this safety evaluation. DESC also proposes to staff the
OSC Director position within 60 minutes of an Alert or greater emergency classification level.
The OSC Director will provide oversight of the 60-minute Mechanical and Electrical Maintenance responders. The supervision of repair team activities are discussed in Section 3.1.10 of this safety evaluation. DESC states that these positions will provide additional support to the SM/ISEM during the period between 60 and 90 minutes after an event, until augmented by the TSC Station Emergency Manager and Technical Support Manager in the CERC.
The NRC staff finds that the augmentation of the Dose Assessment Team Leader and OSC Director within 60 minutes of an Alert or greater emergency classification level provides additional support to the SM/ISEM and reduces the Command and Control burden through providing oversight of maintenance and RP personnel and being able to provide recommendations to the SM/ISEM. Therefore, this allows for the change in augmentation times (1) for the TSC Station Emergency Manager from within 60 minutes to within 90 minutes of an Alert or greater emergency classification level and (2) for the Technical Support Manager in the EOF from within 60 minutes of a Site Area Emergency or greater classification level to (in the CERC) within 90 minutes of an Alert or greater emergency classification level due to the reduced burden on the SM/ISEM.
Based on the above, the NRC staff has determined that the proposed VCSNS Emergency Plan meets 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.
3.1.2 Communications
The purpose of the Communications function is to communicate EAL and PAR classifications to offsite response organizations (OROs) and the NRC, until relieved. The licensee provided its analysis of the communications function in Section 3.3, Notification/Communication Function,
in the LAR Attachment 1 for VCSNS.
NUREG-0654, Table B-1 recommends that the TSC be staffed with two communicators within 60 minutes of an Alert or greater emergency classification level and an additional communicator, as needed, within 90 minutes of an Alert or greater emergency classification level. In addition, NUREG-0654, Table B-1 recommends the staffing of one communicator in the EOF within 60 minutes of declaring a Site Area Emergency or greater emergency classification level.
The current DESC staffing for the Communications function is consistent with the NUREG-0654, Table B-1 with two differences. The first difference is that the current VCSNS Emergency Plan provides one dedicated on-shift communicator instead of one on-shift communicator that may be assigned other duties in Table B-1. The second difference is that the on-shift communicator is augmented by one responder at 30 minutes and four additional responders at 60 minutes from an Alert or greater emergency classification level.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to maintain the on-shift dedicated communicator for performance of State/local and Federal notification functions, and augmented support by the NRC Emergency Communicator in the control room at 60 minutes, and one State/local Communicator in the TSC and one in the CERC at 90 minutes, from an Alert or greater emergency classification level, respectively. 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 minutes from an Alert or greater emergency classification level. DESC further proposed an augmentation time for the State/local Communicator in the CERC to within 90 minutes of an Alert or greater emergency classification level.
As discussed previously in Section 3.1.1 of th is SE, the NRC finds that activation of the CERC within 90 minutes from an Alert or greater emergency classification level is acceptable.
The proposed VCSNS Emergency Plans will continue to provide one dedicated on-shift communicator with augmentation by one communicator reporting to the control room at 60 minutes and then transitioning to the TSC within 90 minutes an Alert or greater emergency classification level. The VCSNS Emergency Plans include additional augmentation by one communicator reporting to the TSC within 90 minutes and one communicator reporting to the CERC within 90 minutes of an Alert or greater emergency classification level, respectively.
Although the current VCSNS Emergency plan provides for the communications capability that is greater than the guidance of NUREG-0654, Table B-1, the proposed VCSNS Emergency Plan provides two communicators within 60 minutes of an Alert or greater emergency classification level in the control room and an additional two communicators (one in the TSC and one in CERC) within 90 minutes of an Alert or great er emergency classification. The purpose of the communications is effective emergency response because licensees must be able to adequately communicate onsite and offsite to su ccessfully implement their emergency plans.
This function should consist of two staff members to fulfill the communication needs, at a minimum: one for the NRC and one for State and local notifications and status updates. Based on the licensee having a dedicated on shift communicator with augmentation by one communicator at 60 minutes (reporting to the control room at 60 minutes and then transitioning to the TSC within 90 minutes of an Alert or greater emergency classification level) and the additional augmentation by one communicator reporting to the TSC within 90 minutes and one communicator reporting to the CERC within 90 minutes of an Alert or greater emergency classification level, respectively, the NRC sta ff finds the proposed changes to the augmentation response times of the TSC and CERC communicators acceptable.
Based on the above, the NRC staff concludes that the proposed VCSNS 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 RP function 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.
DESC provided its analysis of the RP Function in Section 3.4, Radiological Accident and Support of Operational Accident Assessments Function (Dose Assessments/Projections, Field Monitoring Teams, Radiation Protection ), and in Section 3.6, Protective Actions (In-Plant)
Function, in the LAR Attachment 1 for VCSNS.
NUREG-0654, Table B-1 recommends one reactor protection (RP) Technician per unit for a multi-unit site and three additional RP Technicians within 60 minutes of the declaration of an Alert or greater emergency classification level and three additional RP Technicians within 90 minutes of an Alert or greater emergency classification level.
The current VCSNS staffing for the RP function is consistent with the NUREG-0654 Table B-1 with two differences. The first difference is that the current VCSNS Emergency Plan has one 30-minute augmented responder responsible for performance of in-plant surveys. The second difference is that VCSNS has two 30-minute augmented responders responsible for in-plant protective actions from the declaration of an Alert or greater emergency classification level.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to maintain two dedicated on-shift RP technicians, and augment with three RP Technicians at 60 minutes and three additional RP Technicians at 90 minutes from the declaration of an Alert or greater emergency classification level.
In its letter dated March 26, 2024, DESC stated that it proposes to revise Table B-1a
[Staffing Requirements for the VCSNS ERO ] of the VCSNS Emergency Plan to indicate that personnel providing ln-plant/Onsite (out-of-plant) surveys and protective actions are RP Technicians. DESC further states that one RP Technician is responsible for monitoring in-plant radiological conditions until augmented at 60 mi nutes from an Alert or greater emergency classification level. Electronic monitoring capability of radiological conditions in a large portion of the plant has eliminated the need for general area in-plant surveys. The second on-shift RP Technician provides job coverage, dose monitoring and radiation monitoring for in-plant workers for 60 minutes from an Alert or greater emergency classification level until augmented by additional RP Technicians.
Because the proposed VCSNS Emergency Plan will continue to provide two RP Technicians on-shift with augmentation by three RP Technicians at 60 minutes and three RP Technicians within 90 minutes from an Alert or greater emergency classification level, respectively, consistent with the guidance of NUREG-0654, Table B-1, the NRC staff finds the proposed changes to the VCSNS Emergency Plan acceptable.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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. DESC provided its analysis of the Supervision of Radiation Protection Staff and Site Radiation Protection Function in Section 3.4, in the LAR Attachment 1 for VCSNS.
NUREG-0654 Table B-1 recommends that the supervision of RP function be augmented by a Site RP Coordinator in the TSC within 60 minutes of the declaration of an Alert or greater emergency classification level, and by a RP Manager in the EOF within 60 minutes of the declaration of a Site Area Emergency or greater emergency classification level.
The current DESC staffing for the RP function, which includes RP supervision, is consistent with the NUREG-0654 Table B-1. The current VCSNS Emergency Plan has a Radiological
Assessment Supervisor position augmenting in the TSC for the RP supervisory task within 60 minutes from an Alert or greater emergency classification level and an Offsite Radiological Monitoring Coordinator augmenting within 60 minutes of a Site Area Emergency or greater classification level in the EOF.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to revise the title of the Radiological Assessment Supervisor to Radiological Asse ssment Director and extend the augmentation response time to within 90 minutes of a declaration of an Alert or greater emergency classification level at the TSC. Additionally, DESC proposed to revise the title of Offsite Radiological Monitoring Coordinator to Radiol ogical Assessment Coordinator reporting to the CERC and change the augmentation response time to within 90 minutes from an Alert or greater emergency classification level. The Radiological Assessment Director is responsible for supervising the activities of the onsite radiological assessments and directs the staff in determining the extent and nature of radiological or hazardous material problems onsite. The Radiological Assessment Coordinator is responsible for directing field team radio operator activities; dispatching Offsite Field Team members, as necessary; tracking the dose of Offsite Field Team members; projecting offsite doses; obtaining weather forecasts, as necessary; comparing offsite survey data with offsite dos e projections; formulating protective action recommendations (PARs); briefing the CERC staff and federal/state counterparts on radiological conditions and PARs; and tracking the plume.
The proposed VCSNS Emergency Plan includes a Dose Assessment Team Leader that would respond to the TSC within 60 minutes of an Alert or greater emergency classification level.
DESC proposed that the Dose Assessment Team Leader serve in a support role for on-shift staff performing dose assessment, PAR and exposure control and provide oversight of RP Technicians on shift and responding at 60 minutes from an Alert or greater emergency classification level, until the Radiological Assessment Director responds within 90 minutes at the TSC and the Radiological Assessment Coordinator who would respond to the CERC within 90 minutes from an Alert or greater emergency classification level.
The proposed VCSNS Emergency Plan described above will continue to provide adequate oversight for the on shift and augmenting RP Technicians at 60 minutes from an Alert or greater emergency classification level for the TSC, consistent with the guidance of NUREG-0654, Table B-1. Further, those licensee personnel who are there at 60 minutes will be able to provide adequate supervision of RP staff until the 90 minute responders arrive. Finally, as discussed previously in Section 3.1.1 of this SE, t he NRC finds that activation of the CERC within 90 minutes from an Alert or greater emergency cla ssification level is acceptable. Therefore, the NRC staff finds the proposed changes to the VCSNS Emergency Plan acceptable.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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 applicable PAR decision-maker until relieved.
DESC provided its analysis of the dose assessment s/projections function in Section 3.4 in the LAR Attachment 1 for VCSNS.
NUREG-0654 Table B-1 recommends a dose assessment/projection staff member 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 dose assessment/projection staff member be augmented by a dose assessment/projection staff member in the TSC within 60 minutes of the declaration of an Alert or greater emergency classification level and a dose assessment/projection staff member in the EOF within 60 minutes of the declaration of a Site Area Emergency or greater emergency classification level.
The current DESC staffing for the Dose Assessment function is consistent with the NUREG-0654 Table B-1 with two differences. The current VCSNS Emergency Plan augments the on-shift dose assessment with one additional responder at 30 minutes from the declaration of an Alert or greater emergency classification le vel. The second difference is that the current VCSNS Emergency Plan augments the dose asse ssment with two additional dose assessment positions at 60 minutes in the EOF from the declaration of a Site Area Emergency or greater emergency classification level.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to maintain responsibility for the on-shift dose assessment function as an ancillary duty of an RP Technician. The proposed change extends the augmentation response time from 30 minutes to 60 minutes for the Dose Assessment Team Leader and extends the response time from within 60 minutes of a Site Area Emergency or greater classification level to within 90 minutes of an Alert or greater emergency classification level for the other dose assessment positions. The Dose Assessment Team Lead serves in a support role for on-shift staff performing dose assessment and providing oversight of RP Technicians responding at 60-minutes.
DESC states that it uses the Meteorologi cal Information and Dose Assessment System (MIDAS-NU) for dose assessment. 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. DESC concludes that these improvements provide additional support for extending performance of this function by the on-shift dose assessor by 30 minutes.
As discussed previously in Section 3.1.1 of th is SE, the NRC finds that activation of the CERC within 90 minutes from an Alert or greater emergency classification level is acceptable.
Because the proposed VCSNS Emergency Plan will continue to provide the capability to perform dose assessment on shift with augmentation by the Dose Assessment Team Leader serving in a support role for on-shift staff performing dose assessment at 60 minutes from an Alert or greater emergency classification leve l consistent with the guidance of NUREG-0654, Table B-1, the NRC staff finds the proposed changes to the VCSNS Emergency Plan acceptable.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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 re lieved. DESC provided its analysis of the emergency classifications function in Section 3.2, Emergency Direction and Control (Command and Control, Emergency Classification), in the LAR Attachment 1 for VCSNS.
NUREG-0654 Table B-1 recommends an emergency cl assification 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 level.
The current DESC staffing for the emergency classification function is consistent with NUREG-0654 Table B-1. The current VCSNS Emergency Plan augments the on-shift emergency classification function performed by the SM/ISEM with one Emergency Director at 60 minutes from the declaration of an Alert or greater emergency classification level.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to extend the ERO augmentation response times for the emergency classification function from 60 minutes to 90 minutes. As proposed, the VCSNS Emergency Plan would continue to have the Shift Manager perform the Emergency Classifications Function until relieved by the Emergency Director retitled as the Station Emergency Manager at the TSC.
The proposed change extends the timeframe for ev ent classification by the SM/ISEM by 30 minutes. DESC states that the 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 providin g 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.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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. DESC provided its analysis of the engineering function in Section 3.5, Plant System Engineering, Repair and Corrective Actions Function, in the LAR for VCSNS.
NUREG-0654 Table B-1 recommends 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 level. The core/thermal-hydraulics engineer on-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.
The current DESC staffing for the engineering function is consistent with NUREG-0654 Table B-1 with one difference. The current VCSNS Emergency Plan augments the on-shift STA with one additional Core Engineer position at 30 minutes from the declaration of an Alert or greater emergency classification level.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to maintain performance of the core/thermal hydraulics function as the responsibility of the STA on-shift, and extend the augmentation response time of the TSC engineering staff from the current 30 minutes to within 90 minutes, and for the Core Engineer, and the Electrical and Mechanical Engineers from 60 to within 90 minutes, of a declaration of an Alert or greater emergency classification level. To ensure continued performance of the Core Damage Assessment function for the first 90 minutes after the declaration of an Alert or greater emergency classification level, 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.
DESC proposes to revise Table B-1a of t he current VCSNS Emergency Plan to reflect one electrician and one mechanic responding to the site within 60-minutes of an alert or greater emergency classification level and an OSC Director to provide oversight. These positions will provide additional support to the SM/ISEM during the period between 60 and 90 minutes until augmented by the TSC Station Emergency Manager and the Technical Support Manager in the CERC. The maintenance responders can obtain plant status information from the plant computer system (PCS) and assess any equipment failures occurring during the event to initiate troubleshooting.
The overall process performed by the various involved departments can be summarized as:
- 1. Operations provides initial assessment and gathering of information;
- 2. Maintenance, using the data provided by Operations and working with input from Engineering, as needed, initiates recovery/repair plans for restoration; and
- 3. If the initial maintenance actions are unsuccessful in identifying and resolving the cause of the equipment malfunction, then full engagement from Engineering and a more formal troubleshooting process is entered.
The NRC staff finds 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 with oversight from the OSC Director 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 VCSNS Emergency Plan 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 Site Access Control and Personnel Accountability
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 that the number of staff from operations, security force staff, or fire brigade staff on shift is controlled by the site-specific Technical Specifications or other licensing documents. DESC provided its analysis of the Security function in Section 3.9, Site Access Control and Personnel Accountability Function, in the LAR Attachment 1 for VCSNS.
NUREG-0654 Table B-1 recommends the on-shift securi ty function to be provided by security staffing per the site-specific security plan. The on-shift security staffing is augmented by a security liaison in the TSC within 60 minutes of the declaration of an Alert or greater emergency classification level to coordinate security-related activities and information with the emergency coordinator [station emergency manager].
The current VCSNS Emergency Plan identifies staffing for the Major Functional Area of Site Access Control and Personnel Accountability as per security plan. Table B-1a of the current VCSNS Emergency Plan includes a Security Lead, whose responsibilities included access control and physical security of the plant reporting to the TSC. This figure did not include a specific augmentation time.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to remove the Site Access Control and Personnel Accountability functional area from Table B-1a of the current VCSNS Emergency Plan, as this is addressed in the Site Security Plan, and replace the Security Lead position with the Emergency Security Director located in the TSC. The Emergency Security Director has the responsibility to act as the liaison between site Security and the TSC while retaining responsibility to direct Security activities.
Because the proposed VCSNS Emergency Plan will 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.
DESC 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 VCSNS Emergency Plan 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 purpose of the Repair Team Activities function is to provide support for the emergency core cooling system (ECCS), event mitigation, and equipment repair. DESC provided its analysis of Repair Team Activities in Section 3.5, Plant System Engineering, Repair and Corrective Actions Functions, in the LAR Attachment 1 for VCSNS.
NUREG-0654 Table B-1 does not include on-shift staffing for the Repair Team Activities function 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 level 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 level to assist with logic manipulation, support event mitigation and equipment repair, and support digital I&C, if applicable.
The current VCSNS Emergency Plan is consistent with NUREG-0654 Table B-1 with the following differences: The current VCSNS plan identifies on-shift and 30-minute augmented response at an Alert or greater emergency classification level. On-shift staff includes one (1) Electrical, two (2) Mechanical Maintenance, and one (1) 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) additional I&C Technician as 60-minute responder at an Alert or greater emergency classification level.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposes to remove the on-shift maintenance positions and would have one mechanical technician and one electrical technician respond within 60 minutes of an Alert or greater emergency classification level. These resources report to the OSC and will act under the direction of the OSC Director 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 to initiate troubleshooting. Additionally, DESC proposes to have one I&C technician respond within 90 minutes of an Alert or greater emergency classification level.
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 VCSNS 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 proposed VCSNS Emergency Plan would be consistent with the guidance in NUREG-0654, Table B-1.
Based on the above, the NRC staff has determined that the proposed VCSNS Emergency Plan 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 purpose of the Supervision of Repair Team Activities function is to provide supervision for electrical, mechanical, I&C and RP activities. DESC provided its analysis of Supervision of Repair Team Activities in Section 3.2, in the LAR Attachment 1 for VCSNS.
NUREG-0654 Table B-1a recommends a Lead OSC Supervisor to staff the OSC within 60 minutes with an Electrical Supervisor, Mechanical Supervisor, I&C Supervisor, and an RP
Supervisor to staff the OSC within 90 minutes from the declaration of an Alert or greater emergency classification level.
The current VCSNS Emergency Plan is consistent with NUREG-0654 Table B-1 with the following difference: The current VCSNS plan identifies one OSC Supervisor and one Radiological Assessment Supervisor to staff the OSC and TSC respectively at 6 minutes from an Alert or greater emergency classification le vel to provide supervision for electrical, mechanical, I&C and RP activities.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to augment one OSC Director position to supervise the augmenting maintenance and electrical technicians for ECCS equipment, event mitigation and repair, with a response time of 60 minutes from an Alert or greater emergency classification level, with further augmentation by a Mechanical maintenance, Electrical maintenance, I&C maintenance, and site RP Coordinators responding to the OSC at 90 minutes from an Alert or greater emergency classification level.
Because the proposed VCSNS Emergency Plan will include an OSC Director to supervise the maintenance and electrical technicians within 60 minutes of an Alert or greater emergency classification level with further augmentation by the Mechanical maintenance, Electrical maintenance and I&C maintenance Coordinators and an I&C maintenance technician within 90 minutes of an Alert or great emergency classification level, the NRC staff finds the proposed changes to be consistent with the guidance of NUREG-0654, Table B-1 for the Supervision of Repair Team Activities functional area and, therefore, the changes are acceptable.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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
The purpose of the Field Monitoring Teams function is to assess areas inside and outside the protected area for radiation contamination, to provide input to the site radiation protection coordinator, and provide radioactive plume tracki ng. DESC provided its analysis for the field monitoring teams in Section 3.4 in the LAR Attachment 1 for VCSNS.
NUREG-0654 Table B-1 recommends this function be performed by one onsite field monitoring team (FMT) and two offsite FMTs. Each FMT would consist of one driver and one qualified individual (i.e., field monitor) to assess the area for radiation and contamination, provide input to the site radiation protection coordinator, and provide radiation protection coverage as directed by either the site radiation protection coordinator in the TSC or radiation protection manager in the EOF. 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 level.
The current VCSNS Emergency Plan is consistent with NUREG-0654 Table B-1 with the following differences: The current VCSNS Emergency Plan has one 30-minute responder responsible for onsite (out of plant) surveys, and an on-shift HP Specialist is responsible for performance of In-plant surveys, augmented by one 30-minute responder from an Alert or greater emergency classification level. For offsite surveys, the current VCSNS Emergency Plan
has two 40-minute responders and two 60-minute responders for offsite monitoring from a Site Area Emergency or greater emergency classification level.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to utilize one of the three RP Technicians to perform the onsite (near site) FMT function responding within 60 minutes of a declaration of an Alert or greater emergency classification level. DESC further states that in the proposed change, dispatch of the two Offsite Monitoring Teams is extended by 20 minutes and 30 minutes, respectively, resulting in one offsite monitoring teams responding at 60 minutes and the second team responding at 90 minutes from an Alert or greater emergency classification level rather than at a Site Area Emergency or greater emergency classification level.
DESC stated that the monitoring capability as provided by the Integrated Plant Computer System and the use of updated dose assessment software 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 to 60 minutes for the first offsite team and from 60 minutes and 90 minutes for the second offsite team.
DESC stated that Improvements in technology allow for remote monitoring of plant radiological conditions in key areas by on-shift RP Technicians. This remote monitoring network provides for easy access to plant area radiation data and allows on-shift RP Technicians to quickly provide radiological information to the SM/ISEM, including changes in radiological conditions that could impact response activities. The improvements have reduced the burden for 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 the U.S. Environmental Protection Agency Protective Action Guidelines.
The on-shift RP Technician, 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 and serves as the basis for the onsite monitoring team.
The NRC staff finds the augmentation of the three RP Technicians and a field monitoring team at 60 and 90 minutes, respectively, from an Aler t or greater emergency classification level is consistent with the guidance in NUREG-0654, Table B-1.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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 providing the Media Information function is to manage and coordinate information related to the event. DESC provided its analysis of media information in Section 3.10, Aspects associated with EOF relocation, in Attachment 1 of the LAR.
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 level but notes that this function does not need to be performed at the TSC or OSC. 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 classification level. For the JIC, 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 f unction(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 VCSNS Emergency Plan has a Chief Technical Spokesperson available within 60 minutes of a declaration of a Site Area Emergency or greater emergency classification level.
The Chief Technical Spokesperson reports to the Corporate Response Manager.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to relocate the JIC from West Columbia, South Carolina to the CERC in Glen Allen, Virginia. Additionally, it proposes to change the time the Chief Technical Spokesperson becomes active from within 60 minutes of the declaration of a Site Area Emergency or greater emergency classification level to within 90 minutes of a declaration of an Alert or greater emergency cla ssification level. Offsite response organization plans provide for CERC interface from their respective emergency operations centers (EOCs),
primarily the South Carolina State EOC/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.
Because DESC proposed to reduce the classification level for augmenting the Chief Technical Spokesperson from the declaration of a Site Area Emergency or greater emergency classification level to the declaration of an Alert or greater emergency classification level, the NRC staff finds the proposed change acceptable. As discussed previously in Section 3.1.1 of this SE, the NRC finds that activation of the CERC within 90 minutes from an Alert or greater emergency classification level is acceptable.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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 level and that another IT lead staff the CERC/JIC within 60 minutes of the declaration of a Site Area Emergency or General Emergency classification level.
The current VCSNS Emergency Plan does not include IT personnel; however, Part 2, Section B.5.b.8, Resource Support Team, of the proposed VCSNS Emergency Plan adds a Resource Support Team that will provide logistical and administrative support, including development of long-term staffing plans and acquiring supplemental staff as appropriate (e.g., Telecommunications, Information Technology, etc.) to the non-minimum staffing of the CERC. Because DESC added the Resource Support Team to provide logistical and administrative support to the proposed VCSNS Em ergency Plan to acquire supplemental staff
as appropriate (e.g., Telecommunications, Information Technology, etc.), the NRC staff find the proposed change acceptable.
As discussed previously in Section 3.1.1 of th is SE, the NRC finds that activation of the CERC within 90 minutes from an Alert or greater emergency classification level is acceptable.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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 states that the number of staff from operations, security force staff, or fire brigade staff on-shift is controlled by the site-specific Technical Specifications or other licensing documents.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to remove the Plant Operations and Assessment of Operational Aspects Function from the VCSNS Emergency Plan. In Section 3.1, Plant Operations and Assessment of Operational Aspects, of the LAR Attachment 1, the licensee stated that on-shift staffing of Operations personnel is maintained under VCSNS Technical Specification (TS) 6.2.2, Unit Staff. On-shift staffing of operations personnel is maintained under documents outside of the Emergency Plan. Since operations staffing is controlled by site-specific documents, and Plant Operations and Assessment of Operational Aspects function is not identified as a functi onal area in NUREG-0654, Table B-1, the NRC staff has determined that the proposed change is acceptable.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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 that the number of staff from operations, security force staff, or fire brigade staff on-shift is controlled by the site-specific Technical Specifications or other licensing documents.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to remove the Fire Fighting function from the current VCSNS Emergency Plan. DESC stated in Section 3.7, Firefighting Function, that the proposed change removes reference to the firefighting function in Table B-1a as this is addressed under the VCSNS Fire Protection Program. Since the fire brigade staffing is controlled by site-specific documents and the Firefighting function is not identified as a functional area in NUREG-0654, Table B-1, the NRC staff has determined that the proposed change is acceptable.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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.
3.1.16 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 that the number of staff from operations, security force staff, or fire brigade staff on-shift is controlled by the site-specific Technical Specifications or other licensing documents.
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposed to remove the Rescue Operations and First Aid function from the current VCSNS Emergency Plan. DESC stated in Section 3.8, Rescue Operations and First Aid Function, that 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. Since rescue operations and first aid staffing is controlled by site-specific documents and the Rescue Operations and First Aid function is not identified as a functional area in NUREG-0654, Table B-1, the NRC staff has determined that the proposed change is acceptable.
Based on the above, the NRC staff concludes that the proposed VCSNS Emergency Plan 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 EOF Relocation
In its application dated June 8, 2023, as supplemented by letters dated October 31, 2023, March 26, 2024, and May 20, 2024, DESC proposes to relocate the EOF and JIC from Ballentine and West Columbia, South Carolina, respectively, to the CERC in Glen Allen, Virginia.
The purpose of an EOF is to provide a facility from which the licensee can manage the overall licensee emergency response during an event, including coordinating radiological and environmental assessments, determining protective actions, and communicating and coordinating with Federal, State, and local agencies. This facility complements other licensee emergency response facilities such as the TSC, which is located onsite at each respective site. The TSC is a facility from which the licensee staff provides plant management and technical support to plant operations personnel during emergency conditions, relieves the reactor operators of peripheral duties and communi cations not directly related to reactor system manipulations, prevents congestion in the control room, and performs EOF functions until the EOF is staffed and ready to respond.
The NRC staff considered relevant regulations and guidance documents in its evaluation of DESCs request to relocate the VCSNS EOF/JIC and consolidate it with the CERC facility in Glen Allen, Virginia. Under 10 CFR 50.47(b)(8), an emergency plan must meet the following planning standard: Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
The NRC amended its EOF regulations as part of the 2011 Final Rule (76 FR 72560; November 23, 2011), which was developed, in part, in response to Commission direction in the staff requirements memorandum (SRM) to SECY-04-0236, Southern Nuclear Operating Companys Proposal to Establish a Common Em ergency Operating Facility at its Corporate Headquarters, dated February 24, 2005 (ML050550131). The SRM stated, in part:
The staff should consider revising 10 CFR Part 50 to make the requirements for EOFs more performance-based to allow other multi-plant licensees to consolidate their EOFs, if those licensees can demonstrate their emergency response strategies will adequately cope with an emergency at any of the associated plants.
As such, paragraph IV.E.8.c of Appendix E to 10 CFR Part 50 was revised by the 2011 Final Rule to establish the following minimum capabilities for an EOF:
(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[.]
In accordance with paragraph IV.E.8.b of Appendix E to 10 CFR Part 50, a licensee with an EOF located more than 25 miles from a nuclear power reactor site must also have an additional facility 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. This near-site facility must meet the fo llowing requirements in paragraph IV.E.8.b of Appendix E to 10 CFR Part 50, which were also added by the 2011 Final Rule:
(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[.]
The NRCs issuance of the guidance document, NUREG-0696, in 1981, established criteria for the NRC staff to use in evaluating whether an applicant/licensee met the then-existing requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50 for an EOF. Section 4, Emergency Operations Facility, of NUREG-0696 provided compliance criteria for the EOF in the following nine 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);
Technical Data and Data System (Section 4.8); and Records Availability and Management (Section 4.9).
While retaining the nine categories of the EOF criteria in NUREG-0696, Section 4, the guidelines in several categories were subsequently supplemented as part of the 2011 Final Rule with the guidelines in NSIR/DPR-ISG-01,Section IV.I, Emergency Operations Facility - Performance-Based Approach. DESC evaluated the CERC using these nine categories in Attachment 1 of the LAR. As such, the NRC staff evaluated the proposed VCSNS EOF/JIC relocation using the nine ca tegories in Section 4 of NUREG-0696, as supplemented by Section IV.I of NSIR/DPR-ISG-01.
By letter dated February 27, 2019 (ML19031B227), the NRC approved amendments to revise the North Anna Power Station (NAPS) and the Surry Power Station (SPS) Emergency Plans to consolidate the near-site EOFs, their common backup EOF, and the headquarters support organization at the proposed Virginia Electric and Power Company (Dominion Energy Virginia)
CERC in the Innsbrook Technical Center, located at 5000 Dominion Boulevard, Glen Allen, Virginia (VA). In Section 3.7 of its safety evaluation, the NRC concluded in this review that:
On the basis of its evaluation, the NRC staff concludes that the proposed CERC is consistent with the guidance in Section 4 of NUREG-0696, as supplemented by Section IV.I of NSIR/DPR-ISG-01, and NUREG-0654 and, as such, continues to meet the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
Given the technological capabilities of the facility, its demonstrated capacity to address simultaneous, multi-site events, and the staffing of an ERO that will be comprised of experienced and diverse disciplines, the NRC staff finds that there is reasonable assurance that protecti ve measures can and will be implemented in the event of a radiological emergency at any of the sites that the proposed CERC will serve.
Since the CERC was approved, the NRC staff conducted numerous inspections of drills and biennial exercises of the NAPS and the SPS Emergency Plans which include the activation of the CERC to respond to a simulated event at the respective site. The table below lists the dates of the drills and biennial exercises, and the associated inspection reports.
Inspection Report Site Exercise Date Accession Number SPS April 11, 2019 (drill at CERC) ML19217A072 July 22, 2019 ML19311C688 July 19, 2021 ML21331A000 July 17, 2023 ML23296A031 NAPS August 17, 2020 ML20310A166 July 18, 2022 ML22311A542
3.2.1 Functions
In Section 3.10.1, Functions, DESC discusses how the CERC provides the facilities and capability to: (1) manage the overall licensee emergency response; (2) coordinate radiological and environmental assessment; (3) determine recommended public protective actions; (4) perform offsite notifications to State and local agencies; (5) coordinate event, plant, and response information provided to public information staff for dissemination to the media and the public; (6) staff and activate the facility within timeframes and at emergency classification levels defined in the licensees emergency plan; (7) coordinate emergency response activities with Federal, State, Tribal, and local agencies; (8) loca te NRC and offsite agency staff closer to the affected sites because the EOF is greater than 25 miles from the sites; (9) obtain and display key plant data and radiological information for each plant that the EOF serves; (10) analyze plant technical information and provide technica l briefings on event conditions and prognosis to licensee staff and offsite agency responders for each type of unit or plant; and (11) effectively respond to and coordinate response efforts for events occurring simultaneously at more than one site.
Furthermore, DESC states that an advantage of the CERC being located in the Innsbrook Technical Center in Glen Allen, VA, 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 who have a wide range of expertise.
In its letter dated March 26, 2024, DESC states, in part:
Dominion Energy plans to conduct a demonstration drill involving a response to concurrent events requiring CERC activation with VCSNS and either North Anna or Surry Power Stations on December 11, 2024. The scope of the drill will require response to and coordination of response efforts for events occurring simultaneously at more than one site. Specifically, this drill will demonstrate the following:
Management of overall licensee emergency response.
Coordination of radiological and environmental assessment.
Determination of recommended protective actions at a minimum of one site.
Notification of respective ORO response centers.
Coordination of event, plant and response information provided to public information staff for dissemination to the media and the public.
Staffing and activation of the facility within CERC activation time frames for an Alert or higher emergency class at VCSNS and either North Anna or Surry Station.
Coordination of emergency response activities with Federal, State and local agencies.
Obtaining and displaying key plant data and radiological information for the affective units per the drill scenario.
Analyzing plant technical information and providing technical briefings on event conditions and prognosis to licensee staff and offsite agency responders for the affected units per the drill scenario.
The December 11, 2024, drill will impact multiple units at either Surry or North Anna. Representatives of the NRC and the Federal Emergency Management Agency will be invited to observe the drill.
In addition, the letter dated March 26, 2024, states,
Part 2, Section N.1 of the VCSNS Emergency Plan has been revised to require at least once every eight-year exercise cycle, one drill shall be conducted involving CERC response to concurrent events at multiple Dominion Energy Units.
Based on the above, and observations by regional inspectors as part of previous drills/exercises at the CERC, the NRC staff finds that, with the proposed relocation of the VCSNS EOF/JIC to the CERC, the CERC will continue to meet the functional requirements for an EOF. Therefore, the NRC staff concludes that the CERC is cons istent with the guidance in NUREG-0696, as supplemented by NSIR/DPR-ISG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
3.2.2 Location, Structure, and Habitability
Location
The CERC is located at 5000 Dominion Boulevard, Glen Allen, Virginia, which is 312 miles straight-line distance to the VCSNS TSC and is the location for the Dominion Energy Corporate Office. The proximity to the Dominion Energy Corporate Office allows corporate support and management personnel to staff the CERC.
The CERC currently supports emergency respon se to an emergency declared at the NAPS and SPS sites and has demonstrated its capabilities to effectively perform the designated EOF function for these sites located more than 25 miles from their respective TSCs during previous drills and biennial exercises observed by NRC regional inspectors. DESC states that the location, size, and layout of the CERC will continue to meet the emergency plan staffing and equipment requirements to carry out overall strategic direction for onsite and support operations.
The NRC staff also evaluated the following considerations in determining the adequacy of the relocation of the VCSNS EOF, including the JIC function, and consolidation into the CERC.
Offsite Agreement
The regulations at 10 CFR 50.47(b)(3) require, in part, arrangements to accommodate State and local staff at the licensees EOF. In Attachment 7, Offsite Response Organization Concurrence Letters, of the LAR, DESC provided signed letters from the following agencies indicating that they concur with the proposed consolidation of the VCSNS EOF/JIC with the CERC:
Fairfield County Emergency Management; Lexington County Emergency Management; Newberry County Emergency Management;
Richland County Emergency Management; and South Carolina Emergency Management Division.
Per the Memorandum of Understanding Between the Department of Homeland Security/Federal Emergency Management Agency [FEMA] and Nuclear Regulatory Commission Regarding Radiological Emergency Response, Planning, and Preparedness, dated December 7, 2015 (ML15344A371), FEMA makes findings and determinations as to the adequacy and capability of implementing offsit e radiological emergency response plans and communicates those findings and determinations to the NRC. By letter dated August 25, 2023 (ML23243B046), FEMA provided the following:
The FEMA Region 4 REP [Radiological Emergency Preparedness] staff and HQ [Headquarters] reviewed the proposed consolidations of the EOF/JIC to determine the adequacy of offsite radiological emergency plans and preparedness. FEMA finds that with minor adjustments (outlined in the FEMA Region 4 enclosure) the offsite plans and procedures are not negatively impacted by the proposed changes.
In addition, the enclosure stated the following:
FEMA Region 4 conducted a review of the proposal and concurs with the State of South Carolina and the offsite response organizations surrounding the Virgil C.
Summer Nuclear Station that this move will not negatively impact offsite preparedness.
South Carolina currently sends state liaisons and radiological health personnel to Duke Energys Charlotte, North Carolina corporate Emergency Operations Facility for the H.B. Robinson, Catawba and Oconee Nuclear sites, and Southern Companys Emergency Operations Facility for the Vogtle Electric Generating Plant in Birmingham, Alabama.
Minor plan changes to incorporate the new Emergency Operations Facility address and other such minor adjustments will be developed prior to the next joint biennial exercise in 2025 by the State to address the consolidation by Dominion Energy of the Virgil C. Summer Emergency Operations Facility and the Joint Information Center from Ballentine, South Carolina and West Columbia, South Carolina, respectively, to the Dominion Energy Corporate Emergency Response Center in Glen Allen, Virginia.
Based on its review of the licensees submittal and FEMAs evaluation of the impact of the proposed EOF relocation/consolidation on offs ite emergency preparedness plans, the NRC staff finds that the CERC will continue to meet the functional requirements for an EOF. Therefore, the NRC staff concludes that the CERC is cons istent with the guidance in NUREG-0696, as supplemented by NSIR/DPR-ISG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
Impact on NRCs Incident Response
As previously stated, the CERC currently suppor ts the NAPS and SPS sites. In Section 3.10.4, Size, of Attachment 1 to the LAR, DESC states that there is a space provided for an NRC team in the CERC. A diagram of the CERC layout, provided in Attachment 1 to the LAR,
Figure 3.10.4 Proposed CERC Layout, illustrates designated areas for Federal Agencies. As an existing facility supporting EOF functions for the NAPS and SPS sites, the CERC has demonstrated a capability to support Federal responders and effectively integrate with licensee ERO personnel.
Paragraph IV.E.8.b of Appendix E to 10 CFR Part 50 requires that provisions 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 site for an EOF located more than 25 miles from a nuclear power reactor site.
DESC states in Section 3.10(a) of Attachment 1 to the LAR,
The VCSNS 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.
Based on the above and observations by regional inspectors as part of previous drills/exercises at the CERC, the NRC staff finds that the CERC will continue to meet the functional requirements for an EOF. Therefore, the NRC staff concludes that the CERC is consistent with the guidance in NUREG-0696, as supplemented by NSIR/DPR-ISG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
Structure
Section 4.2 of NUREG-0696, as supplemented by Table 2, Relation of EOF Location to Habitability Criteria, to Section IV.I of NSIR/DPR-ISG-01, provides guidance stating that for an EOF located at or beyond 10 miles of the sites TSC, the structure be Well engineered for design life of plant. Footnote 2 to Table 2 provides an example of well engineered as referring to the applicable Uniform Building Code, and states that the structure must be able to withstand adverse conditions of high winds (other than tornados) and floods, referencing a 100-year recurrence frequency as an acceptable design basis.
Additionally, Section 8.4, Emergency Operations Facility (EOF), of NUREG-0737, Supplement 1, states,
The EOF will be:
- d. Structurally built in accordance with the Uniform Building Code.
DESC states that the CERC is designed to withstand wind speeds up to 120 mph. The building is capable of withstanding wind and live loads equal to or greater than those specified in the BOCA [Building Officials and Code Administrators] National Building Code/1981.
Section 912.0, Wind Speed, of the BOCA National building code 1981, figure 912.1, Basic Windspeed in Miles Per Hour, shows that the CERC, located in Glen Allen, VA falls within the
basic wind speed zone of 80 miles per hour. The wind speed in figure 912.1 is based on the fastest mile speed 30 feet above the ground for a 50-year mean recurrence interval.
Although the guidance in NUREG-0696 describes criteria for determining wind loads based on a recurrence frequency of 100 years, the BOCA National building code 1981 uses a recurrence frequency of 50 years, which are events with a higher probability of occurring than a 100-year event. The NRC staff previously found this to be acceptable for the CERC in the letter dated February 27, 2019.
Additionally, the NRC staff considered precedent where the NRC staff previously approved the use of a 50-year wind design for other facilities, such as the Southern Nuclear Operating Company (SNC) common EOF, as set forth in a letter dated July 26, 2018 (ML18183A073),
approving the relocation of the SNC Common EOF and for the Duke Energy Proposed Common EOF, as set forth in a letter dated March 10, 2023 (ML22332A493), approving the relocation of the Duke Energy Common EOF. Therefore, the NRC staff finds the structures design for wind loads acceptable, because; (1) it is consist ent with the design of the current NRC-approved CERC; and (2) the CERC meets the BOCA National Building Code/1981 requirements.
DECS further states that the CERC is in a minimal flood hazard zone which is outside the 500-year flood zone. The NRC staff finds this to be acceptable.
Based on the above and the previous approval of the CERC, the NRC staff finds that the physical structure of the CERC would continue to be consistent with the guidance in NUREG-0696, as supplemented by NSIR/DPR-I SG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
Habitability
Section 4.2 of NUREG-0696, as supplemented by Table 2 to Section IV.I of NSIR/DPR-ISG-01, provides guidance for the ventilation standards and protection factor for a radiological release.
Because the CERC in Glenn Allen, VA is located beyond 10 miles from any NRC-licensed nuclear power reactor site, EOF functions are not expected to be impacted by a radiological release. In these situations, the applicable criter ion in Table 2 of NSIR/DPR-ISG-01 states that no specialized ventilation systems or protection factor are needed. Therefore, the NRC staff finds that the habitability of the CERC will continue to be consistent with the guidance in NUREG-0696, as supplemented by NSIR/DPR-I SG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
3.2.3 Staffing and Training
Section 4.3 of NUREG-0696, as supplemented by Section IV.I of NSIR/DPR-ISG-01, provides guidance on EOF staffing and training to provide for the overall management of licensee resources, and the continuous evaluation and coordination of licensee activities during and after an accident. In addition, Section 4.3 to NURE G-0696 provides guidance on the conduct of periodic EOF activation drills in accordance with the licensees emergency plan.
DESC states that on January 1, 2019, it 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, VA. DESC further states that 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 personne l from the DESC Corporate Office. 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, co ordinate 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.
DESC states that 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 be trained in the emergency response for VCNS in accordance with the VCSNS Emergency Plan. 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.
The CERC staff currently includes personnel that have demonstrated the ability to effectively manage overall licensee emergency response, co ordinate radiological and environmental assessment, determine recommended public protective actions, and interface with offsite officials, based on NRC-observed exercise s in support of the NAPS and SPS sites.
Based on the above, and observations by regional inspectors as part of previous drills/exercises at the CERC, the NRC staff finds that the CERC will continue to meet the staffing and training criteria for an EOF. Therefore, the NRC staff concludes that the CERC is consistent with the guidance in NUREG-0696, as supplemented by NS IR/DPR-ISG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
3.2.4 Size
Section 4.4 of NUREG-0696, as supplemented by Section IV.I to NSIR/DPR-ISG 01, provides guidance that the EOF building will be large enough to provide adequate workspace for personnel assigned to the EOF as specified in the licensees emergency plan, at the maximum level of occupancy without crowding, as well as provide separate office space to accommodate NRC staff and other Federal personnel.
Section 3.10.4, Size, of Attachment 1 to the LAR specifies that the CERC facility measures approximately 5987 square feet of space, divided between the EOF and the JIC. Section 3.10.4 of Attachment 1 to the LAR also states, in part:
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 use of computer monitors and video display monitors.
Previous drills/exercises, which have been obser ved by NRC regional inspectors, continue to demonstrate that the size of the CERC EOF provides adequate working space for the number of ERO staff, including State and NRC responders, at a level of occupancy supporting an event at more than one reactor site. DESC is not proposing to change the staffing levels and capabilities for the existing CERC.
Paragraph IV.E.8.c.(3) of Appendix E to 10 CFR Part 50 requires the capability to support response to events occurring simultaneously at more than one nuclear power reactor site if the EOF serves more than one site. Recognizing that there is a possibility for simultaneous events to occur at the sites that the CERC serves, DESC discusses, in Section 3.10.1(11) of to the LAR, that the CERC will be able to support simultaneous events at two of the sites it serves. 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.
Based on the above, and observations by regional inspectors as part of previous drills/exercises at the CERC, the NRC staff finds that the CERC will continue to be of sufficient size to accommodate and support Federal, State, local, and licensee ERO personnel, equipment, and documentation for an EOF. Therefore, the NRC staff concludes that the CERC is consistent with the guidance in NUREG-0696, as supplemented by NSIR/DPR-ISG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
3.2.5 Radiological Monitoring
Section 4.5 of NUREG-0696, as supplemented by Section IV.I of NSIR/DPR-ISG-01, and Section 3.10.5, Radiological Monitoring, of Attachment 1 to the LAR address radiological monitoring with respect to the CERC. The guidance in NUREG-0696 specifies that to ensure adequate radiological protection of EOF personnel, radiation monitoring systems should be provided in the EOF if located within 10 miles of a nuclear power reactor site. No NRC-licensed nuclear power reactor site is located within 10 miles of the CERC; therefore, radiological monitoring capabilities described in NUREG-0696, as supplemented by NSIR/DPR-ISG-01, are not needed to meet the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
3.2.6 Communications
Section 4.6 of NUREG-0696 provides guidance t hat the EOF shall have reliable voice communications facilities to the sites TSC and control room, the NRC, and State and local emergency operations centers, and describes the primary functions of the EOF voice communications facilities.
In Section 3.10.6, Communications, of Attachment 1 to the LAR, DESC describes the communications capabilities of the CERC as follows:
The CERC has reliable voice communication facilities 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 system supply system (NSSS), the Federal Emergency Management Agency, and the U.S. 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 serves as the designated backup means of communications in the event of an emergency communication system failure.
DESC states that backup power to voice and data communications in the CERC is provided by a diesel generator, DC battery and uninterruptable power supply systems. The testing of communications systems at the CERC will be performed as described in Section O.2, Communication Drills, to the proposed VCSNS Emergency Plan to ensure the reliable, timely flow of information between all parties having an emergency response role.
DESC further states that FMT communications for the NAPS, SPS, and VCSNS sites employ radio systems to coordinate radiological monitoring. In Section 3.10.6 of Attachment 1 to the LAR, DESC states that the 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 emergency response facilities and the CERC.
Based on the above, and observations by regional inspectors as part of previous drills/exercises at the CERC, the NRC staff finds that the CERC would continue to have sufficient internal and external telecommunications capabilities to support EOF. Therefore, the staff concludes that the CERC will continue to provide reliable EOF voice and data communications, and information collection consistent with the gui dance in NUREG-0696, as supplemented by NSIR/DPR-ISG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
3.2.7 Instrumentation, Data Systems Equipment, and Power Supplies
Section 4.7 of NUREG-0696 provides guidance on equipment to gather, store, and display data needed in the EOF to analyze and exchange information on plant conditions, as well as criteria to perform these functions.
In Section 3.10.7, Instruments, data system equipment, and power supplies, of Attachment 1 to the LAR, DESC addresses the CERC capabilities in relation to instruments, data system equipment, and power supplies. DESC states that the CERC has access to displays that are representative of the displays in the Control Room via the DEV WAN and Local Area Networks (WAN and LAN). Data acquisition for the CERC is achieved through a secure connection to the plant computer servers. DESC states that DEV has established an availability goal for the LAN/WAN that exceeds the 0.01 unavailabilit y goal identified in NUREG-0696. The CERC has access to the same data points that are available to the operators in the Control Room and emergency responders in the TSC, including the Safety Parameter Display System (SPDS) data points. The CERC video display system will display the graphics on screens in the Command Center area.
DESC states that two utility circuits feed the Innsbrook Technical Center where the CERC is located. 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 backup power available. DESC states that a loss of commercial power would not impact voice or data communications equipment in the CERC.
DESC states that the workstations and related LAN/ WAN equipment require alternating current (AC) power to operate. The LAN equipment housed within the CERC is on backup power with an emergency diesel generator. The facility also has an uninterruptable power supply designed to eliminate the necessity to restart computers in the CERC while loads are transferred from the commercial power supply to the backup diesel generator in the event of a loss of commercial power. Since the CERC is located offsite of VCSNS, its electrical equipment loads do not affect any safety-related power source. Loss of primary commercial power does not cause loss of any stored data vital to EOF functions.
DESC further states that historical data from the site are accessible from a historical database.
This information can be accessed by the CERC, as needed once power is restored to the LAN.
Based on the above and observations by regional inspectors as part of previous drills/exercises at the CERC, the NRC staff finds that t he CERC would continue to have sufficient instrumentation, data system equipment, and pow er supplies to support EOF. Therefore, the NRC staff concludes that the CERC will cont inue to have instrumentation, data system equipment, and power supplies consistent with the guidance in NUREG-0696, as supplemented by NSIR/DPR-ISG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
3.2.8 Technical Data and Data Systems
Section 4.8 of NUREG-0696 provides guidance on t he technical data system needed to receive, store, process, and display information sufficient to perform assessments of the actual and potential onsite and offsite environmental consequences of an emergency condition.
In Section 3.10.8, Technical data and data system, of Attachment 1 to the LAR, DESC states that the CERC has 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. The CERC data set includes radiological, meteorological, and other environmental data needed to assess environmental conditions, coordinate radiological monitoring activities, and recommend implementation of offsite protective actions. A proxy server will allow the display of data points that cover Type A, B, C, D, and E variables discussed in Section 4.8 of NUREG-0696 (which references RG 1.97, Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants, and RG 1.23, Meteorological Monitoring Programs for Nuclear Power Plants), including meteorological variables required for dose assessment.
DESC states that the CERC will have access to the same data points that are available to the operators in the control room and emergency responders in the VCSNS TSC, including SPDS data points. NAPS, SPS, and VCSNS use MIDAS in the event of an actual or potential release of airborne radioactivity to the environment at levels warranting declaration of an emergency as specified in the NAPS and SPS Emergency Plans, and the proposed VCSNS Emergency Plan.
Based on the above and observations by regional inspectors as part of previous drills/exercises at the CERC, the NRC staff finds that the CERC will continue to have sufficient technical data and data systems to support EOF. Therefore, the NRC staff concludes that the CERC will continue to have technical data and data systems consistent with the guidance in NUREG-0696, as supplemented by NSIR/DPR-ISG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
3.2.9 Records Availability and Management
Section 4.9 of NUREG-0696 provides guidance on the ready access to up-to-date plant records, procedures, and emergency plans needed to exercise overall management of licensee emergency response resources.
In Section 3.10.9, Records availability and management, of Attachment 1 to the LAR, DESC states that the CERC will maintain key reference materials for NAPS, SPS, and VCSNS and that station design documentation, plant drawings, procedures, etc., are available electronically via the LAN connection.
Examples include:
Plant Technical Specifications; Plant operating procedures; Emergency operating procedures; Final Safety Analysis Reports; Emergency plans - Station emergen cy plans and State emergency plans (including site-specific appendices);
Offsite population distribution data; Evacuation plans; and Drawings.
Based on its review of the licensees submittals and observations by regional inspectors as part of previous drills/exercises at the CERC, the NRC staff finds that the CERC will continue to
have sufficient records availability and management criteria to support EOF functions.
Therefore, the NRC staff concludes that the CERC will continue to have records availability and management criteria consistent with the guidance in NUREG-0696, as supplemented by NSIR/DPR-ISG-01, and the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
3.2.10 VCNS Joint Information Center
In Part 2, Section G.3, Media Accommodations, of the proposed VCSNS Emergency plan, DESC states that the Dominion Energy Public Affairs Group is notified when an Unusual Event or higher emergency condition exists. They will handl e public media inquiries in the early stages of the event (until the CERC is activated) by distributing background information, news releases, and providing information to Dominion Energy management. News releases and official company statements to the media will be iss ued and made from the CERC unless otherwise requested by State Emergency Management Division.
DESC further states that the Chief Technical Spokesperson is the primary spokesperson for Dominion Energy. The Chief Technical Spokesperson has direct access to all necessary information. All information will be coordinated before conducting news briefings. Rumors or misinformation are identified during an emergency by Dominion Energy public information personnel who respond to telephone calls and social media from the public and the media and monitor media reports.
Based on its review of the licensees submittals and observations by regional inspectors as part of previous drills/exercises at the JIC, co-located with the CERC, the NRC staff finds that the facility has equipment, communications, and staffing sufficient to support public information functions. Therefore, the NRC staff concludes that the JIC, co-located with the CERC, will continue to be consistent with the guidance in NUREG-0654 and the requirements of 10 CFR 50.47(b)(7).
3.3 NRC Staff Conclusion
3.3.1 Emergency Response Organization Changes
Based on the NRC staffs review and evaluation of the information in DESCs application as described above, the NRC staff finds that the proposed changes to the VCSNS Emergency Plan continue to meet the standards of 10 CFR 50.47(b)(2), and the requirements in Appendix E to 10 CFR Part 50, Section IV.A., and that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at VCSNS. Therefore, the NRC staff concludes that the proposed VCSN S Emergency Plan contained in its application and supplemental letters, is acceptable.
3.3.2 EOF Relocation
On the basis of its evaluation, the NRC staff concludes that the proposed relocation of the VCSNS EOF to the CERC is acceptable because the CERC is consistent with the guidance in Section 4 of NUREG-0696, as supplemented by Section IV.I of NSIR/DPR ISG-01, and, as such, continues to meet the relevant standards of 10 CFR 50.47(b) and the requirements of paragraph IV.E.8 of Appendix E to 10 CFR Part 50.
Given the technological capabilities of the fa cility, its demonstrated capacity to address simultaneous, multi-site events, and the staffing of an ERO that will be comprised of experienced and diverse disciplines, the NRC staff finds that there is reasonable assurance that adequate protective measures can and will be implemented in the event of a radiological emergency at any of the sites that the proposed CERC will serve. Therefore, the NRC staff concludes that the proposed VCSNS Emergency Plan contained in its application and supplemental letters, is acceptable.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the NRC staff notified the South Carolina State official of the proposed issuance of the amendment on May 31, 2024. On June 14, 2024, the State official confirmed the State of South Carolina had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change administrative procedures or requirements 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.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that public health and safety 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 amendment will not be inimical to the common defense and security or to public health and safety.
Principal Contributors: M. Norris J. Herrera J. Arce
Date of Issuance: July 31, 2024
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