ML25065A189

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Stations, Units 1 and 2 and Associated Independent Spent Fuel Storage Installations - Revision to Emergency Plan Report of Change
ML25065A189
Person / Time
Site: Surry, North Anna, 07200002, 07200055  Dominion icon.png
Issue date: 03/05/2025
From: James Holloway
Virginia Electric & Power Co (VEPCO)
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
25-046
Download: ML25065A189 (1)


Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMO ND, VIRGINIA 23261 March 5, 2025 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 VIRGINIA ELECTRIC AND POWER COMPANY 10 CFR 50.54(q)

Serial No.:

25-046 NRA/DPJ:

RO Docket Nos.:

50-280/281 50-338/339 72-2/55 72-16/56 License Nos.: DPR-32/37 SNM-2501 NPF-4/7 SNM-2507 NORTH ANNA AND SURRY POWER STATIONS UNITS 1 AND 2 AND ASSOCIATED INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS REVISION TO EMERGENCY PLAN REPORT OF CHANGE Pursuant to 10 CFR 50.54(q)(5) and 10 CFR 72.44(f), summaries of the change analyses for Revision 56 to the North Anna Power Station (NAPS) Emergency Plan and Revision 75 to the Surry Power Station (SPS) Emergency Plan are provided in Attachments 1 and 2, respectively. The NAPS and SPS Plans were effective on February 4, 2025. The revisions incorporate editorial changes, as well as changes that did not require prior NRC approval, and do not implement actions that reduce the effectiveness of the NAPS Emergency Plan or SPS Emergency Plan. The respective Emergency Plans continue to meet the standards of 10 CFR 50.47(b) and Appendix E.

If you have any questions or require additional information, please contact Mr. Daniel P.

Johnson at 804-273-2381.

Respectfully,

I)

~,Jqtw7 James E. Holloway Vice President - Nuclear Engineering and Fleet Support Commitments made by this letter: None

Attachments:

Serial No.: 25-046 Docket Nos.: 50-280/281, 72-2/55 50-338/339, 72-16/56 Page 2 of 3

1. North Anna Power Station Emergency Plan, Revision 56, 10 CFR 50.54(q) Summary
2. Surry Power Station Emergency Plan, Revision 75, 10 CFR 50.54(q) Summary

cc:

U.S. Nuclear Regulatory Commission - Region II Attn: Regional Administrator Marquis One Tower 245 Peachtree Center Avenue, NE., Suite 1200 Atlanta, Georgia 30303-1257 Mr. L. John Klos NRC Project Manager-Surry Power Station U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. G. Edward Miller Serial No.: 25-046 Docket Nos.: 50-280/281, 72-2/55 50-338/339, 72-16/56 Page 3 of 3 NRC Senior Project Manager - North Anna Power Station U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station Ms. Yen-Ju J. Chen NRC Senior Project Manager - ISFSls U. S. Nuclear Regulatory Commission Mail Stop 4B34 Two White Flint North 11545 Rockville Pike Rockville, Maryland 20852-2738

ATTACHMENT 1 Serial No.: 25-046 Docket Nos.: 50-338/339, 72-16/56 NORTH ANNA POWER STATION EMERGENCY PLAN, REVISION 56, 10 CFR 50.54(q)

SUMMARY

Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station - Units 1 and 2 North Anna Independent Spent Fuel Storage Installation

Serial No.: 25-046 Docket Nos.: 50-338/339, 72-16/56 Page 1 of 5 North Anna Power Station Emergency Plan, Revision 56, 10 CFR 50.54(9) Summary On February 4, 2025, Revision 56 of the North Anna Power Station (NAPS) Emergency Plan was implemented to incorporate the changes described below. These descriptions provide an explanation of why each change is not a reduction in effectiveness of the Emergency Plan, thus not requiring prior NRG approval, and the regulatory basis for each non-editorial change.

1. Section 1.0 Definitions. Corporate Emergency Response Center (CERC)

This change supports the V. C. Summer Nuclear Station (VCSNS) Emergency Operations Facility (EOF) move to the CERC by removing the specific references to NAPS and Surry Power Station (SPS) and replacing with "Dominion Nuclear Power Stations."

Corporate Emergency Response Center (CERC) -

Consolidated emergency operations facility for Dominion Nuclear Power Stations. Designated facility serving as the focal point for inter-company efforts implemented to support station emergency response actions and for dissemination of emergency information. The CERC is located at the Innsbrook Technical Center in Glen Allen, Virginia.

This administrative change maintains the effectiveness of the Emergency Plan.

2. Section 1.0 Definitions. Emergency Plan Implementing Procedures (EPIPs)

The definition of EPIPs was changed to include Controlled Supporting Documents.

Emergency Plan Implementing Procedures (EPIPs) -

Emergency response procedures including Controlled Supporting Documents that implement the Emergency Plan.

Common EPIPs used at NAPS, SPS, and Innsbrook Technical Center, as well as equivalent implementing procedures at VCSNS, are integrated into fleet common implementing procedures and labeled Controlled Supporting Documents.

The functions of the replaced implementing procedures are maintained. This change is administrative and maintains the effectiveness of the Emergency Plan.

Serial No.: 25-046 Docket Nos.: 50-338/339, 72-16/56 Page 2 of 5

3. Section 1.1 Acronyms and Abbreviations. CSD - Controlled Supporting Documents The definition of the acronym CSD was changed from "Cold Shutdown" to "Controlled Supporting Document." Cold Shutdown is not abbreviated with the acronym CSD in the current Emergency Plan revision, therefore there is no conflict with dual acronym usage with this change. This administrative change maintains the effectiveness of the Emergency Plan.
4. Section 6.3.1 Offsite Criteria for the 10 Mile Emergency Planning Zone (EPZ)

The 10-mile EPZ has been revised to replace sectors with Protective Action Zones (PAZs). The initial Protective Action Recommendation (PAR) for any event classified as a General Emergency will be to evacuate a two-mile radius and five miles in the downwind PAZs unless severe accident conditions exist, an evacuation dose threshold is exceeded beyond two miles, or sheltering-in-place is appropriate.

The PAZs represent the same criteria and logic (two-mile radius 360 degrees and from two to five miles in three downwind sectors). When the Commonwealth of Virginia receives the initial PAR, it converts the sectors into the affected PAZs. In collaboration with the Commonwealth of Virginia, NAPS has agreed to provide future PARs directly as affected PAZs based on wind direction. This approach was developed to determine affected PAZs based on a keyhole area superimposed over an EPZ map.

Use of PAZs eliminates the need by the Commonwealth to convert a radius and sector recommendation into affected zones. The affected zones determined for each level of PAR (initial two-mile, expanded five-mile, expanded 10-mile, Rapidly Progressing Severe Accident (RPSA), and Hostile Action Based {HAB) Shelter) were determined based upon agreed strategies with the Offsite Response Organizations (OROs) and incorporate the results of the station Evacuation Time Estimate (ETE) in those strategies.

Evaluation:

The proposed change provides guidance equivalent to that provided in the current method to determine PARs using current meteorology.

Therefore, it satisfies regulations by maintaining the requirements of 10 CFR 50.47(b)(10) and 10 CFR 50 Appendix E. This change does not constitute a reduction in the ability to develop a PAR or reduce the effectiveness of the Emergency Plan.

5. Backup Emergency Notification Form Figure 6.1 Serial No.: 25-046 Docket Nos.: 50-338/339, 72-16/56 Page 3 of 5 The sample Backup Notification Form included in the applicable CSD was revised to incorporate the PAR logic change from downwind sectors to communicating PAZs. The Backup Emergency Notification Form maintains the capability and process for backup offsite notification, to maintain commitments for notifying offsite authorities in a timely manner.

Evaluation:

The proposed change meets the regulations by maintaining all the requirements of 1 0 CFR 50.47{b)(5), 10 CFR 50 Appendix E, and NUREG-0654. This change is not a reduction in the effectiveness of the Emergency Plan.

6. Protective Action Recommendation {PAR) Figure 6.2 Based on agreement with the Commonwealth of Virginia, the PAR is now included on the offsite notification form distributed via the Dominion Energy Emergency Notification System (DEENS). Therefore, the separate attachment is no longer necessary.

Evaluation:

The notifications and communications procedure provides methods and processes to provide PARs within 15 minutes of a General Emergency, as required in regulation and committed to in the respective station emergency plans. The proposed change meets the regulations by maintaining all the requirements of 10 CFR 50.47(b)(5), 10 CFR 50 Appendix E, and NUREG-0654. This change is not a reduction in the effectiveness of the Emergency Plan.

7. Radiological Status Figure 6.4 The Radiological Status Form has been changed to add a Drill Message Field and an Emergency Message Field. These fields are used to designate the appropriate condition for when the form is used. This change is administrative and does not change the function of the form, therefore, it continues to maintain the purpose of reporting a radiological status to the Commonwealth.
8. 7.1.4 Corporate Emergency Response Center Serial No.: 25-046 Docket Nos.: 50-338/339, 72-16/56 Page 4 of 5 This change supports the VCSNS EOF move to the CERC by removing the specific references to NAPS and SPS in Section 7.1.4 and replacing them with "Dominion Nuclear Power Stations."

The CERC is the consolidated EOF for Dominion Nuclear Power Stations. The CERC is located at the Innsbrook Technical Center in Glen Allen, Virginia.

The facility provides workstations for Corporate, Federal, and State officials who may be assembled at this location. This facility is the designated central collection point for the receipt and analysis of all field monitoring data and the coordination of sample media.

Plant data is available from the Plant Computer System (PCS). The Meteorological Information and Dose Assessment System (MIDAS) is used to estimate offsite doses.

This administrative change maintains the effectiveness of the Emergency Plan.

9. 8.1 Responsibilities for Maintaining Emergency Preparedness This change is an administrative change as it replaces the specific reference to procedure VPAP-2601, "Maintaining Emergency Preparedness," in Section 8.1 with the more general term "applicable Emergency Preparedness Procedures." Removing the specific reference to VPAP-2601 in Section 8.1 does not delete the procedure.

VPAP-2601 remains an active procedure, and the purpose of the procedure is maintained. Therefore, this change maintains the effectiveness of the Emergency Plan.

The hierarchy for program maintenance is further outlined in applicable Emergency Preparedness procedures.

10.Appendix 10.4 List of Emergency Plan Implementing Procedures The changes in Appendix 10.4, "List of Emergency Plan Implementing Procedures,"

are limited to replacing affected EPIPs that are now EP-AA-CSD-XXX procedures. The listing of Emergency Plan Implementing Procedures was changed to differentiate between implementing procedures that are labeled EPIP and CSD. This change is administrative and maintains the effectiveness of the Emergency Plan.

11.Appendix 10.4 NAEP-EPIP Cross Reference Serial No.: 25-046 Docket Nos.: 50-338/339, 72-16/56 Page 5 of 5 The NAPS Emergency Plan EPIP Cross Reference in Appendix 10.4 was changed to incorporate applicable EPIPs that are relabeled as CSDs.

This change is an administrative change that supports the VCSNS EOF move to the CERC. This change maintains the effectiveness of the Emergency Plan.

12.Appendix 10.5 Protective Equipment and Supplies This change is required to switch the current flashlights using D size cell batteries to flashlights using AA size cell batteries.

Evaluation:

This change does not impact the intent or purpose of the emergency kit flashlights and maintains the function for the ERO to perform offsite monitoring tasks with the available equipment within the kits. This change meets the regulatory requirements of 10 CFR 50.47(b)(8) and 10 CFR 50 Appendix E, and maintains the effectiveness of the Emergency Plan.

ATTACHMENT 2 Serial No.: 25-046 Docket Nos.: 50-280/281, 72-2/55 SURRY POWER STATION EMERGENCY PLAN, REVISION 75, 10 CFR 50.54(g)

SUMMARY

Virginia Electric and Power Company (Dominion Energy Virginia}

Surry Power Station - Units 1 and 2 Surry Independent Spent Fuel Storage Installation

Serial No.: 25-046 Docket Nos.: 50-280/281, 72-2/55 Page 1 of 5 Surry Power Station Emergency Plan, Revision 75 1 10 CFR 50.54(9) Summary On February 4, 2025, Revision 75 of the Surry Power Station (SPS) Emergency Plan was implemented to incorporate the changes described below. These descriptions provide an explanation of why each change is not a reduction in effectiveness of the Emergency Plan, thus not requiring prior NRC approval, and the regulatory basis for each non-editorial change.

1. Section 1.2 Definitions. Corporate Emergency Response Center (CERC)

This change supports the V. C. Summer Nuclear Station (VCSNS) Emergency Operations Facility (EOF) move to the CERC by removing the specific references to SPS and North Anna Power Station (NAPS) and replacing them with "Dominion Nuclear Power Stations."

Corporate Emergency Response Center (CERC) -

Consolidated emergency operations facility for Dominion Nuclear Power Stations. Designated facility serving as the focal point for inter-company efforts implemented to support station emergency response actions and for dissemination of emergency information. The CERC is located at the Innsbrook Technical Center in Glen Allen, Virginia.

This administrative change maintains the effectiveness of the Emergency Plan.

2. Section 1.2 Definitions. Emergency Plan Implementing Procedures (EPIPs)

The definition of EPIPs was revised to include Controlled Supporting Documents.

Emergency Plan Implementing Procedures (EPIPs) -

Emergency response procedures including Controlled Supporting Documents that implement the Emergency Plan.

Common EPIPs used at NAPS, SPS, and Innsbrook Technical Center, as well as equivalent implementing procedures at VCSNS, are integrated into fleet common implementing procedures and labeled Controlled Supporting Documents.

The functions of the replaced implementing procedures are maintained. This change is administrative and maintains the effectiveness of the Emergency Plan.

Serial No.: 25-046 Docket Nos.: 50-280/281, 72-2/55 Page 2 of 5

3. Section 1.6 Acronyms and Abbreviations. CSD - Controlled Supporting Documents The definition of the acronym CSD was changed from "Cold Shutdown" to "Controlled Supporting Document." Cold Shutdown is not abbreviated with the acronym CSD in the current Emergency Plan revision, therefore there is no conflict with dual acronym usage with this change. This administrative change maintains the effectiveness of the Emergency Plan.
4. Section 6.3.1 Offsite Criteria for the 10 Mile Emergency Planning Zone (EPZ)

The 10-mile EPZ has been revised to replace sectors with Protective Action Zones (PAZs). The initial Protective Action Recommendation (PAR) for any event classified as a General Emergency will be to evacuate a two-mile radius and five miles in the downwind PAZs unless severe accident conditions exist, an evacuation dose threshold is exceeded beyond two miles, or sheltering-in-place is appropriate.

The PAZs represent the same criteria and logic (two-mile radius 360 degrees and from two to five miles in three downwind sectors). When the Commonwealth of Virginia receives the initial PAR, it converts the sectors into the affected PAZs. In collaboration with the Commonwealth of Virginia, SPS has agreed to provide future PARs directly as affected PAZs based on wind direction. This approach was developed to determine affected PAZs based on a keyhole area superimposed over an EPZ map.

Use of PAZs eliminates the need by the Commonwealth to convert a radius and sector recommendation into affected zones. The affected zones determined for each level of PAR (initial two-mile, expanded five-mile, expanded 10-mile, Rapidly Progressing Severe Accident (RPSA), and Hostile Action Based (HAB) Shelter) were determined based upon agreed strategies with the Offsite Response Organizations (OROs) and incorporate the results of the station Evacuation Time Estimate (ETE) in those strategies.

Evaluation:

The proposed change provides guidance equivalent to that provided in the current method to determine PARs using current meteorology.

Therefore, it satisfies regulations by maintaining the requirements of 10 CFR 50.47(b)(10) and 10 CFR 50 Appendix E. This change does not constitute a reduction in the ability to develop a PAR or reduce the effectiveness of the Emergency Plan.

5. Backup Emergency Notification Form Figure 6.1 Serial No.: 25-046 Docket Nos.: 50-280/281, 72-2/55 Page 3 of 5 The sample Backup Notification Form included in the applicable CSD was revised to incorporate the PAR logic change from downwind sectors to communicating PAZs. The Backup Emergency Notification Form maintains the capability and process for backup offsite notification, to maintain commitments for notifying offsite authorities in a timely manner.

Evaluation:

The proposed change meets the regulations by maintaining all the requirements of 10 CFR 50.47(b)(5), 10 CFR 50 Appendix E, and NUREG-0654. This change is not a reduction in the effectiveness of the Emergency Plan.

6. Protective Action Recommendation Figure 6.2 Based on agreement with the Commonwealth of Virginia, the PAR is now included on the offsite notification form distributed via the Dominion Energy Emergency Notification System (DEENS). Therefore, the separate attachment is no longer necessary.

Evaluation:

The notifications and communications procedure provides methods and processes to provide PARs within 15 minutes of a General Emergency, as required in regulation and committed to in the respective station emergency plans. The proposed change meets the regulations by maintaining all the requirements of 10 CFR 50.47(b)(5), 10 CFR 50 Appendix E, and NUREG-0654. This change is not a reduction in the effectiveness of the Emergency Plan.

7. Radiological Status Figure 6.4 The Radiological Status Form has been changed to add a Drill Message Field and an Emergency Message Field. These fields are used to designate the appropriate condition for when the form is used. This change is administrative and does not change the function of the form, therefore, it continues to maintain the purpose of reporting a radiological status to the Commonwealth.
8. 7.1.4 Corporate Emergency Response Center Serial No.: 25-046 Docket Nos.: 50-280/281, 72-2/55 Page 4 of 5 This change supports the VCSNS EOF move to the CERC by removing the specific refences to SPS and NAPS in Section 7.1.4 and replacing them with "Dominion Nuclear Power Stations."

The CERC is the consolidated EOF for Dominion Nuclear Power Stations. The CERC is located at the Innsbrook Technical Center in Glen Allen, Virginia. The facility provides workstations for Corporate, Federal and State officials who may be assembled at this location. This facility is the designated central collection point for the receipt and analysis of all field monitoring data and the coordination of sample media. Plant data is available from the Plant Computer System (PCS). The Meteorological Information and Dose Assessment System (MIDAS) is used to estimate offsite doses.

This administrative change maintains the effectiveness of the Emergency Plan.

9. Section 7.1.6 Alternate Facility When Under Threat or Experiencing Hostile Action The reference to the Surry Administrative Building was replaced by the facility name of the Surry Emergency Operations Center, which is where the staging area for augmentation of emergency response staff is located when under threat of or experiencing hostile action.

This change is administrative in nature.

It replaces the Administrative Building reference in section 7.1.6. The Surry County Emergency Operation Center remains the designated staging area, and the purpose of the procedure is maintained.

Therefore, this change maintains the effectiveness of the Emergency Plan.

10.Appendix 10.5 List of Emergency Plan Implementing Procedures The changes in Appendix 10.5, "List of Emergency Plan Implementing Procedures,"

are limited to replacing affected EPIPs that are now EP-AA-CSD-XXX procedures. The listing of Emergency Plan Implementing Procedures was changed to differentiate between implementing procedures that are labeled EPIP and CSD. This change is administrative and maintains the effectiveness of the Emergency Plan.

11.Appendix 10.7 Protective Equipment and Supplies Serial No.: 25-046 Docket Nos.: 50-280/281, 72-2/55 Page 5 of 5 This change is required to remove Anti-fog (1 bottle} from the Technical Support Center (TSC) Health Physics (HP) Kits. Since there are no respirators located in the new TSC the Anti-Fog may be removed from the emergency kit. The emergency kits in the TSC are maintained with adequate supplies to support emergency response.

Evaluation:

This change does not impact the intent or purpose of the emergency kit supplies and maintains the function for the Emergency Response Organization (ERO) to perform offsite monitoring tasks with the available equipment within the kits. This change is administrative and maintains the effectiveness of the Emergency Plan.