ML24087A218

(Vcsns), Unit 1 - License Amendment Request - Emergency Response Organization (ERO) Augmentation Time Change, Emergency Operations Facility Relocation and Other Emergency Plan Changes - Response to Request.

ML24087A218
Person / Time
Site:	Summer
Issue date:	03/26/2024
From:	James Holloway Dominion Energy South Carolina
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
24-087
Download: ML24087A218 (1)

Text

Dominion Energy South Carolina, Inc.

5000 Dominion Boulevard, Glen A llen, VA 23060 :f; Dominion DominionEnergy.com March 26, 2024 ii a,, Energy

Attn: Document Control Desk Serial No.: 24-087 U.S. Nuclear Regulatory Commission NRA/YG: RO Washington, DC 20555-0001 Docket No.: 50-395 License No.: NPF-12

DOMINION ENERG Y SOUTH CAROLINA (D ESC )

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 LICENSE AM E NDMENT REQUEST - EMERGENC Y RESPONSE ORGANIZATION (ERO) AUGMENTATION TIM E CHANG E, EMERG ENCY OPERATIONS FACILITY R EL OCATION AND OTH ER EMERGENCY PLAN CHANGES RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAil

By letter dated June 8, 2023 (Agencywide Document Access and Management System Package Accession No. ML23159A233), Dominion Energy South Carolina, Inc. (DESC),

submitted a license a mendment request (LAR) to revise the Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Emergency Plan to the U.S. Nuclear Regulatory Commission (NRC) for prior review and approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR).

In an email dated March 1, 2023, from Ed Miller, NRC Senior Project Ma n a ger, to Yan Gao of Dominion Energy, the Nuclear Regulatory Commission (NRC) staff requested additional information (RAI) to facilitate their review of the subject LAR. The NRC's RAI and the DESC responses are provided in Attachment 1 to this letter.

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

Respectfully,

Ja~~

Vice President - Nuclear Engineering and Fleet Support

COMMONWEAL TH OF VIRGINIA

COUNTY OF HENRICO

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by James E.

Holloway, who is Vice President - Nuclear Engineering and Fleet Support of Dominion Energy South Carolina, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document on behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this u-r~ day of r4are-k 2024.

My Commission Expires: ii.( "3{ };..:/ l

CRAIG D SLY Notary Public Commonwealth of Virginia My Commission EReg.# 7518653 !J.~-xpires December 31, 2u _

Serial No.24-087 Docket No. 50- 395 Page 2 of 2

Commitments made in this letter:

The response to RAl-6 in Attachment 1 provides a commitment that DESC will conduct a drill involving CERC response to simultaneous events at more than one nuclear power plant. Details are provided in the RAl-6a and RAl-6b responses.

Attachment:

1. Response to NRC Request for Additional Information

cc: U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. G. Edward Miller NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Zach M. Turner NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-08 B01A 11555 Rockville Pike Rockville, Maryland 20852-2738 NRC Senior Resident Inspector V.C. Summer Nuclear Station Mr. Nathan Gauthier Section Manager Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Mr. G. J. Lindamood Santee Cooper - Nuclear Coordinator 1 Riverwood Drive Moncks Corner, SC 29461 Serial No.24-087 Docket No. 50-395

Attachment 1

Response to NRC Request for Additional Information

Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Dominion Energy South Carolina, Inc. (DESC)

Serial No.24-087 Docket No. 50-395 Attachment _ 1: Page 1 of 18

TABLE OF CONTENTS

1.0 BACKGROUND

............................................................................................................... 2 2.0 NRC RAls and Responses.............................................................................................. 2 RAl-1..................................................................................................................................... 2 RAl-2(a)................................................................................................................................. 7 RAl-2 (b)................................................................................................................................. 7 RAl-4(a)(b)(c)(d)(e)................................................................................................................ 9 RAl-5(b)................................................................................................................................ 13 RAl-6 (New RAI)................................................................................................................... 14

3.0 REFERENCES

............................................................................................................... 18 Serial No.24-087 Docket Nos. 50-395 Attachment 1 : Page 2 of 18

RESPONSE TO REQUEST FOR ADDITIONAL IN FORMA TION LIC ENSE AMENDMENT REQUEST - EMERGENC Y RESPONSE ORGANI ZATI ON

( ERO ) AUGMENTATION TIME CHANGE, EMERGEN CY OPERATIONS FACILITY RELOCA TION AND OTHER EMERGENC Y PLAN CHANG ES

1.0 BA CKGROUND

By letter dated June 8, 2023 (Agencywide Document Access and Management System Package Accession No. ML23159A233) [3.1 ], Dominion Energy South Carolina, Inc.

(DESC), submitted a license amendment request (LAR) to revise the Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Emergency Plan to the U.S. Nuclear Regulatory Commission (NRC) for prior review and approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). The NRC staff has reviewed the LAR and generated a request for additional information (RAI) [3.2] to complete their review.

Section 2 below provides the RAI descriptions and the corresponding DESC responses.

2.0 NRC RAls and Responses

RAl-1

==

Description:==

"The DESC response to round 1 RAl-1 indicates the proposed changes rely upon unique design characteristics to provide relief for the Shift Manager or Emergency Director functions (command and control) for 90 minutes as indicated in Table B-1 a of the VCSNS Emergency Plan.

Because the response to RAl-1 relies upon unique design characteristics and those unique design characteristics are not significantly different from other nuclear power stations. in addition, the design characteristics were already in existence prior to publishing of NUREG-0654. Rev. 2. DESC does not have relief for the Shift Manager or Emergency Director to perform the command-and-control function within 60 minutes, RA/-

1 is clarified as follows:

Clarification of RAl-1: Provide clarification indicating how the Shift Manager will be relieved of either the Shift Manager or Emergency Director function (command and control) within 60 minutes of an alert or higher emergency classification."

Response

The VCSNS staffing plans allow for separation of responsibilities between performance of the Operations Shift Manager and Interim Station Emergency Manager (ISEM) functions. The individual performing the Operations Shift Manager role prior to an event assumes ISEM responsibilities at the onset of the event, and a Unit Supervisor assumes

Note: RAI texts are italic and underlined Serial No. 24- 087 Docket No. 50-395 Attachment 1 : Page 3 of 18

the responsibilities of the Operations Shift Manager. This ch a nge in roles relieves the Unit Supervisor, who is performing Opera tions Shift Manager oversight a nd controlling unit operation, of the colla teral duties of the ISEM function during the first 60 minu tes.

The Dominion Fleet Procedure for Conduct of Operations currently provides for this tra nsition of responsibilities. The only authority the Unit Supervisor does not assume from the Operations Shift Manager is approval of actions in accordance with 10 CFR 50.54(x) and overall event supervision.

Part 2, Section B.5.a.1) of the VCSNS Emergency Plan lists responsibilities of the ISEM.

In the proposed VCSNS Emergency Plan, Shift Manager duties outside of emergency response were deleted to remove those responsibilities assumed by the Unit Supervisor.

DESC proposes to further clarify the ISEM role in Section 8.5. a.1) by including the responsibilities maintained by the ISEM during event response. T a ble 1 below summarizes the proposed changes. Additionally, Table 1 describes which ISEM activities would be supported by other on -shift resources, including the Shift Technical Advisor (STA) and Emergency Communicator.

DESC proposes to revise Part 2, Section 8.5.a.1) (see Table 2 below) of the Emergency Plan to align with the list of responsibilities in Table 1.

In conclusion, the individual performing the Operations Shift Manager role assumes ISEM responsibilities at the onset of the event, and a Unit Supervisor assumes the responsibilities of Operations Shift Manager. The Unit Supervisor provides relief of Operations Shift Manager responsibilities when the Operations Shift Manager transitions to the ISEM role, with two exceptions noted previously. ISEM activities are also supported by other on-shift resources such as the STA and the Emergency Communicator.

Therefore, the proposed approach continues to ensure adequate relief of the colla teral duties of the ISEM function for the acting Operations Shift Manager, during the first 60 minutes of the event.

Table 1 - Summary of Proposed Changes to Part 2, Section 8.5.a.1) of VCSNS Emergency Plan No. Function ISEM Description Responsibility 1 Directs activities of the N Qualified SRO assuming the operating crew. responsibilities of plant oversiaht.

2 Reactor Shutdown based N Qualified SRO assuming the on exceedance of operating responsibilities of plant parameters. oversight.

3 Review of post trip causal N Qualified SRO assuming the evaluations prior to unit responsibilities of plant restart. oversiaht.

4 Provide reactor oversite N Qualified SRO assuming the during unit start up a nd responsibilities of plant power chanaes. oversiaht.

Serial No.24-087 Docket No. 50-395 Attachment 1 : Page 4 of 18

Table 1 (continued) - Summary of Proposed Changes to Part 2, Section 8.5.a.1) of VCSNS Emergency Plan No. Function ISEM Description Responsibility 5 Adherence to site Technical N Qualified SRO assuming the Specifications. responsibilities of plant oversight.

6 Adherence to unit operating N Qualified SRO assuming the procedures. responsibilities of plant oversight.

7 Supervision of Control N Qualified SRO assuming the Room crew. responsibilities of plant oversight.

8 Identification of applicable y Non-delegable duty of the ISEM.

Emergency Action Levels - Activity is supported by the and event classification. STA who keeps the ISEM informed of changing plant conditions 9 Activation of the ERO. y Non-delegable duty of the ISEM.

- Performed by on-shift Emergency Communicator, as this is a subset of implementation of the offsite notification process.

10 Supervision of Control y Supervision of Emergency Room Communicator and Communicator and electrician 60-minute responders. and mechanic augmented at 60 minutes to initiate troubleshooting as aooropriate.

11 Initiation of onsite protective y Non-delegable duty of the ISEM.

actions.

12 Authorization of emergency y Non-delegable duty of the ISEM.

exposure limits.

13 Approve and implement y Function retained by ISEM as emergency special senior manager in accordance procedures under the with administrative procedure provisions of 10 CFR OP-AA-100.

50.54(x).

Serial No.24-087 Docket No. 50-395 Attachment 1 : Page 5 of 18

Table 2 - Proposed Changes to Part 2, Section 8.5.a.1) of VCSNS Emergency Plan

Part 2: Plan ning Standar ds and Criteria V. C. Summer Nuclea r Station

All QRB:il,e ERO personnel shall ha ve the authority to perform ass igned duties in a m anner consi stent with the objectives of this plan. In addition to m aintainin g adequate documentatio n of the event, position responsibilities include :

1) Shift Manag er (I nterim Stqtjon Emergency Manaoe r9iHttittfl CR A Shift Manager is on duty 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and is the ISEMQ in a declared em ergen cy untD relieved of this function by the TSC a nd CERC. While serving in this capa city, the ISEM <"'~jft U aRll!j'iF is responsible for.

• Event classification

• Activating the ERO (as deemed appropriate or as procedurally required).

• Initiating the NR C Emerge ncy R esponse Data System (EROS).

• PeFftllfRiR!I Oleee lluliee e lltiirlell fer lhe &EMEQ, EQF MOAB!!BF, Sfl!l Cf!UEC O <;u pervision of the contr ol roo m comm u nica tor and 60-rninute respond ers.

• In itiation of onsi te protective a ction s.

• Authorization of em ergency ex posure limits.

• Appro ve and implement emergency specia l pro c ed u res as required u nde r the provision of 10 CFR 50.54(X).

J:l'le BR !lift;' &ltiil MBRB!!Bf ilireolo YIB eoli'ililiBB Bf tl'lo OflBFBliR!I OFBl/i' &nil ie FBBflBRBilillo fer lho eefo BflOFBliBR Bf tAe,ilonl iR 8Bll'lflU8fllD *,~ "18 HA R ~IRG llfHlraliA!I lic1n1&11 a Rd the 'olAit 11paratin!I prosed* 'Fili T he ISEM returns to the Shift Man ag er ro le; after relinquishing event command and control, a n d funcfionaDy reports to the SE MeG in the TSC until the even t is termina ted.

The Shift Man ager ' s R!spo nsibRilies, when net 11'1 Gemm ans anll oonti:el, are G88&ribed belew :

• ll:!e a l/Ul9my and r-espon~ilily 18 shYlll9'1.'R 11:te reacler 'JitlBR GBIBFA'liRBG lhal the lliHBI}' 8f Ille r-eacler is in jBOpardy BF WRBR 8fl8FaYA9 flaJaRlBI0RI BXGBBG any Qf fli!e reeeler 11releotien eireltit oet,oiflle BAIi BlffBll'l&lia el'llftllevRl lleee nel BBBIII'.

t +8 8RBNF8 8 f81Ji9Y/ ttae ~BBR 08Alplel88 le llolalWliAO i-le BiF&IBMBBAIB, BEIUBB J Bflll liFMB lfflllerw hioh OflOF9tiOAO BM DMBly flFBOOBll bofere l:ho F898lBFie f4!M"ABII W pg:ruur foDg, sriRg a tRp o r an 11qrcbed1ded or UAi')(f11ain8Q pg,,rer reducticq

• ll:!e rDllpensibility te be p r86ent at tile plant and kl flf8'Jide elrelllien f.8r retuming Ille rea cl9r kl poi.i,,ar f.8118'.lling a trip er an 1rnsshed1,1led or 1mex plained fl8\\\\'BF red1,1soon.

• ll:!e responsibility le as her-e 19 the 1,1nil Tecl=lnisal Spesilisatiens aml lo re'liev.i roUline e11eretin!I llele lo BDBHFB oefe e11efilltien

e i:l'le fBBjlBABibilit;i lo illenlwj 01111lieeble E,A,ba BRll Oll'IOf!IORIY oleoeifieetiono

Page 24 of 198 EP-10 0 Rev XX Serial No.24-087 Docket No. 50-395 Attachment 1: Page 6 of 18

Table 2 (continued) - Proposed Changes to Part 2, Section 8.5.a.1) of VCSNS Emen::iencv Plan

Part 2: Planning Standards and Criteria V. C. Su mmer Nu clea r Station

n l=he fi88jl8Aeiliilily le 88A8F8 to lelRit OJIOFBliRg preee!llfl'BO en!I il<lo FBlllfiFBIMBR~B Jor il<leir 1e1ee. 9itFiAg en ernergllf!ey, e1r.tllerii!e epeHtliene 11ereenAel le !le11e1t fl'ilM appliOU O~ pro&liMiJWMi& u SAore AOGOlaGiiiPJ '" preHiRI iAJU '¥ to Pi'R.OARel, iJlGl!tdiAg tl:le p11tlRG, er damage \\e tile faGility Goosi61ent witJl the FBQYifenu1r:Ils Bf 1Q CFR 5Q.54(ll) and M-

• lllitiale immegiale OOITTIGtille actioos le limit er G9Rlain Die emergency inwkin g tf:le J!Fll'liBiBRB Bf 19 ef.1-l. li9.li4fn) if epprepHIM8, and 0JI0MiBelly \\IIABFI it!l!lree&ing

~

• AppFe'.18 81MOFgilAOY 8jl BBi8I JIF888dlfl'BO, 8Ad iA'lplBAlBAl O.B Fill!leliFed lelA!IBF ~B prg>JilliColAI gf 10 C~~ 50 54,ll~

0 &UJIBFYiBB 818 BBliYiMB8 Bf lhe fseRIFof liiloent BfilJl.W 8.tU~ 1MB SORlrtllffli&et8Fe

e IRiaalu QRGite p~tustiuo aGfiiQAli; inGIWfifing au&Ros:i.atioA of 8Xpof'!IPI DPlHC for emergenGY werkeffi in 8)16866 Bf oormal slatioo limits

2) station Em ergen cy Manage ~ (S EMQ.) TS C The SEMEQ.supervises an d direc ts the Onsite ERO. The S EMEQ-' s responsil>ilroes include organizing and coord inating the on.site emergency efforts. A d<fll:ionaly, the SE MeQ. has the requ isite authority, plant operating experience, and qualfication s to implement in-plant recovery o perations. The S EMeQ. is respons ible for relieving the I SEM9 of dassifying emergencies, and other non-delegable duties.

SJ LiRDFQDR8\\1 PffiB8:F8EIFIB08 AdYliBer TeG

r;11e i!P Adyjeer repelte le tills i!Q eAd io ree11ene illle fer 11!1111ioin!I en!I BlfflJ!OMg 3:le J:i'C eR iilAJU!,QUAGY pJaA aGtiORli iHUi fU8pOR8fl8s a'it,ciciRg lt:te E30 OR regulatocy cequiwrwents, and intecfadng urJlh the FAE gr ollGita OF9&a'atism& soakin§i eR&.itu iRfel'RlatieR er data. The lt.d*Jiser is al&e respeAsitlle fGr oo ~f}letiAg ti:le Emer!JBAcy

~lotilicatien Fo r:ms, 0 '18F&iglll 8f ti:le a cliens taken by tf:le ala-l&JCeunty CeRl!llu n isateF& iR swppert of nelifisaaons.

..3i) Radiological Assessment Director (RAD ) SlfBBMBBF TSC The Radiologica l Assessmen t Oirecto r1e1pof'llieer reports to fhe SE~ and supervises the a ctivities of the o nsite radiological assessments. The su pervisor directs the staff in determining the extent and nature of radiologica l or hazardou s material problems on site.

4) pose APerforms dose asses sm ent upo n augmentation until ssessmen tTeam Leader rsrelieved by the Dose Assessor c

in the CERC. Maintains contact with a nd transmits instructions to the Offsite Monitoring teams and o pe rates the dose a ssessment prog ram. The Dose Assessmen t T eam Leader interprets radio logical da ta from the offsite mon itoring tea m s reports the results of the offsite releases and PARs based on dose pro jection s to the RAD.

5) Offsite Moni toring Teams TSC Tea ms report to the Dose Assessment Team Le ad er in the TSC or the Accident Assessment Team Le.ad er in the CERC. Teams provide offsite monitoring and sa m ple collection as needed.

Page 25 of 198 EP-100 Rev XX Serial No. 24- 087 Docket No. 50- 395 Attachment 1 : Pag e 7 of 18

RA l-2 (a )

Description "The DESC response to round 1 RAl-2(a) indicates that the Radiation Protection (RP) qualified individuals are personnel included in the VCSNS Health Physics (HP) Training Program and who are task qualified to perform RP Technician activities.

Because the response to RAl-2(a) does not provide sufficient justification to demonstrate that the RP qualified individuals are fully qualified RP technicians. RAl-2 is clarified as follows:

Clarification RAl-2(a): Provide documentation indicating how the RP qualified individuals are fully qualified RP Technicians per 10 CFR 50.120."

Res pon se DESC proposes to revise Table B-1A of the proposed VCSNS Emergency Plan to indicate that personnel providing ln -plant/Onsite (out-of-plant) surveys and protective actions are RP Technicians. RP Technicians at VCSNS ar e qualified in accordance with the INPO Accredited Training program for RP Technicians, thereby m ee ting the requirements of 10 CFR 50.120.

RA l-2 (b)

==

Description:==

"The DESC response to round 1 RAl-2(b) indicates that the proposed change will rely on the use of improvements in dose assessment software and use of an alarming electronic dosimeter and electronic Radiation Work Permits to allow one RP qualified individual to perform both dose assessment and dosimetry/access control functions.

Because the response to RAl-2(b) does not provide sufficient iustification to demonstrate how the VCSNS Emergency Plan will maintain two RP qualified individuals that are able to provide radiation protection iob coverage for unknown radiological environments or in plant surveys under emergency conditions. RAl-2(b) is clarified as follows:

Clarification RAl-2(b): Provide clarification indicating how DESC will provide for two RP qualified individuals to perform the RP functions that include the following elements:

• Capability to provide coverage for responders accessing potentially unknown radiological environments during emergency conditions.

• Capability to monitor radiation levels to support individuals performing activities in response to a radiological event.

• Capability to monitor the dose received by workers performing activities in response to a radiological event.

Serial No.24-087 Docket No. 50-395 Attachment 1 : Page 8 of 18

• Capability to establish and perform radiation surveys and establish radiation monitoring and oversight capability for areas that were not established at the initiation of a radiological event."

Re s ponse As noted in the response to RAl-2(a), DESC proposes to replace the reference to 'RP qualified individuals' with 'RP Technicians." Responsibilities for the two RP Technicians on-shift, consistent with Table 8-1 of NUREG-0654, Revision 2, are assigned to ensure capability for performance of job coverage, radiological monitoring, tracking dose received by in-plant workers and in areas not established at the initiation of an event are maintained. Specific activities completed by each of the on-shift RP Technicians are outlined in the Table 3 below.

Table 3 - On-Shift RP Technicians Responsibilities Activity RP Technician-1 RP Technician-2 Capability to provide coverage for responders accessing potentially unknown radiological X environments during emergency conditions.

Capability to monitor radiation levels to support individuals performing activities in response to X a radiological event.

Capability to monitor the dose received by workers performing activities in response to a X radiological event.

Capability to establish and perform radiation surveys and establish radiation monitoring and oversight capability for areas that were not X established at the initiation of a radiological event.

One RP Technician is responsible for monitoring in-plant radiolocial conditions until augmented at 60-minutes. 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 until augmented by additional RP Technicians. Auxiliary operators are dispatched to locations in accordance with the existing Emergency Operating Procedures/Abnormal Operating Procedures (EOPs/AOPs). As discussed in Attachment 1, Section 3.6 of the amendment request, these operators respond using pre-established Radiation Work Permits (RWPs). The in plant personnel are assigned automated dosimetry with pre-established limits and audible dose and dose rate alarms consistent with the RWPs. The use of pre-established RWPs and automated dosimetry reduces the time needed for dose monitoring by the RP Technicians allowing them to focus on job coverage and monitoring area radiation levels.

This is the case even if workers are in areas where pre-established electronic radiation monitoring is not available.

Serial No. 24- 087 Docket No. 50- 395 Attachment 1: Page 9 of 18

RA l-4 (a)(b)(c)(d)( e)

Des cription

"Round 1 RAl-4(a) was written to obtain iustification for the extension in response time from 60 to 90 minutes for electrical and mechanical engineers and technicians. Although DESC provided additional detail related to FLEX this detail was limited to high level comments.

Because the response indicates that the VCSNS FLEX Integrated Plan defines strategies capable of mitigating simultaneous loss of alternating current power and normal access to the ultimate heat sink resulting from a beyond-design -basis events, and relies on the three unique design characteristics describe in RAl-1, RAl-4(a)(b)(c) are clarified as follows:

Clarification RAl-4(a):

• Provide analysis or clarification that the FLEX strategies could be used to mitigate a radiological event for a wide spectrum of events and is not limited to the requirements of 10 CFR 50.155 and that the need for mechanical or electrical engineer input is no longer necessary at 60 minutes as a result of the FLEX strategies.

Clarification RAl-4(b):

• Provide analysis that demonstrates that there is sufficient staff on -shift to effectively implement the FLEX strategy and are trained on implementing the FLEX strategies so that the need for mechanical or electrical engineer coverage is no longer necessary at 60 minutes and can be extended to 90 minutes as a result of the FLEX strategies.

• Provide analysis that demonstrates that the equipment is sufficiently maintained and is reliable to iustify extending the response times of mechanical or electrical engineers from 60 to 90 minutes.

Clarification RAl-4(c):

• Provide sufficient technical iustification to demonstrate that engineering support would not be needed within 60 minutes for troubleshooting and/or repair activities for emergency core cooling system (EGGS) repair or event mitigation activities; or

• Provide analysis sufficient to show that troubleshooting and/or repair activities for EGGS repair or other event mitigation activities could be provided within 60 minutes prior to the arrival of engineering personnel.

Clarification RAl-4(d) and (e):

• Provide analysis to show that FLEX strategies are sufficiently effective and reliable and do not require support for EGGS equipment, event mitigation and equipment repair within 60 minutes from mechanical and electrical technicians.

Serial No.24-087 Docket No. 50-395 Attachment 1 : Page 10 of 18

• If the DESC FLEX strategies do not iustify extending the response times of mechanical and electrical maintenance technicians, clarify who will provide electrical and mechanical maintenance support for ECCS equipment, event mitigation and equipment repair within 60 minutes of an Alert or greater classification."

Responses:

RAl-4(a) response:

DESC proposes to clarify the use of FLEX strategies to mitigate radiological consequences from a wide spectrum of events and is not limited to responses as described in 10 CFR 50.155, obviating the need for engineering input at 60 minutes after an event.

Dominion emergency procedures used for standard plant responses and for the spectrum of accidents described in Section IV.C of NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants, have been revised to include transitions to the FLEX strategies and equipment. The procedure revisions provide access to expanded capability described in 10 CFR 50.155 for use in mitigating events described in 10 CFR 50.47 Appendix E, such as restoration of core cooling, containment integrity, and spent fuel cooling, regardless of the condition that initiated the event.

Because the procedures used by plant operations transition seamlessly to FLEX strategies, engineering input for connection of FLEX equipment and operation of plant systems using alternate means is no longer required at 60-minutes from event initiation.

RAl-4(b) response:

The FLEX Validation Study, completed in accordance with NEI 12-06 evaluated Time Sensitive Actions (TSAs) which included tasks, manual actions and decisions identified as time constraints in the Flex Integrated Plan. The validation assumes minimum site on shift staffing without augmentation for a 6-hour period. The results of the FLEX validation activities indicate that all time sensitive actions can be completed with margin available.

Training on implementation strategies is conducted in accordance with the Licensed Operator Requalification Training Program (VCS-TQP-0804), and the Emergency Response Organization Training Program Guide (TR-AA-TPG-2400). As a result, there is no longer a need for engineering coverage during the first 60-minutes after an event.

Preventive maintenance and testing requirements for FLEX equipment are established from templates contained in the Electric Power Research Institute (EPRI) Preventive Maintenance Basis Database, EPRI Technical Report 3002000623, "Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment" or from manufacturer provided information and recommendations. A FLEX equipment maintenance and testing program has been established in accordance with NEI 12-06, Section 11.5 as identified in the VCSNS NRC Safety Evaluation (dated August 1, 2017) related to orders EA-12-049 and EA-12-051. The periodic maintenance and testing program is controlled by fleet procedure ER-AA-102, "Preventive Maintenance Program."

Serial No. 24- 087 Docket No. 50- 395 Attachment 1 : Page 11 of 18

The maintenance and testing program ensures FLEX equipment reliability such that engineering support is no longer required during the first 60-minutes after an event.

RAl-4c response:

Dominion Fleet Procedure MA-AA-103, "Conduct of Troubleshooting" is performed by Operations and Maintenance. The overall process performed by the various involved departments can be summarized as:

1. Operations provides initial assessment and gathering of information,

2. Maintenance, using the data provided by Operations and working with input from Engineering, as needed, initiates recovery/repair plans for restoration,

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.

Per this procedure, initial troubleshooting is performed by maintenance personnel rather than engineering resources. As stated in RAl-4(d) response below, DESC proposes to augment one Electrician and one Mechanic at 60-minutes to initiate the troubleshooting process, thus negating the need for engineering resources during this period.

RAl-4(d) and RAl-4(e) responses:

Dominion proposes to revise the response to RAl-4(d) and (e). Table B-1a of the VCSNS Emergency Plan has been revised to reflect one electrician and one mechanic responding to the site within 60-minutes of an alert or higher classification. These resources report to the Operations Support Center (OSC) and will act under the direction of the ISEM until the OSC is activated. 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. A copy of the revised Table B-1a and Figure B-1b showing these 60-minute responders are included in Table 4 and Table 5 below.

Serial No.24-087 Docket No. 50- 395 Attachment 1 : Page 12 of 18

Table 4 - "Table B-1a" Marku

Part 2: Phmnin Standards o nd Criteria V. C. Summer Nuclear Statlo

Tab le B-1a: Staffin g Requiremen ts for the VCSN S ERO

Functional,._ M.,j~*T-

• En<rg cncy Pos lion s Soll.. so SW!ina llinutca....-

-~ (SRO) 1 - -

~ Dil'<dion<nl C""'3Jlwi<n0vcnighl Sla lon fa1cfgcn <)' v.n,gcr (TSCJ - - I Caitrr,j Emt,gtncy Opernliona Dn c!o< (TSC) - - I Tl!drioll S<JAll)ltM,m*g*r (CEile) - - I

~ c -~, - -

N<:Uleata'l& Liceft5ee,Loea/5W e & ~ Sl.>la'tccal~ (TSC) - - I

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Page 45 of 198 EP-1 00 Rev XX Serial No.24-087 Docket No. 50-395 Attachment 1 : Page 13 of 18

Table 5 - "Fi u re B-1 b" Marku

Part 2: Planni n g Sta n dards and Criteria V. C. Su m mer Nucle ar Statlo

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Pa ge 37 of 1 98 EP-100 R ev XX

RAl-5(b)

==

Description:==

"The DESC response to round 1 RAl-5(b) indicates the proposed changes would extend the electrical and mechanical technician response times from 60 to 90 minutes.

Because the response to RAl-5(b) indicates that the response provides the ability for diagnostic aspects and troubleshooting using existing procedures. but not the repair support needed to restore equipment needed for event mitigation. RAl-5(b) is clarified as follows:

Clarification RAl-5(b): Provide clarification indicating how the analysis of the procedures provides for the ability to maintain the Repair Team Activities function for equipment repair at 60 minutes from the Alert or greater emergency class declaration."

Serial No.24-087 Docket No. 50- 395 Attachment 1 : Pag e 14 of 18

Response :

As discussed in RAl-4 (d) and (e), Table B-1a of the VCSNS Emergency Plan has been revised to reflect one electrician and one mechanic responding to the site within 60-minutes of an Alert or higher classification to provide the repair support discussed in RAl-5b.

RA l-6 (New RA il

"During a review of the first round of RA/ responses one additional RA/ (new) was identified regarding the DESC proposed drill requiring Corporate Emergency Response Center (CE RC) activation for demonstrating ERO capability.

Regulation 10 CFR 50. Appendix E.8.c.3 requires a licensee's emergency operations facility to have 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.

Issue VCSNS LAR. attachment 1. section 3.10 states the following:

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

However. the scope of the drill does not specify that the drill will demonstrate the capability to support a response to events occurring simultaneously at more than one nuclear power reactor site.

In addition, Dominion's license amendment request dated January 16, 2018 (ML1802584680.) Attachment 1, "Discussion of Proposed Change," Section 1. 2, "Detailed Description of Change." states, Dominion Energy Virginia plans to conduct a proof-of-concept demonstration involving response to concurrent events requiring CERC activation with both NAPS and SPS.

It further states, In addition, the event at one of the two sites will affect multiple units.

This proof -of concept demonstration is scheduled for March 5. 2018, and may be observed by NRG staff.

Additionally. in a response to a request for additional information dated June 13. 2018 (ML18169A224). Dominion stated in Attachment 2, "Marked-up NAPS {North Anna Power Station[ Emergency Plan Changes," Section 8. 5, "Emergency Drills." states.

Serial No.24-087 Docket No. 50-395 Attachment 1 : Page 15 of 18

At least once every eight-year exercise cycle. at least one drill shall be conducted involving CERC response to simultaneous events at North Anna Power Station and Surry Power Station.

Request

a. Provide evidence to demonstrate that the scope of the drill includes the demonstration of the capability of the CERC to support a response to events occurring simultaneously at more than one nuclear power reactor site if the CERC serves more than one site.

b. Provide evidence that the scope of the drill will include an event at one of the sites that will affect multiple units."

c. Provide evidence that the VCSNS Emergency Plan be revised to include a statement similar the NAPS 8-y ear cycle?"

Res pon se:

RAl-6a response:

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 simultan eously 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 affected 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.

Serial No.24-087 Docket No. 50-395 Attachment 1 : Page 16 of 18

RAl-6b response:

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.

RAl-6c response:

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. The revision to Part 2, Section N.1 is provided in Table 6 below.

Serial No. 24- 087 Docket No. 50- 395 Attachm ent 1 : Pag e 17 of 18

Tabl e 6 - Pa rt 2, Section N.1 Revision Mark - up

Part 2: Planning Standar ds an d Criteria V.C. Sum mer Nuc lea r Station

Sec tion N: Drill and Exerc ise Pro g ram

This section describes the DriU and Exer cise Progra m that V CSN S has implemented to :

• V ertfy the adequacy of the Eme rgen cy Preparedness Program

• Develop, maintain, a nd evaluate the capabilities o f the ERO to respond to emergency conditions a nd safeguard the h ealth and sa fety of station personnel a nd the ge nera l public

• Identify deficiencies in the Em ergency Plan and its associ3led pro ce dur es, or in the training of response personnel, and en su re that they are promptly corre cted

• Identify deficiencies in the relationship be tween the Em ergency Plan and the V CSNS Security Plan and ensure that they are promptly co rrected

• En sure the continued adequacy of emergency fac Hllies, supp *es, and equipme n t, includlng c ommunications networks

1. Exer cises

Ex ercises pro vide a n opport u nity lo eva b.Jate the a b ility of pa rticipating organ izations to implement a coordinated response to postula ted emergen cy conditions. Pro visiooo wiD be made for qualified personne l from VCS NS, o ther commercial nu clear fac iities, or federa l, s!::lte, or loca l governments to obseN e and critique e ac h exercise as appropriate. Exerc ises are conducte d to ensure that all major elements of the emergency plan and prepa redness progr m a re demonstrated at least onc e in cy cle. Ea ch sce nario variation shall be demon strated a t least onc e durin g the cy cle and sha ll include, but not limited to, the fo owing :

• An off-hours exercise betwee n 6:00 p.m. an d 4:00 a.m. W eekends and ho lidays are also considere d off-hour periods.

• Hos ble action directed at the plant site involving the integration of o ffsite resour ces with onsite response ; VCSNS participates on a rota6ng basis with the other fixed n uclear fac ilities in the state of So uth Carol in a

• An initial classificatio n of, or ra pid escalation to Site Area Emer gency or Gener al Em ergen cy

• No rad iological release or a n u nplan n ed m inim al radiologica l release that requires the site to declare a Site Area Emergenc y, b ut do es n ot require dec laration of Gen era l Em ergency

• An ingestion pathway e xercises; V CSN S participates on a rota tin g basi s with the other fixed n ucle ar fac ilities in the state o f South Carolina

• At least on ce e very eight-year ex ercise cycl e, one drill shaU be c ond uct ed involvin g CERC response to concurrent events at multiple Dominion Units.

Page 111 o f 198 EP-1 00 R ev XX Serial No.24-087 Docket No. 50-395 Attachment 1 : Page 18 of 18

3.0 REFERENCES

3.1 ADAMS Accession No. ML23159A233, Dominion Energy South Carolina (DESC) license amendment request to revise the Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Emergency Plan, June 8, 2023 3.2 Email from Ed Miller (NRG) to Yan Gao of Dominion Energy regarding RAI for DESC Emergency Plan LAR, March 1, 2024