ML18025B488

Attachments 1 to 4: Proposed Consolidated Emergency Operations Facility

ML18025B488
Person / Time
Site:	Surry, North Anna, 07200002, 07200055, 05200017
Issue date:	01/16/2018
From:	Dominion Energy Services, Virginia Electric & Power Co (VEPCO)
To:	Office of Nuclear Material Safety and Safeguards, Office of New Reactors, Office of Nuclear Reactor Regulation
Shared Package
ML18025B468	List: ML18025B488 ML18025B491 ML18025B493
References
17-325
Download: ML18025B488 (246)

Text

S:S, 0om** Iii .. 1n1on P' Energy* Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Page 1 of 4 PROPOSED CONSOLIDATED EMERGENCY OPERATIONS FACILITY TABLE OF CONTENTS Serial No.17-352 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Page 2 of 4 ATIACHMENT 1 DISCUSSION OF PROPOSED CHANGE ........................................

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SUMMARY

DESCRIPTION

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........................... 1 1.1 HISTORY .....................

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1 1.2 DETAILED DESCRIPTION OF CHANGE ..............................

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3 2.0 EVALUATION

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..................................... 6 2.1 FUNCTIONS

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............. 6 2.2 LOCATION, STRUCTURE, AND HABITABILITY

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11 2.3 STAFFING AND TRAINING .....................

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13 2.4 SIZE ........................

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............ 15 2.5 RADIOLOGICAL MONITORING

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......................... 21 2.6 COMMUNICATIONS

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21 2.7 INSTRUMENTATION, DATA SYSTEM EQUIPMENT, AND POWER SUPPLIES .....................

22 2.8 TECHNICAL DATA AND DATA SYSTEM ...........................................

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23 2.9 RECORDS AVAILABILITY AND MANAGEMENT

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3.0 CONCLUSION

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... 24 4.0 JUSTIFICATION

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24 5.0 NO SIGNIFICANT HAZARDS CONSIDERATION

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26 6.0 ENVIRONMENTAL CONSIDERATION

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27 7 .0 REFERENCES

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28 ATTACHMENT 2 DISPOSITION OF CORPORATE EMERGENCY RESPONSE PLAN CONTENTS .........

1 ATIACHMENT 3 ADDITIONAL NAPS AND SPS EMERGENCY PLAN CHANGES REQUIRING NRC APPROVAL .......................................................................

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1.0 INTRODUCTION

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2.0 DESCRIPTION

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2 2.1 EMERGENCY RESPONSE ORGANIZATION AUGMENTATION AND EMERGENCY RESPONSE FACILITY ACTIVATION GOALS .................

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............ 2 2.2 ELIMINATION OF COUNTY RINGDOWN PHONES ..........................................................

.4 2.3 TRAINING EXEMPTION/EQUIVALENT 0UALIFICATION

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5 2.4 APPROVAL AUTHORITY FOR CHANGES TO EMERGENCY PLANS AND IMPLEMENTING PROCEDURES

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............ 6 2.5 MAINTENANCE OF EMERGENCY PLAN LETTERS OF AGREEMENT

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9 Serial No.17-352 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Page 3 of 4 2.6 EXPANDING THE TIME PERIOD FOR STARTING A DRILL OR EXERCISE OUTSIDE NORMAL WORKING HOURS ................................

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3.0 CONCLUSION

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11 4.0 JUSTIFICATION

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12 4.1 REQUIREMENTS AND GUIDANCE -CLARIFICATION OF ERO AUGMENTATION AND ERF ACTIVATION GOALS ...................................................................

............................ 12 4.2 ELIMINATION OF COUNTY RINGDOWN PHONES .........................

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12 4.3 REQUIREMENTS AND GUIDANCE -USE OF ADMINISTRATIVE PROCESSES FOR TRAINING EXEMPTIONS AND EQUIVALENT QUALIFICATIONS

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13 4.4 REQUIREMENTS AND GUIDANCE -APPROVAL AUTHORITY FOR EMERGENCY PLAN AND IMPLEMENTING PROCEDURE REVISIONS

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13 4.5 REQUIREMENTS AND GUIDANCE -MAINTENANCE OF EMERGENCY PLAN LETTERS OF AGREEMENT

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13 4.6 EXPANDING THE TIME PERIOD FOR STARTING A DRILL OR EXERCISE OUTSIDE NORMAL WORKING HOURS ................................

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.. 13 5.0 NO SIGNIFICANT HAZARDS CONSIDERATION

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............ 14 6.0 ENVIRONMENTAL CONSIDERATION

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7.0 REFERENCES

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....... 15 ATTACHMENT 4 MARKED-UP NAPS EMERGENCY PLAN PAGE CHANGES .......................

......... 1 ATIACHMENT 5 PROPOSED CHANGED NAPS EMERGENCY PLAN PAGES .................

............... 1 A TI ACHMENT 6 MARKED-UP SPS EMERGENCY PLAN PAGE CHANGES ...................

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... 1 AT T ACHMENT 7 PROPOSED CHANGED SPS EMERGENCY PLAN PAGES ............................

...... 1 ATIACHMENT 8 0FFSITE RESPONSE AGENCY LETTERS OF CONCURRENCE

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1 TABLE OF FIGURES Attachment 1 Serial No.17-352 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Page 4 of 4 FIGURE 2.4-1: LAYOUT OF PROPOSED CERC ..................................

.................................. 16 FIGURE 2.4-2: PROPOSED CERC COMMAND CENTER ..............

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18 FIGURE 2.4-3: VIDEO WALL DISPLAY (LEFT SIDE: NAPS-SPECIFIC SCREENS, RIGHT SIDE:SPS-SPECIFIC SCREENS) .............................

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.............. 18 FIGURE 2.4-4: CERC SURRY HEALTH PHYSICS ACCIDENT ASSESSMENT

& VIRGINIA RADIOLOGICAL HEAL TH WORK AREA IMAGE 1 ...............

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.......................... 19 FIGURE 2.4-5: CERC SURRY HEAL TH PHYSICS ACCIDENT ASSESSMENT

& VIRGINIA RADIOLOGICAL HEALTH WORK AREA IMAGE 2 ............................................

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... 19 FIGURE 2.4-6: CERC NORTH ANNA HEAL TH PHYSICS ACCIDENT ASSESSMENT

& VIRGINIA RADIOLOGICAL HEALTH WORK AREA IMAGE 1 ..............................

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20 FIGURE 2.4-7: CERC NORTH ANNA HEALTH PHYSICS ACCIDENT ASSESSMENT

& VIRGINIA RADIOLOGICAL HEAL TH WORK AREA IMAGE 2 ...................

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....................... 20 FIGURE 2.4-8: PROPOSED CERC GOVERNMENT AFFAIRS, MEDIA MONITORING AND NEWS ROOM IMAGES .............

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..................... 21 TABLE OF TABLES Attachment 1 TABLE 1.2-1: DECLARATIONS THAT REQUIRE EOF ACTIVATION

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.4 TABLE 1.2-2: NRC CONSOLIDATED EOFs LOCATED >25 Ml. FROM STATION ..........................

5 TABLE 2.1-1: RESPONSIBILITIES FOR KEY FUNCTIONS

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....... ? TABLE 2.3-1: CURRENT AND PROPOSED CERC STAFFING FOR ACTIVATION

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..... 13 TABLE 2.3-2: RESPONSIBILITY FOR NEI 99-02 KEY EOF FUNCTIONS

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............... 15 TABLE 2.4-1: DESCRIPTION OF EACH AREA IN THE PROPOSED CERC LAYOUT ....................

17 Attachment 2 TABLE 2.0-1 DISPOSITION OF EMERGENCY RESPONSE PLAN CONTENTS .........................

....... 1 Attachment 1 Discussion of Proposed Change Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 1.0

SUMMARY

DESCRIPTION Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 1 of 30 This evaluation supports a request to establish a consolidated emergency operations facility (EOF) for North Anna Power Station (NAPS) Unit Nos. 1 and 2, and Surry Power Station (SPS) Unit Nos. 1 and 2. The consolidated EOF will hereinafter be referred to as the Corporate Emergency Response Center (CERC). The proposed CERC will re p lace the existing NAPS and SPS local EOFs , and their common back-up central EOF and headquarters support organization.

The proposed CERC is approximately 30 miles from the NAPS Technical Support Center (TSC) and approximately 59 miles from the SPS TSC. A license amendment is required to request Commission approval for locating an EOF greater than 25 miles from a nuclear power reactor site per 10 CFR 50, A p pendix E ,Section IV.E.8.b.

1.1 HISTORY

The SPS Units 1 & 2 Safety Evaluation Report (SER) dated February 23 , 1972, and the NAPS Units 1 & 2 SER (NUREG-0053) dated June 4, 1976, were issued before requirements for EOFs were developed.

NUREG-0053, Supplement 11 (August 1980) for NAPS Unit 2 described the [interim]

EOF as being in the North Anna Visitors Center (within 1 mile of the station) and its alternate at the Louisa County Courthouse complex (approximately 9 miles from the site). Pursuant to the 1980 EP-rule change , the NAPS and SPS emergency plans were upgraded with provisions for performing EOF functions, with the CERP containing additional information. Generic Letter 80-73, "Functional Criteria for Emergency Response Facilities

," NUREG-0696, dated August 1 , 1980 , provided draft EOF criteria for comment. On October 31, 1980 , Generic Letter 80-90, "Post-TMI

[Three Mile Island] Requirements," NUREG-0737, was issued and indicated that additional guidance on the emergency response fac i lities (Section 111.A.1.2) would be forwarded separately at a later date. A draft-NUREG 0696, " Functional Criteria for Emergency Response Facilities," implementation plan for NAPS and SPS was submitted on December 18 , 1980 , ind i cating that details on EOFs would be provided in a future revision to the plan. Generic Letter 81-10, " Post-TMI Requirements for the Emergency Operations Facility," dat e d February 18, 1981, provided additional information (NUREG 0696 Revision 0). Revision 1 to the NUREG-0696 Implementation Plan was forwarded to the Nuclear Regulatory Commission (NRC) on June 1, 1981. The NRC's response dated November 23, 1981 indicated additional information was needed. Additional guidance was pro v ided by NRC Region II letters dated January 29 and February 12, 1982. A pro p osed EOF plan was provided by letter dated April 8 , 1982 , and supplemented by letter dated December 6, 1982. NRC conducted appraisals of the NAPS and SPS emergency preparedness programs during February 16-26 and March 15-26, 1982, respectively (reference NRC Inspection Reports 50-338, -339/82-05 and 50-280, -281/82-05 , respectively). Items identified during the appraisals were incorporated into the NAPS and SPS emergency plans and Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 2 of 30 their implementing procedure sets. The post-EP appraisal NAPS emergency plan dated J u ly 22 , 1982 (Revision

0) referred to the interim [EOF] facility and described engineering conceptual studies for an EOF in the General Office in Richmond and a separate EOF on the station property.

The post-EP Appraisal SPS Emergency Plan d a ted July 29 , 1982 (revisions earlier than 33 were not numbered , but this is considered Revision 0) referred to an interim [EOF] facility in the Surry Simulator Building.

Generic Letter 82-33, " Supplement 1 to NUREG-0737 -Emergency Response Capability," dated December 17 , 1982 , provided clarification of TMI action plan requirements for EOFs. In reply to Generic Letter 82-33 , the plan for a near-site EOF and back-up central EOF were provided by letters dated April 14 and May 6, 1983. The location of the primary NAPS EOF was identified as onsite 0.25 miles from the reactor co n tainment and the primary EOF for the Surry site was identified as onsite 0.2 miles from containment.

The common back-up EOF location was identified as 43 miles from NAPS and 51 miles from SPS at the Headquarters Emergency Cente r in downtown Richmond, Virginia.

Completion of NUREG-0737 , Item 111.A.2.1 , Emergency Preparedness, Upgrade Emergency Plans to Appendix E , 10 CFR 50 , was documented in NRC letters dated May 10, 1983 for NAPS and May 13 , 1983 for SPS. NRC letter da t ed January 13 , 1984 advised that the Commission found the location of the back-up and primary EOFs for NAPS and SPS described in the referenced letters acceptable.

Th e SPS emergency plan dated June 28 , 1984 (unnumbered , Revision 15) referred to space on the 5th Floor of Corporate Headquarters in Richmond as the location for headquarters support and the back-up EOF. The NAPS emergency plan dated Se p tember 27 , 1984 (Revision

8) referred to an area on the 5th floor of One James River Plaza in downtown Richmond as the location for headquarters support and the back-up EOF. Completion of NUREG-0737 , Item 111.A.1.2, Emergency Preparedness , Upgrade Emergency Response Facilities , was documented for NAPS by NRC letter dated May 25 , 1987 and for SPS by NRC letter dated June 12, 1987. The common back-up EOF was relocated to the Innsbrook Technical Center (ITC) in Glen Allen , Virginia , approximately 30 miles from NAPS and 59 miles from SPS , on September 16 , 1988. Letter dated Septembe r 14, 1988, Corporate Emergency Operations Facility Relocation, informed the NRC Region II Emergency Preparedness and Radiological Protection Acting Branch Chief of this modification , wi t h copies to the NRC Document Control Desk , and NAPS and SPS NRC Resident Inspec t ors. The ITC is t h e same building that Dominion is proposing to locate the proposed CERC. The SPS emergency plan dated April 27 , 1989 (unnumbered , Revision 32) and the NAPS emergency plan dated October 2, 1989 (Revision

12) identified the ITC as the location for headquarters support and the back-up EOF. The current emergency plans (NAPS Emergency Plan Revision 44 (effective February 2 , 2017) and SPS Emergency Plan Revision 63 ( effective March 16 , 2017) continue to referen c e ITC as the location of the back-up EOF. The back-up EOF, with site-specific remote mustering areas , satisfies the 10 CFR 50 , Appendix E ,Section IV.E.8.d requirement for an alternate facility when under threat or experiencing hostile action. A description of the alternate facility, limited to the Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 3 of 30 capabilities required by June 20, 2012, was added to the NAPS and SPS emergency plan dated December 21, 2012 (Revisions 38 and 58 , respectively) and updated with capabilities required by December 23 , 2014 in the current emergency plans (NAPS Emergency Plan Revision 44 (effective February 2 , 2017) and SPS Emergency Plan Revision 63 ( effective March 16, 2017). The central EOF staff has successfully demonstrated the ability to manage emergency response during several simulated response activities (e.g., SPS off-year exercise conducted November 13, 1996; NAPS off-year emergency exercise conducted November 12 , 2003; SPS hostile action based drill conducted December 2, 2008; and NAPS Biennial Exercise conducted July 8 , 2014 ). Section 13.3 of the NAPS Updated Final Safety Analysis Report (UFSAR) and Section 12.3 of the SPS UFSAR briefly refer to "a comprehensive Corporate Emergency Response Plan (CERP) and a site specific Station Emergency Plan." The CERP provides the organizational descriptions for the EOF emergency response organization (ERO), the Joint Information Center (JIG) and for headquarters support. Corporate plan implementing procedures (CPIPs) provide detailed instructions for managing emergency response at the local EOFs and the back-up central EOF, and for headquarters support, including interface with the JIG. Select site-specific emergency plan implementing procedures (EPIPs) are used in the local EOFs and the back-up central EOF to formulate offsite protective action recommendations (PARs), prepare and transmit emergency messages to the Commonwealth of V i rginia and NAPS and SPS plume exposure pathway risk jurisdictions, and assess offsite radiological consequences.

These are the same EPIPs used by the NAPS and SPS Control Rooms/Health Physics Offices and TSCs when these facilities perform the associated functions.

Dominion Energy Virginia proposes to incorporate applicable CERP contents into the NAPS and SPS emergency plans. Attachment 2 provides a table indicating where this information is proposed to be relocated or where it has been determined to be duplicative to existing NAPS and SPS emergency plan content. Attachments 4 and 6 contain proposed marked-up NAPS and SPS emergency plan page changes. Attachments 5 and 7 contain proposed changed NAPS and SPS emergency plan pages. NAPS and SPS Emergency Plans and sets, although site-specific and approved by station personnel , are prepared by Nuclear Fleet Emergency Preparedness staff. This support relationship assures that their content will remain in alignment.

1.2 DETAIL

E D DESCRIPTION OF CHANGE The proposed consolidation is expected to have the following positive effects on the emergency response capability of both stations:

• Enhanced availability for emergency response by relocating the EOF away from a reactor site that could be affected by a large scale external event , hostile action , or radioactivity release; Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 4 of 30

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

• Increased efficiency through the consolidation of EOF functions and headquarters support in a single facility.

The greater distance involved in the proposed p l an should not impede implementation of EOF funct i ons by NAPS and SPS EROs , or offsite response organizations , including the Commonwealth of Virginia Department of Emergency Management (VDEM), the Department of Health (VDH) Office of Radiological Health (ORH), or the NRC. Local governments do not send representatives to the existing local EOFs , so the distance to the proposed CERC does not impede their response. Mobilization time of VDEM and VDH responders will be improved due to relative proximity of the i r normal offices to the ITC. Likewise , due to the relative proximity to the Richmond International Concourse , the time it would take for the NRC Region II Incident Response Team to arrive at the consolidated EOF should be less than that needed to travel to either local EOF. Additionally , consolidation will obviate the need for VDEM , VDH and NRC to staff se p arate EOFs at both NAPS and SPS for simultaneous events. Although NUREG-0696 stated that activation of the EOF was optional at the Alert emergency class and required at the higher emergency classification levels, NAPS and SPS emergency plans provide for EOF activation after an Alert or higher emergency classification is declared.

The table below lists NAPS and SPS declarations that required EOF activation:

Table 1.2-1: Declarations That Require EOF Activation Date Station(s)

Emergency Class July 3 , 1980 North Anna Alert December 9 , 1986 Surry Alert July 15 , 1987 North Anna Al e rt February 25 , 1989 North Anna Alert April 24 , 1993 North Anna Alert October 7 , 2006 Surry Alert August 23, 2011 North Anna Al e rt The Mineral Virginia earthquake on August 23 , 2011 , whi c h precipitated declaration of an Alert at NAPS , led to declaration of a Notification of Unusual Event at SPS. The initial notification messages from the NAPS and SPS Control Rooms to the Commonwealth of Vi r ginia Emergency Operations Center (EO C) ove r lapped. This precluded th e Virginia EOC Duty Communications Officer from ac knowledging the roll call from one of the station's communicators due to receiv i ng noti fi cation from the other station. The proposed CERC's l ayout c o-loca t es site-specific communicators so Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 5 of 30 overlapping notifications can be avoided following activation of the consolidated EOF for concurrent events at NAPS and SPS. The NRG has approved 5 consolidated EOFs located more than 25 miles from some of the stations they support: Table 1.2-2: NRC Consolidated EOFs Located >25 mi. from Station NRC Region Location Utility Stations Coatesvi I le , Limerick I Exelon Peach Bottom Pennsylvania Three Mile Island Farley II Birmingham , Alabama Southern Nuclear Hatch Vogtle Brunswick Catawba Harris II Charlotte, North Carolina Duke Energy Lee McGuire Oconee Robinson Chattanooga , Tennessee Valley Browns Ferry II Tennessee Authority Sequoyah Watts Bar Braidwood Byron 111 Warrensville , Illinois Exelon Clinton Dresden LaSalle Quad-Cities More than 70 percent of the utilities in NRC Region II have approval to use a consolidated EOF, all of these with stations located in different states. The plume exposure pathways of both NAPS and SPS are entirely with i n the Commonwealth of Virginia.

The proximity of the proposed CERC to NAPS and SPS is within the range of distances for which consolidated EOF requests have been approved in the past. Dominion Energy Virginia plans to conduct a proo f-of-concept demonstra t ion involving response to concurrent events requiring CERC activation with both NAPS and SPS.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 6 of 30 The scope of the demonstration will require response to, and coordination of, response efforts for events occurring simultaneously at NAPS and SPS, specifically:

• Management of overall licensee emergency response,

• Coordination of radiological and environmental assessment,

• Determination of recommended public protective actions at NAPS and/or SPS,

• Notification of the Commonwealth of Virginia EOC, and both NAPS and SPS jurisdiction 911 Centers,

• Coordination of event, plant, and response information provided to public information staff for dissemination to the media and public,

• Staffing and activation of the facility within CERC activation time-frames for an Alert or higher emergency class as defined in the proposed emergency plans for NAPS and SPS,

• Coordination of emergency response activities with Federal, State, and local agencies,

• Obtaining and displaying key plant data and radiological information for the affected unit(s) at NAPS and SPS per the drill scenario, and

• Analyzing plant technical information and providing technical briefings on event conditions and prognosis to licensee staff and offsite agency responders for the affected unit(s) at NAPS and SPS per the drill scenario.

In addition, the event at one of the two sites will affect multiple units. This concept demonstration is scheduled for March 5, 2018 and may be observed by NRC staff. Federal Emergency Management Agency (FEMA) representatives will be afforded the opportunity to observe as well. Following approval, the CERC staff will participate in CERC activation drills, which will be conducted periodically in accordance with the NAPS and SPS emergency plans, including at least one involving response to simultaneous events at NAPS and SPS during each station's exercise cycle thereafter.

2.0 EVALUATION

NUREG-0696, "Functional Criteria for Emergency Response Facilities" (as updated by NSIR/DPR-ISG-01, "Emergency Planning for Nuclear Power Plants"), provides guidance for complying with 10 CFR 50, Appendix E, Section IV.E.8. The information provided in sections 2.1 through 2.9 below address this guidance to demonstrate acceptability of the proposed CERC with respect to the NAPS and SPS EOF attributes.

2.1 FUNCTIONS

Management of overall licensee emergency response Operation of the proposed CERC will not alter the overall approach to emergency response at NAPS and SPS. Established protocols currently contained in the CPIP-set will be relocated to the respective station's EPIP-sets.

NAPS and SPS EPIP-sets, although site-specific and approved by station personnel, are prepared by Nuclear Fleet Emergency Preparedness staff. This support relationship assures that content of EPIPs Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 7 of 30 used by the staff in the proposed CERC will be in alignment.

Current and proposed CERC responsibilities for Key functions are identified in the table below: Table 2.1-1: Responsibilities for Key Functions Key Function Current Responsibility Proposed Responsibility Approve PARs LEOF Recovery Manager 1 Site-specific CERC Technical Support Manager Prepare emergency LEOF State & Local Site-specific CERC State & messages Emergency Communicator2 Local Emergency Communicator Approve emergency LEOF Recovery Manager 1 Site-specific CERC Technical messages Support Manager Transmit emergency LEOF State & Local Site-specific CERC State & messages Emergency Communicator Local Emergency Communicator Assess radiological LEOF Radiological Site-specific CERC consequences Assessment Coordinator 3 Radiological Assessment Coordinator Review press releases LEOF Recovery Manager 1 Site-specific CERC Technical for technical accuracy Support Manager Approve press releases Senior headquarters support CERC Corporate Response position Manager The proposed CERC will be the primary facility for offsite PAR formulation; preparation and transmittal of emergency messages to the Commonwealth of Virginia EOC, and bo t h NAPS and SPS risk-jurisdiction 911 Centers/local EOCs; and offsite radiological consequence assessment, with the TSC as back-up. Responsibility for event classification will remain in the TSC. If the proposed CERC becomes unavailable during an event, the NAPS and SPS TSCs will have the capability to determine PARs for the public, notify offsite agencies , and perform dose assessments.

2 3 When the back-up central EOF is activated, the senior headquarters support position assumes the CEOF Recovery Manager title and fulfills this responsibility. When the back-up central EOF is activated , the stand-by CEOF State & Local Emergency Communicator fulfills this responsibility.

When the back-up central EOF is activated , the headquarters radiological position assumes the CEOF Radiological Assessment Coordinator title and fulfills this responsibility.

Coordination of radiological and environmental assessment Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 8 of 30 The back-up central EOF staff is responsible for coordinating radiological and environmental assessments in the event the local EOF is unavailable.

The back-up central EOF staff currently monitors and maintains a log of site field team activities , and operates in a support role with respect to performing dose assessments during emergencies, exercises and drills. Upon implementation of the proposed consolidation, the CERC staff will coordinate site field team activities and be the lead facility for dose assessments.

In the event both stations are in an emergency class requiring CERC activation, supplemental staff will be mobilized to support the additional station. Determination of recommended public protective actions The back-up central EOF staff is responsible for determining recommended public protective actions in the event the local EOF is unavailable.

Upon implementation of the proposed consolidation, the CERC staff will become the lead emergency response facility (ERF) for developing PARs based upon plant conditions or dose projections.

Station EPIPs will continue to be used for developing PARs. The NAPS and SPS PAR processes are identical.

The responsibility for PAR development, which is currently assigned to the local EOF Recovery Manager, will be assigned to the site-specific CERC Technical Support Manager. In the event both stations are in an emergency class requiring CERC activation, supplemental staff will be mobilized to support the additional station. Notification of offsite agencies The back-up central EOF staff is responsible for notifying the Commonwealth of Virginia and site-specific risk jurisdiction 911 Centers/EOCs in the event one or both of the local EOFs is unavailable. The back-up central EOF staff currently monitors notifications during emergencies, exercises and drills. These notifications include initial notifications, changes in emergency classification or PARs, and periodic updates. Upon implementation of the proposed EOF consolidation these notifications will be made from the CERC following turnover from the affected station(s).

The proposed CERC has separate communications workstations for NAPS and SPS located in the Communications Area. In the event both stations are in an emergency class requiring CERC activation, supplemental staff will be mobilized to support the additional station. Coordination of event, plant, and response information provided to public information staff for dissemination to the media and public The existing headquarters support organization is responsible for providing event, plant , and response information to public information staff for dissemination to the media and public through the Joint Information Center (JIC). A local EOF Public Information Technical Advisor provides technical information to the headquarters support organization.

Upon implementation of the proposed consolidation the responsibility for Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 9 of 30 reviewing draft press releases for technical accuracy , which is currently assigned to the local EOF Recovery Manager, will be assigned to the site-specific CERC Technical Support Manager. Responsibility for approving press releases, which is currently assigned to the senior headquarters support position, will be the responsibility of the CERC Corporate Response Manager (this is not a change). Staffing and activation of the facility within time frames and at emergency classification levels defined in the licensee emergency plan The headquarters support organization and back-up central EOF staff currently mobilize at an Alert or higher emergency per the CERP, and NAPS and SPS emergency plans, and will continue to do so as the CERC staff upon implementation of the proposed consolidation.

In the event both stations are in an emergency class requiring CERC activation , supplemental staff will be mobilized to support the additional station. The activation time goal for the proposed CERC is within 75 minutes of the declaration of an Alert or higher emergency class by either station, with activation defined as the assembly of required positions in the proposed CERC and the CERC Corporate Response Manager declaring the facility activated.

Coordination of emergency response activities with Federal, State, tribal , and local Agencies As required by 10 CFR 50, Appendix E, Section IV.0.3, the capability exists for notifying responsible Commonwealth of Virginia, and NAPS and SPS plume exposure pathway ris k jurisdictions within 15 minutes after declaring an emergency (a site-specific Phone network).

Initial notification is made from the affected site's Main Control Room and transitions to its TSC. This responsibility is transferred to the local or back-up ce n tral EOF, as appropriate. The same site-specific lnsta-Phone network is available in the Main Control Rooms, TSCs, local EOFs and back-up central EOF. Subsequent notifications are transmitted at a designated frequency or as conditions change. The NRC is notified via the Emergency Notification System (ENS) immediately after notification of the Commonwealth of Virginia, and NAPS or SPS plume exposure pathway risk jurisdictions, and not later than one hour after the time one of the emergency classes is declared, as required by 10 CFR 50.72(a)(ii)(3).

Follow-up NRC notifications are made in accordance with 10 CFR 50.72(c).

Responsibility for these notifications is transferred from the affected site's Main Control Room to its TSC where it remains for the duration of the event response.

The local EOF has the capability of establishing Health Physics Network (HPN) communications with the NRC. The back-up central EOF also has designated circuits for establishing HPN communications.

The proposed CERC will utilize these specific circuits for HPN communications.

The NRC may dispatch a Region II Site Team to advise, assist and, as necessary, direct onsite response.

NRC Region II Site Team members interface with their Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 1 O of 30 counterparts in the local EOF and elsewhere.

The Commonwealth of Virginia VDEM sends a liaison to the local EOF(s) to provide on-scene coordination with the Virginia EOC staff and interface with the local EOF Recovery Manager. Local governments do not send representatives to the existing local EOFs. The Commonwealth of Virginia VDH ORH sends a team to the local EOF(s) which coordinates with counterparts at the V i rginia EOC and with the local EOF Radiological Assessment Coordinator.

This team coordinates the placement of monitoring teams and independently calculates radiological consequences using its dose calculation model. NAPS and SPS plume exposure pathway risk jurisdictions do not send representatives to the existing local EOFs. Arrangements meeting the 10 CFR 50.47(b)(3) emergency planning standard for accommodating responding organizations exists at the NAPS and SPS local EOFs, and exists in the back-up central EOF. The proposed CERC will utilize the same areas as the back-up central EOF, which includes separate conference rooms for the NRC Region II Site Team and Commonwealth of Virginia liaisons, desk space in the main work area and designated work-stations in the site-specific Health Physics/Accident Assessment

& Virginia Radiological Health rooms. Locating NRG and offsite agency staff closer to a site if the EOF is greater than 25 miles from the site. Minimum provisions at this location should include the following items: conference area with whiteboards , separate areas suitable for briefing and debriefing response personnel , telephones, site ERO contact lists , computers with internet access , access to a copier and office supplies, and radiation monitoring capability.

Dominion Energy Virginia will establish on-site response locations at the following locations prior to implementation of the proposed change: North Anna: North Anna Nuclear Information Center Surry: Surry Nuclear Information Center These locations will include a conference area with whiteboards, separate areas su i table for briefing and debriefing response personnel, and access to a copier and office supplies.

Telephones , site ERO telephone contact lists , computers with internet access, and access to plant data and radiological information are also provided at these locations.

Procedural guidance will ensure the near-site facilities are made operational and available in a timely manner. Obtaining and displaying key plant data and radiological information for each unit or plant the EOF serves The back-up central EOF staff currently acquires plant data through a secure connection to the NAPS and SPS plant computer servers. The proposed CERC has access to data via the Dominion Energy Virginia Wide and Local Area Networks (WANs and LANs). Dominion Energy Virginia has established an availability goal for the LAN/WAN that exceeds the 0.01 unavailability goal identified in NUREG-0696. The proposed CERC is capable of accessing the same data points that are available to the Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 11 of 30 Operators in the Control Rooms and emergency responders in the TSCs, including the Safety Parameter Display System (SPDS) data points. The proposed CERC's video wall display system can display the graphics on screens in the command center area. V i deo monitors in the site-specific Health Physics/Accident Assessment

& Virginia Radiological Health rooms can display this i nformation also. Analyzing plant technical information and providing technical briefings on event conditions and prognosis to licensee staff and offsite agency responders for each type of unit or plant The back-up central EOF staff has the capability to access key plant parameters from NAPS and SPS Plant Computer System (PCS) networks, and analyze radiological consequences using the Meteorological Information and Dose Assessment System (MIDAS). These capabilities will continue to be available in the proposed CERC. Thus , the CERC staff will be able to monitor and display plant parameters , assess the severity of an accident, project the accident's course , and provide decision-makers with information needed for mitigation, recovery, and PARs. The proposed CERC has a sufficient number of workstations to monitor conditions at NAPS and SPS simultaneously. The proposed CERC is equipped with conference rooms for technical br i efings of licensee staff and offsite agency responders.

Telephone conferencing capability is available for briefing responders not located in the CERC. In the event both stations are in an emergency class requiring CERC activation, supplemental staff is mobilized to support each station. Effectively responding to and coordinating response efforts for events occurring simultaneously at more than one site for a consolidated EOF The proposed CERC is capable of monitoring and analyzing events at NAPS and SPS simultaneously.

A sufficient number of workstations are available for data retrieval and the facility has adequate display capability to simultaneously present this information to the CERC staff. In the event both stations are in an emergency class requiring CERC activation, supplemental staff is mobilized t o support the additional station. Separate NAPS and SPS communications networks will be used for notifying the Commonwealth of Virginia, and NAPS and SPS plume exposure pathway risk jurisdictions. Site-specific work spaces in the command center area and the separate NAPS and SPS Health Physics/Accident Assessment

& Virginia Radiological Health rooms provide a physical se p aration to segregate response efforts. 2.2 LOCATION, STRUCTURE , AND HABITABILITY The proposed CERC is located in the Innsbrook Technical Center (ITC) at 5000 Dominion Boulevard, Glen Allen, Virginia.

This location is approximately 30 miles from the NAPS TSC and approximately 59 miles from the SPS TSC. There are no specific NUREG-0696 habitability criteria for an EOF located more than 10 miles from a nuclear station and a back-up facility is not required.

The proposed CERC Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 12 of 30 is greater than 10 miles from NAPS and SPS. Thus , EOF functions would not be in t errupted during radiation releases for which it was necessary to recommend protective actions for the public to offsite officials. The ITC was constructed in the mid-1980s. The building is capable of withstanding wind loads and live loads equal to or greater than those specified in the BOCA National Building Code/1981.

Access to the ITC is continually controlled by a contracted security service. The main entrance to the proposed CERC is controlled by a monitored electronic card reader that allows entry to a u thorized personnel only. When the proposed CERC is activated these doors may be placed in access. Two utility circuits feed the ITC. Primary power is provided by commercial power. Electrical outlets, heating, ventilation and air conditioning (HVAC), lighting fixtures, and the wiring closet that supports both the voice and data communications in the proposed CERC have back-up power available.

Thus, a loss of commercial power would not impact voice or data communications equipment in the proposed CERC. The Dominion E n ergy Virginia telecommunications infrastructure supporting the proposed CERC functions, including , but not limited to, fiber optic transmission equipment , telephone switching equipment and data network routers, is configured to operate from at least one and usually multiple back-up power sources in the event of a loss of commercial power. These back-up sources include generator, DC battery and uninterruptable power su p ply (UPS) systems.

2.3 STAFFING

AND TRAINING Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 13 of 30 The staff needed to activate the proposed CERC will consist of the staff needed to activate an existing station EOF and unique positions of the existing headquarters (HQ) support organization as shown below: Table 2.3-1: Current and Proposed CERC Staffing for Activation Current Local EOF Proposed CERC Current HQ support Recovery Manager Ops Support Coordinator State/Local Communicator Radiological Assessment Coordinator Corporate Response Manager Tech Support Manager Ops Support Coordinator State/Local Communicator Radiological Assessment Coordinator Dose Assessment Dose Assessment Field Team Radio Field Team Radio Operator Operator HPN Communicator HPN Communicator Resource Manager Facility Coordinator or anization Corporate Response Manager Technical Support Manager .. -. . . .. Back-up State/Local Communicator*

Radiological Support Back-up Dose Assessment*

Back-up Field Team Radio Operator*

Back-up HPN Communicator*

Plan/Design/Construction Manager Facility Coordinator Nuclear News Manager Nuclear News Manager Chief Technical Spokesperson Chief Technical Spokesperson

• Currently not required for activating the headquarters support organization.

NRC's January 13, 1984 letter (Reference 7.20) accepted 1-1/2 hours as the EOF act i vation goal for both NAPS and SPS local EOFs. However, the times for augmenting the local EOF Recovery Manager and Radiological Assessment Coordinator positions in NAPS Emergency Plan Table 5.2, Emergency and Recovery Corporate Response Required for Nuclear Station Emergencies, was listed as 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The corresponding tab l e in the SPS Emergency Plan listed 1-1 /2 hours for these positions.

This inconsistency was carried forward when an emergency response facility activation goal of "approximately 60 minutes" was added for the local EOF by NAPS Emergency Plan Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 14 of 30 Revision 18 (January 3, 1996) and of "approximately 90 minutes" for the SPS local EOF by SPS Emergency Plan Revision 40 (January 1 , 1996). Dominion Energy Virginia proposes 75-minutes following declaration of an Alert or higher emergency class as the Corporate Emergency Response Center (CERC) activation goal (unless special circumstances apply). Table 2.3-1, Current and Proposed Staffing for Activation, lists the ERO positions required for activation of the proposed CERC. Special circumstances include situations where the movement of emergency responders could place them at risk, e.g., severe weather. Activation will be defined as the assembly of required positions in or under the operational control of the designated Corporate Response Manager and declaring the facility activated (i.e., ready to begin the turnover process with the affected station TSC(s)). T h e NAPS and SPS on-shift staffing analyses (OSAs) showed that, for the event sequences analyzed, on-shift responders can appropriately respond to an emergency wi t hout an augmented staff for a time of up to 90 minutes. Thus, for these event sequences, the on-shift staff can analyze the conditions and declare the appropriate emergency class within 15 minutes as required by 10 CFR 50 , Appendix E, IV.C.2 , notify the Commonwealth of Virginia Emergency Operations Center (EOC) and specific risk-jurisdiction 911 Centers, and respond to the emergency event during the proposed CERC's 75 minute augmentation goal. The location of the proposed CERC facilitates prompt response by corporate support and management personnel who commute to the building on a regular basis. The cu r rent back-up central EOF and headquarters support organization staffs will transition into the staff for the proposed CERC. This ERO population participates in periodic augmentation capability assessments which have consistently demonstrated the capability to staff the existing organization within 75 minutes of a simulated event declaration.

The same training program guide for the current local EOF staff also governs training for the back-up central EOF and headquarters support organization staffs. Prior to implementation of the proposed CERC, this training program guide will be revised to ref l ect the new roles of the proposed CERC and the ERO members filling these roles wi ll be qualified accordingly.

Training for key ERO members supporting NAPS and SPS wil l include station-specific differences, e.g., plume exposure pathway risk jurisdictions, release pathways, station ingress and egress routes, offsite protective action zones, and evacuation time estimates.

NAPS Unit Nos. 1 and 2 , and SPS Unit Nos. 1 and 2, are 3-loop Westinghouse pressurized water reactors, and both stations have Independent Spent Fuel Storage Installations; thus, the plans and procedures for operation and emergency response are similar. Upon implementation of the proposed CERC, responsibility for the key EOF functions listed in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, for the Drill/Exercise Performance (DEP) and ERO Drill Participation performance indicators (Pis) will be updated as shown below:

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 15 of 30 Table 2.3-2: Responsibility for NEI 99-02 Key EOF Functions Key EOF Responsible Position in Responsible Position Responsibility/Function Current Local EOF in Proposed CERC Senior Manager/ Local EOF Recovery CERC Technical Management of Manager Support Manager corporate resources Key Protective Measures / Radiological effluent Local EOF Radiological CERC Rad i ological and environs monitoring, Assessment Coordinator Assessmen t assessment , a n d dose Coordinator projections Key EOF Communicator Local EOF State and CERC State and Local / provides offsite Local Communicator Communica t or ( state/local) notification Subsequent to implementation of the proposed CERC , notification and PAR DEP Pl opportunities performed in the CERC will be credited in accordance with NRG-endorsed NEI 99-02. If the option for EROs with common facilities is exercised , negative performance , positive performance , a n d performance enhancing ERO participation opportunities for the proposed CERC pos i tions will be credited for both NAPS and SPS. 2.4 S I ZE The total usable space of the proposed CERC is approximately 5987 square fee t. Based on the 75 square foot per person guidance of NUREG-0696 , this provides enough space for approximately 80 individuals. The expected number of EOF personnel during a dual-station event , includ i ng offs i te agency responders , will be less than 60. Space is allocated for accident assessment , radiation assessment and offsite monitoring , offsite communicat i ons , command and control , conferences , NRC team members, and administra t ive support. Office s pace is provided for federal incident responders , administrative services , offsite communications , accident assessment , radiation assessment, offsite monitoring , command and control , conferences , NRC team members, and storage. The space is sufficient for service of equipment and displays.

Phones and special communications equipment are prov i ded as needed throughout the facility at personnel work stations.

Individuals needing access to plant data are provided access via personal computers (PCs). Space is provided for ready access to functional d i splays of d a ta th ro ugh th e use o f comp u te r mon i tors and video display monitors.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 16 of 30 Figure 2.4-1: depicts the layout of the proposed CERC: I -?Oft. ( EntranCQ lrQJll-----.----~-,gr-lnlOhJYl r--------iQI Compumr Room 1) D Command C@ntgr D Government Affair.s, Media Monitomg &News H oom ro1 Administr.ltive SUpport Virgini a Dept. ot~y Ma nagefflC!l'lt cations l!J Heallh Physics/ AccD!nt Assessment

& Virginia Rad Health Health Physics/ Accident Assessment

& Virginia Rad Health IFil Briefino Figure 2.4-1: Layout of Proposed CERC -90 ft.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 17 of 30 Table 2.4-1: Description of Each Area In The Proposed CERC Layout Area Description Command Center Main area (approximately 46 ft x 55 ft) with separate tables for NAPS and SPS (one each) designated for management , intrafacility communications and plant parameter monitoring , common tables for logistics and external affairs functions, table for federal and state representatives, and tables for observers.

Computer Room Houses Information Technology server equipment and communications connections (approximately 12 ft x 14 ft). Federal Office area (approximately 15 ft x 20 ft) with conference table with electrical outlets and communications network ports and screen connection(s).

Chairs , a speaker phone, dry erase board , and networked display screen are also in this office area. Administrative Support Office area ( approximately 14 ft x 17 ft) with location-specific procedures, reference materials and administrative supplies , and Multi-function scanner/printer.

Communications Office area (approximately 7 ft x 14 ft) for state/local notifications.

lnstaphone (NAPS & SPS) and Automatic Ringdowns (NAPS & SPS) are located in this area. Health Office areas (approximately 16 ft x 28 ft) designated for NAPS Physics/ Accident and SPS (one each). P r ovided in this area are: Assessment

& Virginia

• Networked display screens Rad Health (2 rooms)

• Multi-function scanner/printer

• Computers Government Affairs, Office area (approximately 20 f t x 30 ft) with: Media Monitoring

&

• Multi-function scanner/printer News Room

• Networked display screens

• Dry erase boar d Virginia Dept. of Office area (approximately 15 ft x 20 ft) with conference table Emergency with electrical outlets and communications network ports and Management screen connection(s).

Chairs , a speaker phone , dry erase board , and networked displa y screen are also in this office area. B r iefing Office area (approximately 20 f t x 22 ft) with:

• Dry erase board

• Networked display sc r een ---*--1 I I The proposed CERC command center is shown below: Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 18 of 30 Figure 2.4-2: Proposed CERC Command Center Figure 2.4-3: Video Wall Display (Left Side: NAPS-Specific Screens, Right Side:SPS-Specific Screens)

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 19 of 30 P ro posed site-specific CERC Health Physics/Accident Assessment

& Virginia Radiological Health work areas are shown in Figures 2.4-4 thru 2.4-7 below: Figure 2.4-4: CERC Surry Health Physics Accident Assessment

& Virginia Radiological Health Work Area Image 1 Figure 2.4-5: CERC Surry Health Physics Accident Assessment

& Virginia Radiological Health Work Area Image 2 Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 20 of 30 Figure 2.4-6: CERC North Anna Health Physics Accident Assessment

& Virginia Radiological Health Work Area Image 1 -= -~-J ~--Figure 2.4-7: CERC North Anna Health Physics Accident Assessment

& Virginia Radiological Health Work Area Image 2 Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 21 of 30 T h e proposed CERC's Government Affairs , Media Monitoring

& News Room is shown b e low: Figure 2.4-8: Proposed CERC Government Affairs, Media Monitoring and News Room Images 2.5 RADIOLOGICAL MONITORING The proposed CERC is further than 10 miles from NAPS and SPS. Consequently, the h abitability criteria described in NUREG-0696, Section 4.2, Table 2, are not applicable. 2.6 COMMUNICATIONS The proposed CERC has reliable voice communication to the NAPS and SPS Main Control Rooms, TSCs, the NRC, State and local emergency operations centers, nuclear steam supply system (NSSS) suppliers, the Federal Emergency Management Agency , the US Department of Energy, and the Joint Information Center. The existing communications systems include:

• Dominion Energy Virginia-installed telephone system (to manage licensee emergency response resources and communications with NAPS and SPS TSCs) with access to the Dominion Energy Virginia internal phone system, public switched network and long distance

• NAPS and SPS lnsta-Phones (for providing emergency notifications to the Commonwealth of Virginia and site-specific risk jurisdiction 911 Centers/EOCs)

• Radio systems for communication with NAPS and SPS field monitoring teams to coordinate radiological monitoring Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 22 of 30

• 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 connection are provided by the Dominion Energy Virginia communications infrastructure)

• Virginia Satellite Radio/Telephone (to be installed upon implementation)

• Facsimile (fax) transmission capability

• Scanning (e-mail) transmission capability The emergency communications systems at the proposed CERC are designed to ensure the reliable, timely flow of information between all parties having an emergency response role. The lnsta-Phone networks enable Control Rooms, TSCs, current local EOFs and back-up central EOF communications with the Commonwealth of Virginia EOC and site-specific risk-jurisdiction 911 Centers/local EOCs and with each other. The lnsta-Phone will be the primary means of communicating event classification changes to the Commonwealth of Virginia EOC, and site-specific risk-jurisdiction 911 Centers/local EOCs. Existing commercial telephone service and fax will serve as the designated back-up means of communications in the event of an lnsta-Phone failure. Dominion Energy Virginia has telecommunications capabilities that can provide access to long distance networks without having to go through a local telephone company switch. Dominion Energy Virginia maintains an extensive private Synchronous Optical Network (SONET) that serves to connect the ITC to NAPS and SPS. Telephones are provided for the respective Federal and State representatives.

Multifunction machines with fax capability are available in the proposed CERC to support the transmission of information between the emergency response facilities and state, local, and federal authorities.

2.7 INSTRUMENTATION, DATA SYSTEM EQUIPMENT, AND POWER SUPPLIES Data acquisition for the proposed CERC is achieved through a secure connection to the plant computer servers. The proposed CERC has access to displays that are representative of the displays in the Control Room via the Dominion Energy Virginia Wide and Local Area Networks (WAN and LAN). Dominion Energy Virginia has established an availability goal for the LAN/WAN that exceeds the 0.01 unavailability goal in NUREG-0696.

The proposed CERC has access to the same data points that are available to Operators in the Control Room and emergency responders in the TSCs, including the SPDS data points. The video display system in the proposed CERC will display the graphics on screens in the Command Center area. The workstations and related LAN/WAN equipment require AC power to operate. A loss of AC power to the equipment, located at numerous locations throughout the Dominion Energy Virginia system, will cause a loss of this capability.

The LAN equipment housed within the proposed CERC is provided with back-up power. The core network equipment in the ITC is also provided with back-up power.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 23 of 30 S i nce the proposed CERC is located offsite, its electrical equipment loads will not affect any safety related power source. Loss of primary commercial power would not cause loss of any stored data vital to EOF functions. Historical data from the site will be accessible from a historical database.

This information could be accessed by the proposed CERC , as needed, after power is restored to the LAN. 2.8 TECHNICAL DATA AND DATA SYSTEM The proposed CERC will have the capability to receive, store , process, and display information needed to perform assessments of actual and potential offsite environmental consequences during an emergency at NAPS and SPS. A proxy server will allow the display of data points that cover Type A, B , C, D, and E variables discussed in NUREG-0696, Section 4.8. In addition, the meteorological variables required for dose assessment will be made available through the proxy server. This data will also be accessible from a historical database.

The new communication voice and data network will meet the functional intent of the criteria described in NUREG-0696, Sections 4.7 and 4.8. Offsite dose assessment is performed for NAPS and SPS using the Meteorological Information and Dose Assessment System (MIDAS). MIDAS is a computer software program intended for use at nuclear generating stations and other emergency response facilities in the event of an actual or potential release of airborne radioactivity to the environment at levels warranting declaration of an emergency specified in the NAPS and SPS emergency plans. 2.9 RECORDS AVAILABILITY AND MANAGEMENT Hard copies of key reference materials for NAPS and SPS will be maintained in the ITC. In addition , station design documentation, plant drawings , procedures, etc., are available electronically via the local area network connection.

Examples include:

• Plant Technical Specifications

-accessed electronically

• Plant operating procedures

-accessed electronically

• Emergency operating procedures

-accessed electronically

• Final Safety Analysis Reports -accessed electronically

• Emergency plans -controlled hard copies of station emergency plans and State emergency plans (including site specific appendices)

• Offsite population distribution data -accessed electronically

• Evacuation plans -accessed electronically

• Licensee employee radiation exposure history -accessed electronically

• Drawings -accessed electronically Hard copy records will be maintained by a controlled distribution process.

3.0 CONCLUSION

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 24 of 30 The proposed replacement of the NAPS and SPS local EOFs, and their common up central EOF, with a consolidated EOF (proposed CERC) more than 25 miles from both power reactor sites constitute emergency plan changes requiring Commission approval per 10 CFR 50.54(q)(4) to satisfy the provisions of Appendix E Section IV.E.8.b.

4.0 JUSTIFICATION

The proposed change affects the NAPS and SPS emergency plans, including relocation of CERP content, but does not alter any of the requirements of the Operating Licenses or the Technical Specifications.

The change does not alter any of the assumptions used in the safety analyses, nor does it cause any safety system parameters to exceed their acceptance limit. Therefore, the proposed change has no adverse effect on plant safety. Additionally, the changes can be made without adverse impact to plant operations or to the health and safety of the public. Based on the technical analysis performed by Dominion Energy Virginia, the proposed change is acceptable. Requirements and Guidance -EOF Relocation 10 CFR 50, Appendix E, Section IV.E.8.b requires a licensee desiring to locate an EOF more than 25 miles from a nuclear power reactor site to request prior NRG approval by submitting an application for an amendment to its license. For the purposes of the proposed change, this requirement clearly applies because the proposed consolidated EOF in Glen Allen, Virginia is greater than 25 miles from both of the facilities that it serves. In addition, a back-up facility for the proposed CERC is not required because IV.E.8.b requires a back-up when the primary EOF is less than 10 miles from the site only.Section IV.E.8.b of Appendix E also requires that, for an EOF located more than 25 miles from a nuclear reactor site, provisions be made for locating NRG and offsite responders closer to the reactor site to facilitate face-to-face interaction with emergency personnel entering and leaving the site. This regulation also describes the requirements for space and equipment as follows:

• Space for members of an NRG site team and federal, state, and local responders

• Additional space for conducting briefings with emergency response personnel

• Communication with other licensee and offsite emergency response facilities

• Access to plant data and radiol9gical information

• Access to copying equipment and office supplies Utilizing the clarification of the above items contained in NSIR/DPR-ISG-01, near-site response locations will be established to meet this requirement, as described above.Section IV.E.8.c of Appendix E establishes requirements for data acquisition and display, technical analysis of event conditions, and support response for multiple reactor Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 25 of 30 sites. Compliance with these requirements, as applicable to the proposed change, is d i scussed in Section 2.1 above. The 10 CFR 50.47(b)(1) emergency planning standard for assigning primary responsibilities for licensee and state and local organization emergency response and for each organization to have staff to respond and to augment on a continuous basis will continue to be met because:

• Primary responsibilities will continue to be assigned as described above and in the proposed NAPS and SPS emergency plan revisions.

• Dominion Energy Virginia staff will respond and augment on a continuous basis , as described in the proposed NAPS and SPS emergency plans. The 10 CFR 50.4 7(b )(3) emergency planning standard for making arrangements to a ccommodate State and local staff at the licensee's EOF will continue to be met because space is provided for the Commonwealth of Virginia VDEM liaison and VDH ORH team (risk-jurisdiction radiological emergency response plans do not include provisions for staffing the existing local EOF or proposed CERC). T he 10 CFR 50.47(b)(8) emergency planning standard for providing and maintaining adequate emergency facilities and equipment to support the emergency response will continue to be met. After the proposed consolidation, NAPS and SPS will each continue to have an EOF from which effective direction can be given and effective control can be exercised during an emergency.

Furthermore, the proposed CERC meets the EOF criteria in NUREG-0696, as discussed below, with the exception of its distance from NAPS and SPS. The 10 CFR 50.47(b)(9) emergency planning standard for having adequate methods, systems, and equipment for assessing and monitoring the actual or p otential offsite consequences of a radiological emergency condition is encompassed in t he EOF criteria in NUREG-0696 , as discussed below. Section 4 of NUREG-0696 provides guidance on the overall criteria for the EOF:

• Functions

• Location , structure , and habitability

• Staffing and training

• Size

• Radiological monitoring

• Communications

• Instrumentation , data system equipment, and power supplies

• Technical data and data system

• Records availability and management Each of these criteria , as applicable to the proposed change , is discussed in Sections 2.1 through 2.9 above. NUREG-0696 expands on the Functions criterion with the following detail (expanded list included in NSIR/DPR-ISG-01

):

• Management of overall licensee emergency response Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 26 of 30

• Coordination of radiological and environmental assessment

• Determination of recommended public protective actions

• Notification of offsite agencies

• Coordination of event, plant, and response information provided to public information staff for dissemination to the media and public

• Staffing and activation of the facility within time frames and at emergency classification levels defined in the licensee emergency plan

• Coordination of emergency response activities with Federal, State, tribal, and local agencies

• Locating NRC and offsite agency staff closer to a site if the EOF is greater than 25 miles from the site

• Obtaining and displaying key plant data and radiological information for each unit or plant the EOF serves

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

• Effectively responding to and coordinating response efforts for events occurring simultaneously at more than one site for a consolidated EOF Each of these criteria, as applicable to the proposed change, is discussed above. 5.0 NO SIGNIFICANT HAZARDS CONSIDERATION Dominion Energy Virginia has evaluated whether or not a significant hazards consideration (SHC) is warranted for the proposed amendments by addressing the t hree criteria set forth in 10 CFR 50.92(c) as discussed below. Criterion 1: Do the proposed amendments involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No. The proposed amendments affect the NAPS and SPS emergency plans, including relocation of CERP content, but do not alter any of the requirements of the Operating Licenses or the Technical Specifications.

The proposed amendments do not modify any plant equipment and does not impact any failure modes that could lead to an accident.

Additionally, the proposed amendments have no effect on the consequences of any analyzed accident since the amendments do not affect any equipment related to accident mitigation.

Therefore , the proposed amendments do not involve a significant increase the probability or consequences of an accident previously evaluated.

Criterion 2: Do the proposed amendments create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No. Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 27 of 30 The proposed amendments affect the NAPS and SPS emergency plans , including relocation of CERP content, but does not alter any of the requirements of the Operating Licenses or the Technical Specifications.

It does not modify any plant equipment and there are no impacts on the capability of existing equipment to perform its intended functions.

No system setpoints are being modified and no new failure modes are introduced. The proposed amendments do not introduce new accident initiator or malfunctions that would cause a new or different kind of accident.

Therefore , the proposed amendments do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3: Do the proposed amendments involve a significant reduction in a margin of safety? Response:

No. The proposed amendments affect the NAPS and SPS emergency plans, including relocation of CERP content , but do not alter any of the requirements of the Operating Licenses or the Technical Specifications.

The proposed amendments do not affect any of the assumptions used in the accident analyses, or any operability requirements for equipment important to plant safety. Therefore, the proposed amendments do not involve a significant reduction in the margin of safety. In summary , Dominion Energy Virginia concludes that the proposed amendments do not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

6.0 ENVIRONMENTAL

CONSIDERATION Dominion Energy Virginia has determined that the proposed change would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor would it change inspection or surveillance requirements.

Dominion Energy Virginia has evaluated the proposed change and has determined that the change does not involve:

• A Significant Hazards Consideration,

• A significant change in the types or significant increase in the amounts of an effluent that may be released offsite, or

• A significant increase in individual or cumulative occupational radiation exposure. Accordingly , the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10)(ii). Therefore , pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

7.0 REFERENCES

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 28 of 30 7.1 10 CFR 20 -Standards for Protection Against Radiation.

7 .2 10 CFR 50 -Domestic Licensing of Production and Utilization Facilities sub-parts 4 7 Emergency plans, 54 Conditions of licenses , 72 Immediate notification requirements for operating nuclear power reactors and 92 Issuance of amendment, and Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities.

7.3 10 CFR 51 -Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions sub-part 22 Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review. 7.4 NUREG-0696, Functional Criteria for Emergency Response Facilities (February 1981 ). 7.5 NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements:

Requirements for Emergency Response Capability (January 1983). 7.6 NSIR/DPR-ISG-01 , Emergency Planning for Nuclear Power Plants (November 2011 ). 7.7 Generic Letter 80-73, Functional Criteria for Emergency Response Faci l ities, NUREG-0696 , dated August 1 , 1980. 7.8 Generic Letter 80-90, Post-TM! [Three Mile Island] Requirements , NUREG-0737 , dated October 31, 1980. 7.9 Generic Letter 81-10, Post-TM! Requirements for the Emergency Operations Facility , dated February 18 , 1981. 7.10 Generic Letter 82-33 , Supplement 1 to NUREG-0737

-Emergency Response Capability, dated December 17 , 1982. 7.11 Safety Evaluation by the Division of Reactor Licensing, U. S. Atomic Energy Commission , in the matter of Virginia Electric and Power Company , Surry Power Station Units 1 and 2 , Surry County, Virginia , Docket Nos. 50-280 and 50-281 , February 23, 1972. 7 .12 Safety Evaluation Report related to the operation of North Anna Power Station Units 1 and 2 (NUREG-0053 , June 1976), including NUREG-0053 , Supplement 11 (August 1980) for Unit 2. 7.13 Nuclear Reactor Regulation Letter , unt i tled (adv i sed that conceptual design provided in December 18 1980 and June 1 , 1981 letters no t sufficiently detailed), dated November 23 , 1981.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 29 of 30 7.14 NRC Region II Letter , NRC Region II Emergency Response, dated January 29, 1982. 7.15 NRC Region II Letter , NRC Region II Emergency Response , dated February 12 , 1982. 7.16 NRC Region II Letter , untitled (provided results of March 15-26, 1982 emergency preparedness program appraisal, including as appendices Confirmation of Action Letter dated April 6, 1982, Preparedness Improvement Items , Emergency Plan Deficiencies , and Inspection Report Nos. 50-280 , 281/82-05), dated May 25, 1982. 7.17 NRC Region II Letter , untitled (provided results of February 16-26 , 1982 emergency preparedness program appraisal, including as appendices Confirmation of Action Letter dated March 10 , 1982, Preparedness Improvement Items , and Inspection Report Nos. 50-338 , -339/82-05 , with list of Emergency Plan Deficiencies attached), dated July 1, 1982. 7.18 Nuclear Reactor Regulation Letter , NUREG-0737 Item 111.A.2.1 Emergency Plan Upgrade to Meet Rule [Re: North Anna Power Station , Unit No. 1 and No. 2 (NA-1 &2)), dated May 10, 1983. 7.19 Nuclear Reactor Regulation Letter , NUREG-0737 Item 111.A.2.1 -Emergency Plan Upgrade to Meet Rule (Surry Power Station Unit Nos. 1 and 2), dated May 13, 1983. 7.20 Nuclear Reactor Regulation Letter , untitled (advised that the Commission found the location of the back-up and primary EOFs for NAPS and SPS acceptable), dated January 13, 1984. 7.21 Nuclear Reactor Regulation Letter , Emergency Response Capability, North Anna Power Station, Units No. 1 and No. 2 (NA-1&2), dated May 25, 1987. 7.22 Nuclear Reactor Regulation Letter , NUREG-0737 , TMI Action Item 111.A.1.2, " Emergency Response Facilities" and Item 111.A.2.2 , Meteorological Data Upgrade ," Surry Power Station Units 1 and 2, dated June 12 , 1987. 7 .23 Surry Power Station Updated Fina l Safety Analysis Repo rt (UFSAR) (Revision 48.03 dated February 28 , 2017). 7.24 North Anna Power Station Updated Final Safety Analysis Report (UFSAR) (Revision 52.06 dated June 15 , 2017). 7.25 Corporate Emergency Response Pl a n (CERP) (Revision 15 dated November 22 , 20 1 6).

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 1 -Page 30 of 30 7.26 North Anna Power Station Emergency Plan (Revision O dated July 22 , 1982 , Revision 8 dated September 27 , 1984 , Revision 12 dated October 2 , 1989 , Revision 18 dated January 3 , 1996 , Revision 38 dated December 21 , 2012 , and Revision 44 dated February 2 , 2017). 7.27 Surry Power Station Emergency Plan (Revision O dated July 29 , 1982 , Revision 15 dated June 28 , 1984 , Revision 32 dated April 27 , 1989 , Revision 40 dated January 1 , 1996 , Revision 58 dated December 21 , 2012 , and Revision 63 dated March 16 , 2017 (Revisions 0-32 were not numbered , but these revision numbers correspond to the sequence by date)). 7.28 Outgoing Letter Ser i al No. 1008 , Draft NUREG 0696 Implementation Plan for Surry Power Station [and] North Anna Power Stat i on, dated December 18 , 1980. 7.29 Outgoing Letter Serial No. 312, untitled (updates Outgoing Letter Serial No. 1008 dated December 18, 1980), dated June 1 , 1981. 7.30 Outgoing Letter Serial No. 102 , NUREG-0696, Emergency Response Facil i ties, North Anna and Surry Power Stations , dated April 8 , 1982. 7.31 Outgoing Letter Serial No. 676 , Supplemental Information , re: NUREG-0696 Response , dated December 6 , 1982. 7.32 Outgoing Letter Serial No. 237, Generic Letter 82-33 , Emergency Operations Facilities , North Anna and Surry Power Stations , dated April 14 , 1983. 7.33 Outgoing Letter Serial No. 259, Generic Letter 82-33 , Emergency Operations Facilities , North Anna and Surry Power Stations , dated May 6, 1983. 7.34 Outgoing Letter Serial No.88-617 , Corporate Emergency Operations Facility Relocation , dated September 14 , 1988. 7.35 Build i ng Offic i als and Code Administrators (BOCA) National Building Code/1981. 7.36 Nuclear Energy Institute (NEI) 99-02 , Revision 7, R e gulatory Assessment Performance Indicator Guideline, dated August 31 , 2013. 7.37 North Anna NEl-10-05 , "Assessment of On-Sh i ft Emergency Response Organization Staffing and Capabilities," December 2012. 7.38 Surry NEl-10-05 , "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities

," December 2012.

Attachment 2 Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Disposition of Corporate Emergency Response Plan Contents Section Introduction Table of Contents 1.0 1.1 Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 1 of 25 Table 2.0-1 Disposition of Emergency Response Plan Contents Existing CERP Wording Disposition The Corporate Emergency Response Plan (CERP) establishes guidelines The format of the North Anna for contending with emergencies that may occur at North Anna or Surry Emergency Plan (NAEP) and Power Station. Company policy mandates an Emergency Preparedness Surry Emergency Plan (SEP) Program designed to support our nuclear power stations in such a do not include an manner as to ensure effective control and coordination of response "Introduction" section. NAEP efforts should the need arise. The CERP complies with standards set & SEP Sections 2.1 provide forth by the Nuclear Regulatory Commission, and is formulated for the necessary information.

compatibility with governmental, vendor and volunteer support organizations that may render emergency assistance.

Pre-planned response efforts with support organizations sustain our mutual goal of protecting public health and safety. Compliance with this Plan is required.

Self-explanatory The format of the NAEP & SEP includes a table of contents which will be revised as necessary.

Definitions NAEP & SEP Sections 1.0 will be updated to include CERP-defined terms as appropriate.

Acronyms and Abbreviations NAEP & SEP Sections 1.1 will be updated to include unique acronyms and abbreviations as appropriate.

2.0 Scope

and Applicability The Corporate Emergency Response Plan (CERP) establishes the fundamental guidelines necessary for the Corporate Emergency Response Organization to respond to emergency events that may occur at the North Anna or Surry Power Station. Included are provisions to commit Company resources to the response effort, to allow deviation from standard policy and to provide long term recovery support. The CERP is also designed to ensure compatibility with the planning efforts of offsite organizations which may provide assistance in the event of an emergency.

The basic purpose of the Plan is to establish a corporate emergency response organization which will support the affected station with respect to emergency management and resources, and to provide facilities, equipment, and services necessary for recovery.

The ultimate goal is to ensure the protection of the health and safety of the general public during unusual or emergency conditions.

The organizational framework of the CERP dictates that the Corporate Response Manager is responsible for implementation of this plan. 3.0 Summary of Corporate Emergency Response Plan (CERP) The types of emergencies at the nuclear stations are divided into four classifications covering a broad spectrum of potential occurrences.

These classifications range from "Notification of Unusual Event" in which offsite officials are notified of an unusual condition, through "General Emergency" in which onsite and offsite evacuation may be required and a major state of emergency exists. These classifications are compatible with the applicable state and local government emergency plans. The CERP, which is implemented at an "Alert" or higher classification, provides a mechanism for supporting the station response effort, Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 2 of 25 NAEP & SEP Sections 2 describe scope and applicability sufficiently.

The content of the first and second paragraphs of NAEP & SEP Sections 3 address the content of the corresponding paragraphs in CERP Section 3.0 sufficiently.

The detail in the subsequent paragraphs is beyond the scope of a summary. However, a summary of public information including determination of offsite radiological conditions and establishing recovery operations.

The CERP also provides additional support if the emergency is of such a magnitude that Company resources are overextended.

Such support may be additional manpower to augment the station's operating staff, manpower in specialized disciplines, and specialized emergency response equipment and services.

Upon activation of the CERP, the Corporate Response Manager directs operation of the Corporate Emergency Response Center (CERC), while the Recovery Manager directs Local Emergency Operations Facility operations and serves as a liaison between the station and CERC. Upon activation of the CERC, the Nuclear News Manager will coordinate public information activities and, after it is activated by the Commonwealth of Virginia, interface with the Joint Information Center (JIG) (Virginia State Police Administrative Headquarters in Chesterfield, Virginia).

Official press releases to the media, including briefings by the Chief Technical Spokesperson, are made from the JIC. Following approval by the Corporate Response Manager, press releases are distributed to the media and, when it is activated, to the Local Media Center for distribution to news personnel assembled at. that facility.

Questions from the general public concerning the event are addressed from the JIG. 4.0 Emergency Conditions The following guidelines describe the criteria used by station personnel in classifying or determining the type of emergency.

The types of potential accidents or emergencies can be numerous and vary in magnitude.

The . classification system is wide-ranged and flexible to respond to this diversity.

There are a total of four classifications.

The classification system is not intended to include permissible deviations Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 3 of 25 activities will be added to NAEP & SEP Sections 3. Content corresponds with NAEP & SEP Sections 4.0.

during normal operation.

4.1 Classification

System 4.1.1 Notification of Unusual Event This is the first or lowest classification of an emergency.

Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs. Corrective and assessment actions are required.

Local and state agency notification occurs to assure that the first step in any response has been carried out. Notification also provides information to public officials and assists in ensuring that offsite communications are effective.

4.1.2 Alert

Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of intentional malicious dedicated efforts of a hostile act. Any releases are expected to be limited to small fractions of the Environmental Protection Agency Protective Action Guideline exposure levels. The Alert classification assures that emergency response personnel are available if the situation deteriorates or if confirmatory radiation monitoring is required.

Information concerning current station conditions is provided to public officials to assist in ensuring that offsite communications are functional.

4.1.3 Site Area Emergency Events are in process or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 4 of 25 Content corresponds with NAEP & SEP Sections 4.2. Content corresponds with NAEP & SEP Sections 4.2. Content corresponds with NAEP & SEP Sections 4.2. Content corresponds with NAEP & SEP Sections 4.2.

4.1.4 4.2 security events that result in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) prevents effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed Environmental Protection Agency Protective Action , Guideline exposure levels beyond the site boundary.

The Site Area Emergency classification assures that response centers are manned and information for those personnel required for nearsite evacuation assistance is available.

Current station conditions are provided to public officials with consultation occurring promptly.

The communications system and offsite agency response capabilities are activated.

General Emergency Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or security events that result in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed Environmental Protection Agency Protective Action Guideline exposure levels offsite for more than the immediate site area. The General Emergency warning initiates predetermined protective actions for the public and provides continuous assessment of information with appropriate radiation monitoring.

Current information is provided to officials with appropriate notification to the news media. State and Local Government Classification System The Commonwealth of Virginia Emergency Operations Plan (COVEOP), Hazard-Specific Annex #1 -Radiological Emergency Response addresses response to the release of radioactive materials from a fixed nuclear facility.

The COVE OP provides protective action decision-making guidance for protecting the health and safety of the public in the affected emen:1encv planninQ zone, notification and evacuation, if deemed Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 5 of 25 Content corresponds with NAEP & SEP Sections 4.2. Content corresponds with NAEP & SEP Sections 4.3.

neces-sary.

Provisions are in COVEOP for dose assessments within 50 miles of the station for the ingestion of radioactive material via the food pathway. COVEOP's protective actions are based on guidelines appearing in Table 2-1 of EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, for projected doses to the population-at-risk.

5.0 Corporate

Emergency Response Structure The Corporate Emergency Response Organization (GERO) operates under direction of the Corporate Response Manager. Upon declaration of an Alert, Site Area Emergency or General Emergency at either Surry or North Anna Power Stations, the Corporate Emergency Response Plan (CERP) is activated.

In response, the Recovery Manager reports to the Local Emergency Operations Facility (LEOF) and acts as the liaison between the Station Emergency Manager, Corporate Response Manager, and federal, state, and local agencies.

The Joint Information Center (JIG) is activated in accordance with the Commonwealth of Virginia Radiological Emergency Response Plan. Other members in the CERP will assist the Corporate Response Manager in responding to the emergency and recovery in their respective areas. Members of each support area have procedures to assemble and provide direction to their staff. If the LEOF is unavailable, the Central Emergency Operations Facility (CEOF) is activated.

CEOF staffing is achieved using a transitional organization (composed of corporate emergency response personnel) who may be augmented with other ERO members as necessary.

The process for staffing and activating the CEOF is specifically outlined in Corporate Plan Implementing Procedures (CPIPs) designed to provide for Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 6 of 25 Added NAEP Section 5.2.2 to complement NAEP Section 5.2.1, excluding obsolete references to the back-up central EOF which will be replaced by the consolidated EOF. Replaced SEP Section 5.2.2, which had referenced the CERP, with new content to complement SEP Section 5.2.1, excluding obsolete references to the back-up central EOF which will be replaced by the consolidated EOF.

re-assignment of LEOF functions, including:

protective action recommendations, state/local notifications, and Health Physics functions (dose assessment, control of Offsite Monitoring Teams, and Health Physics Network (HPN) communications).

5.1 Corporate

Emergency Response Center Functional Descriptions

5.1.1 Corporate

Response Manager The Corporate Response Manager assumes overall control and operation of the CERC, and is responsible for allocating the use of company resources to aid the affected station in the mitigation of and recovery from an accident, activating the CERC, ensuring CERC functional positions are adequately staffed to support the affected station, ensuring requests are dispatched efficiently and in a timely manner, directing transition of CERP personnel functions from response to recovery operations upon event termination, and providing management direction to the CERC Executive Liaison. 5.1.2 Chief Technical Spokesperson The Chief Technical Spokesperson reports to the Corporate Response Manager and is responsible for serving as the official company spokesperson during CERP activation, responding to technical inquiries from the news media, ensuring that statements issued to the media are technically correct and factual, conducting press briefings, reporting changes in emergency status to the media (i.e., classification changes), and providing management direction to the following positions:

JIC Dominion Liaison JIC Dominion Technical Advisor 5.1.3 Nuclear News Manager The Nuclear News Manager assumes overall control for all media and public information functions.

The Nuclear News Manager is responsible Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 7 of 25 -A Corporate Response Manager position description will be added as NAEP & SEP Sections 5.2.2.1. A Chief Technical Spokesperson position description will be added as NAEP & SEP Sections 5.2.2.5 and a Joint Information Center Support Team as NAEP & SEP Sections 5.2.2.14.

A Nuclear News Manager position description will be added as NAEP & SEP for operation of media response activities; ensuring all press releases have been approved by the Corporate Response Manager prior to release; ensuring that all public information representatives from local, state and federal agencies have been notified of impending press releases; providing for the prompt distribution of written statements to the news media; providing non-technical information to the news media; identifying those persons authorized to make official company statements about station status during an emergency; notifying corporate employee communications, government relations and investor relations about the event; ensuring that media monitoring and rumor control personnel are provided updates and that proper information is being disseminated; and providing management direction to the following positions:

News Writer News Room Administrative Support Information Center Coordinator LEOF Public Information Technical Advisor 5.1.4 Plan/Design/Construction Manager The Plan/Design/Construction Manager reports to the Corporate Response Manager and is responsible for providing the direct contact between the company, the Architect/Engineer, the Nuclear Steam Supply System supplier and other equipment suppliers for all design changes and/or needed assistance; directing, coordinating and approving engineering, design and construction activities onsite as needed; coordinating in-house engineering reviews and design efforts; determining the need for construction of new facilities onsite in order to mitigate and/or recover from an accident; establishing which engineering design and construction activities, if any, shall conform to utility formal requirements or be documented by the utility quality assurance proQram; Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 8 of 25 Sections 5.2.2.4, a News Team description as NAEP & SEP Sections 5.2.2.13, and a Joint Information Center Support Team as NAEP & SEP Sections 5.2.2.14.

LEOF Public Information Technical Advisor functions will be assumed by the [CERC] Nuclear News Manager. The duties of the headquarters support organization position of Plan/Design/Construction Manager will be assigned to the Resource Manager. Its position description will be added as NAEP & SEP Sections 5.2.2.3 and a Resource Team description will be added as NAEP & SEP Sections 5.2.2.12.

providing administrative and logistical support, including making provisions for establishing a 24-hour shift schedule (as necessary), coordinating additional company support personnel to support needs in the areas of planning, design, engineering, construction, recovery, supply chain, document retrieval, information technology, telecommunications and access control; and providing management direction to the following positions:

Facility Coordinator Logistics Coordinator Administrative Support 5.1.5 Technical Support Manager The Technical Support Manager reports to the Corporate Response Manager and is responsible for ensuring station conditions are analyzed and guidance developed (if necessary) for core and system protection, supporting the station by developing procedures to support operations (if necessary), reviewing and assessing radiological controls in effect at the stations, analyzing and coordinating waste management controls and plans, performing dose assessment calculations as back-up to the stations, resolving questions concerning operating license requirements, and providing management direction to the following positions (includes CEOF-specific positions):

Reactor Core Analysis (including core damage assessment)

Radiological Support (CEOF Health Physics Network Communicator) (CEOF Field Team Radio Operator) (CEOF State & Local Communicator)

Plant Information/Communications Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 9 of 25 A Technical Support Manager position description will be added as NAEP & SEP Sections 5.2.2.2, an Operations Support Team added as NAEP & SEP Sections 5.2.2.9 and an Accident Assessment T earn description as NAEP & SEP Sections 5.2.2.11.

Meteorology Safety Analysis Operations Support (CEOF Dose Assessment)

Figure CORPORATE EMERGENCY RESPONSE CENTER (Page 5-5) Minimum Organization For Activation Figure CORPORATE EMERGENCY RESPONSE CENTER J (Page 5-6) Fully Staffed Organization

5.2 Local

Emergency Operations Facility Functional Descriptions

5.2.1 Recovery

Manager The Recovery Manager assumes overall control of LEOF operations and functions.

The Recovery Manager is responsible for ensuring that necessary personnel are available to staff functional positions within the LEOF; directing, supervising, and coordinating LEOF activities; assessing and providing protective action recommendations to offsite authorities; notifying state and local governments of the emergency status and any changes in a timely manner; providing prompt and accurate information to the CERC; working with state and federal agency representatives located in the LEOF; ensuring that prompt and accurate dose assessments are performed; working with the Station Emergency Manager to determine the need to escalate or de-escalate the emergency classification; and arranging for special assistance or services requested by the affected station. 5.2.2 Radiological Assessment Coordinator The Radiological Assessment Coordinator (RAC) reports to the Recovery Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 1 O of 25 Added NAEP & SEP Figures 5.5d. (Also added Figures 5.5a-c for TSC, OSC and on-site HP.) Added NAEP & SEP Figures 5.5d. The role of the Recovery Manager will be distributed to the Corporate Response Manager and Technical Support Manager. These positions will be described in NAEP & SEP Sections 5.2.2.1 and 5.2.2.2. A Radiological Assessment Coordinator position Manager and is responsible for dose assessment staffing and operations; directing performance of emergency dose calculations using available computer equipment; 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 dose projections; formulating protective action recommendations (PARs); briefing Recovery Manager on radiological conditions and PARs; tracking the plume; ensuring LEOF habitability; ensuring LEOF heating, ventilation and air conditioning is functioning properly and is in the correct mode of operation; and identifying any supplemental resources needed. 5.2.3 Field Team Radio Operator The Field Team Radio Operator reports to the RAC and is responsible for ensuring the plant radio is properly used, maintaining communications with the offsite field teams, transmitting and receiving information to and from the offsite field teams, ensuring that information which is transmitted and/or received is correct, providing direction to the offsite field teams, conveying the RAC's instructions to the field teams, providing plume direction information to the field teams(s), and assisting in correlation of field measured doses to calculated projected doses. 5.2.4 Offsite Field T earns The responsibilities of the Offsite Field Teams are delineated at section 5.2.1 .18 of the North Anna and Surry Emergency Plans. I 5.2.5 Dose Assessment Staff The Dose Assessment Staff reports to the RAC and is responsible for Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 11 of 25 description will be added as NAEP & SEP Sections 5.2.2.1 Oas appropriate (e.g., excluding responsibility for ensuring LEOF habitability due to the location of the proposed CERC). The role of the Field Team Radio Operator will be fulfilled by the Accident Assessment Team in the proposed CERC (see NAEP & SEP Sections 5.2.2.11).

The reference to NAEP & SEP Sections 5.2.1.18 will be incorporated into the Accident Assessment Team description in NAEP & SEP Sections 5.2.2.11.

The role of the LEOF Dose Assessment Staff will be setting up the dose assessment computer and checking proper operation, contacting the Radiological Assessment Director in the Technical Support Center (TSC) (as necessary), entering radiological and meteorological information into the computer and running dose projections, providing continuous dose projections and utilizing actual field measurement numbers and comparing to dose projections.

5.2.6 HPN Communicator The HPN Communicator reports to the RAC and is responsible for establishing and maintaining contact with the Nuclear Regulatory Commission (NRC) on the HPN, transmitting correct and accurate information regarding dose projections and offsite field measurements to the NRC, and staying updated on radiological conditions in the plant, dose projections and offsite field measurements.

5.2.7 Emergency

Plan Advisor The Emergency Plan Advisor reports to the Recovery Manager and is responsible for advising the Recovery Manager on emergency action levels, emergency classifications, protective action recommendations and any questions regarding the Emergency Plan; and coordinating with the Operations Support Coordinator on emergency action levels. 5.2.8 Operations Support Coordinator The Operations Support Coordinator reports to the Recovery Manager and is responsible for advising the Recovery Manager on unit conditions and methods being implemented to mitigate the incident and progress, coordinating with the Emergency Plan Advisor on present and potential emergency action levels and protective action recommendations, assisting in the development of the Recovery Plan after incident mitigation, coordinating with the Recovery Manager in interfacing with the NRC representative in the LEOF (if applicable), monitorina plant Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 12 of 25 fulfilled by the Accident Assessment Team in the proposed CERC (see NAEP & SEP Sections 5.2.2.11 ). The role of the LEOF HPN Communicator will be fulfilled by the Accident Assessment Team in the proposed CERC (see NAEP & SEP Sections 5.2.2.11).

An Emergency Plan Advisor position description will be added as NAEP & SEP Sections 5.2.2.7. An Operations Support Coordinator position description will be added as NAEP & SEP Sections 5.2.2.8.

conditions using the Plant Computer System (PCS) and ensuring the staffing of and providing direction to LEOF Communicator and State/Local Communicator.

5.2.9 LEOFServices

Coordinator The LEOF Services Coordinator reports to the Recovery Manager and is responsible for tracking and staffing of LEOF personnel, providing scheduling of relief shifts (as necessary), controlling procurement and ordering supplies, obtaining procedures from library or document control (as necessary), checking telecopiers functional, coordinating any necessary travel arrangements with CERC administrative personnel, ensuring food and sanitation facilities are available for LEOF personnel, distributing information/instructional packets in the LEOF (if necessary) and managing activities performed by the LEOF Administrative Coordinators.

5.2.10 LEOF Telecommunications Coordinator The LEOF Telecommunications Coordinator reports to the Recovery Manager and is responsible for maintaining the functionality of the Communication systems within the emergency response facilities (ERFs), coordinating the installation of additional communications as necessary, implementing system repairs as necessary, and monitoring siren control system status. Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 13 of 25 The role of the LEOF Services Coordinator is subsumed by the Resource Manager and Resource Team which will be described in NAEP & SEP Sections 5.2.2.3 and 5.2.2.12.

The role of the LEOF Telecommunications Coordinator is addressed by NAEP & SEP Sections 5.2.1 .12 except for the monitoring of siren control system status which will be addressed by the Emergency Plan Advisor position which will be described in NAEP & SEP Sections 5.2.2.7.

5.2.11 LEOF Public Information Technical Advisor The LEOF Public Information Technical Advisor reports to the CERC Nuclear News Manager and is responsible for reporting directly to the appropriate LEOF, ensuring the Nuclear News Manager receives the latest technical information regarding the incident, functioning as liaison between the LEOF and Nuclear News Manager with regard to accuracy/approval of press releases, ensuring that the Recovery Manager documents (by initialing) the technical review of potential news, and ensuring that Federal, State and local personnel in the LEOF understand technical aspects of information (press releases) being transmitted to the Nuclear News Manager if deemed necessary.

5.2.12 LEOF Plant Information Coordinator The LEOF Plant Information Coordinator reports to the Recovery Manager and is responsible for providing assistance to LEOF personnel regarding use of the PCS and coordinating corrective actions should problems with the PCS arise. Figure LOCAL EMERGENCY OPERATIONS FACILITY (Page 5-Minimum Organization For Activation

10) Figure LOCAL EMERGENCY OPERATIONS FACILITY (Page 5-Fully Staffed Organization

11) 5.3 Augmentation of Station Organization The Station Emergency Manager has the authority to request additional support at the Station, Technical Support Center or Operational Support Center. These requirements will be coordinated throuoh the Recovery Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 14 of 25 The role of the LEOF Public Information Technical Advisor will not be needed because the Nuclear News Manager and News Team can interact directly with the CERC staff. The role of the LEOF Plant Information Coordinator will not be needed because the Operations Support Team will fulfill this role in the proposed CERC (see NAEP & SEP Sections 5.2.2.9).

Added NAEP & SEP Figures 5.5d. Added NAEP & SEP Figures 5.5d. Provisions for additional support are addressed in NAEP & SEP Sections 5.3.

Manager and the LEOF staff. 5.4 Coordination With Participating Government Agencies CERC personnel coordinate support activities with federal and state agencies responding to the emergency and/or recovery.

The Corporate Response Manager may also assemble NRC, state, vendor, and/or consultant support at the CERC. Assistance may be sought from other nuclear utilities, if needed. If requested by the State EOC, a Company technical representative will be dispatched to provide technical interpretation or clarification of data transmitted to that office. (This individual's responsibilities do not include making statements to the media) 6.0 Emergency Response Facilities (ERFs) Special emergency facilities are staffed upon declaration of an Alert, Site Area Emergency, or General Emergency classification.

They include the Control Room, Technical Support Center, Operational Support Center, Local Emergency Operations Facility, Corporate Emergency Response Center, and Central Emergency Operations Facility.

A Joint Information Center is activated in accordance with the Commonwealth of Virginia Radiological Emergency Response Plan. A Local Media Center may be activated when conditions warrant. The inter-relationship between the various ERFs is outlined in this section of the Plan. These facilities are designed to be a cohesive structure, each providing a role in the emergency.

6.1 Control

Room (CR) This is the main control center at the station and any emergency situation is immediately dealt within the CR (classification, assessment, etc.) Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 15 of 25 Added paragraph to NAEP & SEP Sections 5.4. Content corresponds with NAEP & SEP Sections 7.0. Content corresponds with NAEP & SEP Sections 7.1.1.

6.2 Technical

Support Center (TSC) The TSC is staffed at an Alert or greater emergency classification to assist the CR Staff and to be the focal point of the onsite emergency organization.

The TSC is in direct contact with the LEOF and CR. It serves to support in-station functions and has the necessary instrumentation and documents to permit emergency response personnel to make recommendations and advise the Station Emergency Manager. 6.3 Operational Support Center (OSC) This is an onsite ERF that is a staging area for emergency response personnel and is a resource for use by the TSC management.

6.4 Local

Emergency Operation Facility (LEOF) The North Anna LEOF Building and the Surry LEOF Building serve as the LEOF and Recovery Center. The Recovery Manager and the LEOF staff will coordinate with federal and state and local officials at this center. Field data will be gathered for analysis and provided to the LEOF. The State Mobile Lab may also support this facility.

This data will be evaluated to provide protective action recommendations to the state and locals. In addition, the LEOF will provide periodic updates of emergency information to the state and local government officials.

Upon event termination, the Recovery Manager and staff will develop a recovery plan to deal with the post emergency situation.

6.5 Corporate

Emergency Response Center (CERC) This support facility is located on the third floor of the Innsbrook Technical Center. The function of the CERC is to serve as the focal point of the inter-company effort to support the affected station, to manage the recovery operations, and to disseminate all information concerning the emergency.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 16 of 25 Content corresponds with NAEP & SEP Sections 7.1.3. Content corresponds with NAEP & SEP Sections 7.1.2. Proposed NAEP & SEP Sections 7.1.4 describe the consolidated EOF (proposed CERC). Proposed NAEP & SEP Sections 7 .1 .4 describe the consolidated EOF (proposed CERC).

6.6 Central

Emergency Operations Facility (CEOF) The CEOF is collocated with the CERC on the third floor of the Innsbrook Technical Center. If the LEOF is not functional or has to be evacuated, the CEOF will be activated using a transitional staff comprised of corporate emergency response personnel.

Other emergency response organization members may be called upon to augment the transitional staff that initially activates the CEOF. 6.7 Joint Information Center (JIC) The Joint Information Center (JIC) is located at the Virginia State Police Administrative Headquarters in Chesterfield, Virginia.

Official company statements to the media will be made from this facility, by the Chief Technical Spokesperson.

6.8 Local

Media Center (LMC) A Local Media Center will be activated at the Station Nuclear Information Center when conditions warrant. When activated, members of the media can be briefed at this facility by federal, state and/or company representatives in-person or via telephone.

Figure CORPORATE EMERGENCY RESPONSE CENTER (Page 6-4) INNSBROOK TECHNICAL CENTER, THIRD FLOOR -NORTHEAST Figure NORTH ANNA AND SURRY POWER STATION (Page 6-5) LOCAL EMERGENCY OPERATIONS FACILITY Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 17 of 25 Proposed NAEP & SEP Sections 7 .1 .4 describe the consolidated EOF (proposed CERC). Renumbered NAEP & SEP Sections 7 .1 .5 describe the Joint Information Center. Renumbered NAEP & SEP Sections 7.1.5 describes the Local Media Center in its Joint Information Center description.

NAEP and SEP do not contain images of station emergency response facility floorplans and no requirement for relocating this image has been identified.

LEOF figure no longer needed because the facility will be replaced by the consolidated EOF.

Figure NORTH ANNA AND SURRY POWER STATION (Page 6-6) LOCAL MEDIA CENTER (NUCLEAR INFORMATION CENTER) Figure MAP TO SURRY POWER STATION (Page 6-7) Figure MAP TO NORTH ANNA POWER STATION (Page 6-8) 7.0 Recovery A recovery plan is formulated upon event termination, and a recovery organization is established to accommodate the specific objectives outlined in the plan. The Recovery Manager, who is responsible for implementation and administration of the recovery plan and organization, may direct recovery operations from the Local Emergency Operations Facility, or relocate to another facility better suited to manage the recovery effort. 7.1 Recovery Plan The recovery plan is designed to expedite station damage assessment, accommodate requests for assistance in offsite recovery activities by state and local agencies (as resources allow), and initiate efforts to return the station to an operational status. Normal practices will be followed to the furthest extent possible with regard to maintenance, repair, modification, decontamination, and radiation exposure control activities:

Recovery plan objectives and Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 18 of 25 NAEP and SEP do not contain images of station emergency response facility floorplans and no requirement for relocating this image has been identified.

SEP Figure 6.6, Remote Assembly Areas, provides a similar image. NAEP Figure 6.6, Remote Assembly Areas provides a similar image. Added CERP-specific content to NAEP & SEP Sections 9.0. Added CERP-specific content to NAEP & SEP Sections 9.1.

associated schedules will be periodically evaluated and modified, if necessary, to accommodate changing circumstances.

Provisions to review, prioritize, coordinate and proceduralize recovery activities (e.g., repair, maintenance, modification, and decontamination) will also be addressed.

Specific instructions related to development of recovery plans and procedures are maintained in an Emergency Plan Implementing Procedure (EPIP) designed for this purpose. 7.2 Recovery Organization Figure 7.1, Example Recovery Organization, is representative of a typical organization that may be designated by the Recovery Manager. Responsibilities of the recovery organization include defining recovery objectives, developing a plan to accomplish these objectives, establishing controls and anticipating potential complications, monitoring the recovery effort and adjusting the plan accordingly, and evaluating accomplishments against the designated objectives.

Under the direction of the Recovery Manager, the recovery organization addresses planning and coordination of the recovery effort (in cooperation with governmental officials, when required).

Federal and state agencies may augment the recovery organization and participate in establishing recovery objectives.

Figure FIGURE 7.1 (Page 7-3) EXAMPLE RECOVERY ORGANIZATION

8.0 Maintaining

Emergency Preparedness The organizational structure for maintaining emergency preparedness is shown in the figure below: Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 19 of 25 Added CERP-specific content . to NAEP & SEP Sections 9.0 and9.1. Relocated figure to NAEP & SEP Sections 9 as Figure 9.1. The normal organization for maintaining emergency preparedness is described in NAEP & SEP Sections 8.1 8.1 The Manager Nuclear Fleet Emergency Preparedness (NFEP) is responsible for maintaining this plan and its implementing procedures, and implementing provisions of this plan at locations other than the Local Emergency Operations Facility (LEOF) and Local Media Center (LMC). The Managers Nuclear Emergency Preparedness (NEP) are responsible for implementing provisions of this plan at the LEOF and LMC. The Corporate Emergency Response Plan (CERP) and the Corporate Plan Implementing Procedures (CPIPs) are reviewed annually.

The results of this review are evaluated by the Manager NFEP. Proposed revisions to the CERP and/or CPIPs are submitted to the Manager NFEP for review and implementation.

Revisions, when implemented, are distributed in accordance with a "Controlled Distribution" list in order to maintain copies up-to-date.

Dissemination of Public Information The Company will disseminate emergency preparedness information to the public within a ten-mile radius of North Anna and Surry Power Stations.

The information, distributed on an annual basis, will include: Information regarding how the public will be notified as well as expected actions during an emergency; Educational information on radiation; Contact for additional information; Protective measures; Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 20 of 25 NAEP & SEP Sections 8.2 address annual review of emergency plans and their implementing procedures, and revisions thereof. NAEP & SEP Sections 8.8 address informing the public.

Needs of the handicapped.

The Company will coordinate efforts with state and local authorities to ensure the public (permanent, transient and handicapped residents) is informed by publications which may include telephone books, calendars, newspaper advertisements, postings and public information brochures.

The Company will conduct programs on an annual basis to inform and acquaint the media with the emergency plans, the effects of radiation and the points of contact for release of public information in an emergency.

8.2 Organizational

Preparedness

8.2.1 Training

Requirements Annual training for Corporate Emergency Response Organization members regarding implementation of the CERP and functional responsibilities is conducted.

8.2.2 Program

Maintenance The Manager NFEP coordinates shared NEP program elements for North Anna and Surry. This includes:

Corporate/Station liaison, outside agency interface, and public information and education.

The North Anna and Surry Managers NEP are responsible for the development and conduct of emergency drills and exercises, and station early warning systems. The Manager NFEP and Managers NEP are responsible for regulatory adherence, NEP staff administration, communications, and training at their respective locations.

Corporate/Station liaison activities include development and coordination of activities, as outlined in the CERP, which establish the supporting mechanism for corporate and station emergency preparedness; providing Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 21 of 25 The normal organization for maintaining emergency preparedness is described in NAEP & SEP Sections 8.1. NAEP & SEP Sections 8.3 will be revised to address station and corporate ERO training.

The normal organization for maintaining emergency preparedness is described in NAEP & SEP Sections 8.1.

guidance and assistance to corporate and station management and staff on matters relating to emergency preparedness; and providing assistance in conducting annual emergency exercises.

Regulatory adherence ensures that the emergency preparedness program meets current regulatory requirements and that Company efforts to meet these requirements are compatible with planning bases established by federal, state and local government organizations.

Liaison is maintained with federal, state, and local government agencies, (Nuclear Regulatory Commission (NRC), Federal Emergency Management Agency, Virginia Department of Emergency Management and local county and city jurisdictions) concerning matters which mutually relate to emergency planning and preparedness for nuclear power stations.

Letters of agreement between the company and supporting government agencies and volunteer organizations are reviewed and negotiated on a biennial frequency.

The NEP staff develops and maintains the CERP to ensure that provisions for corporate support during a nuclear power station emergency are kept up-to-date.

Staff members plan, coordinate and conduct emergency exercises, and ensure that the exercise program conforms to standards as prescribed by the NRC. Staff members serve as liaison to other corporate departments which provide support for emergency response functions; develop and maintaining procedures for alerting, notifying and activating corporate emergency response personnel; and review proposed station emergency plan and implementing procedure revisions for consistency, regulatory adherence and CERP interface prior to implementation.

Responsibilities in the area of communications include establishing and maintaining reliable primary and back-up means of communications for licensee, state and local response organizations; evaluating functionality Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 22 of 25 of emergency communication systems; coordinating modifications to CERP related communications systems and equipment, as necessary, for emergency response facilities at the Innsbrook Technical Center; and ensuring functionality of the Early Warning System (EWS). Public information and education responsibilities include coordinating the development and review of publications which provide information to the public in the plume exposure pathway emergency planning zone as prescribed by NUREG-0654, and establishing means for the dissemination of public information by use of periodic mailings, specific press releases, and/or telephone directory advertisements.

Training responsibilities range from identifying training needs which support emergency preparedness to ensuring emergency response training meets the guidance of NUREG-0654.

Further details concerning emergency response training are contained in Section 9 of the CERP. 8.2.3 Equipment and Supplies Inventory, inspection and functionality checks of emergency equipment/instruments in the CERC and Joint Information Center is required once each calendar quarter and after each use. These checks are performed in accordance with governing administrative procedures.

9.0 Maintaining

Emergency Preparedness Policy Statement It is the company's policy to vigorously support an emergency preparedness program for our nuclear power stations.

This goal is achieved, in part, through the selection, retention and training of qualified individuals to staff emergency response po_sitions.

Emergency Response Organization (ERO) personnel are assigned positions (i.e., added, moved and deleted, as necessary) in accordance with criteria specified the governing administrative procedures.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 23 of 25 References to required LEOF communications equipment checks detailed in NAEP & SEP Sections 8.7.d will be revised to address the CERC in lieu of the LEOF. The format of the NAEP & SEP does not include a "Policy Statement" section. NAEP & SEP Sections 8.0 provide the necessary information.

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9.1 Training Program Personnel assigned to the ERO are provided initial and continuing training in accordance with the applicable training program guide (i.e., Innsbrook, North Anna and Surry Nuclear Emergency Responder Training Program Guides (TR-IN-TPG-2400, TR-NA-TPG-2400 and TR-SU-TPG-2400, respectively) or TR-AA-TPG-2400, Emergency Response Organization (ERO) Training Program (when issued)).

The training programs are designed to achieve the following purposes:

Ensure qualified individuals are selected to participate as ERO members; Maintain an appropriate level of individual qualification and experience; Provide responders with the skills and knowledge necessary to perform assigned duties in a competent manner. Table 9.1 provides a listing of select emergency response positions along with an overview of the training provided.

9.1.1 Maintaining

Emergency Preparedness Training Program The Manager Nuclear Fleet Emergency Preparedness (NFEP) and Managers Nuclear Emergency Preparedness (NEP) are responsible for developing and maintaining training programs that meet the requirements of this plan. Program requirements for initial training of newly assigned personnel and for continuing training are specified in the program guide. Nuclear Training is responsible for developing and scheduling training that meets Emergency Plan requirements for those departments receiving annual Emergency Preparedness training through other continuing training programs.

9.1.2 Training

Records Records documenting ERO training will be maintained by Records Management.

Training records are subject to examination by company representatives assigned auditing and oversight responsibilities, and by Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 24 of 25 References to TR-NA-TPG-2400 in the NAEP Section 8.3 and TR-SU-TPG-2400 in the SEP Section 8.3 will be updated to reference TR-AA-TPG-2400 in intermediate revisions unrelated to the proposed license amendment.

The reference to CERP Table 9.1 will be superseded by the NAEP & SEP Sections 8.3.3 reference to NAEP & SEP Tables 8.1. NAEP & SEP Sections 8.3 will be revised to address station and corporate ERO training.

NAEP & SEP Sections 8.3.6 address training records.

the Nuclear Regulatory Commission.

Table 9.1 Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 2 -Page 25 of 25 NAEP & SEP Tables 8.1 will be expanded to describe the scope of training for CERP positions.

Attachment 3 Serial No.17-352 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Additional NAPS and SPS Emergency Plan Changes Requiring NRC Approval

1.0 INTRODUCTION

Serial No.17-325 Docket Nos.: 50-338/339 50-2a'o12a1 52-017 72-2/16/55/56 Attachment 3 -Page 1 of 19 Dominion Energy Virginia proposes additional changes to the North Anna Power Station (NAPS) and Surry Power Station (SPS) emergency plans. It has been determined prior Nuclear Regulatory Commission (NRG) approval is required in accordance with 10 CFR 50.54(q)(4) because the proposed changes are considered a reduction in effectiveness.

The approved emergency plans are the plans referenced in letters dated May 10, 1983 and May 13, 1983, which documented that NUREG-0737 Item 111.A.2.1, Emergency Preparedness, Upgrade Emergency Plans to Appendix E, 10 CFR 50, was complete for NAPS and SPS, respectively.

These emergency plans were dated July 22, 1982 and July 29, 1982, respectively.

The current emergency plans, NAPS Emergency Plan Revision 44 and SPS Emergency Plan Revision 63, are dated February 2, 2017 and March 16, 2017, respectively.

Dominion Energy Virginia has concluded that following implementation of the proposed changes, the NAPS and SPS emergency plans will continue to meet the requirements of Appendix E and the planning standards of 10 CFR 50.47(b), and will continue to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

The proposed changes consist of the following six areas of the NAPS and SPS emergency plans:

• Clarification of references to emergency response organization (ERO) augmentation and emergency response facility (ERF) activation goals.

• Elimination of ringdown phones between the EOF and risk jurisdictions capable of activating the site-specific Early Warning System (EWS) siren systems.

• Replacement of references to "equivalency credit" for required training sessions with reference to administrative processes for training exemptions and equivalent qualifications.

• Establishment of the station Facility Safety Review Committee (FSRC) as the approval authority for emergency plan revisions and the station Manager Nuclear Emergency Preparedness (NEP) as the approval authority for emergency plan implementing procedure (EPIP) revisions.

• Replacement of reference to letters of agreement being maintained in an emergency plan appendix with references to these letters being maintained separately.

• Expansion of the time period for, at least once in every eight-year exercise cycle, initiating a drill or exercise from between 6:00 p.m. and 4:00 a.m. to starting between 6:00 p.m. and 4:00 a.m. on a weekday or during a weekend. Details regarding each of the above proposed changes are provided in Sections 2.1 through 2.6 below.

2.0 DESCRIPTION

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 2 of 19 2.1 EMERGENCY RESPONSE ORGANIZATION AUGMENTATION AND EMERGENCY RESPONSE FACILITY ACTIVATION GOALS Dominion Energy Virginia proposes to clarify references to emergency response organization (ERO) augmentation and emergency response facility (ERF) activation goals. The NAPS and SPS emergency plans state these goals as approximations, do not define the time from which achieving these goals is measured, and do not define ERF activation.

In addition, there is an inconsistency between the NAPS and SPS emergency plan activation goals for the existing local emergency operations facilities (EOFs), and augmentation goals for select EOF and headquarters support positions.

Generic Letter 80-22, Transmittal of NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated March 10, 1980, provided interim guidance and updated acceptance criteria to applicants and licensees.

Table 8-1, Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies, listed major functional areas, major tasks, and position titles or expertise, with numbers in columns headed "On Shift" and "Additions Within 30 Minutes." The associated evaluation criteria referred to availability of capabilities and staffing within one-half hour following the declaration of the emergency class. When NUREG-0654/FEMA-REP-1, Revision 1 was issued in October 1980, "one-half hour following" was replaced by "a short period after and referenced capability as indicated in Table 8-1. This table contained a column headed "Capability for Additions" with "30 min" and "60 min" sub-columns within that column. Proposed NAPS Emergency Plan dated May 1, 1980, Table 5.1, Minimum Shift Manning Requirements, provided a table listing major functional areas, major tasks, and position titles or expertise, with numbers in columns headed "On Shift" and "Additions Within 60 Minutes." Headings in proposed page changes dated June 25, 1980 and July 24, 1980 were identical.

Proposed SPS Emergency Plan dated May 1, 1980, Table 5.1, Minimum Shift Manning Requirements, provided a table listing major functional areas, major tasks, and position titles or expertise, with numbers in columns headed "On Shift" and "Additions Within 60 Minutes After Notification:" The post-EP Appraisal NAPS Emergency Plan dated July 22, 1982 (Revision 0), Table 5.1 listed major functional areas, location, major tasks, and emergency titles, with numbers in columns headed "On Shift" and "Additional Within Approx." over "30 Min." and "60 Min." columns. Section 5, Organizational Control of Emergencies, of the post-EP Appraisal SPS Emergency Plan dated July 29, 1982 (Revision 0), was revised on August 2, 1982 (Revision 1 ). This table listed major functional areas, major tasks, and position titles, Serial No.17-325 Docket Nos.: 50-338/339

' 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 3 of 19 with numbers in columns headed "On Shift" and "Additions Within 60 Minutes After Notification." SPS Emergency Plan dated September 17, 1982 (Revision

3) replaced the column "Additions Within 60 Minutes After Notification" with a "Capability For Additions" heading over "==30 Min." and "==60 Min." columns. Although NRC's January 13, 1984 letter that responded to letters dated April 8, 1982, December 6, 1982, April 14, 1983 and May 6, 1983 regarding the design of the EOFs for NAPS and SPS accepted "1 1/2 hours" as the EOF activation goal, the times stated in NAPS Emergency Plan Table 5.2, Emergency and Recovery Corporate Response Required for Nuclear Station Emergencies, for the local EOF Recovery Manager and Radiological Assessment Coordinator positions was 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The corresponding table in the SPS Emergency Plan listed "1 1h hours" for these positions.

By letter dated November 30, 1988, a request for approval was submitted to revise NAPS Emergency Plan, Table 5.1 to align response times for other positions with the "approximately one hour after activation" TSC activation goal described in NUREG-0737, Supplement 1, and Table 5.2 to align position-specific local EOF response times with the EOF activation goal NRC accepted in its January 13, 1984 letter. A similar request for prior approval to revise SPS Emergency Plan, Table 5.1 was submitted on June 30, 1989. NRC letter dated September 8, 1989 indicated that the requested change did not provide an equivalent alternative to recommended augmentation times. Consequently, the previous requests were superseded by letter dated January 17, 1990, which proposed adjusting the TSC Core/Thermal Hydraulic Engineer augmentation time from approximately 30 minutes to approximately 60 minutes, primarily due to the capabilities of the on-shift Shift Technical Advisor. Letter dated May 18, 1990, provided NRC's review and conclusion that the proposed changes were consistent with the provisions of 1 O CFR 50.47(b), Appendix E, and Supplement 1 to NUREG-0737.

By letter dated February 18, 1994, a request for approval was submitted to revise the NAPS and SPS Emergency Plan, Table 5.1 to address on-shift staffing and delete Table 5.2. The proposed alternative to position-specific augmentation was facility / function-activation including the positions listed in Tables 5.1 and 5.2, and other positions considered necessary for emergency response facility functionality.

The proposed facility activation goals were within approximately 60 minutes, except for the Surry local EOF with a proposed facility activation goal of within approximately 90 minutes. By letter dated July 6, 1995, NRC indicated that the requested change would be considered a decrease in effectiveness.

A July 18, 1995 NRC summary of a July 11, 1995 meeting on this subject documented a new package would be submitted and that commitments for emergency response facility activation goals would be added to the respective site emergency plan. The revised emergency plan submittal, which included adding facility activation goals of approximately 60 minutes (approximately 90 minutes for the Surry local EOF) and changing the Table 5.1 column headings from "Additional Within Approximately 30 Min." to "Additional Within Approximately 45 Min." was Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 4 of 19 submitted by letter dated September 6, 1995. NRC letters, with associated safety evaluation reports, dated December 12, 1995 for NAPS and December 13, 1995 for SPS, provided NRC's approval of the proposed change and concluded that the extension of response times for selected positions was reasonable and that the NAPS and SPS emergency plans continued to meet the standard required by 10 CFR 50.47(b).

NAPS Emergency Plan Revision 18 (January 3, 1996) and SPS Emergency Plan Revision 40 (January 1, 1996) implemented the approved changes. The proposed change is to specify that the start time for augmentation is the declaration of an Alert or higher emergency class (unless special circumstances apply), clarify references to approximate times by rounding-up approximations to the next quarter hour (e.g., approximately 60 minutes becomes 75 minutes), align NAPS and SPS ERFs activation.

goals with the proposed Corporate Emergency Response Center (CERC) activation goal, and define ERF activation as the assembly of required positions in or under the operational control of the designated ERF lead and their declaring the facility activated.

Special circumstances include those where the movement of emergency responders could place them at risk, e.g., security conditions, severe weather, hazardous environments.

The NAPS and SPS on-shift staffing analyses (OSAs) showed that, for the event sequences analyzed, on-shift responders can appropriately respond to an emergency without an augmented staff for a time period of up to 90 minutes. Thus, the on-shift staff can analyze the conditions and declare the appropriate emergency class within the 15 minutes required by 10 CFR 50, Appendix E, Section IV.C.2, notify the Commonwealth*

of Virginia Emergency Operations Center (EOG) and site-specific risk-jurisdiction 911 Centers, and respond to the event for 75 minutes after event declaration.

2.2 ELIMINATION

OF COUNTY RINGDOWN PHONES Dominion Energy Virginia proposes to eliminate automatic ringdown (ARD) phones between the EOF and risk jurisdictions capable of activating the site-specific Early Warning System (EWS) siren systems. The following are excerpts from a letter, subject: NUREG-0696, Emergency Response Facilities, North Anna and Surry Power Stations, dated April 8, 1982: "At the Surry Local EOF, communications will also include ringdown phones to James City County and Surry County." "At the North Anna Local EOF, communications will also include ringdown phones to Louisa and Spotsylvania Counties." A revised submittal, subject: Generic Letter 82-33, Emergency Operations Facilities, North Anna and Surry Power Stations, dated May 6, 1983, replying to Generic Letter 82-33 (Supplement 1 to NUREG-0737

-Emergency Response Capability)

Section Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 5 of 19 8.4.1.f reaffirmed that the communications links described above would be provided.

N RC letter dated January 13, 1984 replied to these submittals and indicated that a implementation appraisal would be conducted after the emergency response facilities were completed.

SPS Emergency Plan dated February 18, 1988 (unnumbered, Revision 31) Section 7.2.1, Communications Systems Within the Station, and Figure 7.4, Communications Links, identified that the local EOF had ARDs to several locations, including Surry County and James City County. The NAPS Emergency Plan dated October 2, 1989 (Revision

12) added Table 7.1, ERF [Emergency Response Facility]

Communications, which identified that the local EOF had ARDs to several locations, including Louisa

• County and Spotsylvania County. SPS Emergency Plan Revision 33 (effective February 21, 1991) relocated the contents of Section 7.2.1 to a new Table 7.1, ERF Communications.

The current NAPS and SPS emergency plans (NAPS Emergency Plan Revision 44, effective February 2, 2017, and SPS Emergency Plan (Revision 63, effective March 16, 2017) continue to identify that there are ARDs from the respective site's local EOF to their associated counties in Table 7.1. Figure 7.3, Communications Links, in SPS Emergency Plan Revision 63 also identifies this ARD capability for SPS. The difference between these counties and other risk jurisdictions is that they are capable of activating their site-specific EWS siren systems (the Commonwealth of Virginia Emergency Operations Center is capable of activating both the Surry EWS sirens and the North Anna EWS sirens). As described in SPS and NAPS Emergency Plan, Sections 6.2, Protective Actions, recommendations for offsite protective actions are made to the State [Commonwealth of Virginia].

Commonwealth of Virginia protocols provide for consultation with risk jurisdictions prior to the issuance of protective action decisions by the Governor.

No records have been found indicating that these county ARDs have ever been used during any drill, exercise or actual event, although functionality has been checked each quarter for more than 30 years. 2.3 TRAINING EXEMPTION/EQUIVALENT QUALIFICATION Dominion Energy Virginia proposes to replace references to "equivalency credit" for required training sessions with reference to administrative processes for training exemptions and equivalent qualifications.

The NAPS and SPS emergency plans identify the approval authority for awarding equivalency credit as the Director Nuclear Emergency Preparedness and the Site Vice President.

These provisions were not described in the approved emergency plans (NAPS Revision 0, July 22, 1982 and unnumbered SPS Revision 0, July 29, 1982). These provisions were added to the NAPS and SPS emergency plans in Revision 12 (October 2, 1989) and Revision 34 (March 10, 1992), respectively.

When added, the approval authority was vested in the Superintendent of Nuclear Training and the Station Manager. These approval authorities were selected at that time because emergency planning management was assigned to the Corporate Emergency Planning department which Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 6 of 19 intertaced with on-site coordinators in the station organizations.

These positions were identified as appropriate because the ERO was populated by employees across multiple departments.

The Superintendent of Nuclear Training was changed to the Director Nuclear Emergency Preparedness when the. Corporate Emergency Preparedness Department assumed line-management responsibility for on-site coordination activities, including responsibility for training in 1996. This change was reflected in NAPS Emergency Plan Revision 19 (December 11, 1996) and SPS Emergency Plan Revision 41 (December 17, 1996). The Station Manager was changed to the Site Vice President in NAPS Emergency Plan Revision 22 (July 17, 1998) and SPS Emergency Plan Revision 43 (August 12, 1998) pursuant to Technical Specification Amendment No. 212 to Facility Operating License No. NPF-4 and Amendment No. 193 to Facility Operating License No, NPF-7 for NAPS Unit Nos. 1 and 2, respectively (issued on June 23, 1998), and Amendment No. 215 to Facility Operating License No. DPR-32 and Amendment No. 215 to Facility Operating License No. DPR-37 for SPS Unit Nos. 1 and 2, respectively (issued on June 19, 1998). As described in Topical Report DOM-QA-1, Nuclear Facility Quality Assurance Program Description (Revision 22, effective July 1, 2016), an emergency preparedness management position now exists within the station organization.

Thus, there is now a separate facility emergency preparedness group responsible for development and maintenance of the Company radiological emergency plan for NAPS and a separate facility emergency preparedness group for SPS. Accordingly, the Director Nuclear Emergency Preparedness was changed to the location-specific emergency preparedness manager in NAPS Emergency Plan Revision 44 (effective February 2, 2017) and SPS Emergency Plan Revision 63 (effective March 16, 2017). The administrative process for training exemptions and equivalent qualifications requires approval by the training program owner. The location-specific emergency preparedness training program owner for station ERO positions is the NAPS or SPS Manager Nuclear Emergency Preparedness, as appropriate, and for corporate positions the Manager Nuclear Fleet Emergency Preparedness.

The proposed change will align the emergency preparedness training exemption and equivalent qualification processes with the process employed by other nuclear training programs.

2.4 APPROVAL

AUTHORITY FOR CHANGES TO EMERGENCY PLANS AND IMPLEMENTING PROCEDURES Dominion Energy Virginia proposes to establish the station Facility Safety Review Committee (FSRC) as the approval authority for changes to the Emergency Plan and establish the respective site Manager Nuclear Emergency Preparedness (NEP) as the approval authority for emergency plan implementing procedure (EPIP) revisions.

Appendix "A" to License No. NPF-4, NAPS Unit 1 Technical Specifications, dated November 26, 1977, included Administrative Control 6.5.1.6.j, which indicates:

"[T]he Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 7 of 19 SNSOC (Station Nuclear Safety and Operating Committee) shall be responsible for ... Review of the Emergency Plan and implementing procedures and shall submit recommended changes to the Chairman of the Station Nuclear Safety and Operating Committee." By letter dated February 23, 1981 , which supplemented requests to modify SPS Technical Specifications dated March 31, 1980 (supplemented by letter dated August 4, 1980), August 28, 1980 and November 14, 1980, it was requested that Administrative Control 6.1.C.1.f

.10 be added to indicate the SNSOC shall be responsible for: "Review of the Emergency Plan and its implementing procedures and shall submit recommended changes to the Chairman of the Station Nuclear Safety and Operating Committee." This addition was not explicitly described in the accompanying Safety Evaluation Report, which described other changes. The SER stated: "[T]he proposed changes to the Administrative Controls Section of Technical Specifications formalizes the licensee's new corporate and plant organization." Associated Amendment No. 69 to Facility Operating License No. DPR-32 and Amendment No. 69 to Facility Operating License No. DPR-37 for the Surry Power Station, Unit Nos. 1 and 2, respectively, were issued on May 22, 1981. * . Sections 8.5.1 and 8.5.2 of the approved Emergency Plan (July 22, 1982 for NAPS and July 29, 1982 for SPS, Revisions

0) stated that revisions to the emergency plan and EPIPs shall be reviewed and approved by the Station Nuclear Safety and Operating Committee (SNSOC). These provisions aligned with the administrative controls in NAPS and SPS Technical Specifications described above. These provisions were relocated to Sections 8.2.1 and 8.2.1 of NAPS Emergency Plan Revision 8, effective September 27, 1984, and combined into Section 8.2.1 of NAPS Emergency Plan, Revision 12, effective October 2, 1989. These provisions were relocated to Sections 8.2.1 and 8.2.1 of SPS Emergency Plan, Revision 15, effective June 28, 1984, and combined into Section 8.2.1 of SPS Emergency Plan, Revision 30, effective July 30, 1987. The proposed revision is to split the existing Section 8.2.1 into three separate sections addressing the annual review of the emergency plan and EPIPs (Section 8.2.1 ), revision of the emergency plan (Section 8.2.3), and maintenance of the EPIPs (Section 8.2.4). Also, the reference to 1 OCFR50.54(q) in the existing Section 8.2.1 will specify sections (3) and (4) with respect to emergency plan revisions, and sub-section (2) with respect to maintenance of EPIPs. By letters dated November 2, 1984, modifications to NAPS and SPS Technical Specifications were proposed with respect to the approval authority for changes to the Emergency Plan and its implementing procedures.

Previously, following review by the SNSOC, recommended Emergency Plan and EPIP changes were submitted to the SNSOC Chairman, a role assigned to the Station Manager. The proposed change was to assign the new Assistant Station Manager (Nuclear Safety and Licensing) position as the SNSOC Chairman and for the SNSOC to review Emergency Plan and EPIP Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 8 of 19 changes and submit recommended changes to the Station Manager. The NRC Safety Evaluation Report dated December 11, 1985, documented that the proposed changes, which included but were not limited to the approval of emergency plan and implementing procedure changes, were acceptable as they meet the acceptance criteria of Sections 13.1.1, 13.1.2, and 13.4 of NUREG-0800, the Standard Review Plan. Associated Amendment No. 104 to Facility Operating License Nos. DPR-32 and DPR-37 for SPS Unit Nos. 1 and 2, were issued on December 11, 1985. Associated Amendment No. 78 to Facility Operating License No. NPF-4 and Amendment No. 67 to Facility Operating License No. NPF-7 for NAPS Unit Nos. 1 and 2, respectively, were issued on May 6, 1986. These provisions were incorporated into Section 8.2.1 of SPS Emergency Plan Revision 30, effective July 30, 1987. These provisions were incorporated into Section 8.2.1 of NAPS Emergency Plan Revision 12, effective October 2, 1989. By letter dated July 20, 1993, modifications to NAPS and SPS Technical Specifications were proposed to remove NAPS Administrative Control 6.5.1.6.j and SPS Administrative Control 6.1.C.1.f

.10. These requests were made pursuant to a proposed generic communication published in Federal Register Volume 58 (17293), which allowed re-locating these requirements to the Emergency Plan. Guidance was subsequently issued as NRC Generic Letter 93-07, Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans, dated December 28, 1993. NRC Safety Evaluation Report dated March 1, 1994, documented that the proposed changes were acceptable as they met the acceptance criteria of Section 5.5.1 of the Improved Standard Technical Specifications.

Associated Amendment No. 180 to Facility Operating License No. NPF-4 and Amendment No. 161 to Facility Operating License No. NPF-7 for NAPS Unit Nos. 1 and 2, respectively, and Amendment No. 188 to Facility Operating License Nos. DPR-32 DPR-37 for SPS Unit Nos. 1 and 2, were issued on March 1, 1995. Technical Specification Amendment No. 212 to Facility Operating License No. NPF-4 and Amendment No. 193 to Facility Operating License No, NPF-7 for NAPS Unit Nos. 1 and 2, respectively (issued on June 23, 1998), and Amendment No. 215 to Facility Operating License Nos. DPR-32 and DPR-37 for SPS Unit Nos. 1 and 2, respectively (issued on June 19, 1998), replaced references to the Station Manager with Site Vice President with respect to Emergency Plan and implementing procedure approval.

Subsequently, NAPS and SPS Emergency Plan Section 8.2.1 references to the Station Manager were revised to reference the Site Vice President as the approval authority for Emergency Plan and implementing procedure changes (NAPS Emergency Plan, Revision 22 (July 17, 1998) and SPS Emergency Plan, Revision 43 (August 12, 1998)). Prior to 1982, emergency planning was one of multiple functions assigned to a series of corporate departments (e.g., Technical Services, Corporate Licensing and Quality Assurance, and Corporate Quality Assurance).

In January 1982, a Corporate Emergency Planning department was established for NAPS and SPS, interfacing with Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 9 of 19 on-site coordinators in the station organizations.

In August 1996, the Corporate Emergency Preparedness Department assumed line-management responsibility for site coordination activities.

As described in Topical Report DOM-QA-1, Nuclear Facility Quality Assurance Program Description (Revision 22, effective July 1, 2016), an emergency preparedness management position now exists within the station organization.

Thus, there is now a facility Emergency Preparedness group responsible for development and maintenance of the Company radiological emergency plans for NAPS and a separate group for SPS. Benchmarking has revealed that approval of proposed revisions to the Emergency Plan by multi-disciplinary plant operating review committees (PORCs), which Dominion Energy Virginia refers to as FSRCs, is typical in the industry.

Approval by a site executive (or corporate executive for fleet emergency plans) is not universal.

For example, at the Dominion Nuclear Connecticut, lnc.'s Millstone Power Station, the approval authority is vested in the FSRC. With respect to EPIPs, benchmarking did not identify any other stations where EPIP revisions required PORC review (there were examples where specific EPIPs received a PORC review). In most cases, EP manager(s) maintain the authority to approve EPIP revisions.

Designating the FSRC as the approval authority for revisions to the Emergency Plan will align the content of the NAPS Emergency Plan for Units 1 and 2 with Section 11.P.4 of the North Anna Unit 3 Combined License Emergency Plan. This will preclude having to reconcile approval of these documents in the future. Consistent with the proposed change, Topical Report DOM-QA-1 Section 6.3, Document Review and Approval, specifies, "[D]ocuments, including procedures, programs and changes thereto are approved by responsible management or the facility safety review committee, as applicable." 2.5 MAINTENANCE OF EMERGENCY PLAN LETTERS OF AGREEMENT Dominion Energy Virginia proposes to replace references to letters of agreement being maintained in an appendix to the Emergency Plan with references to these letters being maintained separately.

Section 5.3.3 of the approved NAPS and SPS Emergency Plans (July 22, 1982 for NAPS and July 29, 1982 for SPS, Revisions

0) documents that letters of agreement in support of the NAPS and SPS Emergency Plans would be re-negotiated once every 2 years. The letters of agreement were included in an appendix to the Emergency Plans. Section 5.3.3 of the current NAPS and SPS Emergency Plan contains a similar statement and the current letters of agreement also appear in an appendix to NAPS Emergency Plan Revision 44 (effective February 2, 2017) and SPS Emergency Plan Revision 63 (effective March 16, 2017). NUREG-0053 Supplement 11, Safety Evaluation Report related to the operation of North Anna Power Station, Unit 2 for Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 10 of 19 NAPS Unit 2 (August 1980), Appendix B, Emergency Preparedness Evaluation Report, Section P indicates:

"[R]e-negotiated letters will be distributed as revisions to the Plan." NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Section 11.B.9 indicates copies of agreements are to be appended to the licensee's Emergency Plan. NRG Region II EP Inspectors have recommended that the letters of agreement be removed from the Emergency Plans and be maintained on-file where they are easily assessable for review during inspections.

Benchmarking has revealed that a large number of licensees have Emergency Plans that contain a list of agencies with which letters of agreement are maintained without having the letters of agreement in the Emergency Plan. 2.6 EXPANDING THE TIME PERIOD FOR STARTING A DRILL OR EXERCISE OUTSIDE NORMAL WORKING HOURS Dominion Energy Virginia proposes to expand the time period for starting a drill or exercise outside normal working hours. Currently, at least once in every eight-year exercise cycle, a drill or exercise is required to be initiated "between 6:00 p.m. and 4:00 a.m." It is proposed to change the initiation time to "between 6:00 p.m. and 4:00 a.m. on a weekday or during a weekend." NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (November 1980), Section 11.N.1.b, provided evaluation criteria for meeting the 10 CFR 50.47(b)(14) emergency planning standard, which concerns drills and exercises.

As originally presented, this criteria called for each organization to make provisions to start an exercise between 6:00 p.m. and midnight, and another between midnight and 6:00 a.m. At the time the criteria were developed, exercise frequency was annual and there was a five year period during which major elements of the plans and preparedness organizations were to be tested. Subsequently, on September 28, 1983, FEMA published the "Review and Approval of State and Local Radiological Emergency Plans and Preparedness" final rule, 44 CFR 350 in the Federal Register (48 FR 44332). 44 CFR 350 changed the exercise frequency for state and local governments to a biennial requirement

[see 44 CFR 350.9(c)(1

)-(4)]. The final rule became effective October 28, 1983. FEMA Guidance Memorandum (GM) PR-1, Policy on NUREG-0654/FEMA-REP-1 and 44 CFR 350 Periodic Requirements (October 1 , 1985) was issued to interpret and clarify the subject requirements.

In part, this guidance modified the NUREG-0654/FEMA-REP-1 Section 11.N.1.b criteria (i.e., annual exercise, testing of major elements over a five-year period, and starting an exercise between 6:00 p.m. and midnight, and another between midnight and 6:00 a.m.) to correspond with 44 CFR 350.9(c)(1

)-(3) (i.e., a biennial exercise frequency).

The revised guidance referred to a Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 11 of 19 biennial exercise, testing of major elements over a six-year period, and starting an . exercise between 6:00 p.m. and 4:00 a.m. on a weekday or during a weekend. NUREG-0654/FEMA-REP-1 Supplement 1, Criteria for Utility Offsite Planning and Preparedness (September 1988), Section 11.N.1.b, carried forward provisions for a biennial exercise, testing of major elements over a six-year period, and starting an exercise between 6:00 p.m. and 4:00 a.m., but not include the, "on a weekday or during a weekend" clause. NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants (November 2011 ),Section IV.G, Challenging Drills and Exercises, revised Evaluation Criterion 11.N.1.b to recognize that scenarios may be based on non-accidental events, remove criteria for the conduct of post-exercise critiques for onsite and offsite emergency response organizations, and replace out-of-date references to an annual exercise and five-year period. In addition, criteria for conducting off-hour and unannounced exercises were relocated to new Evaluation Criterion 11.N.1.c, which appears below: "Provisions must be made to start a drill or exercise between 6:00 p.m. and 4_:00 a.m. at least once in every eight-year exercise cycle. Some drills or exercises should be unannounced." The current emergency plans (NAPS Emergency Plan Revision 44 (effective February 2, 2017) and SPS Emergency Plan Revision 63 (effective March 16, 2017)) reflect this criterion at Sections 8.6.1, Scheduling of Emergency Exercises.

The underlying objective of the criteria is to demonstrate response at times when the majority of licensee staff is away from their normal work location.

It recognizes that commercial nuclear power plant emergencies may take place at any time, and response organizations should have the capability to respond at any time of the day or night, and on weekends.

This involves augmentation by personnel who are at off-duty locations prior to the start of the exercise or drill. Starting a drill or exercise between 4:00 a.m. and 6:00 p.m. on a weekend supports the underlying objective.

Expanding this time period will align the content of the NAPS Emergency Plan for Units 1 and 2 with Section 11.N.1.c of the North Anna Unit 3 Combined License Emergency Plan. This will preclude having to reconcile these documents in the future.

3.0 CONCLUSION

The proposed change to the NAPS and SPS Emergency Plans are as follows: 1) clarify ERO augmentation and ERF activation goals, 2) eliminate ringdown phones between the EOF and risk jurisdictions capable of activating the site-specific EWS siren systems, 3) replace references to "equivalency credit" for required training sessions with reference to administrative processes for training exemptions and equivalent qualifications, 4) establish the station's FSRCs as the approval authority for emergency plan revisions and the station's Manager NEP as the approval authority for EPIP Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 12 of 19 rev1s1ons, 5) replace reference to letters of agreement being maintained in an emergency plan appendix with references to these letters being maintained separately, and 6) expand the time period for crediting a drill or exercise initiated between 4:00 a.m. and 6:00 p.m. on a weekend as satisfying off-hours criteria.

The changes constitute reductions in the effectiven~ss of the emergency plan. Therefore, NRG approval is required to implement these changes to satisfy the requirements of 10 CFR 50.54(q)(4).

4.0 JUSTIFICATION

The proposed changes affect the NAPS and SPS emergency plan, but do not alter any of the requirements of the Operating Licenses or the Technical Specifications.

The changes do not alter any of the assumptions used in the safety analyses, nor do they cause any safety system parameters to exceed its acceptance limit. Therefore, the proposed changes have no adverse effect on plant safety. Additionally, the changes would not have an adverse impact to plant operations or to the health and safety of the public. Based on the technical analysis performed by Dominion Energy Virginia, the proposed changes are acceptable.

4.1 REQUIREMENTS

AND GUIDANCE -CLARIFICATION OF ERO AUGMENTATION AND ERF ACTIVATION GOALS The 10 CFR 50.47(b)(2) emergency planning standard for establishing and maintaining the process for timely augmentation of the on shift staff and associated program elements related to availability of timely augmentation of response capabilities will continue to be met as discussed above. The composition of the ERO and the functions of the ERFs remain the same. The proposed ERO augmentation and ERF activation goals replace the approximate times contained in the emergency plans with equivalent, specific goals. 4.2 ELIMINATION OF COUNTY RINGDOWN PHONES The 10 CFR 50.47(b)(6) emergency planning standard for providing prompt communications among principal response organizations and the 10 CFR 50.47(b)(8) emergency planning standard for maintaining adequate emergency facilities and equipment will continue to be met because reliable primary and back-up means of communications continue to exist. The 10 CFR 50.47(b)(5) emergency planning standard for notification methods and procedures, and the 10 CFR 50 Appendix E, Part IV.D.3 requirements for having the capability to notify responsible state and local governmental agencies within 15 minutes after declaring an emergency are not reduced because reliable primary and back-up means of communications continue to exist. __J Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 13 of 19 4.3 REQUIREMENTS AND GUIDANCE -USE OF ADMINISTRATIVE PROCESSES FOR TRAINING EXEMPTIONS AND EQUIVALENT QUALIFICATIONS The 10 CFR 50.47(b)(15) emergency planning . standard for providing radiological emergency response training to those who may be called on to assist in an emergency, and the 10 CFR 50 Appendix E, Part IV.F.1 requirements regarding licensee employees being familiar with their specific emergency response duties and that the emergency plans contain a description of specialized and initial and periodic retraining be provided for various categories of emergency personnel will continue to be met as discussed above. The existing requirement was self-imposed, and based on the station organization and assignment of emergency preparedness training responsibilities that existed at the time. Assigning responsibility for making these decisions to the training program owner will bring ERO training processes into alignment with other nuclear training programs.

This constitutes a change to the licensing basis requiring prior NRC review because this individual is lower in the organization's hierarchy.

4.4 REQUIREMENTS

AND GUIDANCE -APPROVAL AUTHORITY FOR EMERGENCY PLAN AND IMPLEMENTING PROCEDURE REVISIONS

• 10 CFR 50 Appendix E, Part IV addresses the content of emergency plans, but does not prescribe licensee processes for making changes thereto. The 10 CFR 50.47(b){16) emergency planning standard concerning plan development and review will continue to be met because the responsibility for development and updating of emergency plans continues to be assigned.

The designation of approval authority will conform with Topical Report DOM-QA-1, Nuclear Facility Quality Assurance Program Description.

4.5 REQUIREMENTS

AND GUIDANCE -MAINTENANCE OF EMERGENCY PLAN LETTERS OF AGREEMENT The 10 CFR 50.47(b)(2) and (3) emergency planning standards for identifying offsite support services will continue to be met because the agreements will continue to be maintained and will be available for inspection.

The 10 CFR 50.47(b)(16) emergency planning standard concerning plan development and review will continue to be met because the responsibility for development and updating of emergency plans continues to be assigned.

4.6 EXPANDING

THE TIME PERIOD FOR STARTING A DRILL OR EXERCISE OUTSIDE NORMAL WORKING HOURS The 10 CFR 50A7(b)(14) emergency planning standard for conducting drills and exercises will continue to be met because a drill or exercise will continue to be started outside normal working hours during the eight-year exercise cycle. Starting a drill or exercise between "4:00 a.m. and 6:00 p.m. on a weekend" is equivalent to starting a drill Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 14 of 19 or exercise between "6:00 p.m. and 4 a.m." because the majority of licensee staff will be away from their normal work location when augmentation processes are initiated.

5.0 NO SIGNIFICANT HAZARDS CONSIDERATION Dominion Energy Virginia has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed changes addressing the three criteria set forth in 10 CFR 50.92(c) as discussed below. Criterion 1: Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No. The proposed changes affect the NAPS and SPS emergency plans, but do not alter any of the requirements of the Operating Licenses or the Technical Specifications.

The proposed changes do not modify any plant equipment and do not impact any failure modes that could lead to an accident.

Additionally, the proposed changes have no effects on the consequences of any analyzed accident since the changes do not affect any equipment related to accident mitigation.

Based on this discussion, the proposed amendment does not increase the probability or consequences of an accident previously evaluated.

Criterion 2: Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No. The proposed changes affect the NAPS and SPS emergency plans, but do not alter any of the requirements of the Operating Licenses or the Technical Specifications.

The proposed changes do not modify any plant equipment and do not impact the capability of existing equipment to perform its intended functions.

No system setpoints are being modified.

No new failure modes are introduced by the proposed changes. The proposed changes do not introduce any accident initiators or malfunctions that would cause a new or different kind of accident.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3: Does the proposed amendment involve a significant reduction in a margin of safety? Response:

No.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 15 of 19 The proposed changes affect the NAPS and SPS emergency plans, but do not alter any of the requirements of the Operating Licenses or the Technical Specifications.

The proposed changes do not affect any of the assumptions used in the accident analyses and does not affect any operability requirements for equipment important to plant safety. Therefore, the proposed amendment does not involve a significant reduction in the margin of safety. In summary, Dominion Energy Virginia concludes that the proposed change does not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

6.0 ENVIRONMENTAL

CONSIDERATION Dominion Energy Virginia has determined that the proposed changes would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor would it change inspection or surveillance requirements.

Dominion Energy Virginia has evaluated the proposed changes and has determined that the changes do not involve:

• A Significant Hazards Consideration,

• A significant change in the types or significant increase in the amounts of an effluent that may be released offsite, or

• A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (1 O)(ii). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

7.0 REFERENCES

7.1 1 O CFR 20 -Standards for Protection Against Radiation.

7.2 10 CFR 50 -Domestic Licensing of Production and Utilization Facilities sub-parts 47 Emergency plans, 54 Conditions of licenses and 92 Issuance of amendment, and Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities.

7.3 10 CFR 51 -Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions sub-part 22 Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review. 7.4 44 CFR 350 -Review and Approval of State and Local Radiological Emergency Plans and Preparedness sub-part 9 Exercises.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 16 of 19 7.5 Federal Register, Volume 48, Number 189, Wednesday, September 28, 1983 (Pages 44332-44341

), Review and Approval of State and Local Radiological Emergency Plans and Preparedness:

Final Rule. 7.6 FEMA Guidance Memorandum (GM) PR-1, Policy on NUREG-0654/FEMA-REP-1 and 44 CFR 350 Periodic Requirements, dated October 1, 1985. 7.7 NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (November 1980). 7.8 NUREG-0654/FEMA-REP-1, Revision 1, Supplement 1, Criteria for Utility Offsite Planning and Preparedness (September 1988). 7.9 NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants (November 2011 ). 7.10 Generic Letter 80-22, Transmittal of NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated March 10, 1980. 7.11 Generic Letter 82-33, Supplement 1 to NUREG-0737

-Emergency Response Capability, dated December 17, 1982. 7.12 Generic Letter 93-07, Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans, dated December 28, 1993. 7.13 Safety Evaluation Report related to the operation of North Anna Power Station Unit 2 (NUREG-0053 Supplement

11) (August 1980). 7.14 Nuclear Reactor Regulation Letter, Issuance of Facility Operating License No. NPF-4 -North Anna Power Station Unit 1, dated November 26, 1977. 7.15 Nuclear Reactor Regulation Letter, untitled (transmitted Amendment No. 69 to Facility Operating License No. DPR-32 and Amendment No. 69 to Facility Operating License No, DPR-37 for the Surry Power Station, Unit Nos. 1 and 2, respectively), dated May 22, 1981. 7.16 Nuclear Reactor Regulation Letter, NUREG-0737 Item 111.A.2.1 Emergency Plan Upgrade to Meet Rule [Re: North Anna Power Station, Unit No. 1 and No. 2 (NA-1&2)), dated May 10, 1983. 7.17 Nuclear Reactor Regulation Letter, NUREG-0737 Item 111.A.2.1

-Emergency Plan Upgrade to Meet Rule (Surry Power Station Unit Nos. 1 and 2), dated May 13, 1983.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 17 of 19 7.18 Nuclear Reactor Regulation Letter, untitled (advised that the Commission found the location of the back-up and primary EOFs for NAPS and SPS acceptable), dated January 13, 1984. 7.19 Nuclear Reactor Regulation Letter, untitled (transmitted Amendment No. 104 to Facility Operating License No. DPR-32 and Amendment No. 104 to Facility Operating License No, DPR-37 for the Surry Power Station, Unit Nos. 1 and 2, respectively), dated December 11, 1985. 7.20 Nuclear Reactor Regulation Letter, untitled (transmitted Amendment No. 78 to Facility Operating License No. NPF-4 and Amendment No. 67 to Facility Operating License No, NPF-7 for the North Anna Power Station, Unit Nos. 1 and 2, respectively), dated May 8, 1986. 7.21 NRC Region II Letter, North Anna Power Station Emergency Plan Review, dated September 8, 1989. 7.22 NRC Region II Letter, Surry and North Anna Proposed Emergency Plan Changes, dated May 18, 1990. 7.23 -Nuclear Reactor Regulation Letter, Surry Power Station Units 1 and 2 and North Anna Power Station Units 1 and 2 -Issuance of Amendments Re: Review and Audit Frequencies (No. 188 to Facility Operating License Nos. DPR-32 and DPR-37, No. 180 to Facility Operating License No. NPF-4, and Amendment No. 161 to Facility Operating License No. NPF-7), dated March 1, 1994. 7.24 NRC Region II Letter, Review of Proposed Plan Change Request for Emergency Plan Changes for Surry, dated July 6, 1995. 7.25 NRC Region II Letter, Review of Proposed Plan Change Request for Emergency Plan Changes for North Anna, dated July 6, 1995. 7.26 Nuclear Reactor Regulation summary, July 11, 1995 Meeting with VEPCO Representatives, dated July 18, 1995. 7.27 Nuclear Reactor Regulation Letter, Review of Proposed Cost Beneficial Licensing Action Request for Emergency Plan Changes for North Anna Power Station, dated December 12, 1995. 7.28 Nuclear Reactor Regulation Letter, Surry Power Station, Units 1 and 2 Emergency Plan Revisions, dated December 13, 1995. 7.29 Nuclear Reactor Regulation Letter, Surry Unit 1 and 2 -Issuance of Amendments Re: Station Management Title Changes (No. 215 to Facility Operating License No. DPR-32 and Amendment No. 215 to Facility

• Operating License No. DPR-37), dated June 19, 1998.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -Page 18 of 19 7.30 Nuclear Reactor Regulation Letter, North Anna Power Station, Unit 1 and 2 -Issuance of Amendments Regarding a Proposed Technical Specification Change on Station Management Title Changes (No. 212 to Facility Operating License No. NPF-4 and Amendment No. 193 to Facility Operating License No. NPF-7), dated June 23, 1998. 7.31 Topical Report DOM-QA-1, Nuclear Facility Quality Assurance Program Description (Revision 22, effective July 1, 2016). 7.32 North Anna Power Station Emergency Plan (Proposed version dated May 1, 1980, Revision O dated July 22, 1982, Revision 8, effective September 27, 1984, Revision 12 dated October 2, 1989, Revision 18 dated January 3, 1996, Revision 19 dated December 11, 1996, Revision 22 dated July 17, 1998, and Revision 44 dated February 2, 2017). 7.33 Surry Power Station Emergency Plan (Proposed version dated May 1, 1980,Revision O dated July 29, 1982, Revision 3 dated September 17, 1982, Revision 15 dated June 28, 1984, Revision 30 dated July 30, 1987, Revision 31 dated February 18, 1988, Revision 33 dated February 21, 1991, Revision 34 dated March 10, 1992, Revision 40 dated January 1 , 1996, Revision 41 dated December 11 , 1996, Revision 43 dated August 12, 1998, and Revision 63 dated March 16, 2017 (Revisions 0-32 were not numbered, but these revision numbers correspond to the sequence by date)). 7.34 North Anna Unit 3 Emergency Plan (Combined Operating License Application Part 5 Revision 5) (December 2013). 7.35 Outgoing Letter Serial No. 079, Amendment to Operating Licenses DPR-32 and DRP-37, Surry Power Station Units No. 1 and No. 2, Supplement to Proposed Technical Specification Change (supplemented requests to modify SPS Technical Specifications dated March 31, 1980 (supplemented by letter dated August 4, 1980), August 28, 1980 and November 14, 1980), dated February 23, 1981. 7.36 Outgoing Letter Serial No. 038, Organization for Emergency Planning, dated February 2, 1982. 7.37 Outgoing Letter Serial No. 102, NUREG-0696, Emergency Response Facilities, North Anna and Surry Power Stations, dated April 8, 1982. 7.38 Outgoing Letter Serial No. 676, Supplemental Information, re: NUREG-0696 Response, dated December 6, 1982. 7.39 Outgoing Letter Serial No. 237, Generic Letter 82-33, Emergency Operations Facilities, North Anna and Surry Power Stations, dated April 14, 1983.

Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Attachment 3 -page 19 of 19 7.40 Outgoing Letter Serial No. 259, Generic Letter 82-33, Emergency Operations Facilities, North Anna and Surry Power Stations, dated May 6, 1983. 7.41 Outgoing Letter Serial No. 577, Proposed Technical Specification Change, Surry Power Station, dated November 2, 1984. 7.42 Outgoing Letter Serial No. 578, Proposed Technical Specification Change, Review and Audit Frequencies, North Anna Power Station, dated November 2, 1984. 7.43 Outgoing Letter Serial No. 88-662A, Proposed Emergency Plan Revisions (North Anna), dated February 18, 1988. 7.44 Outgoing Letter Serial No.89-341, Proposed Emergency Plan Revisions (Surry), dated June 30, 1989. 7.45 Outgoing Letter Serial No.89-856, Proposed Emergency Plan Revisions (North Anna and Surry), dated January 17, 1990. 7.46 Outgoing Letter Serial No.93-356, Proposed Technical Specification Change, Review and Audit Frequencies, North Anna and Surry Power Stations, dated July 20, 1993. 7.47 Outgoing Letter Serial No.93-767, Proposed Emergency Plan Revisions, dated February 18, 1994. 7.48 Outgoing Letter Serial No.95-425, Emergency Plan Revision (North Anna and Surry), dated September 6, 1995. 7.49 North Anna NEl-10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," December 2012. 7.50 Surry NEl-10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," December 2012.

Attachment 4 Serial No.17-325 Docket Nos.: 50-338/339 50-280/281 52-017 72-2/16/55/56 Marked-Up NAPS Emergency Plan Page Changes

-tiil~ Dominion Emergency Plan Title: North Anna Power Station Emergency Plan Revision Number: #TBD Effective Date: Revision#

TBD updates this entire document.

Revised material includes, but is not limited to: 1. Establishment of a consolidated emergency operations facility known as the Corporate Emergency Response Center (CERC) in Glen Allen, Virginia. This CERC replaces the former on-site Local Emergency Operations Facility (local EOF, LEOF), the former backup Central EOF, and the headquarters support organization assembly location formerly known as the CERC. A near-site location is identified for Nuclear Regulatory Commission (NRC) and offsite responders to interact face-to-face with emergency response personnel entering and leaving the nuclear power reactor site. 2. Incorporation of the applicable content previously contained in the Corporate Emergency Response Plan. 3. Clarification of emergency response organization (ERO) augmentation and emergency response facility (ERF) activation goals. 4. Elimination of automatic ringdown phones between the EOF and Louisa County, and between the EOF and Spotsylvania County. 5. Replacement of references to " eguivalency credit" for required training sessions with reference to administrative processes for training e x emptions and equivalent qualifications. 6. Designation of the Facility Safety Review Committee (FSRC) as the approval authority for emergency plan revisions and the Manager Nuclear Emergency Preparedness as the approval authority for emergency plan implementing procedure revisions. 7. Addition of reference to availability of current letters of ag r eement (LOAs) and removal of LOAs from Appendix 10.1. 8. Expand the start time for other-than-normal working hours drill or e x ercise to include between 4: 00 am and 6: 00 pm on a weekend. Items 1-8 authorized b License Amendment

1. 1. /## and associated NRC SER Reference lncomin Serial #-## dated'#!#/####. Thi s information is to b e added fo ll owi n g rec e ipt of NR C Safety Eva lu at i on Report. Approvals on File SECTION 1.0 1.0 1.1 2.0 2.1 2.2 2.3 3.0 3.0 4.0 4.0 4.1 4.2 4.3 4.4 5.0 5.0 5.1 5.2 5.3 5.4 NORTH ANNA POWER STATION EMERGENCY PLAN TABLE OF CONTENTS SUBJECT TABLE OF CONTENTS Table of Contents NUREG-0654 Cross Reference Index DEFINITIONS Definitions Acronyms and Abbreviations SCOPE AND APPLICABILITY Site Specifics Emergency Plan North Anna Hydroelectric Unit

SUMMARY

OF EMERGENCY PLAN Summary of Emergency Plan EMERGENCY CONDITIONS Emergency Conditions Spectrum of Postulated Accidents Emergency Classification System State and Local County Classification System Requirements for Written Summaries of Emergency Events ORGANIZATIONAL CONTROL OF EMERGENCIES Organizational Control of Emergencies Normal Station Organization Gfisite-Emergency Response Organization Augmentation of GAsite-Emergency Response Organ iz ation Coordination with Participating Government Agencies NAEP Page i.1 Revision # TBD PAGE NO. i.1 i.4 1.1 1.2 1.5 2.1 2.2 2.2 2.3 3.1 3.2 4.1 4.2 4.2 4.3 4.8 4.8 5.1 5.3 5.3 5.4 5.11 5.13 SECTION 6.0 6.0 6.1 6.2 6.3 6.4 6.5 7.0 7.0 7.1 7.2 7.3 7.4 7.5 7.6 8.0 8.0 8.1 8.2 8.3 8.4 8.5 8.6 8.7 8.8 8.9 9.0 9.0 9.1 9.2 SUBJECT EMERGENCY MEASURES Emergency Measures Activation of the Emergency Plan Assessment Actions Protective Actions Aid to Affected Personnel Offsite Support EMERGENCY FACILITIES AND EQUIPMENT Emergency Facilities and Equipment Emergency Response Facilities Communications System Assessment Facilities Available Onsite Assessment Facilities Available Offsite Damage Control Equipment and Supplies Early Warning System MAINTAINING EMERGENCY PREPAREDNESS Maintaining Emergency Preparedness Responsibility for Maintaining Emergency Preparedness NAEP Page i.2 Revision # TBD PAGE NO. 6.1 6.2 6.2 6.2 6.3 6.6 6.8 7.1 7.3 7.3 7.5 7.7 7.10 7.10 7.10 8.1 8.3 8.3 Maintenance of the Emergency Plan Implementing Procedures , and Related Documents 8.4 8.5 8.7 8.8 8.10 8.12 8.13 8.13 Training of Station Emergency Response Organization Personnel Training of Offsite Support Personnel Emergency Drills Emergency Exercises Testing and Maintenance of Emergency Equipment Informing the Public Independent Review of the Emergency Preparedness Program RECOVERY Recovery Recovery Methodology Population Exposure 9.1 9.2 9.2 9.2 SECTION 10.0 10.1 10.2 10.3 10.4 10.5 10.6 10.7 10.8 10.9 10.10 10.11 SUBJECT APPENDICES Letters of Agreement Deleted NAEP Page i.3 Revision # TBD Maps of Exclusion Area , Low Population and Emergency Planning Zone Boundaries Listing of EPIPs Protective Equipment and Supplies Deleted Supporting Plan Contact Estimation of Evacuation Times Radiation Emergency Plan , MCVHNCU -Dominion Power Federal Radiological Monitoring and Assessment Center (FRMAC) Operations Plan Initiating Conditions/Emergency Action Levels r--NUREG-0654 Ref. Section A. 1a. A. 1b. A. 1c. A. 1d. A. 1e. A. 2a. A. 2b. A. 3 A.4 8. 1 8.2 8.3 8.4 8.5 8.6 8. 7a. 8. 7b. 8. 7c. 8. 7d. 8.8 8.9 C. 1a. C. 1b. C. 1c. C. 2a. C. 2b. C. 3 C.4 D. 1 D.2 D.3 0.4 E. 1 E. 2 E. 3 E. 4.a thru n E.5 E.6 E. 7 NO R T H A N NA EMERGENCY PLAN N U REG-0654 CROSS REFERENCE INDEX NAEP NUREG-0654 Section No. Ref. Section 5.3 -5.4 F. 1a. 5.4 F. 1b. Figure 5.4 F. 1c. 5.0 F. 1d. 5.2 , 5.4 , 5.4.5 F. 1e. N/A F. 1f. N/A F. 2 5.3 , Appx. 10.1 F. 3 5.2 , 5.3 G. 1 5.1 G. 2 NAEP Section No. NAEP Page i.4 Revision # TBD 5.2 , 5.4.5 , 7.2 7.2 7.2 7.2 5.2 7.2 6.4.3 8.7 8.8 8.8 5.0 , 5.2 G. 3a.

• 8.8 , 7.4-alA_, 5.3.1 5.0 G. 3b. 7.1.5 5.2.1.1 G. 4a. 5.3.1 5.2 , Table 5.2 G. 4b. 5.3.1 Figure 5.4 G. 4c. 8.8 5.3.1 G. 5 8.8 5.3.1 5.3.1 H. 1 7.1 5.3.1 H.2 7.1 5.3.2 H.3 7.1 5.3.3 , 5.4 , Appx. 10.1 H.4 5.2 H.5 7.3 5.3.1 , 5.4. 7 H. 5a. 7.3.1 , 7.3.3 5.4.7 H. 5b. 7.3.2 5.4.7 H. 5c. 7.3.4 N/A H. 5d. 7.3.5 ~5.3,5.4 H. 6a. 7.4 5.3.3 H. 6b. 7.3.2 5.3.3 H. 6c. 7.3.2 H. 7 7.3.2 4.2 H , 8 7.3.3 4.2 H.9 7.1.2 N/A H. 10 8.7 , 7.5 N/A H. 11 Appx. 10.5 H. 12 7.1.4 5.4 , 6.0 -6.1 6.1 1 4.2 6.1 2 7.3 6.1 3a. 6.2 N/A 3b. 6.2 6.3.1 , 7.6 4 6.2 6.3.1 5 7.3.3 , 7.3.4 .6 7.3.2 I. 7 7.3.2 I. 8 5.2 , 7.3.2 I. 9 7.3.2 I. 10 6.3.1 I. 11 N/A NUREG-0654 Ref. Sect i on J. 1a. J. 1b. J. 1c. J. 1d. J. 2 J. 3 J.4 J. 5 J. 6a. J. 6b. J. 6c. J. 7 J.8 J.9 J. 10a. J. 10b. J. 10c. J. 1 Od.-1. J. 10m J. 11 J. 12 K. 1 a.-g. K.2 K. 3a. K. 3b. K.4 K. 5a. K. 5b. K. 6a. K. 6b. K. 6c. K. 7 L. 1 L. 2 L. 3 L. 4 M. 1 M. 2 M. 3 M. 4 NORTH ANNA EMERGENCY PLAN NUREG-0654 CROSS REFERENCE INDEX NAEP NUREG-0654 Section No. Ref. Section 6.3.2 N. 1a. 6.3.2 N. 1b. 6.3.2 N.1c. 6.3.2 N.1.d. 6.3.2 N.2 6.3.2 N.2a 6.3.2 N. 2b. 6.3.2 N. 2c. 6.3.3 N. 2d. 6.3.3 N. 2 e.1 6.3.3 N. 2e.2 6.1 -6.3 N. 3a.-f. 6.3.1 , App x. 10.8 N.4 N/A N.5 Appx. 10.8 App x. 10.8 0. 1 6.3.1 0. 1.a N/A 0. 1.b 6.3.1 0.2 N/A 0.3 N/A 0.4a. 0. 4b. 6.4.1 0. 4c. 6.4.1 0. 4d. 5.2 , 6.4 0. 4e. 6.4 0. 4f. N/A 0. 4g. 6.4.2 0. 4h. 6.4.2 0.4 i. 6.4.2 0.4j. 6.4.2 0. 5 6.4.2 6.4.2 P. 1 P.2 6.4 P.3 6.4.2 P.4 N/A P.5 6.4.3 P.6 P. 7 9.1 P.8 9.0 , Figure 9.1 P.9 9.0 P. 10 9.2 NAEP Section No. 8.6 8.6 8.6.1 N/A 8.5 8.5.1 8.5.2 8.5.3 8.5.4 8.5.6 8.5.5 8.5 , 8.6 8.6.5 8.6.5 8.3 8.4 N/A 8.4 NAEP Page i.5 Rev i sion # TBD 6.4.2 , Table 8.1 8.3.3 , Table 8.1 Table 8.1 Table 8.1 T able 8.1 T able 8.1 Table 8.1 Table 8.1 8.4 , Table 8.1 Table 8.1 T able 8.1 8.3.3 8.3.3 8.1 8.1 8.2.1 8.2.3 App x. 10.1 Index 10.4 Pages i.1 -i.5 8.9 8.2.2 Part 1.0 1 .1 Subject Definitions NORTH ANNA POWER STATION EMERGENCY PLAN SECTION 1 DEFINITIONS Acronyms and Abbreviations NAEP Page 1.1 Revision # TBD Page No. 1.2 1.5

1.0 DEFINITIONS

NAEP Page 1.2 Revision # TBD

• Alert -Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the Environmental Protection Agency Protective Action Guideline exposure levels.

• Annually -12 months +/-3 months.

• Biennial -Occurring every two years.

• Buffer Sectors -Two 22 1/2° sectors flanking each side of the 22 1/2° primary sector.

• Commonwealth of Virginia Emergency Operations Plan (COVEOP), Hazard-Specific Annex #1 -Radiological Emergency Response.

• Control Room -Station main control center serving as the initial location for command and control of the emergency response effort.

• Corporate Emergency Response Center (CERC) -Consolidated emergency operations facility for North Anna Power Station and Surry Power Station. Designated facility serving as the foca l point for inter-company efforts implemented to support station emergency response acti ons and for dissem ination of emergency information. The CERC is located at the Innsbrook Technical Center in Glen Allen. Virginia.

• Deep Dose Equivalent (DOE) -Direct external radiation exposure to the body (e.g., cloud shine , contamination , or direct radiation).

ODE is assumed equivalent to Effective (external)

Dose Equivalent (EDE) with respect to uniform exposure.

• Drill -A supervised instruction period aimed at testing , developing and maintaining skills.

• Effective Date -Date of change; implementation date assigned by approval authority; date from which 30-day NRC submittals are required in accordance with 10 CFR 50 , Appendix E.V.

• Emergency

-Any situation that may result in undue risk to the health and safety of the public and/or site personnel , or significant damage to property or equipment.

• Emergency Action Levels (EALs) -Events , such as equipment malfunctions , natural phenomena , radiological dose rates , etc., that may be used as thresholds for initiating such specific emergency measures as designating a particular class of emergency , initiating a notification procedure , or initiating a particular protective action.

• Emergency Classif ications:

Notification of Unusual Event Alert Site Area Emergency General Emergency NAEP Page 1.3 Revision # TBD

• Emergency Plan Implementing Procedures (EPIPs) -Emergency response procedures that implement the Emergency Plan.

• Emergency Planning Zones (EPZ):

• Plume Exposure Pathway EPZ -An area delineated by an approximate ten-mile radius circle around the North Anna Power Station.

• Ingestion Exposure Pathway EPZ -An area delineated by an approximate fifty-mile radius circle around the North Anna Power Station with the potential of internal exposure from the ingestion of radioactive material through the food pathway.

• Emergency Response Facility (ERF) -Emergency facilities include the Control Room, Technica l Support Center, Operational Support Center. Corporate Emergency Response Center, and Joint Information Center.

• Exclusion Area -The area within a 5000 feet radius of the now abandoned North Anna Unit 3 containment.

• Exercise -A test of the response capabilities of the Emergency Organization that permits the evaluation of training and response to a given situation.

Exercises are conducted in accordance with pre-planned scenarios with defined objectives.

• General Emergency

-Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or security events that result in an actual loss o f physical control of the facility. Releases can be reasonably expected to exceed Environmental Protection Agency Protective Action Guideline exposure levels offsite for more than the immediate site area.

• Hostile Action -An act toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment , takes hostages , and/or intimidates the licensee to achieve an end. This i ncludes attack by air , land , or water using guns , explosives , projectiles, vehicles , or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be i ncluded. Hostile Action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant. Non-terrorism-based EALs should be used to address such activities , (e.g., violent acts between individuals in the owner controlled area.)

• Hostile Force -One or more indiv i duals who are engaged in a determined assault , overtly or by stealth and deception , equipped with suitable weapons capable of killing , maiming , or causing destruction.

• Interim -A temporary or provisional emergency response position or facility which is augmented or transferred as resources become available.

NAEP Page 1.4 Revision # T BD

• Joint Information Center (JIG) -Designated facility from which official information concerning an emergency is provided to the media. The JIG is located at the Virginia State Police Administrative Headquarters in Chesterfield, Virginia.

• Local Counties -This term shall be used to denote the Counties of Louisa , Spotsylvania , Caroline , Orange , and Hanover in the approximate ten (10) mile emergency planning zone.

• Loca l Emergencv Operations Facilitv (LEOF) /\ near site facility where the Recovery Manager controls tho overall omorgoncy response.

• Local Media Center (LMC) -This facility provides a near site location for official media releases.

The Local Media Center is in the North Anna Nuclear Information Center.

• Nearsite -Within the Exclusion Area , but beyond Protected Area.

• Notification of Unusual Event -Even t s are in process or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

• Offsite -Beyond the Exclusion Area.

• Onsite -Within the Protected Area , (surrounded by security fence).

• Operational Support Center (OSC) -An assembly area that serves as the staging location for Damage Control Teams, the Fire Brigade , the First Aid Team , and the Search and Rescue Team.

• Primary Sector-The 22 1/2° sector which bounds the existing wind direction.

• Projected Dose -An estimated rad i oactive dose which affected population groups could potentially receive if no protective actions are taken.

• Protected Area (PA) -An area encompassed by physical barriers and to which access is controlled. For the purposes of this plan, the Protected Area refers to the designated security area around the reactor and turbine buildings.

• Protective Action Guides (PAGs) -The projected dose to individuals in the general population or the dose rate which warrants taking protective actions.

• Protective Act i ons -Those emergency measures taken before or after an uncontrolled release of radioactive material has occurred for the purpose of preventing or minimizing radiological exposure.

• Recovery Actions -Those actions taken after the emergency to restore the station as nearly as possible to its pre-emergency condition.

• Rem (Roentgen Equivalent Man) -A unit of radiation dose that relates exposure to the biological effects of the exposure (absorbed exposure or dose). A unit related to the rem is the millirem (mrem). 1 mrem = 1/1000 rem.

• Restricted Area -Any area where access is controlled for the purpose of radiation protection.

• Semi-annual -Occurring once during each of the first and last six months of the calendar yea r.

NAEP Page 1.5 Revision # TBD

• Site -The Power Station proper and the 5000 foot radius exclusion area around the Power Station.

• Site Area Emergency

-Events are in process or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevents effective access to equipment needed for the protection of the publ i c. Any releases are not expected to result in exposure levels which exceed Environmental Protection Agency Protective Action Guideline exposure levels beyond the site boundary.

• Station Emergency Manager (SEM) -Designated onsite individual having the responsibility and authority for implementing the North Anna Emergency Plan.

• Technical Support Center -A facility located adjacent to Unit 1 Control Room which will be the central control center for the onsite emergency response organization after the on shift staff has been augmented.

• Thyroid Committed Dose Equivalent (COE) -Radiation exposure to the thyroid through inhalation or ingestion of radioactive material assuming a 50 year exposure period from uptake.

• Total Effective Dose Equivalent (TEDE) -The sum of external and internal dose.

1.1 ACRONYMS

AND ABBREVIATIONS AC ARD Asst. cc Ce COE CEDE CERC Ge-R+ CFR CH COVEOP cpm CR Cs CSD CTS eves DBE DC ODE DEGON DEPT. DOE EAD EALs EAS ECCS EDE e.g. EMO ENS EOG Alternating Current Automatic Ringdown Line Assistant Cubic Centimeter Cerium Committed Dose Equivalent Committed Effective Dose Equivalent Central Emergency Operations Facility Corporate Emergency Response Center Corporate Emergency Response Plan Corporate Emergency Response Team Code of Federal Regulations Charging System Commonwealth of Virginia Emergency Operations Plan Counts per minute Control Room Cesium Cold Shutdown Current Technical Specifications Chemical Volume Control System Design Basis Earthquake Direct Current Deep Dose Equivalent Decontaminate Department Department of Energy Emergency Administrative Director Emergency Action Levels Emergency Alert Sys t em Emergency Core Cooling System Effective Dose Equivalent For example [From Latin exempli gratia] Emergency Maintenance Director NRG Emergency Notification System Emergency Operations Center NAEP Page 1.6 Revision # TBD EOD EOF EPA EPC EPIPs EPZs EROS ERF ERGs ERO etc. ETD EWS F FEMA FRMAC FRMAP FSRC ft GOV'T. gpm HP HPN HRSS HSD I IAW i.e. IEIN 1/0 ISFSI ITS JOG JIG Kl Kr Emergency Operations Director Emergency Operations Facility Environmental Pro t ection Agency Emergency Procedures Coordinator Emergency Plan Implementing Procedures Emergency Planning Zones Emergency Response Data System Emergency Response Facility Emergency Response Guidelines Emergency Response Organization et cetera Emergency Technical Director Early Warning System Fahrenheit Federal Emergency Management Agency Federal Radiological Monitoring and Assessment Center Federal Radiological Monitoring and Assessment Plan Facility Safety Review Committee Feet Government Gallons per minute Health Physics Health Physics Network (Communications System) High Radiation Sampling System Hot Shutdown Iodine In accordance with That is [From Latin id est] Inspection and Enforcement Information Notice (NRG) Input/Output Independent Spent Fuel Storage Installation Improved Technical Specifications Job Demonstration Guide Joint Information Center Potassium Iodide Krypton NAEP Page 1.7 Revision # TBD KW LAN LCO LMC LOCA LW MCL MCVH MIDAS mph mR/hr MSL Mwe MWt N/A NAEP NANIC NAPS NOT NEP NRG NSSS NUREG OBE ODCM OPX osc PAGs PAR PBX PCS Pk. PLS PMCL PORV Kilowatt Local Area Network License Condition of Operation Local Emergency Operations Facility Local Media Center Loss of Coolant Accident Liquid Waste System Management Counterpart Link Medical College of Virginia Hospital Meteorological Information and Dose Assessment System Miles per hour Millirem per hour Mean Sea Level Megawatt electric Megawatt thermal Not applicable North Anna Emergency Plan North Anna Nuclear Information Center North Anna Power Station Nil Ductility Transition Nuclear Emergency Preparedness Nuclear Regulatory Commission Nuclear Steam Supply System NRC Report Operating Basis Earthquake Offsite Dose Calculation Manual Off-Premises exchange (Communications System) Operational Support Center (Onsite Operations Assembly Area) Protective Action Guides Protective Action Recommendation Private Branch exchange (Communications System) Plant Computer System Package Plus Local Support Protective Measures Counterpart Link Power Operated Relief Valve NAEP Page 1.8 Revision # TBD psi , psia, psig RAA RAC RAD , Rad , rad RCP RCS Rem RERP R/hr RHR RIC RM , RMS RO RPS RSCL Ru RVLIS Rx SCBA SEM SI SN SONET SPDS SRO sssc STA SW Te TR Pounds per square inch , psi absolute , psi guage Remote Assembly Area Radiological Assessment Coordinator NAEP Page 1.9 Revision#

TBD Radiological Assessment Director , radiation or radiological depending on context Reactor Coolant Pump Reactor Coolant System Roentgen Equivalent Man Radiological Emergency Response Plan Roentgen per hour Residual Heat Removal Richmond International Concourse (Airport)

Radiation monitor or Radiation Monitoring System depending on context Reactor Operator Radiation Protection Supervisor Reactor Safety Counterpart Link Ruthenium Reactor Vessel Level Indication System Reactor Self contained breathing apparatus Station Emergency Manager Safety Injection Serial number Synchronous Optical Network Safety Parameter Display System Senior Reactor Operator Sealed Surface Storage Cask Shift Technical Advisor Service Water system Tellurium Technical Requirement (from Technical Requirements Manual)

T.S., Tech Specs TEDE THY TLD TSC µCi UFSAR UHF U.S. V vcu VCUMC VDEM VG VPAP WAN Xe X/Q Technical Specification(s)

Total Effective Dose Equivalent Thyroid Thermoluminescent Dosimeter Technical Support Center Micro (µ) Curie Updated Final Safety Analysis Report Ultrahigh frequency (radio) United States Volts Virginia Commonwealth University Virginia Commonwealth University Medical Center Virginia Department of Emergency Management Vents -Gaseous Virginia Power Administrative Procedure Wide Area Network Xenon Chi/0; Dilution and dispersion factor, seconds per cubic meter NAEP Page 1.10 Revision # TBD Part 2.1 2.2 2.3 Subject Site Specifics Emergency Plan NORTH ANNA POWER STATION EMERGENCY PLAN SECTION 2 SCOPE AND APPLICABILITY North Anna Hydroelectric Unit NAEP Page 2.1 Revision # TBD Page No. 2.2 2.2 2.3

2.0 SCOPE

AND APPLICABILITY 2.1 SITE SPECIFICS NAEP Page 2.2 Revision # TBD The North Anna Power Station consists of two units , each of which includes a three loop pressurized light water reactor , nuclear steam supply system (NSSS) and turbine generator furnished by Westinghouse Electric Corporation. The balance of the station was designed and constructed by the Company with the assistance of its ArchitecVEngineer , the Stone and Webster Engineering Corporation. Each reactor unit design output is limited to maximum power level stated in the current Operating License. The units are located on a peninsula on the southern shore of Lake Anna in Louisa County approximately 40 miles North Northwest of Richmond , Virginia; 38 miles East of Charlottesville , Virginia; and 24 miles Southwest of Fredericksburg , Virginia. Cooling water , contained by an earthen dam structure, is obtained from the 17 mile long North Anna Reservoir. An Independent Spent Fuel Storage Installation (ISFSI) is located on the plant site. 2.2 EMERGENCY PLAN The North Anna Power Station Emergency Plan (the Plan) describes the organization , facilities , emergency response measures , and functional interfaces with offsite agencies which can be used to respond to a broad range of defined emergencies. The organization has well defined responsibilities and specific authorities which provide for effective control and coordination of the emergency response , both onsite and offsite. The organization is augmented , as required, to address situations with the most serious potential consequences. The Plan is formulated for compatibility with existing local , State, and Federal response organizations which may render emergency assistance. A coordinated response effort between the company and other agencies supports the mutual goals of protecting public health and safety and of minimizing damage to both public and private properties.

The basic purposes of the Plan are as follows: 1) To define potent i al types of emergencies

2) To establish an organization for managing an emergency;

3) To provide measures for coping with an emergency; 4) To provide facilities from which to perform selected measures; 5) To provide for a recovery program following an emergency; and , 6) To provide methods for maintaining the Plan active and current. Emergency Plan Implementing Procedures (EPIPs) provide instructions for accomplishing the provisions established in the Plan. The procedures guide the classification of the emergency , provide for offsite notifications , and activation of the full response organization.

They also provide techniques for estimating the consequences of offsite releases and making recommended Protective Action Recommendations.

NAEP Page 2.3 Revision # TBD The Plan satisfies the emergency plan requirements for the North Anna ISFSI under provisions of Title 10 of the Code of Federal Regulations , Part 72 , Subpart B , Section 32 , Subsection (c). 2.3 NORTH ANNA HYDROELECTRIC UNIT I n addition to the North Anna Emergency Plan , an Emergency Action Plan has been prepared for the North Anna Hydroelectric Plant. The North Anna Hydroelectric Plant, a small hydroelectric generating unit of 855KW capacity, is operated by Dominion and located on the North Anna River at the Lake Anna Dam (approximately

5.5 miles

Southeast of the North Anna Power Station).

The North Anna Hydroelectric Plant Emergency Action Plan was prepared to conform with the provisions of Title 18 of the Code of Federal Regulations , Part 12 , Subpart C , and was developed in consultation and cooperation with Federal , State , and local agencies responsible for public health and safety. The action Plan includes provisions for notifying State and downstream counties that may be affected by a class ifi ed project (dam) emergency. It also sets forth procedures to be followed by station personnel to control the emergency and to notify the appropriate authorities. In order to meet the requirements of 18 CFR Part 12 , Subpart C , provisions for operation of spillway equipment concurrent with an incident at North Anna Power Station is addressed as part of this plan. Should a (nuclear) station emergency occur , the Auxiliary Operator(s) shall remain at the dam to ensure proper operation of spillway gates , unless contacted by Security or Operations to evacuate because of safety reasons.

Part 3.0 Subject NORTH ANNA POWER STATION EMERGENCY PLAN SECTION 3

SUMMARY

OF EMERGENCY PLAN Summary of Emergency Plan NAEP Page 3.1 Revision # TBD Page No. 3.2 3.0

SUMMARY

OF EMERGENCY PLAN NAEP Page 3.2 Revision # TBD Types of emergencies are divided into four classifications which cover a broad spectrum of potential occurrences.

The classifications range from a "Notification of Unusual Event" , in which offsite officials are notified of an unusual condition , through "General Emergency ," in which onsite and offsite evacuation may be required and a major state of emergency exists. This classification scheme is compatible with existing State and local plans. An emergency response organization is established with specific duties and responsibilities defined , and points of contact between onsite and offsite supporting agencies are designated.

Augmentation of the emergency organization will occur at "Alert" and higher levels , and includes activation of beth station and corporate omorgoncy rosponso teams. Provisions for prompt notification of State , Local and Federal agencies are established and include pre-planned information which may be required for offsite agency response.

Methods and procedures provide corrective and protective actions including evaluation of the operability of the unaffected unit. The use of protective equipment , protective action guides and exposure limits are also pre-specified.

The facilities available for assessment and management of the emergency consist of onsite and offsite response facilities, communication systems, and portable or fixed equipment and systems for detection and measurement of those parameters causing or resulting from the emergency. Medical facilities are also available. Provisions are provided for public information activities, including development and issuance of p r ess releases, media briefings, and responding to public inquiries. A recovery program describes the organization and procedural approach required to re-start the affected unit. The recovery program provides guidance for relaxing protective measures that have been instituted and requires the periodic estimation of total population exposure. The Emergency Plan and Emergency Plan Implementing Procedures are reviewed annually. The Facility Safety Review Committee (FSRC) shall evaluate the review and may provide additional recommendations as necessary. Periodic drills and exercises involving communications , fire-fighting , radiological monitoring and Health Physics activities are routinely conducted. A joint exercise involving participation by State and local response agencies will be held on even-numbered years at North Anna (on odd-numbered years , the State participates at Surry) to ensure all major elements of the Plan are tested within an eight year period. Federal response agencies may also participate in these joint exercises. Critiques of each implementation of the Plan allow for critical reviews of technique , methods , and shortcomings. Improvements will be factored into the Plan and/or Implementing Procedures through revisions.

Part 4.0 4.1 4.2 4.3 4.4 Subject NORTH ANNA POWE R STATI ON E MERGE NCY P L A N SECTION 4 EMERGENCY CONDITIONS Emergency Conditions Spectrum of Postulated Accidents Emergency Classification System State and Local County Emergency Classification System Requ i rements Fo r Written Summaries of Emergency Events NAEP Page 4.1 Revision # TBD Page No. 4.2 4.2 4.3 4.8 4.8

4.0 EMERGENCY

CONDITIONS NAEP Page 4.2 Revision # TBD The following guidelines describe the criteria used by station personnel in classifying or determining the type of an emergency. The types of potential accidents or emergencies can be numerous and vary in magnitude. Accordingly , the classification system is wide-ranged , although flexible and straight forward. The four classifications are defined in accordance with Appendix 1 of NU REG 0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." The classification system is not intended to include minor deviations during normal operation.

Furthermore, it may be discovered that an event or condition , which met the classification criteria , had existed , but that the basis for the emergency class no longer exists at the time of discovery. For example , the event may have rapidly concluded or been discovered during a post-event review. As discussed in NUREG-1022 , "Event Reporting Guidelines

10 CFR 50.72 and 50.73" (Revision 1), actual declaration of an emergency class is not necessary in these circumstances , although notification to the Nuclear Regulatory Commission and Virginia Department of Emergency Management (VDEM) is warranted.

4.1 SPECTRUM

OF POSTULATED ACCIDENTS The spectrum of emergencies peculiar to nuclear power stations range from accidents with minor implications on health and safety to the postulation of major occurrences resulting in the release of significant quantities of radioactive material.

Examples of minor accidents include unplanned or uncontrolled releases of small amounts of radioactive material in excess of allowable limits as well as equipment malfunctions. Major occurrences , though not expected to take place , have been postulated for planning and design purposes because their consequences could include the potential for release of significant amounts of radioactive material.

The range of conditions in Appendix 1 to NUREG-0654 and Section 15 of the North Anna Updated Final Safety Analysis Report (UFSAR) have been included in the classification system of this Plan. Of the Condition IV -Limiting Faults analyzed in the UFSAR , three are considered to have the potential for releasing significant amounts of radioactivity.

These are the loss of coolant accident , the steam generator tube rupture accident and the fuel handling accident.

The nature of these three accidents is such that a safety analysis can produce results which vary considerably in the radiological consequences.

The analysis results depend on assumptions used concerning such items as the status of primary coolant radioactivity content , meteorological conditions , or performance of station safety systems. The UFSAR makes very conservative estimates of the consequences. The Emergency Plan Implementing Procedures are written in anticipation of having to contend with these worst case consequences.

4.2 EMERGENCY

CLASSIFICATION SYSTEM NAEP Page 4.3 Revision # TBD Emergency conditions which may develop will be categorized as one of the following emergency classifications (defined in Section 1 of this plan): 1. Notification of Unusual Event. 2. Alert. 3. Site Area Emergency.

4. General Emergency. The Notification of Unusual Event classification requires notification of appropriate offsite support groups and station management personnel that an abnormal condition exists at the station. The purpose of this notification is to increase the awareness of key offsite support organizations and station management of a condition which can currently be managed by the onsite resources , but which could escalate to a more serious condition. The on-shift operations personnel are assigned response tasks in accordance with the pre-augmentation organization responsibilities defined in Section 5 of this plan. The Alert classification is indicative of a more serious condition which has the potential for radioactive release. As a result, the emergency response organization is notified to augment onsite resources and activate corporato emergency response facilities. The Site Area Emergency classification reflects conditions where some significant radiation releases are likely or are occurring , but where a core melt situation is not currently indicated. In this situation , there would be full mobilization in the nearsite environs of monitoring teams and associated communications.

A Site Area Emergency can be declared for reasons other than radiological releases. The General Emergency classification is indicative of actual or imminent substantial core degradation or melting with the potential for loss of containment , or non-radiological events which could endanger public health and/or safety. Within fifteen minutes of declaring a General Emergency , predetermined protective action recommendations will be made to the State based on plant and meteorological conditions. Tables 4.1 -4.4 list the initiating conditions for each emergency classification. The Emergency Action Level Matrix groups these conditions by event category for easy reference and identification. For each condition , specific indications available from instruments and unit operating response are defined in the matrix to confirm that the proper thresholds have been met for declaring a given classification.

Once indications are available to plant operators that an emergency action level has been exceeded, the event is promptly assessed and classified , and the corresponding emergency classification level is declared.

This declaration occurs as soon as possible and within 15 minutes of when these indications become available.

TABLE 4.1 INITIATING CONDITIONS:

NOTIFICATION OF UNUSUAL EVENT NAEP Page 4.4 Revision # TBD NOTE: The alpha-numeric designator , (AAN], preceding each initiating condition below , indicates the Emergency Action Level Identifier category , emergency classification and subcategory number; respectively.

Recognition Category C -Cold Shutdown/Refueling System Malfunction (Cold Conditions (RCS.$. 200°F) only)) CU 1 a AC power capability to emergency busses reduced to a s i ngle power source for greater than 15 CU1b CU2 CU3 CU4 CU5 CU6 minutes such that any additional single failure would result in loss of all AC power to emergency busses Unplanned loss of required DC power for greater than 15 minutes Unplanned loss of RCS inventory with irradiated fuel in the Reactor Vessel Unplanned loss of decay heat removal capability with irradiated fuel in the Reactor Vessel Unplanned loss of all onsite or offsite communications capabilities RCS leakage Inadvertent criticality Recognition Category E -Independent Spent Fuel Storage Installation (ISFSI} EU1 Damage to a loaded cask confinement boundary Recognition Category F -Fission Product Barriers (Hot Conditions (RCS> 200°F) only)} FU 1 Any loss or any potential loss of Containment Recognition Category H -Hazards HU1 Natural or destructive phenomena affecting the Protected Area or Main Dam HU2 Fire or explosion within the Protected Area boundary HU3 Release of toxic , corrosive , asphyxiant or flammable gases deemed detrimental to normal operation of the plant HU4 Confirmed security condition or threat which indicates a potential degradation in the level of safety of the plant HUS None HU6 Other cond i t i ons e xi sting which in the judgment of the SEM warrant declaration of a NOUE Recognition Category R -Abnormal Radiological Release/ Radiological Effluent RU1 a Any unplanned release of liquid radioactivity to the environment that exceeds two times the radiological effluent Technical Specifications for 60 minutes or longer RU1 b Any unplanned release of gaseous radioactivity to the environment that exceeds two times the allocated radiological effluent ODCM limits for 60 minutes or longer RU2 Unexpected in crease in plant radiation Recognition Category S -System Malfunction (Hot Conditions (RCS >200°F} only)} SU1 Loss of all offsite power to emergency busses for greater than 15 minutes SU2 None SU3 Inability to reach required shutdown within Technical Specification limits SU4a Unplanned loss of most or all safety-related structures , systems and components annunciation or indication in the Control Room for greater than 15 minutes SU4b Unplanned loss of all onsite or offsite communications capabilities SUS Fuel clad degradation SU6 RCS leakage for 15 minutes or longer SU? Inadvertent criticality TABLE 4.2 INITIATING CONDITIONS:

ALERT Recognition Category C -Cold Shutdown/Refueling System Malfunction (Cold Conditions (RCS 5 200°F) only)) CA 1 Loss of all offsite power and loss of all onsite AC power to emergency busses CA2 Loss of RCS inventory NAEP Page 4.5 Revision # TBD CA3 Inability to maintain plant in cold shutdown with irradiated fuel in the Reactor Vessel CA4 None CA5 None CA6 None Recognition Category F -Fission Product Barriers (Hot Conditions (RCS> 200°F) only)) FA 1 Any loss or any potential loss of either Fuel Clad or RCS Recognition Category H -Hazards HA 1 Natural or destructive phenomena affecting a plant safe shutdown area HA2 Fire or explosion affecting the operability of plant safety-related structures , systems or components required to establish or maintain safe shutdown HA3 Access to a safe shutdown area is prohibited due to release of toxic , corrosive , asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor HA4 Hostile action within the Owner Controlled Area or airborne attack threat HAS Control Room evacuation has been initiated HA6 Other conditions existing which in the judgment of the SEM warrant declaration of an Alert Recognition Category R -Abnormal Radiological Release I Radiological Effluent RA 1 Any unplanned release of gaseous or liquid radioactivity to the environment that exceeds 200 times the radiological effluent Technical Specifications for 15 minutes or longer RA2a Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the Reactor Vessel RA2b Release of radioactive material or increases in radiation levels within the facility that impedes operation of systems required to maintain safe operations or to estab l ish or maintain cold shutdown Recognition Category S -System Malfunction (Hot Conditions (RCS >200 °F) only)) SA 1 AC power capability to emergency busses reduced to a single power source for greater than 15 minutes such that any additional single failure would result in loss of all AC power to emergency busses SA2 Automatic trip fails to shutdown the reactor and the manual actions taken from the reactor control console are successful in shutting down the reactor SA3 None SA4 Unplanned loss of most or all safety-related structures , systems and components annunciation or indication in Control Room with EITHER (1) a significant transient in progress , OR (2) compensatory non-alarming indicators are unavailable SAS None SA6 None SA? None TABLE 4.3 INITIATING CONDITIONS:

SITE AREA EMERGENCY Recognition Category C -Cold Shutdown/Refuel System Malfunction (Cold Conditions (RCS.$. 200°F} only}) CS1 None CS2 Loss of Reactor Vessel inventory affecting core decay heat removal capability CS3 None CS4 None CSS None CS6 None Recognition Category F -Fission Product Barriers (Hot Conditions (RCS > 200°F) only)) FS1 Loss or potential loss of any two barriers Recognition Category H -Hazards HS1 None HS2 None HS3 None HS4 Hostile action within the Protected Area NAEP Page 4.6 Revision # TBD HSS Control Room evacuation has been initiated and plant control cannot be established HS6 Other conditions existing which in the judgment of the SEM warrant declaration of Site Area Emergency Recognition Category R -Abnormal Radiological Release / Radiological Effluent RS1 Offsite dose resulting from an actual or imminent release of gaseous radioactivity exceeds 100 mRem TEDE or 500 mRem thyroid COE for the actual or projected duration of the release RS2 None Recognition Category S -System Malfunction (Hot Conditions (RCS >200°F) SS1a Loss of all offsite power and loss of all onsite AC power to emergency busses SS1b Loss of all vital DC power SS2 Automatic trip fails to shutdown the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor SS3 None SS4 Inability to monitor a significant transient in progress SS5 None SS6 None SS7 None TABLE 4.4 INITIATING CONDITIONS:

GENERAL EMERGENCY Recognition Category C -Cold Shutdown/Refuel System Malfunction (Cold Conditions (RCS.$. 200°F) only)) CG1 None NAEP Page 4.7 Revision # TBD CG2 Loss of Reactor Vessel inventory affecting fuel clad integrity with Containment challenged and irradiated fuel in the Reactor Vessel CG3 None CG4 None CG5 None CG6 None Recognition Category F -Fission Product Barriers (Hot Conditions (RCS> 200°F) only)) FG1 Loss of any two barriers AND Loss or potential loss of third barrier Recognition Category H -Hazards HG1 None HG2 None HG3 None HG4 Hostile action resulting in loss of physical control of the facility HG5 None HG6 Other conditions existing which in the judgment of the SEM warrant declaration of General Emergency Recognition Category R -Abnormal Radiological Release / Radiological Effluent RG1 Offsite dose resulting from an actual or imminent release of gaseous radioactivity exceeds 1000 mRem TEDE or 5000 mRem thyroid COE for the actual or projected duration of the release using actual meteorology RG2 None Recognition Category S -System Malfunction (Hot Conditions (RCS >200°F) SG 1 Prolonged loss of all offsite power and prolonged loss of all onsite AC power to emergency busses SG2 Automatic trip and all manual actions fail to shutdown the reactor and indication of an extreme SG3 SG4 SG5 SG6 SG7 challenge to the ability to cool the core exists None None None None None NOTE: The appropriate Protective Action Recommendations for the preceding conditions MUST BE provided to the State within 15 minutes following the declaration of a General Emergency.

4.3 STATE

AND LOCAL COUNTY EMERGENCY CLASSIFICATION SYSTEM NAEP Page 4.8 Revision # TBD The Commonwealth of Virginia Emergency Operations Plan (COVEOP) emergency classification system defines two levels based on pro j ected radiological doses resulting from the release of radioactive materials from a fixed nuclear facility. The company will provide projected radiological doses based on plant parameters and meteorological conditions. Provisions are in the COVEOP for dose assessments within 50 miles of the station for the ingestion of radioactive material via the food pathway. Thresholds used for protective action determination are based on projected doses recommended in Table 2.1 of EPA-400-R-92-001 , "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" , as implemented by the Commonwealth of Virginia. 4.4 REQUIREMENTS FOR WRITIEN SUMMARIES OF EMERGENCY EVENTS NUREG-0654 , Appendix 1 establishes the guidance for providing written summaries of emergency events to offsite authorities. A written summary is provided to VDEM following activation of the North Anna Emergency Plan. The schedule for submitting the written summary for a Notification of Unusual Event is within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following declaration. For any other classification , the schedule for submitting the written summary is within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following termination. This schedule was established with the concurrence of VDEM and subsequent notification to the NRC (reference Letter , Serial Number 84-302 , dated 5-31-84).

Part 5.0 5.1 5.2 5.2.1 5.2.1.1 5.2.1.2 5.2.1.3 5.2.1.4 5.2.1.5 5.2.1.6 5.2.1.7 5.2.1.8 5.2.1.9 5.2.1.10 5.2.1.11 5.2.1.12 5.2.1.13 5.2.1.14 5.2.1.15 5.2.1.16 5.2.1.17 5.2.1.18 5.2.1.19 5.2.1.20 5.2.1.21 5.2.1.22 5.2.1.23 NORTH ANNA POWER STATION EMERGENCY PLAN SECTION 5 ORGANIZATIONAL CONTROL OF EMERGENCIES Subject Organizational Control of Emergencies No r mal Station Organization GR&ite-Emerge n cy Response Organ i zation Station Eme r gency Posit i o n and Team Descriptions Sta ti on Emergency Manager Emergency Communicato r Emergency Procedures Coordinator Emergency Ope r ations Director Emergency Ma i ntenance D ir ector Eme r gency Te c hnical Dire c tor Sh i ft T echnical Advisor Emergency Adm i n i strative Director Radiological Assessment Director Radiat i on Protection Superv i sor Operat i onal Support Center Director (OSC Directo r) OSC Support Team Technical Support Team Chem i stry Team Admin i strative Support Team Securi t y T earn Dose Assessmen t Team Offsite Monitoring Team Evacuation Monitoring T eam In-Plant Monitoring Team Samp l e Analysis Team Personnel Monitoring And Decontamination Team Onsite (Out of Plant) Monitoring Team NAEP Page 5.1 Revision # TBD Page No. 5.3 5.3 5.4 5.5 5.5 5.5 5.6 5.6 5.6 5.6 5.6 5.7 5.7 5.7 5.8 5.8 5.8 5.8 5.8 5.8 5.9 5.9 5.9 5.9 5.9 5.10 5.10 5.2.1.24 5.2.1.25 5.2.1.26 5.2.1.27 5.2.2 5.2.2.1 5.2.2.2 5.2.2.3 5.2.2.4 5.2.2.5 5.2.2.6 5.2.2.7 5.2.2.8 5.2.2.9 5.2.2.10 5.2.2.11 5.2.2.12 5.2.2.13 5.2.2.14 5.3 5.3.1 5.3.1.1 5.3.1.2 5.3.1.3 5.3.1.4 5.3.1.5 5.3.2 5.3.3 5.4 5.4.1 5.4.2 5.4.3 5.4.4 5.4.5 5.4.6 Fire Brigade First Aid Team Damage Control Team Search and Rescue Team Corporate Emergency Positions and Team Descriptions Co r porate Response Manage r Technical Support Manager Resource Manager Nuclear News Manager Chief Technical Spokesperson E x ecutive Liaison Emergency Plan Advisor Operations Support Coordinator Operations Support Team Radiological Assessment Coordinator Accident Assessment Team Resource Team News Team Joint Information Center Support Team NAEP Page 5.2 Revision # TBD 5.10 5.10 5.10 5.10 Augmentation of GAs+te-Emergency Response Organization 5.11 ~Notificat i on and Response 5.11 Environmental Monitoring 5.12 Logistics Support for Emergency Personnel 5.12 Technical Support for Planning and Re-entry/Recovery Operations 5.12 Interface with Governmental Authorities 5.12 Release of Information to News Media 5.12 Vendor and Supplemental Personnel 5.12 Local Services Support 5.13 Coordination with Participating Government Agencies 5.13 Commonwealth of Virginia Department of Emergency Management (VDEM) 5.15 Commonwealth of Virginia Department of Health (VDH) 5.15 Additional State Agency Support 5.15 Louisa County 5.16 Spotsylvania , Caroline , Hanover , and Orange Counties 5.16 Counties and C i ties Within the Fifty Mile Ingestion Emergency Planning 5.17 Zone

5.4.7 Table

5.1 Table 5.2 Table 5.3 Figure 5.1 Figure 5.2 Figure 5.3 Figure 5.4 Federal Radiological Monitoring and Assessment Center (FRMAC) Operations Plan Minimum Shift Manning Requirements Emergency and Recovery Corporate Response Required for Nuclear Station Emergencies (Alert Status And Above) Cities and Counties Within the North Anna 50 Mile Emergency Planning Zone Station Emergency Organization Prior to Augmentation Station Emergency Organization Following Augmentation Station to Support Group Interface Prior to Augmentation of the Onsite Emergency Organization Station to Support Group Interface After ~CERC Activation Figure 5.5.a Technical Support Center Organization Figure 5.5.b Operational Support Center Organization Figure 5.5.c Radiation Protection Organization Figure 5.5.d Corporate Emergency Response Center Organization NAEP Page 5.3 Revision # TBD 5.17 5.18 5.21 5.22 5.23 5.24 5.25 5.26

5.0 ORGANIZATIONAL

CONTROL OF EMERGENCIES NAEP Page 5.4 Revision # TBD An integral part of this Emergency plan is to assure that classificat i ons of Notification of Unusual Event , Alert, Site Area Emergency , and General Emergency are consistently made in a timely manner. All employees are instructed to contact the Shift Manager to report any emergency.

This notification and the information available to the Shift Manager in the Control Room enable a timely classification of the emergency and subsequent actions. The Shift Manager or Unit Supervisor initially acts in the capacity of the Station Emergency Manager (SEM) and takes actions as outlined in the EPIPs. If required by the emergency classification , or if deemed appropriate by the Station Emergency Manager , emergency response personnel will be notified and instructed to report to their emergency response locations. The Shift Manager is relieved as Station Emergency Manager when the Site Vice President o r his designated alternate reports to the station (normally to the Control Room) and is updated as to the status of the unit , the emergency actions taken , and the current status of the emergency. Following this relief , the Station Emergency Manager may relocate to the onsite Technical Support Center (TSC). The Local Emergency Operations FacilityCorporate Emergency Response Center (~CERC) is activated concurrent with the TSC. The ~CERC is staffed by station and corporate pe r sonnel , including the Recovery ManagorCorporate Response Manager and Technical Support Manager , who direc ts the activities of this facility. Once tho LEOF is staffed, tho Recovery Manager becomes tho liaison botwoon tho in plant omorgoncy organization hoadod by tho Station Emergency Manager and tho Corporate Emergency Response Team (CERT). The Rocm.iory Technical Support Manager is responsible for ensuring the heGF-CERC communicates emergency status to the State and local governments , directs the efforts of the offsite monitoring teams, makes radiological assessments , recommending offsite protective measures to the State , and arranging through tho CERT for dispatch of any special assistance or services requested by the station. Specific information rolating to tho staffing and roporting structuro of tho LEOF organization is provided in tho Corporate Emergency Response Plan (CERP). Tho Recovery Manager reports to tho Corporate Response Manager who directs tho activities of tho CERT at tho Corporate Emergency Response Center (CERC). Tho CERC will be activated at tho ALERT or higher emergency classification._

The Corporate Response Manager is a senior lovol company roprosontati*,o who is responsible to tho President of tho Company for tho total mwcution of tho oompany's emergency response effort. lo=lo has the ultimate authority to commit company resources and set policy as part of managing the long term recovery effort. Moro detailed information on tho oomposition of tho CERT and their rosponsibilitios is provided in tho CERP. 5.1 NORMAL STATION ORGANIZATION The Site Vice President is ultimately responsible for the operation of the Station. The minimum staff required to conduct Station operation is maintained at the station at all times. For purposes of the Emergency Plan , the on-shift manning is assumed to be on back-shift because the normal station complement of personnel is only present during regular duty hours on scheduled work days.

NAEP Page 5.5 Revision # TBD The basic shift (back-shift) complement of personnel is comprised of Operations , Health Physics , Chemistry , and Security personnel with coverage by Maintenance on designated shifts. In addition , technical/engineering support is available on all shifts from the Shift Technical Advisor (STA). Station administrative procedures provide the details of the normal station organization including reporting relationships. 5.2 ONSITE EMERGENCY RESPONSE ORGANIZATION The first line of control in an emergency at North Anna Power Station lies with the on-shift personnel.

The shift complement is staffed with personnel qualified to take the initial actions necessary to respond to an emergency. The organizat i onal relationship of the on-shift emergency organization prior to augmentation is shown in Figure 5.1. Coverage by the Chemistry Team and the Damage Control Team would be provided on an as needed basis. However , augmentation of the onsite emergency organization will specifically provide such coverage. Also , personnel assigned to the Search and Rescue Team , the First Aid Team , and the Fire Brigade may be assigned other functions until their services are required. The capability of the on-shift personnel to effectively manage an emergency is assured by the timely call out of supplementary emergency response personnel.

The capabilities of the assigned on-shift personnel are adequate to assess the condition of the affected unit(s) and take in i tial mitigative actions in accordance with emergency operat i ng procedures including corrective actions necessary to implement procedures consistent with operations personnel training. Additionally , on-shift personnel make notifications to off-site authorities and initiate a call out of supplementary emergency response personnel as required.

The EPIPs are used to procedurally control these actions. A detailed analysis of on-shift personnel assigned emergency plan implementation functions was performed under provisions of 1 O CFR 50 Appendi x E Part IV.A.9. This analysis determined the staff complement listed in the on-shift column of Table 5.1 can adequately perform required emergency response actions in a timely manner until augmenting ERO staff is required to arrive. This analysis considered a spectrum of events , including UFSAR Condition IV events requiring augmented ERO response , a probable aircraft threat , a design basis threat , a fire requiring Control Room evacuation and remote shutdown , a station black out , etc. This staffing analysis is incorporated by reference as a part of this emergency plan. Should the Station Emergency Manager deem that additional emergency response personnel are needed or the emergency classification is upgraded to Alert or higher , he shall initiate the augmentation of the on shift Emergency Organization by instructing Station Security to commence callout of supplementary emergency response personnel.

Table 5.1 represents the minimum number of personnel that are required to augment emergency operations and the estimated response times of these personnel.

The responsibilities of the emergency response personnel assigned on shift and those who make up the augmentation crews meet the staffing functions identified in Table B-1 of NUREG-0654. The numbers of emergency response personnel designated for both the on-shift and augmentation contingents meet or exceed the guidance.

Sufficient train i ng has been provided for the on-shift personnel to ensure that NAEP Page 5.6 Revision # TBD the response actions needed to bring the affected unit(s) to a stable condition in preparation for the longer term recovery will be taken. If an emergency occurs on one of the two units , the Shift Manager or Unit Supervisor assumes the operational responsibility for the unaffected unit. This allows the other to assume the position of Station Emergency Manager until relieved. Figure 5.2 shows the station emergency organization after full augmentation.

5.2.1 Station

Emergency Position and Team Descriptions The Station Emergency Organization , when fully implemented, will consist of at least the positions discussed below. Reporting relationships are as depicted in Figure 5.2. Additional personnel may be designated by Station Management as emergency responders providing special expertise deemed beneficial, but not mandatory , to the planned response. The individuals assigned as interim , primary and alternate responders for the emergency positions will be designated by Station Management based on the technical requirements of the position. Guidance for selection of emergency responders is provided in administrative procedures.

Designated individuals will receive training in accordance with Section 8 of the North Anna Emergency Plan. 5.2.1.1 Station Emergency Manager The Station Emergency Manager (SEM) has the responsibility of managing and directing emergency operations during the course of the emergency.

The SEM initially operates from the Control Room and then transitions to the Technical Support Center. The SEM ultimately reports to the Rooovery Corporate Response Manager , once augmented. SEM responsibilities shall include, but not be limited to: 1) Classifying the emergency, 2) Authorizing notification to the NRG, State and local agencies of the emergency status , 3) Recommending protective measures, 4) Authorizing emergency exposure limits , 5) Activating emergency personnel and facilities , 6) Reducing power or shutting down both reactors , 7) Committing company funds as necessary , 8) Acquiring emergency equipment or supplies , 9) Ordering site evacuation, 10) Restricting access to the site , 11) Notifying company management , 12) Implementing work schedules , and 13) Directing onsite emergency activities.

Items 1 through 4 above MAY NOT BE DELEGATED.

The LEOf ReoovoryCERC Technical Support Manager will be responsible for assuming the non-delegatable responsibilities of notifying State and local governments of the emergency status , and for recommending offsite protective measures to the State.

5.2.1.2 Emergency Communicator NAEP Page 5.7 Revis i on # TBD The Emergency Communicators r eport to the SEM in the Control Room prior to activation of the TSC , and to the TSC after its activation.

The duties of the Emergency communicators are to initially notify and periodically update the Emergency Operations Centers of the counties within the 10-mile Emergency Planning Zone , the Virginia Emergency Operations Center (VEOC), and the NRC. The -1:::eGF-CERC staff becomes responsible for notification of State and local governments.

5.2.1.3 Emergency Procedures Coordinator The Emergency Procedures Coordinator (EPC) will report to the SEM in the Control Room and then relocates to the TSC as part of the augmentation of the on-shift emergency organization.

The responsibilities of the EPC include: 1) Ass i sting the SEM in assur i ng all appropriate procedures and responses are initiated , 2) Monitoring emergency action level entry conditions , 3) Assist i ng the SEM in maintaining a working document of the controlling EPIP procedures and other appropriate procedures , 4) Assisting the SEM in obtain i ng all procedures generated as a result of the emergency , 5) Reviewing procedures for accuracy and completeness , and 6) Assisting in the preparat i on of these documents for review by the Facility Safety Review Committee. 5.2.1.4 Emergency Operations Director The Emergency Operations Director (EOD) reports to the SEM in the Technical Support Center as ' part of the augmentation of the on-shift emergency organization.

His duties include directing the activities of Operations personnel , advising the SEM on emergency operations , and directing the development of procedures necessary for conducting emergency operat i ons. 5.2.1.5 Emergency Maintenance Director The Emergency Maintenance Director (EMO) reports to the SEM in the TSC as part of the augmentation of the on-shift emergency organization. The EMO is responsible for advising the SEM on emergency maintenance activities including prioritization , status and providing i nterface with the Operational Support Center (OSC) Director (when necessary).

5.2.1.6 Emergency Technical Director The Emergency Technical Director (ETD) reports to the SEM in the TSC as part of the augmentation of the on-shift emergency organization.

He directs the activities of the Technical Support Team. The Emergency Technical Director will analyze mechanical , electrical , instrumentation and control , hydraulic , thermodynamic , and reactor physics problems , and develop solutions to the problems. He shall provide technical support to the SEM and assist in developing procedures necessary for conducting emergency operations and maintenance.

5.2.1.7 Shift Technical Advisor NAEP Page 5.8 Revis i on # TBD The Shift Technical Advisor (Control Room) will remain in the Control Room to advise the Shift Manage r or Unit Supervisor on operations activities. He also provides engineering support until the Technical Support Team is staffed. Shift Technical Advisor (STA) coverage is provided on a 24-hour per day , 7-days per week on-shift basis to enable timely assistance in the Control Room. 5.2.1.8 Emergency Administrative Director The Emergency Adm i nistrative Director (EAD) reports to the SEM in the TSC as part of the augmentation of the on-shift emergency organization. He directs activities of the Administrative Support Team and advises the Station Emergency Manager on emergency First Aid , Fire Protection , Security , Administrative and Logistical Support activ i ties. He coordinates the acquisition of equipment , supplies , personnel , and other assistance needed to cope with the emergency. He also ensures that the TSC log keeper maintains a chronological record of key events. 5.2.1.9 Radiological Assessment Director The Radiological Assessment D i rector (RAD) reports to the Station Emergency Manager in the Technical Support Center after relieving the interim director who was the Senior Radiological Protection representative on-site at the init i ation of the emergency.

He directs the activities of the Radiation Protection Supervisor in maintaining the Radiation Protection Program on-site during an emergency.

He also directs the activ i ties of the Dose Assessment Team and Offsite Monitoring Teams in determining offsite consequences of radiological releases until control is assumed by the Radiological Assessment Coord i nator (RAC) at the h-WF-CERC. Other duties of the Radiological Assessment Director are to provide the status of offsite releases to the Station Emergency Manager , to direct the activities of the Chemistry Team (following augmentat i on), to evaluate radiological conditions and recommend onsite and offsite protective actions to the Station Emergency Manager , to provide recommendations and Health Physics coverage for onsite corrective actions , to direct decontamination efforts , and to provide advice and monitoring for evacuation of on-site personnel.

5.2.1.10 Radiation Protection Supervisor The position of Radiation Protection Supervisor will be filled upon augmentation of the on-shift emergency organization.

The Radiation P r otection Supervisor normally operates from the Station Health Physics office and reports to the Radiological Assessment Director. The Radiation Protection Supervisor directs the activities of the In Plant Monitoring Team , the Sample Analysis Team , the Personnel Monitoring and Decontamination Team , the Onsite (Out of Plant) Monitoring Team , and the Evacuation Monitoring Team. He will also provide radiological support , as needed , to the Fire Brigade , First Aid Team , Search and Rescue Team , and the Damage Control Team. Additional dut i es include evaluating onsite radiological conditions , ensuring that appropriate monitoring and sampling is performed , checking that appropriate personnel monitoring i s performed and personnel exposu r es are evaluated , and maintaining dose re c ords.

NAEP Page 5.9 Revision # TBD He shall also recommend onsite protective measures to the Radiological Assessment Director and provide him with survey results and sample analysis results needed for offsite dose assessment.

5.2.1.11 Operational Support Center Director {OSC Director)

Upon augmentation of the on-site shift , the position of OSC Director will be manned. He will base his activities from the Operational Support Center and shall report to the Station Emergency Manager , normally through the EMO. The duties and responsibilities of the OSC Director include directing the activities of the Operational Support Team , planning, scheduling and material requisitioning in support of damage control tasks and development of procedures necessary for conducting emergency maintenance. The OSC Director is also responsible for dispatch and control of the Reserve Fire Brigade , the Reserve First Aid Team , the Damage Control Team , the Search and Rescue Team and standby operations personnel.

5.2.1.12 OSC Support Team The OSC Support Team will operate out of the OSC under the direction of the OSC Director after augmentation of the on-shift emergency organization. The OSC Support Team plans required maintenance evolutions , develops emergency maintenance procedures , arranges for material acquisition , and can direct the efforts of the Damage Control Teams , if activated.

5.2.1.13 Technical Support Team The Technical Support Team will operate out of the TSC under the direction of the ETD after augmentation of the on-shift emergency organization. The Team members include an Operational Advisor , a Reactor Engineer , a Mechanical and an Electrical Engineer.

The on-duty Shift Technical Advisor has the required training to provide technical support until the Team is fully manned. The Team shall assist the ETD in analyzing electrical , mechanical , instrumentation and control , chemistry , reactor physics, hydraulic and thermodynamic problems and in developing solutions to the problems. The Team shall also assist in developing procedures necessary to deal with the emergency condition.

5.2.1.14 Chemistry Team The Chemistry Team , after augmentation , reports to the RAD/designee and operates out of the Chemistry area of the Station. The Chemistry Team will conduct liquid and gaseous sampling , and sample analys i s , as directed. 5.2.1.15 Administrative Support Team The Administrative Support Team will assist the Emergency Administrative Director on emergency fire protection , security , administrative and logistical support activities. The Team will also provide clerical and records support. If the emergency is Security related , the Administrative Support Team Leader may report directly to the Station Emergency Manager. In a fire or first aid emergency , the Safety/Loss Prevention representative may transfer from the Administrative Support team and report directly to the Station Emergency Manager.

5.2.1.16 Security Team NAEP Page 5.10 Revision # TBD The Security Team reports to the EAD. The Team will maintain personnel accountability , provide site access control , and provide station security. The Team will also maintain liaison and communications with local law enforcement agencies in accordance with procedural guidelines or when directed to do so by the Station Emergency Manager. 5.2.1.17 Dose Assessment Team This Team will operate out of the TSC under the direction of the RAD. The Dose Assessment Team maintains contact with and transmits instructions to Offsite Monitoring Teams , performs offsite dose assessment calculations , and provides the Radiological Assessment Director with offsite release calculat i ons and dose projections.

The Team will also assign an individual to transmit Health Physics and environmental information to the NRG using the Health Physics Network (HPN) phone. The Dose Assessment Team Leader will r eport the results of the offsite releases and dose projections to date to the RAC. The Dose Assessment Team Leader will also inform the RAC of the locat i ons of the Offsite Monitoring Teams and of the current data received from these teams. Control of Offsite Monitoring Teams and responsibility for making HPN notifications will transfer to the ~CERC. The Dose Assessment Team will then provide support to the RAD regarding onsite response and interface with the ~CERC. 5.2.1.18 Offsite Monitoring Teams These Teams will report to the Dose Assessment Team in the TSC or to the MG-Accident Assessment Team in the ~CERC. These Teams will provide offsite monitoring and sample collection as directed by the Dose Assessment Team or the R,I\C. 5.2.1.19 Evacuation Monitoring Team This Team is under the direction of Radiation Protection Supervisor and is activated at the Remote Assembly Area only if a site evacuation is ordered. The duties of this Team include monitoring station personnel at the Remote Assembly Area following a site evacuation , collecting evacuated personnel dosimetry , and decontaminating personnel as necessary. 5.2.1.20 In-Plant Monitoring Team The In-Plant Monitoring Team reports to the Radiation Protection Supervisor in the Station Health Physics Office. This Team will perform monitoring and sample collection inside the protected area. The team will also provide monitoring services to the Search and Rescue Team, the Damage Control Team , the Fire Brigade , and the First Aid Team , if required.

5.2.1.21 Sample Analysis Team NAEP Page 5.11 Revision # TBD The Sample Analysis Team reports to the Radiation Protection Supervisor in the Station Health Physics Office. The team shall analyze samples collected offsite as well as post accident liquid and gaseous samples. 5.2.1.22 Personnel Monitoring and Decontamination Team This Team reports to the RPS in the Station HP Office. The Team will monitor personnel , decontaminate personnel , and provide monitoring services to the Search and Rescue Team , the Damage Control Team, the Fire Brigade , and the First Aid Team, if required. 5.2.1.23 Onsite (Out of Plant) Monitoring Team This Team reports to the RPS and operates out of the Station HP Office. The team will perform monitoring and sample collection within the site boundary but outside the protected area. 5.2.1.24 Fire Brigade The Fire Brigade members arriving at the Station to augment the on-shift Fire Brigade will report to the Loss Prevention Coordinator in the OSC and remain there until their services are needed. Upon activation , the Team reports to the Loss Prevention Coordinator, Station Emergency Manager or responsible Emergency Director , as needed. The Fire Brigade will combat fires in accordance with the Station Fire Protection Program. The onshift Fire Brigade members with other duties will not report to the OSC , but will remain in their normal duties unless called out to combat a fire. 5.2.1.25 First Aid Team The First Aid Team members reporting to the Station to augment the on-shift First Aid Team will report to the Loss Prevention Coordinator in the OSC and remain there until their services are needed. Upon activation, the Team reports to the Loss Prevention Coordinator, Station Emergency Manager or responsible Emergency Director , as needed. The Team will respond to first aid emergencies in accordance with the Station Administrative Procedures and in accordance with standard first aid practices.

The on-shift First Aid Team members will remain in their normal duties unless activated to respond to a first aid emergency. 5.2.1.26 Damage Control Team The Damage Control Team will report to the OSC Director.

When their support is required , the team will report to the EMO or the responsible emergency director as needed. The Damage Control Team will perform emergency assessment and repairs. The Team composition will be determined by the technical expertise required to address the specific problem. Personnel capable of dealing with mechanical, electrical, or instrumentation problems will be assigned to the Team.

5.2.1.27 Search and Rescue Team NAEP Page 5.12 Revision # TBD This Team will report to the OSC Director in the OSC until circumstances require their function to be performed. Upon activation , the Team will report to the SEM , the Safety/Loss Prevention representative or the designated Emergency Director as needed. Prior to arrival of augmentary personnel , an on-shift Fire Brigade Scene Leader will lead the Team. The Team members will be members of the Fire Brigade and the First Aid Team. The Search and Rescue Team will search for and rescue personnel following an explosion , a fire, or any other hazardous event. The Team can be used to locate personnel who are unaccounted for during an emergency.

5.2.2 Corporate

Emergency Position and Team Descriptions The CERC Emergency Organization, when fully implemented, will consist of at least the positions discussed below. Reporting relationships are as depicted in Figure 5.2. Additional personnel may be designated by corporate management as emergency responders providing special expertise deemed beneficial, but not mandatory, to the planned response.

The individuals assigned as interim, primary and alternate responders for the emergency positions will be designated by corporate management based on the technical requirements of the position. Guidance for selection of emergency responders is provided in administrative procedures. The Joint Information Center (JIC) is activated in accordance with the Commonwealth of Virginia Radiological Emergency Response Plan. 5.2.2.1 Corporate Response Manager The Corporate Response Manager (CRM) assumes overall control and operation of the CERC, and is responsible for allocating the use of company resources to aid the affected station(s) in the mitigation of and recovery from an accident.

The CRM works with state and federal agency representatives located in the CERC and approves press releases.

The CRM supervises the Station Emergency Manager, the Technical Support Manager, the Resource Manager, the Nuclear News Manager, the Chief Technical Spokesperson, the Executive Liaison and Emergency Plan Advisor. 5.2.2.2 Technical Support Manager The Technica l Support Manager (TSM) reports to the CRM and is responsible for ensuring that prompt and accurate dose assessments are performed; notifying state and local governments of the emergency status and any changes in a timely manner; assessing and providing protective action recommendations to offsite authorities

ensuring that statements issued to the media are technically correct and factual; and working with the SEM to determine the need to escalate or de-escalate the emergency classification.

The TSM supervises the Operations Support Team and Accident Assessment Team. 5.2.2.3 Resource Manager The Resource Manager (RM) reports to the CRM and is responsible for logistical and administrative support for the CERC. The RM supervises the Resource Team.

5.2.2.4 Nuclear News Manager NAEP Page 5.13 Revision # TBD The Nuclear News Manager (NNM) reports to the CRM and is responsible for overall control for all media and public information functions. The NNM supeNises the News Team and coo r dinates with the JIG Support Team. 5.2.2.5 Chief Technical Spokesperson The Chief Technical Spokesperson (CTS) reports to the CRM and is responsible for seNing as the official company spokesperson. responding to technical inquiries from the news media, and conducting press briefings. The CTS supeNises the JIG Support Team. 5.2.2.6 Executive Liaison The Executive Liaison (EL) reports to the CRM and is responsible for interfacing with senior Dominion management with respect to event status. 5.2.2.7 Emergency Plan Advisor The Emergency Plan Advisor (EPA) reports to the CRM and is responsible for providing assistance with facility operations and interpretation of the North Anna Emergency Plan, including emergency action levels, emergency classifications, protective action recommendations. monitoring siren control system status, and interface with offsite response organizations. 5.2.2.8 Operations Support Coordinator The Operations Support Coordinator (OSC) reports to the TSM and is responsible for providing advice on unit conditions and methods being implemented to mitigate the incident, and assisting in the development of the Recovery Plan after incident mitigation. The OSC supeNises the Operations Support Team. 5.2.2.9 Operations Support Team The Operations Support Team monitors plant conditions using the Plant Computer System (PCS), transmits notifications to the VEOC and local governments, maintains communications with the TSC, and maintains a log of significant events. 5.2.2.1 O Radiological Assessment Coordinator The Radiological Assessment Coordinator (RAC) reports to the TSM and is responsible for directing performance of emergency dose calculations:

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 dose projections:

formulating protective action recommendations (PARs): briefing the CERC staff and federal/state counterparts on radiological conditions and PARs: tracking the plume: and identifying any supplemental resources needed. The RAC supeNises the Accident Assessment Team. 5.2.2.11 Accident Assessment Team The Accident Assessment Team will analyze core conditions and accident progression, develop dose projections. direct the movement and activities of Offsite Field Teams described in Section 5.2.1.18, and establish the Health Physics Network (HPN) when requested by the NRG.

5.2.2.12 Resource Team NAEP Page 5.14 Revision # TBD The Resource Team will provide logistical and administrative support, including development of long-term staffing plans and and acquir i ng supplemental staff as appropr i ate (e.g., Telecommun i cations, Informat i on Technology, Company Meteorologist, etc.). 5.2.2.13 News Team T he News T eam will develop and coordinate review of press releases and other means of providing information to the public, and i ssue approved information. 5.2.2.14 Joint Information Center Support Team The Joint In f ormation Center Suppo rt Team will assist the CTS by providing techn i cal advice and i nterface with offsite r esponse organization public information staff at the JIC, when activated.

5.3 AUGMENTATION

OF ONSITE EMERGENCY RESPONSE ORGANIZATION The Station Emergency Manager has the authority to request assistance from any organization which he deems necessary to mitigate the conditions causing the emergency. In addition , the Station Emergency Manager may request offsite assistance in fire fighting , rescue services, law enforcement , and medical support prior to augmentation of the onsite emergency organization (see Figure 5.3). The participating agencies and support services with whom emergency support services have been negotiated are listed , by letters of agreement , in Appendix 10.1 of this Plan. If conditions at the Station require an Alert or higher classification , the CERC, beGP, TSC and OSC shall be activated (unless special ci r cumstances apply). The facility activation goal for tho LEOr , TSC and GSGthese emergency response facilities is approximately 6075 minutes follow i ng declaration of an Alert or higher emergency class. Special circumstances include those where the movement of emergency responders could place them at risk, e.g., security conditions, severe weather , hazardous environments. Facility act i vation requ i res the assembly of r equ i red pos i t i ons in or under the operationa l control of the designated facility leader and the i r declar i ng the facility activated. The Station Emergency Manager would normally forward information or request additional support through the Rooovory Corporate Response Manager located in the ~CERC (See Figure 5.4). Upon oomplotion of tho notification , tho Recovery Manager wo1:Jld notify tho Corporate

~osponso Manager and provide recommendations concerning additional manpower , oq1:Jipmont , services , and tho overall participation of tho Corporate Emor§oncy Response Toam (CERT). Additional resources shall be obtained through personnel assigned to the Ge-RTCERC. Those additional personnel directed to report to the site during the emergency shall report to oitAef-.the Station Emergency Manager or Recovery Manager for assignment , as appropriate. Figures 5.5.ad display min i mum staff required fo r activation. Tho Corporate Response Manager has tho 1:Jltimato responsibility for directing tho corporate emergency rosponso. Corporate sl:lpport wo1:Jld be coord i nated between tho Station Emor§oncy Manager and tho Recovery Manager at tho LEOF Tho Recovery Manager and his staff will servo as tho point of contaot boP.voon station personnel , tho oorporato emergency response staf.f , and governmental a1:Jthor i tios.

NAEP Page 5.15 Revision # TBD In the event that the LEOF becomes uninhabitable , the functions of tho LEOF will be transferred to the Central EOF (CEOF) located in Gian Allon , Virginia. 5.3.1 Ge-R+Notification and Response The Corporate Emergency Response Teamemergency response organization (ERO) is notified to augment in the event of an Alert , Site Area Emergency or General Emergency.

This will also activate the Corporate Emergency Response Plan as tho toam members report to tho Corporate Emorgoncy Response Center (CERC) in Glen Allon, Virginia. Tho LEOF Recovery Manager will become tho liaison betwoon tho Station and the CERC. He will provide recommendations concerning the corporate response based on tho emergency classification. The Corporate Emergency Response Plan establishes the necessary guidelines for both tho CERC and tho LEOF to assist tho station staff in managing tho omorgoncy.

Those include tAeThe following functions wl=HeA---may be necessary for emergency mitigation and recovery: 5.3.1.1 Environmental Monitoring Provisions for obtaining additional environmental monitoring personnel shall be the responsibility of the G-E-RTCERC. 5.3.1.2 Logistics Support for Emergency Personnel CERT Administrative SorvicosThe CERC Resources Manager will be responsible for all administration and l ogistics including accommodations , Corporate communications, purchasing , finance, commissary , sanitary , transportation , and security services.

5.3.1.3 Technical Support for Planning and Re-entry/Recovery Operations Technical support for recovery and subsequent re-entry would be directed by the Recovery Corporate Response Manager. Trained technical personnel are available in the areas of nuclear fuel management , water quality, air quality, engineering , health physics , and chemistry. Additional technical support would be obtained from Surry Power Station, A/E , and NSSS vendor. Consulting services would be obtained as necessary. Technical support for recovery and subsequent re-entry would be directed by the Recovery Manager. Trained technical personnel are available in the areas of nuclear fuel management , water quality , air quality , engineering , health physics , and chemistry. Additional technical support would be obtained from Surry Power Station , A/E , and NSSS vendor. Consulting services would be obtained as necessary.

5.3.1.4 Interface with Governmental Authorities

~CERC management is responsible for contacting governmental agencies when coordinating mobilization of resources or requesting additional support. The Local Emergency Operations FacilityCERC , once activated , serves as principal point of interaction between Station and governmental authorities once they are mobilized. 5.3.1.5 Release of Information to News Media News releases shall be coordinated with the External Affairs Department.

The Chief Technical Spokesperson is responsible for meeting with the news media. Releases will be coordinated with the appropriate governmental authorities. Briefings will be conducted at the Joint Information Center at the NOTE: Upd ate of r efere n ces t o l egacv vendors i s b eyo nd the sco p e of thi s li ce n se a m e ndm e nt r e qu est. NAEP Page 5.16 Revision # TBD Virginia State Police Administrative Headquarters in Chesterfie , Virginia and , when activated , at the Local Media Center in the North Anna Nuclear Information Center The process for preparing , reviewing

5.3.2 Vendor

and Supplemental Personnel Support will be obtained from the NE , e NSSS vendor , and other consultants and vendors as needed to respond to the emergency and ecovery operations.

Experienced personnel with in-depth expertise in Station design , engineering d construction will be obtained to aid in solving critical technical problems.

This support is normally 1cited by the Corporate Response Manager or his representative. In the event of an emergency, Westinghouse (the NSSS vendor) will also be informed of the plant status. In addition , the Institute of Nuclear Power Operations can be contacted to provide sources of additional support , if necessary. In addition , radiological count laboratory resources are available through the Commonwealth to respond to an emergency at the Station. These resources include those facilities listed below. Estimated travel times to the station are provided parenthetically:

1. University of Virginia , Charlottesville , VA (45 minutes) 2. Virginia Department of General Services , Division of Consolidated Laboratory Services , Richmond , VA (75 minutes) 3. Virginia Commonwealth University Medical Center , Richmond , VA (75 minutes) 4. Newport News Shipbuilding

& Drydock , Newport News, VA (3 1/2 hours) 5. Virginia Department of Health, Office of Radiological Health Mobile Laboratory (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) If required at the time of the event, additional resources can be obtained through purchase agreements with private institutions. These agreements would not be prepared in advance, but would be negotiated on an as needed basis. 5.3.3 Local Services Support Agreements have been arranged to provide fire fighting , rescue squad, medical and hospital services.

Responding rescue squads are trained in the handling , treatment , and transportation of injured personnel.

The Virginia Commonwealth University Medical Center (VCUMC) has developed an Emergency Plan designed to provide medical care in the case of a radiation emergency. The MCVHNCU Radiation Emergency Plan supports the company's nuclear power stations in the case of occupational and/or major accidents , including contaminated personnel.

In the event of a need for their support , a call ahead to VCUMC will be made to alert them to activate their Radiation Emergency Plan. A copy of the plan is maintained on file by Nuclear Emergency Preparedness Department and is incorporated into this plan by reference as Appendix 10.9. Letters of Agreement in support of the North Anna Emergency Plan are re-negotiated once every 2 I years. Copies of current agreements are maintained on file by the Nuclear Emergency Preparedness NOTE: U pd ate of thi s l egacy title i s beyond th e sco p e of thi s li cense amendment r equest. department.

NAEP Page 5.17 Revision # TBD revision. Agreement letters are limited to Federa , tate , Local , and volunteer organizations.

Negotiation responsibility lies with the Director Nuclear Emergency Preparedness. 5.4 COORDINATION WITH PARTICIPATING GOVERNMENT AGENCIES The State organization for response to radiological emergencies is based on normal governmenta l structures and channels of communication. The Governor , in his role as Director of Emergency Management , directs the emergency response through the State Coordinator of Emergency Management.

The State Coordinator of Emergency Management coordinates the overall response , and the Department of Health provides technical advice and assistance on radiological accident assessment , protective action , radiological control , and radiological monitoring.

Responsibility for radiological emergency response rests primarily with the elected officials of local governments.

As time is a major facto r in realizing the benefits of protective action in the event of a radiological emergency , certain of these actions are predetermined and agreed upon by the local governing body and are implemented without delay upon notification of a radiological emergency. An lnsta-phone (dedicated county and state ringdown loop), continuously monitored by the Operations Shift , with extensions available in the Control Room , TSC and ~CERC , is used for normal transmission of emergency notifications to these authorities (See Section 7.2.2.5). Procedures for authentication of an emergency , via the use of restricted , unpublished call-back telephone numbers , are maintained in State and local Radiological Emergency Response Plans. When notification is received , the Commonwealth of Virginia Emergency Operations Plan (COVEOP) is implemented and the Virginia Department of Health (VDH) initiates action to assess and evaluate the radiological situation in order to provide guidance and assistance to local governments. After the initial immediate actions , subsequent protective actions are made based on the results of the State evaluation of the radiological situation and the company's recommendations. State and Federal agencies provide assistance as required. Response operations at the State level are coordinated by the Virginia Department of Emergency Management (VDEM). The State will also provide police support during activation of this plan. In the event of an emergency , the dispatcher at the State Police Headquarters in Richmond , Virginia would normally be called. The first response would most likely be from police un it s normally based in the local area. These resources would be supplemented by add i t i onal units dispatched from other parts of the state. The State Police would also provide traffic control and additional security. The Virginia Department of Game and Inland Fisheries is also part of the response to this Plan. Their role would be to assist in monitoring Lake Anna and provide knowledge of local terrain. The local County Sheriffs of Louisa and Spotsylvania counties also respond to this Plan. They can perform essentially the same functions as the State Police and coordinate their efforts w i th that o r ganization. In the event of an eme r gency , the Station w i ll be in communication with the Louisa , Spotsylvania , Orange , Hanover , and Caroline Directors of Emergency SeNices who have the capability of activating their Emergency Operations Centers. The Station relies upon these counties to provide assistance in the event NAEP Page 5.18 Revision # TBD an evacuation from the site requires a remote assembly point or for any services the counties are capable of provid i ng to mitigate the results of the emergency. The Station relies upon Louisa and the Commonwealth of Virginia to coordinate response with other local , state , and federal agencies during a large scale incident , such as a hostile action against the station or a secur i ty event. Response agencies will use Incident Command Systems (ICS) guidelines in managing large scale incidents. The Station will also maintain close contact with the NRG Operations Center and/or the NRG Region II offices in Atlanta , Georgia. This is an important function to ensure that accurate information and assessment of the emergency are available to the Federal Government.

As a result of these communications , the NRG can best appraise their response to the emergency.

In a like manner , the U.S. Department of Ene r gy, Oak Ridge Operations , is available to provide radiological assistance to the Station. The Station has the responsibility to provide to supporting agencies i nvolved in the recovery of the facility or participating in controlling the emergency the necessary information to permit them to use their resources. In the case of the local counties , the Company provides communication and , when needed , training.

This training takes the form of participation in drills and exercises by the county and radiological training for members of local volunteer rescue squads and fire departments. The Company and/or Station will arrange drills and exercises on a routine basis to ensure the plan is workable and to gain experience in its implementation.

The total effort of all parties involved shall be directed toward minimizing the results of an emergency and working toward the recovery of the facility with the least impact on the population at large. CERC personnel coordinate support activit i es with federal and state agencies responding to the emergency and/or recovery. The Corporate Response Manager may also assemble NRC. state. vendor. and/or consultant support at the CERC. Assistance may be sought from other nuclear utilities.

if needed. If requested by the State EOC. a Company technical representative will be dispatched to provide technical interpretation or clarification of data transmitted to that office. (This individual

's responsibilities do not include making statements to the media.) 5.4.1 Commonwealth of Virginia Department of Emergency Management (VDEM) The State Coordinator of Emergency Management coordinates the overall response operations at the State level and performs specific duties as defined in the COVEOP. The VEOC is located in Richmond , Virginia. There are local Emergency Operations Centers in Louisa and Spotsylvania Counties.

The VDEM will send appropriate l i a i son personnel to the heeal Emergency Operations FacilityCorporate Emergency Response Center upon activation. 5.4.2 Commonwealth of Virginia Department of Health (VDH) VDH personnel , in coordination with VDEM , provide technical advice and assistance on rad i ological accident assessment , protective actions , radiological exposure control , and radiological monitoring. (Reference COVEOP for more specific information

.) Upon either an Alert or higher classification , VDEM will notify VDH's Office of Radiological Health which will then implement its response procedures. Included in NAEP Page 5.19 Revision # TBD the planned response is a team sent to the ~CERC , which provides a direct interface between VDH and the i r Radiological Emergency Response Team (RERT) ope r ating from the VEOC. VDH also p r ovides advice and assistance , as required , to Local Health Districts which provide primary health services to their respective areas. 5.4.3 Additional State Agency Support Additional State organizations having possible responsibilities in a r adiological emergency a r e listed in COVEOP. Requests for support services from these organizations will be coordinated through VDEM by the SEM or the Recovery CERC Resource Manager. 5.4.4 Louisa County The authority and responsibilities of Louisa County are presented in the Louisa County Radiological Emergency Response Plan (RERP). The Louisa County Radiological Emergency Response Plan applies to radiological emergencies within the county and: a. Assigns responsibilities to county offices and organizations for radiolog i cal emergency response and preparedness. b. Sets forth procedures for dissemina ti ng warning of radiological emergencies to the citizens o f the cou nt y. c. Specifies response actions fo r specific emergency classificatio n s. d. Delineates the policies and concepts under wh i ch the county government will operate in radiological emergency response. Upon noti fi cation from t h e Station Emergency Manage r , the Sher i ff's Office w i ll notify the County Coordinator of Eme r gency Serv i ces , or his designated rep r esentat i ve , who shall: a. Check the notification from t he Power Station. b. Initiate the key county official's alert system. c. Initiate public warning procedures , as authorized by the appropr i ate State authority. d. Prepare for evacuation of people for the affected a r ea if autho riz ed by the approp r iate State authority.

The County Coordinator of Emergency Serv i ces or his representat i ve will activate and ensu r e that the EOC i s manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Once initial notifications are complete , the S t ation Emergency Manager or Recovery Technical Support Manager provides periodic status reports to the County Coo r dinator o f Emergency Services. These reports will i nclude a n y changes in status o r emergency classification. The County She r i ff's Office w i ll serve as the local point for official communications within and out of the county , prior to establishment of the County Emergency Operations Center (EOC). When the EOC is established , this responsibility will transfer to the EOC. 5.4.5 Spotsylvania, Caroline, Hanover, and Orange Counties The authority and responsibilities of the above coun t ies during a radiological emergency are presented in their respective RERP. The RERPs apply to the radiological emergencies within these localities caused by events at the North Anna Power Station. Th e Spotsylvania , Caro l ine , Hanover , and NAEP Page 5.20 Revision # TBD Orange County RERPs are identical to the Louisa RERP , as described in Section 5.4.4 of this Plan, except for information that is specific to the respective counties. In the event of an emergency of any classification , the SEM will notify all local jurisdictions (Louisa , Spotsylvania , Caroline , Hanover , and Orange and the State) by using the lnsta-phone loop. If the lnstaphone is out of service , regular commercial telephone will be used to make the notifications and the above localities have a system to call back to the power station and check the message. All local jurisdictions provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day coverage. 5.4.6 Counties and Cities Within the Fifty Mile Ingestion Emergency Planning Zone {EPZ) The counties that are directly involved in the emergency plan are Louisa and Spotsylvania.

These counties are the major component of the 10 mile zone. They have emergency response functions as previously stated in this section. The counties and cities within the fifty mile EPZ are listed in Table 5.3. In the event of an emergency , notification and coordination with these entities is the responsibility of the VEOC. 5.4.7 Federal Radiological Monitoring and Assessment Center {FRMAC) Operations Plan The FRMAC Operations Plan provides for the coordinated management of Federal technical response activities related to a radiological emergency. Its primary goals include:

• Assisting the State and Federal Coordinating Agency with personnel , equipment, and technical resources , as needed;

• Collecting offsite environmental radiological data; and ,

• Providing the data and related assessments to involved State agencies and to the Federal Coordinating Agency. The Department of Energy (DOE), because of its history and capabilities in radiological monitoring and assessment , was assigned the responsibility to prepare for , establish , and manage the FRMAC. The FRMAC may be activated when a major radiological emergency exists, and the Federal government will respond when a State , other governmental entity with jurisdiction , or a regulated entity requests federal support. The SEM , Recovery Manager or Corporate Response Manager may request FRMAC assistance directly or through the NRG (Federal Coordinating Agency). The Company will provide designated facilities (space and communications equipment) for the NRG (Federal Coordinating Agency) in the ~CERC. It is estimated that a FRMAC Advance Party could be expected at the site within 6 to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> following the order to deploy, based on the availability of airports near North Anna. Richmond International Airport (RIC) is a major commercial facility and is within about an 85 minute drive from the station. Smaller airports located within about an hour of the site may also be used. Further information concerning objectives and organization is provided in the FRMAC Operations Plan (See Appendix 10.10).

TABLE 5.1 MI N IMUM STA FFING R EQ U IREME N TS FOR EMERGENCIES N A EP Page 5.21 Re v ision # TBD Bolded titles indicate 1 O CFR 50 Appendix E Part IV.A.9 minimum on-shift requirements. Additional Within Approx. Major Functional On 4a60 6075 Area Location Major Tasks Emergency Title Shift Min. Min. Assessment of CR Supervision of Shift Manager-Op e rationa l St a tion Operations

{SRO} 1 Aspects a n d Assessment of Operationa l Aspects CR Plant Operations Unit Supervisor

{SRO} 2 Control Room Operator {RO} 4 Control Room Operator {AO} 8 Emergency CR!TSC Direct i on and Station Direction and C o ntrol of On-Site Emergency Control Emergency Manager 1 a Activities Notifications and CR!TSC Notify Offsite Emergency Communications S u pport Groups and Communicator 2b 2 Maintain Communications Support of Management of Recovery (Refer to Table 5.2) Operational CERC Emergency Technical Suggort Accident Response Manager Assessment Resources and Recovery Operations Radiological TSC/~ Radiological Dose Radiological Accident CERC Assessmen tL Assessment Assessment Accident Director/ 1c Assessment Rad i ological Assessment Coordinator Offsite Off s ite Surveys Offsite Monitoring Team Leader Offs i te Mon i tor i ng Team Member Onsite On s ite (Out of Plant) Onsite Monitoring Surveys Team Leader Onsite Monitoring Team Member NAEP Page 5.22 Revision # TBD Additional Within /1.pprox.

Major Functional On 4e60 6075 Area Location Major Tasks Emergenc~

Title Shift Min. Min. Radiological In-Plant In-Plant Surveys In-Plant Accident and Radiochemistry Monitoring Team Assessment Leader 1 [continued]

In-Plant Monitoring T earn 1 Member In-Plant Chemistry Chemistry Team Leader Chemistry Team Member 1 Plant Systems CR/TSC Operational Shift Technical Engineering Technical Support Advisor 1d Repair and (STA) Technical Support Corrective Team Member Actions (Operational Advisor) 1e TSC Core and Thermal Technical Support Hydraulics Team Member 1 f TSC Electrical Technical Support Team Member TSC Mechanical Technical Support Team Member 1 Repair and Corrective Actions osc Mechanical Damage Control Maintenance Team Member 19 2 osc Electrical Damage Control Maintenance Team Member 19 osc Instrumentation and Damage Control Control Team Member In-Plant In-Plant Radiation Protection Personnel Protective Monitoring T earn Actions Personnel Leader Monitoring and H.P. Personnel Coverage , Monitoring Team 1h Dosimetry and Member 2 Access Control Major Functional Area Location Major Tasks Emergency Title Firefighting In-Plant Firefighting Fire Brigade Members (Operations)

Fire Brigade Members (Security)

First Aid & In-Plant First Aid First Aid T earn Rescue Member In-Plant Search and Rescue Search and Rescue Team Member Site Access In-Plant Security and Access Security Control and Control Team Personnel Members Accountability In-Plant Personnel Security T earn Accountability Leader NOTES: a This coverage is provided by the Shift Manager until relieved.

NAEP Page 5.23 Revision # TBD Additional With in Approx. On 4e60 e075 Shift Min. Min. 3; local support 2' 2 i local support (Proprietary) (Proprietary) 22 9 19 b Communicator taken from the complement of reactor operators/auxiliary operators on shift. c This coverage is provided by the Senior RP representative onsite until relieved. d Numbers shown are for 2 Unit Operation. With both units in cold shutdown condition , the minimum shift crew will be as defined in 1 OCFR50.54(m)(2)(i) and the Technical Specifications.

e The candidates for this position are limited to qualified ST As , SROs , former ST As, or former SROs. The on-duty Shift Technical Advisor performs the responsibilities of this position prior to augmentation. g Mechanical and electrical maintenance personnel are normally onsite on a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per day, 7 day per week basis. This coverage may be provided by personnel who are assigned to other functions during the period that mechanical and electrical maintenance personnel are not onsite (not counted in total). h This personnel monitoring team member is qualified to provide RP job coverage duties. The Fire Brigade consists of auxiliary operators on shift and other qualified non-operations personnel.

This coverage is provided by personnel who may be assigned other functions (not counted in total).

TABLE 5.2 NAEP Page 5.24 Revision # TBD EMERGENCY AND RECOVERY CORPORATE RESPONSE REQUIRED FOR NUCLEAR STATION EMERGENCIES Major Functional Area (Emergency Position Title) Management of hooal emergency Operations Faoil ity (Rooovory Ma nagor)Corporate Emergency Response Center (Corporate Response Manager) Health Physics & Chemistry (Radiological Assessment Coordinator)

Technical Support (Technical Support Manager) Plan/Design/Construction (P lan/Dosign/Construotion Resource Manager) News Center interface (Chief Technical Spokesperson) (ALERT STATUS AND ABOVE) Major Tasks To coordinate the Company's response to emergency and recovery with Federal , State and local authorities.

Report to the Rooovory Techncial Support Manager to conduct radiological assessment activities.

Reports to the Corporate Response Manager to provide technical and evaluation support. Reports to the Corporate Response Manager to provide engineering technical and vendor support in areas dealing with construction or design changes. Reports to the Corporate Response Manager to become the Company Spokesperson in any statements to the News Media. Available

_In_ 75 min.4--Rf.,. 75 min.4--Rf.,. 75 min.4--Rf.,. 75 min.4--Rf.,. 75 min.4--Rf.,.

1 . 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20 * ** TABLE 5.3 NAEP Page 5.25 Revision # TBD CITIES AND COUNTIES WIT HIN THE N O RTH AN N A 50 MILE EMERGENCY PLANNING Z ONE** City of Charlottesville

21. Louisa County City of Fredericksburg

22. Madison County Cit y of Richmond

• 23. Ne l son County Albemar l e Coun t y 24. Ora n ge County Amelia County 25. Page County Buckingham County 26. Powhatan County Caro l ine County 27. Pr i nce William County Chesterfield County

• 28. Rappahannock County Culpeper County 29. Rocki n gham Co u nty Cumberland County 30. Spotsy l vania County Essex County

• 31. Stafford County Fauquier County 32. Westmoreland County Fluvanna County Goochland County Green County Hanover County

• Henrico County

• K i ng and Queen County

• King George County King W illiam County

• Within 50 miles of both Surry and North Anna That portion of the State of Mar y land l ying within the 50 mile zone has been exc l uded. (Reference N RG Letter of February 6 , 1981 , Serial Number 100).

• ** # ## NAEP Page 5.26 Revision # TBD STATION EMERGENCY ORGANIZATION PRIOR TO AUGMENTATION

• FIGURE 5.1 STATION EMERGENCY MANAGER H EMERGENCY I COMMUNICATOR I SHIFT MANAGER OR UNIT SUPERVISOR I ON-DUTY OPERATIONS PERSONNEL I ON-DUTY -1 CHEMISTRY STA## TEAM DAMAGE SECURITY CONTROL ..__ -TEAM TEAM# FIRE TEAM TEAM** -1 FIRST AID .__________.

._______.

SEARCJIAND RESCUE TEAM** Augmented for Alert, Site Area Emergency and General Emergency. This coverage is provid ed by p erso nn e l who may be assigned other functions.

This coverage may not be provided on a full time basis. I RADIOLOGICAL ASSESSMENT DIRECTOR I IN-PLANT MONITORING TEAM The on-duty ST A provides technical support as well as operations s upport to the SEM until the Technical Support Team is activated.

--* ** # NA EP P a ge 5.2 7 Revi si o n # TBD STATION EMERG E NCY ORGANIZATION FOLLOWING AUGMENTATION

• FIGURE 5.2 STATION EMERGENCY MAN ~GER EMERGENCY I EMERGENCY PROCEDURES I COMMUNICATOR I COORDINATOR I I I I EMERGENCY EMERGENCY EMERGENCY EMERGENCY OPERATIONS MAINTENANCE TECHNICAL ADMINISTRATIVE DIRECTOR DIRECTOR DIRECTOR DIRECTOR I I I SHIFT TECHNICAL ADMINISTRATIVE MANAGER SUPPORT SUPPORT OR TEAM TEAM UNIT I SUPERVISOR I I RADIOLOGICAL SECURITY osc ASSESSMENT DIRECTOR TEAM .... DIRECTOR ON-DUTY I OPERATIONS I I DOSE RADIATION osc PERSONNEL ASSESSMENT PROTECTION SUPPORT --TEAM SUPERVISOR TEAM ON-DUTY I STA## OFFSITE IN-PLANT FIRE MONITORING MONITORING TEAM --TEAMS (2) TEAM **,# SAMPLE FIRST AID ANALYSIS TEAM --EVACUATION TEAM **,# MONITORING DAMAGE TEAMS** CHEMISTRY CONTROL TEAM -PERSONNEL TEAM**,# MONITORING SEARCH AND AND ON-SITE RESCUE DECON TEAM ** (OUT OF PLANT) --TEAM**,# MONITORING TEAM STANDBY OPERATIONS

-Augme n ted for A l ert, Site Area Emergency and G e n era l Emergency.

PERSONNEL ,# This team will be activated on l y if circumstances r e quire this functio n to be performed. Norma l reporting str u cture i s s h own. If t h e team is ac t ivated , contro l of the team will transfer to t h e Statio n E merge n cy Manager or appropriate Emergency Dir ec tor.

STATION TO SUPPORT GROUP INTERFACE PRIOR TO AUGMENTATION OF THE EMERGENCY ORGANIZATION FIGURE 5.3 STATION EMERGENCY MANAGER CORPORATE STATION OFFICE EMERGENCY ORGANIZATION I SEE FIGURE 5.1 NEWS MEDIA LOCAL FIRE LOCAL FIGHTING RESCUE SERVICES SERVICES VIRGINIA LOCAL LAW COMMONWEALTH UNIVERSITY EN F ORCEMENT MEDICAL CENTER AGENCIES OTHER SERVICES NAEP Page 5.28 Revision # TBD STATION EMERGENCY MANAGER STATION EMER G ENCY ORGANIZATION (SEE FIG. 5.2) SYMBOLS: STATIO N TO SUPPORT G R OUP INTERFACE FOLLOWING LEOF ACTIVATION FIGURE 5.4 NAEP Page 5.29 Revision # TBD CORPORATE RESPONSE MANAGER ----.--LO EME RG CY OPERATI S FACILITY VIRGINIA DEPT. OF EMER G ENCY MANAGEMENT VIRGINIA DEPT. OF HEALTH (OFFICE OF RADIOLOGIC HEALTH GINIA ONWEALTH UNIVERSITY MEDICAL CENTER VIRGINIA DEPT. OF GAME AND INLAND FISHERIES RECOVE R Y MANAGE R FIRE DEPARTME N TS RESCUE SQUADS ' I I I I I I I I r-UNAFFECTED POWER STATION SUPERINTENDE N T SCHOOLS DEPT.OF SOCIAL SE R VICES DEPT.OF PUBLIC HEALTH NUCLEAR STATION TO SUPPORT GROUP INTERFACE FOLLOWING beGI<CERC ACTIVATION FIGURE 5.4 CORPORATE

---

NA EP Page 5.30 Re vi sion # TB D UNAFFECTED REGULATORY

---

RESPONSE POWER COMMISSION MANAGER STATION I EXECUTIVE LIAISON t-CHIEF JOINT INFORMATION

-TECHNICAL

-CENTER {.TI C) I EMERGENCY PLAN ADVISOR~ SPOKESPERSON SUPPORT TEAM I I STATION . TECHNICAL EME RGENCY SUPPORT --, MANAGER MANAGER I I I I STATION OPERATIONS . EME RGENCY SUPPORT& ORGANIZATION I ACCIDENT (SEE FIG. 5.2) I ASSESSMENT TEAMS I r I -----------

I VIRGINIA DEPT. OF EMERGENCY

-MANAGEMENT VIRGINIA DEPT. OF HEALTH (OFFICE OF ,__ RADIOLOGICAL HEALTH) D EPT. OF VIRGINIA STATE -POLICE VIRGINIA COMMONWEALTH

-UNIVERSITY MEDICAL CENTER VIRGINIA DEPT. OF GAME AND -INLAND SYMBOLS: FISHERIES MANAGEMENT CONTROL COORDINATED ASSISTANCE I RESOURCE MANAGER I I I I I I I I I : I RESOURCE I I I : TEAM I I I I I I INDUSTRY u." s. DEPT. SUPPORT OFENERGY -----------

-, I I DIRECTOR EMERGENCY SERVICES (LOCAL GOV'T) (D OE) I I i NUCLEAR NEWS MANAGER I I NEWS I TEAM O FFICE OF EMERGE NCY SERVICES SUPERINTENDENT SCHOOLS SHERIFF OR POLICE FIRE DEPARTMENTS RESCUE SQUADS SHADED BOX IDENTIFIES SUPPLEMENT AL STAFFING WHEN CERC SUPPORTING SUR R Y AND NORTH A N NA DEPT.OF SOCIAL SERVICES DEPT.OF PUBLIC HEALTH I TECHNICAL SUPPORT CENTER ORGANIZATION FIGURE 5.5.a I I I I llll'l~Clll: ( lp.:1 di I< llh I l11 L 0 l ll )I Tse* ( \ 1111111u11ica1< ,r I l111L-r-l:1cilit\

l NRC I .111cr~c11n ( *, l)]]lllll lliL*:11<

ll" I ---------------, __ : Plant Status : : Communicator

l--------------~

Emergency Procedures Coordinator I lllc"I ~l"lll: I Cl'illlll,il I )11 c*LI, ll Technical Support Team Leader

• TSC Communicator fu l fills state/local notification function ifEOF unavailab l e. S1.111,l11 I 111L'l~l*11L:

\J.111a~c*1 Indicates ositions necessarv for facilit activation.

_[] Indicates fully a ugmented organization position s. ;--: Indicates position established if needed. -,_ __ I 111L*1~l"lll\

\ l.11111c11.111LL" I l11n 1,)1 Emergency Administrative Director Administrative Support Team Leader TSC Logkeeper Adrninistrati ve Support Team Clerk (3) NAEP Page 5.31 Revision # TBD R.1d1,,J,,~1l,il . \ SSl'SSil]L'I]( I l11 L*ct"1 OPERATIONAL SUPPORT CENTER ORGANIZATION FIGURE 5.5.b < >S(. I )11 c'c ll ll I OS C Supp o rt T ea m I I I i ! I ' l ! I I I I I i I Radiological 1

• Operations OSC Team Leader

• j! Protection Coordinator I Coordin ato r ; Material E l ec tri ca l Coordinator NAEP Page 5.32 Revision # TBD I I Coordinator

...._.....__, Outage & Planning Coordin ator ~------~*

! l, 1 Status Board Safety Keeper Coordinator

Additional as n ee d ed: *----------------.,, 1. Wgkoepe, :::::: 1 E ngineerin g I Coordinator I I i I 1 I I------.--------I I Ii*.. i 1 -0:*~~~:,~:~~-j I : : Rad Wa ste : i -, I i l [ _ -_::~~

--_: ! i i I I : *Additional as n ee d e d: I L----------------

1 I 1----------------1 L-:~~~~~<l!~ _: I I * ...........

................................

.... -...........................................

...........................

.....................................................

............................................................

J I I I ,------_ J_ -------, ,--------L -------1 ,--------L-------1 , Search & R esc u e 0 I I 1 First Aid Team * ' I I L---------------~

I , Fire Brigade * : L---------------~

I I , Team** 0 L---------------~

• F ir s t Aid T e am and F ir e Bri g ad e function s ar c addre ss ed by o n-s hift per s onn e l. Addition a l qualifi e d per s onn e l wh o report t o the OSC m a y be de s ign a t e d for th ese fun c tion s. ** Se a rch & R esc u e T ea m form e d fr o m Fir e Bri ga d e/Fir s t Aid T e am/S ec urity s t a ff as a pprop r i a t e. Indi ca t es o it io n s n ecessa r for fa c ilit ac ti va ti o n. Indi ca t es full a u m e nt e d o r ga ni za ti o n os iti o n s. ;--, Indi ca te s team es tabli s h e d as n ee d e d.

In l'l.1111 \l(ll]ill>llll~

I L'.llll I c.idcr RADIATION PRO T ECTION ORG A NIZATION FIGURE 5.5.c ( l11-S1IL 0 1<lu1-,,1-l'l.11111

\ '"llil\lll II~ I L"dlll I L',ldc*1 l{,1d1.11 lllll J'illil'Lllllll Supc*111s<>I I I I r----------------------r-------

1 I I ( )! hill' \l,,1111,,1111~

I c*.1111 '/ :'. I c*.1dc*1 l'L"I SllllllL" I \I<,11!1<>1111~

I c.1111 LL\idL'I l'L"( ,(l(lflc'I

\ 1< 11111, ,1111~ I c\1111 \k111hc*1 In d i ca t es os i t i o n s n ecessa r for ac ti va ti o n. NAEP Page 5.33 Revision # TBD ChL'llll sl I I J L".1111 l.c*.1,lc-1

• O ffs it e Mo nit o rin g Tea m s a r e co n tro ll e d by CE R C Acc id e nt Assess m e n t Tea m after be in g s t aged.

NAEP Page 5.34 Revision # TBD CORPORA TE EMERGENCY RESPONSE CENTER ORGANIZATION FIGURE 5.5.d < )pL'I at H llla I Suppo1 t ('001d111.1to1 Executive Liaison Emergency Plan Adv iso r TL'L illlll',il Suppo1 t \J.m.igL'I R.1d 10 log IL' .ii \ssL'SSlllL'll( ( *001d111.1to1

('illjlllldll' RL'Sjl( )ilSL' \l.111.1gl' 1 C'h1L'I I L'L'hllll,il SpokL'spL'1 so11 ! ~~nt !~~';;:~tion Cente, Dominion I',,. t-----1 Dominion Technical

............................ ~'..~.'..~:.~ ...........................

........................

..... ~.~.~i*~*~*~************ .. ********* .. 1 RL'S()lllLL'

\J.111.tgL'I

\uck,11 :'\L'\\ S \l.111.1gl'1

---l l-+-.,,O~e""r""at,.,_io""n,.,,a,,.,l'-----

'+-j ..-i +--'A-"c""c""i""d""en

.... t"------~j f--+[+---=Rc,;e"'s""o'""u""rc""e"-----

+-i -+j +--=N"'-e=-w"'""s i Su ort [ i ~s::::: nt ' Team I , Tea~~~:, I,. D ~--. L--CERC Communicator (Inter-facility)

Plant Information Coordinator Indicates ositions necessary for facility activation.

Indicates fully augmented organization positions. Indicates team established as needed. Q Indicates expa nd ed ERO for dual-station response. Safet Analy : ............... -....................

..................................

• i,,',,,,, ,:',,. ~eLo~::g:is

10. nt 1 i:ctgs 0 i:t ' Talking-Points I n"o~r 0 mi~a~t~1*o;ne;Ct~ei:nter I Administrative

, I : Suppor : 1 .................

...............

• i.,,. :_ { Other Support : ! , Personnel

! 1 __________

_____ , ! ! .........................

............................

...........

Part 6.0 6.1 6.2 6.3 6.3.1 6.3.2 6.3.3 6.3.3.1 6.3.3.2 6.3.3.3 6.4 6.4.1 6.4.2 6.4.3 6.4.4 6.5 Table 6.1 Table 6.2 Table 6.3 Figure 6.1 Figure 6.2 Figure 6.3 Figure 6.4 Figure 6.5 Figure 6.6 NORTH ANNA POWER STATION EMERGENCY PLAN SECTION 6 EMERGENCY MEASURES Subject Emergency Measures Activation of the Emergency Plan Assessment Actions Protective Actions Offsite Criteria for the 10 Mile Emergency Planning Zone (EPZ) Onsite Criteria for the Exclusion Area Use Onsite of Protective Equipment and Supplies Respiratory Protection Protective Clothing Thyroid Blocking Agent Aid to Affected Personnel Emergency Exposure Limits Decontamination and First Aid Medical Transportation Med i cal Treatment Offsite Support Radionuclides with Significant Contribution to Dominant Exposure Modes North Anna Population Distribution and Evacuation Time Estimates North Anna Power Station Population Data by Sector Sample Form: Report of Emergency to State and Local Governments Sample Form: Protective Action Recommendation Sample Form: Radiological Status Form (MIDAS generated)

Sample Form: Radiological Status Form (manual) NAPS 10 -Mile Emergency Planning Zone Remote Assembly Areas NAEP Page 6.1 Revision # TBD Page No. 6.2 6.2 6.2 6.3 6.3 6.5 6.6 6.6 6.6 6.6 6.6 6.7 6.7 6.8 6.8 6.8 6.9 6.10 6.11 6.12 6.13 6.14 6.15 6.16 6.17

6.0 EMERGENCY

MEASURES NAEP Page 6.2 Revision # TBD Emergency measures provide pre-planned actions, methods, and criteria which guide personnel during the course of an emergency. The initial response to any emergency condition will be the activation of the Emergency Plan. After activation, the emergency organization that is formulated by activation of the Emergency Plan performs the necessary assessment activities to classify the type of emergency. If the emergency is radiological in nature , the potential consequences of the emergency will be evaluated for the necessary offsite and onsite protective actions to guard the health and safety of the population.

If additional assistance is required , offsite support will be requested as provided for in letters of agreements established with a variety of government agencies and volunteer organizations. 6.1 ACTIVATION OF THE EMERGENCY PLAN Each full time employee of the station is required to be familiar w i th the provisions of the Emergency Plan. Any employee , upon becoming aware of an emergency condition , shall immediately notify the Shift Manager on duty unless it is apparent notification has already taken place. Upon such notification or other indications , the Shift Manager or Unit Supervisor assumes the responsibilities of the Station Emergency Manager. The SEM will classify the emergency , initiate the appropriate not i fications and call outs , and coordinate the actions of the emergency response organization.

State and local community officials will be notified within 15 minutes after declaration of an emergency (meaning the emergency classification level has been provided to the Virginia and risk-jurisdiction Emergency Operations Centers (EOCs)). The initial information following declaration of any emergency class includes the class of emergency, whether a release is in progress , and any recommended protective measures. Additional information will be provided as it becomes available. Figures 6.1 through 6.4 are samples of message forms used for these notifications. The content of the messages have been established in conjunction with the State and local governments.

Notifications will be made to the NRC as soon as possible but within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after declaration of an emergency. Initial information is provided to the NRC as required by 10 CFR 50. 72 (Immediate notification requirements for operating nuclear power reactors).

Dedicated communicators will be available to provide regular updates to state and local officials approximately every 60 minutes , when conditions change or as otherwise agreed , and to maintain a continuous channel of communications with the NRC. 6.2 ASSESSMENT ACTIONS EPIP-1.01 , Emergency Manager Controlling Procedure , is the procedure for emergency event categorization and classification , while EPIP-4.01 , Radiological Assessment Director Controlling Procedure , provides guidance for conducting dose assessment , source term determination , atmospheric diffusion factor determination , monitoring team activities , personnel monitoring and decontamination , monitoring of onsite facilities , evacuation , respiratory protection , sampling and sample analysis , and use of the MIDAS computer model. Once the emergency classification has been determined , the appropriate EPIPs are initiated to direct the activation of the required emergency response facilities and call out of designated emergency response NAEP Page 6.3 Revision # TBD personnel.

The design of the facilities and the data retrieval and monitoring capabilities provide the information needed to make timely assessments and formulate appropriate protective actions. 6.3 PROTECTIVE ACTIONS The Recovery Technical Support Manager or the Station Emergency Manager (if the ~CERC is not yet activated) is responsible for recommending offsite protective actions to the State. The State and local governments are responsible for notification of the public and implementation of the appropriate protective measures. 6.3.1 Offsite Criteria for the 10 Mile Emergency Planning Zone (EPZ) Dose contribution from key isotopes such as those listed in Table 6.1 (and analyzed in UFSAR Sections 11 and 15) are used to calculate offsite doses for comparison to protective action recommendation thresholds.

Protective action recommendations are required to be made to the State within 15 minutes of declaring a General Emergency.

Specific protective action recommendations tied to plant and meteorological conditions have been designed to facilitate meet i ng this time requirement.

This gu i dance is based on Supplement 3 (Guidance for Protective Action Strategies) to NUREG-0654/FEMA

-REP-1 , " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." The initial protective action recommendation for any event classified as a General Emergency will be to evacuate a 2 mile radius and 5 miles in the downwind sectors unless severe accident conditions exist, an evacuation dose threshold is exceeded beyond 2 miles or sheltering

-in-place is appropriate. Sheltering

-inplace may be appropriate when known conditions make evacuation dangerous , such as a hostile action based event. Follow-up protective action recommendations that the station may make to the state will be based on current meteorological data such as wind direction , w i nd speed and stability class , and dose projections. Also , consistent with the Commonwealth of Virginia's strategies for supplementing these protective actions with use of potassium iodide (Kl) by the general public as a prophylact i c , recommendations will be made for implementing these strategies. A Site Area Emergency will be declared when offsite doses are projected to exceed 0.1 Rem TEDE or 0.5 Rem Thyroid COE. A General Emergency will be declared when offsite Protective Action Guides (PAGs) of 1.0 Rem TEDE and/or 5.0 Rem Thyroid COE are projected to be exceeded due to a direct radiation or inhalation hazard , or when non-radiological conditions exceed General Emergency EALs. Warnings to the public within the 10-mile EPZ (Figure 6.5) will be the responsib i lity of State and local officials who will be assisted by the Virginia Department of State Police upon request. The primary method of warning the public is by the use of the Early Warning System si r ens. Route alerting provides backup alert and notification capability (reference 10 CFR 50 , Appendix E , paragraph IV.0.4). Other warning methods may include telephone communications , television and radio Emergency Alert System stations , public address systems, bull horns from patrol cars and personal contact. There are currently no hospitals , prisons , or nursing homes within the 10 mile EPZ.

NAEP Page 6.4 Revision # TBD It is estimated that the primary sector and the two buffer sectors (spanning 67 1/2°) can be alerted of the emergency within 15 minutes using the Early Warning System. If evacuation is recommended, it is estimated that the 67 1 /2 ° sector can be evacuated within 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Evacuation zones , routes, and relocation centers have been established in the event that an evacuation is recommended.

This information is published in brochures and distributed by the State. Population distribution and evacuation time estimates are maintained on file by the Nuclear Emergency Preparedness Department (reference Appendix 10.8) and are summarized in Tables 6.2 and 6.3. Written pre-planned messages intended for transmittal to the public via radio and television stations will be consistent with the classification scheme. They will be released to the media by the State Coordinator of Emergency Management or Local Coordinator of Emergency Services or his designated representative.

The messages will give instruction with regard to specific actions to be taken by the occupants of the inhabited area. The messages will , as appropriate , give instruction on the aspects of sheltering , thyroid blocking , evacuation , the nature of the emergency , and recommended protective actions. The local governments are charged by the COVEOP with the responsibility to conduct information programs to educate their citizens on: 1. Radiological hazards , 2. Procedures for notification of a radiological emergency, 3. Evacuation routes and assembly points , and 4. Other protective measures. The COVEOP identifies the methods to be utilized in preventing or minimizing direct or subsequent ingestion exposure to radioactive materials deposited on the ground or other surfaces.

Upon notification of a radiological emergency which may affect livestock , crops , or farmlands , the Virginia Department of Agriculture and Consumer Services will institute a program to assess the impact upon the agriculture community. Members of that department will take samples of milk from dairy cattle in the affected area for analysis and will monitor soil , crops and farm equipment for contamination. Follow-up action includes the disposition of radiologically contaminated materials. The local county government(s) has the prime responsibility for controlling affected area ingress and egress. Assistance from the State Police shall be supplied as requested by local officials.

6.3.2 Onsite

Criteria for the Exclusion Area NAEP Page 6.5 Revision # TBD The area within 5000 feet of the former North Anna Unit 3 containment is defined as the Exclusion Area for the purposes of this Plan. Company employees, supplemental personnel, occasional visitors at the site , and boaters on the reservoir and cooling lagoons may be inside the Exclusion Area. The area immediately surrounding the units which is enclosed by a security fence is defined as the Protected Area. The Station Emergency Manager is responsible for making the decision to evacuate the Protected Area , and will take appropriate measures in cooperation with State and local agencies for evacuation of persons in the Exclus i on Area and those members of the public who may be passing through the site or within Company property. The company will also commit personnel and appropriate equipment (search lights , power amplified loudspeakers) to assist the Virginia Department of Game and Inland Fisheries in clearing the Exclusion Area when required. Visitors to the Protected Area of the station a r e under continuous escort by personnel knowledgeable in emergency personnel accountability procedures. Supplemental personnel are also trained in personnel accountability procedures. Onsite personnel will be immediately notified of an emergency that is initially classified as an Alert or higher event, unless doing so poses a threat to personnel safety. For example, hurricane force winds , a tornado , or a secur i ty breach may dictate suspension or deferral of assembly , accountability and/or initiation of facility staffing. However , these activities would be implemented as quickly as achievable given the specific situation.

Station procedures provide for a range of protective actions to protect onsite personnel during hostile action and ensure continued ability to safely shut down the reactor and perform emergency plan functions. Tho Central Emergency Operations Facility (CEOF) may be activated in lieu of tho LEOF upon a management dooision to do so or if tho readiness of the LEOF is impaired.

Normally , alarms will be sounded and announcements will be made to conduct personnel accountability or , i f necessary , a site evacuation of non-essential workers. Those individuals within the Exclusion Area will be alerted by station personnel , Security , and/or personnel from the Virginia Department of Game and Inland Fisheries.

In the event of an evacuation , radiation monitoring teams will be dispatched to the appropriate Remote Assembly Area. Emergency Assembly Areas have been established outside the Protected Area to facilitate the dissemination of information to personnel.

The Station has the capability to conduct personnel accountability for individuals inside the Protected Area within approximately 30 minutes. After accountability is completed , an evaluat i on is made and search teams may be dispatched to locate any individual noted as missing or unaccounted.

If onsite evacuation is to occur , Security collects only the security key cards , not the dosimetry , of all personnel leaving the Protected Area. Continuous accountability of personnel in the Protected Area not evacuating the site shall be maintained throughout the emergency. Evacuees , who may use personal vehicles , proceed to either the primary or secondary remote assembly area (See Figure 6.6).

N OTE: Exa mpl es of p ro t ec ti ve clot hin g t o be up da t ed t o r e O ec t c u rre nt i n ve n tor i es. T hi s cha n ge i s beyo n d th e sco p e of t h is li ce n se ame ndm e n t r e qu es t. NAEP Page 6.6 Revision # TBD Station evacuees will be surveyed for contamination following events involving a r diological release, and decontaminated , if necessary , prior to being released from the remote assembly rea. Decontamination agents and supplies are available at the station wh i ch can be transported to the re ote assembly areas to provide decontamination capabilities.

6.3.3 Use of Onsite Protective Equipment and Supplies 6.3.3.1 Respiratory Protection The company has a comprehensive respiratory protection program at its uclear stations.

VPAP 2101 , "Radiation Protection Plan" , establishes the Respiratory Protection Program hich is implemented by HP procedures. Those individuals likely to wear respirators are given a pulmonary amination and training on respiratory protection including a practical examination.

A "fit test" is given before an individual is allowed to enter an area requiring respiratory protection. 6.3.3.2 Protective Clothing The station maintains an adequate inventory of protective clothing in the Clean Change Room. Contaminated clothing is washed at the station and re-issued provided contaminati n is below established radiation criteria. A Radiation Work Permit system is utilized whereby Radiologica Protection establishes personnel protective clothing and equipment criteria.

Such clothing may consist of cotton coveralls , hoods , cotton glove inserts , rubber gloves , plastic shoe covers , rubber shoe covers and rubber boots. Station personnel requiring access to a Radiological Control Area are given training on how to don and remove protective clothing so as to minimize personal contamination or introduction of contamination into adjacent areas. 6.3.3.3 Thyroid Blocking Agent The process for administering a thyroid blocking agent in a potential radioiodine inhalation situation was authorized by the company's employee health services staff in consultation with its medical support staff. 6.4 AID TO AFFECTED PERSONNEL The Company has made arrangements with the Virginia Commonwealth University Medical Center (VCUMC), to provide medical assistance to personnel injured or exposed to radiation and/or radioactive material.

VCUMC has developed its own plan for responding to the emergency. VCUMC's plan establishes a specialized area of the hospital for treatment with appropriate Health Phys i cs functions , and implements a coded system to alert hospital team members. Radiation monitoring equipment, dosimetry , and protective clothing are available at VCUMC. The Station will provide and distribute self reading and cumulative type dosimeters to all personnel involved in emergency onsite response regardless of their affiliation. Dose records shall be maintained and checked throughout the emergency. 6.4.1 Emergency Exposure Limits Emergency response personnel may, because of necessity , receive once-in-a-lifetime exposure to contamination and radiation up to the 1 OCFR20 annual limits , not including accumulated occupational exposure. Approval from the Station Emergency Manager is necessary for planned exposures greater than NAEP Page 6.7 Revision # TBD the 1 OCFR20 annual limits. Under limited circumstances, exposure levels greater than 5 times the 1 OCFR20 annual limits are allowed, but only on a voluntary basis to persons fully aware of the risks involved.

Selection criteria for volunteer emergency workers includes consideration of those who are in good physical health, are familiar with the consequences of emergency exposure , and are not a "declared pregnant adult". It is preferable, though not mandatory , that volunteers be older than 45 years of age and not be a female capable of reproduction. Emergency exposure may be authorized for such needs as removal of injured personnel , undertaking corrective actions , performing assessment actions , providing first aid , performing personnel decontamination , providing ambulance service, providing medical treatment, etc. Guidelines for emergency exposure limits , including life saving actions, are consistent with EPA Emergency Worker and Life Saving Activity Protective Action Guides. 6.4.2 Decontamination and First Aid There are First Aid stations located throughout the North Anna Power Station that contain the normal complement of first aid supplies and equipment necessary to treat those injuries not involving hospitalization or professional medical services.

At least two First Aid Team members are available at all times to respond to personnel injury. As a minimum, the First Aid Team personnel are Multi-Media first aid trained. In addition, the following Medical facilities and services are available: 1. Company nurse available during normal working hours (Mon. -Fri.). 2. Company ambulance. 3. Company designated physicians in the area. 4. Local Rescue Squads. 5. The Virginia Commonwealth University Medical Center facilities.

Actions are required to be taken when levels of radioactive contamination for workers , equipment or areas exceed 1 , 000 dpm / 100 square centimeters of removable contamination.

Any detected personnel contamination will initiate appropriate evaluation and decontamination. The Station controls access for onsite contamination and the return of these areas and their contents to normal use. No food supplies are grown on the site and the water supplies come from deep wells. Areas designated permissible for employees to eat and drink during the emergency and recovery phases of operations are monitored for contamination.

If onsite personnel are required to relocate or routinely leave the site during an emer!Jency, the Station will provide adequate supplies for personnel decontamination , clothing and means to provide for decontaminating the clothing. If radioiodine contamination of the skin is determined , provisions will be made to provide for decontamination.

NAEP Page 6.8 Revision # TBD Monitoring of vehicles and personnel will be performed at the Remote Assembly Areas (RM). Should decontamination of vehicles or personnel be warranted , Health Physics personnel can perform the task at the Station , the RM , or if necessary , at Patrick Henry High School in Hanover County. 6.4.3 Medical Transportation A Station ambulance is available to transport contaminated injured personnel.

Contaminated injured personnel will be suitably clothed or prepared to prevent the spread of contamination in the transporting vehicle. Communication can be maintained w i th VCUMC from the station. The Station can also communicate with the ambulance by use of a UHF radio , and the ambulance can communicate with VCUMC by way of the HEAR system. In addition , arrangements have been made with local volunteer rescue squads to transport injured contaminated personnel to the Virginia Commonwealth University Medical Center. Response team members have received training concerning transportation of contaminated injured individuals. A Health Physics technician , with appropriate instrumentation , would normally accompany contaminated injured personnel to VCUMC. The approximate time to transport a patient to VCUMC is 75 minutes. The estimated time for local rescue squads to arrive at the station is 30 minutes. 6.4.4 Medical Treatment The MCVHNCU-Dominion Power Radiation Emergency Plan (Appendix 10.9) provides guidance for the treatment of contaminated injured personnel by qualified individuals. The Radiation Emergency Plan includes provisions to request assistance from other facilities having the capability to receive and treat injured and/or contaminated individuals.

In the event the facilities at VCUMC become over extended , VCUMC may coordinate further assistance with these facilities directly or through the Virginia Department of Health. 6.5 OFFSITE SUPPORT In addition to the offs i te agencies listed above , local volunteer fire departments have agreed to assist in fighting fires. A list of services and equipment is included in the Agreement Letters referenced in Appendix 10.1. The response time of these volunteer fire departments varies from 30 minutes to 45 minutes , unless adverse weather conditions prevail. Police support for an emergency is provided by State and local governments as detailed in their respective Emergency Plans.

TABLE 6.1 NAEP Page 6.9 Revis i on # TBD RADIONUCLIDES WITH SIGNIFICANT CONTRIBUTION TO DOMINANT EXPOSURE MODEs<1> Radionuclides with Significant Contribution to Thyro i d Exposure Half life Radionucl i de .(Qfil'.fil 1-131 8.05 1-132 0.0958 1-133 0.875 1-134 0.0366 1-135 0.280 Te-132 3.25 (1) Der i ved from NU REG 065 4 Radionuclides with Significant Contributio n to TEDE Exposure Half l if e Rad i onuclide {days) 1-131 8.05 Te-132 3.25 Xe-133 5.28 1-133 0.875 Xe-135 0.384 1-135 0.280 Cs-1 34 750 Kr-88 0.117 Cs-137 11 , 000 Radionuclides with Significant Contribut i on to Lung Exposure (Lung only controlling when thyro i d dose is reduced by iodine blocking o r there is a long delay prior to releases)

Half Life Radionucl i de {days) 1-131 8.05 1-132 0.0958 1-133 0.875 1-134 0.0366 1-135 0.280 Cs-134 750 Kr-88 0.1 17 Cs-13 7 11 , 000 Ru-106 365 Te-132 3.25 Ce-144 284 NAEP Page 6.10 Revision # TBD NORTH ANNA POPULATION DISTRIBUTION AND EVACUATION TIME ESTIMATES (In hours and minutes) TABLE 6.2 Region 1 Region 2 Region 3 Scenario 2mile 5 mile 10 mile EPZ EPZ EPZ Summer Midweek Mid-day Good Weather 2: 30 2: 30 2: 35 Summer Midweek Mid-day Rain 2: 30 2: 30 2: 40 Summer Weekend Mid-day Good Weather 1 : 45 1 : 45 2:00 Summer Weekend Mid-day Rain 1 : 50 1 : 50 2: 00 Summer Evening Good Weather 1 : 50 1 :50 1 :55 Winter Midweek Mid-day Good Weather 2: 30 2: 30 2:40 Winter Midweek Mid-day Rain 2: 30 2: 35 2:40 Winter Midweek Mid-day Snow 3:20 3:25 3: 30 Winter Weekend Mid-day Good Weather 1 : 50 1 :50 2: 00 Winter Weekend Mid-day Rain 1 : 50 1 : 50 2: 00 Winter Weekend Mid-day Snow 2: 50 2: 55 3: 05 Winter Evening Good Weather 1 : 50 1 : 55 2:00 Winter Weekend Mid-day Special Event 1 : 50 1 : 50 2:00 Winter Weekend Mid-day Road Impacted 2: 30 2: 30 2:35 Region 1 Region 2 Region 3 Total Population Evacuated 2 mile Smile 10 mile EPZ EPZ EPZ 2 , 969 13 , 705 46 , 186 Information summarized above derived from KLD Eng i neering , P.C. Evacuation Time Estimates for the North Anna Power Station and Surrounding Jurisdictions dated November 2012 (Figure 3-2 , Permanent Resident Population by Sector , and Figure 3-13 , Transient Population by Sector Table 5) and Table 3-7 , Summary of Population Demand. Total population evacuated represents the total population loaded onto the netwo r k during the 14 simulations listed and evacuation time est i mates were calculated based on when approximately 90% of that population has ex i ted the 10-mile radius. A region i s a grouping of contiguous Protective Action Zones (PAZ) evacuated in response to a radiological emergency A scenario is a combination of ci r cumstances , includ i ng time of day , day of week , season , and weather conditions. Scenarios define the number of people in each of the affected population groups and their respective mobilizat i on time distributions.

NORTH ANNA POWER STATION POPULA TIO N DATA BY SECTOR TABLE 6.3 Direction/Sector Population 2-Mile Ring 5-Mile Ring Direction:

North Permanent Resident 76 367 Sector: A Transient 0 159 Direction:

North Northeast Permanent Resident 21 282 Sector: B Transient 150 35 Direction:

Northeast Permanent Resident 12 142 Sector: C Transient 0 0 Direction: East Northeast Permanent Resident 0 163 Sector: D Transient 0 0 Direction: East Permanent Resident 63 263 Sector: E Transient 0 58 Direction: East Southeast Permanent Resident 20 378 Sector: F Transient 0 0 Direction:

Southeast Permanent Resident 29 231 Sector: G Transient 0 0 Direction: South Southeast Permanent Resident 64 341 Sector: H Transient 0 0 Direction: South Permanent Resident 92 261 Sector: J Transient 0 0 Direction: South Southwest Permanent Resident 39 128 Sector: K Transient 0 0 Direction:

Southwest Permanent Resident 11 220 Sector: L Transient 0 0 Direction:

West Southwest Permanent Resident 12 142 Sector: M Transient 0 0 Direction:

West Permanent Resident 149 188 Sector: N Transient 0 0 Direction:

West Northwest Permanent Resident 41 546 Sector: P Transient 0 0 Direction:

Northwest Permanent Resident 0 405 Sector: Q Transient 0 390 Direction: North Northwest Permanent Resident 58 161 Sector: R Transient 0 2383 NAEP Page 6.11 Revision # TBD 10-Mile Ring 1181 0 1305 0 1678 0 1720 0 1258 0 1064 0 931 0 1184 0 1714 0 861 0 1598 0 1683 0 750 0 812 2000 1429 98 980 0 22.5° conical sectors are designated by compass direction point outward from the plant on the centerl i ne of the sector , e.g., sector from 348. 75° to 11.25° is designated as Direction: North. Sectors are designated by letter beginning with A for North and where the remaining 15 sectors are designated in a clockwise direction by the subsequent letter , excluding I and 0. Rings are defined as the area between circles of radius O and 2 miles, 2 and 5 miles, and 5 and 10 miles. Information summarized above derived from KLD Engineering , P.C. Evacuation Time Estimates for the North Anna Power Station and Surrounding Jurisdictions dated November 2012 (Figure 3-2 , Permanent Resident Population by Sector , and Figure 3-13. Table 5 , Transient Population by Sector).

NAEP Page 6.12 Revision # T BD Figure 6.1 REPORT OF EMERGENCY TO STATE AND LOCAL GOVERNMENTS R OE MESSAGE# ----APPROVAL:---------------(Station Emergency Manager or Recovery Manager) ATTENTION ALL STATIONS. Tois is North Anna Power station. Standby for a (n) 0 Dri ll Message D Eme r gency Message D Drill Term i nation Message D Emergency Term i nat i on Message. Use the Report o f Emergency form to copy message. (READ S L OWLY) Item 1. EMERGENCY CLASSIFICATION

0 NOUE 0 Alert D Site Area Emergency D Genera l Emergency In .iccord.ince w i th EAL --------Declared at {2 4..flr fime) on {date). This is (name} / Emergency Commun i cato r. P lease aeknowledge rece i pt o r t his message: (Conduct ro ll-ca ll .ind check bo x es as e.ich p.irty .inswers.) D VA E OC D Lou i sa cou n ty D Spotsy l van i a County D Hanover County 0 Orange County D caroline County N otification comple t ed at (24-hr time) on (date). Item 2. METEOROLOGICAL DATA: Based on: D On-si te Measurements 0 Off-site l'v 1easurements D Not Ava i l able llme: AVE Wind Speed mph; A VE Wmd Directlon from degrees (o* to 360°) {24-nrtJme)

Item 3. RELEASE OF RADIOACTIVE MATERIA L: Routine r eleases ongoing due to pla nt operations. Additional rad i olog i cal releases associated w it h the even t D A. No rad i ological release. Will N OT transmit Report of Radiological Conditions to Virginia E OC. D B. Radiolog i cal release in progress. Will transmit Report or Rad iologi cal COOOitions to Virginia E OC. D C. Rad l ological release now terminated. Will transmit Report of Radiolog i cal Condltlons to Vi r g i n i a EOC. D D. Ra d iotog l cat release projected t o occur. Will t ransmit Report or Radiological conditions t o Virginia E OC. Item 4. SITE ACCESS: D Ava il able D N o t Al/affable Item 5. PROTECTIVE ACTION RECOMMENDATION

0 is NOT l8Qlli r ed 0 *11 be uansm i tted to V EOC O has been tra nsm i tted to VEOC. Item 6. UPDATE SCHEDULE: 0 60 minutes (recommended

); 0 Other : EOC Watch Officer: NOTE: Items 7 -11 op t iona l for message reporting initia l E mef9ency Plan ent,y , emergency classification change oc PAR changes a n d 'Excluded from message* may be checked. " It e m s 7 -11 are exclude d fr om mess ag e" ma y be r ead i n l i eu of read i ng e a ch item. Item 7. EMERGENCY RESPONSE ACTIONS UNDERWAY: ' D Excluded from message 0None D station emergency personnel ca ll ed in 0 station mon it oring t eams d i spatched off-site D other Item 8. EVACUATION OR COMPANY DISMISSAL OF SITE PERSONNEL: D Excluded from message DN o D Evacuation t o Prim.iry Reroot e Assembly Area: 0 Planned D In progress D Comp leted O Released from RAA 0 Evacuation to Secondary Re mot e Assembly Area: D Planned D In progress D Comp leted D Released from RAA 0 Company Dismissal: O Planned D In progress D Comp l eted D Otner I tem 9. PROGNOSIS OF S I TUATION S I NCE LAST REPORT: D Exduded from message D Stable D Worsen i ng D Improving D ot11er Item 10. ASSISTANCE REQUESTED OR BEING PROVIDED: D Exduded from message ON one ___ (#) Fire Un i ts from ___ (#)Pol i ce Units from (#) R escue Units from (#)Other Item 11. ADDITIONAL INFORMATION (Do not use .ibbrev i.it l ons , m.ir k numbers or .icronyms.): 0 Excluded from message Tols I s Nortn Anna Power St ati on ou1 at (24-n r time) on (date). Item 12. TERMINATION INFORMATION (Complete ONLY tor termin.ition message): Even t T erm i nated a t (24-hr time) on (date). P lease acknowledge rece l pt o r th i s message: (Conduct roll-call .ind check boxes as e.ich party .inswers.) 0 VA E OC O L o u isa County D Spotsylva n i a County D Hanover County D Orange County D Carol i ne County Tois is North A nna Powe r Station out at 24-hr time on date .

Figure 6.2 Protective Action Recommend.ttion PROTECTIVE ACTION RECOMMENDATION

NAEP Page 6.13 Revision # TBD D SHELTER-I N-PLACE: __ M i le radius 360° and __ M i l es downw i nd i n the follow i ng sectors: D EVACUATE: __ Mile rad i us 360° and __ Miles downwind i n the following sectors: D BE YO ND 10 M IL E EPZ: D Evacuate Area: __ Centerline i n degrees; __ D i stance in Miles; __ Width i n feet D Shelter-in-place

__ Ce n te rl ine i n degrees; __ Distance in M i les; __ W i dth in feet D POTASSIUM IODIDE: Recommend Implementation of Potass i um Iodide (Kl) strateg i es for the general public. The pro ected dose a t the site boundary is~ 5 Rem Thyroid COE. The time is ______ (24-hr time). Message rece* ed by: Virgin i a EOC Watch Officer (name) _______________

_

F'agure 6.3 Radiological Status Form GD.MIDAS Method (circle one): M o njtor Ru d ing Plume Correlation A. rtfiDAS PROJECTION:

.--2Mla 411am' DIZ4"6w .. . rm .mm PAO Dea Thy C OE , teD1. ffll'l, I mn .. C URRENT iTEOB *ttilillit J'emfhr rem/hr OOSE niyetm rem/hr tc" ZNlt t RA'l'E , m)J3 ti:m!irt" n-.mihr RATIO TE1J e!O'OE at oeak OD E PLUME ARRJVAL f rom un o r release X/Q sec/m3 se c/mJ sec/nu Distance to which 4-hour TEDE exceeds I rem: Miles Distance to which 4-hour Thyroid DE exceed s 5 rem: * *1 % of Technical Specification

(B a Scd on S it e Bo u nd"')' Dose lut es) Remarks: B. RELEASE D E CRIPT I ON: Site: Reactor Shutdown Time: NAEP Page 6.14 Revis i on # TBD Ptq>affd Rcvi.cwcd b,y: -----Dala'Iims:

_____ _ .. ,_ _____ _ What-If (Hypot h etical) SMDa 10 11.Dm am nm rem te,m .mrt/hr* f¢1Mlt mrJhr :r.em!hr :remlh r . --Se<" J m J se d m3 ---lo ofTS for Thy DE Start of Release Time: h u i nce .Rea c tor shutdown Remaining Release Duration (I: Total Relea e Durati o n (hr) Pathway: GROUND P R OC V T TEA 1 VE TVNT TOTAL Plume Height (ft): Percent of Plume on Ground: Noble Gas Release Rate (C i/sec): cc) .Partlw iate Rel ease Rat )! C. METEOROLOGI AL CONDITIONS:

Time Period: Stability Class (PG A-0): ~Temt, (-..-F~ Pw,~(m/15-.):

F igure 6.4 R A D I O L OG ICAL S TATU S NAEP Page 6.15 Revision # TBD Comple t e based o n in f ormatio n av ailable wh e n f orm prepared.

Report tt ------Prepared by:-------A. U m/Re l ease Status: Site: North Anna A1fected Unit (s)/Area: 1; 2; LSFSI Unit 1: Power ___ %; ReactorShuk!ownDate

/Time: ____ -----Unit 2: Power %; Reactor Shuk!own Date /T ime: ________ ..., ON/A ON/A Release i n progress: o No; Unit 1 , Date I Ti me Release S t arnd: ____ I ____ _ o No; Unit 2, Date/ Ti me Release Stari!d: ___ / ____ _ D No; Other , -----Date I Time:_ --Release Patlway: _______ ; o Unkoown Release Dll'alk. '~ , . __ . Unknown Release Pattway: ; o Unknown Release O tS ation \

• o Unknown B. Meteorological Conditions asof ____ (24-hrtime) A erage Lower Wind <irection is f rom __ degre~ "' ,o*) Average Lower ind Speed is ____ ~; D<Mir oo Sect. A erage Upper 1nd <irec ion is from__ ")ree:. * ..J 360") Average Upper Wind Speed is ____

• Do. Yind Seci>r is ___ _ Stlb il lty Class is --~ ~m!jen *en,, *ature i s ____ deg r ees F Precipitation

D None; 0 Rain~ D S t, '* u '

• DO her ______ _ C. Radiological Conditions base o,. :t>l e a~

• O On-silestntey results indic._ ___ .arn.tirat

___________ (l ocation. Additiona l infol'Tl'-

• -... will be * ,idedwhen ava l able. O Off-site s1.Cvr results in,.*rate _ __ rem rat ___________ l ocation). A<Xlitiooa J ir , rm.i .-1111 .., pn. ,ided when avai l able. o No survey i nfonnation , ext , ia l exposure es imates , dosimelly infa-ma io n o r any liher rad i olog i cal in forrr ** -..1va l lable. o ______________________________ _ D. Remarks: ------------------------

---

Reviewed by:--------------.Radologca l Assessment Direcior or Raciological Assessmen Coord i na a Date/ n me FIGURE 6.5 NORTH ANNA POWER STATION 10 -MILE EMERGENCY PLANNING ZONE (EPZ) NAEP Page 6.16 Revision # TBD FIGURE 6.6 Rt 700 I Mineral! NORTH ANNA POWER STATION REMOTE ASSEMBL V AREAS NAPS Primary Remote Assembly Area North Anna Dam: Secondary Remote

• Assembly Area .... :a NAEP Page 6.17 Revision # TBD Graphics N o. S B 1212B PRIMARY REMOTE ASSEMBLY AREA: PROCEED TO INTERSECTION OF RT. 700 AND 618. TURN RIGHT ON RT. 618 AND PROCEED 0.3 M I LES TO RT. 70 0 AND TURN LEFT. PROCEED 1.3 MILES AND TURN LEFT ON SACRED HEART AVENUE. PROCEED 0.5 MILES TO THE ANIMAL SHELTER ACCESS ROAD ON THE R I GHT. TURN RIG H T. THE E NTRANC E TO THE ASSEMBLY AREA (LOUISA FIRE TRAINING CENTER) IS ON THE LEFT. SECONDARY REMOTE ASSEMB L Y AREA: PROCEED TO INTERSECTION OF RT. 700 AND 652. TURN LEFT ON RT. 652 AND PROCEED TO RT. 622. TURN LEFT ON RT. 622 AND PROCEED TO RT. 701. TURN L EFT ON RT. 701 AND PROCEED TO R T. 601. TURN LEFT ON RT. 601 AND PROCEED 0.1 MILES. THE ASS EMBL Y AREA IS ON THE LEFT , THROUGH THE GATE , AT THE DAM.

Part 7.0 7.1 7.1.1 7.1.2 7.1.3 7.1.4 7.1.e.§. 7.1.-7§. 7.1.7 7.2 7.2.1 7.2.1.1 7.2.1.2 7.2.1.3 7.2.1.4 7.2.2 7.2.2.1 7.2.2.2 7.2.2.3 7.2.2.4 7.2.2.5 7.2.3 7.2.4 NORTH ANNA POWER STATION EMERGENCY PLA N SECT ION 7 EME RGE NCY F A C I LITIES A N D EQU IP MENT Subject Emergency Facilities and Equipment Emergency Response Facilities Control Room Operational Support Center Technical Support Center hooai-Corporate Emergency Operations FacilityResponse Center Corporate Emorgoncy Rosponso Cantor and Central Emergency Operations Facility Joint Information Center and Local Media Center Alternate Facility When Under Threat or Experiencing Hostile Action Near-Site Location For Offsite AgencJ'. Coordinat i on Communications Systems Communications Systems With i n the Station Public Address and In t ercom System Radio Communicati o ns System (Onsite) Private Branch Telephone Exchange (PBX) Sound Powered Telephone System Offsite Communications Systems Commercial Telephone Synchronous Optica l Network (SONET) Ring Radio Communications System (Offsite)

Dedicated N RC Communications lnsta-phone Loop Communications System Reliability Emergency Response Facility Communications NAEP Page 7.1 Revision # TBD Page No. 7.3 7.3 7.3 7.3 7.3 7.4 M 7.4 7.5 7.5 7.5 7.5 7.5 7.5 7.5 7.6 7.6 7.6 7.6 7.6 7.6 7.7 7.7 7.7 Part 7.3 7.3.1 7.3.2 7.3.3 7.3.4 7.3.5 7.3.6 7.4 7.5 7.6 Table 7.1 Table 7.2 Figure 7.1 Figure 7.2 Subject Assessment Facilities Available Onsite Seismic Monitoring Radiological Monitoring Meteorological Monitoring Plant Process Parameter Monitoring Fire Detection Post Accident Sampling Assessment Facilities Available Offsite Damage Control Equipment and Supplies Early Warning System ERF Communications Meteorological Monitoring System Parameters Environmental Monitoring Locations Map Environmental Monitoring Locations Listing NAEP Page 7.2 Revision # TBD Page No. 7.7 7.7 7.8 7.9 7.9 7.9 7.10 7.10 7.10 7.10 7.12 7.14 7.15 7.16

7.0 EMERGENCY

FACILITIES AND EQUIPMENT NAEP Page 7.3 Revision # TBD The facilities required in the implementation of the Emergency Plan consist of the Control Room (shared for both Unit 1 and 2), the Operational Support Center (OSC), the Technical Support Center (TSC), the Local Emergency Operations Facility (LEOF), and the Corporate Emergency Response Center (CERC) and tho Central Emergency Operations Facility (CEOF). These facilities were designed to meet the intent of the guidance in NUREG-0696 and the clarification in NUREG-0737 Supplement

1. In addition , a Joint Information Center (JIG) and a Local Media Center (LMC) are required for the implementation of the Emergenc y Plan. A description of each i s given below. 7.1 EMERGENCY RESPONSE FACILITIES

7.1.1 Control

Room The Control Room of the affected unit(s) shall be the initial location for command and control of the emergency response effort. All controls and instrumentation needed to diagnose plant conditions and to take immediate actions to place the affected unit(s) in a safe condition are available in the Control Room. Within the Control Room , the Station Emergency Manager has access to the information needed to classify the emergency. Redundant communication systems are also available in the Control Room to make the required onsite and offsite notifications. The Control Room has the required shielding and ventilation system to remain habitable during the emergency.

Access to the Control Room shall be limited to those individuals responsible for carrying out assigned emergency response tasks plus other technical advisors , as necessary.

7.1.2 Operational

Support Center The Work Control Center is designated as the Operational Support Center (OSC). The OSC is not designed to remain habitable under all projected emergency conditions

however , implementing procedures make provisions for relocating the OSC as needed, based on ongoing assessments of plant conditions and facility habitability.

The Maintenance Building , 3rd Floor , and the Unit One Emergency Switchgear Room are designated as Alternate OSCs. Augmenting Station operations personnel will report to the primary OSC until instructed by the Shift Manager/SEM to perform a required emergency function. The OSC is also the designated reporting location for the Fire Brigade , the First Aid Team , the Damage Control Team , and the Search and Rescue Team. 7.1.3 Technical Support Center The Technical Support Center is located adjacent to Unit 1 Control Room , and its alternate location is the Control Room. Emergency response personnel will assemble at the primary TSC unless otherwise instructed by the Station Emergency Manage r. The primary loca tion contains controlled copies of selected manuals , procedures , drawings , and other documents as approved by the Facility Safety Review Committee.

Information about plant conditions is available via real time data displays from the Plant Computer System (PCS). Dedicated phone line communications would also be established with the Control Room to keep TSC personnel knowledgeable on current operating evolutions and to provide consultation and recommendations to the Control Room staff.

NAEP Page 7.4 Revision # TBD The construction of the facility walls and design of the ventilation system are such that the whole body and thyroid doses received by occupants of the TSC are below General Design Criteria 19 limits. Radiation monitoring equipment for making airborne particulate and direct radiation measurements is installed in the TSC. 7.1.4 M>Gal-Corporate Emergency Operations Response Fasilit\'Center The station's Local Emergency Operations FacilityCERC is the consolidated emergency operations facility (EOF) for North Anna Power Station and Surry Power Station. The CERC is located at the Innsbrook Technical Center in Glen Allen, Virginia. adjacent to tho ~JAPS Training Facility. The LEOF is located within the Exclusion Area and includes designated The facility provides work stations 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 PCS. The Meteorological Information and Dose Assessment System (MIDAS) is used to estimate offsite doses. The LEOF was designed to provide a specified protection factor from gamma radiation.

The facility also has a specially designed ventilation system to limit tho exposure of its occupants and further assure its availability during an omergoncy.

Radiation monitoring equipment for making airborne particulate and direct radiation measurements is installed in tho LEOF. Should the LEOF becomo unavailable during an emergency the responsibilities assigned to the LEOF will be transferred to the backup facility known as tho Central Emergency Operations Facility.

Situations with the potential to affect both Surry and North Anna may warrant transfer of the responsibilities assigned to tho LEOF to tho CEOF. 7.1.5 Corporate emergens\'

Response Center and Central emergens\'

Operations Facility Space is designated for the Corporate Emergency Response Center (CERC) and tho Central Emergency Operations Facility (CEOF) at tho Innsbrook Technical Center in Glen Allen , Virginia. Tho facility will be manned by members of tho Corporate Emergency Response Team as defined in the Corporate Emergency Response Plan. Plant data is a>,iailable from the PCS. 7.1.6-5 Joint Information Center and Local Media Center Official company statements to the media will be made from Joint Information Center (JIC) by the Chief Technical Spokesperson. The primary JIC is located at the Virginia State Police Administrative Headquarters in Chesterfield , Virginia.

These company statements are prepared by members of tho Corporate Emergency Response Team as defined in the Corporate Emorgoncy Response Planat the CERC. A Local Media Center (LMC) may be activated as an adjunct to the JIC. The Local Media Center for North Anna Power Station is located at the end of Route 700 on company property.

The facil i ty is designated as the North Anna Nuclear Information Center in normal operation. There are dedicated rooms for Dominion , NRC , FEMA , State , and media representatives as well as an auditorium that will accommodate 200 people. Provisions have been made to accommodate TV cameras , copying machines , typewriters , and other equipment needed for press conferences. Should the Local Media Center become NAEP Page 7.5 Revision # TBD uninhabitable , small groups of the Media , no more than 20 , can be accommodated in the ~CERC with the approval of the Recovery Corporate Response Manager. 7 .1.-7-6 Alternate Facility When Under Threat or Experiencing Hostile Action The Louisa Fire Training Center functions as a staging area for augmentation of emergency response staff if the site is under threat of or experiencing hostile action. This location has the capability to communicate with the omorgoncy operations facilityCERC , control room , and plant security.

The~ which will be activated in lieu of tho LEOf= under those oonditions

, CERC has the capability to perform offsite notifications.

The staff at the staging area , working with CERC organization , provides capability for engineering assessment activities , including damage control team planning and preparation. 7.1.7 Near-Site Location For Offsite Agency Coordination The North Anna Nuclear Information Center is the location for the NRG and other offsite agency staff to interact face-to-face with emergency response personnel enter i ng 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 contact lists, computers with internet access, access to a copier and office supplies , and access to plant radiological information.

These provisions exist because the CERC is located more than 25 miles from the TSC. 7.2 COMMUNICATIONS SYSTEMS The station communications system is designed to provide redundant means to communicate with all essent i al areas of the station associated with North Anna Units 1 and 2 and to essential locations remote from the station during normal operation and under accident conditions.

Communication systems vital to Units 1 and 2 operation and safety are designed so that failure of one component would not impair the reliability of the total communications system. This is accomplished within the Station by using diverse systems and designated personne l. 7.2.1 Communications Systems Within the Station The systems wh i ch provide for communications within the Station are discussed below. 7 .2.1.1 Public Address and Intercom System A five channel public address and intercom system (Gai-Tronics System) is installed in the Station. The system power is supplied from a power supply which will maintain the system in an operational condition in the event of a normal station service power failure. Zones are provided with i n that Station to insure operability of a major portion of the system should equipment in a z one become inoperative. Loudspeaker and paging phone stations are located throughout the Station. The coverage of the loudspeakers permits broadcasts to be heard throughout the station. A visual indicator has been installed in those areas where evaluation of N RC Bullet i n 79-18 , Audibility Problems Encountered on Evacuation of Personnel from High-Noise Areas , identified noise levels which might exceed the volume of the loudspeakers. In the event of an emergency , the system is used to alert Station personnel of any emergency situation and to direct emergency response act i ons required of on-site personnel.

7.2.1.2 Radio Communications System (Onsite) NAEP Page 7.6 Revision # TBD An Ultra-High Frequency (UHF) two-way radio trunking system is provided at the Station consisting of base stations/repeaters , mobile units installed in emergency vehicles , and hand-held portable radios. The radio trunking system provides redundancy and independent emergency backup equipment for designated station functions.

7.2.1.3 Private Branch Telephone Exchange (PBX) A Private Branch Telephone Exchange (PBX) is installed at the Station. The PBX switching equipment is physically located in the PBX Building and is connected to a commercial telephone exchange in Mineral , Virginia.

Backup battery power is provided to maintain the system operable 6 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following the loss of A.G. power. 7.2.1.4 Sound Powered Telephone System A sound powered telephone communications system is installed which serves North Anna Units 1 and 2. This system is a mult i ple channel system connecting selected operating areas of the plant. Headsets consisting of an earphone and microphone are connected to a two wire channel for direct communication between pe r sons in different areas. Operation of this system is not dependent on the availab i lity of the electrical power system. During an emergency , the system would provide an alternate means of relaying messages.

7.2.2 Offsite

Communications Systems Those systems provided for communication between the Station and offsite are described below: 7.2.2.1 Commercial Telephone Commercial telephone lines are provided between the Station and a commercial telephone exchange in Mineral , Virginia. These lines are connected into the Station PBX. In addition , lines are provided for communications between the Station and the commercial telephone network which are independent of the Station PBX. 7.2.2.2 Synchronous Optical Network (SONET) Ring The SONET ring p r ovides Wide Area Network (WAN) connectivity , voice/Automatic Ring Down (ARD) phone and radio control circuits between station emergency response facilities and the GER~. and the Commonwealth of Virginia Emergency Operations Center (VEOC). The VEOC is linked to the SONET r ing via a dedicated m i crowave facility.

The SONET ring and associated microwave facility provide the communication link from the VEOC to the Early Warning System (EWS) transmitter located at North Anna. The SONET ring and associated microwave facility are DC powered with either battery back up or generator back up a t each location for extended operation upon loss of AC power. 7.2.2.3 Radio Communications System (Offsite)

The same UHF two-way radio trunking system that provides onsite communications also provides for communications within a ten mile radius of the Station. During an emergency , this system will allow direct contact with Radiation Mon i toring Teams , Security vehicles , and a separate channel (Talk Group) between the Security Central Alarm Station and the Louisa County Sheriff's Department.

NO TE: R e pl ace m e nt o f r e f e r e n ces t o a m o d e m with a v irtu a l pri va t e n e t work i s b e y o nd th e sco p e of thi s li ce n se a m e ndm e n t r e qu es t. 7.2.2.4 Dedicated NRC Communications Separate telephone lines are dedicated to the NRC and include the following: NAEP Page 7.7 Revision # TBD

• Emergency Notification System (ENS): The ENS is the system on which initial noti ications , as well as ongoing information about plant systems , status and parameters, are provided to t e NRC. ENS lines are located in the Control Room , TSC and ~CERC.

• Health Physics Network (HPN): Provides for communications regarding radiological and meteorological conditions, assessments , trends , and protective measures.

HPN lines are locat d in the TSC and ~CERC.

• Reactor Safety Counterpart Link (RSCL): Allows for internal NRC discussions r garding plant and equipment conditions.

RSCL lines are located in the TSC and ~CERC.

• Protective Measures Counterpart Link (PMCL): Allows for the conduct of internal RC discussions on radiological releases , meteorological conditions , and protective measures.

PMCL ines are located in the TSC and ~CERC.

• Emergency Response Data System (EROS) Channel: Allows transmittal of reactor rametric data from the site to the NRC. EROS data is transmitted from the PCS computer, via modem, to the NRC Operations Center.

• Management Counterpart Link (MCL): This system has been established for internal discussions between the NRC Executive Team Director/members and the NRC Director of Site Operations or licensee management.

MCL lines are located in the TSC and ~CERC.

• Local Area Network (LAN) Access: Provides access to the NRC local area network. Telephone jacks are provided in the TSC and ~CERC for NRC LAN access. 7.2.2.5 lnsta-Phone Loop A County and State Ringdown Loop (lnsta-Phone) has been installed that permits simultaneous telephone-speaker communications from the Station to the Counties of Louisa , Spotsylvania , Orange , Caroline , and Hanover and the VEOC on a 24-hour per day basis. This loop can be activated at the Station from the Control Room , TSC , or ~CERC. 7.2.3 Communications System Reliability A failure of one communication system will not affect the operation of other communications systems at the station. The communications systems within the Station have diverse power supplies. The public address system has an emergency backup , and the sound powered phone system does not rely on any station power system. Since the onsite communication systems normally will be in use , or periodically tested , equipment failure will not go unnoticed. The multiplicity of onsite communications networks ensures the availability of adequate communications.

Equipment for these systems is located in different areas of the Station thus ensuring that an accident in one area of the Station would not incapacitate all communication systems. Failure of normal power supplies will not deprive the station of offsite communication capability since , in most cases , backup power is provided.

Dedicated telephone lines are checked according to specified schedules.

7.2.4 Emergency

Response Facility Communications NAEP Page 7.8 Revision # TBD The communication systems discussed above are used extensively in the Emergency response facilities. A summary of the types of communications is provided in Table 7.1. 7.3 ASSESSMENT FACILITIES AVAILABLE ONSITE A number of instrumentation and monitoring systems are available onsite for emergency assessments. These systems are described below. 7.3.1 Seismic Monitoring The Seismic Monitoring System is designed to detect the occurrence of an earthquake at the North Anna site , to alert the Control Room via panel indications and annunciation, and to provide records of the intensity, duration , and frequency of the earthquake.

Detection devices are located in several locations , including the Unit 1 Containment , Auxiliary Building , and a free-field sensor at the meteorological tower. The system collects information related to the ground motion experienced which is used to promptly determine the response of those structures important to safety to permit comparison of such response with that used as the design basis. 7.3.2 Radiological Monitoring The installed Radiation Monitoring System (RMS) consists of process monitors and area monitors which read out and record in the Control Room. The process system continuously monitors selected lines for radioactive effluents.

The system's function is to warn personnel of increasing radiation levels , to give early warning of a system malfunction, and to record and control discharges of radioactive liquids and gases to the environment.

High range process monitors are installed to provide accurate indication of plant releases during and following an accident.

The flow paths monitored include the ventilation vents, the process vent (part of the Gaseous Waste System), the main steam lines , and the turbine driven auxiliary feedwater pump exhaust. High range area monitors, located inside the containments , are installed to provide additional information on core integrity during and after a design basis accident.

In addition to the fixed radiation monitoring equipment , portable radiation monitoring equipment would be used to perform dose assessments.

The equipment consists of low and high range instruments to measure gamma, alpha, beta, and neutron radiation. This equipment is maintained by the Radiological Protection Department and is used on a routine basis. Portable gamma detection instrument are also dedicated for emergency kit use (See Appendix 10.5). The kits are set aside solely for emergency use and are inventoried and checked for calibration and operability on a quarterly basis. Portable equipment is also available to take low or high volume air samples. Battery operated air samplers can be used to collect low volume samples either onsite or offsite. Silver Zeolite cartridges would be used for sampling radioiodine with a minimum detectable activity capability of 5X1 o-8 microcuries per cc. Silver Zeolite has a low retention efficiency for Xenon and therefore , interference should be minimal. Plastic bags and bottles are available to collect water, soil, foodstuffs or other samples.

NAEP Page 7.9 Revision # TBD Emergency Plan Implementing Procedures provide the methodology for determining the magnitude of a release by three separate and independent methods: (1) using data or samples continuously obtained by the onsite Radiation Monitoring System , (2) using known inventory data for the system(s) affected and (3) obtaining offsite data from air samplers or dosimeters which are continuously in place , or taking radiation surveys and appropriate samples, and using this data to calculate releases. Equipment designated for use in environmental surveillance such as air samplers and thermoluminescent dosimeters (TLDs) is used to obtain offsite data. The radiological monitoring instrumentation and sampling devices used by the station meet the minimum requirements of the NRC Radiological Assessment Branch Technical Position for Environmental Radiological Monitoring Programs.

Two TLDs have been placed in each of the 16 sectors within an approximate 5 mile radius of the station for environmental monitoring. Eight (8) TLDs are located beyond five miles from the station and are used to establish normal background radiation levels. Further details can be found in VPAP-2103N, Offsite Dose Calculation Manual (North Anna). The State also has TLD monitoring points located around the Station used for verification purposes. Dosimetry and air sampler locations within the 10 mile EPZ are shown on Figures 7.1 and 7.2. North Anna maintains fixed laboratory equipment to support sampling analysis and monitoring.

The equipment includes Multichannel Analyzers , proportional counters , a tritium analyzer , and whole body counters; arrangements are maintained for reading TLDs. 7.3.3 Meteorological Monitoring The station's Meteorological Monitoring System provides the capability for predicting atmospheric effluent transport and diffusion. The system consists of a primary and a backup tower , the locations of which were chosen so as to be representative of regional conditions.

Instruments located at these towers provide data to MIDAS via the PCS. The data is also transmitted to the Control Room and to the company's Weather Center. Table 7.2 provides a listing of the parameters measured.

The meteorological equipment was designed to meet the criteria of Regulatory Guide 1.23 , " On Site Meteorological Programs" , dated February 1972. 7.3.4 Plant Process Parameter Monitoring Installed in the Control Room are the necessary instrumentation readouts to assess station status under all conditions. Information is available from meter displays , chart recorders , annunciators , and the plant process computers to assist the operator in contend i ng with accident conditions. In order to support the data acquisitions need of the emergency response facilities , the PCS has been installed.

The PCS provides plant monitoring , data acquisition , and critical plant data in the form of real-time status displays for the purpose of making a rapid evaluation of the reactor plant's safety status. The PCS includes the Safety Parameter Display System (SPDS), Emergency Response Guidelines (ERGs), process and instrument displays , and pressure-temperature plant d i splays. Monitor displays are continuously updated by the computer systems as they collect and process parametric data from the various plant sensors. The PCS host computers are housed in the TSC. These units process inputs from NAEP Page 7.10 Revision # TBD plant sensors and distribute information via the station LAN and corporate Wide Area Network (WAN). The information is available any LAN/WAN-connected PC which has the appropriate software and security level for access, including the Control Room , TSC , -b*GF,-and CERC~. 7.3.5 Fire Detection The Station's Fire Protection System is designed to furnish water and other extinguishing agents with the capability of extinguishing any single or probable combination of simultaneous fires that might occur. Smoke and heat detectors are utilized for fire detection resulting in automatic fire suppression initiation and/or alarming.

These systems are designed in accordance with the standards of the National Fire Protection Association.

7.3.6 Post Accident Sampling A contingency plan , controlled by normal Chemistry procedures , has been developed for obtaining and analyzing highly radioactive samples of reactor coolant , containment sump , and containment atmosphere. (Reference NRC Letter ,

Subject:

North Anna Power Station, Units 1 and 2 -Issuance of Amendments Re: Elimination of Post-Accident Sampling System Requirements , dated December 19 , 2001 , Serial No.01-760) 7.4 ASSESSMENT FACILITIES AVAILABLE OFFSITE The facilities and equipment located at the Surry Power Station may be utilized as applicable during emergency conditions at the North Anna Station. Additional seismic and meteorological data would be available.

Respiratory protection , portable radiation detection instrumentation , and count room and sample analysis facilities would also be made available.

Se i smic data may be obtained from the National Earthquake Information Service. Meteorological data can be obtained from the following sources: DISTANCE FROM LOCATION ORGANIZATION NORTH ANNA (MILES) Chesterfield Wakefield , Virginia Charlottesville Dulles Airport Dominion National Weather Service Federal Aviation Admin i stration National Weather Service 56 82 43 65 The State Health Department has equipped a mobile laboratory with radioassay equipment to respond to radiation emergencies.

This vehicle is equipped with a radio to facilitate coordination between the State and the company's offsite monitoring teams. 7.5 DAMAGE CONTROL EQUIPMENT AND SUPPLIES The Station maintains an adequate inventory of spare parts , equipment and supplies, and could rely on additional equipment and supplies from the Surry Power Station. Such equipment and supplies consist of full face respirators with proper filters or canisters , SCBA respirators , air supplied respirators , silver zeolite cartridges (radioiodine sampling), portable survey instruments , protective clothing and auxiliary apparel , portable sampling equipment , TLDs self-reading dosimeters, count room instrumentation , polyethylene bags NAEP Page?.11 Revision # TBD and bottles , radiation signs and rope , radioactive waste containers , ion-exchange resin (liquid waste processing), portable hand-held 2-way radios, portable lighting equipment , and Company-owned vehicles. This equipment is normally stored either in the Health Physics office and/or warehouse to facilitate transfer to the Operational Support Center as needed. Equipment specifically designated for emergency response is inspected and inventoried at least once a quarter. Portable survey instrumentation is calibrated in accordance with manufacturer's recommendations , and count room instrumentation is calibrated annually (source checked daily). 7 .6 EARLY WARNING SYSTEM The company has installed and is responsible for maintaining and periodically testing an Early Warning System (EWS) consisting of sirens located throughout the 1 O mile EPZ. The purpose of this system is to ensure that essentially 100% of the population w i thin 5 miles of the site can be alerted within 15 minutes and that essentially 100% of the population from 5 to 10 miles from the site who may not have received the initial notification can be alerted within 45 minutes. The Federal Emergency Management Agency (FEMA) has determined that the system satisfies the requirements of NUREG-0654/FEMA-REP

-1 , Revision 1 , and FEMA-REP-10. The state and local governments have ultimate responsibility for warning the public. Should it be necessary , state and local authorities will alert the public within the 10 miles EPZ using alternative methods described in the COVEOP. Members of the public within the ten (10) mile EPZ shall be informed of what actions to take following activation of the EWS sirens. Upon hearing the alert , they have been instructed to turn on their radios or television sets to the Emergency Alert System (EAS) to receive further instructions. Louisa and Spotsylvania counties and the State have 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day capability to activate the EWS system. Messages sent out over the EAS are prepared by VDEM.

TABLE7.1 ERF COMMUNICATIONS Control Room 1. ARD to TSC , OSC , Security , System Operator , VEOC 2. lnsta-phone Loop to State and Country EOCs 3. Station PBX Phones 4. OPX Phone (General Office Network) 5. Radio System 6. NRG Emergency Notification System (ENS) 7. Commercial Phones (Independent of Station PBX) 8. Public Address/Intercom (Gai-tronics)

9. Sound Powered System 10. Emergency Response Data System (EROS) Channel Technical Support Center (TSC) NAEP Page 7.12 Revision # TBD 1. ARD to Control Room , OSC , LEOF/CEOF(CER q , Security , Primary Remote Assembly Area , VEOC 2. lnsta-Phone Loop to State and County EOCs 3. Commercial Phones (Independent of Station PBX) 4. Radio System 5. Station PBX Phones 6. OPX Phone (General Office Network) 7. NRG Emergency Notification System (ENS) 8. Public Address/Intercom (Gai-tronics)

9. Sound Powered System 10. NRG Health Physics Network (HPN) 11. NRG Reactor Safety Counterpart Link (RSCL} 12. NRG Protective Measures Counterpart Link (PMCL) 13. NRG Emergency Response Data System (EROS) Channel 14. NRG Management Counterpart Link (MCL) 15. NRG Local Area Network (LAN) Access Operational Support Center 1. Public Address/Intercom (Gai-Tronics) 2. Station PBX Phone 3. ARD to TSC , Control Room , HP NAEP Page 7.13 Revision # TBD t:eGal--Corporate Emergency Operations FacilityResponse Center (~CERC) 1. ARD to TSC , LMC , CERC ~Jews Room , Primary Romoto Assembly Area.and VEOC , Louisa County , Spotsylvania County 2. lnsta-Phone Loop to State and County EOCs 3. Commercial Phones (Independent of Station PBX) 4. Radio System 5. Station PBX Phones 6. OPX Phone (General Office Network) 7. NRC Emergency Notification System (ENS) 8. NRC Health Physics Network (HPN) 9. NRC Reactor Safety Counterpart Link (RSCL) 10. NRC Protective Measures Counterpart Link (PMCL) 11. NRC Management Counterpart Link (MCL) 12. NRC Local Area Network (LAN) Access Corporate Emergency Response Center (CERC) 1. 2. d 4. OPX Phone (Station PBX) CEOF ARD to TSC lnsta Phone Loop to State and County EOCs General Office Network Phones Local Media Center (Located in North Anna Nuclear Information Center) 1. Commercial Phones (Independent of Station PBX) 2. ARD to -L-*GF-, CERC News Room

• 3. NANIC PBX Phones 4. OPX Phones (Station PBX and General Office Network) 5. Media Conferencing Network 6. Central Office (CO) leased phone lines Legend ARD -Automatic Ringdown OPX -Off-Premises Exchange ENS -Emergency Notification System (NRC) PBX -Private Branch Exchange VEOC -Virginia Emergency Operat i ons Center Measurement Wind Speed Wind Direction Sigma-theta Temperature Differential Temperature Dew Point Temperature Precipitation (1) (2) TABLE 7.2 NAEP Page 7.14 Revision # TBD METEOROLOGICAL MONITORING SYSTEM PARAMETERS<

1> Primary Tower Backu12 Tower Control Rm. 48.4 Meters. 1 O Meters Ground 10 Meters. Readout X X X X X X X X X X X x<2> X X X X X X X All data available via dial-up link at Meteorological Operations in Richmond. Signal from Backup Tower only.

FIGURE 7.1 NORTH ANNA POWER STATION MONITORING LOCATION MAP NAEP Page 7.15 Revision # TBD NOT E: Specific lo catio n s are provided in Figure 7.2. Locations within one-h a lf mile not displayed.

NAEP Page 7.16 Revision # TBD F IGUR E 7.2 NORTH ANNA POWER STATIO N M ONITORING LOCATIO N LIST ING Sam~l e Media L o c ation Station # Distance Directio n Remarks {miles) Environme n ta l Bearin g Cooling Tower N-1/33 0.06 N On-Site (TLDs) Sturgeon's Creek Marina N-2/34 2.04 N Par k ing Lot "C" NNE-3/35 0.24 NNE On-Site Good Hope Church NNE-4/36 3.77 NNE NAPS Waste Treatment Plant , end of parking lot B NE-5/37 0.20 NE On-Site Boggs Drive NE-6/38 1.46 NE Weather Tower Fence ENE-7/39 0.36 ENE On-Site Route 689 ENE-8/40 2.43 ENE Near Training Facility E-9/41 0.30 E On-Site "Morning Glory Hill" E-10/42 2.85 E Island Dike ESE-11/43 0.12 ESE On-Site Route 622 ESE-12/44 4.70 ESE Biology Lab SE-13/45 0.64 SE On-Site Route 701 (Dam Entrance)

SE-14/46 5.88 SE " Aspen H i lls" SSE-15/47 0.93 SSE Site Boundary Elk Creek SSE-16/48 2.33 SSE NAPS Access Road S-17/49 0.36 s On-Site Elk Creek Church S-18/50 1.55 s NAPS Access Road SSW-19/51 0.24 SSW On-S i te Route 618 SSW-20/52 5.30 SSW 500KV Tower SW-21/53 0.60 SW On-Site Route 700 SW-22/54 3.96 SW At NAPS , on pole , SE of switchyard , entrance on Rt. 700 WSW-23/55 0.38 WSW On-Site Route 700 WSW-24/56 1.00 WSW Site Boundary Sou t h Gate of Switchyard W-25/57 0.32 w On-Site Route 685 W-26/58 1.55 w End of Route 685 WNW-27/59 1.00 WNW Site Boundary Route 685 WNW-28/60 1.40 WNW Laydown Area North Gate NW-29/61 0.52 NW On-S it e Lake Anna Campground NW-30/62 2.54 NW #1/#2 Intake NNW-31/63 0.07 NNW On-Site Route 208 NNW-3 2/64 2.21 NNW Bumpass Post Office C-1/2 7.30 SSE Orange , Va. C-3/4 22.00 NW Control Mineral , Va. C-5/6 7.10 WSW Louisa , Va. C-7/8 11.54 WSW Control Airborne NAPS Waste Treatmen t P l ant , Particulate and end of park i ng lot B 01 0.20 NE On-S i te Radioiodine Biology Lab 01-A 0.64 SE On-S i te Frederick's Hall 02 5.30 SSW Minera l , Va. 03 7.10 WSW Wares Cro s sroads 0 4 5.10 WNW Route 7 5 2 0 5 4.20 NNE Sturgeon's Creek Marina 05A 2.04 N Levy , Va. 06 4.70 ESE Bumpass , Va. 0 7 7.30 SSE End of Route 685 21 1.00 WNW Site Boundary Route 700 22 1.00 WSW Site Boundary " Aspen H i lls" 23 0.93 SSE Site Bo u ndary Orange , Va. 2 4 22.00 NW Control Source Docu m ent VPAP-2 103N , Rev 27 , Attachment 10 , Environme n ta l Sampling Locations.

Part 8.0 8.1 8.2 I 8.2.1 8.2.2 8.2.3 8.2.4 8.2.~§. 8.2.4§ 8.3 8.3.1 8.3.2 8.3.3 8.3.4 8.3.5 8.3.6 8.4 8.5 8.5.1 8.5.2 8.5.3 8.5.4 8.5.5 8.5.6 NORTH ANNA POWER STATION EMERGENCY PLAN SECTION 8 MAINTAINING EMERGENCY PREPAREDNESS NAEP Page 8.1 Revision # TBD Subject Page No. Maintaining Emergency Preparedness

8.3 Responsibility

for Maintaining Emergency Preparedness

8.3 Maintenance

of the Emergency Plan, Emergency Plan Implementing 8.4 Procedures, and Emergency Personnel Notification List Annual Review of the Emergency Plan and Emergency Plan Implementing

8.4 Procedures

Review of the Emergency Personnel Notification List Revision of the Emergency Plan Maintenance of Emergency Plan Implementing Procedures Distribution of Emergency Plans Review of Evacuation Time Estimates Training of Station Emergency Response Organization Personnel Responsibilities for Maintaining Emergency Preparedness Training Nuclear Employee and Visitor Training Emergency Response Personnel Training Cognitive Evaluations Task Performance Evaluations Training Records Training Offsite Support Personnel Emergency Drills Communications Drills Fire Drills Medical Emergency Drills Environmental Monitoring Drills Radiological Monitoring Drills Combined Functional Drills 8.4 8.X 8.X 8.4 8.5 8.5 8.5 8.6 8.6 8.7 8.7 8.7 8.7 8.8 8.9 8.9 8.9 8.9 8.10 8.10 Part 8.6 8.6.1 8.6.2 8.6.3 8.6.4 8.6.5 8.6.6 8.7 8.8 8.9 Table 8.1 Subject Emergency Exercises Scheduling of Emergency Exercises Emergency Exercise Content Emergency Exercise Scenarios Conduct of Emergency Exercises Emergency Exercise Evaluation and Corrective Action Records of Emergency Exercise Testing and Maintenance of Emergency Equipment Informing the Public Independent Review of the Emergency Preparedness Program Emergency P r eparedness Training NAEP Page 8.2 Revision # TBD Page No. 8.10 8.10 8.10 8.11 8.11 8.12 8.12 8.12 8.13 8.13 8.15

8.0 MAINTAINING

EMERGENCY PREPAREDNESS NAEP Page 8.3 Revision # TBD Dominion has instituted an emergency preparedness program to support development , maintenance and coordination of the company's emergency response capability.

The Emergency Plan and associated Emergency Plan Implementing Procedures , which provide specific guidance to emergency response personnel, are revised as required and reviewed at least annually in accordance with this program. Personnel who may be required to fill emergency response positions receive initial and annual training in their functional responsibilities.

Training is also provided for various offsite groups that have agreed to support the station response to an emergency.

Dedicated emergency equipment is kept operational through testing in accordance with an established periodic surveillance program. Periodic drills and a biennial exercise are conducted for training and to identify program strengths and weaknesses.

Additionally , the emergency preparedness program provides for the issuance of public information material.

This material provides the public with a description of the emergency notification process , and guidelines used to protect public health and safety in an emergency.

Independent reviews of the emergency preparedness program are also conducted. 8.1 RESPONSIBILITIES FOR MAINTAINING EMERGENCY PREPAREDNESS The Senior Vice President and Chief Nuclear Officer , assigned the overall authority for maintaining emergency preparedness , has delegated the responsibility for maintaining emergency preparedness to the Vice President Engineering and to the Site Vice President.

The Vice President Engineering has delegated the responsibility to the Director Nuclear Regulatory Affairs. The Director Nuclear Regulatory Affairs has delegated the responsibility to the Manager Nuclear Fleet Emergency Preparedness. The Site Vice President has delegated the responsibility to the Director Safety and Licensing. The Director Safety and Licensing has delegated the responsibility to the Manager Nuclear Emergency Preparedness. The primary responsibilities for maintaining the emergency preparedness program include: a) Coordinating the Company emergency preparedness program with offsite emergency response organizations b) Coordinating Company emergency preparedness planning activities c) Conducting public information and media information activities d) Coordinating emergency drills and exercises between Company departments and offsite agencies , and ensuring that they are conducted as required; e) Coordinating emergency preparedness program reviews f) Coordinating emergency preparedness activities between the stations and other Company departments g) Providing support to the stations in the area of emergency preparedness h) Obtaining letters of agreement from appropriate offsite emergency response organizations i) Coordinating the annual review of Emergency Action Levels with State and local j) Performing the annual review of the emergency plan and implementing procedures NAEP Page 8.4 Revision # TBD k) Maintaining the Emergency Plan , Implementing Procedures , and other documents related to Emergency Preparedness I) Ensuring distribution of copies of the Emergency Plan and Implementing Procedures to persons or organizations with responsibility for implementation of the plan or procedures m) Coordinating emergency preparedness training and ensuring that it is performed n) Ensuring that required testing and maintenance of emergency equipment is performed o) Ensuring that required emergency preparedness records are maintained and filed p) Coordinating the conduct of an augmentation capability assessment at least once per calendar quarter The hierarchy for program maintenance is further outlined in VPAP-2601 , "Maintaining Emergency Preparedness". 8.2 MAINTENANCE OF THE EMERGENCY PLAN , EMERGENCY PLAN IMPLEMENTING PROCEDURES, AND EMERGENCY PERSONNEL NOTIFICATION LIST Station documents which are required to ensure emergency preparedness include: a) The North Anna Emergency Plan b) The North Anna Emergency Plan Implementing Procedures c) The North Anna Emergency Personnel Notification List 8.2.1 Annual Review of the Emergency Plan and Emergency Plan Implementing Procedures Nuclear Emergency Preparedness personnel shall review the North Anna Emergency Plan and associated Implementing Procedures at least annually , certifying that they are adequate and current. Nuclear Emergency Preparedness personnel shall also review the results of independent assessments of the emergency preparedness program and critiques of exercises and drills to evaluate their impact on station emergency preparedness documents. The results of these reviews shall be reported to the Facility Safety Review Committee (FSRC) and the documentation filed by Records Management.

FSRC shall review proposed revisions to tho Emergency Plan and the Emergency Plan Implementing Procedures and mal~o recommendations to tho Site Vice President , who is responsible for their approval.

If a proposed revision is judged to decrease tho offoctivonoss of those documents with respect to tho requirements of 10 CFR 50.47 (b) or 10 CFR 50 , Appendix E , it shall be submitted to the NRG for approval in accordance with tho requirements of 10 CFR 50.54 (q) prior to implementation. 8.2.2 Review of the Emergency Personnel Notification List Nuclear Emergency Preparedness personnel shall ensure a review of the Emergency Personnel Notification List is performed at least quarterly, and shall ensure required revisions are made. Documentation of this review shall be filed by Records Management.

8.2.3 Revision

of the Emergency Plan In accordance with 1 OCFR50.54(q)(3), proposed revisions to the North Anna Emergency Plan shall be screened/evaluated against 10CFR50.47(b) and 10CFR50 , Appendix E. to determine whether the proposed change is a reduction in effectiveness. Any such changes shall be submitted to the NRG for NAEP Page 8.5 Revision # TBD approval prior to implementation in accordance with the requirements of 10CFR50.54{q)(4). The FSRC shall review and approve proposed revisions to the North Anna Emergency Plan. 8.2.4 Maintenance of Emergency Plan Implementing Procedures Proposed revisions to EPIPs shall be reviewed to verify the effectiveness of the emergency plan is maintained as required by 1 OCFR50.54(q){2). The Manager NEP shall review and approve proposed revisions to EPIPs. 8.2.~5 Distribution of Emergency Plans In accordance with 10 CFR 50.54(q)(5) revisions to the Emergency Plan shall be submitted to the NRG within 30 days following the assigned effective date. Revisions to the NAEP will also be distributed to those offsite agencies requiring copies in order to perform their emergency response functions.

8.2.4-6 Review of Evacuation Time Estimates Nuclear Emergency Preparedness personnel shall ensure evacuation time estimates (ETEs) are developed within 365 days of when U.S. Census Bureau decennial data becomes available. ETEs are a factor considered in the development of off-site protective action recommendations (see Section 6.3.1) and are provided to Commonwealth and local governmental authorities for use in developing off-site protective action strategies.

ETEs are reviewed against estimated EPZ permanent resident population changes at least once a year and within 365 days of the date of the previous ETE or its most recent review. Increases of ET Es greater than the limits detailed in 10 CFR 50 Appendix E require the ETE analysis be updated. The decennial ETE and its updates are submitted to NRG as required by 10 CFR 50 Appendix E. 8.3 Training of Station Emergency Response Organization Personnel The effectiveness of a response to a station emergency relates directly to the level of emergency preparedness maintained by station emergency response organization personnel.

Emergency preparedness of station porsonnol is maintained through an integrated program that includes general orientation for all persons badged at the station and additional detailed training for persons assigned specific emergency response functions to supplement the general orientation and normal job related training. The primary objectives of this emergency preparedness training program are to: a) Ensure emergency response personnel maintain familiarity with the North Anna Emergency Plan , its implementing procedures and their functional responsibilities during an emergency b) Inform emergency response personnel of their functional role and responsibilities during an emergency c) Familiarize emergency response personnel with significant changes to the North Anna Emergency Plan and its implementing procedures NAEP NOTE: U pdate o f re ferences to T R-NA-TPG-2400.

w hich has bee n s uperseded.

is beyo nd the sco pe of this license a mendment request. Page 8.6 Revision # TBD Training Program (when provided as follows: a. The Site Vice President is responsible for ensurin AA-TPG-2400 or TR-AA-TPG-2400 (when issued) b. Department directors , managers and supervisors , Ml~r-7:>..

t"r conducting emergency preparedness

-TPG-2400, North Anna Nuc l ear training.

This includes designating individuals ho may serve as primary , interim emergency response personnel and ensuring they uccessfully complete the training specified by NA-TPG-2400 or TR-AA-TPG-2400 (when issue . c. The Manager Nuclear Emergency Preparedness is r sponsible for developing and scheduling training programs that meet the requirements for this plan , an for maintaining records to document the training.

d. Nuclear Emergency Preparedness personnel other th those designated to develop training programs will independently check that the training required by R-NA-TPG-2400 , or TR-AA-TPG-2400 (when issued), and th i s plan is accomplished. 8.3.2 Nuclear Employee and Visitor Training All persons badged to enter the Protected Area unescorted receive , as part of Nuclear Employee Training , computer-based training (CBT) and annual retraining in the following subjects:

a) Station Policies and Procedures including , in part: 1) Reporting abnormal conditions (e.g., fire , first a i d event , etc.) 2) Fire and First Aid alarms and announcements

3) Response to Fire and First Aid emergencies b) Radiation Protection Training including basic principles of radiological safety c) Emergency Preparedness Training Overview including: 1) General scope and overview of the Emergency Plan 2) Station Emergency Alarm and announcements

3) Response to Station Emergency Alarm 4) Personnel accountability

5) Visitor control during an emergency

6) Site evacuation

7) Emergency Plan Implementing Procedures

8) Emergency Organization

9) Emergency Control Centers (Emergency Facilities)

10) Emergency Action Levels NOTE: U p da t e o f r efere n ces t o TR-NA-TPG-2400. w hi c h h as bee n s up erse d e d , i s beyo n d th e sco p e of NAEP Page 8.7 Revision # TBD As appropriate, some or all of the above subjects in Personnel designated to fill

• erim, primary or alternate emerge training in accordance with TR-NA-TPG-2400 or TR-AA-TPG-2400 se positions will receive Emergency preparedness training not conducted by the NEP staff is conducted pursuant to upporti training program guidance.

NEP will ensure that this training is consistent with the pr isions of TPG-2400 or TR-AA-TPG-2400 (when issued). These training programs taken collectivel stablish the initial training and retraining requirements for all emergency response positions.

Table 8.1 provide of select emergency response positions along with an overview of the training provided.

Revisions to NA-TPG-2400 , or TR-AA-TPG-2400 (when issued), that affect those descriptions referenced in Table 8.1 will be reflected in the next scheduled revision of this Plan. Training exempt i ons and equiva lent qualifications Equivalency credit for required training sessions may be awarded based on an individual

's knowledge of the subject matter may be approved by the training program owne r. Such credit requ i res the approval of the Manager Nuclear Emorgoncy Preparedness and tho Sito Vice President.

8.3.4 Cognitive

Evaluations Cognitive evaluations may include self-critiques, group discussions , and/or tests administered following completion of training.

Evaluations are normally administered by the course instructor and may be scheduled at the end of a workshop, learning activity, instructional unit , or a number of related units. A minimum score of 70% is considered passing on tests. For training incorporated into regularly scheduled continuing training programs, the passing criteria for that training program applies. Individuals failing to successfully complete the required training within the required time interval will be relieved of their emergency response assignments. 8.3.5 Task Performance Evaluations Task performance evaluations are prescribed for individuals who must perform tasks as responders which are outside of their normal day-to-day responsibilities and may be satisfied through completion of a Job Demonstration Guide (JOG), participation in an appropriate drill , Simulator Exercise , facility training activity or included in classroom learning activities as part of the tra i ning requirement.

JOG evaluations are conducted by the applicable primary responder , team leader or instructor and are scored on a pass/fail basis. 8.3.6 Training Records The Manager Nuclear Emergency Preparedness is responsible for ensuring that required emergency preparedness training records are maintained. These records are maintained by Records Management.

The required emergency preparedness training records include: a) Program Records: Attendance sheets , master copies of Job Demonstration Guides , master copies of tests and answer keys, copies of instructor guides , training rosters and extensions.

b) Trainee Records: Completed tests and responder training records.

8.4 TRAINING

OF OFFSITE SUPPORT PERSONNEL NAEP Page 8.8 Revision # TBD The various offsite organizations which support the station during an emergency receive training as part of their own emergency preparedness programs. For example , corporate personnel receive emergency preparedness training as part of the Corporate Emergency Response Plan , and the State and local governments conduct training for their personnel as part of their Radiological Emergency Response Plan program. However , in order to promote effective emergency response capability , the station offers site specific emergency response training on an annual basis to local offsite emergency support organizations which have agreed to provide assistance. The organizations include the Commonwealth of Virginia Department of State Police and local county sheriffs departments , volunteer fire companies, and rescue squads. The annual training shall address the following:

a) The basic scope of the North Anna Power Station Emergency Plan b) Emergency classifications c) Notification methods d) Basic radiation protection e) Station access p r ocedures f) The individual , by title , in the station emergency response organization who will direct their activities onsite g) Definition of their support roles Training offered to local offsite support organizations will be coordinated with Station Safety and Loss Prevention or Station Security, as appropriate.

Safety and Loss Prevention , Security , and/or Nuclear Training may assist in the conduct of offsite training.

Training records shall be maintained and filed by Records Management.

These records shall include letters of invitation (or record of telephone invitation), attendance sheets , and the curriculum outline. 8.5 EMERGENCY DRILLS As a part of maintaining emergency preparedness , periodic drills shall be conducted.

The primary objectives of drills are to: a) that facilities, equipment , and communication systems function as required b) Demonstrate the adequacy of station procedures used during an emergency c) Familiarize station emergency response personnel with planned emergency response actions d) Disclose deficiencies which may require corrective action Drills may be conducted independently , in conjunction with another drill or conducted as part of an exercise. The individual responsible for the drill shall ensure that all necessary documentation is maintained. A scenario will be developed to support the conduct of each drill. The scenario should be designed to allow for open decision-making (free-play). If a drill is conducted in conjunction with another drill or as part NAEP Page 8.9 Revision # TBD of an exercise , the drill scenario , objectives and narrative shall be incorporated into the overall drill/exercise package. Drill packages shall include: a) Objectives of the drill b) Evaluation criteria c) Date and time period of the drill d} Participating personnel or organizations e) A narrative summary describing the overall integration of scenario events (e.g., simulated casualties , offsite assistance , rescue of personnel , simulated activity levels , and deployment of monitoring teams) f) A time schedule of the real and simulated events It is not required that all emergency response personnel assigned a particular emergency function participate in a drill covering that function.

State and local governments will be allowed to participate in drills at their request. Participation by offsite organizations may be simulated. 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. Drills shall be controlled and observed by individuals qualified to conduct and evaluate the drill. Critiques will be used to document evaluation of the drill. Deficiencies identified as a result of the drill evaluation will be presented to Station Management , and corrective actions will be coordinated through NEP. Records of each drill will be maintained by Records Management and include the drill scenario package and the post-drill critique.

Records of drills held in conjunction with an exercise may be integrated into the emergency exercise package (i.e. scope , objectives , critique , etc.). The types and frequencies of drills conducted at the station are designated below. Provisions for conducting post accident sampling drills , previously addressed herein , became obsolete upon implementation of contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant , containment sump , and containment atmosphere.

Although these contingency plans must be available during an accident , they do not have to be carried out in emergency plan drills or exercises. (Reference NRG Letter ,

Subject:

North Anna Power Station , Units 1 and 2 -Issuance of Amendments Re: Elimination of Post-Accident Sampling System Requirements , dated December 19 , 2001 , Serial No.01-760) In addition to the following drills , an augmentation capability assessment shall be performed once per calendar quarter. This activity shall assess the elements involved in notification processes for augmenting the emergency response organization.

8.5.1 Communications

Drills Communications drills shall be conducted at least once per calendar year and shall include: I a) Use of emergency communications systems between the Control Room , the TSC , the ~CERC , the OSC , the NRG Operations Center , the Virginia EOG , the county EOCs , and the Onsite and Offsite Monitoring T earns b} Sending, receiving , and verification of message content 8.5.2 Fire Drills NAEP Page 8.10 Revision # TBD Fire drills shall be conducted in accordance with the requirements of the North Anna Fire Protection Program. 8.5.3 Medical Emergency Drills Medical Emergency drills shall be conducted at least once per calendar year and shall include: a) A simulated contaminated injured individual b) Participation by a local rescue squad c) Transport to an offsite medical facility d) Part i cipation by the offsite medical facility 8.5.4 Environmental Monitoring Drills Environmental Monitoring drills shall be conducted at least once per calendar year and shall include: a) Collection of water , vegetation , soil , and air samples both onsite and offs i te , as appropriate b) Analysis of the above samples c) Use of communications with the monitoring teams d) Use of the appropriate procedures for collecting and analyzing samples and recording results 8.5.5 Radiological Monitoring Drills Radiological Monitoring drills shall be conducted semi-annually with a maximum allowable grace period not to exceed 25%, and shall include: a) Response to s i mulated elevated airborne and/or liquid activity levels , as appropriate b) Response to simulated elevated area radiation levels c) Analysis of the simulated radiological situation using the appropriate procedures.

8.5.6 Combined

Functional Drills Combined Functional drills shall be conducted at least once during the interval between biennial exercises and involve a combination of some of the principal functional areas of onsite emergency response capabilities , such as: a) Management and coordination of emergency response b) Accident assessment c) Protective action decision making d) Plant system repair and corrective actions 8.6 EMERGENCY EXERCISES An emergency exercise shall be conducted with a stated scope and object i ves. The primary objectives of an emergency exercise are to: a) Check the integrated capability of the various emergency response organizations to respond to an emergency NAEP Page 8.11 Revision # TBD b) Test a major portion of the basic elements existing within the emergency response plans and organizations c) Demonstrate the adequacy of procedures used during an emergency d) Provide an opportunity for emergency response personnel to demonstrate their ability to perform planned emergency response actions e) Disclose deficiencies which may require corrective action 8.6.1 Scheduling of Emergency Exercises An emergency exercise shall be conducted at North Anna Power Station at least once per biennium , normally on even numbered years. All biennial exercises must include demonstration of response to at least the Site Area Emergency classification level. At least once in every eight-year exercise cycle , a drill or exercise should be initiated between 6:00 pm and 4:00 am on a weekday or during a weekend. Unannounced exercises or drills are conducted on a periodic basis to the extent such exercises can be supported by affected internal and external organizations. 8.6.2 Emergency Exercise Content Exercises are conducted on a periodic basis. The exercises allow demonstration of the key skills specific to emergency response duties in the Control Room, TSC , OSC , ~CERC , and Joint Information Center in order to implement the principal functional areas of emergency response.

The exercises: a) Test the adequacy of timing and content of implementing procedures and methods b) Test emergency equipment and communications networks c) Test the public notificat i on system d) Test the familiarity of emergency organization personnel with their duties Scenarios are varied so major elements of the state , local and station plans and preparedness organizations are tested , including , at least once during the 8-year exercise cycle , the following: a) Hostile action directed at the plant s i te b) No radiological release or an unplanned minimal radiolog i cal release that does not require public protective actions c) An initial classification of or rapid escalation to a Site Area Emergency or General Emergency d) Implementation of strategies , procedures , and guidance developed unde r §50.54(hh)(2) e) Integration of offsite resources with onsite response 8.6.3 Emergency Exercise Scenarios Each emergency exercise shall be based on a pre-planned written scenario.

The overall exercise package shall address, but not be limited to: a) Basic performance objectives of the exercise b) Evaluation criteria used to check demonstration of performance objectives c) Date , initiation time , and exercise duration d) Participating organizations e) Simulated events f) Time schedule of the real and simulated events NAEP Page 8.12 Revision # TBD g) A narrative summary describing the overall integration of scenario events such as s i mulated causalities , offsite assistance , rescue of personnel, use of protective equipment , simulated activity and radiation levels , and deployment of monitoring teams h) A description of the number , location , and basic duties of the controllers i) A description of the arrangements made for , and advance materials to be provided to , the controllers. Advance knowledge of the scenario shall be minimized to ensure realistic participation by those involved. 8.6.4 Conduct of Emergency Exercises The emergency exercise will be initiated and supeNised by designated controllers.

These controllers shall ensure that: a) The information supplied to the participants is of sufficient detail to allow realistic analysis of the simulated events and to provide a basis for rational decision making b) The information is supplied on a real time basis c) The exercise is not so structured as to prevent free play and independent decision making on the part of the participants

8.6.5 Emergency

Exercise Evaluation and Corrective Action Emergency exercises shall be evaluated by qualified controllers.

Controllers shall be selected based on expertise , knowledge of the areas to be evaluated , and familiarity with emergency response requirements. Personnel from federal , state , or local governments may obseNe the exercise. Specific areas to be evaluated by the controllers will be defined in the form of pre-printed critique sheets. Critiques will be held as soon as practicable after the exercise. Critiques should be attended by exercise controllers and key participants. Notes of cri ti que comments shall be recorded. Controllers shall complete critique sheets documenting their obseNations.

Critique sheets shall be submitted in accordance with the schedule established for the exercise. Within 60 days of the exercise , a Post-Exercise Critique Report shall be issued, including suggested corrective actions. Identified corrective actions will then be assigned for implementation.

8.6.6 Records

of Emergency Exercises The exercise scenario package and Post-Exercise Critique are filed by Records Management.

8.7 TESTING

AND MAINTENANCE OF EMERGENCY EQUIPMENT Emergency equipment shall be periodically tested to identify and correct deficiencies.

The specific scope and respons i b i lities for performing these tests are provided in administrative procedures.

For inventory purposes, an item-by-item count is not required if a mechanism is in place to assure the container has not been compromised since the previous satisfactory check. The testing shall include: a) The contents of the emergency kits dedicated for emergency use shall be inventoried quarterly and following each use.

NAEP Page 8.13 Revision # TBD b) Dedicated emergency survey instrumentation shall be inventoried and operationally checked quarterly and following each use. Calibration of dedicated emergency survey instrumentation shall be performed in accordance with manufacturer's recommendations. c) Self-contained breathing apparatus shall be inspected and operationally checked monthly and following use during an emergency.

d) State and local ringdown loop (lnsta-phone) extensions and the ringdown phone to the Virginia EOC located at the station and ~CERC shall be operationally checked on a monthly basis. In addition , NRC Emergency Notification System extensions and NRG Health Physics Network extensions located at the station and ~CERC shall be operationally checked monthly. e) A daily operability check of the Safety Parameter Display System (SPDS) f) Every 18 months, functional and performance testing of the TSC and LEOF Ventilation system g) Operability testing in accordance with manufacture's recommendations and biennial calibrations of TSC and LEOF radiation monitors h) Semimonthly functional polling testing and quarterly full cycle activation and/or growl testing of the Early Warning System (EWS) 8.8 INFORMING THE PUBLIC Information describing the emergency notification process as well as actions that should be taken in the event of an emergency shall be provided to the public on an annual basis. Information provided to the public shall include: a) Educational information on radiation b) Contact points for additional information c) Special needs of the handicapped d) Initial actions following Early Warning System Activation e) Protective actions , such as sheltering or evacuation f) Evacuation routes The company will coordinate its efforts with State and local authorities to ensure the public is informed by using the best means available. These means may include: a) Information in telephone books b) Utility bill inserts c) Newspaper ads d) Postings in public areas e) Information in calendars distributed to residents The information will be distributed to ensure coverage within the 10 mile emergency planning zone. The company shall also establish a telephone system for dealing with rumors. The telephone numbers will be announced over the Emergency Alert System and individuals within the 10 mile emergency planning zone will be invited to call collect.

NAEP Page 8.14 Revision # TBD The Manager Nuclea r Fleet Emergency Preparedness shall ensure that a program to acquaint the news media with the following information is offered on an annual basis: a) Emergency plans b) Information concerning radiation c) Points of contact for release of public information in an emergency

8.9 INDEPENDENT

REVIEW OF THE EMERGENCY PREPAREDNESS PROGRAM An independent review of the emergency preparedness program shall be conducted either: a) at intervals not to exceed 12 months or b) as necessary, based on an assessment against performance indicators , and as soon as reasonably practicable after a change occurs in personnel, procedures, equipment, or facilities that potentially could affect emergency preparedness , but no longer than 12 months after the change. In any case , all elements of the emergency preparedness program shall be reviewed every 24 months. This review shall be conducted in accordance with 10 CFR 50.54 (t). This review shall include: a) The North Anna Emergency Plan and Implementing Procedures b) Emergency Plan training c) Emergency drills d) Emergency exercises e) Emergency equipment f) Interfaces with State and local governments g) Required records and documentation This review shall be conducted by an internal company organization or outside consultant which has no direct responsibility for emergency preparedness. The results of the review and recommendations for improvements shall be documented and reported to company management.

The results regarding adequacy of interface between Dominion and State and local governments shall be made available to the cognizant offsite authority. Recommendations for improvement shall be evaluated and , when appropriate , assigned for corrective action. The following records shall be filed by Records Management and maintained for 5 years: a) The review results and recommended improvements b) The answers to the recommended improvements c) A description of the correct i ve actions taken TABLE 8.1 EMERGENCY PREPAREDNESS TRAINING NAEP Page 8.15 Revision # TBD EMERGENCY RESPONSE POSITION SCOPE OF TRAINING (See Footnotes, next page) Station Emergency Manager Emergency Communicator Emergency Procedures Coordinator Emergency Operations Director Emergency Maintenance Director Emergency Techn i cal Director Shift Technical Advisor Emergency Administrative Director Radiological Assessment Director Radiation Protection Supervisor Operational Support Center Director OSC Support T earn Technical Support Team Chemistry Team Administrative Support Team 1 , 2, 7 , 13 , 15 1 , 3 , 13 1, 2 , 13 1 , 2 , 13 , 15 1 , 4 , 6 , 13 1 , 6 , 13 , 15 1 , 2 , 13 , 15 1, 6 , 7 , 13 1 , 9 , 10 , 11 , 13 , 15 1 , 10 , 11 , 13 1 , 4 , 5 , 13 1 , 4 , 6 , 13 1 , 6 , 13 , 15 1 , 12 , 13 Team Leader 1 , 6 , 8 , 13 Clerical Personnel 1 , 6 , 13 Loss Prevention/Safety Personnel 1 , 13 , 14 Security T earn 1 , 8 , 13 Dose Assessment Team 1 , 9 , 13 Sample Analysis and Monitoring Teams 1 , 11 , 13 Fire Brigade 1 , 13 , 14 First Aid Team 1 , 13 , 14 Damage Control Team 1 , 4 , 13 Search and Rescue T earn 1 , 13 , 14 Corporate Response Manager and Technical Support Manager 1 , 13. 16, 17 N uclear News Manager and News Team 1 , 13. 17 , 18 Chief Techn ical Spokesperson and J IG Support Team 1, 13, 17, 18 Exec utive Liaison 1 13. 16 17 Operations Support Coord i nato r and Operations Support Team 1, 13, 15, 17 Rad iological Assessment Coord i nator 1 , 9, 10, 13 , 15, 17 Acciden t Assessment T earn dose assessors HPN Communicator State & Local Emergency Communicator (CERC) CERC positions not listed above Information Center Coo r dinators 1, 9, 13 , 17 1 3 13 17 1,3 , 13,17 1, 13 , 17 1 13 19 NAEP Page 8.16 Revision # TBD NAEP Page 8.17 Revision # TBD SCOPE OF TRAINING FOOTNOTES: 1. Training provided to all emergency response personnel emphasizes an overview of: Emergency organization , emergency classification system, personnel accountability , emergency exposure limits , emergency response facilities , security access control and site evacuation process , and exposure control techniques.

Station badged responders will receive this training as part of Nuclear Employee Training. 2. Training provided emphasizes:

Assessing emergencies , classifying emergencies , notification systems , contaminated injured personnel actions , site evacuation, emergency radiation exposure authorization , offsite support group capabilities , and recovery.

3. Training provided emphasizes

Notifications and reports to offsite authorities and communication systems as appropriate for individual position assignments. 4. Training provided emphasizes

Emergency Plan Damage Control organization , communication systems , and planning and coordination of damage control tasks. 5. Training provided emphasizes

Activation and administration of the Operational Support Center. 6. Training provided emphasizes

Activation and administration of the Technical Support Center. 7. Training provided emphasizes

Site evacuation procedure. 8. Training provided emphasizes

Notification of station personnel , personnel accountability/evacuation , and station access control during an emergency. The Security Department is responsible for the conduct of this training and for ensuring that documentation is properly maintained for Security Department pe r sonnel. 9. Training provided emphasizes

Dose Assessment.

10. Training provided emphasizes:

Control of emergency Health Physics organization , emergency exposure evaluation , and protective measures.

NAEP Page 8.18 Revision # TBD 11. Training provided emphasizes

Respiratory protection , personnel decontamination , inplant monitoring , offsite monitoring , monitoring of emergency centers and remote assembly areas , contaminated injuries , and radio communications as appropriate for individual position assignments. 12. T r aining provided emphas i zes: Chemistry sampling and h i gh level activity sample analysis under emergency conditions. 13. Training provided emphasizes

Organizational interfaces and responsibilities appropriate for individual position assignments. 14. Training provided emphasizes

Emergency organ iz ational interfaces , search and rescue procedures , and communications systems. Fire Brigade members shall also receive F i re Brigade training as required by the North Anna Power Station Fire Protection Program. First Aid Team Members shall also receive t r a i ning as requ i red by stat i on administrat i ve procedures , which meet the requirements of the Acciden t Prevention Manual. 15. Training provided emphasizes

Use of the Plant Computer System appropriate for individual position assignments.

16. Training provided emphasizes

Protective measures, notification systems and processes, offsite support group capabilities and interface, press release review. and recovery. 17. Training provided emphasizes:

Activation and administration of the Corpo r ate Emergency Response Center. 18. Training provided emphasizes:

Activation and administration of the Joint Information Center appropriate for individual position assignments. 19. Training provided emphasizes

Activation and administration of the Local Media Center appropriate for individual position assignments.

Part 9.0 9.1 9.2 Figure 9.1 NORTH ANNA POWER STATION EMERGENCY PLAN SECTION 9 RECOVERY Subject Recovery Recovery Me t hodology Population E x posure ExamQle Recover}'.

Organization NAEP Page 9.1 R evision# TBD Page No. 9.2 9.2 9.2 9.X

9.0 RECOVERY

NAEP Page 9.2 R evisio n # TBD The recovery process will be managed by a special , designated organization composed of Dominion personnel.

The recovery organization is described in tho Corporate Emorgonoy Response P+aRFigure 9.1. The basic organization may be modified , as required , to address the needs of the given situation.

The Rooovory Technical Support Manager assumes control and direction of the recovery operation with the authority and responsibilities for implementating and administering the recovery plan and organizationsot forth in tho Corporate Emorgonoy Response Plan. Responsibilities of the recovery organization include defining recovery objectives, developing a plan to accomplish these objectives, establishing controls and anticipating potential complications.

monitoring the recovery effort and adjusting the plan accordingly, and evaluating accomplishments against the designated objectives. The recovery process is implemented when the Rooovory Corporate Response Manager, Technical Support Manager and the Station Emergency Manager , with concurrence of State and Federal agencies , have determined the station to be in a stable and controlled condition. Upon the determination , the Rooovory Manager shall notify the NRG Operations Center , the Virginia Emergency Operations Center , and the Looal Countylocal Emergency Operations Centers will be notified that the emergency has been terminated and any required recovery has commenced. 9.1 RECOVERY METHODOLOGY The Recovery organization will develop plans and procedures designed to address both immediate and long term actions. The necessity to maintain protective measures implemented during the emergency will be evaluated and , if deemed appropriate , the Recovery organ i zation will recommend relaxation of the protective measures. The following conditions shall be considered appropriate for the recommendation to relax protection measures. a. Station parameters of operation no longer indicate a potential or actual emergency exists. b. The release of radioactivity from the Station is controllable , no longer exceeds permissible levels and does not present a credible danger to the public. c. The Stat i on is capable of sustaining itself in a long term shutdown condition. Because it is not possible to foresee all of the consequences of an event , specific recovery procedures may need to be written to address specialized requirements.

Normal practices will be followed to the furthest extent possible with regard to maintenance, repair, modification, decontamination, and radiation exposure control activities. Where possible , existing station procedures will be utilized in the areas of operations , maintenance and radiological controls.

Any special recovery procedures will require the same review and approval process accorded other station procedures and , as such , will require the approval of the Facility Safety Review Committee (FSRC). Recovery plan object i ves and associated schedules w i ll be periodically evaluated and modified , if necessary , to accommodate changing circumstances. Provisions to review , p r io ri t i ze , coo r dinate and p r ocedural i ze recove r y activities (e.g., repair, maintenance, modification, and decontamination) will also be add r essed. The recovery organization NAEP Page 9.3 R ev i s ion # TBD addresses planning and coordination of the recovery effort {in cooperation with governmental officials , when required). Federal and state agencies may augment the recovery organization and participate in establishing recovery objectives.

9.2 POPULATION

EXPOSURE Total population doses shall be periodically estimated in the affected sectors and zones utilizing population distribution data from within the emergency planning zones. Station personnel initially determine Total Effective Dose Equivalent (TEDE) due to external exposure from airborne material , external exposure from ground deposition , and internal exposure due to inhalation.

Initial calculations are also performed for determination of Thyroid Committed Dose Equivalent (COE) resulting from inhalation of radioiodines.

The methodology used is consistent with that presented in EPA-400-R-92-001 , MANUAL OF PROTECTIVE ACTION GUIDES AND PROTECTIVE ACTIONS FOR NUCLEAR INCIDENTS. Determination of total population doses will be performed utilizing the Meteorological Information and Dose Assessment System (MIDAS) computer code or equivalent, and will include assessments of exposure received from (but not necessarily limited to) immersion , inhalation , ground shine , and ingestion of radioactive materials.

Public Affairs Interface Cost Administrat i ve Support NRC Interface Eng i neer i ng EXAMPLE RECOVERY ORGANIZATION FIGURE 9.1 Sen i or VP Recovery Manager StateA..ocal IN PO/Industry

~FEMA Affected Un i t Adm i n i stra ti ve Support Ope r ations Ma i ntena n ce I NAEP Page 9.4 R ev i s i on # TB D Operating Units I Affected S t ation Unaffected Unit Unaffected Station I Corporate Coo r dination I Pla n n i ng Safety & Licens i ng Rad i olog i ca l Protection EXAMPLE RECOVERY ORGANIZATION Graphic No: NB47 NORTH ANNA POWER STATION EMERGENCY PLAN SECTION 10 APPENDICES Subject Letters of Agreement Deleted NAEP Page 10.1 R ev i s i o n # TBD 10.1 10.2 10.3 Maps of Exclusion Area , Low Population and Emergency Planning Zone Boundaries 10.4 Listings of EPIPs 10.5 Protective Equipment and Supplies 10.6 Deleted 10. 7 Supporting Plan Contact 10.8 Estimat i on of Evacuation Times 10.9 Radiation Emergency Plan , MCVHNCU -Dominion Power 10.1 O Federal Radiological Monitoring and Assessment Center (FRMAC) Operations Plan 10.11 Initiating Conditions

/Emergency Action Levels Letters of Agreement Federal Agencies: State Agencies:

Local Agencies:

U.S. Department of Energy -Field Office , Oak Ridge Commonwealth of Virginia Department of Emergency Management Commonwealth of Virginia Department of Health Commonwealth of Virginia Department of State Police Commonwealth of Virginia Department of Game and Inland Fisheries Virginia Commonwealth University Medical Center Louisa County Administrator Louisa County Sheriff Louisa County Department of Fire and EMS Spotsylvania County Sheriff Spotsylvania Department of Fire , Rescue , and Emergency Management Orange County Sheriff Orange County Administrator Caroline County Department of Fire & Rescue Caroline County Sheriff Hanover County Administrator Hanover County Sheriff (Maintained under separate cover by Nuclear Emergency Preparedness Department.

Available upon request.)

NAEP Page 10.1.1 R ev i s i o n # TBD Mr. Mark Sartain Vice President Engineerin Dominion Resources , Inc. 5000 Dominion Blvd., 2 SE Glen Allen , VA 23060

Dear Mr. Sartain:

Department of En e rgy National Nuclear Security Administration Oak Ridge Office P.O. Box 2001 Oak Ridge , Tennes s ee 37831 September 2 , 2016 U.S. DEPARTMENT OF ENERGY AVAILABILITY FOR NORTH ANNA This letter is in response to the July 27 , 20161 er fro NAEP Page 10.1.2 Revision # TBD requested that the Letter of Agreement for the av

• ab* ty of the DOE/National Nuclear Security Administration (NNSA) Radiological Assistance RAP Region 2 be updated. This l etter super cedes all previous such letters between your r ization and the DOE Oak Ridge Office (ORO). The c urr ent version of the DOE/NNSA Radi ogical Assist ce Program , Region 2 , Regional Plan is dated December 2006, and should on file at your o ce. If you are unable to locate your copy , please let us know and an e l e onic PDF ver s ion w1 be provided to you. Please note that this document is currently un rgoing a revision and on comp l eted and approved , it will be provided to yo u e)ectronica ll This plan sets forth the procedur or obtaining radiological ass is tance d conditions pertaining to the scope that DOE will pro

• e in support of your fa c ility. Prior to di tch of radiological assistance , we will consult wi the Nuclear Regulatory Commission (NRC state authorities to ensure they are informed of the request and that there duplication of efforts. Th type and duration of radiological assistance provid *11 depend on the severity of the incid t and will be limited to advice and emergency actions es ntial for the control of immediate ds t o health and safety. P l ease recognize that RAP Regi 2 also has the responsibility capabilities to coordinate the request and arri v al of additional D E/NNSA Emergency Respo e Assets , should the situation warrant. We und erstan at the combined license application Dominion submitted for the proposed North Anna nit 3 remains under review by the Nuclear Regulatory Commission. If you ha any questions or require additional information , please contact me at (865) 576-40. Sincerely , L__ ----NAEP Page 10.1.3 R evisio n# T B D COMMONWEALTH of VIRGINI A NA E P Page 10.1.4 R evisio n# TBD D epartme n t of Emergency Manage m e n t 10501 Trade Court State Coordinator North Ches meld , Virgin i a 23236-3713 BRETT A. BURDICK Deputy Coord i nator SUSAN L. MO N GOLD Deputy Coord in ator M ark Sartain Vi c e President E n gi n eering Domi n io n Resources , Inc. 5000 Dominion Boulevard , 2 SE Glen A11en , VA 23060

Dear Mr. Sartain:

August 15 , 20 1 6 (804) 897-6500 (TDD) 674-2417 FAX (804) 897-6506 Reference is made to your letter of July Agreement in compliance with the federa l criteri , regarding the need to update our Letter of scribed by NUREG 0654/FEMA-REP-l.

We have reviewed the North Anna an Surry wer Stations' eme r gency p l ans and are ass u red that they p roperly in t erface wi th t h tate Radio l *cal Emergency Respo n se Pla n (RERP), whkh is a part of the Commonw. alth of Virginia mergency Operations P l an (COVEOP), as we ll as with the local s , site-specific t o " ther power station. Upon receiv in g notification of a radiologica ccident at a Dominion eneration nuclear power station , state agencies and l ocal governmen wi11 implement their Radio ical Emergency Response Plans in accordance with state an oca l govenunent procedures. S cifically , the Virginia Department of Emergency Man ement (VDEM) agrees t o impleme all or parts of the fo11owing actions in the'event a ra d io l ogical emergency at either pl I. Operate Virginia E gency Operations Center (VEOC). 2. Provide VDEM o cene coordinator(s) to the EOF. 3. Provide warning* coordination with other sta t e and l ocal govenune nuclear facility:

perator. 4. Provide eme ency comm u nications. 5. Coordinate m ergency response actions of federa l and state agenc i es. 6. Notify th o 11 owi n g federa l age n c i es of a radio l ogica l emergency:

a. Fed al Emergency Ma n agement Agency (FEMA) when the emergency act a e power faci l ity is classed as an Alert. A l so provide updated .information quest assistance , if required , when the "Worki11g to Protect People, Property a11d Our Communities" N AE P P a g e 10.1.5 Revisio n # TBD ergency action level is c l assed as a Site Area Emergency or General Erne ency. b. ral Aviation Admin i stration air controllers at Richmond International irport of a ra

• l ogical emergency and request that aircraft be instructed to avoid ected until notified otherwise. c. Comm er, Fifth U.S. Coast Guard District of a radiological emer cy at the Surry Power Sta n and request establishment of traffic control of boats id ships on the James River the vicinity of the power station. d. Fort Eustis in e event of an incident at the Surry Power Stati health and safe fpersonnel stationed at his military install 10n. 7. Notify CSX Transport

• on of a radiological emergency at the orth Anna or Surry Power Station and reque that rail service in the affected are e discontinued temporarily.

8. Notify the Office ofRadiolo

• cal Health , Department of ealth immediately of all classes of accidents and incide s reported by operato f nuc l ear facilities.

9. Notify the Virginia Department Transportation to tablish roadblocks and to temporarily term i nate ferry service etween James tty County and Surry County, when appropriate.

10. Notify other state agencies that have e RERP. 11. Notify the state of Maryland EOC of radio Station resulting in either a Site Area Em g cy or General Emergency. Notify the state of North Carolina EOC ofradiologicaJ ciden at the Surry Power Station resulting in either a Site Area Emergency or Gene Emerge y. 12. Provide public information based o nformation

• shed by the Department of Health and the nuc l ear facility operator.

13. Request assistance from the fed al government in ace ance with the Federal Radiological Emergency Res?, se Plan (FRERP) and th ational Response Framework (NRF). 14. Specifically , the Common ealth , through the Virginia Erner cy Support Team (VEST) led by the Virginia Dep ment of Emergency Management (V M), wiH support Dominion's efforts to tain necessary resources , as appropriate. r Beyond Design Basis (BOB) events , e VEST wiJI coordinate street or road closur with law enforcement durin elicopter flight operations as described in the C for North Arma P. wer Station and Surry Power Station. 15. Specifically , fo security or Hostile Action Based events , the Virginia De Emergency nagement will assist as appropriate with other local , state , agencies. I 1dent Command system guidelines will be used. of the emergency response actions stated above, we will, on an annual perform t h e lowing missions:

Ass* t state agencies and political subdivisions in the development , promotion , and ntenance of plans, procedures, and preparedness programs.

oordinate radiological emergency response training and conduct annual training "Working to Protect People, Property and Our Communities" NA E P Page 10.1.6 Rev i s i on # TBD 3. M

• tain a list of media representatives , including names and te l ephone numbers; s nece ary , issue news releases respective to emergency operations involving th orth Anna Surry Power Stations. We unders d that the combined license application Dominion submitted proposed North Ann Unit 3 remains under review by the Nuclear Regulatory These actions ar uthorized by the Governor of Virginia (Executive rder Number Nineteen (1990) and are c sonant.with the Commonwealth of Virginia E ergency Services and Disaster Law of2000 Code Vir inia Chapter 3.2 , Title 44) as amen d. JDS/bcf "Worki11g to Protect People, Property a11d Our Co1111111111ities" COMMONWEALTH of VIRGINIA Mr. Mark Sartain Vice President Enginee

• ng Dominion Resources , Inc. 5000 Dominion Boulevard , Glen Allen , Virginia 23060

Dear Mr. Sartain:

Department of Health POBO X 2448 RICHMOND , VA 23218 September 30 , 2016 27, 2016 requesting ren al of our biennial Letter of NAEP Page 10.1.7 Revisio n # TBD ID7-1-10R 1-800-828-1120 Thank you fo r your l etter of J Agreement affinning emergency respo t\.nna an d Surry Power Stations. By this letter , we are renewing our *tment to pond to any radiological emergency at the North Anna and Surry Power Station. Th Virginia partment of Emergency Management (VDEM) is the lead agency for the Commo n we th in viding a coordinated emergency respons e strategy. VDEM's State Coordinator of Emergen agement coordinates such efforts under the framewo r k of the Commonwealth of Virginia's Ra logical Emergency Response Plan (COVRERP). The Virginia Department of Health (V D H) is co to providing its s u pport to the State Coordinator of Emergency Management in the* plem tation of the COVRERP. We understand that the combined Li nse applicatio Regulatory Commission for the proposed orth Anna Unit 3 1ains under review b y that agency , and that Dominion has not yet made a final cision on whether or n t to build a new nuclear unit at North Anna. Please contact Mr. Steven . Harrison , Director -Office of Ra *ological Health at (804) 864-8151 or by email at stev .harri vdh.vir inia. ov should yo u have additional information relatin o this correspondence. Cc: Jeffrey . Stem , Ph.D Steve 'A. Harrison , MA , ME P Sincerely , +-< t) ~le0\"'-:

Marissa J. Levi n e , MD , MPH , F AAFP State Health Commi s sioner COMMONWEALTH of VIRGINIA DEPARTM E NT OF STATE POLI CE (804) 6 74-2000 9300 Brook Road , Glen Allen , VA 23060 August 15, 2016 Mr. Mark Sartain Vice President Engine Dominion Resources S 500 Dominion Boulevard , SE Glen Allen , Virginia 23060 Ref: Letter of Agreement North Anna Power Station

Dear Mr. Sarta i n:

This is in response to your corresponde updating our Letter of Agreement for N We pledge our continued assistanc and hereby ree to provide the following specific support to any emergenc hat may occur a he North Anna Power Station, upon the direction of th irginia Department f Emergency Management:

To include assi ance with Hostile Actio ased events as deemed appropriate with ot r local , state and federal ag cies in keeping with federal criteria prescribed 10 CFR 50 Appendix E, Sect i IV.A.7: 1) Assist local offi als in disseminating warnings 2) Assist in eva at i on in coordination with local officials

3) Enforce ac ss/egress provision in controlled areas in co local offic* s 4) Provide affic control 5) Ass i st o the extent possible , in radiological monitoring of vehic pers nel at traffic control points As st with communications in a support roll sist with re-entry after emergency A NATIONALLY ACCREDITED LAW ENFORCEMENT AGENCY TDD l-SD0-553-3144 NAEP Page 10.1.8 Revi s ion # TBD L ter of Agreement No Anna Power Station Pag icipate in training and exercises to prepare for emergencies Spe 'fically, for security or Hostile Action Based events, the Vir State olice will assist as appropriate with other local, state, a federal agenci . Incident Command System (ICS) guidelines will used. NAEP Page 10.1.9 R e vi s ion # TBD We understand that t proposed North Anna Commission. combined license application Dominion ubmitted for the it 3 remains under review by the Nuc ar Regulatory SLC/vmh Cc: Lieutenant Colonel George L. First Sergeant Michele R. Tic o NAEP Page 10.1.10 Revision#

TBD COMMONWEALTH of VIRGINIA Bob Dun ca n J:.xec ut ive Di rec t or Departm e nt of Gam e and Inland F i s heri es August 26, 2016 Mark Sartain Vice President Enginee

• Dominion Resources, Inc. 5000 Dominion Boulevard , 2 Glen Allen , VA 23060

Dear Mr. Sartain:

The Department of Game and I emergency response plans for the Surry agreed , this agency will continue to assist y plan , to the greatest extend possible at the tim an We agree to provide the support listed

• Radiological Emergency Response Plan. Anna Power Stations as dir ected by the Vi We understand that the combin proposed North Anna Unit 3 remain IF) remains in agreement with Power Stations. As we have previously e emergency situations, as outlined in your emergency might evolve. endix 2, Task Assignments , Virginia es will be provided al the Surry and North ent of Emergency Management.

Executive Director RWD/GFM/ag Greene , Acting Chief, DGIF Law Enforcement Division 7870 V ill a Park Drive , Ste 400, P.O. Box 90778, H enrico , VA 23228-0778 (804) 367-1000 (VffDD) Equa l O ppor t11 11ity E111p l oy m e 11 t , Programs a11d Faciliti es Health Dom.inion Resour , Inc. 5000 Dominion Bou Glen Allen, Virginia 23

Dear Mr. Sartain:

LETTER OF AGREEMENT NAEP Page 10.1.11 Revision # TBD Debor 1 h W. Dav is , FACHE Ch i ef Executive Off i cer, VC U Hospitals and Clinics , and Vice Pres i dent fOf Clin ica l Services, VCU The Medical College of Virginia Hospit /Virginia Commonwealt niversity agree to participate in the implementation of the Radiation Emerge y Plan for the North nna and Surry Power Stations and to support the plan within the limits of our or nizationa l capa 1ties and to provide decontamination and treatment facilities for chemically exposed in *viduals. The Medical College of Virginia H.ospitals/Virginia m onwealth University agree to participate in any planning, training and drilling necessary to ensure p aredness for radiological disasters. We agree io the following services will be provided: 1. Facilities to treat up to four seriously* ured and r ioactively or chemically contaminated patients in the Emergency Departm t's Decon Area 2. Facilities to treat up to ten non-s ous l y injured radioa *vely or chemically contaminated ment's Decon Area B. 3. ED driveway to the emergency department. 4. Campus Police to suppo raffic control and maintain security ar nd the treatment areas. (oxygen, defibrillators , etc.) to support tre ment in the ED driveway. 5. 6. Mon i toring and cou ng equipment for the detection and analysis o 7. Decontamination d other supp l ies necessary for the isolation and tre or chemically co aminated patients. These services will b avai l able 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. The radio l ogical response is outlined i reater deta i l in ency Plan. The Radiation Safety Section of the Office of the Environ ntal Health onsible for supplying the radiological support services necessary for the of this plan. An equal opportunity/affirmative action university NAEP Page 10.1.12 R ev i s ion # TBD derstand that the combined license application Dominion submitted for the proposed Nort Unit 3 mains under review by the Nuclear Regulatory Commission. Deborah W. Davis Chief Executive Officer, VCU Hospitals and Clinics, VCU Health System and C O UN T Y O F L O UISA Office of t he Co un ty Administrator September 8, 2016 Mr. Mark Sartain Vice President Nuclear Engine Dominion Resources, Inc. 5000 Dominion Boulevard , 2 SE Glen Allen, Virginia 23060 RE: Letter of Agreement for the North Ann

Dear Mr. Sartain:

This letter is in response to your request of J Agreement for the North Anna Power Statio . NA E P Pa g e 10.1.13 Revision # TBD On April 19 , 1976, the Louisa County B d ofSuperviso adopted, by resolution, the Louisa County Emergency Plan to coordinate mergency services r nse capabilities.

The County has revised its plan to comply with t regulations contained t NUREG-0654 and again in May 1985, to include the Early Warnin iren System. The County mplies with the Federal and State regulations regarding re-a tion of Emerge ncy Operating s every four (4) years and most recently re-adopted the p on March 17 , 2014. This letter confirms Louis ounty's agreement to provide the followin Emergency Operations Center (EOC); 1. Operate the Cou 2. Coordinate the erall emergency response of the County; 3. unty point-of-contact with State and Federal agencies, representati of Dominion Generation;

4. Provide e y warning and public information

5. Coord* e radio l ogical emergency re sponse and training;

6. Coor

• a te with State and Dominion Generation staff regarding community ou pro ams for Radiological Emergency Preparedness;

7. U n request and availability, coordinate use of the Louisa County Fire/EMS Tra*

• g enter for North Anna training or as an assembly location in an emergency; and pon request and availability, obtain available resources to be sent to North Anna, sue as bulldozers to move the in-place Vehicle Barrier for access in an emergency event. I Woolfolk Aven u e. Post Office Box 160

• Louisa, Virginia 23093 (540) 967-0401 * (866) 325-4 1 3 1 e understand that the combined license application Dominion submitted for the proposed Anna Unit 3 remains under review by the Nuclear Regulatory Commission.

NAEP Page 10.1.14 Revision#

TBD If you ave any questions or require additional information , please do not hesitate to contact CRG/lec I Wool fo lk Av e nu.e

• Po s t Offic e Bo x 160

• L o u isa , V i r gi n i a 23 09 3 (540) 967-0401 * (866) 3 2 5-41 3 1 Lo ASHLAND D. FORTUNE -SHERIFF P.O. B ox 504

• LOUISA , VIRGJNIA 23093 ngineering Dominion Resou e , Inc 5000 Dominion Bo evard, 2 SE Gl e n All e n , Virgiofa 060

Dear Mr. Sartain ,

NAEP Page 10.1.15 Rev i s i o n# T BD This is to confrrm our contin the following serv i ces: d our willingness to provide *!* Te l ephone and R a dio c ho u r basis *!* Traffic control Specifically , for security or Hosti l e Office will assist as appropr i ate wi Command System (ICS) guideli h the station on a twenty-four (24) We understand that the comb" ed license application Domi *on submitted for t h e proposed North Anna Unit -remains under review by the Nu Commission.

I./~

County of Louisa Department Of Fire and EMS Mark Sartain NAEP Page 10.1.16 R ev i sio n # T B D V i ce President Engineerin Dominion Resource s, In c. 5000 Dominion Rd. Date: 15 Sept. 2016 Glen Allen, Va. 23060 RE: Letter of Agreement

Dear Mr. Sarta i n ,

T h e Loui sa County Departme n t o ire and E S fully supports t h e North Anna Power Station Emergency P l an. The Department w ome e opportunity to work with a community oriented o r ganization such as Dominion Powe . In the event that emergency service re eve eeded, please ca ll the Louisa County Emergency Communication Center u si n g e 9 1 1 num r. We w i ll s up port your efforts to the ex tent of our capabi li ties and r esources. esently we ha e l even (1 1) Fire/EMS statio n s wi t hin the County, staffed with career and/or l unteer personnel, of which can respond t o your faci l ity if needed. Mineral Stat i on 2 uld be the first due , fo owed by S t ation 3 in the Bumpass/Lake Anna area, Station m Loui sa, Station 5 in Loe t Creek, Station 6 i n Trevilians , Station 4 in Holly Grove and Sta

• n 7 in Zion Cross roads. Within the D e part nt we have approximate l y 150 firefighters, well as the following app atus:

• 1 4 Engines v i 750-1000 gallon water tanks and 1000-1500 gpm pu 'sand Medic s as

• th 2000-7000 ga ll on water tanks and 500-1000 gpm pump

• cks with air, l igh t and foam capabilities.

• 7 brus cks with 2200-500 gallon water tanks and pumps.

• 3 aer* apparatu s ranging u p to 110 feet in height.

• 1 ft of 4 i nch supp l y line on each engine.

• F m capacity on the majori ty of all first in engines. ssortments of ground and r oof ladders on apparatus.

4 breathing air compressors located throughout t he County. Se l f-Contained Breathing Ap p aratus on each of th e first in units. P e rmanent and portable communication equipment on all apparatus Ext rication equipm en t on all engine s a nd sq uads Prov i ding competent and professional F ire , EMS & Emergency Management service s to our community.

• *

• C o unty o f Louisa D e partm ent Of Fire and EMS surface r esc u e capab i li ti es All the a pp ara list e d above would b e ava ilable to respond t our facility in a n NAEP Pag e 10.1.17 Revision # TBD eme rgency on an as n ded basis. The D e partment has trained nitoring teams with acces s to the dosimetry for mo *toring radiation i n both trai nin g and tual emergencies.

A command structure is in p ce within all stations to operate der the d i re ction of th e EMS Ch ief Keith Greene, a he Louisa County Emergenc Operations Center. Th e Department participates in the mergency drill s and exer. ses conducted by your organization to furnish personnel and appara s for monitoring te , decontamination areas, evacuation, etc. SpecificaJly , for security or tile Action Ba se events , the Louisa County Departm e n t of Fire and EMS will assist as appro *ate with o lo ca l , state and federal agencies. Nationally recognized In ci d e nt Comm d Syste (ICS) will be used. The first in s tation has an average re s having the first apparatus on scene. The re facility is 30-40 minutes. Department was established by the prevent i on and EMS service s to the citizens a nd businesses of Louisa ounty. T hi s action mbined the Louisa County Vo l unteer Fire Association , the vo lunteer ergency Medical Ass i ation and tbe Eme r gency Services Department into one combine rganization.

The Departm e considers your organization a corporate citizen of the Cou y and supports it as we wou ld other Cou nty citizens.

We understand that e combined license application Domin n submitted rem a in s und er review by the Nuclear egu l atory Commission (NRC) for the pro ed North Anna Unit 3. opportunity to continue working with an d strengt nship for many years to come. Louisa County D e pt. ofFire-EMS Prov i d i ng competent and professional F i re , EMS & Emergency Management services to our community.

Office of the Sheriff Sheriff R oger L. H arri s P ost Office B o x 124 Spotsy lv ania. Vir gi nia 22553 Phone: 540-582-7115

• F a x: 540-582-9448 Mr. Mark Sartain Vice President of Engineen Dominion Resources, Inc. 5000 Dominion Blvd. 2 SE Glen Allen, VA 23060 Dear Mr. Sartain In reference to your letter dated July 27, Office agrees to participate, if and when services:

1. Telephone and radio co 2. Traffic Control 3. Evaluation Control 4. Potential availabili

5. Assist in radiolog*

al monitoring

6. Potential avails *ty of 144 Sheriff's Office pe We understand that t proposed North Commission.

combined license application Domini nit remains under review by the Nucle Title Vi rgtnt~ U\w £n (o r c r m c u1 Piof<<"~l o n al St a ud.:i rd s Co nm1 1ss1o n An Acc r ed i ted Law Enfo r ce m ent Ag e ncy NAEP Page 10.1.18 Revi s ion # TBD County of Spotsy{vania Mark Sartain Vice President Engineering Dominion Resources , Inc. 5000 Dominion Bou l evard , 2 SE Glen A ll en , Virginia 23060

Dear Mr. Sartain:

• Service , Integrity , Pride August 12, 2016 Within the control l imits of Spotsylvania County and i age n cies , we will provide the followi n g: NAEP Page 10.1.19 Revision#

TBD I. Opera t ion of Spotsylvania County's E m ergenc~ peratio Center (EOC) l ocated i n the Public Safety Building , 9119 Dean Ridings Lane , Spotsylv 1 a, Virginia, 553. 2. Coordination of the overa ll County emerge response.

3. A point of contact for local , state , and fed al agencies.

4. Coordination of emergency response tr

• ing , including radio l ogic We understand that the combined lice Unit 3 remains under review by the Please contact me at (540) 507-7 ORANGE COUNTY SHERIFF'S OFFICE Mark Sartain Vice President Engineering Dominion Resources, Inc. 5000 Dominion Boulevard , 2 S Gle n Allen, Virginia 23060

Dear Mr. Sartain ,

NAEP Page 10.1.20 Revision # TBD This is to update our existing emergency p the following services: eement. We are capable of providing I. Receive and verify the not 2. Notify key county offici emergency responsibil" . 3. Alert the public. 4. Evacuate the publi 5. Traffic control. 6. 7. Perimeter con , in coordination wi ~irginia State Police. eriff's Office Communica

• ons Center. We understand that the combin license application Dominion su er review b y the Nuclear Regulatory Sincerely ,

ORANGE COUNTY, VIRGINIA NSON , D ISTRIC T O N E JAMES K. TE , D ISTRICT Two S. TEEL Goo N , D ISTRICT THR EE JAMES P. CRO , DI STRICT FO UR LEE H. FRAME , D I I CT F IV E PHONE: (5 40)6 72-3 31 3 FAX: (540) 6 72-1 679 Mr. Mark Sartain Vice Pres i dent Engineering Dominion Resources , Inc. 5000 Dominion Boulevard, 2 S Glen Allen, Virginia 23060

Dear Mr. Sartain:

BOARD OF SUPERVISORS August 25 , 2016 NAEP Page 1 0.1.21 R e vi s ion# TBD I have received your letter requesting an Station. r of Agreement for North Anna Powe r Please be advised that we are in agreement Emergency Plan , if required. We are capable o the current Orange County Radio l ogical Respon 1. 2. 3. 4. 5. Plan and are willing to partic i pate in the vid i ng the following serv i ces , as outlined in Ian: We understand that the combined r ense application Dominion s milted for the proposed North Anna Un i t 3 remains under revie y the Nuclear Regulatory Com cc: I can be of further assistance. Th as Lacheney , County Attorney n Harkness , Fire and EMS Chief 1cola Tidey , E-911 Center Directo r Mark Sartain Vice President Engin Dominion Resources , 5000 Dominion Boulev Glen Allen, VA 23060

Dear Mr. Sartain:

We have received your lette concerning response to an emergenc August 11 , 2016 NA E P Page 10.1.22 Revi sio n # TBD This letter is to inform you that C ty bas an obligation to participate in the North Anna Power Station Emergency from surrounding jurisdictions.

Caro lin e Cou services:

• conditions exist that require a response will attempt to provide the following I. Verify the notification fr the pow plant. 2. Initiate the warning no

• cation. 3. Perform access/egres affic control inc rdination with l ocal law e nforc e m ent and th epartrnent of State 4. Arrange and perfi those functions necess individuals , pro rties, hom es, business , etc. I ted in the endangered area(s) in coo ration with local la w-enforcemen the Department of State Police and o er sec urity forces. Will attempt to re *ct entry into the hot zone by p nnel not properly protected b y radiatio onitoring devices. Will als attempt to formulate a site plan to monitor w ers/indiv idual s en t er* the hot zone. 5. Atte pt to maintain trained radio l ogical personnel to be u primarily for lo -l eve l radiological incidents involving transportation acc1 nts or fixed

• e emergencies.

These individuals will also assist in the deco amination of response pe rsonne l and equipment when needed. Provide on sce n e fire and rescue response to transportation acciden involving radioactive materials and initiate proper notific ation and si area warnings when necessary. 233 West Broaddus Avenue , Bowling Green , VA 22427 Phone: 804-633-9831

• Fax: 804-633-9832 We understand that the combined license application Dominion submitted propos North Anna Unit 3 remains under review by the Nuclear Regulatory Comrnis cument represents Caroline County's continued support of protection pack: e developed cooperati v ely between Dominion Resourc Virginia Departrrl t of Emergency Management and local governme JRUmk NAEP Page 10.1.23 Revision#

TED

~?f::/~t-t~~

CAROLINE COUNTY SHERIFF'S OFFICE August 11, 2016 Mark Sartain Vice President Engineering Dominion Resources, Inc. P.O. Box 39 118 Courthouse Lane Bowling Green , VA 22427 Phone (804) 633-1 120 Fax (804) 633-1124 www.carolinesheriff

.org 5000 Dominion Boulevard, 2 SE Glen Allen, VA 23060

Dear Mr. Sartain:

NAEP Page 10.1.24 Revision # TBD This is to acknowledge your letter date July 27 , 2 6 requesti a revision of our agreement with your emergency plan as well as our intention to participate in North rgency Plan , if requested. Services provided by this office will be as follows: I. 2. 3. 4. 5. 6. We understand that the combined lice remains under review by the Nuclear ed to the proposed North Anna Unit 3 -------------

A State Accredited Law Enforcement Agency------------

-

FA\'£ 0. PRI C U ARD ASHLAND DISTRICT SCO TI A. \V\'ATI COLO H ARBOR D l~TRI C T Mark Sartain V i ce President Engineering Dominion Resources , Inc. 5000 Dominion Boulevard , 2 SE Glen Allen, VA 23060

Dear Mr. Sartain ,

H ANOVER COURT I/OUSE HAN O VE R CO UNTY EsrABlJSHED I N I 72 0 NA E P P a g e 10.1.25 Revision # TBD X 470 , H A1'0VER , V A 23 069 R OAD, H ANOVER, VA 23069 P HO N E: 804-365-6005 F AX: 80-l-365-6234 W i th regard to updat i ng our Letter of Agreement, i your emergency plan, Hanover will: 1. Continue coordination of the overall emerg County Rad i ological Emergency Response Pl 2. Provide the services and operation of t Co ty Emergency Operations Center, the Evacuation Assembly Center , and the West Hanove taging A a (Beaverdam Fire Station). 3. Serve as the County point-of-contact th State and deral agencies. 4. Provide Public I nformation Services 5. Coordinate Radiol o gical Emergen R esponse Train i ng 6. Coordinate the use of Liberty d ie School as Evacuation sembly Centers for Hanover County and Louisa County , i f required.

We understand that the combined Ii nse application Dominion submitted the proposed North Anna Unit 3 remains under review by the Nucl Regulatory Commission. If you need further assistance , cc: r. James P. Taylor, Deputy County Administrator Mr. Jethro Piland, Fire/EMS Chief Sincerely , Hana ue r: P eop l e , Trad ition and Spirit NA E P Page 10.1.26 Revision # TBD MEMBER OF V I RGI N IA S TATE SHERIFF'S A Mr. Mark Sart a in Vice President Engine e rin g Dominion Reso u rc e s, Inc. 5000 Dominion Boulevard , 2 SE G l e n Allen, VA 23060 D e ar Mr. Sartain: OFFI CE OF SHERIFF COLON EL DA V I D A. H I N ES P.O. BOX 40 HANOVER , VIRG I N I A 23 069 804-365-61 10 8 04-7 30-61 1 0 Augu s t 22 , 2016 I am in receipt of y our J e tter of Jul y 2 Dominion R es ource Service s regarding th e rt s p ec ified arr a ng e m e nts fo r th e exc hang e of

• orm a ti on b y agenci es th a t re s pond t o e mergenci es a t thi s sit e. We under s t a nd th e n ece s s ity of submitting, under t h e t e rms o f the responsibiliti e s of the Han ove r Coun r espons i biliti es ar e as follow s: I. Warnin g th e public 2. A s si s tance in th e e v ac u o n of th e publi c from th e a ff ect 3. Traffi c c ontrol und e r 4. In gress/ egr e s s c ontr sti n g manpo we r c onditi o n s, wh e n asibl e in co ordin a ti o n w ith th e Vir g in ia St a t a t th e combin e d li c en se application Domini nit 3 r e m a in s und e r re v ie w b y th e N u cle ar R e gul WJA,-~ C o l o n e l D a vid R. Hin es She riff A S ta te and Nationa ll y Accredited Law Enforcement Agency APPENDIX 10.2 (DELETED}

NAEP Page 10.2.1 Revision#

TBD APPENDIX 10.3 MAPS OF EXCLUSION AREA, LOW POPULATION AND EMERGENCY PLANNING ZONE BOUNDARIES NA E P Page 10.3.1 Revisio n # TBD

, s n e Bouooary ', J , Exd u sl a, Ar e a) NORTH ANNA POW E R STATION EXCLUSION AREA Lake Anna NAEP Pa g e 10.3.2 R ev i s io n # TBD Gra ph ics N o: SVM4J NORTH ANNA POWER STATION LOW POPULATION ZONE 10 MILE EMERGENCY PLANNING ZONE NAEP Page 10.3.3 Revision#

TBD Grophl.r:r No.SB1213

/ w __ _, .,. ; / ,. j / J-,iNW /*../ / ' ) I . I I / '*'1 NORTH ANNA POWER STATION 50 MILE RADIUS \ ~-NAEP Page 10.3.4 R ev i s ion# TBD Alexandr la NE imtft< Queen (..') * -....,<., l:..)),,.-

.,1* ..:..J v_j\ New Kent '\.,,._""""'*-* ': ":lt!h Charles City C-'? J~mes i' APPENDIX 10.4 LISTING OF EPIPs NAEP Page 10.4.1 Revision # TBD LIST OF EMERGENCY PLAN IMPLEMENTING PROCEDURES Emergency Control Procedures 1.01 Emergency Manager Controlling Procedure 1.02 Response to Notification of Unusual Event 1.03 Response to Alert 1.04 Response to Site Area Emergency 1.05 Response to General Emergency 1.06 Protective Action Recommendations

2. Notification Procedures 2.01 Notification of State and Local Governments 2.02 Notification of NRG 3. Augmentation Procedures 3.02 Activation of Technical Support Center 3.03 Activation of Operational Support Cente r 3.05 Augmentation of Emergency Response Organization 3.06 Augmentation of Corporate Emergency Response Center 4. Radiological Monitoring and Dose Assessment Procedures 4.01 Radiological Assessment Director Controlling Procedure 4.02 Radiation Protection Supervisor Controlling Procedure 4.03 Dose Assessment Controlling Procedure 4.04 Emergency Personnel Radiation Exposure 4.05 Respiratory Protection and Kl Assessment 4.06 Personnel Monitoring and Decontamina ti on 4.07 Protective Measures 4.09 Source Term Assessment 4.14 lnplant Monitoring 4.15 Onsite Monitoring 4.16 Offsite Monitoring 4.17 Monitoring of Emergency Response Facilities 4 .18 Monitoring of LEOf 4.21 Evacuation and Remote Assembly Area Monitoring 4.24 Gaseous Effluent Sampling During an Eme r gency 4.26 High Level Activity Sample Analysis 4.28 TS~ Radiation Monitoring System 4.33 Health Physics Network Communications 4.34 Field Team Radio Operator Instructions 4.35 Chemistry Sampling NAEP Page 10.4.2 R e v i s i o n # T B D List of Emergency Plan Implementing Procedures (Cont.) 5. Protective Action Procedures 5.01 Transportation of Contaminated Injured Personnel 5.03 Personnel Accountability 5.04 Access Control 5.05 Site Evacuation or Company Dismissal 5.07 Administration of Radioprotective Drugs 5.08 Damage Control Guideline 5.09 Security Team Leader Controlling Procedure

6. Recovery and Restoration Procedures 6.01 Re-entry/Recovery Guideline NAEP Page 10.4.3 R ev i s ion # TBD NAEP-EPIP CROSS REFERENCE. NAEP Page 10.4.4 R ev i s i o n# TBD NAEP SECTION NUMBER IMPLEMENTED BY EPIP NUMBER 4.1 4.2 4.4 5.0 5.2 5.3 5.4 6.1 6.2 6.3 6.4 6.5 9.0 9.2 1.01-1.05 1.04-1.05 1.04-1.05 1.01 , 3.05 1.01 , 3.02 , 3.03 , 3.06, 5.08, 5.09 2.01 , 2.02 , 5.09 2.01 1.01 , 2.01 , 2.02, 3.05 , 4.34 1.01 , 4.01-4.03, 4.09 , 4.14-4.18 , 4.24 , 4.26 , 4.28 , 4.33-4.35 1.01 ,-1.05, 4.05 , 4.07 , 4.21, 5.01 , 5.03-5.05 , 5.07 4.04, 4.06 , 5.01 1.02-1.05 , 5.09 6.01 4.03 , 4.09, 4.14, 4.16 Because the Emergency Plan provides a broad overview of the guidelines that must be considered in mitigating an emergency situation, a number of sections of the Plan do not appear in the cross reference , as they are not specifically activated by an EPIP.

APPENDIX 10.5 PROTECTIVE EQUIPMENT AND SUPPLIES NAEP Page 10.5.1 Revision # TBD NOTE: Description of kit contents to be updated to reflect current inventories.

This change is beyond the scope of this license amendment request. NAEP Page 10.5.2 Revision#

TBD Emergency Kits for Offsite Monitoring Teams NOTE: 1 1 6 1 1 1 1 2 2 2 10 2 2 1 1 1 1 1 1 1 3 1 1 2 2 1 6 1 2 4 Description Hand Trowel Forceps Silver Zeolite Filter Map of Orange Map of TLD Location Preselect Monitor Location Map Map of Site Exclusion Boundary Pads of paper Full-face Respirators , e.g., Ultravue or equivalent Pair Rubber Boots Envelopes Pencils Smears Flashlight Map of Louisa Map of Spotsylvania Map of Lake Anna Dosimeter Charger Package or Box of wipes, e.g., Kimwipes Qt. Plastic Container Gallon Plastic Container ackage of Cotton Inserts Bag (15 pair) of Rubber Gloves Hoods Sets of P.C.s Bag assorted Bags "D" Cell Batteries Pk. Air Particulate Patches Digital Alarming Dosimeters (DADs)

• Caution Envelopes with Bag of assorted signs and barrier rope.

• 2 (each) 1 OOR Dosimeters and 1 R Dosimeters may be in the kit in lieu of 2 DADs.

NOTE: Desc,iption of kit con t ents t o be upd a ted t o r eflec t c urr ent inventories.

This c hange i s bevond th e sco p e of thi s li cense Emergency Kits NAEP Page 10.5.3 R e vi s i o n# TBD TSC, OSC, and ALT OSC , and LEOF NOTE: Quantity 2 2 2 1 1 5 2 2 1 1 2 2 Sets in at least the following items: Description Full-face Respirators , e.g., Ultravue or equivalent Pair Rubber Boots Boxes Smears Dosimeter Charger (Not required if DADs used) Package Cotton Insert Pairs of Rubber Gloves Hoods Sets of PCs E520 with 177 (or equal) RM-14 with 210 (or equal) Flashlights Replacement Batteries for flashlight Emergency Kit EVACUATION NOTE: The kit shall contain at least the following items: Quantity 2 8 25 Feet 6 Various 10 10 1 2 3 1 5 2 2 1 3 30 4 1 1 Description Cans of waterless soap Paper coverall suits Radiation barrier rope Radiation placards Radiation inserts for placards Radioactive material stickers Radioactive material tags Package of smears Pads of paper Pencils Box of surgical gloves Trash bags Boxes of cotton swabs Black marking pens Red marking pen Miscellaneous size plastic bags Pairs of shoe covers (disposable or launderable)

Packages of diapers Box of heavy-duty cleanser Roll of tape APPENDIX 10.6 (DELETED)

NAEP Page 10.6.1 Revision # TBD APPENDIX 10.7 SUPPORTING PLAN CONT ACT NAEP Page 10.7.1 Revision # TBD NAEP Page 10.7.2 R evisio n# TBD SUPPORTING PLAN CONT ACT ORGANIZATION Dominion Corporate Emergency Response Plan State Plan (Commonwealth of Virginia Emergency Operations Plan -Specific Annex #1 -Radiologica l Emergency Response)

Louisa County Plan Spotsylvania County Plan Orange County Plan Caroline County Plan Hanover County Plan Medical College of Virginia Plan Department of Energy -FRMAP CONTACT Dominion Nuclear Emergency Preparedness Department Virginia Department of Emergency Management , Emergency Operations Center Sheriff's Dispatcher Sheriff's Dispatcher Sheriff's Dispatcher Sheriff's Dispatcher Sheriff's Dispatcher Hospital Superintendent Oak Ridge Operations APPENDIX 10.8 ESTIMATION OF EVACUATION TIMES (Maintained on file by Nuclear Emergency Preparedness Department.

Available on request.} NAEP Page 10.8.1 R ev i s i o n # TBD APPENDIX 10.9 RADIATION EMERGENCY PLAN MCVHNCU -DOMINION POWER (Maintained on file by Nuclear Emergency Preparedness Department.

Available on request.)

NAEP Page 10.9.1 R ev i s ion # TBD APPENDIX 10.10 NAEP Page 10.10.1 Revision # TBD FEDERAL RADIOLOGICAL MONITORING AND ASSESSMENT CENTER (FRMAC) OPERATIONS PLAN (Maintained on file by Nuclear Emergency Preparedness Department.

Available on request.)

APPENDIX 10.11 INITIATING CONDITIONS EMERGENCY ACTION LEVELS NAEP Page 10.11.1 Revision # TBD This information is presented in the Emergency Action Level Matrix and Emergency Action Level Technical Bases Document.

These documents are subject to the same review and approval process as the North Anna Emergency Plan and incorporated by reference.