ML22263A364

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Alert and Notification System Evaluation Report - ANS Evaluation Redacted Pages 1 - 95
ML22263A364
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Site: Surry  Dominion icon.png
Issue date: 05/23/2022
From: Jay Collins, Cindy Rosales-Cooper, Talmadge S
Dominion Energy, Policy and Oversight Branch, State of VA, Dept of Emergency Management
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Rosales-Cooper C
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Download: ML22263A364 (95)


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Alert and Notification System Evaluation Report SURRY POWER STATION Revision 3.0

Alert and Notification System Evaluation Report Surry Power Station Table of Contents 2

Dominion Energy TABLE OF CONTENTS Signature Page.....................................................................................................4 Revision History...................................................................................................5 Executive Summary.............................................................................................6 Section 1: Alert and Notification System Plan..................................................8 Licensing Obligation.................................................................................................... 8 Description of Systems................................................................................................ 8 Primary Alert and Notification System................................................................................ 8 Backup Alert and Notification System................................................................................. 9 Authority.................................................................................................................... 10 Administration............................................................................................................ 10 Requirements/Function.............................................................................................. 10 Operations.........................................................................................................................10 Security and Privacy.................................................................................................. 12 Training and Quality Assurance................................................................................. 12 Public Outreach and Education................................................................................. 12 Messaging................................................................................................................. 13 Limited English Proficiency (LEP)......................................................................................13 Access and Functional Needs...........................................................................................13 Transient Populations........................................................................................................14 Ingestion Exposure Pathway EPZ Information...................................................................14 Maintenance.............................................................................................................. 14 Section 2: Design Report.................................................................................. 15 Licensing Obligations (if applicable).......................................................................... 15 Requirements............................................................................................................ 15 System Coverage..............................................................................................................15 Population/Demographics.................................................................................................17 Interoperability...................................................................................................................18 Operations.........................................................................................................................20 Management/Administration..............................................................................................20 Security and Privacy..........................................................................................................20 Maintenance/Repair..........................................................................................................21 Availability/Reliability.........................................................................................................21 Testing..............................................................................................................................22 Quality Assurance.............................................................................................................22

Alert and Notification System Evaluation Report Surry Power Station Table of Contents 3

Dominion Energy Description/Performance........................................................................................... 22 Physical Requirements......................................................................................................22 Administrative Components...............................................................................................23 Operational Components...................................................................................................24 Verification................................................................................................................. 25 Availability/Reliability................................................................................................. 25 Security and Privacy.................................................................................................. 26 Training and Public Outreach.................................................................................... 26 Section 3: Attachments.................................................................................... 28 ATTACHMENT 1: FEMA IPAWS Architecture........................................................... 29 ATTACHMENT 2: VDEM and SPS Primary and Backup Alert and Notification System Infrastructure........................................................................................................ 31 ATTACHMENT 3: Draft Annual ANS Audit................................................................ 33 ATTACHMENT 4: Coverage Maps for Tier 1 Cellular Carriers:................................. 41 ATTACHMENT 5: VDEM and FEMA IPAWS Memorandum of Agreement............... 46 ATTACHMENT 6: Relevant Virginia Radiological Emergency Response Plan (Technical Support Document) Appendices and Procedures:............................. 61 ATTACHMENT 7: Surry Power Station EAS Coverage Map................................... 1

Alert and Notification System Evaluation Report Surry Power Station Executive Summary 6

EXECUTIVE

SUMMARY

Dominion Energy has revised this ANS Evaluation Report for Surry Power Station (SPS). This evaluation report supersedes Revision 2 of the SPS ANS Evaluation Report, dated March 12, 2018 (Document Number: 300-170420-SPS-001).

This report provides details of how SPS meets the administrative and physical means to ensure initial alert and notification of the public within the SPS plume exposure pathway emergency planning zone (EPZ) as required by (1) Planning Standard E (Notification Methods and Procedures) and Planning Standard F (Emergency Communications) in 44 CFR 350.5 and 10 CFR 50.47(b); (2) NUREG-0654/FEMA-REP-1, Rev. 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants; and (3) the 2019 FEMA Radiological Emergency Preparedness Manual (RPM).

This report meets each of the four acceptable design objectives for coverage as defined in Part V: REP Program Alert and Notification System Guidance of the 2019 RPM:

1. The capability to provide both an alert signal and an informational or instructional message to the population throughout the plume exposure pathway EPZ within 15 minutes. The basis for any special requirements/exceptions (e.g., for large water areas with transient boats or remote hiking trails) must be documented.
2. The initial notification system will ensure coverage of essentially 100% of the population within 5 miles of the site.
3. Notification methods will be established to ensure coverage within 45 minutes of essentially 100% of the population within the entire plume exposure pathway EPZ who may not have received the initial notification. The basis for any special requirement exceptions (e.g., large water areas with transient boats or remote hiking trails) must be documented. Assurance of continued notification capability may be verified on a statistical basis. The plan must include a provision for corrective measures to provide reasonable assurance that coverage in accordance with the design objectives is maintained. The system should be operable prior to initial operation greater than 5 percent of rated thermal power of the first reactor at a site.
4. The capability of the ANS to cover essentially 100% of the population within the entire plume exposure pathway EPZ, regardless of failures. There must be administrative and physical means to correct any ANS failure for any segment of the population that did not receive the alert and/or notification. The means and methods to correct or compensate for failures are identified and developed in conjunction with state, local, territorial, or tribal government officials and the utility operators. The corrective means/measures will be conducted within a reasonable amount of time, with a recommended goal of 45 minutes.

All failure modes, including total failure, are accounted for and means/ measures to overcome them must be documented. Historically most licensees and governmental jurisdictions use the sequential failure model also known as a primary and backup ANS model; use of this model is acceptable, though REP jurisdictions can use other models such as simultaneous or concurrent activation models, which differ from a redundant (exact duplicate) model.

Alert and Notification System Evaluation Report Surry Power Station Executive Summary 7

The U.S. Federal Emergency Management Agency (FEMA) has issued policy guidance indicating that the Integrated Public Alert and Warning System (IPAWS) may be used by a state, tribal, and local government as a primary or backup means of public alerting and notification.

Refer to FEMA memorandum, IPAWS Implementation Guidance, dated September 13, 2017.

The IPAWS is a modernization and integration of the nations alert and warning infrastructure that will save time when time matters: when protecting life and property. Federal, state, local, territorial, and tribal alerting authorities may choose to use IPAWS and may also integrate local systems that use Common Alerting Protocol (CAP) standards with the IPAWS infrastructure.

IPAWS gives public safety officials an effective way to alert and warn the public about an emergency using the Wireless Emergency Alert (WEA), Emergency Alert System (EAS),

National Oceanic and Atmospheric Administration (NOAA) weather radio, and other public alerting systems from a single interface.

As FEMA strongly encourages the integration of IPAWS with offsite alert and notification plans, IPAWS-WEA is the SPS primary alert method and IPAWS-EAS is the primary notification method for alerting and notifying local residents and transient population in the SPS plume exposure pathway EPZ on emergency information, including the emergency alert and notification process and what protective actions to take during an emergency. For redundancy, VDEM has two IPAWS-compliant Common Alerting Protocol (CAP) Alert Origination Tools that are hosted on separate vendor platforms, one that is designated as the primary and the other as an alternate, readily available to activate IPAWS-WEA and IPAWS-EAS. In instances where IPAWS is inoperable, the Virginia Department of Emergency Management (VDEM) Public Notification System, an emergency telephone notification system that has the capability to perform a mass alert and notification to citizens, is the back-up alerting and notification method. IPAWS and the VDEM Public Notification System, respectively, replace the primary and backup alerting methods previously described in Revision 2.0 of the SPS ANS Evaluation Report. These changes were made to better serve the health and safety of the SPS community in enhancing early notification and providing clear, prompt communication to the public.

VDEM has operational responsibility of the primary and backup ANS sub-systems, as well as responsibility for management, administration, applicable testing, and maintenance and repair of the systems. VDEM has developed procedures and policies related to ANS operations.

This report is provided by SPS to FEMA and describes the primary and backup ANS sub-systems used by VDEM. The evaluation report contains information for FEMA to review and determine its acceptability.

Alert and Notification System Evaluation Report Surry Power Station Section 1: Alert and Notification System Plan 8

SECTION 1: ALERT AND NOTIFICATION SYSTEM PLAN Licensing Obligation The SPS License contains no special license conditions relating to the type of Alert and Notification System.

To satisfy FEMA REP Planning Standard E - Notification Methods and Procedures and applicable, associated evaluation criteria for this report, the means for providing early notification and clear instruction to the residents in the SPS plume exposure pathway EPZ have been established.

Description of Systems The primary and backup ANS sub-systems described below are used to promptly alert and notify the public in the SPS plume exposure pathway EPZ of an emergency event at SPS. The backup system is employed if the primary system becomes unavailable for any reason.

Primary Alert and Notification System x

Primary alerting system: IPAWS-WEA is used as the primary alerting method to alert residents and the transient population within the SPS plume exposure pathway EPZ.

IPAWS-WEA broadcasts alerts and warnings from cell towers to any WEA-enabled mobile device within a geographically targeted area, alerting and notifying individuals of an emergency.

IPAWS-WEA messages are short emergency messages. These messages are sent from authorized Federal, state, local, tribal, and territorial public alerting authorities and go through the Integrated Public Alert and Warning System Open Platform for Emergency Networks (IPAWS-OPEN) to receive and authenticate messages transmitted by alerting authorities. IPAWS-OPEN then routes the IPAWS-WEA message to participating wireless carriers, which then push the alerts to mobile devices in the specified geographical target area.

IPAWS-WEA messages are periodically transmitted to mobile devices for an extended duration, as determined by the state, to maximize the possibility of being received by members of the public. Messages can be received indoors or outdoors and heard and felt through a special tone and vibration, both repeated twice. These messages direct individuals to turn on broadcast stations or a communication media to receive additional information and instruction in the event of an emergency at SPS. Reference Attachment 1:

FEMA IPAWS Architecture.

IPAWS is designed to meet the requirements of NUREG 0654/FEMA-REP-1, Rev. 2.

IPAWS-WEA messages are prepared by VDEM. The primary method for transmitting IPAWS-WEA messages is through VDEMs Primary IPAWS-compliant CAP Alert Origination Tool. Reference Attachment 6: Relevant Virginia Radiological Emergency Response Plan Technical Support Document Appendices and Procedures.

Alert and Notification System Evaluation Report Surry Power Station Section 1: Alert and Notification System Plan 9

x Primary notification system: IPAWS-EAS is used as the primary notification method for providing informational and/or instructional message(s) to the SPS plume exposure pathway EPZ population. EAS is a national public warning system comprised of television and radio broadcasters; cable television systems; wireless cable systems; direct broadcast satellite service providers; and wireless video service providers that allow notification to the public during an emergency.

IPAWS-EAS messages are sent from authorized Federal, state, local, tribal, and territorial public alerting authorities and go through the Integrated Public Alert and Warning System Open Platform for Emergency Networks (IPAWS-OPEN) to receive and authenticate messages transmitted by authorized alerting authorities. IPAWS-OPEN then routes the EAS message to designated EAS broadcast stations, which then push the EAS message to all radio and television (AM FM digital, analog, cable, and satellite). Reference Attachment 1: FEMA IPAWS Architecture. For list of EAS broadcast stations and frequencies, refer to the current Commonwealth of Virginia Emergency Alert System Plan. For the EAS coverage map of SPS, refer to Attachment 7: Surry Power Station EAS Coverage Map.

IPAWS-EAS messages are prepared by VDEM. The primary method for transmitting IPAWS-EAS messages is through VDEMs Primary IPAWS-compliant CAP Alert Origination Tool.

Should VDEMs Primary IPAWS-compliant CAP Alert Origination Tool become unavailable or inoperable, an Alternate IPAWS-compliant CAP Alert Origination Tool will be used to reach IPAWS-OPEN to transmit the IPAWS-WEA and IPAWS-EAS messages. This Alternate IPAWS-compliant CAP Alert Origination Tool is on a separate software platform from the Primary IPAWS-compliant CAP Alert Origination Tool. The inclusion of the Alternate IPAWS-compliant CAP Alert Origination Tool creates zero single points of system failure. Reference Attachment 6: Relevant Virginia Radiological Emergency Response Plan Technical Support Document Appendices and Procedures.

Backup Alert and Notification System x

Backup alerting and notification system: The inclusion of the Alternate IPAWS-compliant CAP Alert Origination Tool eliminates any single points of failure; however, in the chance IPAWS-WEA and/or IPAWS-EAS become unavailable or inoperable, the VDEM Public Notification System will be the backup alerting and/or notification method. This system is a public alert system that uses a database of telephone numbers and associated addresses to deliver geo-targeted emergency alerts to a specific geographic area via landline telephones and other communication methods, such as mobile and VoIP telephone records. The VDEM Public Notification System alerts local residents and businesses by sending a text-to-speech voice message to telephones. The VDEM Public Notification System is hosted on the same vendor platform used for the Primary IPAWS-compliant CAP Alert Origination Tool.

Reference Attachment 2: VDEM and SPS Primary and Backup Alert and Notification System Infrastructure. This system infrastructure is further described and detailed in Section 2 of this report.

Alert and Notification System Evaluation Report Surry Power Station Section 1: Alert and Notification System Plan 10 Authority The State Coordinator of Emergency Management (State Coordinator) is authorized to activate the Commonwealth of Virginia Emergency Operations Plan (COVEOP) and the Virginia Radiological Emergency Response Plan (Technical Support Document) in order to coordinate state government emergency operations on behalf of the Governor of Virginia. In this capacity, the State Coordinator is authorized to activate the Virginia Emergency Support Team (VEST), the statewide emergency management coordination and support mechanism. The primary operations of the VEST are conducted at the Virginia Emergency Operations Center (VEOC), as allowed by prevailing public health and safety standards. The State Coordinator of Emergency Management has responsibility for, and authority to use IPAWS-WEA, IPAWS-EAS, and the VDEM Public Notification System. Reference : Relevant Virginia Radiological Emergency Response Plan (Technical Support Document) Appendices and Procedures.

VDEM is on the FEMA list of Organizations with Alerting Authority Completed, and thus has authority to operate IPAWS-WEA, IPAWS-EAS, and the VDEM Public Notification System. A Memorandum of Agreement (MOA) has been signed by VDEM as the Collaborative Operating Group (COG) and FEMA. Reference IPAWS COG Identification Number 200058 for the Virginia Department of Emergency Management. Reference Attachment 5: VDEM and FEMA IPAWS Memorandum of Agreement.

Administration The Governor of Virginia, or his/her designate, administers and provides ultimate oversight for the primary and backup ANS sub-systems.

VDEM is responsible for the management of the primary and backup ANS sub-systems. As described in the Virginia Emergency Operations Plan, Radiological Emergency Response Technical Support Document, VDEM has the authority and ability to activate the primary ANS and backup ANS sub-systems and can do so for itself, or as requested by any or all of its local counties and/or public safety agencies. IPAWS-WEA, IPAWS-EAS, and the VDEM Public Notification System are activated from the VDEM Situational Awareness Unit (SAU). Reference Attachment 6:

Relevant Virginia Radiological Emergency Response Plan (Technical Support Document)

Appendices and Procedures.

Requirements/Function Operations x

Activation Procedures: The ANS is to be activated during any emergency where the immediate dissemination of emergency information and instruction to the public is critical in protecting the public health and safety.

The decision to activate the primary and/or backup ANS is made by VDEM. Activation of the ANS is performed by qualified SAU personnel, per VDEMs established IPAWS-WEA and IPAWS-EAS activation procedures. The primary method the SAU uses to transmit IPAWS-WEA and IPAWS-EAS messages is through VDEMs Primary IPAWS-compliant CAP Alert Origination Tool, a web-based system to transmit EAS/WEA messages. This system is used and monitored daily by SAU personnel for other hazards.

Alert and Notification System Evaluation Report Surry Power Station Section 1: Alert and Notification System Plan 11 IPAWS-WEA and IPAWS-EAS messages are pre-scripted and pre-approved for prompt ANS activation (reference Attachment 6: Relevant Virginia Radiological Emergency Response Plan [Technical Support Document] Appendices and Procedures). Approval to disseminate an IPAWS-WEA and IPAWS-EAS message is needed from the designated positions identified in the Virginia Radiological Emergency Response Plan (reference : Relevant Virginia Radiological Emergency Response Plan [Technical Support Document] Appendices and Procedures). IPAWS-WEA messages will be transmitted to mobile devices in the designated area selected and local broadcasters will immediately interrupt their regular scheduled programming to broadcast the IPAWS-EAS message.

In the event the Primary IPAWS-compliant CAP Alert Origination Tool becomes inoperable, the Alternate IPAWS-compliant CAP Alert Origination Tool can be activated, which is outlined in VDEMs established IPAWS-WEA and IPAWS-EAS activation procedures (reference Attachment 6: Relevant Virginia Radiological Emergency Response Plan

[Technical Support Document] Appendices and Procedures).

x Process(es): Once the SAU receives a protective action recommendation (PAR) from the nuclear utility, VDEM, in coordination with the Virginia Department of Health - Office of Radiation Health (VDH-ORH), will review, evaluate, and develop required actions. Based on the information received and other considerations, a protective action decision (PAD) is made for the SPS plume exposure pathway EPZ residential and transient populations. To communicate with the public, SAU personnel will implement VDEMs established IPAWS-WEA and IPAWS-EAS activation procedure which includes a step-by-step process for activating the primary and the backup ANS sub-systems. The process, at a high-level, includes the following:

Approval to disseminate an IPAWS-WEA and IPAWS-EAS message is obtained from the designated positions identified in the Virginia Radiological Emergency Response Plan. VDEM Communications Division will verify the IPAWS-EAS message is accurate and correctly communicates the PAD before transmitting to EAS broadcasters.

Using the pre-approved, pre-scripted IPAWS-WEA and IPAWS-EAS messages, the Primary IPAWS-compliant CAP Alert Origination Tool is used to activate both messages, simultaneously (reference Attachment 6: Relevant Virginia Radiological Emergency Response Plan [Technical Support Document] Appendices and Procedures). Both VDEMs Primary and Alternate IPAWS-compliant CAP Alert Origination Tools provide a verification signal that the IPAWS-WEA message successfully transmitted to IPAWS-OPEN. The SAU monitors radio and local television stations to verify IPAWS-EAS activation is successful.

Upon activation of the primary ANS, the VDEM Public Notification System will be activated concurrently.

In the event the Primary IPAWS-compliant CAP Alert Origination Tool is inoperable, the Alternate IPAWS-compliant CAP Alert Origination Tool will be used to transmit the IPAWS-WEA and IPAWS-EAS messages.

Alert and Notification System Evaluation Report Surry Power Station Section 1: Alert and Notification System Plan 12 Security and Privacy IPAWS-WEA, IPAWS-EAS, the VDEM Public Notification System messages are sent from the SAU, by personnel qualified to operate these systems. The SAU is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week. Access into the SAU is physically and administratively restricted and limited to VEST authorized personnel. If a visitation is justified, visitors are continuously supervised while in the SAU.

Logical/cyber security is used to secure the Primary and Alternate IPAWS-compliant CAP Alert Origination Tools. The VDEM Public Notification System database information is stored on the Primary IPAWS-compliant CAP Alert Origination Tools secure server. The database is stored on secure, non-publicly accessible servers within redundant data centers. User access to both systems is secured by username/password for personnel who are qualified and responsible for sending notifications. User administration access is strictly limited to those VDEM personnel who are qualified and responsible for administrative functions, which further safeguards information.

The security framework for the Primary and Alternate IPAWS-compliant CAP Alert Origination Tools are based on current CAP security requirements/technical specifications and FEMA IPAWS Program guidance, as set by FEMA IPAWS Program Management Office. IPAWS-WEA and IPAWS-EAS messages include digital signatures that guarantee credible end-to-end authentication.

Messages cannot be tampered with after they are disseminated. Additionally, both Primary and Alternate IPAWS-compliant CAP Alert Origination Tools adhere to existing Virginia Information Technology Agency (VITA) policies.

Training and Quality Assurance VDEM determines and maintains sufficient numbers of qualified individuals to operate the ANS sub-systems. Authorized SAU staff complete IPAWS training (IS-247 Integrated Public Alert and Warning System) through the FEMA Emergency Management Institute (EMI) and other recommended or required software provider/vendor-developed system trainings identified by VDEM as deemed necessary and applicable. SAU staff also gain practical experience during the initial training and real-world emergencies.

A SAU Shift Lead identifies, tracks, and verifies trainings are completed for each SAU staff member. The annual SPS ANS audit verifies appropriate trainings for each system are completed and appropriately tracked. See Attachment 3 for a draft audit template.

Public Outreach and Education To educate the public on the emergency alert and notification process and actions to take in the event of a radiological emergency, SPS distributes public information materials to all residents, businesses, schools, and transient populations within the SPS plume exposure pathway EPZ on an annual basis. These informational materials include pertinent information for the public to know in an emergency, including what actions to take in the event the public receives an IPAWS-WEA message and identification of local radio and television stations for the public to access additional information related to the emergency.

In addition to annually distributed public information materials, IPAWS-WEA (the primary alerting method) can alert the public and provide public information and instruction in real time. This

Alert and Notification System Evaluation Report Surry Power Station Section 1: Alert and Notification System Plan 13 capability avoids complications of recalling previously distributed public information and better reaches the transient population, furthering achieving early notification and clear, prompt instruction to all public members. Rather than being limited to condensed versions of emergency information posted in recreational/public areas and at local businesses, IPAWS-WEA provides transients the same public information and instruction received by local residents on how to appropriately respond to alerts and take action in an emergency, including what to do when you hear an alert and where to access additional emergency information.

Messaging SPS and VDEM work together and coordinate messaging contents and distribution arrangements of the annual dissemination of public information within the SPS plume exposure pathway EPZ.

Messaging includes various emergency preparedness topics, including considerations and accommodations for various population groups, such as for individuals with access and functional needs, transient populations, and ingestion exposure pathway EPZ populations (reference : Relevant Virginia Radiological Emergency Response Plan [Technical Support Document] Appendices and Procedures).

Limited English Proficiency (LEP)

According to the November 2012 Surry Power Station - Development of Evacuation Time Estimates, based on U.S 2010 Census data, the total residential population within the SPS plume exposure pathway EPZ is 152,677. According to LEP.gov (2011 - 2015 American Community Survey), the LEP population within each of the six localities in the SPS plume exposure pathway EPZ is below the 10,000+ non-English speaking individuals or 5% of population threshold for providing translated public information in a foreign language. There is a total of 6,073 Spanish-speaking individuals within the six localities in the SPS plume exposure pathway EPZ, which is approximately 4% of the SPS plume exposure pathway EPZ. Therefore, since the LEP population is below the regulatory threshold, public information and educational material is published in English only.

As new data becomes available, a re-assessment of providing additional translations of public information materials will be conducted.

Access and Functional Needs The annual distribution of public information includes messaging for individuals with access and functional needs, including how to self-identify as an individual needing evacuation assistance during an emergency. Information including the individuals name, physical address, and telephone number is voluntarily collected and subsequently maintained in a directory, managed by local county emergency management organizations. Additionally, for these self-identified individuals, a bright, florescent Special Assistance Needed and We Have Been Notified card is provided to put in a window or visible location to alert emergency responders about his/her situation during an emergency and needing special assistance. Appropriate arrangements are made for these identified individuals by local governments to evacuate, if evacuation is the best determined protective action. Reference Attachment 6: Relevant Virginia Radiological Emergency Response Plan (Technical Support Document) Appendices and Procedures.

Based on the 2003 National Assessment of Adult Literacy data, (https://nces.ed.gov/naal/estimates/StateEstimates.aspx) below are the percentages of literate residents in the six Virginia counties that makeup the SPS plume exposure pathway EPZ:

Alert and Notification System Evaluation Report Surry Power Station Section 1: Alert and Notification System Plan 14 x

City of Newport News-88%

x City of Williamsburg-92%

x Surry County-83%

x Isle of Wight County-89%

x James City County-93%

x York County-94%

Transient Populations Transient populations within the SPS plume exposure pathway EPZ will receive IPAWS-WEA messages alerting them of an emergency and where to access additional emergency information on radio and television stations. Additionally, transient populations can get emergency information from signs/bulletins posted in recreational areas/parks and at local businesses. The information contained in these signs/bulletins are condensed versions from the public information disseminated to residents in the SPS plume exposure pathway EPZ.

Ingestion Exposure Pathway EPZ Information VDEM coordinates ingestion messages for the 37 counties within the SPS ingestion exposure pathway EPZ 1. VDEM is responsible for providing situational awareness and for keeping all response organizations informed during intermediate and late phases of a radiological emergency through communications means deemed as necessary and/or applicable by VDEM, which may or may not include the use of IPAWS-WEA. Ingestion information provided in the annual dissemination of public information includes messaging on disaster planning, potential preventive protective actions, and monitoring and decontamination of livestock and crops.

Maintenance VDEM contracts with two separate IPAWS-compliant CAP Alert Origination Software Providers, one of which hosts the VDEM Public Notification System, who individually conduct routine preventative maintenance on their respected platforms. VITA performs routine preventive maintenance on the Commonwealths local area network (LAN) and equipment, identifying and resolving any faults as they occur.

Maintenance logs and procedures are maintained by their respected organization/vendor and utilized as deemed necessary and applicable when conducting maintenance work.

IPAWS and phone carriers are overseen and monitored by FEMA and the Federal Communications Commission (FCC).

1 Sometimes referred to as the 50-mile Ingestion Protective Action (IPZ), 50-mile ingestion pathway EPZ, or ingestion pathway in the Virginia Emergency Operations Plan, Radiological Emergency Response Basic Plan (Technical Support Document).

Alert and Notification System Evaluation Report Surry Power Station Section 2: Design Report 15 SECTION 2: DESIGN REPORT Licensing Obligations (if applicable)

The SPS Emergency Plan was developed in accordance with 10 CFR Part 50, paragraph 50.47; 10 CFR Part 50, Appendix E; Regulatory Guide 1.101, and follows the guidelines of NUREG-0696, Functional Criteria for Emergency Response Facilities and NUREG-0654/FEMA-REP-1, Rev. 2. The SPS Emergency Plan was developed to be compatible with existing state and local emergency plans for effective coordination and response in the event of an emergency at SPS.

The SPS Emergency Plan contains no license obligations to use any particular ANS. Regulatory requirements do not specify the use of a particular alert and notification system(s) for public information dissemination in an emergency. The SPS Emergency Plan describes the equipment and processes used for informing the public during an emergency.

Requirements System Coverage Population: SPS is located in northeastern Surry County, VA (on the south bank of the James River). The site is approximately 44 miles southeast of Richmond and approximately seven miles south of the City of Williamsburg. SPS operates two reactors, with the first unit going online in December 1972 and the second unit in May 1973.

The SPS plume exposure pathway EPZ is defined as an area delineated by an approximate ten-mile radius circle around SPS Unit 1. Portions of the following six Virginia localities make up the SPS plume exposure pathway EPZ: the counties of Surry, Isle of Wight, James City, and York; and the cities of Newport News and Williamsburg.

The entire SPS plume exposure pathway EPZ is covered by IPAWS-WEA, EAS, and the VDEM Public Notification System. According to the U.S 2010 Census data, the total permanent residential population in the plume exposure pathway EPZ is 152,677. As described further below in the Population/Demographics section, there are numerous tourist attractions that may be present at certain times, including Busch Gardens Williamsburg and Jamestown Settlement. Additionally, there are four major military installments within the SPS plume exposure pathway EPZ, including Fort Eustis, Camp Perry, Cheatham Annex, and the Yorktown Naval Weapons Station.

Figure 1 below shows the total permanent resident population in the SPS plume exposure pathway EPZ, by protective action zone (PAZ), according to the current Evacuation Time Estimate (ETE) study that was performed by KLD Engineering, P.C. in December 2012. Population estimates are based upon U.S Census 2010 data.

Alert and Notification System Evaluation Report Surry Power Station Section 2: Design Report 17 Population/Demographics The SPS plume exposure pathway EPZ population comprises of year-round residential and commercial; therefore, the population may include permanent residents, non-resident tourists (transient populations), and commuting employees working in the SPS plume exposure pathway EPZ. These population groups may consist of individuals with access and functional needs or speak a foreign language.

x Permanent Resident Population: The permanent resident population are those who live within each PAZ in the SPS plume exposure pathway EPZ. Based on the 2010 U.S Census data, the total permanent population in the SPS plume exposure pathway EPZ is 152,677. Included in the permanent resident population are resident students attending and living on the College of William and Mary campus, while commuting students are classified under the transient population.

x Transient Population: Transient populations groups are those who are not permanent residents, nor commuting employees, but enter the SPS plume exposure pathway EPZ for a specific purpose, such as shopping, recreation, entertainment, and school.

Transients may spend anywhere less than one day to a month(s) in the SPS plume exposure pathway EPZ.

The SPS plume exposure pathway EPZ consists of areas and facilities that attract transients, including lodging facilities, marinas, campgrounds, gold courses and country clubs, historical sites, parks and recreational attractions, and festival/events (e.g., Busch Gardens Williamsburg, Colonial Williamsburg, Jamestown Settlement, Anheuser-Busch Brewery, Chippokes Plantation State Park, Hog Island Wildlife Management Area, Newport News Fall Festival of Folklife).

College of William and Mary commuting students are a unique population group. In the 2012 ETE, commuter students commuting from either inside or outside the SPS plume exposure pathway EPZ are counted in the transient population group.

x Employee Commuting Population: The employee commuting population are those who live outside of the SPS plume exposure pathway EPZ and commute to jobs within the plume exposure pathway EPZ. The economy includes the following industries:

manufacturing, health care and social assistance, public administration, utilities, information, and transportation and warehousing. This data is credited to:

https://datausa.io/profile/geo/surry-county-va.

According to the 2012 ETE, there is approximately 18,093 employees that commute into the SPS plume exposure pathway EPZ for work.

x School Population: The school population is concentrated in the northern and eastern parts of the SPS plume exposure pathway EPZ, which include the following 38 schools/daycares:

o Clara Byrd Baker Elementary School o College of William and Mary o Bruton High School o Jamestown High School o Holy Tabernacle Christian Academy o Warwick River Christian School o Epes Elementary School o Jenkins Elementary School o David A Dutrow Elementary School

Alert and Notification System Evaluation Report Surry Power Station Section 2: Design Report 18 o Magruder Elementary School o Matthew Whaley Elementary School o Berkeley Middle School o Walsingham Academy (Lower and Upper School) o Laurel Lane Elementary School o Matoaka Elementary School o Williamsburg Head Start o York County Head Start o DJ Montague Elementary School o Providence Classical School o Waller Mill Elementary School o Queens Lake Middle School o BC Charles Elementary School o George J McIntosh Elementary School o James River Elementary School o JM Dozier Middle School o Lee Hall Elementary School o Menchville High School o General Stanford Elementary School o Gilead Christian Academy o Yorktown Middle School o Oliver C Greenwood Elementary School o Richneck Elementary School o Mary Passage Middle School o Denbigh High School o First Baptist Church Denbigh o Sanford Elementary School o RO Nelson Elementary School o Woodside High School x

Individuals with Access and Functional Needs Population: According to the 2012 ETE, less than 5% of the SPS plume exposure pathway EPZ population have self-identified as homebound special needs or transportation-dependent individuals, thus requiring special assistance during an evacuation. These individuals have been and continue to be identified on an annual basis by the local emergency management offices through the annual mailing of emergency public information. These self-identified individuals will be alerted and notified of an emergency in-person.

Further, this report assumes that those who are hearing impaired would unlikely be participating in recreational activities absent the presence of friends or family with normal hearing; therefore, it is reasonable to conclude that an alerting signal would be relayed to these hearing-impaired individuals. For non-English speaking individuals, according to LEP.gov, the total LEP population in the SPS plume exposure pathway EPZ is at or below 5%. IPAWS-WEA supports both English and Spanish language messaging in a single alert. This report assumes foreign languages is not a barrier in providing an alert signal to non-English speaking individuals.

Based on the 2003 National Assessment of Adult Literacy data, (https://nces.ed.gov/naal/estimates/StateEstimates.aspx) below are the percentages of literate residents in the 5 Virginia counties that makeup the SPS plume exposure pathway EPZ:

o City of Newport News-88%

o City of Williamsburg-92%

o Surry County-83%

o Isle of Wight County-89%

o James City County-93%

o York County-94%

Interoperability The primary ANS sub-systems, IPAWS-WEA and IPAWS-EAS, are activated simultaneously using the Primary IPAWS-compliant CAP Alert Origination Tool. This Tool provides the interface for

Alert and Notification System Evaluation Report Surry Power Station Section 2: Design Report 20 If IPAWS-OPEN is unavailable, the VDEM Public Notification System, hosted on the same vendor platform as the Primary IPAWS-compliant CAP Alert Origination Tool, is available to disseminate alert and notification messages by sending a text-to-speech message to telephones within a defined geographical area. The VDEM Public Notification System database is updated on a monthly basis.

Figure 3: VDEM and SPS ANS Primary and Backup ANS Infrastructure Operations The Primary and Alternate IPAWS-compliant CAP Alert Origination Tools are used for disseminating IPAWS-WEA and IPAWS-EAS messages. Both tools are web-based and can be activated by authorized users using multiple remote modes including laptops or mobile phones.

Both IPAWS-compliant CAP Alert Origination Tools are highly reliable, scalable, and secure platform for critical event management.

Management/Administration VDEM has operational responsibility of the primary and backup ANS sub-systems, as well as responsibility for management, administration, maintenance, applicable testing, and repair of the systems. System documentation is maintained by VDEM.

Security and Privacy x

Physical Security: IPAWS-WEA, IPAWS-EAS, and the VDEM Public Notification System messages are sent from the SAU, which is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week. Access into the SAU is physically and administratively restricted and limited to authorized VEST personnel. If a visitation is justified, visitors must sign-in to a visitor log and obtain a security badge. Visitors are continuously supervised while within the SAU.

x Logical/Cyber Security: Logical/cyber security is used to secure the Primary and Alternate IPAWS-compliant CAP Alert Origination Tools. The VDEM Public Notification System database information is stored on the Primary IPAWS-compliant CAP Alert Origination Tools secure server. The database is stored on secure, non-publicly

Alert and Notification System Evaluation Report Surry Power Station Section 2: Design Report 21 accessible servers within redundant data centers. User access to both systems is secured by username/password for personnel who are qualified and responsible for sending notifications. User administration access is strictly limited to those VDEM personnel who are qualified and responsible for administrative functions, which further safeguards information.

The security framework for the Primary and Alternate IPAWS-compliant CAP Alert Origination Tools are based on current CAP security requirements/technical specifications and FEMA IPAWS Program guidance, as set by FEMA IPAWS Program Management Office. IPAWS-WEA and IPAWS-EAS messages include digital signatures that guarantee credible end-to-end authentication. Messages cannot be tampered with after they are disseminated. Additionally, both Primary and Alternate IPAWS-compliant CAP Alert Origination Tools adhere to existing VITA policies.

Maintenance/Repair x

Preventative Maintenance: VDEM contracts with two IPAWS-compliant CAP Alert Origination Software Providers, one of which hosts the VDEM Public Notification System, to perform routine preventative maintenance. For both the Primary and Alternate IPAWS-compliant CAP Alert Origination Tools, a notice is emailed in advance to VDEM SAUs generic email inbox, notifying the agency of the day and timeframe of the preventative maintenance work.

Additionally, VITA performs routine preventive maintenance on the Commonwealths LAN and equipment.

IPAWS and phone carriers are overseen and monitored by FEMA and the FCC.

x Corrective Maintenance: VDEM will contact the applicable IPAWS-compliant CAP Alert Origination Software Provider to troubleshoot any issues with the Primary and/or Alternate IPAWS-compliant CAP Alert Origination Tool. A trouble ticket will be logged into the SAU Equipment Outage Log in WebEOC.

If issues arise with the Commonwealths LAN and/or equipment, VITA will communicate and work with VDEM IT to resolve issues.

Availability/Reliability IPAWS is reported by FEMA to have a 94 percent or greater reliability/availability.

The Primary IPAWS-compliant CAP Alert Origination Tool guarantees 99.99 percent transactional uptime across 15+ data centers, with 24x7 system testing and monitoring, and organized with geo-redundancy and managed by two Network Operations Centers (NOCs) and 24/7 support teams.

The Alternate IPAWS-compliant CAP Alert Origination Tool is a hybrid system that can operate on internet servers and satellite signal. Additionally, the Alternate IPAWS-complaint CAP Alert Origination Tool has two satellites to carry data, fully redundant uplink facilities physically separated, 24/7 365 monitoring of all network infrastructure, and multiple data centers and service clusters.

Alert and Notification System Evaluation Report Surry Power Station Section 2: Design Report 22 VDEM SAU maintains two internet service providers (terrestrial and cellular hotspot) that provide an uptime of essential 100% due to a redundant internet system infrastructure. If for some reason terrestrial internet availability is unavailable, VDEM has cellular hotspot capability to assure internet connectivity is maintained.

Testing IPAWS-WEA and IPAWS-EAS system performance, availability, and reliability is tested and verified on a periodic basis by frequencies and methods established by Federal Regulations and Code. In addition, IPAWS-WEA and IPAWS-EAS are used on a routine basis. For example, during the calendar years January 1, 2018 through January 1, 2021, VDEM SAU initiated 6 IPAWS-WEA and IPAWS-EAS messages. The breadth and scope of these real-world all-hazard notifications confirm ANS adequacy, functionality, interoperability, and enhance public confidence. Therefore, no additional periodic testing is required for IPAWS-WEA and IPAWS-EAS as a result of being included in the SPS ANS Design Report. ANS will be assessed during biennial exercises in accordance with appropriately developed Exercise Evaluation Guides (EEGs) for ANS Objective and Capability Targets.

Quality Assurance Annually, VDEM, with support from Dominion Energy as requested, conducts an audit of IPAWS-WEA, IPAWS-EAS, and the VDEM Public Notification System, verifying the following are maintained and/or completed:

x VDEM IPAWS certification; x

System training; x

Tier 1 cell carrier coverage maps; and x

Monthly database refresh of SPS plume exposure pathway EPZ resident telephone numbers into the VDEM Public Notification System.

Refer to Attachment 3: Draft Annual ANS Audit.

Description/Performance Physical Requirements x

System Components of IPAWS-WEA, IPAWS-EAS, and VDEM Public Notification System:

Alert and Notification System Evaluation Report Surry Power Station Section 2: Design Report 24 Figure 4: Organizational Chart x

Management: The Governor of Virginia, or his/her designate, administers and provides ultimate oversight for IPAWS-WEA, IPAWS-EAS, and the VDEM Public Notification System. IPAWS-WEA and IPAWS-EAS messages are sent from the SAU, by personnel trained and qualified to operate these systems. The SAU is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, seven days per week. SAU personnel are available to activate the primary and/or backup ANS at any time.

Operational Components x

Activation: The decision to activate the ANS is made by VDEM. Both the primary and backup ANS are activated by VDEM in accordance with the Virginia Radiological Emergency Preparedness Plan (Technical Support Document). Activation of the ANS is performed by qualified SAU personnel, per VDEMs established IPAWS-WEA and IPAWS-EAS activation procedures.

Governor of Virginia State Coordinator of Emergency Management VDEM Planning Division Director VDEM Operational Planning Branch Chief (Planning, Operations, Testing)

SAU Personnel VDEM Information Technology Director Assigned VDEM IT Representative (Maintenance)

IPAWS-Complaint CAP Alert Origination Tool Vendor (Maintenance, Training, Testing)

Alert and Notification System Evaluation Report Surry Power Station Section 2: Design Report 25 The primary method SAU uses for transmitting an IPAWS-WEA and IPAWS-EAS messages is through IPAWS-compliant CAP Alert Origination Tools, which are always open and operational to receive and transmit messages, and constantly monitored by SAU personnel. IPAWS-WEA and IPAWS-EAS messages are pre-scripted for prompt ANS activation.

The backup ANS will be activated concurrently with the primary ANS, which is outlined in VDEMs established IPAWS-WEA and IPAWS-EAS activation procedures. Reference : Relevant Virginia Radiological Emergency Response Plan (Technical Support Document) Appendices and Procedures.

x Timing: IPAWS-WEA meets the 15-minute timing requirement, per 2018 National WEA Test After Action Report.

x Geo-Targeting: IPAWS is currently using Federal Information Processing Standard (FIPS) Code and Polygon. The VDEM Public Notification System works for 100 percent of the counties, based on the inputted data into the system.

Verification Verification of ANS sub-systems design report requirements is accomplished through the annual audit. The audit captures the verification documentation / process for how each ANS design requirement is verified (e.g., via inspections, demonstrations, analysis, studies, reports, documentation/maintenance logs, etc.).

x Coverage: Verification of ANS coverage is verified through the annual ANS audit. This audit verifies the following are maintained and/or completed (reference Attachment 3:

Draft Annual Audit):

VDEM IPAWS certification; System training; Tier 1 cell carrier coverage maps; and Monthly database refresh of SPS plume exposure pathway EPZ resident telephone numbers into the VDEM Public Notification System.

x Population/Demographics: Population and demographic information is relied upon data from the 2010 United States Census.

x Metrics: These systems use data provided by a third party (FEMA, cellular phone companies, official U.S census data, etc.). No additional metrics are necessary.

Availability/Reliability According to FEMA reports, IPAWS operates at a 94 percent or greater reliability/availability.

Changes in IPAWS availability/reliability is reported by FEMA and verified during the annual audit.

EAS is overseen and monitored by the FCC and FEMA.

Alert and Notification System Evaluation Report Surry Power Station Section 2: Design Report 26 Security and Privacy x

Physical Security: IPAWS-WEA, IPAWS-EAS, and the VDEM Public Notification System messages are sent from the SAU, which is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week. Access into the SAU is physically and administratively restricted and limited to VEST personnel. If a visitation is justified, visitors must sign-in to a visitor log and obtain a security badge. Visitors are continuously supervised while within the SAU.

x Logical/Cyber Security: Logical/cyber security is used to secure the Primary and Alternate IPAWS-compliant CAP Alert Origination Tools. The VDEM Public Notification System database information is stored on the Primary IPAWS-compliant CAP Alert Origination Tools secure server. The database is stored on secure, non-publicly accessible servers within redundant data centers. User access to both systems is secured by username/password for personnel who are qualified and responsible for sending notifications. User administration access is strictly limited to those VDEM personnel who are qualified and responsible for administrative functions, which further safeguards information.

The security framework for the Primary and Alternate IPAWS-compliant CAP Alert Origination Tools are based on current CAP security requirements/technical specifications and FEMA IPAWS Program guidance, as set by FEMA IPAWS Program Management Office. IPAWS-WEA and IPAWS-EAS messages include digital signatures that guarantee credible end-to-end authentication. Messages cannot be tampered with after they are disseminated. Additionally, both Primary and Alternate IPAWS-compliant CAP Alert Origination Tools adhere to existing VITA policies.

Training and Public Outreach Training has been completed for IPAWS Alerting Authority through online training from FEMA EMI. Additional training has been provided on how to use IPAWS-OPEN, which is necessary to interface between the Alerting Authority and the alert distribution channels, as well as other recommended or required software provider/vendor-developed system trainings identified by VDEM. This training is provided to all authorized personnel with access to the system (reference : Relevant Virginia Radiological Emergency Response Plan [Technical Support Document] Appendices and Procedures).

VDEM determines and maintains sufficient numbers of trained individuals to operate the ANS sub-systems. SAU staff complete IPAWS training (IS-247 Integrated Public Alert and Warning System) through the FEMA Emergency Management Institute (EMI) and other recommended or required software provider/vendor-developed system trainings identified by VDEM as deemed necessary and applicable. VEOC SAU staff also gain practical experience during the initial training, scheduled testing, and real-world emergencies.

To educate the public on the emergency notification process and actions to take in the event of a radiological emergency, SPS distributes public information materials to all residents, businesses, schools, and transient populations within the SPS plume exposure pathway EPZ on an annual basis. These informational materials include pertinent information for the public to know in an emergency, including what actions to take in the event the public receives an IPAWS-WEA message and identification of local radio and television stations for the public to access additional information related to the emergency.

Alert and Notification System Evaluation Report Surry Power Station Section 2: Design Report 27 In addition to annually distributed public information materials, incorporating IPAWS-WEA as the primary alerting method enables SPS and the state and local agencies to promptly convey emergency information in the most efficient and maximal manner to individuals in the SPS plume exposure pathway EPZ. IPAWS-WEA allows the transient population to receive the same public information and instruction received by local residents, rather than being limited to condensed versions of emergency information posted in recreational/public areas and at local businesses on how to appropriately respond to alerts and take action in an emergency (i.e.,

what to do when you hear an alert and where to access additional emergency information).

Additionally, with IPAWS-WEA (the primary alerting method) and the VDEM Public Notification System (the backup alerting method) capable of alerting the public and providing public information and instruction in real time, avoids complications of recalling previous disseminated information, furthering achieving early notification and clear, prompt instruction to the public.

Alert and Notification System Evaluation Report Surry Power Station Section 3: Attachments 28 SECTION 3: ATTACHMENTS

Alert and Notification System Evaluation Report Surry Power Station Section 3: Attachments 29 Dominion Energy ATTACHMENT 1: FEMA IPAWS Architecture

Alert and Notification System Evaluation Report Surry Power Station Section 3: Attachments 31 Dominion Energy ATTACHMENT 2: VDEM and SPS Primary and Backup Alert and Notification System Infrastructure

Alert and Notification System Evaluation Report Surry Power Station Section 3: Attachments 32 Dominion Energy

Alert and Notification System Evaluation Report Surry Power Station Section 3: Attachments 33 Dominion Energy ATTACHMENT 3: Draft Annual ANS Audit

Alert and Notification System Evaluation Report Surry Power Station Section 3: Attachments 38 Dominion Energy 6.1 None 7.0 RECORDS 7.1 The following records generated by this document are non-QA records and should be retained by Corporate Emergency Preparedness for a period of five years:

7.1.1 Completed NAPS Annual ANS Audit.

7.1.2 Completed SPS Annual ANS Audit.

8.0 QUESTIONNAIRE 8.1 Verify all ANS design requirements are maintained and meet the minimum acceptable design objectives for coverage by and capability of the ANS, as well as support the capability to promptly alert and notify the public, and provide clear, accurate communication to the public in timely manner.

8.2 The verification documentation / process is the method for how the ANS design requirement was verified (e.g., via inspections, demonstrations, studies, reports, documentation/maintenance logs, etc.).

Alert and Notification System Evaluation Report Surry Power Station Section 3: Attachments 41 Dominion Energy ATTACHMENT 4: Coverage Maps for Tier 1 Cellular Carriers:

VERIZON AT&T T-MOBILE / SPRINT

Alert and Notification System Evaluation Report Surry Power Station Section 3: Attachments 42 Dominion Energy Reference for Cell Coverage Maps:

SPS Plume Exposure Pathway EPZ

Alert and Notification System Evaluation Report Surry Power Station Section 3: Attachments 45 Dominion Energy T-MobileTM and SprintTM Coverage Map, April 8, 2021**

(Source: https://www.t-mobile.com/coverage/coverage-map)

NOTES:

x Pink indicates 5G LTE coverage.

x Maroon indicates 4G LTE coverage.

x Black indicates no coverage.

x Area shown is well in excess of the NAPS plume exposure pathway EPZ. Reference NAPS plume exposure pathway EPZ map, Page 42.

    • With the Sprint and T-Mobile merger in 2020, map coverage reflects cellular coverage for both T-Mobile and Sprint.

Alert and Notification System Evaluation Report Surry Power Station Section 3: Attachments 46 Dominion Energy ATTACHMENT 5: VDEM and FEMA IPAWS Memorandum of Agreement