ML25248A265

Services, Inc., North Anna - Submittal of Early Site Permit Renewal Approach White Paper for Information Only

ML25248A265
Person / Time
Site:	North Anna, 99902135
Issue date:	09/05/2025
From:	James Holloway Dominion Energy Services
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
25-216
Download: ML25248A265 (1)

Text

Dominion Energy Services, Inc.

5000 Dominion Boulevard, Glen Allen, VA, 23060 DominionEnergy.com United States Nuclear Regulatory Commission Serial No.:

25-216 Attention: Document Control Desk NRA/JHH:

R0 Washington, DC 20555-0001 DOMINION ENERGY SERVICES, INC.

SUBMITTAL OF NORTH ANNA EARLY SITE PERMIT RENEWAL APPROACH WHITE PAPER FOR INFORMATION ONLY Dominion Energy Services, Inc. (Dominion Energy) holds North Anna Early Site Permit (ESP)-003 for a potential reactor site at North Anna Power Station in Louisa, VA.

ESP-003 is set to expire on November 27, 2027. Dominion Energy is actively pursuing renewal of the permit in accordance with the process outlined in 10 CFR 52. As the Nuclear Regulatory Commission (NRC) has not previously renewed an ESP, Dominion Energy and NRC held an observation public meeting on May 23, 2025 to discuss the companys planned approach for the ESP-003 Renewal Application (ADAMS Accession No. ML25163A118). In support of this meeting, Dominion Energy provided a draft white paper to the NRC (ADAMS Accession No. ML25134A007) to outline this approach. NRC staff offered comments on the draft white paper during the public meeting, which are described in meeting summary (ADAMS Accession No. ML25163A116). Enclosure 1 provides a final version of Dominion Energys ESP-003 renewal approach white paper for information only, which incorporates these comments as appropriate.

Should you have any questions regarding this request, please contact Adina LaFrance at 757-365-2658.

Sincerely, James E. Holloway Vice President - Nuclear Engineering and Fleet Support

Enclosure:

Dominion Energy New Nuclear, North Anna Early Site Permit Renewal Application Approach Commitments made by this letter: None

Serial No.25-216 Page 2 of 2 cc: Mr. Mahmoud Jardaneh Chief, New Reactor Licensing Branch Division of New and Renewed Licenses Ms. India Banks NRC Project Manager Licensing and Regulatory Infrastructure Branch Division of New and Renewed Licenses

White Paper North Anna Early Site Permit Application for Dominion Energy

White Paper North Anna Early Site Permit Application Dominion Energy 1

September 2025 Table of Contents Acronyms................................................................................................................................... 3 1.0 Executive Summary - White Paper ESP Renewal............................................................ 5 2.0 Key Regulatory Policy Considerations - White Paper ESP Renewal................................ 6 2.1 Introduction.................................................................................................................. 6 2.2 CFR Part 2, Subpart A, Procedure for Issuance, Amendment, Transfer, or Renewal of a License, and Standard Design Approval............................................................................ 6 2.2.1 10 CFR 2.109(c) - Effect of Timely Renewal Application:.................................... 6 2.3 10 CFR 50.47, Emergency Plans................................................................................. 6 2.3.1 10 CFR 50.47(a)(1)(iii)........................................................................................ 6 2.4 10 CFR Part 51, Environmental Protection................................................................... 7 2.4.1 10 CFR 51.20(b), Criteria Requiring Environmental Impact Statements.............. 7 2.4.2 10 CFR 51.30(a), Environmental Assessment..................................................... 7 2.4.3 10 CFR 51.50(b), Environmental Report............................................................. 8 2.4.4 10 CFR 51.91, Environmental Impact Statement................................................. 8 2.5 10 CFR 52 Subpart A, Early Site Permits..................................................................... 9 2.5.1 10 CFR 52.12, Scope of Subpart......................................................................... 9 2.5.2 10 CFR 52.13, Relationship to Other Subparts.................................................... 9 2.5.3 10 CFR 52.17, Content of Application; General Information................................ 9 2.5.4 10 CFR 52.26(a), Duration of Permit..................................................................10 2.5.5 10 CFR 52.26(b), Duration of Permit..................................................................10 2.5.6 10 CFR 52.31(a), Criteria for Renewal...............................................................11 2.5.7 10 CFR 52.33 Duration of Renewal....................................................................11 2.6 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants...................................................................................................................................12 2.6.1 10 CFR 54.4, Scope...........................................................................................12 2.6.2 10 CFR 54.19 Contents of Application - General Information............................12 2.6.3 10 CFR 54.21, Contents of Application - Technical Information.........................12 2.6.4 10 CFR 54.23, Contents of Application - Environmental Information..................13 2.6.5 10 CFR 54.29, Standards for Issuance of a Renewed License...........................13 2.6.6 10 CFR 54.31, Issuance of a Renewed License.................................................14 2.7 NUREG-1555 Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Environmental Standard Review Plan.......................................................................15 2.7.1 Guidance............................................................................................................15 2.7.2 Dominion Summary............................................................................................15

White Paper North Anna Early Site Permit Application Dominion Energy 2

September 2025 2.8 NUREG-1800 Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants...........................................................................................................15 2.8.1 Guidance............................................................................................................15 2.8.2 Dominion Summary............................................................................................15 2.9 NRC Regulatory Guide 1.188......................................................................................16 2.9.1 Guidance............................................................................................................16 2.9.2 Dominion Summary............................................................................................16 2.10 NRC Regulatory Guide 1.208.................................................................................16 2.10.1 Guidance.......................................................................................................16 2.10.2 Dominion Summary.......................................................................................17 2.11 Regulatory Issue Summary RIS 01-016, Update of Evacuation Time Estimates.....17 2.11.1 Guidance.......................................................................................................17 2.11.2 Dominion Summary.......................................................................................17 3.0 First of a Kind Regulatory Approach - White Paper ESP Renewal..................................18 3.1 Introduction.................................................................................................................18 3.2 Existing ESP-003 Conditions, Commitments, Assumptions, and Unresolved Issues...18 3.3 Summary of the Impact from NAPS Unit 3 Combined License NFP-103 (2017) and NUREG-1835 Supplement 1 on an ESP-003 Renewal.........................................................18 3.4 Use of the NAPS Units 1 and 2 Site-Specific Environmental Reports and Documents for the ESP-003 Renewal Application...................................................................................19 3.4.1 Annual Radioactive Effluent Release Reports (ARERRs)...................................19 3.4.2 Annual Radiological Environmental Operating Report (AREORs)......................19 3.4.3 Final Site-Specific EIS for Licensing Renewal Regarding Subsequent License Renewal for NAPS Units 1 and 2.....................................................................................19 3.5 Summary of the Impact from the NAPS Units 1 and 2 Emergency Plan on an ESP-003 Renewal...............................................................................................................................19 3.6 Use of Existing NAPS Information from other Regulatory Submittals for Inclusion/Exclusion into the ESP Renewal Application.........................................................19 3.7 Summary of 10 CFR Part 51 Methodologies Applied to the ESP-003 Renewal Application............................................................................................................................20 3.8 Summary of 10 CFR Part 54 Methodologies Applied to the ESP-003 Renewal Application............................................................................................................................20 3.9 Summary of NUREG-1800, NUREG-1801 Methodologies Applied to the ESP-003 Renewal Application.............................................................................................................20 4.0 ESP Permit Renewal Application Format and Content Approach.....................................21 4.1 Introduction.................................................................................................................21 4.2 Application Format......................................................................................................21

White Paper North Anna Early Site Permit Application Dominion Energy 3

September 2025 Acronyms ABWR Advanced BWR ACS American Community Survey AEA Atomic Energy Act AREOR Annual Radiological Environmental Operating Report ARERR Annual Radiological Effluent Release Report ASME American Society of Mechanical Engineers BTP Branch Technical Position CFR Code of Federal Regulations COL combined license COLA combined license application CPA construction permit application CWA Clean Water Act DBA Design Basis Accident DC Design Certification DCD design control document DWR Department of Wildlife Resources EA Environmental Assessment EAB exclusion area boundary EIS Environmental Impact Statement EJ environmental justice EP emergency plan EPRI Electric Power Research Institute EPZ emergency planning zone ER environmental report ESBWR economic simplified boiling water reactor ESP early site permit FEIS final environmental impact statement FONSI finding of no significant impact FSAR final safety analysis report GEIS Generic Impact Environmental Statement GMRS Ground Motion Response Spectrum gpm gallons per minute GT-MHR Gas Turbine Modular Helium Reactor IFIM Instream Flow Incremental Methodology IRIS International Reactor Innovative and Secure ITAAC inspections, tests, analyses, and acceptance criteria LPZ low population zone LWR light-water-cooled reactor NAPS North Anna Power Station NEI Nuclear Energy Institute NMS national marine sanctuaries NOAA National Oceanic and Atmospheric Administration

White Paper North Anna Early Site Permit Application Dominion Energy 4

September 2025 NQA National Quality Assurance NRC U.S. Nuclear Regulatory Commission ODCM Onsite Dose Calculation Manual OL Operating License PBMR Pebble Bed Modular Reactor PPE plant parameter envelope PSHA Probabilistic Seismic Hazards Analysis PWR Pressurized Water Reactor QA Quality Assurance RCTS resonant column torsional shear REMP Radiological Environmental Monitoring Program RG Regulatory Guide RFI request for Information RIS Regulatory Issue Summary ROW right-of-way SAR Safety Analysis Report SEIS Site Environmental Impact Statement SER Safety Evaluation Report SLR subsequent license renewal SLRA subsequent license renewal application SMR small modular reactor SRP standard review plan SRP-LR standard review plan for license renewal SSAR Site Safety Analysis Report SSC structures, systems, and components SSE Safe Shutdown Earthquake SSER Site Safety Evaluation Report SWPPP storm water pollution prevention plan TEDE total effective dose equivalent TR Topical Report UFSAR updated final safety analysis report USACE U.S. Army Corps of Engineers USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey VDCR Virginia Department of Conservation and Recreation VDEQ Virginia Department of Environmental Quality VDGIF Virginia Department of Game and Inland Fisheries VPDES Virginia Pollutant Discharge Elimination System VWP Virginia Water Protection

White Paper North Anna Early Site Permit Application Dominion Energy 5

September 2025 1.0 EXECUTIVE

SUMMARY

- WHITE PAPER ESP RENEWAL All nuclear power reactors are required to comply with the applicable standards and requirements of the Atomic Energy Act (AEA) of 1954 (NUREG-0980) as amended and Commission regulations as set forth in Title 10 of the Code of Federal Regulations (10 CFR).

Virginia Electric and Power Company, doing business as Dominion Virginia Power, herein referred to as Dominion or "the licensee, currently holds a combined license (COL) for North Anna Power Station (NAPS) Unit 3 at the NAPS site. The COL incorporated by reference 10 CFR Part 52, Appendix E, "Design Certification Rule for the ESBWR Design," and incorporated by reference 10 CFR Part 52, Subpart A, Early Site Permit (ESP) No. ESP-003. ESP-003 will expire on November 27, 2027. Dominion intends to submit a renewal application to extend the duration of ESP-003 for an additional 20 years.

The purpose of this white paper is to present the NRC with the Dominion position on the level of effort expected for ESP Renewal. Dominion believes that the level of effort should be similar to that required in an Environmental Report (ER) for Subsequent License Renewal Application (SLRA) and that the review should only require an Environmental Assessment (EA) and not an Environmental Impact Statement (EIS) for the North Anna Site ESP Renewal. This paper will address 10 CFR 52.26(a), Duration of Permit, requirements as well as provide a detailed feasibility study to develop an acceptable regulatory structure and address the licensing options available under the AEA for Dominions intended path forward to renew the ESP-003 permit under 10 CFR Part 52.31. This paper establishes a comprehensive outline plan to be used by Dominion to facilitate the efficient, cost-effective permit renewal of ESP-003, while minimizing NRC resources. The Dominion ESP is unique to other ESPs at this time because it is associated with an issued COL, has a recent EIS for an SLRA, and is collocated with operating nuclear plants, and as such should require less detail and use of resources for its ESP renewal application.

Section 2 of this paper examines the key regulatory policy issues and defines Dominions position with respect to the renewal of an ESP. Section 3 describes in detail the first-of-a-kind licensing approach Dominion intends to take, and Section 4 will provide the proposed formatting for the renewal application itself.

White Paper North Anna Early Site Permit Application Dominion Energy 6

September 2025 2.0 KEY REGULATORY POLICY CONSIDERATIONS - WHITE PAPER ESP RENEWAL 2.1 Introduction This section provides an overview of the alignment of the existing Title 10 regulatory framework relative to renewing an ESP. This evaluation will be of particular importance in making the permit renewal licensing process more efficient and effective and will provide the NRC with a better understanding of Dominions intended path forward. Only sections of regulations determined relevant and applicable to the Dominion permit renewal are cited herein.

2.2 CFR Part 2, Subpart A, Procedure for Issuance, Amendment, Transfer, or Renewal of a License, and Standard Design Approval 2.2.1 10 CFR 2.109(c) - Effect of Timely Renewal Application:

2.2.1.1 Regulation:

If the holder of an early site permit licensed under subpart A of part 52 of this chapter files a sufficient application for renewal under § 52.29 of this chapter at least 12 months before the expiration of the existing early site permit, the existing permit will not be deemed to have expired until the application has been finally determined.

2.2.1.2 Dominion Summary Dominion will submit the ESP renewal application in time to meet the requirements of this section.

2.3 10 CFR 50.47, Emergency Plans 2.3.1 10 CFR 50.47(a)(1)(iii) 2.3.1.1 Regulation:

If an application for an early site permit under subpart A of part 52 of this chapter includes complete and integrated emergency plans under 10 CFR 52.17(b)(2)(ii), no early site permit will be issued unless a finding is made by the NRC that the emergency plans provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

2.3.1.2 Dominion Summary Dominion intends to submit the major features of the Emergency Plan (EP) as identified in 10 CFR 52.17(b)(2)(i) as a part of the Site Safety Analysis Report (SSAR) in the ESP renewal application. Dominion does not intend to submit complete and integrated EPs as indicated in 10 CFR 52.17(b)(2)(ii) as a part of the ESP renewal application.

White Paper North Anna Early Site Permit Application Dominion Energy 7

September 2025 2.4 10 CFR Part 51, Environmental Protection 2.4.1 10 CFR 51.20(b), Criteria Requiring Environmental Impact Statements 2.4.1.1 Regulation (b) The following types of actions require an environmental impact statement or a supplement to an environmental impact statement:

(1) Issuance of a limited work authorization or a permit to construct a nuclear power reactor, testing facility, or fuel reprocessing plant under part 50 of this chapter, or issuance of an early site permit under part 52 of this chapter.

2.4.1.2 Dominion Summary The regulations do not explicitly identify the required type of environmental review to be performed by the NRC for the ESP renewal application. Considering the recent environmental licensing work on the same nuclear site property documented in NUREG-1437, Supplement 7a, Second Renewal, Dominions position is that an EA is acceptable for this effort. Site characterization requirements are expected to be reduced because the ESP is for a site within the owner-controlled area of an existing operating nuclear plant and the site has recently been characterized in the NAPS Units 1 and 2 application for renewed operating license. Considering the above, Dominions position is that preparation of an EA for the ESP renewal application would provide an adequate technical review of the environment impacts of ESP renewal and desired improvement in licensing process efficiency.

2.4.2 10 CFR 51.30(a), Environmental Assessment 2.4.2.1 Regulation (a) An environmental assessment for proposed actions, other than those for a standard design certification under 10 CFR part 52 or a manufacturing license under part 52, shall identify the proposed action and include:

(1) A brief discussion of:

(i) The need for the proposed action; (ii) Alternatives as required by section 102(2)(E) of NEPA; (iii) The environmental impacts of the proposed action and alternatives as appropriate; and (2) A list of agencies and persons consulted, and identification of sources used.

White Paper North Anna Early Site Permit Application Dominion Energy 8

September 2025 2.4.2.2 Dominion Summary The regulations do not explicitly identify the required type of environmental review to be performed by the NRC for the ESP renewal application. If the NRC concludes that an EA will be prepared for ESP renewal, Dominion intends to support the review of the EA.

2.4.3 10 CFR 51.50(b), Environmental Report 2.4.3.1 Regulation (b) Early site permit stage. Each applicant for an early site permit shall submit with its application a separate document, entitled "Applicant's Environmental ReportEarly Site Permit Stage," which shall contain the information specified in §§ 51.45, 51.51, and 51.52.

2.4.3.2 Dominion Summary Dominion intends to prepare an ER as a part of the ESP renewal application. The ER will contain the information specified in 10 CFR 51.45, 51.51, and 51.52. Because the Duration of Renewal in 10 CFR 52.33 was changed to be consistent with the NRCs regulations concerning renewal of nuclear power plant operating licenses (OLs) as specified in 10 CFR 54.31 [72 FR 49377, Aug. 28, 2007], Dominion intends to supplement the information in the ER in a manner and level of detail similar to that identified for the operating license renewal stage in 10 CFR 51.53(c).

2.4.4 10 CFR 51.91, Environmental Impact Statement 2.4.4.1 Regulation (a)(1) The final environmental impact statement will include responses to any comments on the draft environmental impact statement or on any supplement to the draft environmental impact statement.

(b) The final environmental impact statement will discuss any relevant responsible opposing view not adequately discussed in the draft environmental impact statement or in any supplement to the draft environmental impact statement and respond to the issues raised.

(c) The final environmental impact statement will state how the alternatives considered in it and decisions based on it will or will not achieve the requirements of sections 101 and 102(1) of NEPA and of any other relevant and applicable environmental laws and policies.

(d) The final environmental impact statement will include a final analysis and a final recommendation on the action to be taken.

2.4.4.2 Dominion Summary If the NRC concludes that an EIS will be prepared for ESP renewal, Dominion intends to support the review of the EIS.

White Paper North Anna Early Site Permit Application Dominion Energy 9

September 2025 2.5 10 CFR 52 Subpart A, Early Site Permits 2.5.1 10 CFR 52.12, Scope of Subpart 2.5.1.1 Regulation This subpart sets out the requirements and procedures applicable to Commission issuance of an early site permit for approval of a site for one or more nuclear power facilities separate from the filing of an application for a construction permit or combined license for the facility.

2.5.1.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.12 for the ESP renewal application.

2.5.2 10 CFR 52.13, Relationship to Other Subparts 2.5.2.1 Regulation This subpart applies when any person who may apply for a construction permit under 10 CFR part 50, or for a combined license under this part seeks an early site permit from the Commission separately from an application for a construction permit or a combined license.

2.5.2.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.13 for the ESP renewal application.

2.5.3 10 CFR 52.17, Content of Application; General Information 2.5.3.1 Regulations (a) For applications submitted before September 27, 2007, the rule provisions in effect at the date of docketing apply unless otherwise requested by the applicant in writing. The application must contain:

(1)

A site safety analysis report (xi) For applications submitted after September 27, 2007, a description of the quality assurance program applied to site-related activities for the future design, fabrication, construction, and testing of the structures, systems, and components of a facility or facilities that may be constructed on the site. Appendix B to 10 CFR part 50 sets forth the requirements for quality assurance programs for nuclear power plants. The description of the quality assurance program for a nuclear power plant site shall include a discussion of how the applicable requirements of appendix B to part 50 of this chapter will be satisfied.

(2)

A complete environmental report as required by 10 CFR 51.50 (b)

White Paper North Anna Early Site Permit Application Dominion Energy 10 September 2025 (3)

Emergency Plans (b)(2)(i) Propose major features of the emergency plans, in accordance with either the requirements in § 50.160 of this chapter, or the requirements in appendix E to part 50 of this chapter and § 50.47(b) of this chapter, as applicable, such as the exact size and configuration of the emergency planning zones, for review and approval by the NRC, in consultation with the Federal Emergency Management Agency (FEMA), as applicable, in the absence of complete and integrated emergency plans.

(b)(2)(ii) Propose complete and integrated emergency plans for review and approval by the NRC, in consultation with FEMA, as applicable in accordance with either the requirements in § 50.160 of this chapter, or the requirements in appendix E to part 50 of this chapter and § 50.47(b) of this chapter. To the extent approval of emergency plans is sought, the application must contain the information required by § 50.33(g) and (j) of this chapter.

2.5.3.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.17 for the ESP renewal application.

2.5.4 10 CFR 52.26(a), Duration of Permit 2.5.4.1 Regulation (a) Except as provided in paragraph (b) of this section, an early site permit issued under this subpart may be valid for not less than 10, nor more than 20 years from the date of issuance.

2.5.4.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.33 (Duration of Renewal) for the ESP renewal application, which differs from the requirements of 10 CFR 52.26(a). Dominion intends to request that the renewed ESP be valid for 20 years plus any remaining years on the ESP then in effect before renewal, as allowed by 10 CFR 52.33.

2.5.5 10 CFR 52.26(b), Duration of Permit 2.5.5.1 Regulation (b) An early site permit continues to be valid beyond the date of expiration in any proceeding on a construction permit application or a combined license application that references the early site permit and is docketed before the date of expiration of the early site permit, or, if a timely application for renewal of the early site permit has been docketed, before the Commission has determined whether to renew the permit.

White Paper North Anna Early Site Permit Application Dominion Energy 11 September 2025 2.5.5.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.26(b) for the ESP renewal application. Details of the expected use of existing information from recent regulatory submittals and NRC response documents associated with NAPS are provided in Section 3 of this report.

2.5.6 10 CFR 52.31(a), Criteria for Renewal 2.5.6.1 Regulation a) The Commission shall grant the renewal only if it determines that:

(1) The site complies with the Act, the Commissions regulations, and orders applicable and in effect at the time the site permit was originally issued; and (2) Any new requirements the Commission may wish to impose are:

(i) Necessary for adequate protection to public health and safety or common defense and security; (ii) Necessary for compliance with the Commissions regulations, and orders applicable and in effect at the time the site permit was originally issued; or (iii) A substantial increase in overall protection of the public health and safety or the common defense and security to be derived from the new requirements, and the direct and indirect costs of implementation of those requirements are justified in view of this increased protection.

2.5.6.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.31(a) for the ESP renewal application.

2.5.7 10 CFR 52.33 Duration of Renewal 2.5.7.1 Regulation Each renewal of an ESP may be for not less than 10, nor more than 20 years, plus any remaining years on the ESP then in effect before renewal.

2.5.7.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.33 for the ESP renewal application. Dominion intends to request that the renewed ESP be valid for 20 years plus any remaining years on the ESP then in effect before renewal.

White Paper North Anna Early Site Permit Application Dominion Energy 12 September 2025 2.6 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants 2.6.1 10 CFR 54.4, Scope 2.6.1.1 Regulation (a) Plant systems, structures, and components within the scope of this part are (1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events.

(2) All non-safety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in paragraph (a)(1) of this section.

(3) All systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61), anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63).

2.6.1.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 54.4 as applicable for the ESP renewal application, but notes that there are no systems, structures, and components (SSCs) applicable to the ESP renewal application.

2.6.2 10 CFR 54.19 Contents of Application - General Information 2.6.2.1 Regulation (a) Each application must provide the information specified in 10 CFR 50.33(a) through (e), (h),

and (i). Alternatively, the application may incorporate by reference other documents that provide the information required by this section.

(b) Each application must include conforming changes to the standard indemnity agreement, 10 CFR 140.92, Appendix B, to account for the expiration term of the proposed renewed license.

2.6.2.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 54.19.

2.6.3 10 CFR 54.21, Contents of Application - Technical Information 2.6.3.1 Regulation Each application must contain the following information:

White Paper North Anna Early Site Permit Application Dominion Energy 13 September 2025 (a) An integrated plant assessment (IPA).

(b) CLB changes during NRC review of the application. Each year following submittal of the license renewal application and at least 3 months before scheduled completion of the NRC review, an amendment to the renewal application must be submitted that identifies any change to the CLB of the facility that materially affects the contents of the license renewal application, including the FSAR supplement.

(c) An evaluation of time-limited aging analyses.

(d) An FSAR supplement. The FSAR supplement for the facility must contain a summary description of the programs and activities for managing the effects of aging and the evaluation of time-limited aging analyses for the period of extended operation determined by paragraphs (a) and (c) of this section, respectively.

2.6.3.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 54.21.

2.6.4 10 CFR 54.23, Contents of Application - Environmental Information 2.6.4.1 Regulation Each application must include a supplement to the environmental report that complies with the requirements of Subpart A of 10 CFR Part 51.

2.6.4.2 Dominion Summary Dominion intends to prepare an ER as a part of the ESP renewal application. The ER will contain the information specified in 10 CFR 51.45, 51.51, and 51.52. Because the Duration of Renewal in 10 CFR 52.33 was changed to be consistent with the NRCs regulations concerning renewal of nuclear power plant OLs as specified in 10 CFR 54.31 [72 FR 49377, Aug. 28, 2007],

Dominion intends to supplement the information in the ER in a manner and level of detail similar to that identified in Subpart A of 10 CFR 51 as specified for the operating license renewal stage in 10 CFR 51.53(c).

2.6.5 10 CFR 54.29, Standards for Issuance of a Renewed License 2.6.5.1 Regulation:

A renewed license may be issued by the Commission up to the full term authorized by § 54.31 if the Commission finds that:

(a) Actions have been identified and have been or will be taken with respect to the matters identified in Paragraphs (a)(1) and (a)(2) of this section, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in

White Paper North Anna Early Site Permit Application Dominion Energy 14 September 2025 accordance with the CLB, and that any changes made to the plant's CLB in order to comply with this paragraph are in accord with the Act and the Commission's regulations.

b) Any applicable requirements of Subpart A of 10 CFR Part 51 have been satisfied.

(c) Any matters raised under § 2.335 have been addressed.

2.6.5.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 54.29 as applicable for the ESP renewal application. Dominion intends to request that the renewed ESP be valid for 20 years plus any remaining years on the ESP then in effect before renewal, as allowed by 10 CFR 52.33.

2.6.6 10 CFR 54.31, Issuance of a Renewed License 2.6.6.1 Regulation:

(a) A renewed license will be of the class for which the operating license or combined license currently in effect was issued.

(b) A renewed license will be issued for a fixed period of time, which is the sum of the additional amount of time beyond the expiration of the operating license or combined license (not to exceed 20 years) that is requested in a renewal application plus the remaining number of years on the operating license or combined license currently in effect. The term of any renewed license may not exceed 40 years.

(c) A renewed license will become effective immediately upon its issuance, thereby superseding the operating license or combined license previously in effect. If a renewed license is subsequently set aside upon further administrative or judicial appeal, the operating license or combined license previously in effect will be reinstated unless its term has expired, and the renewal application was not filed in a timely manner.

(d) A renewed license may be subsequently renewed in accordance with all applicable requirements.

2.6.6.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 54.31 for the ESP renewal application. Dominion intends to request that the renewed ESP be valid for 20 years plus any remaining years on the ESP then in effect before renewal, as allowed by 10 CFR 52.33.

White Paper North Anna Early Site Permit Application Dominion Energy 15 September 2025 2.7 NUREG-1555 Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Environmental Standard Review Plan 2.7.1 Guidance This document provides guidance to the Nuclear Regulatory Commission (NRC) staff in implementing provisions of 10 CFR 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, related to nuclear power plants. It supersedes Environmental Standard Review Plan NUREG-1555, Vol. 1 & 2 issued in 2000. The document reflects new regulatory requirements and guidance that have appeared since 2000 and also the NRCs experience with applications for early site permits. Supplement 1 to this document should be used by the staff for review of environmental reports related to applications for renewal of nuclear power plant operating licenses.

2.7.2 Dominion Summary Dominion intends to comply with the guidance of the latest version of NUREG-1555 and NUREG-1437 as applicable for the ESP renewal application.

2.8 NUREG-1800 Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants 2.8.1 Guidance The Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) provides guidance to U.S. Nuclear Regulatory Commission (NRC) staff reviewers in the Office of Nuclear Reactor Regulation. These reviewers perform safety reviews of applications to renew nuclear power plant licenses in accordance with Title 10 CFR Part 54.

The principal purposes of the SRP-LR are to ensure the quality and uniformity of staff reviews and to present a well-defined base from which to evaluate applicant programs and activities for the period of extended operation. The SRP-LR also is intended to make regulatory information widely available to enhance communication with interested members of the public and the nuclear power industry and to improve public and industry understanding of the staff review process. The safety review is based primarily on the information provided by the applicant in a license renewal application. Each of the individual SRP-LR sections addresses (a) who performs the review, (b) the matters that are reviewed, (c) the basis for review, (d) the way the review is accomplished, and (e) the conclusions that are drawn.

2.8.2 Dominion Summary Dominion intends to comply with the guidance of the latest version of NUREG-1800 as applicable for the ESP renewal application.

White Paper North Anna Early Site Permit Application Dominion Energy 16 September 2025 2.9 NRC Regulatory Guide 1.188 2.9.1 Guidance This regulatory guide (RG) describes an approach that is acceptable to the staff of the U.S.

Nuclear Regulatory Commission (NRC) for the format and content of an application to renew or subsequently renew an NRC-issued operating license under Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. This RG endorses Revision 6 of Nuclear Energy Institute (NEI) 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54The License Renewal Rule, and NEI 17-01, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal.

2.9.2 Dominion Summary Dominion intends to comply with the guidance of the latest version of NRC Regulatory Guide 1.188 as applicable for the ESP renewal application.

2.10 NRC Regulatory Guide 1.208 2.10.1 Guidance Investigations of the site and region around the site are necessary to identify capable tectonic sources and to determine their potential for generating earthquakes and causing surface deformation. If it is determined that surface deformation need not be taken into account at the site, sufficient data to clearly justify this determination should be presented in the application for an early site permit or license. Generally, any tectonic deformation at the earths surface within the Site Area [8 km (5 mi) of the site] will require detailed examination to determine its significance. Potentially active tectonic deformation within the seismogenic zone beneath a site will have to be assessed using geological, geophysical, and seismological methods to determine its significance. Engineering solutions are generally available to mitigate the potential vibratory effects of earthquakes through design. However, engineering solutions cannot always be demonstrated to be adequate for mitigation of the effects of permanent ground displacement phenomena such as surface faulting or folding, subsidence, or ground collapse. For this reason, it is prudent to select an alternative site when the potential exists for permanent ground displacement at the proposed site (Ref. C.4).

The level of detail for investigations should be governed by knowledge of the current and late Quaternary tectonic regime and the geological complexity of the site and region. The investigations for determining seismic sources should be carried out in all the following levels, with areas described by radii of 320 km (200 mi), 40 km (25 mi), and 8 km (5 mi) and 1 km (0.6 mi) from the site. The investigations should provide increasingly detailed information as they proceed from the regional level down to the site. Whenever faults or other structures are encountered at a site in either outcrop or excavations, it is necessary to perform many of the investigations described below to determine whether or not they are capable tectonic sources.

White Paper North Anna Early Site Permit Application Dominion Energy 17 September 2025 2.10.2 Dominion Summary Dominion intends to comply with the guidance of the latest version of RG 1.208 as applicable for the ESP renewal application. It is expected that much of the information required to comply with this guidance is present in multiple recent applications and their corresponding NRC safety and environmental evaluations (e.g., the NAPS Unit 3 COL NFP-103, SLRA, SLR ER, and Site Environmental Impact Statement [SEIS]), which addressed the recent seismic event experienced at the site.

2.11 Regulatory Issue Summary RIS 01-016, Update of Evacuation Time Estimates 2.11.1 Guidance The U.S. Nuclear Regulatory Commission (NRC) is issuing this Regulatory Issue Summary (RIS) to alert addressees to the possible need to update emergency planning evacuation time estimates as the results of the year 2000 census are published. This RIS does not transmit any new requirements or staff positions. No specific action or written response is required.

2.11.2 Dominion Summary Dominion intends to consider the latest census information (2020) when determining if changes are necessary for the ESP renewal application, but does not expect significant changes to evacuation time estimates.

White Paper North Anna Early Site Permit Application Dominion Energy 18 September 2025 3.0 FIRST OF A KIND REGULATORY APPROACH - WHITE PAPER ESP RENEWAL 3.1 Introduction The regulatory guidance regarding renewal of an ESP is not precise. The requirements contained in 10 CFR 52.29 and 10 CFR 52.31, only specify that: (1) all the information that was in the original permit be updated and conforms with the Commissions regulations, and (2) that the ESP complies with orders applicable and in effect at the time the site permit was originally issued and any new orders or regulations as deemed necessary by the Commission.

Dominion intends to take a conservative path forward and renew ESP-003 with the intent to keep the renewed version available for possible reference in a different future combined license application (COLA) or Construction Permit Application (CPA) at the NAPS site.

3.2 Existing ESP-003 Conditions, Commitments, Assumptions, and Unresolved Issues Dominion intends to review all of the conditions incorporated by amendments through ESP-003 Amendment 3. Dominion will evaluate the ESP-003 assumptions to determine if they are still valid and review the unresolved issues to determine if they require modifications as part of the submission of the ESP renewal. Conditions that are no longer applicable, or if in Dominions opinion require modifications or deletion, may be addressed under 10 CFR 50.90.

3.3 Summary of the Impact from NAPS Unit 3 Combined License NFP-103 (2017) and NUREG-1835 Supplement 1 on an ESP-003 Renewal The NAPS Unit 3 COL references specific technologies and methods of compliance with NRC regulations and conformance to NRC RGs and industry codes based on the ESBWR design.

The COL contains specific additional departures, variances, exemptions, and proposed license conditions (NFP-103 Part 7 and Part 10 respectively). In NUREG-1835, Supplement 1, the staff based their acceptance and made specific conclusions with respect to the COL based on the COLs and ESP-003 content. Where Dominion intends to use NRC-approved information from the COL for the ESP renewal application, Dominion will perform a gap analysis to determine which, if any, technology-based compliances and conformances are required to be removed or modified from the ESP renewal application. Dominion will review and evaluate NUREG-1835, Supplement 1, to determine the information that was relied upon by the NRC for the safety evaluation, as well as proposed license conditions based on the specific technologies described in the COL. License conditions that are no longer applicable or, if in Dominions opinion, require modifications or deletion, may be addressed under 10 CFR 50.90 or other appropriate approach if the license condition in the COL is applicable to the ESP.

White Paper North Anna Early Site Permit Application Dominion Energy 19 September 2025 3.4 Use of the NAPS Units 1 and 2 Site-Specific Environmental Reports and Documents for the ESP-003 Renewal Application Dominion will review the contents of the NAPS Unit 1 and Unit 2 site-specific Environmental Report and its associated SEIS and incorporate by reference relevant information into the ESP permit renewal application.

3.4.1 Annual Radioactive Effluent Release Reports (ARERRs)

The latest available ARERRs will be reviewed, and any applicable information will be incorporated into the ESP renewal application.

3.4.2 Annual Radiological Environmental Operating Report (AREORs)

The latest available AREORs will be reviewed, and any applicable information will be incorporated into the ESP renewal application.

3.4.3 Final Site-Specific EIS for Licensing Renewal Regarding Subsequent License Renewal for NAPS Units 1 and 2 Dominion will follow the requirements denoted in 10 CFR Part 51 to develop a site-specific ER for the ESP-003 renewal application. After an evaluation, Dominion may incorporate by reference data that was previously submitted to the NRC in recent regulatory submittals and their associated safety evaluations and environmental impact statements.

3.5 Summary of the Impact from the NAPS Units 1 and 2 Emergency Plan on an ESP-003 Renewal Since the North Anna ESP-003 applies to the site where currently operating NAPS Units 1 and 2 are co-located, Dominion will review the emergency planning documents to determine the extent that the Unit 1 and 2 EP should be referenced or depended upon in lieu of preparing a stand-alone EP submittal for the ESP renewal application. Dominion will ensure that the basis documents of the existing EP have been reviewed against current NRC requirements and industry guidance.

3.6 Use of Existing NAPS Information from other Regulatory Submittals for Inclusion/Exclusion into the ESP Renewal Application Dominion will review recent regulatory submittals and their associated safety evaluations and environmental impact statements to determine if any information from these sources should be included or referenced in the ESP renewal application. This review will consider the appropriateness of the information for inclusion into the ESP renewal application. Specifically, Dominion will determine if any information being considered for reference or inclusion from other submittals could be incorporated by reference and/or meet the new and significant threshold.

White Paper North Anna Early Site Permit Application Dominion Energy 20 September 2025 3.7 Summary of 10 CFR Part 51 Methodologies Applied to the ESP-003 Renewal Application Activities associated with 10 CFR Part 51 will be included in the proposed ESP-003 renewal application. Dominion will follow the requirements denoted in the regulation to develop a site-specific ER for the proposed ESP-003 renewal application. Dominion may incorporate by reference data that was previously submitted to the NRC in recent regulatory submittals and their associated safety evaluations and environmental impact statements.

3.8 Summary of 10 CFR Part 54 Methodologies Applied to the ESP-003 Renewal Application Dominions proposed ESP-003 renewal application does not fall under the jurisdiction of 10 CFR Part 54. This regulation only governs the issuance of renewed OLs and renewed COLs pursuant to Sections 103 or 104b of the AEA of 1954. The renewal of an ESP permit is governed by 10 CFR 52, Subpart A.

3.9 Summary of NUREG-1800, NUREG-1801 Methodologies Applied to the ESP-003 Renewal Application Dominion will utilize Nuclear Energy Institute (NEI) 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, as guidance.

The development of the format and content of the ESP renewal application will be described in Section 4.0.

White Paper North Anna Early Site Permit Application Dominion Energy 21 September 2025 4.0 ESP PERMIT RENEWAL APPLICATION FORMAT AND CONTENT APPROACH 4.1 Introduction Dominion is seeking to renew ESP-003. As detailed in ESP-003, Dominion has selected a site but has not yet finalized a choice of technology and has not yet committed to the COLA process. Dominion is evaluating long-term generation and intends to reserve the NAPS site for possible future development. Because the North Anna ESP-003 was reviewed and approved by the NRC, Dominion believes that the timeframe for the ESP permit renewal preparation and NRC review should be much shorter than for a new ESP. The value of renewing the ESP permit is tied to the early resolution of siting issues that can then be utilized in future licensing applications.

4.2 Application Format For the purposes of the proposed North Anna ESP-003 permit renewal application, Dominion will follow a modified version that incorporates the guidance in NEI 95-10, Revision 3, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule Section 6.2, and includes the guidance in NEI 08-03, Revision 0, Lessons Learned from Initial Early Site Permit Experience. The following will be the format and content of the ESP renewal application:

Table of Contents Part 1: Administrative Section Part 2: Site Safety Analysis Part 3: Environmental Report Part 4: Programs and Plans Part 5A: Emergency Plan (Site Boundary EPZ)

Part 6: Exemptions and Departures Appendices:

Appendix A - Summary of Proposed License Conditions, Assumptions and Unresolved Issues Appendix B - Summary of ESP-003 Gap Analyses and Evaluations Appendix C - Acronyms/Abbreviations/Initialisms Appendix D - References Appendix E - List of Figures Appendix F - Lists of Tables