ML022210143
| ML022210143 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/30/2002 |
| From: | Hartz L Virginia Electric & Power Co (VEPCO) |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 02-320, 67FR31960 00002, NUREG-1437 | |
| Download: ML022210143 (15) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 30, 2002
.J Chief Serial No.: 02-320 LR/LTB RO Rules and Directives Branch Mailstop T-6D 59 Docket Nos.: 50-338/339 United States Nuclear Regulatory Commission License Nos.: NPF-4/7 Washington, DC 20555-0001 67K5'5 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
NORTH ANNA POWER STATION UNITS 1 AND 2 LICENSE RENEWAL APPLICATION RESPONSE TO REQUEST FOR COMMENT ON THE DRAFT PLANT-SPECIFIC SUPPLEMENT 7 TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT In a letter dated April 19, 2002, the NRC provided Virginia Electric and Power Company (Dominion) a draft supplement environmental impact statement (SEIS) regarding license renewal of North Anna Power Station, Units 1 and 2. This draft SEIS is the draft plant-specific Supplement 7 to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants and was provided for review and comment.
Attached are our comments on the draft SEIS.
Dominion considers the draft SEIS to be an accurate and factual representation of the environmental conditions associated with plant operation during the license renewal period. Furthermore, we concur with the conclusions of the NRC that any environmental impacts associated with license renewal would be of small significance and that any adverse environmental impacts of license renewal would be smaller than those of other reasonable energy alternatives. Dominion specifically concurs with the NRC's topic discussions and conclusions presented in the draft SEIS.
Should you have any questions regarding this submittal, please contact Mr. J. E.
Wroniewicz at (804) 273-2186.
Very truly yours, VC Hart Leslie N.
Vice President - Nuclear Engineering Attachment A2/I -) 3 Commitments made in this letter: None e 1 c 7 / 9 6 ,k (&
Serial No.: 02-320 NAPS LR - Response to Request for Comment cc page 1 of 4 cc:
U. S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, GA 30303-8931 Mr. M. J. Morgan NRC Senior Resident Inspector North Anna Power Station Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station Mr. J. E. Reasor, Jr.
Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.
Suite 300 Glen Allen, VA 23060 Ms. Ellie Irons, EIR Program Manager Virginia Dept. of Environmental Quality 629 East Main St., 6th FI Richmond, VA 23219 Mr. David Paylor, Program Coordinator Virginia Dept. of Environmental Quality P.O. Box 10009 Richmond, VA 23240-0009 Mr. Joe Hassell, Environmental Manager Virginia Dept. of Environmental Quality Water Division P.O. Box 10009 Richmond, VA 23240-0009
Serial No.: 02-320 NAPS LR - Response to Request for Comment cc page 2 of 4 Mr. Frank Daniel, Regional Director Virginia Dept. of Environmental Quality Tidewater Regional Office 5636 Southern Blvd.
Virginia Beach, VA 23462 Mr. Gregory Clayton, Regional Director Virginia Dept. of Environmental Quality Northern Virginia Regional Office 13901 Crown Ct.
Woodbridge, VA 22193 Mr. Frank Fulgham, Program Manager Virginia Dept. of Agriculture & Consumer Services Office of Plant & Pest Services 1100 Bank St.
Richmond, VA 23219 Mr. David Brickley, Agency Director Virginia Dept. of Conservation & Recreation 203 Governor St.
Richmond, VA 23219 Mr. William Woodfin, Director Virginia Dept. of Game & Inland Fisheries 4010 West Broad St.
Richmond, VA 23230 Mr. Robert Hicks, Director Virginia Dept. of Health Office of Environmental Health Services 1500 East Main St., Room 115 Richmond, VA 23219 Ms. Kathleen S. Kilpatrick, Director Virginia Dept. of Historic Resources State Historic Preservation Office 2801 Kensington Ave.
Richmond, VA 23221
Serial No.: 02-320 NAPS LR - Response to Request for Comment cc page 3 of 4 Dr. Ethel Eaton, Archeologist Senior Virginia Dept. of Historic Resources State Historic Preservation Office 2801 Kensington Ave.
Richmond, VA 23221 Mr. Robert W. Grabb, Assistant Commissioner Virginia Marine Resources Commission 2600 Washington Ave.
Newport News, VA 23607 Dr. John Olney, Associate Professor Virginia Institute of Marine Science School of Marine Science Gloucester Point, VA 23062 Mr. John Simkins Virginia Dept. of Transportation Environmental Division 1401 East Broad St.
Richmond, VA 23219 Mr. Robert Burnley Virginia Economic Development Partnership 901 East Byrd St.
Richmond, VA 23219 Mr. William F. Stephens, Director Virginia State Corporation Commission Division of Energy Regulation 1300 East Main St., 4 Fl., Tyler Bldg.
Richmond, VA 23219 Mr. Michael Cline, State Coordinator Commonwealth of Virginia Department of Emergency Management 10501 Trade Rd.
Richmond, VA 23236-3713 Mr. Terry Lewis, County Administrator P.O. Box 65 Surry, VA 23883
Serial No.: 02-320 NAPS LR - Response to Request for Comment cc page 4 of 4 Mr. Lee Lintecum Louisa County Administrator P.O. Box 160 Louisa, VA 23093 Mr. Douglas C. Walker Acting Spotsylvania County Administrator P.O. Box 99 Spotsylvania, VA 22553 Ms. Brenda G. Bailey, County Administrator P.O. Box 11 Orange, VA 22960 Chairman Reeva Tilley Virginia Council on Indians P.O. Box 1475 Richmond, VA 23218 Mr. Don Lillywhite, Director Economics Information Services Virginia Employment Commission State Data Center 703 East Main St., Room 213 Richmond, VA 23219 Mr. Alan Zoellner Government Information Department Swem Library College of William and Mary Landrum Dr.
P.O. Box 8794 Williamsburg, VA 23187-8794 Mr. Walter Newsome Government Information Resources Alderman Library University of Virginia 160 McCormick Rd.
P.O. Box 400154 Charlottesville, VA 22904-4154
SN: 02-320 Docket Nos.: 50-338/339
Subject:
LRA - Response to Request for Comment Draft Plant-Specific Supp. 7 to the GElS COMMONWEALTH OF VIRGINIA )
)
COUNTY OF HENRICO
)
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Engineering, of Virginia Electric and Power Company. She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.
Acknowledged before me this 30th day of July, 2002.
My Commission Expires: March 31, 2004.
"NotaryPublic (SEAL)
Docket Nos. 50-338/339 Serial No.: 02-320 Attachment Page 1 of 9 Attachment License Renewal - Response to Request for Comment Draft Plant-Specific Supplement 7 to the GElS Serial No.02-320 North Anna Power Station, Units 1 and 2 License Renewal Application Virginia Electric and Power Company (Dominion)
Docket Nos. 50-338/339 Serial No.: 02-320 Attachment Page 2 of 9 Section 1.5 Compliance and Consultations Page 1-9, Line 8:
Draft GElS Statement:
Table 1-1 indicates that the US Fish & Wildlife Service Migratory Bird Treaty Act Permit expired December 31, 2001.
Dominion Comment:
Depredation Permit Number MB705136-0 was renewed effective 4/22/02, and expires 3/31/03. It is suggested that this update be reflected in Table 1-1.
Section 2.1.5 Non-radioactive Waste Systems Page 2-12, Line 34:
Draft GElS Statement:
The statement is made that, "An onsite solvent shop recycles paint."
Dominion Comment:
The following correction is suggested as a replacement: "An onsite paint shop recycles solvent."
Comment 3:
Section 2.1.5 Non-radioactive Waste Systems Page 2-13, Line 2:
Draft GElS Statement:
The statement is made that, "Non-radioactiveliquid waste produced ... (e.g., water treatment activities, stormwaterrunoff, housekeeping wastes) are sampled and treated
Docket Nos. 50-338/339 Serial No.: 02-320 Attachment Page 3 of 9 Dominion Comment:
The statement is not accurate without exception. It is suggested that "housekeeping wastes" be deleted from this statement since there are waste disposal processes in which not all "housekeeping wastes" are sampled.
Comment 4:
Section 2.2.3 Water Quality Page 2-17, Line 29:
Draft GElS Statement:
It is stated that "The US EPA has authorized VDEQ to implement NPDES within the State.".
Dominion Comment:
It is suggested that the statement read "The US EPA has delegated implementation of NPDES to VDEQ within the Commonwealth of Virginia." to reflect the actual federal to-state relationship.
Section 2.2.4 Air Quality Page 2-18, Line 14:
Draft GElS Statement:
It is stated "... the annualaverage wind power rated as 1 on a scale of 1 to 7 (Elliott, et al. 1987).
Dominion Comment:
It is suggested that the following words be inserted " ... on a scale of 1 to 7, with 1 being the lowest ... " prior to the reference callout.
Docket Nos. 50-338/339 Serial No.: 02-320 Attachment Page 4 of 9 Section 2.2.5 Aquatic Resources Page 2-22, Lines 21-22, Table 2-2:
Draft GElS Statement:
The slippershell mussel (Alasmidonta viridis) is given as a Federal-listedspecies.
Dominion Comment:
Based on a 2002 review of the Virginia Fish & Wildlife Information Service web site for the slippershell mussel, this species only occurs in the extreme western part of the Commonwealth of Virginia. It is not considered to occur in streams in counties adjacent to Lake Anna, immediately upstream or downstream North Anna River, or in counties crossed by North Anna transmission line corridors. Table 2-1 of the License Renewal Application Environmental Report does not list this species as a species of concern, and the description of this species within the SEIS implies it is of potential concern for the area in which North Anna Power Station is located. It is therefore requested that this species be deleted from the SEIS.
Commnift7:
Section 2.2.6 Terrestrial Resources Page 2-24, Table 2-3, and Page 2-25, Lines 4-7:
Draft GElS Statement:
The sensitive joint-vetch is listed in Table 2-3 and discussed on Page 2-25, yet stated "It is not known to occur at North Anna or the transmission line rights-of-way.".
Dominion Comment:
Based on a review of the Virginia Fish & Wildlife Information Service web site for the sensitive joint-vetch, this species is only located along tidally-influenced fresh waters.
This is not the case for North Anna, near Lake Anna, nor for any transmission line corridors for North Anna Power Station. The description of this species within the SEIS implies it is of potential concern for the area in which North Anna Power Station is located. It is therefore requested that the listing and discussion of this species be deleted from the SEIS.
Docket Nos. 50-338/339 Serial No.: 02-320 Attachment Page 5 of 9
-ommrnt ,
Section 2.2.8.1 Housinq Page 2-28, Line 50:
Draft GElS Statement:
It is stated that "Louisa County is currently updating its plan (VEPCo 200 1b)."
Dominion Comment:
Louisa County approved an updated Louisa County Comprehensive Plan in September 2001, referenced on Page 2-51, Lines 33-34. This statement should be updated accordingly.
C&mment 9:
Section 2.2.8.1 Housinq Page 2-30, Table 2-7:
Draft GElS Statement:
Table 2-7 is titled "PopulationGrowth ... 1980-2010". Population data includes Richmond City & County.
Dominion Comment:
It is suggested the title read "Estimated Population Growth ... ". Population data given in Table 2-7 varies from the License Renewal Application Environmental Report due to the inclusion of Richmond City & County. Richmond County is not located in the population zone for consideration.
Comment 10:
Section 2.2.8.2 Public Services, Water Suppiy Page 2-30, Lines 21-22:
Docket Nos. 50-338/339 Serial No.: 02-320 Attachment Page 6 of 9 Draft GElS Statement:
It is stated that Henrico County provides water to approximately80,215 customers.
Dominion Comment:
The License Renewal Application Environmental Report stated 74,000 customers, and the Draft SEIS references the ER. We cannot substantiate the source of the SEIS number and suggest that the number be revised to reflect the LRA ER identified number of customers, or the source of the SEIS number specified.
mm ntt.i1:
Section 2.2.8.2 Public Services, Water Supply Page 2-30, Line 30:
Draft GElS Statement:
It is stated that the maximum capacity of the City of Richmond is 128 MGD.
Dominion Comment:
The License Renewal Application Environmental Report stated the maximum capacity at 132 MGD. We cannot substantiate the source of the SEIS number and suggest that the number be revised to reflect the LRA ER number, or the source of the SEIS number specified.
C0mment 12:
Section 4.6.1 Aquatic Species Page 4-42, Line 23:
Draft GElS Statement:
It has been determined that impacts "... would be SMALL, ... "
Dominion Comment:
Docket Nos. 50-338/339 Serial No.: 02-320 Attachment Page 7 of 9 It is requested that the following words be added to the above sentence to be consistent with Endangered Species Act wording and Surry Draft SEIS conclusion statements:" ... would be SMALL and would not be adversely affected, ..
Com.me"t 61-3:
Section 4.7.1 Evaluation of Potential New and Significant Information Received from the FWS Chesapeake Bay Field Office Page 4-44, Lines 24-27:
Draft GElS Statement:
It is written that the NRC staff will inform VEPCo of comments provided by FWS and recommend further dialogue.
Dominion Comment:
It is requested that this statement be changed to reflect recent discussions regarding this issue and the final course of action as determined by the NRC staff. We recommend that the April 30, 2002 correspondence from NRC to FWS be referenced for completeness.
o mment 14:
Section 5.2.6.1 VEPCo Evaluation Page 5-22, Line 32:
Draft GElS Statement:
There is a "?"providedin the APE formula.
Dominion Comment:
The question mark "T' should be a "delta symbol" in the APE formula.
Comment 15:
Section 5.2.6.1 VEPCo Evaluation
Docket Nos. 50-338/339 Serial No.: 02-320 Attachment Page 8 of 9 Page 5-23, Line16:
Draft GElS Statement:
It is written that "This higher value is primarily due to the high frequency of SGTRs ... .
Dominion Comment:
It is requested that the words "frequency of" be replaced with "contribution to CDF from".
Section 8.2.3.1 Once-Through Cooling System Page 8-35, Lines 24-35:
Draft GElS Comment:
It is written that "Approximately200 ha (500 ac) would be needed for the construction of the new plant."
Dominion Comment:
Since the initial Final Environmental Statement for North Anna Power Station was written for four units, it should be summarized that no additional land may be needed for construction of a new plant.
Comment 17:
Section 9.1.2 Irreversible or Irretrievable Resource Commitments Page 9-6, Lines 20-21:
Draft GElS Statement:
It is written that "The most significant resource commitments related to operation during the renewal term are the fuel and the permanent storage space."
Dominion Comment:
Docket Nos. 50-338/339 Serial No.: 02-320 Attachment Page 9 of 9 It is our presumption that "permanent storage space" refers to a national repository. In light of recent federal government actions regarding spent fuel disposition, it is requested that this statement be changed to reflect federal direction, and add the word "offsite" to the phrase "permanent storage space" to be consistent with the phrase "permanent offsite storage space" in Line 18.