ML040510226

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Letter Forwarding the Consistency Certification for the Surry ISFSI, for Review and Concurrence
ML040510226
Person / Time
Site: Surry, 07200002  Dominion icon.png
Issue date: 11/20/2003
From: Faggert P
Dominion
To: Irons E
Office of Nuclear Reactor Regulation, State of VA, Dept of Environmental Quality
References
-RFPFR
Download: ML040510226 (16)
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Text

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-2 P2Mn2 rF.Faggert Dominion-Vice Presidenr and Chief Environmenral Officer 5000 Dominion Boulevard. Glen Allen, VA 23060 Phone: 804S-273-3467 November 20, 2003 Ms. Ellie Irons Program Manager Office of Environmental Impact Review Virginia Department of Environmental Quality 629 East Main Street, 6k" Floor Richmond, VA 23219 Re: Federal Consistency Certification under the Coastal Zone Management Act Virginia Coastal Resources Management Program Surry Independent Spent Fuel Storage Installation -

License Renewal Application

Dear Ms. Irons:

In recent conversations between you and Mr. Tony Banks of Dominion regarding various federal licensing actions for its Virginia nuclear power facilities, it was agreed that Virginia Coastal Resources Management Program (VCP) consistency certification for the Surry Independent Spent Fuel Storage Installation (ISFSI) License Renewal Application would be satisfied with the Surry Power Station concurrence letter received from you, dated February 20, 2002 (enclosed). This letter was included as a part of the Nuclear Regulatory Commission's (NRC) NUREG-1437 Supplement 6, the Generic Environmental Impact Statement for License Renewal of Nuclear Plants for Surry Power Station, published November 2002.

Because of this previous certification, of which the ISFSI was included on the site layout and in description of site facilities, and the fact that continued operation of the ISFSI will result in no changes that would affect Virginia's coastal zone, Dominion believes the necessary requirements would be met for an expeditious review. Enclosed for your review and concurrence is the consistency certification for the Surry ISFSI.

We respectfully request your concurrence within 30 days, which will assist the NRC's review of the Surry ISFSI License Renewal Application.

If you have any comments or questions regarding this request, please contact Jud White at (804) 273-2948 or Tony Banks at (804) 273-2170.

in erely, o Pamela F. Faggert Enclosures cc: Michael Murphy - VDEQ Mary Jane Ross-Lee - NRC F7 -Imm

. Appendix E FEB-27-200Z 12:28 -NRC4NRDSSR/SPLB P.A2/1 COMMONWEALTH of VIR(-INIA DEPARTMFATOF NVRONAW7TL QUALITY

  • ru:l edw.w 629 EsstMlal Samn,aI.hmoncL ViUrni 2"21e W. T&*r MuTphy, Ir. Mallintr w.o IO. Dea Io00o. Riclmend. Virginia 23240 R t. o c Dunlg SoiuytroNznI tRawwcs *FX(a04)de9"00 TDD(D4)693.4021 Di (5&4) 69'4000 Febiry 20,2002 Io592S43 J. W. White, PhD.

Manager, Water and Waste Progrzms Domniirxoa/inia Power Company S000 Dominion 136ulevard GienAllenVrginis 23D60 RE: Suny Power Station License Renewal: Application by Dominion Virginia Power Company to U.S. Nuclear Regulatory Commission for Renewed Operating License -

Federal Consistency Certification under the Coastal Zone Management Act DEQ-01-186F

Dear Dr. White:

This ldtcrtceponds to yolurSeptancr27, 2001 lettcrreqrcting thebDcparment 0 vironmental Quality's co of uc withf e federal consistacy certdficationfor renewal of te Dominion Virinia Power Company's operating license for the Suizy Power sdion. The Departmeni of Environmental Quality is responsible for coordinating Virginia's review of federal consstency cerfiifations and responding to applicants for federal approval on behalf of te Corimonweaslth. The following agecies and planning distict commission took patt midis eview:

Department ofEnvironmental Quality Department of Conservaton Department of Health Marine Resources Commission Chesapeake Eay Local Assistance Departent Crater Planning District Commission.

Tn addition, Suiry County was invited to comTmnnt.

NUREG-1437, Supplement 6 E-14 November 2002

Appendix E EB-27-202 12:29 NCNFWDSSR/SF.L J. W. White. Ph.D.

Februasy 20.2002 Page 2 P-rojct Descsietion Dominion Virginia Power aub-itted infoarion for this rview in tht or of two documents. One, submitted with the initial letter, is called "Appendix E.

Environmental Repon" (cited hereinafler as "Appcndix E). The other is entitled

'Tederal Consistency Certilication for Sutny Power Station License Rcnewl" and is dated October 26; 2001 (cited hereinafter s "Ceytification').

Dominion Virginia Power owns and operatcs the Suny Power Station. a nuclear elecuic genrating stalion located on the James tiver in Surry County. The plant is stuated at the riverjust south of Hog Island Wildlife Manageenmt Area (Appcndix E.

page E-11. figure E-2). The plant consits oftwo nuclear reactors and associated steam tuxbincs that generatc approximately 1,600 megawatts of electricity. The Unit 1 license is to expire on May 25, 2012, whllc the Unit 2 license will expire on Janunay 29, 2013.

Both liccn=s have terms of 20 years, and are wo bc Tencewd for new 20-year terms..

(Appendix E, page E-3). The Company expects Sury Power Station operations during the new license term to be a continuation ofprmseat operations (Appendix E. page E-2).

Federal ConsistencM Amalysis The VirginiQ Cossial Resoumes Management Prograr (VCP) is comprised ofa networkc of prograris adminislered by sev64l anencies- In order to be consistent witb thc VCP, the applicant for federal licensing must obtin all the applicable permits and approvals listed undei the Enforceable Programs of the VCP prior to commencing the proicet. Based on he commitment's provided in-the Consistcncy Certification that Dominion Virginia Power will obtain and comply with all approvals from agencies administering the apphicable Enforceable Progrms(Certficatiom.page 1; Appendix F, page E-2) and comments submited by agencies administering the Enforceable Programs.

the Department of En-ironamntal Quality concurs with the idixig that the license renewal and continued operation of the Surry Power Station Is consistent with Virginia's Coastal Resouces Managemennt Proam.

This discussion analyzes the continued operation of the project under the license renewal in light of the Enforccable PRograms of the Virginia Coastal Management Program.

J. Subaqueous Lands ManqgemenL The Marine Resources Commission indicates no objection to the renewal of the Nuclear kegulatory Commission (MC) license for this project, provided that the applicant adheresto cxisting acstivirica penirined by the Commission and/or submits appropriate permit applications for any new activities November 2002 E-1 5 NUREG-1437, Supplement 6

MMMMM Appendix E FEB-27-2a2 12:28 NRC'NRDSSAvSP1Ls P. e4/11 J. W. White. PhD.

Pebruary20, 2002 Page 3 afEecting State-owned subaqueous l1nds. According to the Certification, the applicant has no plans for any ctivity under the license renewal that would require a permit from the ComMission(page 13, Table 2, item b).

2. CoastalLandsManiariment. According tD thc Chceapcke Say Local Assistance Department, the proposed license renewal is not subect to any rmquiTreents under the Chesapeake Bay Preservidon Art because the license renewal would allow continued operations without new 6onsinrcti6n cr redevelopme-t.
3. Wetlands AianaemenLt. Aeoding to DEQ'x Piedmont REgional Office renewal of the NRC license for this project will not affect the existing Virginia Water Protection Permit covering the project, as cing as the project utas in compliance with fth requiremcnts of the pirmit. Aecording to DEQ's Virgia Water Protectioi Program, activities under the license rei.W will,not affect weclinds.

. . point Source Water Polhrion. According' to DEQ'x Piedmont Regional Office, renewal of the NRC license for thXs project will not affect the existing Virginia Pollutant

.Discharge Efirnation System Permit coveinsg the project, as long as te projec stsay in compliance with the requirtments of thepermit According lo DEQ's Virginia Water Protection Program', activities undms the lieente renewal will not affiect suurefa waters.

S. Air Pollution Cohrral. Acinding to DEQ's Piedmont Regional Office.

rencwal of the NRC license or this .project will not affect he existing air pemits

  • coveringthe project, as long as the project stays in compliance with the reuiwrmcnts of ths permits.

6, Other EnforceabigProgniMs."As the Certification indicates, the remaining Enforceable Programs of the Virginia Coatal Resources Management Progmut do not apply to the renewal of the NRC license ftor he Surry.Power Staton. Specifically, the Fisheries Mariagetient Program, intluding the Staic Tributyltin Ttegulatoiy Program, is not applicable to continued operation of the Surry Power Statlon. Neitherare the Dunes Managemnt Progrurn,-the Non-poirt Source Pollution Control (Erosion and Sediment Control) Progra, or thc Sh0orelineSnitarion Program.

Envirnmental Impacts and Mlization J. Ntatural He riage and ldljRcazource. >"Natural heritage resources" a defined as the habitat of rare, thieatened, or endangered species of plants and animals, unique or cxcmrnplarY nanirl communitics, and iignificant geologic foriationrs, acording to the Department of Conseration aihd Recreation. That Department indicates that NUREG-1437, Supplement 6 E-1 6 November 2002

Appendix E FEB-27-2002 12:29 P . C/NS J. W,White, Ph.D.

Fcbruary 20,2002 Pagr 4 natural heritage resources have not been documented as present in the victnity of the.

project. In addition, the Departnent of C sernvtion and Reacation represents ihe DCpattnent of Agriculture and Consumer Scrices in cornmenting on statc-isted rndangered plant and insect species tt might be affected by a project. The continved operation of the SUy Power Stationwill not affet procted plant or insect species.

2. P>eCrtion rsouor. Continued operation of the Sury Power Statina Will not adversely affect any existing or planned recreational failities. . Nor will it affect SRrams on the NationAl Pak $ervice Nationwide Invcntory. Final List of Rives or.

potental Virginia Seei; .Rivers.The project will not affect arq Virginia Byways.

3. SolfdandjrazardausWpsleMotaemenr. The DEQ's Waste Division, Office of Rmedial Programs did a cursory refvie of Its data files and found that the Surry Power Station is listed as a small-quantity generator of bazarddus waste, suibjct to the provisions of Title 40, Code of PFdeal ftiilations, Part 262 (and related provisions in Pati 264; 26S, and 268). which arm adopted by refrcrnce in the MirginiaIzardous Wiste Manaement Regulations. The most t DEQ inspectdin of the North Anna

.Power Sttion took plice in May 1999; the inspecdon revealed thatthe Station was in compliance with all the reqpirements apWlicfile to sizallquynti goncrators.

4...Radiologicallfe~ihConsjatipns. Accordingto the Dcpartment of Health's uadiologieal Health Progam, the Departmeat of Health providcs indepedent verification of this facility's e ironmel monitoring program for radiological relcases.

The Department of Health irniplemeted its environmental monitoring progr during the pre-opeational stage of the farility; Ihe programn continues to the present day. There is no indication, in the published anrnial tepois of the monitoring program, of any releases of radiation gaffecing the envi rom`ein the history ofthe program, In addition. the applicant ha been supportive of the efforts of state and local goverunments in mnainting an cffctive State Emergency Retponse Plan in case of radiological ctnergencies a the pocr planc. The Nuclear Regulatory Counrussion license includes a condition requiieg crllfication of the Plan by the Federal Emergency Managemnt Agency (FEMA); FE has cetificd the Plan November 2002 E-17 NUREG-1437, Supplement 6

Appendix E 1.W.WM;te Ph.D.

February 20, 2002 Page 5 Thnk you for the cipozrtunty to colment on this fodeWa consisrec ceilification.luccly Efle 1. rons

.Propaxn Ma nager Off~ic o EatEm~ental Imnpaa Review Enclowues cc: DrrlJorse DM Leslie P.Foldresi, VDH Thomas D.'Modenak DBQ-DWPC-ORP Y1.S.Na='asbiznmDEQ-DAPC-ODA MiiS. Ailing, DEQ-PO Brcna K~V~mn, DEQ-VWPP R.1abKhLD*QRO L

Tony Watidinsn, MRC Cathtrin M.HerodK CBLAID DlUiniS K Morris, CiaTer PDC Tery D.Le4s Suriy County Andy Kulecr, Ui.S'. NRC.

NUREG-1 437, Supplement 6 E-1 8 November 2002

FEDERAL CONSISTENCY CERTIFICATION FOR SURRY POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE RENEWAL The Federal Coastal Zone Management Act (16 USC 1451 et seq.) imposes requirements on an applicant for a Federal license to conduct an activity that could affect a state's coastal zone.

The Act requires the applicant to certify to the licensing agency that the proposed activity would be consistent with the state's federally approved coastal zone management program. The Act also requires that the applicant provide to the state a copy of the certification statement and requires that the state, at the earliest practicable time, notify the federal agency and the applicant whether the state concurs or objects to the consistency certification. See 16 USC 1456(c)(3)(A).

The National Oceanic and Atmospheric Administration has promulgated implementing regulations that indicate that the certification requirement is applicable to renewal of federal licenses for activities not previously reviewed by the state [15 CFR 930.51 (b)(1)]. The Commonwealth of Virginia has a federally approved coastal zone management program described below. Dominion is applying to the U. S. Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Surry Power Station (SPS) Independent Spent Fuel Storage Installation (ISFSI), in Surry County, Virginia.

CONSISTENCY CERTIFICATION Dominion has determined that NRC renewal of the SPS ISFSI license to operate would comply with the federally approved Virginia Coastal Resources Management Program. Dominion expects SPS ISFSI operations during the license renewal term to be a continuation of current operations as described below, with no changes that would affect Virginia's coastal zone.

NECESSARY DATA AND INFORMATION Proposed Action The Surry Power Station ISFSI is located on the Surry Power Station site, in Surry County, Virginia. The site is on the Gravel Neck peninsula, on the south side of the James River, approximately 25 upstream of the Chesapeake Bay. The Virginia Department of Environmental Quality lists Surry Count as part of the Virginia coastal zone (Ref. 2). Figures 1 and 2 show the SPS site 50-mile and 6-mile regions, respectively, and Figure 3 shows the site layout.

Spent nuclear fuel removed from the Surry Power Station spent fuel pool is stored in dry casks on concrete pads at the ISFSI. The ISFSI is approximately 15 acres and currently comprises two concrete pads surrounded by security fencing and perimeter fencing. It is licensed for a third pad, which would be constructed when the second pad is full. Each pad is designed to hold 28 spent fuel casks. Each cask holds between 21 and 32 spent fuel assemblies. The U.S.

Department of Energy (DOE) is responsible for the disposal of the spent fuel in a geologic repository.

The proposed action is to renew the operating license of the ISFSI for an additional 40 years which would provide time after the shutdown of the reactors to remove all the fuel from the facility to the geologic repository.

The only utility provided to the ISFSI is electric power for security lights, monitoring instruments, and general use. Potable water, fire protection water, sewage treatment, steam, ventilation, air supply systems, and chemical storage are not required at the ISFSI. It is manned intermittently, I 11/20/03

FEDERAL CONSISTENCY CERTIFICATION FOR SURRY POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE RENEWAL to monitor cask integrity, and to emplace casks. The ISFSI does not have a permanent workforce, but Surry Power Station employees are assigned ISFSI responsibilities as part of their job.

Other than the NRC operating license, the ISFSI requires no licenses, permits or authorizations.

Environmental Impacts The following paragraphs describe the environmental impacts from operating the Surry Power Station ISFSI for 40 years beyond the current license term. For facilities such as the SPS ISFSI that are located in the coastal zone, impacts would affect the coastal zone.

No impacts would occur to surface water hydrology or use, aquatic ecology, groundwater quality or use, air quality, land use, or socioeconomics.

Environmental Impacts that could affect the coastal zone and Dominion's conclusions regarding those impacts are listed below:

Surface water quality This issue addresses the effects of construction of one or two additional concrete storage pads on the water quality of the wetlands at Hog Island Wildlife Management Area and in the James River. Dominion constructs storage pads as they are needed. One and possibly two additional pads likely will be needed during the license term. The pads will be constructed within an industrial area on previously disturbed soil. The ISFSI is approximately 1 mile from the bluffs overlooking the Hog Island Wildlife Management Area, and from the bluffs of the James River. There is little slope at the ISFSI, but there is a ravine immediately west of the facility. Dominion uses sediment and erosion control best management practices and adheres to Surry County building permit requirements.

All runoff from the ISFSI in caught in a percolation basin. There is no discharge from the facility to any surface water. Dominion concludes that impacts to water quality from construction will be small.

  • Threatened or endangered species This issue address effects that ISFSI operations could have on species that are listed under federal law as threatened or endangered. Two such species could occur on the SPS site. Dominion environmental studies and environmental protection programs have identified no adverse impacts to such species and Dominion's consultation with the cognizant Federal agency has identified no impacts of concern. Dominion concludes that impacts to these species are small during current operations and it has no plans that would change this conclusion for the license renewal term.
  • Human health

- Radiation Dose - This issue addresses the dose to workers and the public from the ISFSI. Because this strictly human-health issue does not directly or indirectly affect natural resources of concern within the Coastal Zone Management Act definition of 2 11/20/03

FEDERAL CONSISTENCY CERTIFICATION FOR SURRY POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE RENEWAL "coastal zone" [16 USC 1453(1)], Dominion concludes that the issue is not subject to the certification requirement.

  • Historic and Archaeological Resources This issue address impacts that license renewal activities could have on resources of historic or archaeological significance. One and possibly two additional pads likely will be needed during the license term. The pads will be constructed within an industrial area on previously disturbed soil. A recent survey of the ISFSI area determined that it has no potential for undiscovered archaeological or cultural resources (Mullin 2001). If placement of the additional pads requires that the perimeter fence be moved, Dominion would follow its procedures for activities that disturb the soil. Included in the procedures are steps to take when a previously unknown artifact is discovered. Dominion concludes that impacts to historic or archaeological resources would be small.

Dominion consultation with the State Historic Preservation Officer has identified no issues of concern.

Postulated accidents Accidents were evaluated in the Safety Analysis Report done for the ISFSI. An incredible accident would result in a general population dose well below the dose the population receives from background radiation. Dominion concludes that impacts from accidents would be small.

State Program Like many states, Virginia's coastal zone management program is a "networked" program, which means that it is based on a variety of existing Commonwealth authorities rather than a single law and set of regulations. The U. S. Department of Commerce and the Virginia Department of Environmental Quality have published programmatic documentation of the Virginia program (Ref. 4), called Virginia's Coastal Resources Management Program. The Virginia Department of Environmental Quality administers the program and has identified enforceable regulatory authorities that comprise the program (Ref. 5).

Findings

1. Dominion has determined that all environmental impacts from the operation of the ISFSI are small, and would remain small through the license renewal term.
2. As best assessed, Dominion is in compliance with Virginia licensing and permitting requirements.
3. Dominion's license renewal and continued operation of the Surry Power Station ISFSI would be consistent with the enforceable provisions of the Virginia Coastal Zone Management Program.

3 11/20/03

FEDERAL CONSISTENCY CERTIFICATION FOR SURRY POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE RENEWAL STATE NOTIFICATION By this certification that the Surry Power Station ISFSI license renewal is consistent with Virginia's Coastal Zone Management Program, the Commonwealth of Virginia is notified that it has 3 months from receipt of this letter and accompanying information in which to concur or object with Dominion's certification. However, pursuant to 15 CFR 930.63(b), if the Commonwealth of Virginia has not issued a decision within 3 months following the commencement of state agency review, it shall notify the contacts listed below of the status of the matter and the basis for further delay. The Commonwealth's concurrence, objection, or notification of review status shall be sent to:

TBD Tony Banks U. S. Nuclear Regulatory Commission Dominion Generation One White Flint North Inhsbrook Technical Center 11555 Rockville Pike 5000 Dominion Blvd Rockville, MD 20852-2738 Glen Allen, VA 23060 REFERENCES

1. Procedural Guidance for Preparing EnvironmentalAssessments and Considering Environmental Issues." U. S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation. Office Instruction No. LIC-203. June 21, 2001.
2. Virginia Coastal Program; Our Coastal Zone; Virginia's Coastal Environment. Virginia Department of Environmental Quality. Available online at http://www.deg.state.va.us/coastal/thezone.html. Access October 17, 2001.
3. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. U. S.

Nuclear Regulatory Commission. May 1996.

4. Virginia Coastal Resources Management Program Final Environmental Impact Statement.

U. S. Department of Commerce and Council on the Environment and.Commonwealth of Virginia. July 1985, reprinted April 1999.

5. Enforceable Regulatory Programs Comprising Virginia's Coastal Resources Management Program. Commonwealth of Virginia, Department of Environmental Quality. Undated.

Transmitted as Attachment of Letter, E. L Irons, Virginia Department of Environmental Quality, to J. W. White, Dominion Virginia Power Co., October 11, 2001.

ATTACHMENTS Figure 1 50-Mile Vicinity Map Figure 2 6-Mile Vicinity Map Figure 3 Site Layout Table 1 Compliance With Enforceable Regulatory Programs Comprising Virginia's Coastal Resources Management Program 4 4 1120/03

FEDERAL CONSISTENCY CERTIFICATION FOR SURRY POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE RENEWAL Figure 1 50-Mile Vicinity Map to lo 20 wim"nm a a0 lo 20 LO" OnywPoares-o- so wws 5 11/20/03

FEDERAL CONSISTENCY CERTIFICATION FOR SURRY POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE RENEWAL Figure 2 6-Mile Vicinity Map 6 11/20/03

FEDERAL CONSISTENCY CERTIFICATION FOR SURRY POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE RENEWAL Figure 3 Site Layout s

Hog Island Tract v

$e1 Hog Island Wildlife Management Area

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  • (a C

N

_ _ v I

IS.- - - -

t2 LEGEND ISFSI Independent Spent Fuel Storage Installation

-- - Property line

- Fence Not to Scah 7 11/20/03

FEDERAL CONSISTENCY CERTIFICATION FOR SURRY POWER STATION LICENSE RENEWAL Table 1 Compliance With Enforceable Regulatory Programs Comprising Virginia's Coastal Resources Management Program Item Topic and Virginia Code Compliance Status Citation Fisheries Management a.1. §28.2-200 to §28.2-713 This applies to activities that Dominion has not

§29.1 -100 to §29.1 -570 undertaken at the SPS ISFSI and for which Dominion has no plans to undertake during the license renewal term: recreational and commercial fishing, oystering, alaming, and crabbing, scientific collecting, hunting, fishing, trapping, dealing in furs, and falconry.

a.2 §3.1-249.59 to §3.1-249.62 This applies to an activity that Dominion has not undertaken at the SPS ISFSI and for which Dominion has no plans to undertake during the license renewal term: use of marine anti-fouling paint containing tributylin.

Subaqueous Lands Management

b. §28.2-1200 to §28.2-1213 This applies to an activity that Dominion has not undertaken at the SPS ISFSI and for which Dominion has no plans to undertake during the license renewal term: use of state-owned bottomiands.

Wetlands Management c.1 §28.2-1301 to §28.2-1320 This applies to activity that Dominion has not.

undertaken at the SPS ISFSI and for which Dominion has no plans to undertake during the license renewal term: wetlands development.

c.2 §62.1-44.15:5 This applies to activities that Dominion has no plans Water Quality Certification to undertake during the license renewal term:

pursuant to Section 401 of the excavating in, filling, flooding, and significantly Clean Water Act altering wetlands.

Dunes Management

d. §28.2-1400 though §28.2- This applies to activity that Dominion has not 1420 undertaken at the SPS ISFSI and for which Dominion has no plans to undertake during the license renewal term: development in coastal dunes.

8 11/20/03

FE,DERAL CONSISTENCY CERTIFICATION FOR SURRY POWER STATION LICENSE RENEWAL Table 1 Compliance With Enforceable Regulatory Programs Comprising Virginia's Coastal Resources Management Program, Continued Item Topic and Virginia Code Compliance Status Citation Non-Point Source Pollution Control e.1 §10.1 -560 et seq. TBD e.2 §10.1 -2100 though §10.- See Item i, below 2114 and 9 VAC1 O-20 et seq.

e.3 §10.1 -21 00 though §10.- See Item i, below 2114 and 9 VAC1 0-20 et seq.

Point Source Pollution Control f.1 §62.1 -44.15 The SPS ISFSI has no discharges. Dominion has no plans for license renewal activity that would require a National Pollutant Elimination System Discharge permit.

f.2 §62.1-44.15:5 See Item c.2, above.

Water Quality Certification pursuant to Section 401 of the Clean Water Act Shoreline Sanitation

9. §32.1-164 to §32.1 -165 This applies to activities that Dominion does not undertake at the SPS ISFSI and for which Dominion has no plans to undertake during the license renewal term: operation of septic tanks and land disposal of sewerage.

Air Pollution Control

h. §1 0-1.1 300 to §10.1 -1320 The SPS ISFSI has no air emission source.

Construction activities would be minimal and would have a small impact on the air quality.

9 11/20/03

FEDERAL CONSISTENCY CERTIFICATION FOR SURRY POWER STATION LICENSE RENEWAL Table 1 Compliance With Enforceable Regulatory Programs Comprising Virginia's Coastal Resources Management Program, Continued Item Topic and Virginia Code Compliance Status Citation Chesapeake Bay Preservation Act

i. §10-1.2100 to §10-1.2114 The Commonwealth establishes criteria for 9 VAC10-20 et seq. delineating Chesapeake Bay Preservation Areas (CBPAs) and performance criteria for use of land within such areas. Local governments establish compliant programs, the focus being on controlling non-point-source pollution.

If, in the future, SPS initiated activity that would be subject to CBPA requirements, Dominion would

- ensure compliance.

SPS = Surry Power Station VAC = Virginia Administrative Code

§ = Section 10 11/20/03

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