ML19025A152

Comment (8) of Randal Owen on Virginia Electric and Power Company; Dominion Energy Virginia: Surry Power Station, Unit Nos. 1 and 2

ML19025A152
Person / Time
Site:	Surry
Issue date:	01/22/2019
From:	Owen R State of VA, Marine Resources Commission
To:	Office of Administration
References
83FR65367 00008, NRC-2018-0280
Download: ML19025A152 (3)

Text

PUBLIC SUBMISSION As of: 1/25/19 8:32 AM Received: January 22, 2019 Status: Pending_Post Tracking No. 1k3-97tz-smvk Comments Due: January 22, 2019 Submission Type: Web Docket: NRC-2018-0280 Virginia Electric and Power Company; Dominion Energy Virginia: Surry Power Station, Unit Nos. 1 and 2 Comment On: NRC-2018-0280-0001 Virginia Electric and Power Company; Dominion Energy Virginia: Surry Power Station, Unit Nos. 1 and 2 Document: NRC-2018-0280-DRAFT-0008 Comment on FR Doc # 2018-27547 Submitter Information Name: Randal Owen General Comment See attached file(s)

Attachments VMRC_Surry Power Final Page 1 of 1 01/25/2019 https://www.fdms.gov/fdms/getcontent?objectId=0900006483a013fb&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD=Eric Oesterle, Tam Tran, Barbara Hayes COMMENT (8)

PUBLICATION DATE:

12/20/2018 CITATION 83 FR 65367

COMMONWEALTH of VIRGINIA Marine Resources Commission 2600 Washington Avenue Third Floor Newport News, Virginia 23607 An Agency of the Natural Resources Secretariat www.mrc.virginia.gov Telephone (757) 247-2200 (757) 247-2292 V/TDD Information and Emergency Hotline 1-800-541-4646 V/TDD Matthew J. Strickler Secretary of Natural Resources Steven G. Bowman Commissioner January 22, 2019 Office of Administration Mail Stop TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Virginia Electric and Power Company; Dominion Energy Virginia: Surry Power Station, Unit Nos. 1 and 2 Docket ID NRC-2018-0280

Dear NRC staff:

This will respond to the request for comments regarding the Nuclear Regulation Commissions (NRC) intention to conduct scoping and prepare an environmental impact statement (EIS) for the subsequent license renewal of the operating licenses for Surry Power Station, Unit Nos. 1 and 2 in Surry County, Virginia. Specifically, on October 15, 2018, Dominion Energy Virginia submitted to the NRC an application for subsequent license renewal of Facility Operating License Nos. DPR-32 and DPR-37 for an additional 20 years of operation at Surry Power Station, Unit Nos. 1 and 2. The Surry units are pressurized water reactors designed by Westinghouse. The current renewed operating license for Unit 1 expires at midnight on May 25, 2032, and the current renewed operating license for Unit 2 expires at midnight on January 29, 2033.

Please be advised that the Virginia Marine Resources Commission (Commission) serves as the stewards of Virginias marine and aquatic resources, and protectors of its tidal waters and homelands, for present and future generations. We manage saltwater fishing, both recreational and commercial, to maintain sustainable fisheries for the benefit of all anglers and the ecosystem.

Additionally, the Commission manages the states submerged bottom lands in public trust for the citizens of the Commonwealth, and its tidal wetlands, sand dunes and beaches in order to preserve and protect Virginias natural resources and the habitat our saltwater fisheries depend on.

In a letter to the Commission, dated August 3, 2017, Dominion Energy stated the company does not anticipate any refurbishment as a result of the technical and aging management program information that will be submitted in accordance with the NRC license

U.S. Nuclear Regulatory Commission January 18, 2019 Page Two renewal process. Since the construction of the Surry Plants cooling water intake structures, the EPA implemented its new rule, in response to Section 316(b) of the Clean Water Act, which requires that EPA ensure water intake structures reflect the best technology available to protect aquatic organisms from being killed or injured by impingement (being pinned against screens or other parts of a cooling water intake structure) or entrainment (being drawn into cooling water systems and subjected to thermal, physical or chemical stresses).

Accordingly, the Commission recommends that the draft EIS comprehensively evaluate the alternatives required to ensure compliance with current 316(b) requirements and any renewal permit issued by NRC and DEQ contain the appropriate cooling water intake structure requirements, monitoring conditions, recordkeeping and reporting requirements in accordance with 40 CFR Part 125.98.

Lastly, the Commission would like to point out that the Commonwealth is seeing an increased number of requests for new raw water intakes in the tidal and tidal freshwater reaches of the Chesapeake Bay tributaries. To date, the Commonwealth does not know how much the collective impacts from these intakes contribute to the mortality of anadromous fishes. These species continue to experience depleted stocks nationally. Virginias contribution to the mortality of these migratory finfish species is considered annually by the Atlantic States Marine Fisheries Commission and the Mid-Atlantic Fisheries Management Council. This consideration may lead to additional management actions required of Virginia to reduce mortality.

As such, the Commission requests that in addition to the aforementioned recommendations, the EIS should identify mitigation strategies to offset past and anticipated future mortalities of anadromous and resident fishes resulting from Surry Power Stations continued operation of their intake structures. This is in keeping with mitigation recently required by the Commissions permits issued for municipal raw water intakes in the Chickahominy and Pamunkey Rivers.

Should you have any questions please contact me at (757) 247-2251 or by email at randy.owen@mrc.virginia.gov. Thank you for the opportunity to comment.

Sincerely, Randal D. Owen Deputy Chief, Habitat Management RDO/lrp HM