ML19107A020

Audit Need Update Tracking Spreadsheet

ML19107A020
Person / Time
Site:	Surry
Issue date:	04/16/2019
From:	Eric Oesterle NRC/NRR/DMLR/MRPB
To:
Tran T, DMLR/MRPB 415-3617
Shared Package
ML19107A019	List: ML19107A020 ML19107A021
References
EPID L-2018--RNW-0024
Download: ML19107A020 (5)

Text

Resource Area Audit Need Auditor Audit Need Update TE Terrestrial Ecology Peyton Doub T-11 Provide information on maximum operating plant noise [relative to impacts to wildlife occupying habitats surrounding site facilities]

WM Waste Management Phyllis Clark WM0-1 Provide procedures related to the radiative and nonradiative Waste Management Program, Waste Minimization Program, Chemical Control Program, General Industrial Safety Requirements and Electrical Safety in the electronic reading room.

Phyllis Clark I reviewed the information provided on the portal and no additional information needed.

WM-1 In section E3.6.4.2.1 of the ER Dominion stated that there were three inadvertent onsite liquid radioactive releases estimated to be greater than 100 gallons each. The last inadvertent release referenced in the ER was September 23, 2012. Provide detailed information on this release and the preventive measures implemented. Are there any more recent reportable releases? If any, provide detailed information on the release.

Phyllis Clark Docket the information in an RAI response.

WM-2 Surry is subject to the reporting provisions of 40 CFR Part 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. Any discharges of oil in such quantities that may be harmful to the public health or welfare or the environment must be reported to the U.S.

Coast Guard (USCG) National Response Center. Also, Surry is subject to the reporting provisions of State Water Control Law section 62.1-44.34:19 (Article 11). This reporting provision requires that any release of oil in a quantity of 25 gallons or greater to the environment be reported to the VDEQ, the coordinator of emergency services of the locality that could reasonably be expected to be impacted, and appropriate federal authorities. In sections E3.6.4.2.2, E9.5.3.6, and E9.5.3.7 of the ER, Dominion stated that based on the review of site records from 2012-2017, there was one inadvertent release of approximately eight gallons of glycol-based hydraulic fluid occurred during cleaning of the Unit 2 D service water intake bay. The applicant states that the release was reported to VDEQ and no NOV resulted. Provide detailed information on this release and the preventive measures implemented. Are there any more recent reportable releases? If any, provide detailed information on the release.

Phyllis Clark Docket the information in an RAI response.

SSH Special Status Species and Habitats Briana Grange SSH0-1 ER Table E3.7-4, Federally and State Listed Threatened and Endangered Species lists as its references several Federal and State websites and databases that were last accessed in 2016. Please provide an updated table based on currently available information.

Briana Grange Environmental Report Table E3.7-4, Federally and State Listed Threatened and Endangered Species lists as its references several Federal and State websites and databases that were last accessed in 2016. Please provide an updated table based on currently available information. Docket response as discussed during audit.

SSH0-6 Briana Grange Dominion Energy. 2019. Letter from Jason E. Williams, Director Environmental, to Joseph Bryan, Department of Environmental Quality. RE: Dominion Energy-Surry Power Station VPDES Permit No. VA0004090 CWIS - 2018 Annual Certification and Effectiveness of Control Measures. 3 p. January 23, 2019.

SSH0-7 Briana Grange Dominion Energy. 2018. Letter from Jason E. Williams, Director Environmental, to Emilee Adamson, Department of Environmental Quality. RE: Dominion Energy-Surry Power Station VPDES Permit No. VA0004090 CWIS - 2017 Annual Certification and Effectiveness of Control Measures. 4 p. January 29, 2018.

SSH0-8 Briana Grange Dominion Energys Annual Certification and Effectiveness of Control Measures for 2012 through 2016.

SSH-6 Briana Grange Special Status Species: made available on the portal company guidance related to northern long-eared bat. We discussed this guidance during the ecology breakout, and Dominion staff is aware that I will review the guidance, once posted, and formulate an RAI based on it.

SSH-3 Is Dominion aware of the discovery of injured or dead bats (of any species) on the Surry site? If so, please explain these incidents (as a part of the explanation, please provide copies of any associated reports or documents. Please consider at least the past 10 years of operation in the response. If information is available since Surry began operating in 1972, please include this information as well).

Briana Grange During the NRC environmental site audit, Dominion personnel explained the company has reported the discovery of any injured or dead birds and bats on the Surry site to the U.S. Fish and Wildlife Service since 2009. However, Dominion has not reported any bats of any species as injured or dead from 2009 through present. Please affirm the staffs understanding of this information.

SSH-4 Would any activities during the proposed subsequent license renewal term cause increased site noise or vibration levels compared to current operations? If so, please explain the activities that would cause such changes and the potential impacts of increased noise and vibration associated with such activities on bats.

Briana Grange Does Dominion anticipate any activities during the proposed subsequent license renewal term that could cause increased site noise or vibration levels compared to current operations? If so, please explain such activities and the potential impacts of increased noise and vibration associated with these activities on bats.

SSH-5 In connection with the most recent renewal of the Surry VPDES permit:

(a) Explain how federally listed species and critical habitats were considered during the permit renewal process.

(b) Explain/describe any coordination with the National Marine Fisheries Service (NMFS),

applicable State resource agencies, or other entities related to federally listed species and critical habitats.

(c) As a part of the explanation, provide copies of any monitoring or assessments of impacts to federally listed species and critical habitats resulting from operation of the Surry cooling system that Dominion, the NMFS, the State, or other entities performed in connection with the VPDES permit or its renewal.

Briana Grange Environmental Report Table E9.1-1 lists several permits related to in-water work, including permits authorizing periodic maintenance dredging of the intake channel and debris removal and maintenance of the low-level intake structure.

Additionally, page 14 of Dominions January 29, 2019, Supplement to the ER,, Attachment 1 states: The potential for dredging operations, shoreline modification, and water pollution to have detrimental effects to [Atlantic sturgeon critical] habitat is controlled and mitigated by regulatory processes and permits.

SSH-7 Briana Grange Place holder for RAI related to Dominions northern long-eared bat guidance.

Waiting for Dominion to load guidance document onto the portal so that I can review it and formulate the RAI.

Information Made Available for the Portal A0-1 CH2MHill. 2006. Draft Comprehensive Demonstration Study. Surry Power Station.

Revision 1. November 17, 2006.

Briana Grange Docket response as listed on portal A0-6 EA Engineering, Science, and Technology, Inc. 2006. Entrainment Characterization Report; Surry Power Station, June 2005-May 2006. Draft Report. September 2006.

(NOTE: If the final version of this report is available, please provide the final rather than the draft report.)

Briana Grange Docket response as discussed during audit (i.e., final report August 2007)

A0-7 HDR. 2016a. Draft Entrainment Characterization Study Plan. Prepared for Dominion Services. Inc. May 29, 2016 Briana Grange HDR. 2016a. Draft Entrainment Characterization Study Plan. Prepared for Dominion Services. Inc. May 29, 2016. Docket response as listed on portal A0-8 HDR. 2016b. Draft Impingement Characterization Study Plan. Prepared for Dominion Services. Inc. May 29, 2016.

Briana Grange HDR. 2016b. Draft Impingement Characterization Study Plan. Prepared for Dominion Services. Inc. May 29, 2016. Docket response as listed on portal A0-9 HDR. 2017. 2015-2016 Impingement Characterization Study Report, Draft Final. Surry Power Station, VPDES Permit VA0004090. April 3, 2017.

Briana Grange HDR. 2017. 2015-2016 Impingement Characterization Study Report, Draft Final.

Surry Power Station, VPDES Permit VA0004090. April 3, 2017. Docket response as listed on portal A0-16 VEPCo. 1977. Section 316(a) Demonstration (Type L); Surry Power Station - Units 1 and 2. Submitted to the Virginia State Water Control Board. Richmond, Virginia.

Briana Grange VEPCo. 1977. Section 316(a) Demonstration (Type L); Surry Power Station -

Units 1 and 2. Submitted to the Virginia State Water Control Board. Richmond, Virginia. Docket response as discussed during audit.

A0-17 Briana Grange USFWS. 2015c. Email correspondence from S. Hoskin, USFWS, to M. Overton, Dominion Energy. December 9, 2015.

A-11 Briana Grange Aquatic Resources: I will be formulating two RAIs related to Dominions 2015-2016 impingement characterization study and 2015-2017 entrainment characterization study. Both of these studies are draft final. I will be reviewing these on the portal and formulating RAIs that request a summary of the documents (scheduled 3/25/19)

A-12 Briana Grange Dominion collects samples of commercially and recreationally important fish and invertebrates as part of its annual radioactive effluent release monitoring in accordance with a permit issued by the Virginia Marine Resources Commission (for instance, see Note 3 on page 62 of the 2017 Annual Radioactive Effluent Release Report (ML18128A192)).

a. Identify the species that the Virginia Marine Resources Commission permits Dominion to sample as part of this monitoring effort.

b. Identify the species that Dominion most commonly collects during such sampling.

c. Confirm that Dominion has not collected Atlantic sturgeon or any other federally listed species as part of this sampling effort.

A-13 Briana Grange The ER (Section E3.7.5.1 and E3.7.5.2) identifies several species of invasive aquatic plants and animals.

a. Identify which of these aquatic species occur on the Surry site.

b. Explain whether Dominion performs any specific environmental management or maintenance activities related to these species.

A-14 Briana Grange Place holder for RAI related to 2015-2016 impingement characterization study.

This RAI will request Dominion to summarize the materials, methods, and results of the study, but I need to take some time to figure out exactly what information I need.

A-15 Briana Grange Place holder for RAI related to 2015-2017 entrainment characterization study.

Same caveat as above.

HWQ-GW Hydrology and Water Quality - Groundwater Bill Ford GW0-3 A well log from an onsite well that is representative of the stratigraphy from the surface down to the top of the Potomac aquifer.

Bill Ford Copy of well log requested to be docketed.

GW-14 Is the groundwater that contains tritium believed to be in construction fill or sand?

Bill Ford Response requested for docketing GW-15 What is the first aquitard (low permeability layer) beneath the fill and sand? What is it made of (e.g., clay, silt, etc.). What is the depth to the aquitard?

Bill Ford Response requested for docketing GW-16 Briefly describe plans to restore the groundwater. What has been the experience (effectiveness) of clean up actions to date?

Bill Ford Response requested for docketing GW-17 Briefly describe actions taken to prevent the release of radionuclides into the groundwater (i.e., identifying sources, sealing and lining pipes, etc.).

Bill Ford Response requested for docketing HWQ-SW Hydrology and Water Quality - Surface Water Nancy Martinez SW-17 Nancy Martinez Additionally will be requesting for docketing: HDR. 2017. 2015-2016 Impingement Characterization Study Report, Draft Final. Surry Power Station, VPDES Permit VA0004090. April 3, 2017.

SW-18 Nancy Martinez Additionally will be requesting for docketing:VEPCo. 1977. Section 316(a)

Demonstration (Type L); Surry Power Station - Units 1 and 2. Submitted to the Virginia State Water Control Board. Richmond, Virginia.

SW0-5 VDEQ. n.d.VPDES Permit Fact Sheet. VA0004090. Surry Power Station & Gravel Neck.

No date.

Nancy Martinez Will be requested for docketing, including attachment B to the Fact Sheet.

SW-1 The ER identifies that Dominion has been notified by VDEQ that it will require a separate 401 certification for this renewal and that Dominion is coordinating with VDEQ on that process. Relevant to 10 CFR 51.45(d) and as further specified under the Clean Water Act, Section 401, the NRC cannot issue a renewed operating license unless the applicant provides the NRC with a water quality certification from the State or other appropriate documentation.

a. Provide copies of letters and other communication documents to and from VDEQ pertaining to 401 certification (What is the status of SPSs 401 certification?)

Nancy Martinez In addition to the response on the portal, the discussion and additional information regarding this information need during the break-out session will be requested to be docketed via an RAI. So this information need will be revised into RAI.

SW-2 Table E9.1-1 of the ER identifies that USACE Regional Permit (13-RP-02) expired 08/14/2018 and that the reissuance application is in progress. Regional Permit (18-RP-

02) was re-issued on September 5, 2018 and expires on September 5, 2023. Has Dominion received a permit verification to continue performing dredging within the existing intake channel under Regional Permit 18-RP-02? If so, provide a copy for review.

Nancy

Martinez, Kevin Folk, Briana Grange, Bill Ford This information need will be revised into an RAI that will request the status of the joint application.

SW-4 Section E3.6.3.1 of the ER states that SPS uses approximately 1,942 MGD of water from the James River for once-through cooling and the auxiliary cooling system. How was the 1,942 MGD estimated? Identify if this is an average value and the period of record used to calculate this estimate.

Nancy Martinez Response on the portal will be requested for docketing SW-5 Section E3.6.3.1 of the ER states: After passing through the condensers and the service water system, most of the water is returned to the James River. Less than 22,000 gpm is lost to evaporation, approximately 1% of the initial intake. (VDEQ. 2013a)

According to the ER Reference list, VDEQ. 2013a is Surrys Groundwater Withdrawal Permit (VDEQ. 2013a. Groundwater Withdrawal Permit, Surry Nuclear Power Station, Surry Co. DEQ Permit #GW0003901. October 18, 2013.). Discuss how 22,000 gpm (approximately 1% of the initial intake) was estimated and provide for review the correct reference that supports this value.

Nancy Martinez As discussed during the break-out session, an RAI will be requesting a basis for concluding that 22,000 gmp of water withdrawals from the James River is lost to evaporation under current operating conditions in light of the power uprate, since this value was estimated during initial licensing of SPS.

SW-6 Section E3.6.3.1 of the ER states that in 2017, surface water withdrawal by SPS was reported as 735,023.75 MG. However, Table E3.6-6 identifies that surface water withdrawal for 2017 was 735,282.04. Please identify the most appropriate number to use in the NRCs independent evaluation.

Nancy Martinez Response on the portal will be requested for docketing as well as the 2018 value.

The reports do not need to be docketed, just a response SW-7 Section 9.5.3.9 of the ER identifies that Dominion performs maintenance dredging operation of the intake channel under a USACE Regional Permit and that [no] other current operations at SPS require a Section 404 permit. However, Table E9.1-1 of the ER identifies that in addition to periodic maintenance dredging of the intake channel in the James River, Dominion conducts debris removal of the low-level intake structure under USACE Nationwide Permit (2012-NWP #3/NAO-2018-00103/VMRC# 18-0069).

Please explain:

(a) Where is the debris stored, placed, or disposed of?

(b) What is the frequency of debris removal and quantity (volume) removed? Is this frequency and quantity of debris removal anticipated to remain the same during the proposed license renewal period?

(c) As a part of the explanation, provide a copy of USACEs verification to Dominion regarding use of this nationwide permit for removal of debris on the existing intake structure.

Nancy

Martinez, Kevin Folk, Briana

Grange, Nancy Martinez A response was not provided on the portal, but the permit added to the portal provided the information. Therefore, an RAI will be requesting to provide a summary that descirbes how the debris is disposed of, frequency of removal, and type of debris. The permit does not need to be docketed.

SW-8 Section 9.2 of the ER discusses the status of compliance with various authorizations and Section E3.6.1.2.5 of the ER discusses the compliance history over a six year period (2012-2017) related to SPS wastewater discharges. As a part of the discussion:

(a) Provide copy of the warning letter from the VDEQ (dated October 4, 2016) Dominion received regarding elevated bi-monthly BOD results from Outfall 101.

(b) Provide a copy of the January 2017 non-compliance report provided to VDEQ related to Enterococci bacteria exceedance referenced in section E3.6.1.2.5. Did VDEQ respond to SPSs noncompliance report? If so, provide copies of relevant correspondence.

(c) Identify and describe any SPS VPDES discharge exceedances, as well as any spills, leaks, and other inadvertent releases (e.g., petroleum products, chemicals) since 2017.

(d) Identify and describe any Notices of Violation (NOVs); nonconformance notifications; or infractions received from regulatory agencies associated with VPDES permitted discharges, received since 2017. Include self-reported violations. Provide copies of relevant correspondence to and from the responsible regulatory agencies.

Nancy Martinez (a) does not need to be docketed. (c ) and (d) responses on the portal will be requested for docketing. (b) was not provided on the portal and therefore a summary of its content will be requested as an RAI.

SW-9 Section E2.2.3.2 of the ER discusses thermal effluent dispersion for the discharge canal.

The ER states: During a period of high ambient water temperatures (August 6 to September 10, 1975) when SPS was running at 90% or greater capacity, discharge temperatures ranged from 92.8°F to 99.9°F. These temperatures are believed to be typical of those observed in the discharge canal in late summer when both SPS units are operating at or near full power (

Reference:

SPS. 2001, Section 3.1.2.1). There are no changes since the 2010 uprate. Temperatures immediately outside the discharge canal in the James River are lower, with the effluent losing 1-2°F with every 1,000 feet from the mouth of the discharge canal (

Reference:

SPS. 2001, Section 3.1.2.1). Provide a basis for concluding:

(a) The 1975 high ambient water temperatures recorded are representative of the discharge canal in late summer.

(b) There have been no changes in discharge temperatures (both in the canal and James River) as a result of the additional thermal loading from the approved 2010 measurement uncertainty recapture power uprate.

Nancy Martinez Response on the portal was not sufficient. As discussed during the breakout session, an RAI will be requesting, similarly as requested in this information need, a basis for concluding that under current SPS operating conditions and in consideration of the power uprate here have been no changes in discharge temperature or if current discharge temperatures are available to provide them.

SW-10 In a Clean Water Act 316(b) demonstration for SPS, the maximum temperature rise of water across the condensers was reported to be 7.8 °C (VEPCO 1980; ML020230042).

What is the temperature rise of water across the condensers under current operating conditions (taking into account the 2010 measurement uncertainty recapture power uprate and any other operational changes that could affect heat discharged to cooling water)?

Nancy Martinez Response on the portal was not sufficient. As discussed during the breakout session, an RAI will be requesting, similarly as requested in this information need, for a basis for concluding that under current SPS operating conditions and in consideration of the power uprate that there has been no change in the maximum rise of water across the condensers.

SW-11 Section E4.11.5.4 of the ER states that GNCTS shares air, wastewater, and groundwater withdrawal permits with SPS Units 1 and 2. Section E3.6.1.2.1 of the ER states potentially oil-contaminated stormwater runoff from GNCTS is pumped into the SPS settling basin, which is permitted to discharge to the James River via Outfall 001.

Clarify if VPDES permit VA0004090 is a SPS and GNCTS shared permit and identify all outfalls and sources that receive discharges as a result of GNCTS operation.

Nancy Martinez Response on the portal will be requested for docketing SW-12 The initial license renewal ER (submitted to the NRC in 2001) identifies that typical salinities in the area of the SPS intakes are up to 17.0 parts per thousand, while those in the area of the SPS discharge canal are typically lower at 0.0 to 9.2 parts per thousand.

Is the location of these salinity measurements in the river or in the canal? Have there been changes in salinities in the James River in the area of the SPSs intake and discharge canal since 2001? (As a part of the explanation, provide salinities in the area of the intake and discharge canal under current operating conditions).

Nancy Martinez Response on the portal was not sufficient. As discussed during the breakout session, an RAI will be requesting, similarly as requested in this information need, for salinity data, if available, from the James River specifically at the intake and discharge points under current operating conditions or if any change in salinity at the discharge and intake points have been observed.

SW-13 Section E2.2.3 of the ER states Cooling water is withdrawn from the James River through a channel dredged in the riverbed between the main river channel and the eastern shore of Gravel Neck Peninsula, a distance of approximately 5,700 feet.

Dominion has typically dredged this channel every 3-4 years to maintain a depth of approximately 13 feet (Section E2.2.7.2). Section E3.6.1.2.4 of the ER states Dominion regularly performs maintenance dredging of the intake channel. Dredging occurs as needed and is permitted under a USACE 13-RP-02 Regional Permit 2 authorizing the dredging of a 2,000-foot long by 150-foot wide channel. Section E2.2.7.2 further states: Dominion has dredged approximately 150,000 cubic yards from this channel every 3-4 years. During maintenance dredging within the existing intake channel on the James River (October 2016-January 2017), approximately 41,544 cubic yards were hydraulically dredged to a depth of 12 feet mean lower low water within a 2,000-foot long by 150-foot wide channel. Please provide explanation:

(a) Regarding the 5,700 ft distance discussed in Section E2.2.3 of the ER, clarify what this distance is referring to.

(b) Identify and clarify the portion of the intake channel that Dominion conducts maintenance dredging and the elevation that is maintained. During the requested meeting (break-out session) on surface water resources, please be prepared to identify in Figure E2.2-3 of the ER the location of maintenance dredging.

(c) Clarify if 150,000 cubic yards is the permitted limit and provide the range of typical dredged volumes.

Nancy

Martinez, Kevin Folk, Briana Grange, Bill Ford Only a response to (c ) was provided on the portal. This will be an RAI that will be requesting a, b, and c portions.

SW-14 Section E2.2.3.5 of the ER identifies that water for firefighting is obtained from 2 300,000-gallon water storage tanks that are supplied from two wells (SPS. 2016a, Section 9.10.2.2.1). However, Section E3.6.3.2 of the ER states that there are 3 wells that discharge into a common header that provides water to the two 300,000 gallon fire protection tanks: Wells B, C, and ER discharge into a common header that provides water to the two 300,000-gallon fire protection tanks (Well E was abandoned and replaced with Well ER in 2015). Clarify the apparent discrepancy regarding the number of wells that supply the 300,000 gallon water storage tanks.

Nancy Martinez Response on the portal will be requested for docketing SW-16 Section E2.2.3.2 of ER states that [a]t full power, SPS discharges 11.9 x 10E9 British thermal units (Btu) per hour into the James River estuary The initial license renewal of the ER (submitted to the NRC in 2001) similarly states that at full-power operation, SPS discharges 11.9 x 10E9 British thermal units (Btu)/hr into the James River In 2010, however, both units were uprated. Provide the current full power heat rejection to the James River after the increase in power from the approved 2010 measurement uncertainty recapture power uprate.

Nancy Martinez Response on the portal was not sufficient. As discussed during the breakout session, an RAI will be requesting, similarly as requested in this information need, a basis for concluding that SPS discharges 11.9 x 109 British thermal units (Btu) per hour into the James River under current operating conditions in light of the power uprate.

MET Meteorology and Air Quality Bob Hoffman

MET-1 Please clarify why hazardous air pollutant emissions are quantified in ER Table E3.3-12 for 2016 but not for the other years considered. Is more-recently reported emissions data available (e.g. 2017)?

Bob Hoffman Doket 2017 data comparable to data in ER Table E3.3-12 MET-2 Has Dominion received any notices of violation or non-compliances from the Virginia Department of Environmental Quality (VDEQ) regarding Surry Air Permit No. PRO50336 subsequent to the period discussed in ER Section E3.3.3.2 (i.e., 2012-2016)?

Bob Hoffman Docket response as listed on portal Microbiological Hazards Briana Grange MBH-1 Regulatory Guide 4.2, Supplement 1, Revision 1 states that, The applicant should consult the State agency responsible environmental health regarding the potential existence and concentration ofmicroorganisms in the receiving waters for plant cooling water discharge. The applicant should document the results of this consultation in the ER. The ER should include copies of correspondence with the responsible agency indicating concurrence with the applicants risk assessment and proposed mitigation strategy, if one is required. Please describe Dominion's consultation with the State related to microbiological hazards and the States views of the environmental health risks to the public from thermal effluent in the James River. Provide for NRC staff review copies of relevant correspondence between Dominion and the State.

Briana Grange Regulatory Guide 4.2, Supplement 1, Revision 1 states that, The applicant should consult the State agency responsible environmental health regarding the potential existence and concentration ofmicroorganisms in the receiving waters for plant cooling water discharge. The applicant should document the results of this consultation in the ER. The ER should include copies of correspondence with the responsible agency indicating concurrence with the applicants risk assessment and proposed mitigation strategy, if one is required.

a. Describe Dominion's consultation with the State related to microbiological hazards and the States views of the environmental health risks to the public from thermal effluent in the James River.

b. Please submit with this response copies of relevant correspondence between Dominion and the State.

Land Use Kevin Folk LU-1 Section E2.2.6 of the ER states that Dominion is currently developing a fourth ISFSI pad within the existing ISFSI area and which is scheduled to be completed by the end of 2020. Provide a brief summary description of the project including general design of the pad, area disturbed, footprint of the completed facility, storage capacity, and current project status.

Kevin Folk Docket the response listed on the portal.

LU-2 Section E9.5.10 of the ER describes Dominions process for obtaining a consistency certification for SPS subsequent license renewal from the Commonwealth of Virginia in accordance with the Federal Coastal Zone Management Act (CZMA). Dominion developed and submitted to VDEQ a CZMA consistency certification package (Appendix E of the ER). Dominion further states in the ER that VDEQ responded with a conditional concurrence on February 2, 2018. VDEQs February 2nd, 2018 response is contained in Dominions SLRA Supplement for Sufficiency Review, dated January 29, 2019, submitted to the NRC. Specifically, VDEQ states that its CZMA concurrence is conditional upon satisfaction of the following: DGIF [Department of Game and Inland Fisheries] input and concurrence on the intake technology and conditions implemented to minimize impacts to fisheries resources and incidental take of endangered species in accordance with Virginia Code §29.1-100 to §29.1-570. Given the conditional nature of the CZMA certification, describe the steps that Dominion proposes to undertake to complete the CZMA consistency certification process with VDEQ, including the projected timeframe for completion of all anticipated activities requested by VDEQ.

Kevin Folk Docket the response listed on the portal.

CI Cumulative Impacts Kevin Folk CI-1 Section E4.12 of the ER contains Dominions analysis of cumulative impacts. If Dominion has identified any additional past, present, or reasonably foreseeable projects or actions since the ER was prepared, provide the name, description, location, and status of any such projects.

Kevin Folk Document the response listed on the portal. In addition, provide a map or maps depicting the approximate locations of any newly identified projects.

CI-2 As referenced in the ER (e.g., Sections E2.2.7.2, E3.6.2.5, E3.7.2.6, and E4.1.2.4),

Dominion is developing an offsite dredge material management area (DMMA) as a replacement for Surrys current onsite facility, once the existing facility reaches capacity.

Provide the following information regarding this project:

(a) The projected remaining capacity and/or lifespan of the existing dredge material

pond, (b) A brief summary description of general design and operational features of the new offsite DMMA, dimensions of completed facility, and disposal capacity.

(c) The status of construction and permitting and when the new DMMA is expected to be available to receive dredged materials, (d) Area to be disturbed during construction of the DMMA and acreage of habitat types

affected, (e) A listing and brief summary of any resource studies that have been performed of the DMMA site, and (f) A listing and brief summary of the permits required for construction and operation of the DMMA and their receipt status; include copies of all permits received to date Kevin Folk, Briana Grange, Bill Ford, Nancy Martinez Docket the response(s) as discussed during the audit and provide the requested documentation. In the response, specify the total site acreage, acreage permanently disturbed during construction, total acreage temporarily disturbed during construction, acreage of forest and farmland permanently disturbed/converted during construction, and the acreage of wetlands converted during construction of the disposal facility and effluent pipeline.

CI-3 Section E2.2.6 of the ER references Dominions plans to develop a fifth spent fuel storage pad. Provide an update, if any is available, of Dominions plans for the pad including dimensions and the schedule for siting and constructing the facility. If a site has been selected, identify the location.

Kevin Folk Document the response listed on the portal.

CI-4 Section E2.3 of the ER states in part that Dominion does not anticipate that continued operations of SPS would adversely affect the environment and further does anticipate the need for any refurbishment for purposes of subsequent license renewal. Provide a brief description of any anticipated operation and maintenance activities with the potential to result in new ground disturbance during the second license renewal term, including any plans to demolish existing buildings or related facilities or plans to construct new facilities.

Kevin Folk Document the response listed on the portal.

CI-7 The offsite dredge material management area is currently undergoing permitting and evaluation. Dominion considers that it is being developed to support current station operations and is not in scope for subsequent license renewal. However, to better inform our independent review, we would like to discuss the layout and operation of the off-site dredge material storage site. Some of the questions we would like to discuss include:

(a) What is the quality of the soils that will be disturbed and stock piled?

(b) How much area will the new storage site occupy?

(c) How will the dredged material reach the new disposal site (i.e., by truck, pipeline, or surface water)?

(d) Will new surface water facilities need to be constructed to transport the dredged material?

(e) Will water in the dredged material seep into groundwater aquifers? If so, how salty will the water be?

Kevin Folk, Briana Grange, Bill Ford, Nancy Martinez No followup on these items, except as noted in CI-2.

SOC Socioeconomics Jeff Rikhoff SOC-1 Besides property tax payments, describe any other sizeable annual support payments (e.g., emergency preparedness fees and payments or fees because of the independent spent fuel storage installation), one-time payments, or other forms of non-tax compensation (if any) provided to local governments, agencies, communities, and other jurisdictions, on behalf of SPS.

Jeff Rikhoff SOC0-1 Provide updated property tax information, similar to the data provided in Table E3.9-2 of the ER. Include data for years 2017 and 2018, if available.

Jeff Rikhoff

ALT Alternatives Bob Hoffman ALT-1 Identify the available location(s) on or near the Surry site that would be suitable for siting replacement power generation (Also, please identify possible locations during the general tour).

Bob Hoffman Request Summary of discussion addressing replacement power location ALT-2 ER Section E7.2.1.1 identifies that the proposed NGCC replacement power plant would be designed to generate approximately 1,743 MWe with an 87% capacity factor to replace Surrys 1,676 MWe. However, ER Section E7.2.3.1 identifies that the same facility would be designed to generate approximately 1,710 MWe, and ER Table E8.0-2 identifies that the facility would be designed to generate a total of 1,926 MWe. Please explain (reconcile) these differences.

Bob Hoffman Docket revised response as discussed during the audit ALT-3 Land requirements for a replacement NGCC plant are stated to be 66 acres in ER Sections E7.2.3.1.1 and E7.2.3.3, but 83 acres in ER Table E8.0-2. Explain (reconcile) these differences.

Bob Hoffman Docket revised response as discussed during the audit ALT-4 Please clarify how the design capacity and assumed capacity factor of each component of Dominions proposed combination alternative contribute to replacing the 1,676 MWe generated by Surry. Confirm whether the 1,676 MWe is a gross or net value, and what, if any, capacity factor has been applied.

Bob Hoffman Docket revised response as discussed during the audit