ML21042B904
| ML21042B904 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/11/2021 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 21-041 | |
| Download: ML21042B904 (14) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 11, 2021 10 CFR 50 10 CFR 51 10 CFR 54 United States Nuclear Regulatory Commission Serial No.: 21-041 Attention: Document Control Desk NRA/DEA: RO Washington, D.C. 20555-0001 Docket Nos.: 50-338/339 License Nos.: NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION (NAPS) UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION (SLRA)
RESPONSE TO NRC REQUESTS FOR CONFIRMATION OF INFORMATION FOR THE ENVIRONMENTAL REVIEW
References:
- 1. Letter from Virginia Electric and Power Company to the US Nuclear Regulatory Commission dated August 24, 2020 (Serial No.20-115), "Virginia Electric and Power Company, North Anna Power Station Units 1 and 2, Application for Subsequent Renewed Operating Licenses," [Agencywide Documents Access and Management System (ADAMS) Accession No. ML20246G697]
- 2. Letter from Tam M. Tran of the US Nuclear Regulatory Commission to Daniel G. Stoddard of Virginia Electric and Power Company dated January 22, 2021, "Requests for Confirmation of Information for the Environmental Review of the North Anna Power Station, Units 1 and 2, Subsequent License Renewal Application," [ADAMS Accession No. ML21012A341]
In Reference 1, Virginia Electric and Power Company (Dominion Energy Virginia) submitted the SLRA for NAPS Units 1 and 2. In Reference 2, the NRC provided requests for confirmation of information (RCls) the staff will likely use in the Supplemental Environmental Impact Statement (SEIS), but which has not been previously docketed. The NRC RCls and Dominion Energy Virginia's confirmation of each RCI are provided in the enclosure.
Serial No.: 21-041 Docket Nos.: 50-338/339 Response to NRG RCls - NAPS SLRA Environmental Review Page 2 of 6 If there are any questions regarding this submittal or if additional information is needed, please contact Mr. Paul Aitken at (804) 273-2818.
Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support COMMONWEAL TH OF VIRGINIA )
)
COUNTY OF HENRICO )
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, who is Vice President - Nuclear Engineering and Fleet Support of Virginia Electric and Power Company. He has affirmed before me that he 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 his knowledge and belief.
Acknowledged before me this JJ fh day of f.ebrv.~r ,2021.
1 My Commission Expires: ~12-"--f/~3_1+-/1-_+~----
AIG D SLY otary Public nwealth of Virginia
. # 7518653 -i1 ber31,20'-_
Commitments made in this letter: None
Enclosure:
Response to NRG Requests for Confirmation of Information for the Environmental Review of the NAPS SLRA
Serial No.: 21-041 Docket Nos.: 50-338/339 Response to NRG RCls - NAPS SLRA Environmental Review Page 3 of 6 cc:
U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Ms. Lois James NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Tam Tran NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Vaughn Thomas NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 04 F-12 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. G. Edward Miller NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 NRC Senior Resident Inspector North Anna Power Station
Serial No.: 21-041 Docket Nos.: 50-338/339 Response to NRC RCls - NAPS SLRA Environmental Review Page 4 of 6 Mr. Marcus Harris Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 300 4201 Dominion Boulevard Glen Allen, Virginia 23060 State Health Commissioner Virginia Department of Health James Madison Building - 7th Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Mr. David K. Paylor, Director Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Melanie D. Davenport, Director Water Permitting Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Bettina Rayfield, Manager Office of Environmental Impact Review Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Mr. Michael Dowd, Director Air Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Mr. Justin Williams, Director Division of Land Protection and Revitalization Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Mr. James Golden, Regional Director Virginia Department of Environmental Quality Piedmont Regional Office 4949-A Cox Road Glen Allen, VA 23060
Serial No.: 21-041 Docket Nos.: 50-338/339 Response to NRC RCls - NAPS SLRA Environmental Review Page 5 of 6 Ms. Jewel Bronaugh, Commissioner Virginia Department of Agriculture & Consumer Services 102 Governor Street Richmond, Virginia 23219 Mr. Jason Bulluck, Director Virginia Department of Conservation & Recreation Virginia Natural Heritage Program 600 East Main Street, 24th Floor Richmond, VA 23219 Mr. Ryan Brown, Executive Director Director's Office Virginia Department of Wildlife Resources P.O. Box 90778 Henrico, VA 23228 Mr. Allen Knapp, Director Virginia Department of Health Office of Environmental Health Services 109 Governor St, 5th Floor Richmond, VA 23129 Ms. Julie Langan, Director Virginia Department of Historic Resources State Historic Preservation Office 2801 Kensington Ave Richmond, VA 23221 Mr. Steven G. Bowman, Commissioner Virginia Marine Resources Commission 2600 Washington Ave Newport News, VA 23607 Dr. Mary Fabrizio, Professor Virginia Institute of Marine Science School of Marine Science 7509 Roper Rd,, Nunnally Hall 135 Gloucester Point, VA 23062 Ms. Angel Deem, Director Virginia Department of Transportation Environmental Division 1401 East Broad St Richmond, VA 23219
Serial No.: 21-041 Docket Nos.: 50-338/339 Response to NRC RCls - NAPS SLRA Environmental Review Page 6 of 6 Mr. Stephen Moret, President Virginia Economic Development Partnership 901 East Byrd St Richmond, VA 23219 Mr. William F. Stephens, Director Virginia State Corporation Commission Division of Public Utility Regulation 1300 East Main St, 4th Fl, Tyler Bldg Richmond, VA 23219 Mr. Jeff Caldwell, Director Virginia Department of Emergency Management 10501 Trade Rd Richmond, VA 23236 Mr. Bruce Sterling, Chief Regional Coordinator Virginia Department of Emergency Management 1070 University Blvd Portsmouth, VA 23703
Serial No.: 21-041 Docket Nos.: 50-338/339 Enclosure RESPONSE TO NRC REQUESTS FOR CONFIRMATION OF INFORMATION FOR THE ENVIRONMENTAL REVIEW OF THE NAPS SLRA Virginia Electric and Power Company
{Dominion Energy Virginia)
North Anna Power Station Units 1 and 2
Serial No.: 21-041 Docket Nos.: 50-338/339 Enclosure - Page 2 of 8 Response to NRC Requests for Confirmation of Information for the Environmental Review of the NAPS SLRA North Anna Power Station, Units 1 and 2 Subsequent License Renewal Application By letter dated August 24, 2020, (Agencywide Documents Access and Management System Accession No. ML20246G703), Dominion Energy submitted an application for subsequent license renewal of Renewed Facility Operating License Nos. NPF-4 and NPF-7 for the North Anna Power Station, Unit Nos. 1 and 2 (North Anna) to the U.S.
Nuclear Regulatory Commission (NRG) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and part 54 of title 10 of the Code of Federal Regulations, "Requirements for renewal of operating licenses for nuclear power plants."
During the week of December 1, 2020, the NRG staff conducted an environmental audit of Dominion Energy's records to confirm information submitted in the North Anna license renewal application. During the audit, the staff reviewed documents that contain information which will likely be used in the Supplemental Environmental Impact Statement (SEIS). To the best of the staffs knowledge, this information is not on the docket or accessible in the public domain. Any information used to reach a conclusion in the SEIS must be included on the docket by the applicant.
Therefore, in a letter dated January 22, 2021, the NRG staff transmitted fourteen requests for confirmation of information (RCls) gathered during the environmental audit noted above. The NRG RCls and Dominion Energy Virginia's confirmation of each RGI are provided below.
REQUESTS FOR CONFIRMATION OF INFORMATION (RCls)
Groundwater Specific Regulatory Basis: ESRP Section 3.4 (II) and Section 4.4 (II) in accordance with 10 CFR 51.53(c)(ii)(P)
RCI No.1:
Based on the staff's review of the ER, groundwater sampling information in the North Anna 2020 "Radioactive Effluent Report" and, the Haley and Aldrich 2015 and 2020 reports, please confirm:
Monitoring Well PZ-3 tritium concentrations continue to remain approximately at the Minimum Detectable Activity dependent on the elevation of the water table. In the area PZ-3, leaching from historical tritium releases trapped or perched in porous vadose zone soils is likely to occur when these layers become saturated by relatively higher water table elevations.
Serial No.: 21-041 Docket Nos.: 50-338/339 Enclosure - Page 3 of 8 Dominion Response:
This information has been confirmed to be correct as stated, with the clarification that PZ-3 tritium concentrations continue to remain approximately at Lake Anna tritium levels (<5,000 pCi/L), not MDA.
RCI No. 2:
Based on the staff's review of the ER, groundwater sampling information in the North Anna 2020 "Radioactive Effluent Report" and, the Haley and Aldrich 2015 and 2020 reports, please confirm:
Recent sampling confirms that there was no presence of boron in the water in the pipe tunnel water, nor was there boron in the GWP-18 well sample. Sampling for boron was conducted to rule out a pipe leak within the tunnel. Based on field investigations, there was no indication that a pipe within the pipe tunnel was leaking.
Likely associated with the pipe tunnel concrete leaching tritium to the ground as there was no indication of a pipe leak, elevated GWP-18 concentration remediation activity included preventing surface and rain water from entering the pipe tunnel causing leaching of tritium from the concrete by sealing off external access points in the east-west tunnel section along the Waste Disposal building (also known as the BRT tunnel). Subsequent to removal of excess water from the pipe tunnel, GWP-18 concentrations have decreased to concentrations consistent with Lake Anna background levels. The pipe tunnel is now maintained in a dry condition due to the improvement efforts conducted during 2020 (i.e., sealing to prevent surface or rain water infiltration) minimizing any water seepage from the tunnel to groundwater.
Dominion Response:
This information has been confirmed to be correct as stated, with the clarification that documented evidence of boron sampling in the pipe tunnel water and GWP-18 is not available. However, during the investigation, sampling of the pipe tunnel water and GWP-18 was conducted for radionuclides other than tritium. No radionuclides other than tritium were detected, which provided an alternate means (e.g., other than sampling for boron) to rule out a pipe leak in the tunnel.
Noise RCI No. 3:
Based on the review of Section 3.4 of the ER and the ER states that North Anna Power Station received one noise complaint for the five-year period from 2013- 2017, please confirm:
Since 2017, NAPS has not received noise complaints.
Serial No.: 21-041 Docket Nos.: 50-338/339 Enclosure - Page 4 of 8 Dominion Response:
This information has been confirmed to be correct as stated.
Waste Management and Radiation Protection RCI No. 4:
Based on the review of Section 3.6.4.2.1 of the ER, between 2012 and 2019, there have been no inadvertent radioactive liquid releases. Please confirm:
There have not been any reportable unplanned releases of radioactive materials which would trigger a notification requirement since the ER was written.
Dominion Response:
This information has been confirmed to be correct as stated.
RCI No. 5:
Based on the review of section 3. 6.4.2.2 of the ER, site records for the most recent 7 years (2013-2019), indicate there have been no inadvertent nonradioactive releases that would not be classified as an incidental spill as defined by OSHA [Office of Safety and Health Administration]. Please confirm:
There has not been any reportable inadvertent release which would trigger a notification requirement since the ER was written.
Dominion Response:
This information has been confirmed to be correct as stated.
RCI No. 6:
Based on the staff's review of Section 9.5.3.6 of the ER, North Anna is subject to the reporting provisions of Title 40 of the Code of Federal Regulations 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 National Response Center. For the 7-year period of 2012-2018 there were no reportable spills. Please confirm:
There have not been any reportable spills which would trigger this notification requirement since the ER was written.
Dominion Response:
This information has been confirmed to be correct as stated.
Serial No.: 21-041 Docket Nos.: 50-338/339 Enclosure - Page 5 of 8 RCI No. 7:
Based on the staff's review of Section 9.5.5.12.6 of the ER, North Anna is subject to the reporting provisions of State Water Control Law §62.1-44.34:19. This reporting provision requires that any release of regulated substance from an underground storage tank containing a petroleum product be reported to the VDEQ [Virginia Department of Environmental Quality]. The only reportable spill occurring between 2013 and 2018 was an underground fuel oil leak from the leaking 2H B fuel oil feed line which occurred in December 2016 in which the amount of fuel oil that leaked was not quantified. Please confirm:
There have not been any reportable spills which would trigger this notification requirement since the ER was written.
Dominion Response:
This information has been confirmed to be correct as stated.
RCI No. 8:
Based on the staff's review of the ER information, please confirm:
Regarding the Radiation Protection Program (overview) with emphasis on the as low as reasonably achievable (ALARA) program to control worker radiation exposure (annual dose goals and status), there are currently no proposed changes or upgrades to the program being considered during the current or subsequent license renewal term.
Dominion Response:
This information has been confirmed to be correct as stated.
RCI No. 9:
Based on the staff's review of the ER for the radioactive solid waste program information, please confirm:
Concerning how the plant plans handle low-level radioactive waste (Class A, B, and C, mixed waste, and spent nuclear fuel) during the license renewal term (onsite storage, potential expansion of storage facilities, and disposal options), there are currently no proposed changes or upgrades to the radioactive solid waste program being considered during the current or subsequent license renewal term.
Dominion Response:
This information has been confirmed to be correct as stated.
Serial No.: 21-041 Docket Nos.: 50-338/339 Enclosure - Page 6 of 8 RCI No. 10:
Based on the staff's review of the ER for radioactive gaseous and liquid effluents information, please confirm:
Concerning how the plant processes radioactive effluents to maintain radiation doses to the public to levels that are ALARA, there are currently no proposed changes or upgrades to the program being considered during the current or subsequent license renewal term.
Dominion Response:
This information has been confirmed to be correct as stated.
Alternatives RCI No. 11:
Based on the staff's review of Section E.2.6 of the ER, the stated Units 1 and 2 replacement power value (1,672 MWe) does not appear to reflect the full generation capacity of the plant. Please confirm:
The basis for the replacement power value for NAPS Units 1 and 2 presented in Section E.2.6 of the NAPS ER (1,672 MWe) is Figure 5.3.1 of Dominion's 2018 Integrated Resource Plan (ER reference Dominion 2018a). This 1,672 MWe value only reflects . Dominion Energy's ownership portion of the plant's total licensed capacity of approximately 1,892 MWe, and not the approximately 11.6 percent portion under the ownership of the Old Dominion Electric Cooperative.
Dominion Response:
This information has been confirmed to be correct as stated.
Surface Water RCI No. 12:
Based Off the staff's review of the ER, please confirm:
Dominion has received no documented Notices of Viola(ion; nonconformance notifications; or related infractions from regulatory agencies associated with permitted effluent discharges, sanitary sewage systems, groundwater or soil contamination; as well as any such notifications involving spills, leaks, and other inadvertent releases (e.g., petroleum products, chemicals, or radionuclides) since 2019.
Dominion Response:
This information has been confirmed to be correct as stated.
Serial No.: 21-041 Docket Nos.: 50-338/339 Enclosure - Page 7 of 8 RCI No. 13:
Based on the staff's review of the ER, please confirm:
Concerning Commonwealth's regulations governing the issuance of water protection permits, no Virginia water protection permit is required and no new Clean Water Act
§401 water quality certification is necessary for a facility's surface water withdrawals that were in existence as of July 1, 1989. Further, no Virginia water protection is required for the discharge of wastes into surface waters if the facility's discharges are otherwise subject to a Virginia Pollutant Discharge Elimination System permit, as is the case for North Anna. Accordingly, Dominion is not required to maintain, and does not possess, a separate Virginia water protection permit for operation of North Anna, Units 1 and 2.
Dominion Response:
This information has been confirmed to be correct as stated, with the editorial clarification in square brackets added to the second sentence of RCI No. 13 as indicated below:
Further, no Virginia water protection [permit] is required for the discharge of wastes into surface waters if the facility's discharges are otherwise subject to a Virginia Pollutant Discharge Elimination System permit, as is the case for North Anna.
Additionally, it should be noted that on April 9, 2012, VDEQ issued Virginia Water Protection (VWP) permit 10-2001, which incorporated modifications and additions to account for the additional water withdrawal associated with the proposed North Anna Unit 3. Conditions related to releases from the Lake Anna Dam that are in the existing Virginia Pollutant Discharge Elimination System (VPDES) permit for North Anna Units 1 and 2 (Permit No. VA0052451) are duplicated and included in VWP permit 10-2001.
The VWP permit states that the VPDES permit conditions shall govern releases from the dam until such time as Dominion Energy notifies VDEQ of its intent to permanently raise the target pool elevation of Lake Anna three inches to support Unit
- 3. In a letter dated September 16, 2020 1 , VDEQ concluded that VWP permit 10-2001, "is the commonwealth's §401 Certification for the North.Anna Power Station."
1 Letter from Virginia Electric and Power Company to NRC, "North Anna Power Station (NAPS) Units 1 and 2 Subsequent License Renewal Application (SLRA) Requested Documents in Response to Environmental Audit," January 25, 2021, Agencywide Documents Access and Management System (ADAMS) Accession No. ML21033A301 (included as Enclosure 4, Attachment 3).
Serial No.: 21-041 Docket Nos.: 50-338/339 Enclosure - Page 8 of 8 Land Use RCI No. 14:
Based on the staff's review of Section E3. 1.4, please confirm that the following is still true:
Dominion is not pursuing developmental activities of and has made no decision to proceed with the construction of NAPS Unit 3.
Dominion Response:
This information has been confirmed to be correct as stated.