ML21053A433
| ML21053A433 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/22/2021 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 21-058 | |
| Download: ML21053A433 (21) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 22, 2021 10 CFR 50 10 CFR 51 10 CFR 54 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Serial No.:
21-058 VIRGINIA ELECTRIC AND POWER COMPANY NRA/DEA:
R1 Docket Nos.:
50-338/339 License Nos.: NPF-4/7 NORTH ANNA POWER STATION {NAPS) UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION {SLRA)
ENVIRONMENTAL REVIEW RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION
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 Robert B. Elliott of the US Nuclear Regulatory Commission to Daniel G. Stoddard of Virginia Electric and Power Company dated January 29, 2021, "Requests for Additional Information - North Anna Subsequent License Renewal Application Environmental Review," [ADAMS Accession No. ML21028A390]
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 staff transmitted a request for additional information (RAI) to support completion of the Environmental Review. The response to the RAI is provided in the enclosure.
Serial No.: 21-058 Docket Nos.: 50-338/339 Response to RAI - 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.
-b Acknowledged before me this 1Z_ day of f~ n..f.arf, 2021.
My Commission Expires: IJ /JI /,:;..tj I
I AIG D SLY tary Public wealth of Virginia
. # 7518653
.,d 31, 20!:l Commitments made in this letter: None
Enclosure:
Response to NRG Request for Additional Information - ; NAPS SLRA Environmental Review
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Serial No.: 21-058 Docket Nos.: 50-338/339 Response to RAI - NAPS SLRA Environmental Review Page 3 of 6 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.: 21-058 Docket Nos.: 50-338/339 Response to RAI - NAPS SLRA Environmental Review 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 Page 4 of 6
Serial No.: 21-058 Docket Nos.: 50-338/339 Response to RAI - NAPS SLRA Environmental Review 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 Page 5 of 6
Serial No.: 21-058 Docket Nos.: 50-338/339 Response to RAI - NAPS SLRA Environmental Review 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 Page 6 of 6
Enclosure Serial No.: 21-058 Docket Nos.: 50-338/339 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION NAPS SLRA ENVIRONMENTAL REVIEW Virginia Electric and Power Company (Dominion Energy Virginia)
North Anna Power Station Units 1 and 2
Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 2 of 15 Response to NRC Request for Additional Information NAPS SLRA Environmental Review North Anna Power Station, Units 1 and 2 Subsequent License Renewal Application By letters 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."
In a letter dated January 29, 2021, the NRG staff transmitted a request for additional information (RAI), containing three questions, to support completion of the Environmental Review. Dominion Energy Virginia's response to the RAI is provided below.
Question Number: 127 Cumulative Impact Requirement 10 CFR 51.53(C)(3)(/l)(O) requires that applicants provide information about other past, present, and reasonably foreseeable future actions occurring in the vicinity of the nuclear plant that may result in a cumulative effect.
Table B-1 of 10 CFR Part 51, Appendix B to Subpart A-Cumulative Impacts, requires that the NRG staff evaluate the cumulative impacts of continued operations or refurbishment associated with license renewal in conjunction with regional resource characteristics, the resource-specific impacts of license renewal, and the cumulative significance of other factors affecting the resource.
Section 4.12 of NUREG-1555, Supplement 1, Revision 1, "Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Operating License Renewal," directs the staff to "identify and calculate the likely cumulative environmental impacts for the area(s) or region(s) currently or likely to be affected by power plant operations and/or refurbishment activities associated with license renewal."
Issue An environmental audit breakout session was held on 12/2/2020 to address the NRG staff's information need Gl-1, which requested the name, description, location, and status of any additional past, present, or reasonably foreseeable projects or actions that have been identified since the Environmental Report (ER) was prepared. Dominion Energy staff identified three new proposed projects at NAPS that were in addition to those
Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 3 of 15 previously addressed in Section E4.12.2 of the ER: 1) replacement of the NAPS Wastewater Treatment Plant, 2) installation of osprey nest platforms, and 3) construction of the Cyber Security Testing Facility. The NRG staff requires the information posted to the North Anna portal and discussed during the breakout session to be docketed in order to assess the potential cumulative impact of these projects.
Request Provide a summary of the environmental audit discussion held on 12/2/2020 addressing the narrative response to Cl-1 and the supporting information posted by Dominion on the North Anna portal. Summary should include the name, description, location, and status of any additional past, present, or reasonably foreseeable projects or actions that have been identified since the ER was prepared. This should include the proposed NAPS Wastewater Treatment Plant replacement, Osprey Nest Platform installation, and Cyber Security Testing Facility construction.
Dominion Response There are four reasonably foreseeable projects or actions that have been identified since the Environmental Report (ER) was prepared.
An additional project was identified following the audit and this project is addressed below with the other three that were discussed at the audit.
Project #1:
NAPS Wastewater Treatment Plant (WWTP) Replacement Project - The existing NAPS WWTP is approximately 38 years old and needs rehabilitation and upgrade improvements soon for safety and to prevent accidental waste discharge due to structural failure. Currently, plans are conceptual, but NAPS has initiated a proposed project to install a permanent, fully functional WWTP replacement The new WWTP would incorporate better technology to allow NAPS to meet any future discharge limits. The proposed replacement plant would be located within the existing WWTP footprint The location of the WWTP (labeled as "Sewage Treatment") relative to other plant structures is depicted on Figure E3.1-1 of the Environmental Report.
The general construction sequence is anticipated as follows: install a permanent, fully functional replacement plant of equal capacity to the existing plant, transfer all liquid from the existing tanks to the new plant, divert all incoming raw flows to the new plant, and then demolish and/or rehabilitate the existing WWTP structures.
During the Preliminary Engineering Conference, the Virginia Department of Environmental Quality verified that the NAPS current Wastewater Discharge Permit allows for the replacement of the current plant and there is no need to wait for the permit renewal (currently under review) to proceed. The proposed project is partially funded, and the preliminary timeline targets early 2022 for construction start and October 2022 for completion of all project phases.
Project #2:
Serial No.: 21 -058 Docket Nos.: 50-338/339 Enclosure - Page 4 of 15 Osprey Nest Platform Installation - Ospreys have, in the past, constructed nests on top of the spires of the backbone in the switchyard. Their sticks and feces were causing issues within the switchyard but had not caused an outage. To deter further nesting and associated hazards in the switchyard, perch deterrents were installed on the spires and an alternative platform was erected immediately adjacent to the switchyard in February 2020. During the 2020 nesting season, an osprey pair constructed a nest on the alternate platform. In February 2021, five additional nest platforms were constructed in the area near the switchyard and along the lake to further encourage nesting outside the switchyard. The locations for the new nest platforms are shown below in the locations marked with a red 'X'.
The area of ground disturbance for each pole was a circle approximately four feet in diameter.
Project #3:
Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 5 of 15 Cyber Security Test Facility project-NAPS is implementing a Digital Modernization project where numerous Critical Digital Assets (CDAs) will be received from suppliers for various station projects. The CDAs will be stored and tested in a new Cyber Security Testing Facility {CSTF) which will be located onsite outside the Protected Area. The proposed CSTF location is on previously disturbed land, west of the existing steam generator storage facility and north of the plant main access road. A satellite view of the general location along with a site plan that depicts the proposed footprint are provided below. The CSTF will have utility tie-ins with existing plant systems/utilities which include the station's potable water system, fire water supply system, the sewage system, network system, and telecommunication system. Additionally, electrical power will be supplied to the new facility. The current proposed CSTF schedule and anticipated potential permits are provided below.
Proposed Schedule Milestones:
Detailed design complete for facility by the 1st quarter of 2022 Detailed design complete for the CSTF utilities tie-ins by the 2nd quarter of2022 Construction complete by 1st quarter of 2023 Anticipated Permits:
Building Permit Excavation Permits Louisa County Permit Louisa County Land Disturbance Permit Louisa County Zoning Louisa County Occupancy Permit
R Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 6 of 15
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Project #4:
Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 7 of 15 Main Generator Storage Building - The main generators are anticipated to be replaced in 2028 (Unit 1) and 2031 (Unit 2). A storage facility with a reinforced floor to withstand the weight of the main generator is necessary, and it has been determined that there is insufficient storage available on-site for this purpose. To meet this need, construction of a new storage building is planned outside the Protected Area and within the Owner-Controlled Area of the plant. Most of the facility will be designated for storage, with a portion designated for office space and workshops.
The building is planned to be located to the north side of Warehouse 5. An aerial view and site plan are provided below showing the project location. The building will be approximately 125' by 250'. The dirt road in this area is planned to be partially upgraded to a gravel road. Pathways between the doors on the north face of Warehouse 5 and the south face of the Storage Building are planned to be added. The building will be tied into existing plant utilities (electricity, fire protection, potable water, sewer, and telecommunications}.
The project is currently in the cost estimation phase. Completion of construction is anticipated by the end of 2023.
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Question Number: 126 Aquatic Requirement Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 9 of 15 Table B-1 of 10 CFR Part 51, Appendix B to Subpart A-Environmental Effect of Renewing the Operating License of a Nuclear Power Plant requires that the U.S. Nuclear Regulatory Commission (NRG) staff evaluate whether microbiological hazards to the public (plants with cooling ponds or canals or cooling towers that discharge to a river) will result in SMALL, MODERATE, or LARGE impacts during nuclear power plant license renewal.
Section 4.8.1 of NUREG-1555, Supplement 1, Revision 1, "Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Operating License Renewal," directs the staff to evaluate as part of its review of the issue of microbiological hazards to the public any "available data concerning the occurrence and concentrations of any of the deleterious thermophilic microorganisms listed above in the vicinity of the plant and a determination of whether any of them are present under conditions and in locations that might be harmful to members of the public."
Issue Sections E3.10.1 and E4.9.1 of the North Anna Environmental Report (ER) (ADAMS Accession No. ML20246G698) describe harmful algal blooms caused by elevated levels of cyanobacteria in Lake Anna in 2018. In order to fully assess the issue of whether these blooms constitute a microbiological hazard to the public and to support the staff's finding of SMALL, MODERATE, or LARGE for this issue, the NRG staff requires updated information on this issue (i.e., 2019-present) and further information on Dominion Energy Virginia's (Dominion) monitoring and mitigation efforts that minimize or mitigate health risks to the public.
Please answer the following questions concerning harmful algal blooms in Lake Anna.
Request1 Is Dominion aware of any harmful algal blooms in Lake Anna (either Lake Anna Reservoir or the* Waste Heat Treatment Facility (WHTF)) prior to 2018? If so, please describe the location and duration of the blooms.
Dominion Response Dominion Energy is not aware of any harmful algae blooms in the Lake Anna Reservoir or WHTF prior to 2018.
Reguest2 Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 10 of 15 Has Dominion observed any harmful algal blooms in the WHTF since 201 B? If so, please describe the location and duration of these blooms and any steps Dominion took to monitor or mitigate the blooms. Provide both a narrative description and a diagram or map, if available.
Dominion Response As discussed in Section E3.10.1 and E4.9.1 of the Environmental Report, Dominion Energy observed potentially harmful algal blooms in four locations in the Waste Heat Treatment Facility (WHTF) in 2018. Swim advisories were issued in September 2018 for Beaver Creek, Elk Creek, Millpond Creek, and Moody Creek. The blooms were located near the yellow markers shown on the map below, in areas of stagnant water such as coves. The yellow markers correspond to water sampling locations. These sample locations were selected to provide representative sample points for the nearby algal blooms.
In 2019, Dominion Energy again observed potentially harmful algal blooms in the WHTF.
These blooms were continuations of the algal blooms first observed in the summer of 2018. Dominion Energy collected phytoplankton and toxin samples at 6 locations in the WHTF every few weeks from February 2019 to July 2019. These sample locations included the four creeks where blooms first occurred in 2018 (Elk Creek (38.01521, -
77.81323), Moody Creek (38.00242,-77.76137), Beaver Creek (38.02703,-77.81321) and Millpond Creek 1 (38.00650,-77.78783)). Two additional sample locations, Millpond Creek 2 (38.00374,-77.79727) and Lagoon 1 (38.046385,-77.788999) were also sampled at times during that period. These additional sample locations were based on citizen reports and Dominion Energy field observations of potential blooms. A swim advisory for Lagoon 1 was not issued. The swim advisory issued in 2018 for the bloom near the Millpond Creek 1 sampling location extended to Millpond Creek 2 (the advisory was not confined to a specific area of Millpond Creek).
In accordance with Virginia Department of Health (VDH) guidelines, and based on the sample results, all swim advisories for the WHTF were lifted as of July 25, 2019.
No known potentially harmful algal blooms were observed by Dominion Energy in the WHTF in 2020. A citizen report of a potential bloom near dike 3 was made in September 2020. Dominion Energy biology personnel investigated the citizen report and found no visible signs of an algal bloom in the reported location, and the water quality was within normal parameters.
Dominion Energy actively participates in multiple stakeholder groups and organizations that have a focus on the study and mitigation of harmful algal blooms in Lake Anna.
Specifically, Dominion Energy is supporting efforts by the Lake Anna Advisory Committee (LAAC) to solicit a study of harmful algal blooms on the North Anna branch of Lake Anna and is engaged in ongoing discussions with VDH, the Virginia Department of Environmental Quality (VDEQ), Virginia Polytechnic Institute and State University,
surrounding localities and others regarding Lake Anna harmful algal blooms.
Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 11 of 15 In addition, Dominion Energy and the Dominion Energy Charitable Foundation have awarded grant funding to the Lake Anna Civic Association for a floating wetland pilot program. A floating wetland is a floating raft of native wetland plants that absorbs and competes with algae for nutrients, which has the potential to reduce the occurrence of harmful algal blooms. Dominion Energy funding will allow purchase of the materials necessary to build and deploy a floating wetland to use in a future study of impact to nutrient loads.
Reguest3 For each of the harmful algal blooms that Dominion has documented in the WHTF (2018-present), please specify what members of the public were able to access the affected waters (i.e., all members of the public, only adjacent private landowners, no members of the public if the blooms were within the plant protected area, etc.).
Dominion Response The WHTF is a private body of water accessible only by private landowners and homeowner associations bordering the WHTF and their guests. The observed blooms were not within any plant protected areas, so only private landowners and homeowner associations bordering the WHTF and their guests would have been able to access the affected waters.
Reguest4 Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 12 of 15 The ER (p. E-3-127) states that Dominion "issued no-swimming advisories for four WHTF areas" in 2018. For what four areas of the WHTF were these no-swim advisories made?
Provide both a narrative description and a diagram or map, if available.
Dominion Response No-swim advisories were made for the following WHTF locations: Elk Creek, Moody Creek, Beaver Creek and Millpond Creek. The sampling locations for these creeks, which are representative of where blooms were observed, are depicted on the aerial map below.
Printed notifications are placed at the access gates to the common areas of nearby subdivisions. Past postings have been made at the Seclusion Shores, the Waters at Lake Anna, the Village at Lake Anna, and the Mill Run subdivisions.
Requests Where can the public access Dominion's no-swim advisories? Please provide any of the following, if relevant: publicly available webpage address, printed notices, and locations of physically posted advisory signs at Lake Anna.
Dominion Response If a no-swim advisory is issued, information is made publicly available at the following publicly available website address:
https://www.dominionenergy.com/projects-and-facilities/nuclear-facilities/north-a n na-power-station/waste-heat-treatment-f aci I ity
Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 13 of 15 Dominion also notifies the Virginia Department of Health and provides the information to local media outlets. Printed notifications are placed at the access gates to the common areas of affected subdivisions. Past postings have been made at the Seclusion Shores, the Waters at Lake Anna, the Village at Lake Anna, and the Mill Run subdivisions. An example of a Dominion no-swim advisory printed notice for posting at the WHTF locations is shown on the following page.
Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 14 of 15 Example WHTF No-swim Advisory Printed Notice ATTENTION POTENTIALLY HARMFUL ALGAE HAVE BEEN DETECTED Water quality is being monitored to determine if health risks may be present.
- Avoid swimming and wading in areas where surface swm is present
- Keep away children, pets, and animals, who are more likely to swallow water
- Thoroughly wash skin with dean fresh water after contact SOME ALGAE MAY CAUSE ILLNESS Call your doctor or veterinarian if you or your animals experience illness or signs of poisoning.
While fish consumption is not affected by toxic algae, thoroughly cleaning the fish, discarding the carcass & guts, &
washing hands & surfaces afterward with soapy water is advised.
Request 5 To report a suspected Harmlul Algae Bloom FIii out the Harmful Algae Bloom Dnllne Form at www.SwlmHealthJVA.com To report health enacts onlv. call the VDH hotline at 888-238-6154 Get more informauon at www.SwimHealthJVA.com Dominion Response (continued)
In addition to the no-swim advisories posted by Dominion at WHTF locations, the VDH posts advisory signs for harmful algal blooms on the North Anna Reservoir.
Request6 Serial No.: 21-058 Docket Nos.: 50-338/339 Enclosure - Page 15 of 15 During the proposed license renewal term, does Dominion anticipate continuing to monitor cyanobacteria according to its 2018 plan, issuing related no-swim advisories to the public, and generally coordinating with the Virginia Department of Health (VDH) regarding harmful algal blooms?
Dominion Response Dominion Energy anticipates continuing to monitor cyanobacteria according to its 2018 plan, issuing related no-swim advisories to the public, and generally coordinating with the VDH regarding harmful algal blooms during the proposed license renewal term.
In addition, Dominion Energy will rely on the expertise of VDH and will modify the sampling plan and advisory thresholds as necessary based on VDH guidance and the best available science.
Question Number: 140 Electric Shock In Sections E3.10.2, Electrical Shock Hazards, and E4.9.2.4, Analysis, of the North Anna Power Station Units 1 and 2 Subsequent License Renewal Environmental Report (ER),
Dominion states "Concerning the aboveground in-scope transmission lines, a 2018 investigation by Dominion confirmed that the steady-state discharging current in a worst-case scenario would be less than NESC standard of 5 mA rms." However, a reference citation to this report is not provided in the ER like was done for shock hazard avoidance by providing two Dominion electrical safety documents as references.
Request To provide clarity as to the analysis Dominion relied upon for demonstrating compliance with National Electrical Safety Code (NESC) standard of 5 mA rms, the staff requests that Dominion provide a reference citation to the above 2018 investigation as was provided for ER references Dominion 2017c and Dominion 2017d shown on ER page E-10-4. Also, please provide information on the version of NESC containing the NESC standard of 5 mA rms that was applied in the 2018 investigation.
Dominion Response The 2018 investigation is titled, "North Anna Nuclear Power Plant Discharge Current Investigation," and was authored by Dominion Energy Electric Transmission personnel on 10/19/2018. The investigation utilized the 2012 Edition of the NESC Code, published by IEEE.