ML21098A261
| ML21098A261 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/08/2021 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 20-060G | |
| Download: ML21098A261 (25) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 April 8, 2021 10 CFR 50 10 CFR 51 10 CFR 54 United States Nuclear Regulatory Commission Serial No. : 20-060G Attention: Document Control Desk NRA/DEA: RO Washington, D.C. 20555-0001 Docket Nos. : 50-280/281 License Nos. : DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION (SPS) UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION (SLRA)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE ENVIRONMENTAL REVIEW COASTAL ZONE MANAGEMENT ACT (CZMA) CONSISTENCY CERTIFICATION By letter dated August 3, 2017, Dominion Energy submitted a Coastal Zone Management Act (CZMA) Consistency Certification to the Virginia Department of Environmental Quality (DEQ) to support the subsequent license renewal of SPS, Units 1 and 2. By letter dated February 2, 2018, the DEQ provided a conditional concurrence that the subsequent license renewal was consistent with the Coastal Zone Management Program.
In a February 5, 2020 email, the US Nuclear Regulatory Commission (NRC) staff issued a request for additional information (RAI) [Agencywide Documents Access and Management System (ADAMS) Accession No. ML20029D838] to Dominion Energy that acknowledged the conditional concurrence letter and indicated the renewed operating licenses could not be issued until the state concurred with Dominion Energy's CZMA Consistency Certification.
The RAI letter indicated the following:
Provide a revised CZMA consistency certification determination for Surry subsequent license renewal or other updated correspondence issued by the Commonwealth of Virginia that updates the status of the CZMA consistency certification process. This documentation should show that either the conditions specified in VDEQ's February 2, 2018 letter have been resolved or that Dominion and the Commonwealth of Virginia have reached other terms that resolve the Commonwealth's Conditional Concurrence finding.
Subsequent to the February 5, 2020 RAI, Dominion Energy continued to correspond with VDEQ and the Virginia Department of Game and Inland Fisheries (now Virginia Wildlife
Serial No. 20-060G Docket Nos. 50-280/281 SLRA ER RAI Response - CZMA Consistency Cert.
Page 2 of 6 Resources) with the goal of obtaining a revised CZMA consistency determination letter from the VDEQ.
By letter dated April 1, 2021, the DEQ provided unconditional concurrence that the subsequent license renewal of SPS Units 1 and 2 was consistent with the Virginia Coastal Zone Management Program.
The purpose of this letter is to provide a response to the RAI. Accordingly, the Enclosure to this letter provides a copy of the April 1, 2021 letter issued by the Commonwealth of Virginia that updates the status of the CZMA consistency certification process.
If you have any questions or require additional information regarding this submittal, please contact Mr. Paul Aitken at (804) 273-2818.
Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support COMMONWEALTH 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 ,g+~ day of .4w; I
/ , 2021 .
My Commission Expires: _1~'-/,_3~1,,__/2_'/~-----
CRAIG D SLY Notary Public Commonwealth of Virginia Reg. # 7518653 My Commission Expires December 31, 2o:J.
Commitments ma e 1n t 1s t er:
Enclosure:
Response to NRC Request for Additional Information, SPS SLRA Environmental Review, Letter from Virginia Department of Environmental Quality, Unconditional Concurrence with Consistency Certification, dated April 1, 2021
Serial No. 20-060G Docket Nos. 50-280/281 SLRA ER RAI Response - CZMA Consistency Cert.
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 NRC Senior Resident Inspector Surry Power Station Ms. Angela Wu NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-11 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 0-11 F1 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 O-9E3 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Vaughn Thomas NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop O 4F12 11555 Rockville Pike Rockville, Maryland 20852-2738
Serial No. 20-060G Docket Nos. 50-280/281 SLRA ER RAI Response - CZMA Consistency Cert.
Page 4 of 6 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 Ms. Kathryn Perszyk Land Division Director Virginia Department of Environmental Quality 1111 East Main Street Suite 1400 Richmond, VA 23219 Mr. James Golden, Regional Director Virginia Department of Environmental Quality Piedmont Regional Office 4949-A Cox Road Glen Allen, VA 23060
Serial No. 20-060G Docket Nos. 50-280/281 SLRA ER RAI Response - CZMA Consistency Cert.
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, 51h Floor Richmond, VA 23129 Ms. Julie Langan, Director Virginia Department of Historic Resources State Historic Preservation Office 2801 Kensington Avenue Richmond, VA 23221 Mr. Steven G. Bowman, Commissioner Virginia Marine Resources Commission 380 Fenwick Road Building 98 Fort Monroe, VA 23651 Ms. Angel Deem, Director Virginia Department of Transportation Environmental Division 1401 East Broad Street Richmond, VA 23219 Mr. Stephen Moret, President Virginia Economic Development Partnership 901 East Byrd Street Richmond, VA 23219
Serial No. 20-060G Docket Nos. 50-280/281 SLRA ER RAI Response - CZMA Consistency Cert.
Page 6 of 6 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 Road Richmond, VA 23236 Mr. Bruce Sterling, Chief Regional Coordinator Virginia Department of Emergency Management 7511 Burbage Drive Suffolk, VA 23435 Mr. Jonathan Lynn, Administrator Surry County 45 School Street Surry, VA 23883
Serial No. : 20-0608 Docket Nos.: 50-280/281 Enclosure RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION SPS SLRA ENVIRONMENTAL REVIEW LETTER FROM VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY UNCONDITIONAL CONCURRENCE WITH CONSISTENCY CERTIFICATION dated April 1, 2021 Virginia Electric and Power Company (Dominion Energy Virginia)
Surry Power Station Units 1 and 2
VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY 1111 E. Main Street, Suite 1400, Richmond, Virginia 23219 P.O. Box 1105, Richmond, Virginia 23218 (800) 592-5482 www.deg.virginia.gov Matthew J. Strickler David K. Paylor Secretary of Natural Resources Director (804) 698-4000 April 1, 2021 Dominion Energy Attn: Amanda B. Tornabene Vice President and Chief Environmental Officer Dominion Energy 120 Tredegar St Richmond, VA 23019 RE: Federal Consistency Certification for the VEPCO Surry Power Station Units 1 and 2 Subsequent License Renewal, US Nuclear Regulatory Commission, Surry County, (DEQ 17-121 F)
Dear Ms. Tornabene:
On February 2, 2018, the Commonwealth of Virginia completed its review of the above-referenced Federal Consistency Certification (FCC). The Department of Environmental Quality (DEQ) is responsible for coordinating Virginia's review of federal consistency documents submitted pursuant to the Coastal Zone Management Act (CZMA) and providing the state's response. As a result of that review, DEQ issued a conditional concurrence. The concurrence was conditioned upon the Department of Wildlife Resources' (DWR, formerly the Department of Game and Inland Fisheries) input and concurrence with intake technology to minimize impacts to fishery resources.
SUBSEQUENT COORDINATION In association with the Virginia Pollution Discharge Elimination (VPDES) permit currently under review by DEQ, Dominion Energy prepared reports in accordance with Clean Water Act 40 CFR 316(b) Section 122.21 (r)(2)-(9) and two collegially developed reports:
a White Paper and the Oyster Report. The Virginia Institute of Marine Science (VIMS),
the Virginia Marine Resource (VMRC) and the DWR reviewed these reports and conducted significant coordination with Dominion Energy during the early part of 2021 .
On February 22, 2021, VIMS, at the direction of the VMRC, and with the concurrence of the Director of the DEQ and the Executive Director of DWR, provided their assessment of Dominion Energy's proposed mitigative strategy of reducing river water intake volume at the Surry Nuclear Power Station (SNPS) by approximately 25% during May and June
of each year. On March 4, 2021, DWR provided comment to staff of DEQ supporting Dominion Energy's proposal for 25% seasonal flow (intake) reductions in May to June of each year but requested seasonal reductions from April - June (at a minimum) to best protect anadromous fishes and perhaps during a period in the fall, when federal Endangered Atlantic Sturgeon are spawning (August 1 - November 15). In addition, DWR recommended additional mitigation strategies be implemented.
On March 15, 2021, VMRC responded to both the VIMS and DWR assessments requesting that Dominion Energy consider adding flow reductions for the month of April.
VMRC also agreed with the VIMS and DWR positions that further mitigative measures be evaluated. Included in this response, VMRC provided two mitigation proposals (Alosine recruitment and James River connectivity) to Dominion Energy. On March 18, 2021, Dominion Energy agreed to additional flow reductions in April, where practicable, and on March 31, 2021, Dominion Energy provided a letter VMRC stating that Dominion Energy "fully expects and commits to evaluating mitigation with the agencies during the Surry Power Station's 316(b) process currently being performed ." In response, on March 31, 2021, DWR and VMRC provided unconditional concurrence with the FCC.
FEDERAL CONSISTENCY CONCURRENCE Based on our review of the FCC, subsequent coordination and the comments and recommendations submitted by agencies administering the enforceable policies of the Virginia CZM Program, DEQ concurs that the Proposed Action is consistent with the Virginia CZM Program. If, prior to construction, project activities should change significantly and any of the enforceable policies of the Virginia CZM Program would be affected, pursuant to 15 CFR §930.66, Dominion Energy must submit supplemental consistency certification to DEQ for review and concurrence.
Thank you cooperation and continued coordination on this project. Please contact me at (804) 698-4204 for clarification of these comments.
Sincerely, Bettina Rayfield, Program Manager Environmental Impact Review and Long-Range Priorities Enclosures Ee: David Paylor, DEQ Ryan Brown, DWR Ray Fernald, DWR Amy Ewing, DWR Steven Bowman, VMRC 2
Randy Owen, VMRC Lyle Varnell, VIMS Tam Tran, NRC 3
Office of Research and Ad11isory Services VIRGINIA INSTITUTE OF MARINE SCIENCE February 22, 2021 Steve G. Bowman, Commissioner David K. Paylor, Director Virginia Marine Resources Commission Virginia Depaiiment of Environmental Quality 380 Fenwick Road, Building 96 1111 East Main Street, Suite 1400 Fort Monroe, VA 23651 Richmond, VA 23219 Ryan J. Brown, Executive Director Virginia Depaiiment of Wildlife Resources 7870 Villa Park Drive, Suite 400 Henrico, VA 23228-0778 Messrs. Bowman, Brown, and Paylor, At the direction of the Virginia Commissioner of Marine Resources, with the concurrence of the Director of the Virginia Department of Environmental Quality and the Executive Director of the Virginia Department of Wildlife Resources, the Virginia Institute of Marine Science (VIMS) and Dominion Energy representatives assessed the ecological value of Dominion Energy's proposed mitigative strategy of reducing river water intake volume at the Surry Nuclear Power Station (SNPS) by approximately 25%
during May and June of each year. The objective of this proposal is to reduce the mortality of eggs, larvae, and juveniles of fauna that inhabit the James River during peak times for these life stages of select species.
These data and analyses were requested as necessary information for use by Virginia natural resource agencies in decisions affecting the SNPS relicensing process.
Two collegially developed reports resulted from this effort: a White Paper, focusing primarily on ASMFC managed species, but including all collected species; and the Oyster Report, specific to entrainment impacts to oyster larvae. Scientists from VIMS and Dominion Energy are in agreement with the reliability of the data, the sampling and analyses methods, and the assumptions on which the analyses are based. Dominion Energy data used in the White Paper and also presented in the recent Clean Water Act §316(b) (the Act)
Compliance Submittal were collected and analyzed consistent with the Act's requirements. These requirements result in credible information with reasonable confidence in the summary results, but it is important to understand that these data result from monitoring schemes that generally are less rigorous than most research-based studies designed specifically to develop robust population loss estimates and confidence intervals used in statistical comparisons. A more research-based approach, which is well beyond the Act's legal requirements, would likely result in reduced uncertainty in mortality estimates but would significantly increase effort and costs.
The Oyster Report showed that mortality to oyster larvae was high (and likely overestimated due to difficulties in species identification of early bivalve larval stages), but were proportionally minimal to the annual level of oyster spawn in the James River as estimated by VIMS . We agree with Dominion's conclusions of minimal impact to James River oyster resources from nmmal SNPS water withdrawals.
The results presented in the White Paper show that the proposed pumping reduction reduces potential impingement and entrainment mo1iality for some species of commercial and recreational fisheries concern, and also for many species critical to overall river ecology. Projections of losses to adult populations from P 0. Box I '.$4(i
- l '.'>70 (;rcatc Road
- www.vims.edu
Ecological Value Assessment of Dominion Energy's Proposed Mitigative Strategy Page 2 of3 larvae, egg, and juvenile mortality estimates are emphasized, especially for ASMFC-regulated species.
These "adult equivalency" estimates add context to the egg, larva, and juvenile loss data, and are the primary endpoint estimates of data analyses used to demonstrate probable species mortalities. Calculating these estimates relies heavily on the particular model applied and the accuracy of natural mortality rates presented in the scientific literature. It is important to understand, however, that egg, larva, and juvenile mmiality from intake operation removes these organisms from the ecosystem and therefore they do not contribute to the overall local ecology - some individuals of these life stages would succumb naturally as a food source for other species.
Unlike the recent §316(b) rep01i that used these same data, the White Paper provides some data ranges (minimum-maximum) and broad-level confidence limits that provide further context and serve to demonstrate the variability surrounding the mortality estimates. High variability associated with estimates of wild population metrics from limited sampling is expected and the analytical methods were appropriate.
The report clearly states the challenges resulting from multi-level compounding of error estimates (i.e.,
combining e1rnr rates for mortality from egg to larval to juvenile to adult stages). We recognize the limitation this places on the confidence underlying the mortality estimates in the White Paper.
The implication of this low confidence in the adult equivalency mortality estimates is such that, while we can have confidence that the proposed 25% reduction in withdrawal volume during May and June will result in reduced impingement and entrainment, translating those into actual increased numbers of adult fish faces the same uncertainty.
Although there are large inherent uncertainties accompanying the projected levels of mortality and resource savings from the proposed temporary withdrawal reductions, we agree in principle with the stated conclusion in the White Paper that the 25% reduction in withdrawal volume during May and June provides "immediate, meaningful improvements to important fisheries." However, we fu1iher consider the reported range of mortality reductions of 10%-23% for the select ASMFC-regulated species of Atlantic menhaden, weakfish, spot, and striped bass to be relatively small. Projected reductions for other ecologically important species were also considered small but meaningful. Most importantly, we lack the information needed to place the estimated loss of fishes in the context of population sizes and other cumulative impacts within the James River.
In conclusion, these studies use the best available data to provide evidence of reduced mortality for some fish species and oysters. Application of the reduced withdrawal volumes during May and June will serve to reduce aquatic fauna mmiality. Despite the reductions in mmiality that are projected as a result', of the proposed reduced withdrawal volume, overall mortality estimates for some species remain high. Because we lack a strong basis for putting these mmiality rates in a meaningful ecological context, we recommend that further mitigative measures be thoroughly evaluated.
We can provide no guidance on how these recommendations, if acceptable, should be pursued procedurally with respect to federal consistency determinations. We are aware that fu1iher protective measures that best address the intended ecological goals of federal consistency have been investigated, and should be considered. Although not applicable to the immediate decision regarding federal consistency, we take this opportunity to mention that the Commonwealth may be best served in the future by more rigorous and timely information requirements than those outlined in the Final §316(b) Rule.
P 0. Box I 34G
- 1370 Create Road
- www.vims.edu -
Ecological Value Assessment of Dominion Energy's Proposed Mitigative Strategy Page 3 of3 We stand ready to provide additional support if needed.
Sincerely, Lyle Varnell Associate Director for Advisory Services E 0. Box I '.-\,J(i
- www.vin1s.edu
4/1/2021 Commonwealth of Virginia Mail - Surry Power Station - staff discussion (ESSLog# 38468)
~ Commonwealth of
~ Virginia Rayfield, Bettina <bettina.rayfield@deq.virginia.gov>
Surry Power Station - staff discussion (ESSLog# 38468) 1 message Ewing,Amy <amy.ewing@dwr.virginia.gov> Thu, Mar 4, 2021 at 11:46AM To: Bettina Rayfield <bettina.rayfield@deq.virginia.gov>, Joy Abel <joy.abel@deq.virginia.gov>, Allison Lay
<allison.lay@mrc.virginia.gov>, Justin Worrell <justin.worrell@mrc.virginia.gov>, Randy Owen
<randy.owen@mrc.virginia.gov>, Lyle M Varnell <lyle@vims.edu>
Cc: Fernald Raymond dvs93356 <ray.fernald@dwr.virginia.gov>, Clinton Margeson <clinton.morgeson@dwr.virginia.gov>,
Weaver Lawless ure27863 <alan.weaver@dwr.virginia.gov>, Scott Smith <scott.smith@dwr.virginia.gov>
Hi everyone, We, DWR, have reviewed and discussed the most recent (Feb 4th) submission from Dominion and VIMS' response to it (both attached). I am writing to open up discussion among staff working on the project so that we understand our respective positions. I have included below a bulleted list of our thoughts to date:
- We agree that the 25% seasonal flow (intake) reductions that Dominion offers to implement in May and June will likely reduce take of aquatic fauna present in the river during those months. However, we would prefer to see seasonal reductions from April - June (at a minimum) to best protect anadromous fishes and perhaps during a period in the fall, when federal Endangered Atlantic Sturgeon are spawning (August 1 - November 15).
- If the 25% seasonal flow reduction is the only additional minimization method Dominion proposes, we believe that needs to be coupled with mitigation for ongoing and long-term impacts upon aquatic fauna in the James River not addressed by the proposed seasonal reductions. We have discussed mitigation opportunities in-house and have some good ideas we'd be happy to share and discuss.
Get in touch if you have thoughts, want to discuss, etc.
Thanks, Amy Amy Martin Ewing Environmental Services Biologist Manage,; Wildl{fe b?formation she/her/hers P 804.367.2211 Department of Wildlife Resources CONSERVE. CONNECT. PROTECT.
A 7870 Villa Park Dlive, P.O. Box 90778, Henrico, VA 23228 www.VirginiaWildlife.gov 2 attachments
~ VIMS Comments Surry NPS.pdf 98K
~ SPS Final VIMS CZMA Response Letter and Reports_for email (1).pdf 4770K https://mail.google.com/mail/u/0?ik=dd8e2b1 ade&view=pt&search=all&permthid=thread-f%3A 1693320568510227131 %7Cmsg-f%3A 1693320568510. .. 1/1
COMMONWEALTH of VIRGINIA Marine Resources Commission Building 96 Matthew J. Strickler 380 Fenwick Road Steven G. Bowman Secretary ofNatural Resources Fort Monroe, VA 23651 Commissioner March 15, 2021 Dominion Energy Attn: Amanda B. Tornabene Vice President and Chief Environmental Officer Dominion Energy 120 Tredegar St Richmond, VA 23019 RE: Federal Consistency Certification for the VEPCO Surry Power Station Units 1 and 2 Subsequent License Renewal, U.S. Nuclear Regulatory Commission, Suny County DEQ 17-121F
Dear Ms. Tornabene:
Let me begin by thanking you and Dominion Energy for the dialogue and discussions to date regarding the Commonwealth's review of the U.S. Nuclear Regulatory Commission's (NRC) proposed relicensing of the Su1Ty Power Station (SPS). VMRC is committed to working towards an agreeable solution that will allow the Commonwealth to meet its charge to ensure consistency with the enforceable policies of the Virginia Coastal Zone Management Program while recognizing the critical need and unquestionable public and private benefits of a reliable energy supply for Virginia's economic stability.
As you are aware, on February 2, 2018, the Department of Environmental Quality (DEQ) issued a conditional concunence to Dominion's federal consistency determination in accordance with 15 CPR 930.4. The consistency was conditioned upon the Department of Wildlife Resources' input and concunence with intake technology to minimize impacts to fishery resources. VMRC, after considerable consultation between your team and the Virginia Institute of Marine Science, continues to recommend that the NRC license renewal be contingent on improvements to the existing cooling water intake structure that reflect the best technology available to protect impmiant Virginia fisheries given the current mmiality rates of aquatic organisms associated with the ongoing impingement and entrainment rates at SPS.
This letter is provided in response to both the VIMS and DWR assessments of the ecological value of Dominion Energy's cmrnnt proposed mitigative strategy of reducing river water intake volume at the SPS by approximately 25% during May and June of each year. DWR recently advised that the VIMS review observes that overall mortality rates for some species 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
remain high even with the reduction in withdrawal volumes during the months of May and June, and that VIMS recommends that further mitigative measures be evaluated. In light of tpis finding, DWR recommends that volumes be reduced during the month of April as well, where practicable, and that the attached two DWR proposals be considered as further mitigation.
Based on my and my staff's review of the collective DWR and VIMS advisory guidance to date, I would ask for your consideration of the addition of the month of April for the reduction in river water intake volumes, where practicable. We additionally agree with the VIMS and DWR positions that further mitigative measures be evaluated given the expected high mortality rates for ce1iain aquatic species that will result from the continued operation of the SPS.
In conclusion, while all of the species impacted by the SPS are important to the Commonwealth, we are particularly concerned about the continued lack of recovery of our anadromous alosine (shad and river herring) populations in the James River and Chesapeake Bay watershed. I concur with DWR's position that "rigorously analyzing the complex factors affecting alosine recruitment will have positive and persisting effects on the management and recovery of these species in Virginia."
Should you or your staff have any questions regarding this letter, please do not hesitate to contact me.
Sincerely, Steven G. Bowman
Dominion Energy Services, Inc.
120 Tredegar Street Richmond, VA 23219 P'
tJ; I Dominion Energy March 18, 2021 Marine Resources Commission, Building 96 Attention: Commissioner Steven G. Bowman 380 Fenwick Road Fort Monroe, VA 23651 RE: Federal Consistency Certification for the VEPCO (Dominion Energy Virginia) Surry Power Station Units 1 and 2 Subsequent License Renewal, U.S. Nuclear Regulatory Commission, Surry County
Dear Commissioner Bowman:
Thank you for your March 15, 2021 letter regarding the review, pursuant to the Virginia Coastal Zone Management Program (CZMP), of the U.S. Nuclear Regulatory Commission's (NRC) Surry Power Station (SPS) proposed license renewal. We appreciate your clarification of the March 15 letter as well as the dialogue with Dominion Energy Virginia to work towards concurrence with our determination that NRC's renewal of SPS' license is consistent with the enforceable policies of Virginia's CZMP.
As summarized in your March 15 letter, on February 2, 2018, the Department of Environmental Quality (DEQ) issued a conditional concurrence to Dominion Energy Virginia's federal consistency determination in accordance with 15 CFR 930.4. The concurrence was conditioned because of concerns expressed by the Department of Wildlife Resources' (DWR) (at the time, the Depat1ment of Game and Inland Fisheries) regarding impacts on fishery resources from SPS' cooling water intake flows.
It is our understanding that the Virginia Marine Resources Commission (VMRC), on the advice ofDWR and the Virginia Institute of Marine Science, is willing to provide an unconditional concurrence to Dominion Energy Virginia's federal consistency determination if Dominion Energy Virginia agrees to additional annual interim intake flow reductions, when practicable, in April. These flow reductions would be in addition to the intake flow reductions already offered for May and June outlined in your March 15 letter, the additional studies and information already provided by Dominion Energy Virginia, and Dominion Energy Virginia's ongoing efforts to examine improvements to the existing cooling water intake structure through the Clean Water Act Section 316(b) review process.
Dominion Energy Virginia agrees to provide the requested additional annual interim flow reductions, when practicable, in April. Accordingly, we request that VMRC provide to DEQ its unconditional concurrence with our determination that NRC's renewal of SPS' license is consistent with the enforceable policies of Virginia's CZMP.
Sincerely,
~~~
Amanda B. Tornabene Vice President and Chief Environmental Officer
4/1/2021 Commonwealth of Virginia Mail - Fwd: Follow-Up
~ Commonwealth of
_.... Virginia Rayfield, Bettina <bettina.rayfield@deq.virginia.gov>
Fwd: Follow-Up 1 message Paylor, David <david.paylor@deq.virginia.gov> Wed, Mar 31, 2021 at 1:41 PM To: "Rayfield, Bettina" <bettina.rayfield@deq.virginia.gov>
Cc: Baxter Sharon dku34917 <sharon.baxter@deq.virginia.gov>
Is the next step ours?
David K. Paylor 804-698-4020
Forwarded message ---------
From: Bowman, Steven <steve.bowman@mrc.virginia.gov>
Date: Wed, Mar 31, 2021 at 1:36 PM
Subject:
Re: Follow-Up To: amanda.b.tornabene@dominionenergy.com <amanda.b.tornabene@dominionenergy.com>
Cc: Brown, Ryan <ryan.brown@dwr.virginia.gov>, Paylor, David <david.paylor@deq.virginia.gov>,
mark.sartain@dominionenergy.com <mark.sartain@dominionenergy.com>, katharine.bond@dominionenergy.com
<katharine.bond@dominionenergy.com>, Bob Burnley <rgburnleyllc@comcast.net>, Randy Owen
<randy.owen@mrc.virginia.gov>, Anthony Watkinson <tony.watkinson@mrc.virginia.gov>, Matthew Strickler
<matt. strickler@governor. virginia. gov>
Dear Ms. Tornabene:
I am in receipt of your letter today that delineates the mitigation conditions pursuant to the re-licensure of the Surry Nuclear Power Station. By virtue of this correspondence, copied to the Director David Paylor of the Department of Environmental Quality, the Virginia Marine Resources Commission provides our unconditional concurrence with your determination that Nuclear Regulatory Commission's renewal of Surry Nuclear Power Station's license is consistent with the enforceable policies of Virginia's Coastal Zone Management Plan.
I would like to thank you and your highly professional staff for the dialogue we have had during this process. Because of our collaborative deliberations, I believe the customers you serve as well as our environment are all the better, and all parties have exercised due diligence.
Thank you again.
Steven G. Bowman Commissioner of Marine Resources for the Commonwealth of Virginia On Wed, Mar 31, 2021 at 11 :28 AM amanda.b.tornabene@dominionenergy.com <amanda.b.tornabene@
dominionenergy.com> wrote:
Commissioner Bowman, An additional follow-up to our March 19, 2021 letter. Any questions or you would like to discuss please give me a call on cell.
Mandy Mandy Beasley Tornabene Vice President and Chief Environmental Officer Dominion Energy https://mail.google. com/mail/u/0?ik=dd8e2b 1ade&view=pt&search=all&permth id=th read-f%3A 1695770236755406494 %7Cmsg-f%3A 1695770236755. .. 1/2
4/1/2021 Commonwealth of Virginia Mail - Fwd: Follow-Up 120 Tredegar St Richmond, VA 23019 (c): .804-239-6304 Amanda.b.tornabene@dominionenergy.com
- Due to COVID-19 I will be working remotely. I am available by email and the cell number above.
CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto wh ich binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.
Steven G. Bowman Commissioner of Marine Resources for the Commonwealth of Virginia 380 Fenwick Road, Building 96 Fort Monroe, Virginia 23651 757-247-2205 https://mail.google.com/mail/u/0?ik=dd8e2b 1ade&view=pt&sea rch=all&permth id=thread-f%3A 16957702367 55406494 % 7Cmsg-f%3A 1695770236755. .. 2/2
4/1/2021 Commonwealth of Virginia Mail - Regarding Surry Nuclear Consistency Ji.._ Commonwealth of Rayfield, Bettina <bettina.rayfield@deq.virginia.gov>
~ Virginia 1
Regarding Surry Nuclear Consistency 1 message Fernald, Raymond <ray.fernald@dwr.virginia.gov> Wed, Mar 31, 2021 at 4:00 PM To: "Rayfield, Bettina" <bettina.rayfield@deq.virginia.gov>
Cc: "Sharon K. Baxter" <sharon.baxter@deq.virginia.gov>, Amy Ewing <amy.ewing@dwr.virginia.gov>, Ryan Brown
<ryan.brown@dwr.virginia.gov>, Michael Bednarski <mike.bednarski@dwr.virginia.gov>
Tina and Sharon; As you know, this has been a complex review, including consideration of both the NRC licensing and Coastal Zone Consistency Review, and the ongoing 316(b) process.
Dominion recognizes that the VIMS analysis advised that additional mitigation will be necessary, and as such Dominion commits to addressing this issue with the agencies during the 316(b) process. With this commitment to future evaluation and addressing of necessary mitigation, along with the flow reductions reflected in the VMRC and Dominion letters, we find VMRC's unconditionally consistent determination with respect to this process to be acceptable. We will look forward to working with Dominion and others on the mitigation noted by VIMS during the course of the 316(b) process.
I have attached today's letter from Dominion to VMRC committing to working with us to resolve these issues.
Please feel free to contact me or Amy Ewing if you have any additional questions.
Thanks, ray Raymond T. Fernald (Ray)
Manager, Wildlife Information and Environmental Services Virginia Department of Wildlife Resources PO Box 90778 7870 Villa Park Drive Henrico, VA 23228-0778 Phone: 804-367-8364 E-mail: ray.fernald@dwr.virginia.gov
~ SurryNuclear_DominionToVMRCRelntakeMitigationAndConsistency_Dominion20210331.pdf 331K https://mail.google.com/mail/u/0?ik=dd8e2b 1ade&view=pt&search=all&permth id=th read-f%3A 1695778933748463706% 7Cmsg-f%3A 1695778933748. .. 1/1
4/1/2021 Commonwealth of Virginia Mail - Fwd: Re: Follow-Up
......_ Commonwealth of Rayfield, Bettina <bettina.rayfield@deq.virginia.gov>
~ Virginia Fwd : Re: Follow-Up 1 message Paylor, David <david.paylor@deq.virginia.gov> Wed, Mar 31, 2021 at 3:47 PM To: "Rayfield, Bettina" <bettina.rayfield@deq.virginia.gov>
Cc: Baxter Sharon dku34917 <sharon.baxter@deq.virginia.gov>
David K. Paylor 804-698-4020
Forwarded message ---------
From: Ryan Brown <ryan.brown@dwr.virginia.gov>
Date: Wed, Mar 31, 2021 at 3:40 PM
Subject:
RE: Re: Follow-Up To: <amanda.b.tornabene@dominionenergy.com>, Steven Bowman <steve.bowman@mrc.virginia.gov>
Cc: David Paylor <david.paylor@deq.virginia.gov>, <mark.sartain@dominionenergy.com>, <katharine.bond@
dominionenergy.com>, Bob Burnley <rgburnleyllc@comcast.net>, Randy Owen <randy.owen@mrc.virginia.gov>,
Anthony Watkinson <tony.watkinson@mrc.virginia.gov>, Matthew Strickler <matt.strickler@governor.virginia.gov>
With today's letter to Commissioner Bowman from Dominion recognizing the advice in the VIMS analysis that additional mitigation will need to be evaluated, and Dominion's commitment to evaluating this with the agencies during the 316(b) process, DWR is in concurrence with Commissioner Bowman's finding below. Thanks to your team for your approach and we look forward to working together as we move forward.
Ryan J. Brown Executive Director P 804.367.9231 Virginia Department of Wildlife Resources CONSERVE. CONNECT. PROTEC?:
A 7870 Villa Park Dr., P.O. Box 90778, Henrico, VA 23228-0778 www.virginiawildlife.gov https://mail.google.com/mail/u/0?ik=dd8e2b1 ade&view=pt&search=all&permthid=thread-f%3A 1695770236755406494%7Cmsg-f%3A 1695778171689. .. 1/4
4/1/2021 Commonwealth of Virginia Mail - Fwd: Re: Follow-Up From: amanda.b.tornabene@dominionenergy.com <amanda.b.tornabene@dominionenergy.com>
Sent: Wednesday, March 31, 2021 2:57 PM To: 'Bowman, Steven' <steve.bowman@mrc.virginia.gov>
Cc: Brown, Ryan <ryan.brown@dwr.virginia.gov>; Paylor, David <david.paylor@deq.virginia.gov>;
mark.sartain@dominionenergy.com; katharine.bond@dominionenergy.com; Bob Burnley <rgburnleyllc@comcast.net>;
Randy Owen <randy.owen@mrc.virginia.gov>; Anthony Watkinson <tony.watkinson@mrc.virginia.gov>; Matthew Strickler
<matt. strickler@governor. virgin ia. gov>
Subject:
RE: Re: Follow-Up Thank you, and I echo your thoughts on staff and dialogue. I greatly appreciate all the time and effort spent on the CZMA discussions.
Director Paylor and Director Brown, we would greatly appreciate your confirmation that DEQ and DWR are in agreement with VMRC.
Thank you, Mandy From: Bowman, Steven <steve.bowman@mrc.virginia.gov>
Sent: Wednesday, March 31, 2021 1:37 PM To: Amanda B Tornabene (Services - 6) <amanda.b.tornabene@dominionenergy.com>
Cc: Brown, Ryan <ryan.brown@dwr.virginia.gov>; Paylor, David <david.paylor@deq.virginia.gov>; Mark Sartain (Services - 6) <mark.sartain@dominionenergy.com>; Katharine Bond (Services - 6) <katharine.bond@
dominionenergy.com>; Bob Burnley <rgburnleyllc@comcast.net>; Randy Owen <randy.owen@mrc.virginia.gov>;
Anthony Watkinson <tony.watkinson@mrc.virginia.gov>; Matthew Strickler <matt.strickler@governor.virginia.gov>
Subject:
[EXTERNAL] Re: Follow-Up
- This is an EXTERNAL email that was NOT sent from Dominion Energy. Are you expecting this message? Are you expecting a link or attachment? DO NOT click links or open attachments until you verify them***
Dear Ms. Tornabene:
I am in receipt of your letter today that delineates the mitigation conditions pursuant to the re-licensure of the Surry Nuclear Power Station. By virtue of this correspondence, copied to the Director David Paylor of the Department of Environmental Quality, the Virginia Marine Resources Commission provides our unconditional concurrence with your determination that Nuclear Regulatory Commission's renewal of Surry Nuclear Power Station's license is consistent with the enforceable policies of Virginia's Coastal Zone Management Plan.
I would like to thank you and your highly professional staff for the dialogue we have had during this process. Because of our collaborative deliberations, I believe the customers you serve as well as our environment are all the better, and all parties have exercised due diligence.
Thank you again.
https://mail.google.com/mail/u/0?ik=dd8e2b1 ade&view=pt&search=all&permthid=thread-f%3A 1695770236755406494% 7Cmsg-f%3A 1695778171689. .. 2/4
4/1/2021 Commonwealth of Virginia Mail - Fwd: Re: Follow-Up Steven G. Bowman Commissioner of Marine Resources for the Commonwealth of Virginia On Wed, Mar 31, 2021 at 11 :28 AM amanda.b.tornabene@dominionenergy.com <amanda.b.tornabene@
dominionenergy.com> wrote:
Commissioner Bowman, An additional follow-up to our March 19, 2021 letter. Any questions or you would like to discuss please give me a call on cell.
Mandy Mandy Beasley Tornabene Vice President and Chief Environmental Officer Dominion Energy 120 Tredegar St Richmond, VA 23019 (c): 804-239-6304 Amanda.b.tornabene@dominionenergy.com
- Due to COVID-19 I will be working remotely. I am available by email and the cell number above.
CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.
Steven G. Bowman Commissioner of Marine Resources for the Commonwealth of Virginia 380 Fenwick Road, Building 96 Fort Monroe, Virginia 23651 https://mail.google.com/mail/u/0?ik=dd8e2b 1ade&view=pt&search=all&permthid=thread-f%3A 1695770236755406494%7Cmsg-f%3A 1695778171689. .. 3/4
4/1/2021 Commonwealth of Virginia Mail - Fwd: Re: Follow-Up 757-24 7-2205 CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect.
The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.
https://mail.google.com/mail/u/0?ik=dd8e2b 1ade&view=pt&search=all&permthid=thread-f%3A 1695770236755406494%7Cmsg-f%3A 1695778171689. .. 4/4
Dominion Energy Services, Inc.
120 Tredegar Street Richmond, VA 23219 March 31, 2021 Marine Resources Commission, Building 96 Attention: Commissioner Steven G. Bowman 380 Fenwick Road Fort Momoe, VA 23651 RE: Federal Consistency Certification for the VEPCO (Dominion Energy Virginia) Surry Power Station Units 1 and 2 Subsequent License Renewal, U.S. Nuclear Regulatory Commission, Surry County
Dear Commissioner Bowman:
Thank you for yom March 15, 2021 letter regarding the review, pursuant to the Virginia Coastal Zone Management Program (CZMP), of the U.S. Nuclear Regulat01y Commission's (NRC) Surry Power Station (SPS) proposed license renewal. We appreciate your clarification of the March 15 letter as well as the dialogue with Dominion Energy Virginia to work towards concurrence with our determination that NRC's renewal of SPS' license is consistent with the enforceable policies of Virginia's CZMP.
In a response sent on March 19, 2021, Dominion Energy Virginia agreed to intake flow reductions, when practicable, in April, May and June. These flow reductions would be in addition to the studies and information already provided by Dominion Energy Virginia, and Dominion Energy Virginia's ongoing efforts to examine improvements to the existing cooling water intake structure through the Clean Water Act Section 316(b) review process.
Further, Dominion Energy Virginia recognizes the Department of Wildlife Resources' request in your March 15, 2021 letter that additional mitigation be evaluated in line with advice received from the Virginia Institute of Marine Science. Dominion Energy Virginia fully expects and commits to evaluating mitigation with the agencies during the Surry Power Station's 3 l 6(b) process currently being perfonned.
Accordingly, we request that VMRC provide to DEQ its unconditional concurrence with our determination that NRC's renewal of SPS' license is consistent with the enforceable policies of Virginia's CZMP.
Sincerely, A111a1tlfa 1Pr1tabe1te Ama nda Tornabene (Ma r 31 , 2021 l 0:09 EDT)
Amanda B. Tornabene Vice President and Chief Environmental Officer