ML21181A186

Scoping Summary Report

ML21181A186
Person / Time
Site:	North Anna
Issue date:	06/30/2021
From:	Robert Elliott NRC/NMSS/DREFS/ELRB
To:	Stoddard D Virginia Electric & Power Co (VEPCO)
Tam Tran
Shared Package
ML21181A127	List: ML21181A181 ML21181A186
References
EPID L-2020-SLE-0000
Download: ML21181A186 (17)

Text

Supplemental Environmental Impact Statement Scoping Process Summary Report North Anna Power Station Unit Nos. 1 and 2 Louisa County, VA June 2021 U.S. Nuclear Regulatory Commission Rockville, MD

Introduction On August 24, 2020, the U.S. Nuclear Regulatory Commission received an application from Dominion Energy requesting subsequent license renewal of the operating licenses for North Anna Power Station Unit Nos. 1 and 2 (North Anna) in Louisa County, VA. In its application, Dominion Energy (Dominion) requests subsequent license renewal for a period of 20 years beyond the expiration of the current renewed operating licenses. If granted, the renewed licenses would expire April 1, 2058, for North Anna Unit No. 1 and August 21, 2060 for North Anna Unit No. 2.1 The purpose of this report2 is to (a) summarize the determination of the scope of the NRC staffs environmental review of this application, incorporating stakeholder input and (b) describe the issues identified by the environmental impact statement scoping process.

This report is structured in three sections:

A. The North Anna Subsequent License Renewal Public Scoping Period B. Public Comments and Responses C. List of Commenters A. The North Anna Subsequent License Renewal Public Scoping Period

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Background===

The North Anna subsequent license renewal application (SLRA) and all other relevant public documents are available in the NRC's Agencywide Documents Access and Management System (ADAMS). You can access the ADAMS Public Electronic Reading Room at http://www.nrc.gov/reading-rm/adams.html. For help with ADAMS, contact the NRC's Public Document Room reference staff by telephone at 1-800-397-4209 or 301-415-4737 or by e-mail at pdr.resource@nrc.gov.

For additional information, visit the NRCs North Anna subsequent license renewal application Web site: https://www.nrc.gov/reactors/operating/licensing/renewal/applications/north-anna-1 subsequent.html. This Web site includes application information, the licensing schedule, opportunities for public involvement, project manager contact, and other relevant information. In addition, important documents, including public comments, are available at the Federal rulemaking Web site at https://www.regulations.gov/, under Docket ID NRC-2020-0234.

1 North Anna Unit No. 1s current renewed operating license (NPF-4) expires at midnight on April 1, 2038; North Anna Unit No. 2s current renewed operating license (NPF-7) expires at midnight on August 21, 2040.

2 The NRCs requirements for conducting the scoping process and for preparing a scoping summary report are found at Section 51.29 to Title 10 of the Code of Federal Regulations (10 CFR 51.29),

Scoping-Environmental Impact Statement and Supplement to Environmental Impact Statement.

On August 24, 2020, as part of its North Anna SLRA, Dominion submitted an environmental report (ER) to the NRC (ADAMS Accession Number ML20246G698). Dominion prepared its ER in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, which contains the NRCs requirements for implementing the National Environmental Policy Act of 1969, as amended (NEPA).3 In accordance with 10 CFR 51.95(c), renewal of a power reactor operating license requires the staff to prepare a supplemental environmental impact statement (SEIS) to the Commissions NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, (GEIS) (ADAMS Accession Nos. ML13106A241 and ML13106A242). In the GEIS, the NRC staff identified and evaluated the environmental impact issues associated with license renewal of nuclear power plants and separated these issues into two groups: Category 1 and Category 2 (codified in 10 CFR 51). Category 1 environmental issues have impacts that are generic to all nuclear power plants (or to a subset of plants, such as those with the same type of cooling system). Category 2 environmental issues have impacts for which the NRC cannot determine a conclusion generically. For Category 2 issues, the NRC staff performs a site-specific review to determine the site-specific impacts in a SEIS. According to 10 CFR 51.53(c), an application for license renewal or subsequent license renewal does not require analyses of Category 1 issues in its ER submitted with the application. However, the ER must contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.

Scoping Process and Objectives The first step in developing a SEIS is to conduct a public scoping process to help staff determine the scope of the SEIS. On October 23, 2020, the NRC published a Federal Register (FR) notice announcing the staffs intent to prepare a supplemental environmental impact statement for the North Anna SLRA and conduct a public environmental scoping process. The FR notice (85 FR 67572) described the scoping process, and invited the public and stakeholders to participate by submitting written comments by November 23, 2020, and by attending a public meeting with the opportunity to make oral comments on November 4, 2020 The public meeting was held as a webinar because of the COVID-19 public health emergency (PHE) and transcribed by a court reporter. The NRC staff recorded all written and oral comments and considered them in the scoping process.

The scoping process provided an opportunity for members of the public to highlight concerns and issues to be addressed in the SEIS. This scoping summary report (a) summarizes the comments that the NRC received and (b) provides the determinations and conclusions that the NRC staff reached, during the scoping process. The objectives for the scoping process are as follows:

Define the proposed action, which is to be the subject of the supplement to the GEIS Gather data on the scope of the supplement to the GEIS and identify the significant issues to be analyzed in depth Identify and eliminate from detailed study those issues that are peripheral or are not significant or were covered by a prior environmental review 3 The NRCs requirements for an ER supporting a license renewal application can be found in 10 CFR 51.53(c)(3).

Identify any environmental assessments and other EISs that are being or will be prepared that are related to, but are not part of, the scope of the supplement to the GEIS being considered Identify other environmental review and consultation requirements related to the proposed action Indicate the relationship between the timing of the preparation of the environmental analyses and the Commission's tentative planning and decisionmaking schedule Identify any cooperating agencies and, as appropriate, allocate assignments for preparation and schedules for completing the supplement to the GEIS to the NRC and any cooperating agencies Describe how the supplement to the GEIS will be prepared, including any contractor assistance The NRC staffs determinations and conclusions regarding the above objectives follow.

Define the Proposed Action The NRCs proposed action is to determine whether to renew the North Anna operating licenses for an additional 20 years.

Scope of Review, Significant Issues, and Issues that are not Significant The scope of the SEIS includes an evaluation of the environmental impacts of and reasonable alternatives to North Annas subsequent license renewal. The Public Comments and Responses section of this report includes specific issues identified by the scoping comments.

The NRC staffs responses explain whether the issues will be addressed in the SEIS and, if so, where in the SEIS they will be addressed. Issues that are not significant for in depth analysis, or otherwise out of scope (e.g., peripheral issues), are identified as well.

For North Annas subsequent license renewal review, the NRC staff will follow the structure provided in the License Renewal GEIS. The GEIS evaluates 78 environmental issues related to plant operation and classifies each issue as either a Category 1 issue (generic to all or a subset of nuclear power plants) or a Category 2 issue (specific to individual power plants). Unless new and significant information is discovered, the NRC will rely on the conclusions in the GEIS for all Category 1 issues. If the NRC staff is aware of new and significant information that could change the impact of a Category 1 issue, the staff will evaluate those Category 1 issues in the SEIS. The staff evaluates all Category 2 issues in depth in the SEIS.

The NRC received scoping comments in the following subject areas:

Greenhouse Gases Human Health Radioactive Waste Management Alternatives to License Renewal Refurbishment Activities General Support or Opposition to License Renewal License Renewal Process and NEPA Outside of ScopeOperational Safety Issues or Safety Concerns Outside of ScopeEmergency Evacuation Concerns Outside of ScopeSecurity Concerns

Outside of ScopeFukushima Lessons Learned, Dam Safety, and Chernobyl Concerns Outside of ScopeNot Allowing Reprocessing Concerns Identification of Related Environmental Assessments and other EISs The NRC staff did not identify any upcoming or in-progress environmental assessments, which relate to, but are not within the scope of the North Anna SEIS. As it prepares the North Anna subsequent license renewal SEIS, the staff will consider prior completed EISs such as:

a) the License Renewal GEIS (ADAMS Package Accession No. ML13107A023),

b) the SEIS for the initial North Anna license renewal (ADAMS Accession Nos. ML023380542 and ML023380567) c) the EIS for an early site permit at North Anna (ADAMS Accession Nos. ML063470330 and ML063470332) d) the supplemental EIS for the combined license for proposed North Anna Unit 3 (ADAMS Accession No. ML100680117)

Other Environmental Review and Consultation Requirements In parallel with its NEPA review, the NRC staff is consulting with the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service under Section 7 of the Endangered Species Act of 1973 (ESA) to evaluate the potential impacts of the operation of North Anna for an additional 20 years on endangered and threatened species and their critical habitats.

Consistent with 36 CFR 800.8(c), Use of the NEPA Process for Section 106 Purposes, the NRC staff is also consulting with affected Indian Tribes and the State Historic Preservation Officer (SHPO) of Virginia to fulfill its Section 106 obligations under the National Historic Preservation Act of 1966 (NHPA).

Timing of Agency Action Upon completion of the scoping process and site audits, completion of its review of Dominions ER and related documents, and completion of its own independent evaluations, the NRC staff will compile its findings in a draft SEIS. The NRC staff will make the draft SEIS available for public comment. Based on the information gathered during this public comment period, the NRC staff will amend the draft SEIS findings, as necessary, and will then publish the final SEIS.

The NRC will also prepare and provide a record of decision in accordance with 10 CFR 51.102, Requirement to provide a record of decision; preparation, and 10 CFR 51.103, Record of decisiongeneral. At the same time as, but separately from, the environmental review, the NRC staff will conduct a safety review and document its results in a safety evaluation report (SER). The NRC will consider the findings in both the SEIS and the SER in its decision on whether to issue or deny the North Anna subsequent renewed licenses.

The NRC staffs current schedule is to reach a decision on the North Anna subsequent license renewal by April 2022.

Identification of Cooperating Agencies No other Federal agency is participating in the environmental review as a cooperating agency.

How the SEIS will be Prepared, Including Contractor Assistance

The SEIS will be prepared by the NRC staff with contractor support for document editing and public comment support.

Future Opportunities for Public Participation The NRC staff plans to issue a draft SEIS (DSEIS) for public comment in August 2021. The DSEIS public comment period will provide an opportunity for members of the public; the applicant; interested Federal, State, and local government agencies; Tribal governments; and local organizations to provide further input into the NRCs environmental review. The NRC staff will consider the comments received on the DSEIS in the preparation of the final SEIS (FSEIS).

The FSEIS, along with the NRC staffs safety evaluation report (SER), will document the information considered and evaluations performed by the NRC staff in evaluating the North Anna SLRA. The FSEIS and the SER will also provide the basis for the NRCs decision on whether to issue or deny the North Anna subsequent renewed licenses.

Scoping Process Conclusion The comments provided during the environmental scoping process identified many important issues that the NRC staff will address in its DSEIS for North Annas subsequent license renewal. In the DSEIS, the NRC will not consider issues which do not pertain to the staffs environmental evaluation or are beyond the scope of the subsequent license renewal review.

B. Public Comments and Responses During the scoping comment period (85 FR 67572), the NRC staff received public comments for consideration in the development of the SEIS. This section of the report summarizes the NRC responses to scoping comments. The NRC staff grouped comments based on being in scope or out of scope, and further subgrouped comments according to subject matter areas. Each comment submittal received (e.g., via www.regulations.gov) was uniquely identified with a commenter identification number. When a comment submittal addressed multiple issues, the submittal was further divided into separate comments with tracking identifiers. Section C of this report contains a table that identifies the commenters, their affiliation if provided, and the ADAMS Accession number for the comment submittals.

B.1 Comments in Scope B.1.1 Greenhouse Gases Comment Summary (NAPS-141-8): The commenter expresses the view that nuclear power generation is not carbon free once the power plants life cycle is considered (e.g., mining, milling).

Response: The NRC staff will consider direct greenhouse gas emissions under the proposed action of subsequent license renewal of North Anna, Units 1 and 2 in Chapter 3 of the draft SEIS. The staff notes that Section 4.12.3.1 of the License Renewal GEIS (NUREG-1437) presents life-cycle greenhouse gas emissions associated with nuclear power generation.

B.1.2 Human Health Comment Summary (NAPS-141-9, NAPS-143-10): These comments express general concerns related to radiological emissions and human health impacts from operation of nuclear

power plants.

Response: The NRC staff will describe the human health risks from North Anna, Units 1 and 2 in Chapters 2 and 3 of the draft SEIS. The effect of doses to the public related to license renewal were evaluated in the License Renewal GEIS and determined to be a Category 1 issue.

The GEIS found those impacts to be SMALL. Any new and significant information regarding human health impacts will be discussed in Chapters 2 and 3 of the draft SEIS, and Chapter 3 will include the staffs evaluation of the impacts on human health from license renewal of North Anna.

B.1.3 Radioactive Waste Management Comment Summary (NAPS-43-3, NAPS-57-4, NAPS-90-5, NAPS-138-1, NAPS-138-5, NAPS-138-10, NAPS-140-2, NAPS-141-2, NAPS-141-4, NAPS-143-2, NAPS-143-6, NAPS-143-9, NAPS-141-7, NAPS-141-13): These comments express concerns about long-term nuclear waste management at North Anna.

Response: The NRC staff will describe the management of radioactive waste in Chapters 2 and 3 of the draft SEIS and will consider any new and significant information regarding radioactive waste impacts, including the management of spent nuclear fuel, resulting from subsequent license renewal of North Anna operating licenses.

B.1.4 Alternatives to License Renewal Comment Summary (NAPS-67-3, NAPS-143-1, NAPS-143-3): These comments request that the NRC considers renewable energy technologies, including wind and solar power generation, as alternatives to subsequent license renewal of the North Anna operating licenses.

Response: The NRC staff will evaluate the environmental impacts of the proposed action (i.e., subsequent license renewal for North Anna) as well as alternatives to the proposed action in the draft SEIS. The staff will identify appropriate replacement power alternatives, including renewable energy technologies, as appropriate, in Chapter 2 of the draft SEIS and will assess the potential impacts of the proposed action and alternatives in Chapter 3.

B.1.5 Refurbishment Activities Comment Summary (NAPS-146-3): This comment requests that the NRC consider the environmental impacts associated with potential steam generator replacement.

Response: The NRC staff will evaluate the environmental impacts resulting from continued operations and refurbishment activities (e.g., steam generator and vessel head replacement) associated with license renewal. If refurbishment activities are not undertaken for purposes of license renewal, however, they are outside the scope of the staffs environmental review.

B.1.6 General Support or Opposition to License Renewal Comment Summary (NAPS-1-2, NAPS-2 through NAPS-12, NAPS-14 through NAPS-42, NAPS-44 through NAPS-56, NAPS-63, NAPS-65, NAPS-66, NAPS-68 through NAPS-89, NAPS-92 through NAPS-117, NAPS-118-1, NAPS-118-2, NAPS-119 through NAPS-127, NAPS-128-1, NAPS-128-2, NAPS-128-3, NAPS-129 through NAPS-132, NAPS-134 through NAPS-137, NAPS-144-2, NAPS-144-4, NAPS-145-1, NAPS-142-1, NAPS-144-1, NAPS-144-3,

NAPS-144-5): These comments express general support for nuclear power including license renewal of North Anna Power Station. The commenters indicate that North Anna (a) is a good neighbor, (b) provides positive socioeconomic impact, (c) is recognized for safe operations, and (d) provides for a lower greenhouse gas emission option.

Comment Summary (NAPS-61-1): This comment expresses general opposition to license renewal of North Anna Power Station because of perception of unavailability of updated information on plant conditions (e.g., operation and safety measures).

Response: These comments express general support for or opposition to license renewal and provide no significant information related to scoping. Therefore, these comments will not be considered further in the development of the SEIS.

B.1.7 License Renewal Process and NEPA Comment Summary (NAPS-13-1, NAPS-57-3, NAPS-58-2, NAPS-58-3, NAPS-59-2, NAPS-60-1, NAPS-61-3, NAPS-90-1, NAPS-133-1, NAPS-133-3, NAPS-138-8, NAPS-138-12, NAPS-139-1, NAPS-140-1, NAPS-146-2): These comments express concerns about the adequacy of the NRCs license renewal and environmental review processes regarding: (a) premature application concern (18 years before current license expires) (b) need for the NRC to prepare a new site-specific EIS and concern about the use of a generic EIS and (c) renewal of licenses beyond the initial 40 year license period.

Response

The Atomic Energy Act (AEA) of 1954, as amended, authorizes the NRC to issue 40-year initial licenses, and, upon application and approval, to renew licenses for nuclear power reactors. The NRCs regulations limit these renewals to 20-year increments. Approval of a renewed license is based on the outcome of a safety and environmental review. For license renewal, 10 CFR 54.17, Filing of Application, allows application submittals to be no earlier than 20 years before the expiration of the operating license currently in effect. This is because it may take 10-14 years for new power plants to be designed and constructed (see 1991 Final Rule, Nuclear Power Plant License Renewal, 56 FR 64943).

The NRCs regulations that implement the requirements of the National Environmental Policy Act of 1969, as amended (NEPA), are contained in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions. These regulations require NRC staff to document the renewal of a power reactor operating license in a supplemental environmental impact statement (SEIS). This SEIS supplements the NRCs License Renewal GEIS (NUREG-1437), for which the GEIS conclusions are codified in 10 CFR Part 51. The staffs environmental review in the SEIS will include consideration of any new and significant information related to the conclusions in the GEIS.

Members of the public who believe that NRC regulations should be amended or rescinded may file a petition for rulemaking according to the provisions of 10 CFR 2.802, Petition for RulemakingRequirements for Filing.

B.2 Comments Outside the Scope of License Renewal B.2.1 Operational Safety Issues or Safety Concerns

Comment Summary (NAPS-43-1a, NAPS-57-1, NAPS-57-5, NAPS-58-1, NAPS-58-4, NAPS-58-4, NAPS-58-6, NAPS-58-8b, NAPS-59-1, NAPS-59-3, NAPS-62-1, NAPS-62-2, NAPS 3, NAPS-62-4, NAPS-62-7, NAPS-62-8, NAPS-62-9, NAPS-67-1, NAPS-90-2a, NAPS-90-4, NAPS-133-2, NAPS-138-2, NAPS-138-3, NAPS-138-4, NAPS-138-7, NAPS-138-9, NAPS-138-11, NAPS-138-13, NAPS-138-15, NAPS-138-18, NAPS-139-2, NAPS-140-3, NAPS-141-1, NAPS-141-3, NAPS-141-5, NAPS-141-10, NAPS-141-12, NAPS-146-1, NAPS-143-4, NAPS-143-8): These comments express concerns about North Anna current operational safety issues or material aging management programs. Examples of current operational safety issue comments include those about: (a) inspection status during the COVID-19 PHE, (b) upgrade or maintenance of equipment, structures, and components to withstand future earthquakes, and (c) exemptions. Examples of material aging management program comments include those about: (a) the need for a robust aging management review using results from harvesting and lab testing of aged materials from decommissioned reactors, (b) aging structures and components to withstand future earthquakes, (c) inadequate upgrade of aging equipment, and (d) reactor vessel embrittlement.

Response

The comments expressing current safety concerns are beyond the scope of the license renewal environmental review. The NRC addresses these areas of safety performance as part of its ongoing regulatory oversight of operating nuclear power plants to ensure continued safe operation. The NRC has full authority to modify, suspend, or revoke a license to ensure reasonable assurance of adequate protection of public health and safety. This includes consideration of backfit, as appropriate, relative to the adequacy of the plant safety design (i.e.,

design basis). This oversight will continue during the North Anna period of extended operation if the licenses are renewed.

Information about the Reactor Oversight Process is available at:

https://www.nrc.gov/reactors/operating/oversight.html.

Information about North Annas safety performance is available at:

https://www.nrc.gov/reactors/operating/oversight/docket-chart.html?docket=na1.

Information about NRC actions during the COVID-19 PHE is available at:

https://www.nrc.gov/about-nrc/covid-19/index.html.

In regards to the restart of North Anna after the site experienced the August 23, 2011 Central Virginia (Mineral) earthquake, the NRC staff issued its evaluation in a report Technical Evaluation Related to Plant Restart after the Occurrence of an Earthquake Exceeding the Level of the Operating Basis and Design Basis Earthquakes, (ADAMS Accession No. ML11308B406).

Those material aging management programs and processes of structures and components within the scope of the subsequent license renewal safety review will be addressed in the staffs safety evaluation report for the North Anna subsequent license renewal. In its aging management review, the staff examines Dominions programs and processes designed to manage the effects of structure and component aging and to ensure adequate protection of the publics health and safety during the 20-year subsequent license renewal period. This analysis by the staff may result in additional aging management measures at North Anna as necessary.

The Advisory Committee on Reactor Safeguards (ACRS) will conduct a public meeting as a part

of its independent safety review of the North Anna subsequent license renewal. The ACRS provides its review to the Commission.

Information about the ACRS and its public meetings is available at:

https://www.nrc.gov/about-nrc/organization/acrsfuncdesc.html These safety reviews (i.e., regulatory oversight review, subsequent license renewal safety review, and ACRS independent review) are separate from the environmental review that focuses on the environmental impacts of license renewal. Therefore, these comments will not be considered further in the SEIS.

B.2.2 Emergency Evacuation Concerns Comment Summary (NAPS-43-2, NAPS-57-6, NAPS-58-7, NAPS-62-6, NAPS-90-6, NAPS-138-16, NAPS-139-3, NAPS-146-4): These comments express concern about the staffs evaluation regarding emergency evacuation.

Response

Emergency evacuation is beyond the scope of the license renewal environmental review. Local and State governments have the responsibility and authority for emergency evacuation. The NRC has the role of advising and assisting local and State officials during emergency evacuation. Therefore, the NRC environmental review will not consider these comments further in the SEIS.

Emergency preparedness requirements for nuclear power plant licensees related to emergency planning are set out in the NRCs regulations at 10 CFR 50.47, Emergency plans, and 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities. The NRC has these regulations in place to ensure that licensees update emergency preparedness plans throughout the life of all plants. For example, nuclear power plant operators are required to update their evacuation time estimates after every U.S. Census, or when changes in population would increase the estimate by either 25 percent or 30 minutes, whichever is less. Additionally, the NRC assesses the capabilities of the nuclear power plant licensee to protect the public by requiring the performance of a full-scale exercisethat includes the participation of various Federal, State, and local government agenciesat least once every 2 years. These exercises are performed to maintain the skills of the emergency responders and to identify and correct weaknesses.

Information from FEMA about the performance of offsite emergency planning and response at North Anna is available at:

https://www.nrc.gov/about-nrc/emerg-preparedness/related-information/fema-after-action-reports.html.

B.2.3 Security Concerns Comment Summary (NAPS-58-5, NAPS-138-14): These comments express concerns about North Anna security.

Response: North Anna is subject to existing NRC requirements related to physical security, including protection against potential terrorism, as part of its current licensing basis. The NRCs regulations in 10 CFR Part 73, Physical Protection of Plants and Materials, provide

requirements related to physical security. These requirements apply to all operating licenses including subsequent renewed licenses. The NRC staff will not consider these comments further in the SEIS because they are beyond the scope of this environmental review.

The NRC addresses security performance as part of its ongoing regulatory oversight of operating nuclear power plants. This oversight will continue during the North Anna period of extended operation if the licenses are renewed. While many of the details of the NRC's security requirements are not public to avoid assisting potential adversaries, nuclear security background information can be found at: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/security-enhancements.html.

B.2.4 Fukushima Lessons Learned, Dam Safety, and Chernobyl Concerns Comment Summary (NAPS-43-1b, NAPS-57-2, NAPS-58-8a, NAPS-61-2, NAPS-62-5, NAPS-67-2, NAPS-90-2b, NAPS-90-3, NAPS-138-6, NAPS-138-17, NAPS-141-11, NAPS-143-5, NAPS-143-7): These comments express concern about (a) adequate safety improvement in response to Fukushima lessons learned at North Anna, (b) North Anna Dam safety, and (c) accident implications related from the 1986 Chernobyl plant disaster in the Soviet Union.

Response: Following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the March 11, 2011, tsunami, the NRC established short-term actions and long-term responses including the creation of the Japan Lessons-Learned Project Directorate. To ensure safe operation of reactors in the United States, the Commission issued the following three orders to all U.S. reactor licensees:

Obtain and protect additional emergency equipment, such as pumps and generators, to support all reactors at a given site simultaneously following a natural disaster.

Install enhanced equipment for monitoring water levels in each plant's spent fuel pool.

Improve/install emergency venting systems that can relieve pressure in the event of a serious accident (only for reactors with designs similar to the Fukushima plant).

More information about Fukushima lessons learned is available at: https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/japan-events.

The NRC addresses the adequacy of Fukushima lessons learned implementation by licensees as part of its ongoing regulatory oversight of operating nuclear power plants. This oversight will continue during the North Anna period of extended operation if the NRC issues the renewed licenses. Therefore, issues relating to safety improvements in response to the Fukushima event are outside the scope of the NRC staffs environmental review and will not be considered in the draft SEIS.

Some comments raised concerns about the safety of the North Anna Dam. The NRC has a dam safety program under the review of the NRC dam safety officer to ensure public safety from radiological hazards. This program is in coordination with the Federal Emergency Management Agency. More information about flooding hazards related to the North Anna Dam can be found in NRC staff evaluation reports related to flooding, under ADAMS Accession Nos. ML15238A844 and ML17325B644. Issues relating to North Anna Dam safety are beyond the scope of the environmental impacts to be addressed in the SEIS and will thus not be further considered.

Regarding the nuclear criticality accident that caused core damage at the Soviet Unions Chernobyl plant in 1986, light-water reactors in the United States, including North Anna, have a negative void reactivity coefficient (i.e., nuclear chain reaction decreases as temperature increases), which is different from the graphite-moderated reactor at Chernobyl, whose positive void reactivity coefficient contributed to the 1986 nuclear criticality accident. Accordingly, the Chernobyl reactor design is not comparable to the reactor design at North Anna. Issues relating to the 1986 Chernobyl event in the Soviet Union are outside the scope of the NRC staffs environmental review and will not be considered in the draft SEIS. More information about Chernobyls implications for safety regulation of nuclear power plants in the United States can be found at ADAMS Accession No. ML082030501.

Regarding severe accidents and release, the NRC staff will consider any new and significant information associated with severe accident impacts as a part of the Severe Accident Mitigation Alternatives (SAMA) review in Chapter 3 and Appendix F of the SEIS.

B.2.5 Not Allowing Reprocessing Concerns Comment Summary (NAPS-1-1): This comment expresses concern about not allowing spent fuel reprocessing (recycling), which the commenter says hinders minimizing nuclear waste.

Response: This comment is beyond the scope of the NRC staffs environmental review for North Anna and staff will not consider this further in the SEIS.

On March 4, 2020, the NRC staff held a public meeting to discuss the status of the spent fuel reprocessing rulemaking and to gather public input. The meeting summary can be found at ADAMS Accession No. ML20077K144. More information about reprocessing rule making is available at: https://www.nrc.gov/reading-rm/doc-collections/rulemaking-ruleforum/active/ruledetails.html?id=57.

C. List of Commenters Table C-1 provides a list of commenters identified by name, affiliation (if stated), the commenter identification (ID) number, the comment source, and the ADAMS accession number.

Table C-1: Individuals Providing Comments during the Scoping Comment Period Commenter Affiliation (if stated)

Commenter ID Comment Source ADAMS Accession Number Kevin Quigley NA NAPS-1 Regulations.gov ML20324A679 Luther Jones NA NAPS-2 Regulations.gov ML20324A680 Frederick Gerloff NA NAPS-3 Regulations.gov ML20324A681 Keith Scott NA NAPS-4 Regulations.gov ML20324A682 Joseph Sucha NA NAPS-5 Regulations.gov ML20324A683 Thomas Owens NA NAPS-6 Regulations.gov ML20324A685 Nancy Ashberry NA NAPS-7 Regulations.gov ML20324A686

Commenter Affiliation (if stated)

Commenter ID Comment Source ADAMS Accession Number Lisa Hicks-Thomas NA NAPS-8 Regulations.gov ML20325A051 Martin Blough NA NAPS-9 Regulations.gov ML20325A053 Michael Hamby NA NAPS-10 Regulations.gov ML20325A054 Lauren Lopez NA NAPS-11 Regulations.gov ML20325A057 Melissa Haley NA NAPS-12 Regulations.gov ML20325A058 Terry Clouthier Pamunkey Tribe Consultation Letter NAPS-13 Regulations.gov ML20325A060 Kevin Cordray NA NAPS-14 Regulations.gov ML20325A061 Jason Evans NA NAPS-15 Regulations.gov ML20325A062 Tracy Gill NA NAPS-16 Regulations.gov ML20325A063 Tommy Flynn NA NAPS-17 Regulations.gov ML20325A065 Jim Norvelle NA NAPS-18 Regulations.gov ML20325A066 Ronald Buchanan NA NAPS-19 Regulations.gov ML20325A068 Harold Vaughan NA NAPS-20 Regulations.gov ML20325A071 Mel Holley NA NAPS-21 Regulations.gov ML20325A072 Sarah Marshall NA NAPS-22 Regulations.gov ML20325A073 Andrew Moncol NA NAPS-23 Regulations.gov ML20325A074 Richard Zuercher NA NAPS-24 Regulations.gov ML20325A075 J. Crouch NA NAPS-25 Regulations.gov ML20325A092 J. Crouch NA NAPS-26 Regulations.gov ML20325A094 Jenna Brown NA NAPS-27 Regulations.gov ML20325A097 Ralph Joyce NA NAPS-28 Regulations.gov ML20325A101 Steven Eisenrauch NA NAPS-29 Regulations.gov ML20325A103 David Strole NA NAPS-30 Regulations.gov ML20325A104 Carl Eng NA NAPS-31 Regulations.gov ML20325A105 Angela Baker NA NAPS-32 Regulations.gov ML20325A107 Adam Perry NA NAPS-33 Regulations.gov ML20325A109 Terrance Perrone NA NAPS-34 Regulations.gov ML20325A110 Greg Boutchyard NA NAPS-35 Regulations.gov ML20325A111 Robert George NA NAPS-36 Regulations.gov ML20325A112 Shawn Williams NA NAPS-37 Regulations.gov ML20325A113 Eric Hendrixson NA NAPS-38 Regulations.gov ML20325A115 Carl Aimee Newcomb NA NAPS-39 Regulations.gov ML20325A117 Donald Sharp NA NAPS-40 Regulations.gov ML20325A118

Commenter Affiliation (if stated)

Commenter ID Comment Source ADAMS Accession Number Robert Fleshman NA NAPS-41 Regulations.gov ML20325A120 Edmond Longest NA NAPS-42 Regulations.gov ML20325A124 John Cruickshank Piedmont of the Sierra Club NAPS-43 Regulations.gov ML20325A130 Shaikh Rahman NA NAPS-44 Regulations.gov ML20329A389 Carolyn Morrison NA NAPS-45 Regulations.gov ML20329A390 Harsh Purohit NA NAPS-46 Regulations.gov ML20329A391 Annelewis Weymouth NA NAPS-47 Regulations.gov ML20329A393 Jeff Mock NA NAPS-48 Regulations.gov ML20329A394 Harsh Purohit NA NAPS-49 Regulations.gov ML20329A395 Joseph Blizman NA NAPS-50 Regulations.gov ML20329A396 Annelewis Weymouth NA NAPS-51 Regulations.gov ML20329A397 Jeff Mock NA NAPS-52 Regulations.gov ML20329A398 Jacqueline Vitiello NA NAPS-53 Regulations.gov ML20329A404 Charles Whitlock NA NAPS-54 Regulations.gov ML20329A405 Robert Dickerson NA NAPS-55 Regulations.gov ML20329A406 Jim Norvelle NA NAPS-56 Regulations.gov ML20329A408 William Johnson NA NAPS-57 Regulations.gov ML20329A409 Diana Johnson NA NAPS-58 Regulations.gov ML20329A410 Virginia McCormack NA NAPS-59 Regulations.gov ML20329A412 Kimberly Cleland NA NAPS-60 Regulations.gov ML20329A414 Edward Bogdan Loudoun Climate Project NAPS-61 Regulations.gov ML20329A415 Steve Duggan NA NAPS-62 Regulations.gov ML20329A420 Cathy Horne NA NAPS-63 Regulations.gov ML20329A421 Anonymous NA NAPS-64 Regulations.gov ML20329A422*

Jonathan Bransky NA NAPS-65 Regulations.gov ML20329A423 Brenda Finchum NA NAPS-66 Regulations.gov ML20329A424 Elena Day NA NAPS-67 Regulations.gov ML20329A425 Robert Dickerson NA NAPS-68 Regulations.gov ML20329A427 Jim Norvelle NA NAPS-69 Regulations.gov ML20329A429

Commenter Affiliation (if stated)

Commenter ID Comment Source ADAMS Accession Number Ronald Buchanan NA NAPS-70 Regulations.gov ML20330A190 Samantha Moore NA NAPS-71 Regulations.gov ML20330A191 Alice Campbell NA NAPS-72 Regulations.gov ML20330A206 Virginia Weis NA NAPS-73 Regulations.gov ML20330A207 Shane Compton NA NAPS-74 Regulations.gov ML20330A208 Mike Dodd NA NAPS-75 Regulations.gov ML20330A210 Leigh Wolfram NA NAPS-76 Regulations.gov ML20330A211 Forrest Mills NA NAPS-77 Regulations.gov ML20330A212 Rebecca Fawls NA NAPS-78 Regulations.gov ML20330A213 Elizabeth Gryder NA NAPS-79 Regulations.gov ML20330A214 Donald Henshaw NA NAPS-80 Regulations.gov ML20330A215 Kimberly Reese NA NAPS-81 Regulations.gov ML20330A216 Patrick Hough NA NAPS-82 Regulations.gov ML20330A218 Aaron Brock NA NAPS-83 Regulations.gov ML20330A219 Kristin Cassell NA NAPS-84 Regulations.gov ML20330A220 John Grimes NA NAPS-85 Regulations.gov ML20330A222 Jean Stokes NA NAPS-86 Regulations.gov ML20330A224 Jean Stokes NA NAPS-87 Regulations.gov ML20330A225 Rayhan Daudani NA NAPS-88 Regulations.gov ML20330A233 Michael Chenkovich NA NAPS-89 Regulations.gov ML20330A230 Paula Chow NA NAPS-90 Regulations.gov ML20330A234 Paula Chow NA NAPS-91 (duplicated submittal of NAPS-90)

Regulations.gov ML20332A054 Igor Prskalo NA NAPS-92 Regulations.gov ML20332A055 Lee Katz NA NAPS-93 Regulations.gov ML20332A056 Alison Kaufmann NA NAPS-94 Regulations.gov ML20332A057 Darius Johnson NA NAPS-95 Regulations.gov ML20332A058 Harold Vaughan NA NAPS-96 Regulations.gov ML20332A059 Mel Holley NA NAPS-97 Regulations.gov ML20332A061 Sarah Marshall NA NAPS-98 Regulations.gov ML20332A062 Andrew Moncol NA NAPS-99 Regulations.gov ML20332A063

Commenter Affiliation (if stated)

Commenter ID Comment Source ADAMS Accession Number Richard Zuercher NA NAPS-100 Regulations.gov ML20332A064 Daniel Daroy NA NAPS-101 Regulations.gov ML20332A065 Kirit Doshi NA NAPS-102 Regulations.gov ML20332A066 Daniel Carro NA NAPS-103 Regulations.gov ML20332A067 Craig Hurd NA NAPS-104 Regulations.gov ML20332A068 Craig Hurd NA NAPS-105 Regulations.gov ML20332A077 Jeffrey Wood NA NAPS-106 Regulations.gov ML20332A050 J. Crouch NA NAPS-107 Regulations.gov ML20332A078 Angela Clarke NA NAPS-108 Regulations.gov ML20332A079 J. Crouch NA NAPS-109 Regulations.gov ML20332A080 Jenna Brown NA NAPS-110 Regulations.gov ML20332A082 Jennifer Beyer NA NAPS-111 Regulations.gov ML20332A084 George Lear NA NAPS-112 Regulations.gov ML20332A085 Stephen Kotowski NA NAPS-113 Regulations.gov ML20332A086 Matthew Vinson NA NAPS-114 Regulations.gov ML20332A088 Laura Larkin NA NAPS-115 Regulations.gov ML20332A090 Melissa Cook NA NAPS-116 Regulations.gov ML20332A091 Alex Nahama NA NAPS-117 Regulations.gov ML20332A092 Ryan Compton NA NAPS-118 Regulations.gov ML20332A095 Laurie Beasley-Turner NA NAPS-119 Regulations.gov ML20332A098 Ralph Joyce NA NAPS-120 Regulations.gov ML20332A099 Steven Eisenrauch NA NAPS-121 Regulations.gov ML20332A104 Steven Crawford NA NAPS-122 Regulations.gov ML20332A105 Jennifer Comer NA NAPS-123 Regulations.gov ML20332A106 Bryan Bowles NA NAPS-124 Regulations.gov ML20332A116 Shira Futterman NA NAPS-125 Regulations.gov ML20332A118 John Andrews NA NAPS-126 Regulations.gov ML20332A119 David Strole NA NAPS-127 Regulations.gov ML20332A120 Robert Fullen NA NAPS-128 Regulations.gov ML20332A121 David Craymer NA NAPS-129 Regulations.gov ML20332A122 Carl Eng NA NAPS-130 Regulations.gov ML20332A123 Doswell Pierce NA NAPS-131 Regulations.gov ML20332A124

Commenter Affiliation (if stated)

Commenter ID Comment Source ADAMS Accession Number George O'Connell NA NAPS-132 Regulations.gov ML20332A125 Edward Sandtner NA NAPS-133 Regulations.gov ML20332A126 Bob Zak NA NAPS-134 Regulations.gov ML20332A127 Bob Zak NA NAPS-135 Regulations.gov ML20332A133 Jerry Overman NA NAPS-136 Regulations.gov ML20332A134 Ronald Lovelace NA NAPS-137 Regulations.gov ML20332A135 Natalie Pien Sierra Club NAPS-138 Regulations.gov ML20332A136 Alane Callander NA NAPS-139 Regulations.gov ML20332A137 James Lynch NA NAPS-140 Regulations.gov ML20332A138 Erica Gray NA NAPS-141 Regulations.gov; Scoping Public Meeting Transcript ML20332A140, ML20317A206 Andy Wade County of Louisa NAPS-142 Scoping Public Meeting Transcript ML20317A206 Don Safer Tennessee Environmental Council and Nuclear Free Team of the Sierra Club NAPS-143 Scoping Public Meeting Transcript ML20317A206 Fred Mladen Dominion Energy; NAPS-144 Scoping Public Meeting Transcript ML20317A206 Robert Babyok Louisa County Board of Supervisors NAPS-145 Scoping Public Meeting Transcript ML20317A206 Thomas Saporito Nuclear Energy Oversight project NAPS-146 Scoping Public Meeting Transcript ML20317A206 NA - affiliation information is not stated (not available) verbally or in writing.

• The commenters statements are unrelated to the proposed subsequent license renewal and associated environmental review for North Anna, Units 1 and 2 and will not be considered further.