ML21279A018

Comment (2) E-mail Regarding North Anna SLR Draft SEIS

ML21279A018
Person / Time
Site:	North Anna
Issue date:	10/05/2021
From:	Public Commenter Public Commenter
To:	Office of Nuclear Material Safety and Safeguards
NRC/NMSS
References
86FR47525
Download: ML21279A018 (39)

Text

From: Fulcher, Valerie <valerie.fulcher@deq.virginia.gov>

Sent: Tuesday, October 5, 2021 3:34 PM To: NorthAnnaEnvironmental Resource; rr dgif-ESS Projects; Roberta Rhur; Birge, Tiffany; odwreview (VDH); Keith Tignor; Terrance Lasher; Roger Kirchen; rr EIR Coordination; David Spears; Curtis Brown; cgoodwin@louisa.org; cjacobs@tjpdc.org; Pelchat, John Cc: John Fisher

Subject:

[External_Sender] NRC GEIS License Renewal of Nuclear Plants, Docket ID NRC-2020-0234, DEQ 21-109F Attachments: 21-109F (Subsequent License Renewal for NAPS Units 1 and 2-NRC).geis.pdf Good afternoon - attached is your file copy of the completed federal review for the following project:

Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 7, Second Renewal, Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2, U.S. Nuclear Regulatory Commission, Louisa County, (DEQ 21-109F)

If you have any questions regarding this project, please call John at 804/698-4339; email John.Fisher@deq.virginia.gov Valerie Valerie A. Fulcher, CAP, OM, Admin/Data Coordinator Senior Department of Environmental Quality Environmental Enhancement - Office of Environmental Impact Review 1111 East Main Street Richmond, VA 23219 804/698-4330 Email: Valerie.Fulcher@deq.virginia.gov https://www.deq.virginia.gov/permits-regulations/environmental-impact-review OUR ENFORCEABLE POLICIES HAVE BEEN UPDATED FOR 2020:

https://www.deq.virginia.gov/permits-regulations/environmental-impact-review/federal-consistency

For program updates and public notices please subscribe to Constant

Contact:

https://lp.constantcontact.com/su/MVcCump/EIR

Federal Register Notice: 86FR47525 Comment Number: 2 Mail Envelope Properties (CAEronin7haPBC5LAJZ3OxS98EJ2=_d_BAgriQWnae96VXNBZpA)

Subject:

[External_Sender] NRC GEIS License Renewal of Nuclear Plants, Docket ID NRC-2020-0234, DEQ 21-109F Sent Date: 10/5/2021 3:33:36 PM Received Date: 10/5/2021 3:34:04 PM From: Fulcher, Valerie Created By: valerie.fulcher@deq.virginia.gov Recipients:

"John Fisher" <john.fisher@deq.virginia.gov>

Tracking Status: None "NorthAnnaEnvironmental Resource" <NorthAnnaEnvironmental.Resource@nrc.gov>

Tracking Status: None "rr dgif-ESS Projects" <essprojects@dgif.virginia.gov>

Tracking Status: None "Roberta Rhur" <robbie.rhur@dcr.virginia.gov>

Tracking Status: None "Birge, Tiffany" <tiffany.birge@mrc.virginia.gov>

Tracking Status: None "odwreview (VDH)" <odwreview@vdh.virginia.gov>

Tracking Status: None "Keith Tignor" <keith.tignor@vdacs.virginia.gov>

Tracking Status: None "Terrance Lasher" <terry.lasher@dof.virginia.gov>

Tracking Status: None "Roger Kirchen" <roger.kirchen@dhr.virginia.gov>

Tracking Status: None "rr EIR Coordination" <eir.coordination@vdot.virginia.gov>

Tracking Status: None "David Spears" <david.spears@dmme.virginia.gov>

Tracking Status: None "Curtis Brown" <curtis.brown@vdem.virginia.gov>

Tracking Status: None "cgoodwin@louisa.org" <cgoodwin@louisa.org>

Tracking Status: None "cjacobs@tjpdc.org" <cjacobs@tjpdc.org>

Tracking Status: None "Pelchat, John" <John.Pelchat@nrc.gov>

Tracking Status: None Post Office: mail.gmail.com Files Size Date & Time MESSAGE 1256 10/5/2021 3:34:04 PM 21-109F (Subsequent License Renewal for NAPS Units 1 and 2-NRC).geis.pdf 1703662 Options Priority: Normal

Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Commonwealth of Virginia VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY 1111 E. Main Street, Suite 1400, Richmond, Virginia 23219 P.O. Box 1105, Richmond, Virginia 23218 (800) 592-5482 FAX (804) 698-4178 www.deq.virginia.gov Ann F. Jennings David K. Paylor Secretary of Natural and Historic Resources Director (804) 698-4000 October 5, 2021 U.S. Nuclear Regulatory Commission Office of Administration ATTN: Program Management Announcements and Editing Staff Mail Stop: TWFN-7-A60M Washington, DC 20555-0001 Via email: northannaenvironmental@nrc.gov RE: Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 7, Second Renewal, Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2, U.S. Nuclear Regulatory Commission, Louisa County, (DEQ 21-109F)

Dear NRC Staff:

The Commonwealth of Virginia has completed its review of the above-referenced document. The Department of Environmental Quality (DEQ) is responsible for coordinating Virginias review of federal environmental documents submitted under the National Environmental Policy Act (NEPA) and responding to appropriate federal officials on behalf of the Commonwealth. DEQ reviewed a Federal Consistency Certification submitted in 2019 (DEQ 19-123F) for the proposal pursuant to the Coastal Zone Management Act and on December 23, 2019, found the subsequent license renewal consistent with the enforceable policies of the Virginia Coastal Zone Management Program. This is in response to the August 2021 Generic Environmental Impact Statement (GEIS), Supplement 7, Second Renewal (received August 25, 2021) submitted by the U.S. Nuclear Regulatory Commission (NRC). The following agencies participated in the review of this proposal:

Department of Environmental Quality Department of Wildlife Resources Virginia Marine Resources Commission Department of Conservation and Recreation Department of Health Department of Forestry In addition, the Department of Agriculture and Consumer Services, Department of

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F Historic Resources, Department of Transportation, Department of Energy, Department of Emergency Management, Thomas Jefferson Planning District Commission, and Louisa County were invited to comment on the proposal.

PROJECT DESCRIPTION The NRC has issued a draft plant-specific Supplement 7, Second Renewal, to the GEIS for License Renewal of Nuclear Plants (NUREG-1437), regarding the subsequent renewal of Facility Operating License Nos. NPF-4 and NPF-7 for an additional 20 years of operation at the North Anna Power Station (NAPS) in Louisa County, Virginia.

Virginia Electric & Power Company, doing business as Dominion Energy Virginia (Dominion) initiated the proposed federal action by submitting an application for subsequent license renewal (SLR). The current renewed licenses expire at midnight on April 1, 2038, for Unit 1 (NPF-4), and at midnight on August 21, 2040, for Unit 2 (NPF-7).

The draft plant-specific Supplement 7, Second Renewal, to the GEIS includes a preliminary analysis that evaluates the environmental impacts of the proposed action and alternatives to the proposed action. Most plant operation activities during the subsequent license renewal term would be the same as, or similar to, those occurring during the current license term. Potential refurbishment activities include replacement and repair of major structures, systems, and components. Most major refurbishment activities are actions that would typically take place only once in the life of a nuclear plant, if at all. Dominion did not identify any major refurbishment activities necessary for the continued operation of NAPS beyond the end of the existing operating licenses. The NRC staffs preliminary recommendation is that the adverse environmental impacts of subsequent license renewal for North Anna are not so great that preserving the option of subsequent license renewal for energy-planning decision makers would be unreasonable.

CONCLUSION UNDER THE NATIONAL ENVIRONMENTAL POLICY ACT Provided activities are performed in accordance with the recommendations which follow in the Environmental Impacts and Mitigation section of this report, the Proposed Action is unlikely to have significant effects on ambient air quality, important farmland, forest resources, and wetlands. It is unlikely to adversely affect species of plants or insects listed by state agencies as rare, threatened, or endangered.

ENVIRONMENTAL IMPACTS AND MITIGATION

1. Surface Waters and Wetlands. According to the GEIS Supplement 7 (page 3-43),

the impacts of nuclear power plant license renewal and continued operations would generally be small. No significant surface water impacts with respect to Category 1 (generic) issues are anticipated during the subsequent license renewal term that would be different from those occurring during the current license term. The GEIS Supplement 2

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F 7 (page 3-50) states that the North Anna site boundaries include a total of 650 acres of wetland, lake, and riverine waters. Most of the water and wetland acreage is occupied by Lake Anna, with 630 acres inside the North Anna site. Physical disturbance would be limited to paved or disturbed areas or to areas of mowed grass or early successional vegetation and not encroach into wetlands (GEIS Supplement 7, page 3-54).

1(a) Agency Jurisdiction.

(i) Department of Environmental Quality The State Water Control Board promulgates Virginia's water regulations covering a variety of permits to include the Virginia Pollutant Discharge Elimination System Permit regulating point source discharges to surface waters, Virginia Pollution Abatement Permit regulating sewage sludge, storage and land application of biosolids, industrial wastes (sludge and wastewater), municipal wastewater, and animal wastes, the Surface and Groundwater Withdrawal Permit, and the Virginia Water Protection (VWP) Permit regulating impacts to streams, wetlands, and other surface waters. The VWP permit is a state permit which governs wetlands, surface water, and surface water withdrawals and impoundments. It also serves as §401 certification of the federal Clean Water Act §404 permits for dredge and fill activities in waters of the U.S. The VWP Permit Program is under the Office of Wetlands and Stream Protection, within the DEQ Division of Water Permitting. In addition to central office staff that review and issue VWP permits for transportation and water withdrawal projects, the six DEQ regional offices perform permit application reviews and issue permits for the covered activities:

Clean Water Act, §401; Section 404(b)(i) Guidelines Mitigation Memorandum of Agreement (2/90);

State Water Control Law, Virginia Code section 62.1-44.15:20 et seq.; and State Water Control Regulations, 9 VAC 25-210-10.

(ii) Virginia Marine Resources Commission The Virginia Marine Resources Commission (VMRC) regulates encroachments in, on or over state-owned subaqueous beds as well as tidal wetlands pursuant to Virginia Code

§28.2-1200 through 1400. For nontidal waterways, VMRC states that it has been the policy of the Habitat Management Division to exert jurisdiction only over the beds of perennial streams where the upstream drainage area is 5 square miles or greater. The beds of such waterways are considered public below the ordinary high water line.

1(b) Agency Findings.

(i) Department of Environmental Quality The VWP Permit program at the DEQ Central Office (CO) notes that measures such as, but not limited to, Best Management Practices (BMPs) must be taken to avoid and 3

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F minimize impacts to surface waters during construction activities, including potential water quality impacts resulting from construction site runoff. The disturbance of land and surface waters, which include wetlands, open water, and streams, may require prior approval by DEQ, U.S. Army Corps of Engineers (Corps), VMRC, and/or local government wetlands boards (generally in the northern and piedmont regions of Virginia). The Corps and DEQ work in conjunction to provide official confirmation of whether there are federal and/or state jurisdictional surface waters that may be impacted by the proposed project. VMRC provides its own review to determine its agency jurisdiction. Review of National Wetland Inventory maps or topographic maps for locating wetlands, open waters, or streams may not be sufficient; there may need to be a site-specific review by a qualified professional.

If construction activities will occur in or along any streams (perennial, intermittent, or ephemeral), open water or wetlands, the applicant should contact the DEQ VWP Permit program managers at the DEQ Northern Regional Office (NRO) to determine the need for any permits prior to commencing work that could impact surface waters. DEQs permit need decisions neither replace nor supersede requirements set forth by other local, state, federal, and tribal laws, nor eliminate the need to obtain additional permits, approvals, consultations, or authorizations as required by law before proposed activities may commence.

(ii) Virginia Marine Resources Commission VMRC did not indicate that tidal wetlands under its jurisdiction would be impacted.

VMRC has no objections to the renewal of the North Anna Power Station operating licenses for Units 1 and 2.

1(c) Requirements. Any future impacts to jurisdictional waters may require a VWP Permit. VMRC serves as the clearinghouse for the submission of Joint Permit Applications (JPAs) used by DEQ, VMRC, Corps and local wetlands boards for the review and issuance of any necessary permits or approvals for impacts to jurisdictional waters. Upon receipt of a JPA, the VWP Permit staff at DEQ-NRO will review the proposed project in accordance with the VWP Permit program regulations and guidance.

1(d) Recommendations. Based upon review of the information provided by the NRC, DEQ-CO offers the following recommendations:

1. Prior to commencing project work, all wetlands and streams within the project corridor should be field delineated and verified by the Corps, using accepted methods and procedures.

2. Wetland and stream impacts should be avoided and minimized to the maximum extent practicable. Stream impacts should be minimized or avoided by spanning the transmission line across each stream. No foundations should be placed within streambeds. Where access is required across a wetland, removable mats 4

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F should be used to reduce compaction and rutting. Towers should be placed avoid wetlands, wherever possible. To the extent where any footings must be installed in wetlands, each footing should occupy the minimum space necessary. When excavation for a structure is necessary in a wetland, excess spoil should not be disposed of in adjacent wetland areas unless authorized by a state or federal wetland permit.

3. If the scope of the action changes, additional review will be necessary by this office.

4. At a minimum, compensation for impacts to state waters, if necessary, should be in accordance with all applicable state wetland regulations and wetland permit requirements, including the compensation for permanent conversion of forested wetlands to emergent wetlands.

5. Any temporary impacts to surface waters associated with this project should require restoration to pre-existing conditions.

6. No activity may substantially disrupt the movement of aquatic life indigenous to the water body, including those species, which normally migrate through the area, unless the primary purpose of the activity is to impound water. Culverts placed in streams must be installed to maintain low flow conditions. No activity may cause more than minimal adverse effect on navigation. Furthermore the activity must not impede the passage of normal or expected high flows and the structure or discharge must withstand expected high flows.

7. Erosion and sedimentation controls should be designed in accordance with the Virginia Erosion and Sediment Control Handbook, Third Edition, 1992. These controls should be placed prior to clearing and grading and maintained in good working order to minimize impacts to state waters. These controls should remain in place until the area is stabilized and should then be removed. Any exposed slopes and streambanks should be stabilized immediately upon completion of work in each permitted area. All denuded areas should be properly stabilized in accordance with the Virginia Erosion and Sediment Control Handbook, Third Edition, 1992.

8. No machinery may enter surface waters, unless authorized by a VWP Permit.

9. Heavy equipment in temporarily impacted surface waters should be placed on mats, geotextile fabric, or other suitable material, to minimize soil disturbance to the maximum extent practicable. Equipment and materials should be removed immediately upon completion of work.

10. Activities should be conducted in accordance with any Time-of-Year restriction(s) as recommended by the Department of Wildlife Resources, the Department of Conservation and Recreation, or the VMRC. The permittee should retain a copy of the agency correspondence concerning the Time-of-Year restriction(s), or the lack thereof, for the duration of the construction phase of the project.

11. All construction, construction access, and demolition activities associated with this project should be accomplished in a manner that minimizes construction materials or waste materials from entering surface waters, unless authorized by a permit. Wet, excess, or waste concrete should be prohibited from entering surface waters.

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Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F

12. Herbicides used in or around any surface water should be approved for aquatic use by the United States Environmental Protection Agency (EPA) or the U.S.

Fish and Wildlife Service. These herbicides should be applied according to label directions by a licensed herbicide applicator. A non-petroleum based surfactant should be used in or around any surface waters.

13. Consider mitigating impacts to forested or converted wetlands by establishing new forested wetlands within the impacted watershed.

For additional information, contact the VWP Permit program at DEQ-NRO, Trisha Beasley at (703) 583-3940 or trisha.beasley@deq.virginia.gov, and/or VMRC, Tiffany Birge at (757) 247-2254 or tiffany.birge@mrc.virginia.gov.

2. State Subaqueous Lands. The GEIS Supplement 7 does not specifically address potential impacts to state subaqueous lands.

2(a) Agency Jurisdiction. The Virginia Marine Resources Commission (VMRC) regulates encroachments in, on or over state-owned subaqueous beds as well as tidal wetlands pursuant to Virginia Code §28.2-1200 through 1400. For nontidal waterways, VMRC states that it has been the policy of the Habitat Management Division to exert jurisdiction only over the beds of perennial streams where the upstream drainage area is 5 square miles or greater. The beds of such waterways are considered public below the ordinary high water line.

2(b) Agency Findings. VMRC finds that no new work is proposed over state-owned submerged land. VMRC has no objections to the renewal of the North Anna Power Station operating licenses for Units 1 and 2.

For additional information, contact VMRC, Tiffany Birge at (757) 247-2254 or tiffany.birge@mrc.virginia.gov.

3. Point Source Discharges. The GEIS Supplement 7 (page 3-93) notes that DEQ has granted Dominion multiple, sequential variances under CWA Section 316(a) associated with the NAPS thermal effluent. Because characteristics of the thermal effluent would remain the same under the proposed action, the NRC staff anticipates similar effects during the proposed SLR period. Further, DEQ will continue to review the CWA Section 316(a) variance with each successive VPDES permit renewal and may require additional mitigation or monitoring in a future renewed VPDES permit if it deems such actions to be appropriate to assure the protection and propagation of a balanced, indigenous population of shellfish, fish, and wildlife in Lake Anna and the North Anna River downstream of the lake. NRC staff finds that thermal impacts during the proposed SLR period would neither destabilize nor noticeably alter any important attribute of the aquatic environment and would, therefore, result in small impacts on aquatic organisms.

3(a) Agency Jurisdiction. The Clean Water Act established the National Pollutant Discharge Elimination System (NPDES) program to limit pollutants getting into streams, 6

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F rivers and bays. DEQ administers the program as the Virginia Pollutant Discharge Elimination System (VPDES). The agency issues permits for: all point source discharges to surface waters, dischargers of stormwater from Municipal Separate Storm Sewer Systems (MS4s), and dischargers of stormwater from Industrial Activities.

3(b) Agency Findings. The VPDES program at DEQ-NRO notes that NAPS has an Individual VPDES Permit (VA0052451) and is subject to the requirements of Section 316(a) and Section 316(b) of the CWA.

3(c) Requirements. Any changes to the reactors (e.g. uprates, turbine/blade replacements, etc.) that could have an impact on the thermal component of the discharge and may need to be addressed through VPDES permitting under CWA 316(a). Additionally, any work at the intakes or increase in flows related to reactor changes may need to be addressed through VPDES permitting under CWA 316(b).

For additional information, contact the VPDES Permit program at DEQ-NRO, Susan Mackert at (703) 583-3853 or susan.mackert@deq.virginia.gov

4. Erosion and Sediment Control and Stormwater Management. According to the GEIS Supplement 7 (page 3-23), Dominion maintains a Stormwater Pollution Prevention Plan (SWPPP) for the North Anna site that includes soil erosion and sediment control measures to prevent erosion and potential water quality impacts.

4(a) Agency Jurisdiction. The DEQ Office of Stormwater Management (OSWM) administers the following laws and regulations governing construction activities:

Virginia Erosion and Sediment Control (ECS) Law (§ 62.1-44.15:51 et seq.) and Regulations (9 VAC 25-840);

Virginia Stormwater Management Act (§ 62.1-44.15:24 et seq.);

Virginia Stormwater Management Program (VSMP) regulation (9 VAC 25-870);

and 2014 General Virginia Pollutant Discharge Elimination System (VPDES) Permit for Discharges of Stormwater from Construction Activities (9 VAC 25-880).

In addition, DEQ is responsible for the Virginia Stormwater Management Program (VSMP) General Permit for Stormwater Discharges from Construction Activities related to Municipal Separate Storm Sewer Systems (MS4s) and construction activities for the control of stormwater discharges from MS4s and land disturbing activities under the Virginia Stormwater Management Program (9 VAC 25-890-40).

4(b) Requirements.

(i) Erosion and Sediment Control Plan Dominion is responsible for submitting a project-specific Erosion and Sediment Control 7

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F (ESC) Plan to Louisa County for review and approval pursuant to the local ESC requirements, for future construction involving land-disturbing activities of 10,000 square feet or more. Depending on local requirements the area of land disturbance requiring an ESC Plan may be less. The ESC Plan must be approved by the locality prior to any land-disturbing activity at the project site. All regulated land-disturbing activities associated with the project, including on and off site access roads, staging areas, borrow areas, stockpiles, and soil intentionally transported from the project must be covered by the project-specific ESC Plan. Local ESC program requirements must be requested through the locality. [

Reference:

Virginia Erosion and Sediment Control Law

§62.1-44.15 et seq.; Virginia Erosion and Sediment Control Regulations 9 VAC 25-840-10 et seq.]

(ii) Stormwater Management Plan Depending on local requirements, a Stormwater Management (SWM) Plan may be required for future construction. Local SWM program requirements must be requested through the locality. [

Reference:

Virginia Stormwater Management Act §62.1-44.15 et seq.; Virginia Stormwater Management (VSMP) Permit Regulations 9 VAC 25-870-10 et seq.]

(iii) General VPDES Permit for Discharges of Stormwater from Construction Activities (VAR10)

The owner or operator of projects involving land-disturbing activities of equal to or greater than one acre is required to apply for registration coverage under the General Permit for Discharges of Stormwater from Construction Activities and develop a project-specific stormwater pollution prevention plan (SWPPP). Construction activities requiring registration also include land disturbance of less than one acre of total land area that is part of a larger common plan of development or sale if the larger common plan of development will collectively disturb equal to or greater than one acre.

The SWPPP must be prepared prior to submission of the registration statement for coverage under the General Permit.

The SWPPP must address water quality and quantity in accordance with the VSMP Permit Regulations.

General information and registration forms for the General Permit are available on Construction General Permit webpage. [

Reference:

Virginia Stormwater Management Act 62.1-44.15 et seq.; VSMP Permit Regulations 9 VAC 25-880 et seq.].

For additional information, contact DEQ-OSWM, Larry Gavan at (804) 698-4040 or larry.gavan@deq.virginia.gov.

5. Floodplain Management. The GEIS Supplement 7 (page 3-27 through 3-29) states that Federal Emergency Management Agency (FEMA) has mapped the majority of the 8

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F plant site as Zone X, representing areas of minimal flood hazard and lying outside the 0.2 percent annual chance floodplain (100-year flood level). Several small, low areas along the lakeshore and associated with the discharge canal are mapped as Zone AE, reflecting areas within the 100-year flood level with base flood elevations of 254 feet. In accordance with the NRCs General Design Criteria, plant structures, systems, and components important to safety are designed to withstand the effects of natural phenomena, such as flooding, without loss of capability to perform safety functions.

5(a) Agency Jurisdiction. The DCR Division of Dam Safety and Floodplain Management (DSFM) is the lead coordinating agency for the Commonwealths floodplain management program and the National Flood Insurance Program (Executive Oder 45). The National Flood Insurance Program (NFIP) is administered by the Federal Emergency Management Agency (FEMA), and communities who elect to participate in this voluntary program manage and enforce the program on the local level through that communitys local floodplain ordinance. Each local floodplain ordinance must comply with the minimum standards of the NFIP, outlined in 44 CFR 60.3; however, local communities may adopt more restrictive requirements in their local floodplain ordinance, such as regulating the 0.2% annual chance flood zone (shaded Zone X).

5(b) Requirements. All development within a Special Flood Hazard Area (SFHA) or floodplain, as shown on the localitys Flood Insurance Rate Map (FIRM), must be permitted and comply with the requirements of the local floodplain ordinance. Projects conducted by federal agencies within the SFHA must comply with federal Executive Order 11988: Floodplain Management.

DCRs Floodplain Management Program does not have regulatory authority for projects in the SFHA. The applicant/developer must contact the local floodplain administrator for an official floodplain determination and comply with the communitys local floodplain ordinance, including receiving a local permit. Failure to comply with the local floodplain ordinance could result in enforcement action from the locality. Dominion is encouraged to reach out to the local floodplain administrator to ensure compliance with the local floodplain ordinance.

5(c) Recommendations. DCR recommends the Dominion access the Virginia Flood Risk Information System (VFRIS) to find flood zone information. Local floodplain administrator contact information may be found in DCRs Local Floodplain Management Directory.

For additional information, contact DCR-DSFM, Angela Davis at (804) 371-6135 or angela.davis@dcr.virginia.gov.

6. Air Pollution Control. The GEIS Supplement 7 (page 3-15) notes that NAPS is located in an attainment area for all National Ambient Air Quality Standards (NAAQS) criteria pollutants. Dominion submits annual emission reports to DEQ in accordance with the State Operating Permit. For generic (Category 1) issues related to air quality, 9

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F the impacts of nuclear power plant license renewal and continued operations would be small. The NRC staffs review did not identify any new and significant information that would change the conclusion in the GEIS. Thus, the impacts of continued operation of North Anna on air quality would be small. In addition, there are no site-specific (Category 2) air quality issues applicable to North Anna (GEIS Supplement 7, pages 3-17 and 3-18).

6(a) Agency Jurisdiction. The DEQ Air Division, on behalf of the State Air Pollution Control Board, is responsible for developing regulations that implement Virginias Air Pollution Control Law (Virginia Code §10.1-1300 et seq.). DEQ is charged with carrying out mandates of the state law and related regulations as well as Virginias federal obligations under the Clean Air Act as amended in 1990. The objective is to protect and enhance public health and quality of life through control and mitigation of air pollution.

The division ensures the safety and quality of air in Virginia by monitoring and analyzing air quality data, regulating sources of air pollution, and working with local, state and federal agencies to plan and implement strategies to protect Virginias air quality. The appropriate DEQ regional office is directly responsible for the issuance of necessary permits to construct and operate all stationary sources in the region as well as monitoring emissions from these sources for compliance.

The Air Division regulates emissions of air pollutants from industries and facilities and implements programs designed to ensure that Virginia meets national air quality standards. The most common regulations associated with major State projects are:

Open burning: 9 VAC 5-130 et seq.

Fugitive dust control: 9 VAC 5-50-60 et seq.

Permits for fuel-burning equipment: 9 VAC 5-80-1100 et seq.

6(b) Agency Findings. According to the DEQ Air Division, the NAPS site is located in a designated ozone nonattainment area and an emission control area for the control of oxides of nitrogen (NOx) and volatile organic compounds (VOCs).

6(c) Recommendation. Dominion should take all reasonable precautions to limit emissions of NOx and VOCs during facility construction and operation activities, principally by controlling or limiting the burning of fossil fuels.

6(d) Requirements. Dominion must evaluate all potential sources of air emissions for the facility, including but not limited to boilers, generators, and cooling towers, and submit an application to DEQ-NRO for a permit (or amendment), if necessary. Any required air permit must be obtained prior to future construction activities.

(i) Fugitive Dust During construction, fugitive dust must be kept to a minimum by using control methods outlined in 9 VAC 5-50-60 et seq. of the Regulations for the Control and Abatement of 10

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F Air Pollution. These precautions include, but are not limited to, the following:

Use, where possible, of water or chemicals for dust control; Installation and use of hoods, fans, and fabric filters to enclose and vent the handling of dusty materials; Covering of open equipment for conveying materials; and Prompt removal of spilled or tracked dirt or other materials from paved streets and removal of dried sediments resulting from soil erosion.

(ii) Asphalt Paving In accordance with 9 VAC 5-45-780, there are limitations on the use of cut-back (liquefied asphalt cement, blended with petroleum solvents) that may apply to paving activities associated with ongoing facility construction and maintenance activities.

Moreover, there are time-of-year restrictions on its use during the months of April through October in VOC emission control areas.

(iii) Open Burning If activities include the open burning of construction material or the use of special incineration devices, this must meet the requirements under 9 VAC 5-130 et seq. of the Regulations for open burning, and may require a permit. The Regulations provide for, but do not require, the local adoption of a model ordinance concerning open burning.

Dominion should contact local fire officials to determine what local requirements, if any, exist.

(iv) Fuel Burning Equipment The installation of fuel burning equipment (e.g. boilers and generators), may require permitting from DEQ prior to beginning construction (9 VAC 5-80, Article 6, Permits for New and Modified Sources). Dominion should contact DEQ-NRO for guidance on whether this provision applies.

For additional information, contact DEQ-NRO, David Hartshorn at (703) 583-3895 or david.hartshorn@deq.virginia.gov.

7. Solid and Hazardous Wastes and Hazardous Materials. According to the GEIS Supplement 7 (pages 3-150 through 3-152), like any operating nuclear power plant, NAPS will produce both radioactive and nonradioactive waste during the SLR period.

Radioactive materials in liquid, gaseous, and solid effluents are reduced prior to being released into the environment so that the resultant dose to members of the public from these effluents is well within NRC and EPA dose standards. Radionuclides that can be efficiently removed from the liquid and gaseous effluents prior to release are converted to a solid waste form for disposal in a licensed disposal facility.

11

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F NAPS has a nonradioactive waste management program to handle nonradioactive waste in accordance with federal, state, and corporate regulations and procedures.

NAPS maintains a waste minimization program that uses material control, process control, waste management, recycling, and feedback to reduce waste. Generic issues related to waste management would not be affected by continued operations associated with license renewal. NRC staff identified no new and significant information for these issues. Thus, the impacts of those generic issues related to waste management would be small.

7(a) Agency Jurisdiction. On behalf of the Virginia Waste Management Board, the DEQ Division of Land Protection and Revitalization (DEQ-DLPR) is responsible for carrying out the mandates of the Virginia Waste Management Act (Virginia Code §10.1-1400 et seq.), as well as meeting Virginia's federal obligations under the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response Compensation Liability Act (CERCLA), commonly known as Superfund.

DEQ-DLPR also administers laws and regulations on behalf of the State Water Control Board governing Petroleum Storage Tanks (Virginia Code §62.1-44.34:8 et seq.),

including Aboveground Storage Tanks (9 VAC 25-91 et seq.) and Underground Storage Tanks (9 VAC 25-580 et seq. and 9 VAC 25-580-370 et seq.), also known as Virginia Tank Regulations, and § 62.1-44.34:14 et seq. which covers oil spills.

Virginia:

Virginia Waste Management Act, Virginia Code § 10.1-1400 et seq.

Virginia Solid Waste Management Regulations, 9 VAC 20-81 (9 VAC 20-81-620 applies to asbestos-containing materials)

Virginia Hazardous Waste Management Regulations, 9 VAC 20-60 (9 VAC 20-60-261 applies to lead-based paints)

Virginia Regulations for the Transportation of Hazardous Materials, 9 VAC 20-110.

Federal:

Resource Conservation and Recovery Act, 42 U.S. Code sections 6901 et seq.

U.S. Department of Transportation Rules for Transportation of Hazardous Materials, 49 Code of Federal Regulations, Part 107 Applicable rules contained in Title 40, Code of Federal Regulations.

7(b) Agency Findings. DEQ-DLPR conducted a search of the project area of solid and hazardous waste databases (including petroleum releases) to identify waste sites in close proximity (200-foot radius) to the NAPS site. The search did not identify any waste sites which might impact the future projects.

12

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F 7(c) Requirements.

(i) Solid and Hazardous Waste Management Any soil, sediment or groundwater that is suspected of contamination or wastes that are generated must be tested and disposed of in accordance with applicable federal, state, and local laws and regulations. All construction waste must be characterized in accordance with the Virginia Hazardous Waste Management Regulations prior to management at an appropriate facility.

(ii) Petroleum Contamination If evidence of a petroleum release is discovered during construction, it must be reported to DEQ-NRO in accordance with Virginia Code § 62.1-44.34.8 through 9 and 9 VAC 25-580-10 et seq. Petroleum-contaminated soils and groundwater that is generated during project implementation must be characterized and disposed of properly.

(iii) Petroleum Storage Tanks The removal, relocation or closure of any regulated petroleum storage tanks, either an aboveground storage tank (AST) or an underground storage tank (UST), must be conducted in accordance with the requirements of the Virginia Tank Regulations 9 VAC 25-91-10 et seq. (AST) and/or 9 VAC 25-580-10 et seq. (UST). Documentation must be submitted DEQ-NRO.

The installation and operation of regulated petroleum ASTs or USTs must be conducted in accordance with 9 VAC 25-91-10 et seq. and/or 9 VAC 25-580-10 et seq.

Furthermore, the installation and use of ASTs with a capacity of greater than 660 gallons for temporary fuel storage (>120 days) during construction must follow the requirements in 9 VAC 25-91-10 et seq.

(iv) Asbestos-Containing Materials and Lead-Based Paint All structures being demolished, renovated, or removed should be checked for asbestos-containing materials (ACM) and lead-based paint (LBP) prior to demolition. If ACM or LBP are found, in addition to the federal waste-related regulations mentioned above, state regulations 9 VAC 20-81-620 (ACM) and 9 VAC 20-60-261 (LBP) must be followed.

7(d) Recommendation. DEQ encourages all construction projects and facilities to implement pollution prevention principles, including the reduction, reuse, and recycling of all solid wastes generated. All generation of hazardous wastes should be minimized and handled appropriately.

Questions or requests for further information regarding the above waste comments may 13

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F be directed to DEQ-DLPR, Carlos Martinez at (804) 698-4575 or carlos.martinezz@deq.virginia.gov.

8. Pesticides and Herbicides. DEQ recommends that the use of herbicides or pesticides for construction or landscape maintenance should be in accordance with the principles of integrated pest management. The least toxic pesticides that are effective in controlling the target species should be used to the extent feasible. Contact the Department of Agriculture and Consumer Services at (804) 786-3501 for more information.

9. Natural Heritage Resources. The GEIS Supplement 7 (page 3-51) finds that based on a review of Virginia Natural Heritage Program (VNHP) databases, Dominion identified nine state-listed species known to occur or potentially occur in Louisa or Spotsylvania counties. Of these nine state-listed species, six are terrestrial and three are aquatic. The NRC staff concludes that the landscape maintenance activities, stormwater management, elevated noise levels, and other ongoing operations and maintenance activities that Dominion might undertake during the renewal term would primarily be confined to already disturbed areas of the North Anna site. These activities would neither have noticeable effects on terrestrial resources nor would they destabilize any important attribute of the terrestrial resources on or in the vicinity of the North Anna site (GEIS Supplement 7, page 3-54).

9(a) Agency Jurisdiction.

(i) The Virginia Department of Conservation and Recreations (DCR) Division of Natural Heritage (DNH)

DNHs mission is conserving Virginia's biodiversity through inventory, protection and stewardship. The Virginia Natural Area Preserves Act (Virginia Code §10.1-209 through 217), authorizes DCR to maintain a statewide database for conservation planning and project review, protect land for the conservation of biodiversity, and protect and ecologically manage the natural heritage resources of Virginia (the habitats of rare, threatened and endangered species, significant natural communities, geologic sites, and other natural features).

(ii) The Virginia Department of Agriculture and Consumer Services (VDACS)

The Endangered Plant and Insect Species Act of 1979 (Virginia Code Chapter 39 §3.1-1020 through 1030) authorizes VDACS to conserve, protect and manage endangered and threatened species of plants and insects. Under a Memorandum of Agreement established between VDACS and the DCR, DCR represents VDACS in comments regarding potential impacts on state-listed threatened and endangered plant and insect species.

14

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F 9(b) Agency Findings.

(i) Natural Heritage Resources DCR-DNH searched its Biotics Data System (Biotics) for occurrences of natural heritage resources from the project area. According to the information currently in Biotics, natural heritage resources have not been documented within the project boundary including a 100 foot buffer. The absence of data may indicate that the project area has not been surveyed, rather than confirm that the area lacks natural heritage resources. In addition, the project boundary does not intersect any of the predictive models identifying potential habitat for natural heritage resources.

(ii) State-listed Plant and Insect Species DCR-DNH finds that the proposed activity will not affect any documented state-listed threatened and endangered plant or insect species.

(iii) State Natural Area Preserves DCR finds that there are no State Natural Area Preserves under the agencys jurisdiction in the project vicinity.

9(c) Recommendation. Contact DCR-DNH to secure updated information on natural heritage resources if the scope of the project changes and/or six months passes before the project is implemented, since new and updated information is continually added to the Biotics Data System.

For additional information, contact DCR-DNH, Rene Hypes at (804) 371-2708 or rene.hypes@dcr.virginia.gov.

10. Wildlife Resources and Protected Species. According to the GEIS Supplement 7 (page 3-51), a review of Department of Wildlife Resources databases identified nine state-listed species known to occur or potentially occur in Louisa or Spotsylvania counties. Of these nine state-listed species, six are terrestrial and three are aquatic. The NRC staff concludes that the landscape maintenance activities, stormwater management, elevated noise levels, and other ongoing operations and maintenance activities that Dominion might undertake during the renewal term would primarily be confined to already disturbed areas of the North Anna site. These activities would neither have noticeable effects on terrestrial resources nor would they destabilize any important attribute of the terrestrial resources on or in the vicinity of the North Anna site (GEIS Supplement 7, page 3-54).

10(a) Agency Jurisdiction. The Virginia Department of Wildlife Resources (DWR)

(formerly the Department of Game and Inland Fisheries), as the Commonwealths wildlife and freshwater fish management agency, exercises enforcement and regulatory 15

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F jurisdiction over wildlife and freshwater fish, including state- or federally-listed endangered or threatened species, but excluding listed insects (Virginia Code, Title 29.1). DWR is a consulting agency under the U.S. Fish and Wildlife Coordination Act (16 U.S. Code §661 et seq.) and provides environmental analysis of projects or permit applications coordinated through DEQ and several other state and federal agencies.

DWR determines likely impacts upon fish and wildlife resources and habitat, and recommends appropriate measures to avoid, reduce or compensate for those impacts.

For more information, see the DWR website.

10(b) Agency Findings. DWR does not currently document any listed wildlife or designated resources from the project area and has no significant concerns with the relicensing of NAPS Units 1 and 2. In addition, DWR does not have any significant concerns regarding the surface water intake (i.e. cooling water withdrawal) from Lake Anna, and the resulting thermal discharge back to the lake, assuming no significant changes are proposed to its operation and all currently required monitoring continues to be performed. DWR will review future CWA 316(b) assessments as part of NAPS VPDES renewal package and will provide specific comments on this aspect of the project to DEQ VPDES staff once DWR has had the opportunity to review the information.

10(c) Recommendations.

(i) Comprehensive Aquatic Vegetation Management Plan DWR recommends the development and implementation of a Comprehensive Aquatic Vegetation Management Plan for Lake Anna, in cooperation with DWR. The plan should address issues such as management of emergent vegetation, submerged aquatic vegetation, and algae (particularly harmful algal blooms) in a manner that results in a healthy aquatic ecosystem. The cooperative development of the plan should be coordinated with DWR, John Odenkirk, Regional Aquatic Biologist at (504) 899-4169 or john.odenkirk@dwr.virginia.gov.

(ii) Protection of Aquatic Species DWR typically recommends that surface water intakes be fitted with a 1mm mesh screen and that the intake velocity not exceed 0.25 fps to protect resident aquatic species from impingement and entrainment. In addition, the intake should not withdraw more than 10% instantaneous flow (90% flowby) to ensure continued access to necessary instream habitats by resident aquatic species. However, DWR understands that these standards are not practicable or necessary at every surface water intake to ensure the protection of resources under its jurisdiction.

For additional information, contact DWR, Amy Martin at (804) 367-2211 or amy.martin@dwr.virginia.gov.

16

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F

11. Public Water Supply. According to the GEIS Supplement 7 (page 3-120), major water sources for Louisa County and the towns of Louisa and Mineral include Lake Anna, 9 groundwater wells, an irrigation lake on Spring Branch, and the Northeast Creek Reservoir. Louisa County partnered with Fluvanna County to create the James River Water Authority, which has a Virginia Water Protection Permit for withdrawal from the James River. North Anna is not connected to a municipal system and accesses potable water through a series of groundwater wells. While population and water demand are projected to increase during the subsequent license renewal term, existing water sources are expected to meet the increasing needs of the population (GEIS Supplement 7, page 3-124).

11(a) Agency Jurisdiction. The Virginia Department of Health (VDH) Office of Drinking Water (ODW) reviews projects for the potential to impact public drinking water sources (groundwater wells, springs and surface water intakes). VDH administers both federal and state laws governing waterworks operation.

11(b) Agency Findings. VDH-ODW finds that NAPS (PWS ID 2109600) has four public groundwater wells (North Anna Nuclear Information Center well and wells 6, 7, and 8) within a 1-mile radius of the project site. There are no surface water intakes for public water supply located within a 5-mile radius of the project site. The project site is within the watershed of the Hanover Suburban Water System (PWS ID 4085398) North Anna River public surface water intake.

11(c) Recommendations. VDH-ODW recommends the following.

Best Management Practices should be employed on the project site, including erosion and sediment controls and Spill Prevention Controls and Countermeasures (SPCC).

Well(s) within a 1,000 foot radius of the project site should be "eld marked and protected from accidental damage during any future construction.

For additional information, contact VDH-ODW, Arlene Fields Warren at (804) 864-7781 or arlene.warren@vdh.virginia.gov.

12. Forest Resources. According to the GEIS Supplement 7 (page 3-105), the proposed action would not involve forest management specifically. However, Dominion would continue to perform vegetation maintenance on the site over the course of the proposed license renewal term. Less-developed areas and forested areas would be largely unaffected during the subsequent license renewal term. Dominion does not intend to expand the existing facilities or otherwise perform construction or maintenance activities within these areas. Site personnel may occasionally remove select trees around the margins of existing forested areas if those trees are deemed hazardous to buildings, infrastructure, or other site facilities or to existing overhead clearances.

12(a) Agency Jurisdiction. The Virginia Department of Forestry (DOF) reviews 17

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F applications to ensure that the forest resources of the Commonwealth are managed in a sustainable manner to meet the economic, ecological, and social needs of Virginia in perpetuity. DOF is charged with protecting and developing healthy, sustainable forest resources that maintain functioning forest ecosystem and improve forest health, sustaining the supply of raw materials necessary for the economic growth of Virginias timber industry, and supporting the protection of water quality and sources of water supply within Virginias watersheds (Virginia Code §10.1-1101, 10.1-1105, and 10.1-1106).

12(b) Agency Findings. DOF staff has no comments on the proposed license renewal.

For additional information, contact DOF, Sarah Parmalee at (540) 347-6358 or sarah.parmalee@dof.virginia.gov.

13. Pollution Prevention. DEQ advocates that principles of pollution prevention be used in all construction projects as well as in facility operations. Effective siting, planning, and on-site Best Management Practices (BMPs) will help to ensure that environmental impacts are minimized. However, pollution prevention techniques also include decisions related to construction materials, design, and operational procedures that will facilitate the reduction of wastes at the source.

13(a) Recommendations. We have several pollution prevention recommendations that may be helpful in the construction of this project and in the operation of the facility:

Consider development of an effective Environmental Management System (EMS). An effective EMS will ensure that the Army is committed to minimizing its environmental impacts, setting environmental goals, and achieving improvements in its environmental performance. DEQ offers EMS development assistance and it recognizes facilities with effective Environmental Management Systems through its Virginia Environmental Excellence Program.

Consider environmental attributes when purchasing materials. For example, the extent of recycled material content, toxicity level, and amount of packaging should be considered and can be specified in purchasing contracts.

Consider contractors commitment to the environment (such as an EMS) when choosing contractors. Specifications regarding raw materials and construction practices can be included in contract documents and requests for proposals.

Choose sustainable materials and practices for infrastructure construction and design. These could include asphalt and concrete containing recycled materials, and integrated pest management in landscaping, among other things.

Integrate pollution prevention techniques into utility maintenance and operation, to include the following: inventory control (record-keeping and centralized storage for hazardous materials), product substitution (use of non-toxic cleaners), and source reduction (fixing leaks, energy-efficient HVAC and equipment).

Maintenance facilities should be designed with sufficient and suitable space to allow for effective inventory control and preventative maintenance.

18

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F DEQs Office of Pollution Prevention provides information and technical assistance relating to pollution prevention techniques and EMS. For more information, contact DEQs Office of Pollution Prevention, Meghann Quinn at (804) 698-4021 or meghann.quinn@deq.virginia.gov.

14. Energy Conservation. The facility should be planned and designed to comply with state and federal guidelines and industry standards for energy conservation and efficiency. The commonwealth encourages architectural and engineering designers to recognize and incorporate the energy, environmental, and sustainability concepts listed in the Leadership in Energy and Environmental Design (LEED) Green Building Rating System into the development and procurement of their projects.

The energy efficiency of the facility can be enhanced by maximizing the use of the following:

thermally-efficient building shell components (roof, wall, floor, windows, and insulation);

high efficiency heating, ventilation, air conditioning systems; high efficiency lighting systems and daylighting techniques; and energy-efficient appliances.

Contact the Department of Mines, Minerals and Energy, David Spears at (434) 951-6350 or david.spears@dmme.virginia.gov, for assistance in meeting this challenge.

15. Water Conservation. The following recommendations will result in reduced water use associated with the operation of the facility:

Grounds should be landscaped with hardy native plant species to conserve water as well as lessen the need to use fertilizers and pesticides.

Convert turf to low water-use landscaping such as drought resistant grass, plants, shrubs and trees.

Low-flow toilets should be installed in new facilities.

Consider installing low flow restrictors and aerators to faucets.

Improve irrigation practices by:

o upgrading sprinkler clock; water at night, if possible, to reduce evapotranspiration (lawns need only 1 inch of water per week, and do not need to be watered daily; overwatering causes 85% of turf problems);

o installing a rain shutoff device; and o collecting rainwater with a rain bucket or cistern system with drip lines.

Use new high-efficiency washers and dishwashers to reduce water usage by 30-50% per use.

Check for and repair leaks (toilets and faucets) during regular routine maintenance activities.

19

Subsequent License Renewal for NAPS Units 1 and 2 GEIS Supplement 7, Second Renewal, DEQ 21-109F Thank you for the opportunity to review the Generic Environmental Impact Statement, Supplement 7, Second Renewal for the Subsequent License Renewal of the North Anna Power Station Units 1 and 2 in Louisa County. Detailed comments of reviewing agencies are attached for your review. Please contact me at (804) 698-4204 or John Fisher at (804) 698-4339 for clarification of these comments.

Sincerely, Bettina Rayfield, Program Manager Environmental Impact Review and Long-Range Priorities Enclosures Ec: Amy Martin, DWR Robbie Rhur, DCR Tiffany Birge, VMRC Arleen Warren, VDH Keith Tignor, VDACS Terry Lasher, DOF Roger Kirchen, DHR Heather Williams, VDOT David Spears, VDE Curtis Brown, VDEM Christian Goodwin, Louisa County Christine Jacobs, Thomas Jefferson PDC John Pelchat, NRC 20

MEMORANDUM TO: John Fisher, DEQ/EIR Environmental Program Planner FROM: Carlos A. Martinez, Division of Land Protection & Revitalization Review Coordinator DATE: September 14, 2021 COPIES: Sanjay Thirunagari, Division of Land Protection & Revitalization Review Manager; file

SUBJECT:

Environmental Impact Review: 21-109F NRC Subsequent License Renewal for North Anna Power Station Units 1 and 2 in Louisa, Virginia.

The Division of Land Protection & Revitalization (DLPR) has completed its review of the Nuclear Regulatory Commissions August 27, 2021 EIR for NRC Subsequent License Renewal for North Anna Power Station Units 1 and 2 in Louisa, Virginia.

DLPR staff conducted a search (200 ft. radius) of the project area of solid and hazardous waste databases (including petroleum releases) to identify waste sites in close proximity to the project area. DLPR search did not identify any waste sites within the project area which might impact the project.

DLPR staff has reviewed the submittal and offers the following comments:

Hazardous Waste/RCRA Facilities - none in close proximity to the project area CERCLA Sites - none in close proximity to the project area Formerly Used Defense Sites (FUDS) - none in close proximity to the project area.

Solid Waste - none in close proximity to the project area Virginia Remediation Program (VRP) - none in close proximity to the project area Petroleum Releases - none in close proximity to the project area

PROJECT SPECIFIC COMMENTS None

GENERAL COMMENT

S Soil, Sediment, Groundwater, and Waste Management Any soil, sediment or groundwater that is suspected of contamination or wastes that are generated must be tested and disposed of in accordance with applicable Federal, State, and local laws and regulations. Some of the applicable state laws and regulations are: Virginia Waste Management Act, Code of Virginia Section 10.1-1400 et seq.; Virginia Hazardous Waste Management Regulations (VHWMR) (9VAC 20-60); Virginia Solid Waste Management Regulations (VSWMR) (9VAC 20-81); Virginia Regulations for the Transportation of Hazardous Materials (9VAC 20-110). Some of the applicable Federal laws and regulations are:

the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. Section 6901 et seq., and the applicable regulations contained in Title 40 of the Code of Federal Regulations; and the U.S.

Department of Transportation Rules for Transportation of Hazardous Materials, 49 CFR Part 107.

Asbestos and/or Lead-based Paint All structures being demolished/renovated/removed should be checked for asbestos-containing materials (ACM) and lead-based paint (LBP) prior to demolition. If ACM or LBP are found, in addition to the federal waste-related regulations mentioned above, State regulations 9VAC 20-81-620 for ACM and 9VAC 20-60-261 for LBP must be followed. Questions may be directed to Richard Doucette at the DEQs Northern Regional Office at (703) 583-3800.

Pollution Prevention - Reuse - Recycling Please note that DEQ encourages all construction projects and facilities to implement pollution prevention principles, including the reduction, reuse, and recycling of all solid wastes generated.

All generation of hazardous wastes should be minimized and handled appropriately.

If you have any questions or need further information, please contact Carlos A. Martinez by phone at (804) 698-4575 or email carlos.martinez@deq.virginia.gov.

Fisher, John <john.fisher@deq.virginia.gov>

Re: NEW PROJECT NRC Subsequent License Renewal for North Anna Power Station Units 1 & 2, DEQ 21-109F 1 message Holland, Benjamin <benjamin.holland@deq.virginia.gov> Fri, Sep 10, 2021 at 3:13 PM To: John Fisher <John.Fisher@deq.virginia.gov>

Cc: "Miller, Mark" <mark.miller@deq.virginia.gov>

Northern Regional Office comments regarding the Generic EIS, Supplement 7, Second Renewal for "Subsequent License Renewal for North Anna Power Stations Units 1 and 2," DEQ #21-109F, are as follows:

Land Protection Division - The project manager is reminded that if any solid or hazardous waste is generated/encountered during construction or operation, the project manager would follow applicable federal, state, and local regulations for their disposal.

Air Compliance/Permitting - The project should evaluate all potential sources of air emissions for the facility, including but not limited to boilers, generators, and cooling towers, and submit an application for a permit (or amendment) if necessary. The permit must be obtained prior to construction.

Other VPDES Permitting - The facility has an Individual VPDES Permit (VA0052451) and is subject to the requirements of Section 316(a) and Section 316(b) of the CWA. Any changes to the reactors themselves (e.g. uprates, turbine/blade replacements, etc.) that could have an impact on the thermal component of the discharge may need to be addressed through VPDES permitting for 316(a) purposes. Additionally, any work at the intakes or increase in flows related to reactor changes may need to be addressed through VPDES permitting for 316(b) purposes.

Fisher, John <john.fisher@deq.virginia.gov>

Re: NEW PROJECT NRC Subsequent License Renewal for North Anna Power Station Units 1 & 2, DEQ 21-109F 1 message Gavan, Lawrence <larry.gavan@deq.virginia.gov> Wed, Sep 1, 2021 at 10:27 AM To: "Fisher, John" <john.fisher@deq.virginia.gov>

(a) Agency Jurisdiction. The DEQ administers the nonpoint source pollution control enforceable policy of the VCP through the Virginia Erosion and Sediment Control Law and Regulations (VESCL&R) and Virginia Stormwater Management Law and Regulations (VSWML&R).

(b) Erosion and Sediment Control Plan. The Applicant is responsible for submitting a project-specific erosion and sediment control (ESC) plan to the locality in which the project is located for review and approval pursuant to the local ESC requirements, if the project involves a land-disturbing activity of 10,000 square feet or more (2,500 square feet or more in a Chesapeake Bay Preservation Area). Depending on local requirements the area of land disturbance requiring an ESC plan may be less. The ESC plan must be approved by the locality prior to any land-disturbing activity at the project site. All regulated land-disturbing activities associated with the project, including on and off site access roads, staging areas, borrow areas, stockpiles, and soil intentionally transported from the project must be covered by the project specific ESC plan. Local ESC program requirements must be requested through the locality. [

Reference:

Virginia Erosion and Sediment Control Law §62.1-44.15 et seq.; Virginia Erosion and Sediment Control Regulations 9VAC25-840-10 et seq.]

(c) Stormwater Management Plan. Depending on local requirements, a Stormwater Management (SWM) plan may be required. Local SWM program requirements must be requested through the locality. [

Reference:

Virginia Stormwater Management Act §62.1-44.15 et seq.;

Virginia Stormwater Management (VSMP) Permit Regulations 9VAC25-870-10 et seq.]

(d) General Permit for Stormwater Discharges from Construction Activities (VAR10). DEQ is responsible for the issuance, denial, revocation, termination and enforcement of the Virginia Stormwater Management Program (VSMP) General Permit for Stormwater Discharges from Construction Activities related to municipal separate storm sewer systems (MS4s) and construction activities for the control of stormwater discharges from MS4s and land disturbing activities under the Virginia Stormwater Management Program.

The operator or owner of a construction project involving land-disturbing activities equal to or greater than 1 acre is required to register for coverage under the General Permit for Discharges of Stormwater from Construction Activities and develop a project-specific stormwater pollution prevention plan (SWPPP). The SWPPP must be prepared prior to submission of the registration statement for coverage under the General Permit and the SWPPP must address water quality and quantity in accordance with the VSMP Permit Regulations.

(

Reference:

VSWML 62.1-44.15 et seq.; VSMP Permit Regulations 9VAC 25-880 et seq.)

Larry Gavan (804) 698-4040 larry.gavan@deq.virginia.gov

MEMORANDUM VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY WATER DIVISION TO: John Fisher FROM: Michelle Henicheck Office of Wetlands and Stream Protection DATE: September 10, 2021

SUBJECT:

Generic Environmental Impact Statement, Supplement 7, Second Renewal North Anna Power Station Units 1 & 2 Subsequent License Renewal Location: Louisa County, Spotsylvania County Project Number: DEQ #21-109F The DEQs Office of Wetlands and Stream Protection (OWSP) has reviewed the Generic Environmental Impact Statement (GEIS) concerning the above-referenced project. Dominion Energy Virginia (Dominion) submitted to the U. S. Nuclear Regulatory Commission (NRC) an application requesting subsequent license renewal for the North Anna Power Station, Units 1 and 2 (North Anna).

In its application, Dominion requested license renewal for a period of 20 years beyond the dates when the current operating licenses expire, to 2058 for North Anna Unit 1, and to 2060 for North Anna Unit

2. The NRC staffs preliminary recommendation is that the adverse environmental impacts of subsequent license renewal for North Anna are not so great that preserving the option of subsequent license renewal for energy-planning decision makers would be unreasonable.

Water Quality and Wetlands. Measures such as but not limited to Best Management Practices (BMPs) must be taken to avoid and minimize impacts to surface waters during construction activities, including potential water quality impacts resulting from construction site runoff. The disturbance of land and surface waters, which include wetlands, open water, and streams, may require prior approval by DEQ; the U.S. Army Corps of Engineers; the Virginia Marine Resources Commission (VMRC);

and/or local government wetlands boards (generally in the northern and piedmont regions of Virginia). The Army Corps of Engineers and DEQ work in conjunction to provide official confirmation of whether there are federal and/or state jurisdictional surface waters that may be impacted by the proposed project. VMRC provides its own review to determine its agency jurisdiction. Review of National Wetland Inventory maps or topographic maps for locating wetlands, open waters, or streams may not be sufficient; there may need to be a site-specific review by a qualified professional. If construction activities will occur in or along any streams (perennial, intermittent, or ephemeral), open water or wetlands, the applicant should contact the DEQ- VWP managers at our Northern Virginia Regional Office to determine the need for any permits prior to commencing work that could impact surface waters. DEQs permit need decisions neither replace nor supersede requirements set forth by other local, state, federal, and Tribal laws, nor eliminate the need to obtain additional permits, approvals, consultations, or authorizations as required by law before proposed activities may commence.

Recommendations Page 1 of 3

Based upon review of the information provided by the NRC, we offer the following recommendations:

1. Prior to commencing project work, all wetlands and streams within the project corridor should be field delineated and verified by the U.S. Army Corps of Engineers (the Corps), using accepted methods and procedures.

2. Wetland and stream impacts should be avoided and minimized to the maximum extent practicable. Stream impacts should be minimized or avoided by spanning the transmission line across each stream. No foundations should be placed within streambeds. Where access is required across a wetland, removable mats should be used to reduce compaction and rutting.

Towers should be placed avoid wetlands, wherever possible. To the extent where any footings must be installed in wetlands, each footing should occupy the minimum space necessary. When excavation for a structure is necessary in a wetland, excess spoil should not be disposed of in adjacent wetland areas unless authorized by a state or federal wetland permit.

3. If the scope of the project changes, additional review will be necessary by this office.

4. At a minimum, compensation for impacts to State Waters, if necessary, should be in accordance with all applicable state wetland regulations and wetland permit requirements, including the compensation for permanent conversion of forested wetlands to emergent wetlands.

5. Any temporary impacts to surface waters associated with this project should require restoration to pre-existing conditions.

6. No activity may substantially disrupt the movement of aquatic life indigenous to the water body, including those species, which normally migrate through the area, unless the primary purpose of the activity is to impound water. Culverts placed in streams must be installed to maintain low flow conditions. No activity may cause more than minimal adverse effect on navigation.

Furthermore the activity must not impede the passage of normal or expected high flows and the structure or discharge must withstand expected high flows.

7. Erosion and sedimentation controls should be designed in accordance with the Virginia Erosion and Sediment Control Handbook, Third Edition, 1992. These controls should be placed prior to clearing and grading and maintained in good working order to minimize impacts to state waters.

These controls should remain in place until the area is stabilized and should then be removed.

Any exposed slopes and streambanks should be stabilized immediately upon completion of work in each permitted area. All denuded areas should be properly stabilized in accordance with the Virginia Erosion and Sediment Control Handbook, Third Edition, 1992.

8. No machinery may enter surface waters, unless authorized by a Virginia Water Protection (VWP) permit.

9. Heavy equipment in temporarily impacted surface waters should be placed on mats, geotextile fabric, or other suitable material, to minimize soil disturbance to the maximum extent practicable.

Equipment and materials should be removed immediately upon completion of work.

10. Activities should be conducted in accordance with any Time-of-Year restriction(s) as recommended by the Department of Game and Inland Fisheries, the Department of Conservation and Recreation, or the Virginia Marine Resources Commission. The permittee should retain a copy of the agency correspondence concerning the Time-of-Year restriction(s), or the lack thereof, for the duration of the construction phase of the project.

11. All construction, construction access, and demolition activities associated with this project should be accomplished in a manner that minimizes construction materials or waste materials from Page 2 of 3

entering surface waters, unless authorized by a permit. Wet, excess, or waste concrete should be prohibited from entering surface waters.

12. Herbicides used in or around any surface water should be approved for aquatic use by the United States Environmental Protection Agency (EPA) or the U.S. Fish & Wildlife Service. These herbicides should be applied according to label directions by a licensed herbicide applicator. A non-petroleum based surfactant should be used in or around any surface waters.

13. Consider mitigating impacts to forested or converted wetlands by establishing new forested wetlands within the impacted watershed.

Page 3 of 3

Robert Farrell State Forester COMMONWEALTH of VIRGINIA Department of Forestry 900 Natural Resources Drive, Suite 800 Charlottesville, Virginia 22903 (434) 977-6555 Fax: (434) 296-2369 www.dof.virginia.gov Tuesday, August 31, 2021 John Fisher Department of Environmental Quality Office of Environmental Impact Review P.O. Box 1105 Richmond, VA 23218

Subject:

NRC Subsequent License Renewal for North Anna Power Station Units 1 & 2, DEQ 21-109F Dear John Thank you for the opportunity to provide comments for the License Renewal of the North Anna Power Station in Louisa County that was described in the letter from Valerie Fulcher from August 27th, 2021.

The Virginia Department of Forestry has no comments to provide on the proposed project.

Sincerely, Sarah Parmelee Forestland Conservation Coordinator NRC Subsequent License Renewal for North Anna Power Station Units 1 & 2, DEQ 21-109F

Fisher, John <john.fisher@deq.virginia.gov>

ESSLog# 41133_21-109F_NAPS Units 1 and 2 Relicensing_DWR_AEM20210927 1 message Martin, Amy <amy.martin@dwr.virginia.gov> Mon, Sep 27, 2021 at 3:59 PM To: John Fisher <john.fisher@deq.virginia.gov>

Cc: Stephen Reeser <steve.reeser@dwr.virginia.gov>, John Odenkirk <john.odenkirk@dwr.virginia.gov>, Michael Bednarski

<mike.bednarski@dwr.virginia.gov>

John, We have reviewed the information provided regarding relicensing of Units 1 and 2 and North Anna Power Station on Lake Anna. We do not currently document any listed wildlife or designated resources from the project area. We have no significant concerns with the relicensing of NAPS Units 1 and 2, however we do recommend the development of a Comprehensive Aquatic Vegetation Management Plan for Lake Anna.

We recommend that such a plan be developed and implemented in cooperation with DWR. This plan could address issues such as management of emergent vegetation, submerged aquatic vegetation, and algae (particularly harmful algal blooms) in a manner that results in a healthy aquatic ecosystem. We recommend coordination with John Odenkirk, DWR Regional Aquatic Biologist, at 504-899-4169 or John.Odenkirk@DWR.virginia.gov regarding cooperative development of such a plan for Lake Anna.

We do not have any significant concerns regarding the surface water intake (cooling water intake) from, and resulting thermal discharge to, Lake Anna, assuming no significant changes are proposed to their operation and all currently required monitoring continues to be performed. However, we will review the 316(b) assessment as part of the VPDES renewal package for this facility and will provide specific comments on this aspect of the project to DEQ VPDES staff once we have had the opportunity to review that information. We typically recommend that to protect resident aquatic species from impingement and entrainment, surface water intakes be fitted with a 1mm mesh screen and that the intake velocity not exceed 0.25 fps. In addition, to ensure continued access to necessary instream habitats by resident aquatic species, we recommend that the intake not withdraw more than 10% instantaneous flow (90%

flowby). We understand that these standards are not practicable or necessary at every surface water intake to ensure the protection of resources under our jurisdiction.

Thanks, Amy Amy Martin Environmental Services Biologist Manager, Wildlife Information she/her/hers P 804.367.2211 Department of Wildlife Resources CONSERVE. CONNECT. PROTECT.

A 7870 Villa Park Drive, P.O. Box 90778, Henrico, VA 23228 www.VirginiaWildlife.gov

Fisher, John <john.fisher@deq.virginia.gov>

Re: NEW PROJECT NRC Subsequent License Renewal for North Anna Power Station Units 1 & 2, DEQ 21-109F 1 message Warren, Arlene <arlene.warren@vdh.virginia.gov> Wed, Sep 1, 2021 at 11:25 AM To: John Fisher <john.fisher@deq.virginia.gov>

Cc: rr Environmental Impact Review <eir@deq.virginia.gov>

Project Name: Subsequent License Renewal for North Anna Power Station Units 1 and 2 Project #: 21-109F UPC #: N/A Location: Louisa County VDH - Office of Drinking Water has reviewed the above project. Below are our comments as they relate to proximity to public drinking water sources (groundwater wells, springs and surface water intakes). Potential impacts to public water distribution systems or sanitary sewage collection systems must be verified by the local utility.

The following public groundwater wells are located within a 1 mile radius of the project site (wells within a 1,000 foot radius are formatted in bold):

PWS ID Number City/County System Name Facility Name 2109600 LOUISA NORTH ANNA POWER STATION WELL 6 2109600 LOUISA NORTH ANNA POWER STATION WELL 7 2109600 LOUISA NORTH ANNA POWER STATION WELL 8 2109610 LOUISA NORTH ANNA NUCLEAR INFORMATION CENTER WELL There are no surface water intakes located within a 5-mile radius of the project site.

The project is within the watershed of the following public surface water sources:

PWS ID Number System Name Facility Name 4085398 HANOVER SUBURBAN WATER SYSTEM NORTH ANNA RWI Best Management Practices should be employed, including Erosion & Sedimentation Controls and Spill Prevention Controls & Countermeasures on the project site.

Well(s) within a 1,000 foot radius from the project site should be field marked and protected from accidental damage during construction.

The Virginia Department of Health - Office of Drinking Water appreciates the opportunity to provide comments. If you have any questions, please let me know.

Best Regards, Arlene Fields Warren GIS Program Support Technician

September 22, 2021 Department of Environmental Quality Office of Environmental Impact Review Attn: John Fisher 1111 East Main St Richmond, VA 23219 Re: EIS - Supp. 7, License Renewal, North Anna Power Station Units 1 and 2, DEQ #21-109F

Dear Mr. Fisher,

This will respond to the request for comments regarding the Environmental Impact Statement -

Supplement 7 for the Subsequent License Renewal for North Anna Power Station Units 1 and 2 (DEQ

1. 21-109F), prepared by the U.S. Nuclear Regulatory Commission, on behalf of Dominion Energy Virginia. Specifically, Dominion has proposed to renew the operating license for two nuclear generating units for an additional 20 years in Louisa County. We reviewed the project documents.

Since no new work is proposed over State-owned submerged land, the Virginia Marine Resources Commission (VMRC) has no objections to the renewal of the North Anna Power Station operating licenses for Units 1 and 2.

Please be advised that the VMRC, pursuant to §28.2-1200 et seq of the Code of Virginia, has jurisdiction over encroachments in, on, or over the beds of the bays, ocean, rivers, streams, or creeks which are the property of the Commonwealth. Accordingly, if any portion of the subject project involves encroachments channelward of ordinary high water along non-tidal, natural rivers and streams with a drainage area greater than 5-square miles, a permit may be required from our agency.

Please contact me at 757-247-2254 or by email at tiffany.birge@mrc.virginia.gov if you have questions. Thank you for the opportunity to comment.

Sincerely, Tiffany Birge Environmental Engineer TLB: HM

Rochelle Altholz Deputy Director of Administration and Finance Matthew J. Strickler Secretary of Natural and Historic Nathan Burrell Resources and Chief Resilience Deputy Director of Officer Government and Community Relations Clyde E. Cristman Darryl M. Glover Director Deputy Director of Dam Safety & Floodplain Management and Soil & Water Conservation Thomas L. Smith Deputy Director of Operations MEMORANDUM DATE: September 20, 2021 TO: John Fisher, DEQ FROM: Roberta Rhur, Environmental Impact Review Coordinator

SUBJECT:

DEQ 21-109F, North Anna Power Station Units 1 and 2 Subsequent License Renewal Division of Natural Heritage The Department of Conservation and Recreation's Division of Natural Heritage (DCR) has searched its Biotics Data System for occurrences of natural heritage resources from the area outlined on the submitted map. Natural heritage resources are defined as the habitat of rare, threatened, or endangered plant and animal species, unique or exemplary natural communities, and significant geologic formations.

According to the information currently in Biotics, natural heritage resources have not been documented within the submitted project boundary including a 100 foot buffer. The absence of data may indicate that the project area has not been surveyed, rather than confirm that the area lacks natural heritage resources. In addition, the project boundary does not intersect any of the predictive models identifying potential habitat for natural heritage resources.

There are no State Natural Area Preserves under DCRs jurisdiction in the project vicinity.

Under a Memorandum of Agreement established between the Virginia Department of Agriculture and Consumer Services (VDACS) and the DCR, DCR represents VDACS in comments regarding potential impacts on state-listed threatened and endangered plant and insect species. The current activity will not affect any documented state-listed plants or insects.

New and updated information is continually added to Biotics. Please re-submit project information and map for an update on this natural heritage information if the scope of the project changes and/or six months has passed before it is utilized.

The Virginia Department of Game and Inland Fisheries (VDGIF) maintains a database of wildlife locations, including threatened and endangered species, trout streams, and anadromous fish waters that may contain information not documented in this letter. Their database may be accessed from http://vafwis.org/fwis/ or contact Ernie Aschenbach at 804-367-2733 or Ernie.Aschenbach@dwr.virginia.gov.

600 East Main Street, 24th Floor l Richmond, Virginia 23219 l 804-786-6124 State Parks

• Soil and Water Conservation

• Outdoor Recreation Planning Natural Heritage

• Dam Safety and Floodplain Management

• Land Conservation

Division of Dam Safety and Floodplain Management Floodplain Management Program:

The National Flood Insurance Program (NFIP) is administered by the Federal Emergency Management Agency (FEMA), and communities who elect to participate in this voluntary program manage and enforce the program on the local level through that communitys local floodplain ordinance. Each local floodplain ordinance must comply with the minimum standards of the NFIP, outlined in 44 CFR 60.3; however, local communities may adopt more restrictive requirements in their local floodplain ordinance, such as regulating the 0.2% annual chance flood zone (Shaded X Zone).

All development within a Special Flood Hazard Area (SFHA), as shown on the localitys Flood Insurance Rate Map (FIRM), must be permitted and comply with the requirements of the local floodplain ordinance.

State Agency Projects Only Executive Order 45, signed by Governor Northam and effective on November 15, 2019, establishes mandatory standards for development of state-owned properties in Flood-Prone Areas, which include Special Flood Hazard Areas, Shaded X Zones, and the Sea Level Rise Inundation Area. These standards shall apply to all state agencies.

1. Development in Special Flood Hazard Areas and Shaded X Zones A. All development, including buildings, on state-owned property shall comply with the locally-adopted floodplain management ordinance of the community in which the state-owned property is located and any flood-related standards identified in the Virginia Uniform Statewide Building Code.

B. If any state-owned property is located in a community that does not participate in the NFIP, all development, including buildings, on such state-owned property shall comply with the NFIP requirements as defined in 44 CFR §§ 60.3, 60.4, and 60.5 and any flood-related standards identified in the Virginia Uniform Statewide Building Code.

(1) These projects shall be submitted to the Department of General Services (DGS), for review and approval.

(2) DGS shall not approve any project until the State NFIP Coordinator has reviewed and approved the application for NFIP compliance.

(3) DGS shall provide a written determination on project requests to the applicant and the State NFIP Coordinator. The State NFIP Coordinator shall maintain all documentation associated with the project in perpetuity.

C. No new state-owned buildings, or buildings constructed on state-owned property, shall be constructed, reconstructed, purchased, or acquired by the Commonwealth within a Special Flood Hazard Area or Shaded X Zone in any community unless a variance is granted by the Director of DGS, as outlined in this Order.

The following definitions are from Executive Order 45:

Development for NFIP purposes is defined in 44 CFR § 59.1 as Any man-made change to improved or unimproved real estate, including but not limited to buildings or other structures, mining, dredging, filling, grading, paving, excavation or drilling operations or storage of equipment or materials.

The Special Flood Hazard Area may also be referred to as the 1% annual chance floodplain or the 100-year floodplain, as identified on the effective Flood Insurance Rate Map and Flood Insurance Study. This includes the following flood zones: A, AO, AH, AE, A99, AR, AR/AE, AR/AO, AR/AH, AR/A, VO, VE, or V.

The Shaded X Zone may also be referred to as the 0.2% annual chance floodplain or the 500- year floodplain, as identified on the effective Flood Insurance Rate Map and Flood Insurance Study.

The Sea Level Rise Inundation Area referenced in this Order shall be mapped based on the National Oceanic and Atmospheric Administration Intermediate-High scenario curve for 2100, last updated in 2017, and is intended to denote the maximum inland boundary of anticipated sea level rise.

State agency shall mean all entities in the executive branch, including agencies, offices, authorities, commissions, departments, and all institutions of higher education.

Reconstructed means a building that has been substantially damaged or substantially improved, as defined by the NFIP and the Virginia Uniform Statewide Building Code.

Federal Agency Projects Only Projects conducted by federal agencies within the SFHA must comply with federal Executive Order 11988:

Floodplain Management.

DCRs Floodplain Management Program does not have regulatory authority for projects in the SFHA. The applicant/developer must contact the local floodplain administrator for an official floodplain determination and comply with the communitys local floodplain ordinance, including receiving a local permit. Failure to comply with the local floodplain ordinance could result in enforcement action from the locality. For state projects, DCR recommends that compliance documentation be provided prior to the project being funded.

For federal projects, the applicant/developer is encouraged reach out to the local floodplain administrator and comply with the communitys local floodplain ordinance.

To find flood zone information, use the Virginia Flood Risk Information System (VFRIS):

www.dcr.virginia.gov/vfris To find community NFIP participation and local floodplain administrator contact information, use DCRs Local Floodplain Management Directory: www.dcr.virginia.gov/dam-safety-and-floodplains/floodplain-directory The remaining DCR divisions have no comments regarding the scope of this project. Thank you for the opportunity to comment.

DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR PROGRAM COORDINATION ENVIRONMENTAL REVIEW COMMENTS APPLICABLE TO AIR QUALITY TO: John Fisher We thank OEIR for providing DEQ-AIR an opportunity to review the following project:

Document Type: Generic Environmental Impact Statement, Supplement 7, Second Renewal Project Sponsor: Nuclear Regulatory Commission Project

Title:

Subsequent License Renewal for North Anna Power Station Units 1 and 2 Location: Louisa County Project Number: DEQ #21-109F Accordingly, I am providing following comments for consideration.

PROJECT LOCATION: X OZONE ATTAINMENT AND EMISSION CONTROL AREA FOR NOX & VOC REGULATORY REQUIREMENTSMAY BE APPLICABLE TO: X CONSTRUCTION OPERATION STATE AIR POLLUTION CONTROL BOARD REGULATIONS THAT MAY APPLY:

1. 9 VAC 5-40-5200 C & 9 VAC 5-40-5220 E - STAGE I

2. 9 VAC 5-45-760 et seq. - Asphalt Paving operations

3. X 9 VAC 5-130 et seq. - Open Burning

4. X 9 VAC 5-50-60 et seq. Fugitive Dust Emissions

5. 9 VAC 5-50-130 et seq. - Odorous Emissions; Applicable to

6. 9 VAC 5-60-300 et seq. - Standards of Performance for Toxic Pollutants

7. 9 VAC 5-50-400 Subpart , Standards of Performance for New Stationary Sources, designates standards of performance for the

8. 9 VAC 5-80-1100 et seq. of the regulations - Permits for Stationary Sources

9. 9 VAC 5-80-1605 et seq. Of the regulations - Major or Modified Sources located in PSD areas. This rule may be applicable to the

10. 9 VAC 5-80-2000 et seq. of the regulations - New and modified sources located in non-attainment areas

11. 9 VAC 5-80-800 et seq. Of the regulations - State Operating Permits. This rule may be applicable to COMMENTS SPECIFIC TO THE PROJECT:

All precautions are necessary to restrict the emissions of volatile organic compounds (VOC) and oxides of nitrogen (NOX) if any construction is involved.

For any changes in permit or its extension, our Northern Regional Office maybe consulted.

(Kotur S. Narasimhan)

Office of Air Data Analysis DATE: August 27, 2021