ML21280A357
| ML21280A357 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/07/2021 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 21-306 | |
| Download: ML21280A357 (13) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 October 7, 2021 10 CFR 50 10 CFR 51 10 CFR 54 United States Nuclear Regulatory Commission Serial No.: 21-306 Attention: Document Control Desk NRA/SS: RO Washington, D.C. 20555-0001 Docket Nos.: 50-338/339 License Nos.: NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION (NAPS) UNITS 1 AND 2 COMMENTS ON DRAFT PLANT-SPECIFIC SUPPLEMENT 7, SECOND RENEWAL TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT FOR LICENSE RENEWAL OF NUCLEAR PLANTS REGARDING SUBSEQUENT LICENSE RENEWAL FOR FACILITY OPERATING LICENCES NPF-4 AND NPF-7
References:
- 1. Virginia Electric and Power Company (Dominion) letter to U. S. Nuclear Regulatory Commission (NRC), "North Anna Power Station, Units 1 and 2 - Application for Subsequent Renewed Operating Licenses," (ADAMS Package Accession No. ML20246G703), dated August 24, 2020 (Serial No.20-115)
- 2. Virginia Electric and Power Company (Dominion) letter to U. S. Nuclear Regulatory Commission (NRC), "North Anna Power Station (NAPS) Units 1 and 2, Subsequent License Renewal Application (SLRA), Response to Request for Confirmation of Information for the Environmental Review," (ADAMS Accession No. ML21042B904),
dated February 11, 2021 (Serial No.21-041)
- 3. Virginia Electric and Power Company (Dominion) letter to U. S. Nuclear Regulatory Commission (NRC), "North Anna Power Station Units 1 and 2, Subsequent License Renewal Application, Environmental Review, Response to Request for Additional Information," (ADAMS Accession No. ML21053A433), dated February 22, 2021 (Serial No.21-058)
- 4. U. S. Nuclear Regulatory Commission (NRC) letter to Virginia Electric and Power Company (Dominion), "Notice of Availability of the Draft Plant-Specific Supplement 7, Second Renewal to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2," (ADAMS Accession No. ML21222A197), dated August 24,2021
Serial No.: 21-306 Docket Nos.: 50-338/339 Page 2 of 6 In Reference 1, Virginia Electric and Power Company (Dominion) submitted an application for the subsequent license renewal of Renewed Facility Operating License Nos. NPF-4 and NPF-7 for North Anna Power Station (NAPS) Units 1 and 2, respectively.
An environmental report was provided as Appendix E of the NAPS subsequent license renewal application (SLRA).
In Reference 2, Dominion responded to the U.S. Nuclear Regulatory Commission's (NRC) request for confirmation of information from January 22, 2021, regarding the Environmental Review of the information contained in the NAPS SLRA. In Reference 3, Dominion responded to the NRC's request for additional information from January 29, 2021, regarding the Environmental Review of the information contained in the NAPS SLRA.
In Reference 4, the NRC informed Dominion of the availability of the, "Draft Plant-Specific Supplement 7, Second Renewal to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2," (DSEIS) and indicated that public comments would be accepted. to this letter provides Dominion's written comments related to the NAPS DSEIS.
If there are any questions regarding this submittal or if additional information is needed, please contact Mr. Paul Aitken at (804) 273-2818.
Sincerely, W-hO~-
Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Commitments made in this letter: None
Enclosure:
Dominion Comments on Draft North Anna Power Station Environmental Impact Statement
Serial No.: 21-306 Docket Nos.: 50-338/339 Page 3 of 6 cc:
U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Ms. Lois James NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Tam Tran NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. L. John Klos NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. G. Edward Miller NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 NRC Senior Resident Inspector North Anna Power Station Old Dominion Electric Cooperative Electronically Distributed State Health Commissioner Virginia Department of Health
Serial No.: 21-306 Docket Nos.: 50-338/339 Page 4 of 6 James Madison Building 7th Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Mr. David K. Paylor, Director Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Melanie D. Davenport, Director Water Permitting Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Bettina Rayfield, Manager Office of Environmental Impact Review Virginia Department of Environmental Quality P.O.Box1105 Richmond, VA 23218 Mr. Michael Dowd, Director Air Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Kathryn Perszyk Land Division Director Virginia Department of Environmental Quality 1111 East Main Street Suite 1400 Richmond, VA 23219 Mr. James Golden, Regional Director Virginia Department of Environmental Quality Piedmont Regional Office 4949-A Cox Road Glen Allen, VA 23060 Ms. Jewel Bronaugh, Commissioner Virginia Department of Agriculture & Consumer Services 102 Governor Street Richmond, Virginia 23219
Serial No.: 21-306 Docket Nos.: 50-338/339 Page 5 of 6 Mr. Jason Bulluck, Director Virginia Department of Conservation & Recreation Virginia Natural Heritage Program 600 East Main Street, 24th Floor Richmond, VA 23219 Mr. Ryan Brown, Executive Director Director's Office Virginia Department of Wildlife Resources P.O. Box 90778 Henrico, VA 23228 Ms. Julie Henderson, Director Virginia Department of Health Office of Environmental Health Services 109 Governor St, 5th Floor Richmond, VA 23129 Ms. Julie Langan, Director Virginia Department of Historic Resources State Historic Preservation Office 2801 Kensington Ave Richmond, VA 23221 Mr. Steven G. Bowman, Commissioner Virginia Marine Resources Commission 380 Fenwick Road Building 98 Ft. Monroe, VA 23651 Ms. Angel Deem, Director Virginia Department of Transportation Environmental Division 1401 East Broad St Richmond, VA 23219 Mr. Stephen Moret, President Virginia Economic Development Partnership 901 East Byrd St Richmond, VA 23219 Mr. William F. Stephens, Director Virginia State Corporation Commission Division of Public Utility Regulation 1300 East Main St, 4th Fl, Tyler Bldg Richmond, VA 23219
Serial No.: 21-306 Docket Nos.: 50-338/339 Page 6 of 6 Ms. Lauren Opett, Director Virginia Department of Emergency Management 9711 Farrar Ct North Chesterfield, VA 23236 Mr. Mark Stone, Chief Regional Coordinator Virginia Department of Emergency Management 13206 Lovers Lane Culpeper, VA 22701
Serial No.: 21-306 Docket Nos.: 50-338/339 Enclosure, Page 1 of 7 Enclosure DOMINION COMMENTS ON DRAFT NORTH ANNA POWER STATION ENVIRONMENTAL IMPACT STATEMENT Virginia Electric and Power Company (Dominion Energy Virginia)
Serial No.: 21-306 Docket Nos.: 50-338/339 Enclosure, Page 2 of 7 In a letter dated August 24, 2020 (ADAMS Package Accession No. ML20246G703),
Virginia Electric and Power Company (Dominion) submitted an application for the subsequent license renewal of Renewed Facility Operating License Nos. NPF-4 and NPF-7 for North Anna Power Station (NAPS) Units 1 and 2, respectively. An environmental report was provided as Appendix E of the NAPS subsequent license renewal application (SLRA).
In a letter dated August 24, 2021 (ADAMS Accession No. ML21222A197), the U.S.
Nuclear Regulatory Commission (NRC) informed Dominion of the availability of the, "Draft Plant-Specific Supplement 7, Second Renewal to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2," (DSEIS) and indicated that public comments would be accepted.
This enclosure provides Dominion's written comments related to the NAPS DSEIS.
Serial No.: 21-306 Docket Nos.: 50-338/339 Enclosure, Page 3 of 7 Dominion Comments on NAPS DSEIS No. Section Page Line Comment
- 1. 2.1 .2 2-3 1-2 DSEIS Section 2.1.2, page 2-3, lines 1-2 reflect the following :
"The nuclear reactors produce a nominal core power rating of 2,775 megawatts thermal (MWt)
(Dominion 2020b) ."
The value of 2,775 megawatts thermal appears to conflict with the information provided in Environmental Report Section E2.2.2.2.
Recommend revising to:
"The nuclear reactors produce a nominal core power rating of 2,940 megawatts thermal (MWt)
(Dominion 2020b) ."
- 2. 3.3.1 3-14 27-28 DSEIS Section 3.3.1, page 3-14, lines 27-28 reflect the following :
"The mean annual temperature from the North Anna onsite meteorological tower is 51 .7 °F (10.9 °C)
The value of 51 .7 °F (10.9 °C) appears to conflict with the information provided in the Environmental Report Table E3.3-4.
Recommend revising to:
"The mean annual temperature from the North Anna on site meteoroloqical tower is 57.2 °F (14 °C) ... "
Serial No.: 21-306 Docket Nos. : 50-338/339 Enclosure - Page 4 of 7 Dominion Comments on NAPS DSEIS No. Section Page Line Comment
- 3. 3.4.1 3-22 41-43 DSEIS Section 3.4.1, page 3-22, lines 41-43 reflect the following:
"The size and number of fractures and faults in the bedrock decrease with depth as the bedrock becomes less weathered and more structurally competent. "
The use of the term "faults" appears to conflict with the information provided in Environmental Report Section E3.6.2.1.
Recommend revising to:
"The size and number of joints and fractures in the bedrock decrease with depth as the bedrock becomes less weathered and more structurally competent."
- 4. 3.5.1.3 3-32 3 DSEIS Section 3.5.1.3, page 3-32, line 3 reflects the following:
"Most notably, North Anna's VDPES permit VA0004090 ... "
The cited permit number seems to conflict with the Environmental Report reference "Dominion . 2006a".
Recommend revising to:
"Most notably, North Anna's VDPES permit VA0052541 ... "
Serial No.: 21-306 Docket Nos.: 50-338/339 Enclosure - Page 5 of 7 Dominion Comments on NAPS DSEIS No. Section Page Line Comment
- 5. 3.5.2.2 3-37 1-8 DSEIS Section 3.5.2.2, page 3-37, lines 1-8 reflect the following:
"The North Anna site is in the Virginia Eastern Groundwater Management Area , which comprises all areas east of Interstate 95 (1-95). In this area, VDEQ requires Groundwater Withdrawal Permits to withdraw more than 300,000 gallons (1.1 million liters (L)) in any month. Permit applications for new groundwater withdrawals or for increases to existing groundwater withdrawals are evaluated for sustainability by considering the combined impacts from all existing lawful withdrawals. Focusing on water quality and supply, the annual State Water Resource Plan (VDEQ 2020d) summarizes water withdrawals and identifies water withdrawal trends Statewide and within the management area."
This statement seems to conflict with the Environmental Report Sections E3.1, E3.5 , and E3.6.
Recommend removal of these lines, as North Anna is not located in the Virginia Eastern Groundwater Manaqement Area.
- 6. 3.11.3 3-133 26-27 DSEIS Section 3.11.3, page 3-133, lines 26-27 reflect the following:
"The CDC, VDH, and Dominion report no occurrences of N. fowleri human infection in Lake Anna since the amoeba was identified in 1972."
The cited year (1972) seems to conflict with the Environmental Report Section E3.10.1.
Recommend revising to:
"The CDC, VDH, and Dominion report no occurrences of N. fowleri human infection in Lake Anna since the amoeba was identified in 1978."
Serial No.: 21-306 Docket Nos.: 50-338/339 Enclosure - Page 6 of 7 Dominion Comments on NAPS DSEIS No. Section Page Line Comment
- 7. F.3.2 F-8 24-28 DSEIS Section F.3.2 , page F-8, lines 24-28 reflect the following :
'The fire and seismic CDFs (3.9x10-5 per reactor-year and 6x10-6 per reactor-year, respectively) for North Anna as well as the sum of the two, were less than 5.9x10-5 per reactor-year. This value (5.9x10-
- 5) was the internal events mean value CDF for PWRs that the 2013 GEIS used to estimate probability-weighted , offsite consequences from airborne, surface water, and groundwater pathways, as well as the resulting economic impacts from such pathways. "
The cited values of 3.9E-5 and 6E-6 for North Anna fire and seismic core damage frequencies (CDFs),
respectively , appear to conflict with the Environmental Report Table E4.15-2. There is no fire CDF value provided in the Environmental Report and the seismic CDF referenced in the Environmental Report is 6E-5.
Recommend revising to:
"A combined fire and seismic external hazards value would be expected to be in the range of the internal event CDFs provided in the 2013 GEIS. Similarly, the estimated probability-weighted , offsite consequences from airborne, surface water, and groundwater pathways, as well as the resulting economic impacts from such pathways would be expected to be consistent with the 2013 GEIS ."
- 8. F.3.9 F-13 30 DSEIS Section F.3.9 , page F-13, Line 30 reflects the following :
".. . small North Anna LERF value of 2.49x10-6/year demonstrates that the risk of early and latent ... "
The value of 2.49x10-6/year seems to conflict with Environmental Report Table E4.15-2.
Recommend revising to:
" ... small North Anna LERF value of 1.72E-7/year demonstrates that the risk of early and latent ... "
Serial No.: 21-306 Docket Nos.: 50-338/339 Enclosure - Page 7 of 7 Dominion Comments on NAPS DSEIS No. Section Page Line Comment
- 9. F.5.4 F-20 27-29 OSEIS Section F.5.4, page F-20, lines 27-29 reflect the following:
"Of the results presented in Table E4.15-2, one case (case name labeled as "EOG") yielded an internal events LERF reduction of 57 percent. "
The use of the acronym "LERF [large early release frequency]" seems to conflict with the Environmental Report Section E4.15.4.3.
Recommend revising to:
"Of the results presented in Table E4.15-2, one case (case name labeled as "EOG") yielded an internal events LLRF reduction of 57 percent. "