ML22272A041

(NAPS) Units 1 & 2 - Subsequent License Renewal Application, Appendix E Environmental Report Supplement 1

ML22272A041
Person / Time
Site:	North Anna
Issue date:	09/28/2022
From:	James Holloway Dominion Energy Virginia, Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML22272A041 (98)

Text

VIRGIN IA ELECTRIC AND POWER COMPANY RICHMOND, VIRGIN IA 23261 September 28, 2022 10 CFR 50 10 CFR 51 10 CFR 54 United States Nuclear Regulatory Commission Serial No.: 22-211 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 SUBSEQUENT LICENSE RENEWAL APPLICATION FOR FACILITY OPERATING LICENCES NPF-4 AND NPF-7 APPENDIX E ENVIRONMENTAL REPORT SUPPLEMENT 1

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. NUREG-1437, Revision 1, dated June 2013, Final Generic Environmental Impact Statement for License Renewal of Nuclear Plants (ADAMS Accession Nos.

ML13106A241, ML13106A242, ML13106A244)

3. NUREG-1437, Supplement 7, dated August 31, 2021 -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, Draft for Comment (ADAMS Accession No. ML21228A084)

4. Commission Memorandum and Order CLl-22-02, dated February 24, 2022 (ADAMS Accession No. ML22055A496)

5. Commission Memorandum and Order CLl-22-03, dated February 24, 2022 (ADAMS Accession No. ML22055A554)

Serial No.: 22-211 Docket Nos.: 50-338/339 Page 2 of 7 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 (ER) was provided as Appendix E of the NAPS subsequent license renewal application (SLRA). Relying on the NRC's license renewal regulations and its Generic Environmental Impact Statement (GEIS) for license renewal (Reference 2), the NRC Staff published a draft site-specific Supplement to the GEIS for North Anna Unit 1 and 2, dated August 31, 2021 (Reference 3). Neither Dominion's ER nor the NRC Supplemental GEIS identified any new and significant information related to the SLRA for NAPS Units 1 and 2 that would change any impact finding in the NRC's GEIS for the subsequent period of extended operation or otherwise render the analyses in the GEIS inapplicable to an evaluation of the subsequent period of extended operation for NAPS Units 1 and 2.

Subsequently in Commission Order CLl-22-02, dated February 24, 2022 (Reference 4),

the Commission determined that the GEIS for license renewal does not specifically apply to SLRAs. In Commission Order CLl-22-03 (Reference 5), the Commission directed the NRC Staff to prepare a new GEIS applicable to subsequent license renewal but provided applicants the option of supplementing their ERs and proceeding with a site-specific approach. Accordingly, Dominion elected to complete a site-specific SLR environmental review of NAPS Units 1 and 2 operation, with SLRA ER Supplement 1 (enclosed) addressing each previously generically addressed issue on a site-specific basis.

In addition to the information presented in the enclosed supplement, Dominion has performed a review to identify any new and significant information relevant to the other environmental issues discussed in Chapter 4 of the previously submitted ER. Dominion has identified no new and significant information since the issuance of the Draft Supplemental Environmental Impact Statement that could alter the NRC's conclusions on those issues, which are materially consistent with those presented in the previously submitted ER.

Serial No.: 22-211 Docket Nos.: 50-338/339 Page 3 of 7 If there are any questions regarding this submittal or if additional information is needed, please contact Mr. Paul Aitken at (804) 273-2818.

Sincerely, r

James E. Holloway Vice President- Nuclear Engineering and Fleet Support COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by James E. Holloway, who is Vice President - Nuclear Engineering and Fleet Support of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document on behalf of that company, and that the statements in the document are true to the best of his knowledge and belief.

?Qfh Acknowledged before me this _"-_Oday of Seytlerober , 2022.

My Commission Expires: 1llt\\ACtn::t B 1, 202.1../ .

Kathryn Hill Barret Notary Public Commonwealth of Virginia Reg.No. 7905256 My Commission Expires January 31, 2024

~*7-1-~Notary Public Commitments made in this letter: None

Enclosure:

Subsequent License Renewal Application, Appendix E Environmental Report Supplement 1

Serial No.: 22-211 Docket Nos.: 50-338/339 Page 4 of 7 cc:

U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. Emmanuel Sayoc NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 011 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Ms. Lauren K. Gibson NRC Branch Chief U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 011 E11 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Tam Tran NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 011 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 E3 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 E3 11555 Rockville Pike Rockville, Maryland 20852-2738

Serial No.: 22-211 Docket Nos.: 50-338/339 Page 5 of 7 NRC Senior Resident Inspector North Anna Power Station Old Dominion Electric Cooperative Electronically Distributed State Health Commissioner Virginia Department of Health James Madison Building - 7th Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Mr. Mike Rolbard, Director Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Melanie D. Davenport, Director Water Permitting Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Bettina Rayfield, Manager Office of Environmental Impact Review Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Mr. Michael Dowd, Director Air Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Kathryn Perszyk Land Division Director Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Mr. James Golden, Regional Director Virginia Department of Environmental Quality Piedmont Regional Office 4949-A Cox Road Glen Allen, VA 23060

Serial No.: 22-211 Docket Nos.: 50-338/339 Page 6 of 7 Mr. Joseph Guthrie, Commissioner Virginia Department of Agriculture & Consumer Services 102 Governor Street Richmond, Virginia 23219 Mr. Jason Bulluck, Director Virginia Department of Conservation & Recreation Virginia Natural Heritage Program 600 East Main Street, 24th Floor Richmond, VA 23219 Mr. Ryan Brown, Executive Director Director's Office Virginia Department of Wildlife Resources P.O. Box 90778 Henrico, VA 23228 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. Jamie Green, Commissioner Virginia Marine Resources Commission 380 Fenwick Road Building 96 Ft. Monroe, VA 23651 Ms. Angel Deem, Director Virginia Department of Transportation Environmental Division 1401 East Broad St Richmond, VA 23219 Mr. Jason El Koubi, President Virginia Economic Development Partnership 901 East Byrd St Richmond, VA 23219

Serial No.: 22-211 Docket Nos.: 50-338/339 Page 7 of 7 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 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.: 22-211 Docket Nos.: 50-338/339 Enclosure Enclosure SUBSEQUENT LICENSE RENEWAL APPLICATION, APPENDIX E ENVIRONMENTAL REPORT SUPPLEMENT 1 Virginia Electric and Power Company (Dominion Energy Virginia)

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 1 of 90 E4.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION AND MITIGATING ACTIONS Licensees are required by the Code of Federal Regulations (CFR), specifically 10 CFR 51.53(c)(1), to submit with its application a separate document entitled "Applicant's Environmental ReportOperating License Renewal Stage. The regulations of the Nuclear Regulatory Commission (NRC) at 10 CFR Part 51, which implement Section 102(2) of the National Environmental Policy Act of 1969 (NEPA) as amended, include requirements for applicants to provide information as may be useful in aiding the NRC staff in complying with NEPA. As part of its review, the NRC staff is required to prepare a site-specific Supplemental Environmental Impact Statement (SEIS). Review guidance for the staff is provided in U.S.

Nuclear Regulatory Commission Technical Report Designation (NUREG) 1555, Supplement 1, Revision 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants:

Supplement 1 - Operating License Renewal.

In the 2013 GEIS, the NRC identified and analyzed 78 environmental issues that it considers to be associated with nuclear power plant license renewal (LR). The NRC also codified conclusions for those issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. Twelve of those issues are not applicable to North Anna Power Station (NAPS) because they result from design or operational features that do not exist at the facility.

In Nuclear Regulatory Commission Memorandum and Order (CLI) 22-2 and 22-3, the Commission determined that those 2013 NUREG-1437, Generic Environmental Impact Statements for License Renewal of Nuclear Plants (GEIS) analyses and codified conclusions were applicable to initial license renewals, and that additional site-specific analyses for the subsequent period of extended operation (PEO) (60 to 80 years) are needed to support environmental reviews in subsequent license renewal (SLR) proceedings. For issues that are applicable to NAPS, the discussion below incorporates the corresponding generic analysis from the 2013 GEIS, considers whether that analysis materially differs from initial license renewal to SLR, and supplements that analysis with a further additional site-specific analysis for the subsequent PEO. The additional site-specific analysis for the subsequent PEO considers whether there is any new site-specific information not considered in the GEIS that would lead to a substantially different conclusion of the environmental consequences of license renewal than previously considered, such as 1) an environmental impact finding different from that codified in Table B-1, or 2) any new activity or aspect associated with NAPS that can act upon the environment in a manner, scope, or intensity not considered in the GEIS. Together, those analyses satisfy the requirements of 10 CFR 51.53(c)(2) and 51.45.

With the exception of threatened and endangered species/essential fish habitats (EFH), historic and cultural resources, environmental justice, and electromagnetic fields (EMFs), NAPS has Page-E-4-1

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 2 of 90 identified the significance of the impacts associated with each issue as SMALL, MODERATE, or LARGE, consistent with the criteria that the NRC established in 10 CFR 51, Subpart A, Appendix B, Table B-1, Footnote 3 as follows:

SMALL: Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. For the purposes of assessing radiological impacts, the NRC has concluded that those impacts that do not exceed permissible levels in the NRC's regulations are considered small.

MODERATE: Environmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of the resource.

LARGE: Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource. For issues where probability is a key consideration (i.e., accident consequences), probability was a factor in determining significance.

Consistent with NRC guidance, NAPS identified the significance of the impacts for the remaining issues as follows:

• For threatened and endangered species (Endangered Species Act [ESA]), the significance of the effects from license renewal can be characterized based on a determination of whether continued nuclear power plant operations including refurbishment (1) would have no effect on federally listed species; (2) are not likely to adversely affect federally listed species; (3) are likely to adversely affect federally listed species; or (4) are likely to jeopardize a federally listed species or adversely modify designated critical habitat. For EFH (Magnuson Stevens Fishery Conservation and Management Act) the significance of effects from license renewal can be characterized based on a determination of whether continued nuclear power plant operations, including refurbishment, would have (1) no adverse impact; (2) minimal adverse impact; or (3) substantial adverse impact to the essential habitat of federally managed fish populations.

• For historic and cultural resources (National Historic Preservation Act), the significance of the effects from license renewal can be characterized based on a determination that (1) no historic properties are present (no effect); (2) historic properties are present, but not adversely affected (no adverse effect); or (3) historic properties are adversely affected (adverse effect).

• For environmental justice, impacts would be based on disproportionately high and adverse human health and environmental effects on minority and low-income populations.

• The issue of chronic effects of EMFs remains uncategorized because there is no national scientific consensus on the potential impacts from chronic exposure to EMFs.

(NRC 2013)

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 3 of 90 In accordance with NEPA practice, NAPS considered ongoing and potential additional mitigation in proportion to the significance of the impact to be addressed (i.e., impacts that are SMALL receive less mitigation consideration than impacts that are LARGE).

E4.0.1 CATEGORY 1 LICENSE RENEWAL ISSUES The review and analysis in Chapter 4 generally follows NRC Regulatory Guide 4.2, Supplement 1, Revision 1 with certain modifications that are consistent with the Commissions ruling in CLI-22-2 and CLI-22-3, as summarized below.

• Issue: Title of the issue.

• Generic Analysis for Initial License Renewal: A background excerpt from the applicable section of the GEIS. The specific section of the GEIS is referenced for the convenience of the reader.

• Site-Specific Analysis for NAPS SLR: An analysis of the environmental impact, inclusive of a new and significant information review. If an issue is not applicable, the analysis lists the explanation. The analysis section also provides a summary conclusion of the environmental impacts, and identifies as applicable, either ongoing or additional planned mitigation measures to reduce adverse impacts.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 4 of 90 Table E4.0-1, below, provides a list of the applicable environmental issues that Dominion evaluated as part of this supplement.

Table E4.0-1 Environmental Resource Issues Evaluated for NAPS Section New or Existing Number Issue Number Section 1 Onsite Land Uses E4.1.1 Existing 2 Offsite Land Uses E4.1.2 Existing 4 Aesthetic Impacts E4.1.3 Existing 5 Air Quality Impacts (all plants) E4.2.1 Existing 6 Air Quality Effects of Transmission Lines E4.2.2 Existing 7 Noise (Noise Impacts) E4.3 Existing 8 Geology and Soils E4.4 Existing Surface Water Use and Quality (Non-9 E4.5.6 New Cooling System Impacts)

Altered Current Patterns and Intake and 10 E4.5.7 New Discharge Structures 12 Altered Thermal Stratification of Lakes E4.5.8 New Scouring Caused by Discharged Cooling 13 E4.5.9 New Water Discharge of Metals in Cooling System 14 E4.5.10 New Effluent Discharge of Biocides, Sanitary Wastes, 15 E4.5.11 New and Minor Chemical Spills Surface Water Use Conflicts (Plants with 16 E4.5.12 New Once-Through Cooling Systems)

Effects of Dredging on Surface Water 17 E4.5.13 New Quality Temperature Effects on Sediment 18 E4.5.14 New Transport Capacity Groundwater Contamination and Use 19 E4.5.15 New (Non-Cooling System Impacts)

Groundwater Use Conflicts (Plants that 20 Withdraw Less than 100 Gallons per E4.5.16 New Minute)

Groundwater Quality Degradation (Plants 22 E4.5.17 New with Cooling Ponds in Salt Marshes)

Exposure of Terrestrial Organisms to 23 E4.6.7 New Radionuclides Cooling System Impacts on Terrestrial 24 Resources (Plants with Once-Through E4.6.8 New Cooling Systems or Cooling Ponds)

Bird Collisions with Plant Structures and 26 E4.6.9 New Transmission Lines Transmission Line Right-of-way 27 Management Impacts on Terrestrial E4.6.10 New Resources Page-E-4-4

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 5 of 90 Table E4.0-1 Environmental Resource Issues Evaluated for NAPS Section New or Existing Number Issue Number Section Electromagnetic Fields on Flora and 28 Fauna (Plants, Agricultural Crops, E4.6.11 New Honeybees, Wildlife, Livestock)

Entrainment of Phytoplankton and 30 E4.6.12 New Zooplankton Infrequently Reported Thermal Impacts 32 E4.6.13 New (All Plants)

Effects of Cooling Water Discharge on 33 Dissolved Oxygen, Gas Supersaturation, E4.6.14 New and Eutrophication Effects of Non-Radiological Contaminants 34 E4.6.15 New on Aquatic Organisms Exposure of Aquatic Organisms to 35 E4.6.16 New Radionuclides Effects of Dredging on Aquatic 36 E4.6.17 New Organisms Effects on Aquatic Resources (Non-37 E4.6.18 New cooling System Impacts)

Impacts of Transmission Line Right-of-38 E4.6.19 New way Management on Aquatic Resources Losses from Predation, Parasitism, and 39 Disease Among Organisms Exposed to E4.6.20 New Sub-lethal Stresses Employment and Income, Recreation and 40 E4.8.1 Existing Tourism 41 Tax Revenues E4.8.2 Existing 42 Community Services and Education E4.8.3 Existing 43 Population and Housing E4.8.4 Existing 44 Transportation E4.8.5 Existing 45 Radiation Exposures to the Public E4.9.3 New 46 Radiation Exposures to Plant Workers E4.9.4 New 47 Human Health Impact from Chemicals E4.9.5 New 48 Microbiological Hazards to Plant Workers E4.9.6 New 49 Physical Occupational Hazards E4.9.7 New 50 Design-Basis Accidents E4.15.1 Existing 51 Low-Level Waste Storage and Disposal E4.11.1 Existing 52 Onsite Storage of Spent Nuclear Fuel E4.11.2 Existing Offsite Radiological Impacts of Spent 53 Nuclear Fuel and High-Level Waste E4.11.3 Existing Disposal 54 Mixed-Waste Storage and Disposal E4.11.4 Existing Nonradioactive Waste Storage and 55 E4.11.5 Existing Disposal Page-E-4-5

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 6 of 90 Table E4.0-1 Environmental Resource Issues Evaluated for NAPS Section New or Existing Number Issue Number Section Offsite Radiological ImpactsIndividual 56 Impacts from Other than the Disposal of E4.13.1 Existing Spent Fuel and High-Level Waste Offsite Radiological ImpactsCollective Existing 57 Impacts from Other than the Disposal of E4.13.2 Spent Fuel and High-Level Waste Non-Radiological Impacts of the Uranium Existing 58 E4.13.3 Fuel Cycle Existing 59 Transportation E4.13.4 Termination of Plant Operations and Existing 60 E4.14 Decommissioning Page-E-4-6

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 7 of 90 E4.1.1 ONSITE LAND USE - ISSUE 1, TABLE E4.0-1 E4.1.1.1 Generic Analysis for Initial License Renewal [GEIS Section 4.2.1.1]

Operational activities at a nuclear power plant during the license renewal term would be similar to those occurring during the current license term. Generally, onsite land use conditions would remain unchanged. However, additional spent nuclear fuel (SNF) and low-level radioactive waste (LLRW) generated during the license renewal term could require the construction of new or expansion of existing onsite storage facilities. Should additional storage facilities be required, this action would be addressed in separate license reviews conducted by the NRC. Refurbishment activities, such as steam generator and vessel head replacement, have not permanently changed onsite land use conditions.

E4.1.1.2 Site-Specific Analysis for NAPS SLR NAPS is located on the border of Louisa and Spotsylvania counties in northeastern Virginia, on a peninsula along the southern shore of Lake Anna. The site encompasses approximately 1,803 acres, of which 760 acres are covered by water. Forest is the predominant onsite land use/land cover, followed by open water and developed areas. No license renewal-related refurbishment activities have been identified. (Dominion. 2020a) In the response to NRC request for additional information letter dated February 22, 2021, four reasonably foreseeable projects and/or actions were identified, including a NAPS Wastewater Treatment Plant replacement project, the installation of Osprey Nest Platforms, a Cyber Security Test Facility construction project, and the construction of a new Main Generator Storage Building (Dominion. 2021a). Of the four projects, only the Osprey Nest Platform installations have been completed. The Cyber Security Test Facility and NAPS Wastewater Treatment Plant are currently in the design and development phase, and the Main Generator Storage Building project has been suspended with a target implementation year of 2028 for Unit 1 and 2031 for Unit 2. None of the projects have or would require significant changes to existing land uses. In addition, no license renewal-related construction activities have been identified. Continued operation of NAPS during the proposed SLR term is not expected to change and no refurbishment activities are anticipated; therefore, no changes in onsite land use are projected.

Dominion finds that impacts to onsite land uses for the proposed SLR term would be SMALL.

Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted environmental report (ER)

(Dominion. 2020a).

E4.1.2 OFFSITE LAND USE - ISSUE 2, TABLE E4.0-1 E4.1.2.1 Generic Analysis for Initial License Renewal [GEIS Section 4.2.1.1]

The impacts of continued plant operations during the license renewal term and refurbishment on offsite land use were evaluated separately in the 1996 GEIS. It was predicted that impacts associated with refurbishment and changes in population and tax revenue on offsite land use Page-E-4-7

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 8 of 90 could range from SMALL to MODERATE. SLR reviews, however, have shown no power plant-related population changes or significant tax revenue changes due to license renewal. Non-outage employment levels at nuclear power plants have remained relatively unchanged or have decreased. With no increase in the number of workers, there has been no increase in housing, infrastructure, or demand for services beyond what has already occurred. Operational activities during the license renewal term would be similar to those occurring during the current license term and would not affect offsite land use beyond what has already been affected.

For plants that have the potential to impact a coastal zone or coastal watershed, as defined by each state participating in the national Coastal Zone Management Program (CZMP), applicants for license renewal must submit to the affected state a certification that the proposed license renewal is consistent with the state CZMP. Applicants must coordinate with the state agency that manages the state CZMP to obtain a determination that the proposed nuclear plant license renewal would be consistent with the state program.

E4.1.2.2 Site-Specific Analysis for NAPS SLR There are no plans to add workers to support plant operations during the SLR operating term and no significant changes to tax payments are anticipated (see Section E4.8.2.24). No license renewal-related refurbishment activities have been identified. (Dominion. 2020a) Therefore, no changes in offsite land use during the proposed SLR operating term are anticipated.

NAPS and Louisa County are not located in a coastal zone under the national CZMP, but Spotsylvania County and portions of Lake Anna within Spotsylvania County are included in the Virginia coastal zone. Therefore, Dominion was required to develop a Coastal Zone Management Act certification to the state for the proposed NAPS SLR project. Dominion received concurrence from the Virginia Department of Environmental Quality (VDEQ) on December 23, 2019, that the NAPS project is consistent with the Virginia Coastal Zone Management Program (CZMP) and therefore has fulfilled the regulatory requirement to certify that the NAPS SLR project would be consistent with the states federally approved CZMP for the Virginia coastal zone. (Dominion.

2020a) The certification requires that Dominion obtain and maintain compliance with all federal, state, and local applicable laws and permits.

Dominion finds that impacts to offsite land uses for the proposed SLR term would be SMALL.

Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.1.3 AESTHETICS IMPACTS - ISSUE 4, TABLE E4.0-1 E4.1.3.1 Generic Analysis for Initial License Renewal [GEIS Section 4.2.1.2]

A case study performed for the 1996 GEIS found a limited number of situations where nuclear power plants had a negative effect on visual resources. Negative perceptions were based on aesthetic considerations (for instance, the plant is out of character or scale with the community or Page-E-4-8

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 9 of 90 the viewshed), physical environmental concerns, safety and perceived risk issues, an anti-plant attitude, or an anti-nuclear orientation. It is believed that these negative perceptions would persist regardless of mitigation measures.

In addition, the visual appearance of transmission lines is not expected to change during the license renewal term. After the containment building and cooling towers, transmission line towers are probably the most frequently observed structure associated with nuclear power plants.

Transmission lines from nuclear power plants are generally indistinguishable from those from other power plants. Because electrical transmission lines are common throughout the United States, they are generally perceived with less prejudice than the nuclear power plant itself. Also, the visual impact of transmission lines tends to wear off when viewed repeatedly.

E4.1.3.2 Site-Specific Analysis for NAPS SLR The NAPS plant is located on the south side of Lake Anna in a rural area surrounded by forest.

Predominant visual features at NAPS are the reactor containment buildings, the turbine buildings, and transmission lines. Because of the wooded setting and remote location, NAPS would have minimal visual impact on neighboring properties or from the viewpoint of Lake Anna. No refurbishment or construction activities have been identified that would change the aesthetics of the NAPS facility during the proposed SLR operating term. (Dominion. 2020a) Therefore, no changes in visual resources during the proposed SLR operating term are anticipated.

Dominion finds that impacts to aesthetics for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.2.1 AIR QUALITY IMPACTS (ALL PLANTS) - ISSUE 5, TABLE E4.0-1 E4.2.1.1 Generic Analysis for Initial License Renewal [GEIS Section 4.3.1.1]

Impacts on air quality during normal plant operations can result from operations of fossil fuel-fired equipment needed for various plant functions. Each licensed plant typically employs emergency diesel generators for use as a backup power source. Emergency diesel generators and fire pumps typically require state or local operating permits. These diesel generators are typically tested once a month with several test burns of various durations (e.g., one to several hours).

In addition to these maintenance tests, longer-running endurance tests are typically conducted at each plant. Each generator is typically tested for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on a staggered test schedule (e.g.,

once every refueling outage). In addition to the emergency diesel generators, fossil fuel (i.e.,

diesel-, oil-, or natural-gas-fired) boilers are used primarily for evaporator heating, plant space heating, and/or feedwater purification. These units typically operate at a variable load on a continuous basis throughout the year unless end use is restricted to one application, such as space heating. The utility boilers at commercial plants are relatively small when compared with most industrial boilers and are typically regulated through state-level operating permits.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 10 of 90 As presented in Section 3.3 of the GEIS, cooling tower drift can increase downwind particulate matter concentrations, impair visibility, ice roadways, cause drift deposition, and damage vegetation and painted surfaces. Thus, although there is the potential for some air quality impacts to occur as a result of equipment and cooling tower operations, even in the worst-case situation (Hope Creek), the impacts have been SMALL, and licensees would be required to operate within state permit requirements.

In the 1996 GEIS, the NRC concluded that the impacts from plant refurbishment associated with license renewal on air quality could range from SMALL to LARGE, although these impacts were expected to be SMALL for most plants. However, findings from license renewal SEISs published since the 1996 GEIS have shown that refurbishment activities, such as steam generator and vessel head replacement, have not required the large numbers of workers and months of time, as well as the degree of land disturbance that was conservatively estimated in the 1996 GEIS.

Presumed air pollutant emissions, including levels of fugitive dust, have therefore not been realized.

E4.2.1.2 Site-Specific Analysis for NAPS SLR No license renewal-related refurbishment activities have been identified (Dominion. 2020a). As stated in the GEIS, best management practices (BMPs), including fugitive dust controls and the imposition of permit conditions in VDEQ air emissions permits, would ensure conformance with applicable state implementation plans. Louisa County is in attainment with the national ambient air quality standards (NAAQS) for all criteria air pollutants. Louisa County remains in attainment with the NAAQS for all criteria air pollutants as of June 2022 (EPA. 2022).

No future upgrade or replacement activities (e.g., diesel generators, diesel pumps) that would increase or decrease air emissions over the SLR operating term were identified as necessary for plant operations. (Dominion. 2020a)

NAPS is permitted under a 2019 air permit No. 40726 (Dominion. 2020a). A permitting plan is in place so that new emission units would be evaluated for their potential emissions to verify whether permitting requirements are triggered. Dominion is not aware of any issues that will significantly change the permit conditions listed in the current air permit.

NAPS anticipates the addition of new emission units that can be considered insignificant under Virginia Administrative Code VAC5-80-720(C). Emergency pumps and generators described in VAC5-80-720(C) are limited to 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> per year under Virginia Administrative Code VAC5 1105(B). For informational purposes, these units are expected to be listed in the unpermitted Equipment List in the sites air emissions permit (Dominion. 2020a).

The NAPS air permit contains conditions established by the VDEQ to protect Virginia's ambient air quality standards and ensure impacts are maintained at acceptable levels. Appropriate permit conditions would regulate any future NAPS activities that may increase air pollutants or threaten the attainment status of Louisa County. (Dominion. 2020a)

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 11 of 90 Dominion finds that impacts to air quality for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.2.2 AIR QUALITY EFFECTS OF TRANSMISSION LINES - ISSUE 6, TABLE E4.0-1 E4.2.2.1 Generic Analysis for Initial License Renewal [GEIS Section 4.3.1.1]

Small amounts of ozone and substantially smaller amounts of oxides of nitrogen are produced by transmission lines during corona, a phenomenon that occurs when air ionizes near isolated irregularities on the conductor surface such as abrasions, dust particles, raindrops, and insects.

Several studies have quantified the amount of ozone generated and concluded that the amount produced by even the largest lines in operation (765-kilovolts [kV]) is insignificant.

Ozone concentrations generated by transmission lines are therefore too low to cause any significant effects. The minute amounts of oxides of nitrogen produced are similarly insignificant.

A finding of SMALL significance for transmission lines within this scope of review is supported by the evidence that production of ozone and oxides of nitrogen are insignificant and does not measurably contribute to ambient levels of those gases.

E4.2.2.2 Site-Specific Analysis for NAPS SLR The NRC determined through several studies that the amount of ozone generated by even the largest lines in operation (765-kV) would be insignificant (NRC. 2013, Section 4.3.1.1). The NAPS in-scope transmission lines are 34.5-kV and 500-kV, far less than 765-kV. Further, the NAPS in-scope transmission lines are confined to the site. Therefore, the production of ozone and oxides of nitrogen from in-scope transmission lines at NAPS would be de minimis. (Dominion. 2020a)

Dominion finds that impacts to air quality effects for the proposed SLR term are SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.3 NOISE (NOISE IMPACTS) - ISSUE 7, TABLE E4.0-1 E4.3.1 GENERIC ANALYSIS FOR INITIAL LICENSE RENEWAL [GEIS SECTION 4.3.1.2]

Major sources of noise at operating nuclear power plants are cooling towers, turbines, transformers, large pumps, and cooling water system motors. Nuclear plant operations have not changed appreciably with time, and no change in noise levels or noise-related impacts is expected during the license renewal term. Since no change is expected in the amount of noise generated Page-E-4-11

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 12 of 90 during the license renewal term, the only issue of concern is the number of people now living close to the nuclear power plant who are exposed to operational noise.

Given the industrial nature of the power plant and the number of years of plant operation, noise from a nuclear plant is generally nothing more than a continuous minor nuisance. However, noise levels may sometimes exceed the 55 A-weighted decibels (dBA) level that the U.S. Environmental Protection Agency (EPA) uses as a threshold level to protect against excess noise during outdoor activities. However, according to the EPA, this threshold does not constitute a standard, specification, or regulation, but was intended to provide a basis for state and local governments establishing noise standards. Nevertheless, noise levels at the site boundary are expected to remain well below regulatory standards for offsite residents.

Noise would also be generated by construction-related activities and equipment used during refurbishment. However, this noise would occur for relatively short periods of time (several weeks) and is not expected to be distinguishable from other operational noises at the site boundary nor create an adverse impact on nearby residents.

E4.3.2 SITE-SPECIFIC ANALYSIS FOR NAPS SLR Industrial background noise at NAPS is generally from turbine generators, transformers, loudspeakers, transmission lines, firing range, and the main steam safety valves (Dominion.

2020a).

The loudest sound emitted from NAPS plant systems is from a limited duration steam release by the main steam safety valves or steam generator power-operated relief valves. The ambient sound levels in and immediately around plant structures are generally less than 100dBA, aside from the infrequent use of main steam safety valves to relieve steam pressure. (Dominion. 2020a, Section E3.4)

NAPS is located in a rural area and meets the buffer zone distance of no less than 100 feet, as set by Louisa Countys zoning ordinance for industrial land use (LC. 2022,86-123 Land Development Regulations). Land uses are not anticipated to change during the SLR term, and it is unlikely that noise levels from NAPS would affect offsite sensitive receptors (e.g., residences, schools, churches, etc.) (Dominion. 2020a, Section E3.4).

NAPS received one noise complaint for the period 2013-2017. The complaint was from a nearby resident due to the temporary sound emitted from the emergency diesel generators during a temporary outage. The complaint was resolved by verbal communication between NAPS and the resident. (Dominion. 2020a, Section E3.4) NAPS has not received any noise complaints from 2018 to 2021. To date, no noise complaints have been received in 2022. NAPS may make a public announcement for planned noise-generating activities when necessary and perform outreach to the public for an unplanned noise-generating activity. NAPS also monitors noise at and around the plant site for occupational and ambient effects on an as-needed basis.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 13 of 90 People living in the vicinity of NAPS will not likely experience any changes in noise levels during the proposed SLR term beyond what is currently experienced. Therefore, the impact of continued operations during the proposed SLR term will not likely exceed the noise impacts predicted in the GEIS. NAPS has not received any noise complaints from the public in the last five years, no refurbishment activities are anticipated, and there are no anticipated changes in noise levels associated with continued operations.

Dominion finds that noise impacts for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.4 GEOLOGY AND SOILS - ISSUE 8, TABLE E4.0-1 E4.4.1 GENERIC ANALYSIS FOR INITIAL LICENSE RENEWAL BACKGROUND [GEIS SECTION 4.4.1]

The impact of continued operations and refurbishment associated with license renewal on geologic and soil resources would consist of soil disturbance, including sediment and/or any associated bedrock, for projects such as replacing or adding buildings, roads, parking lots, and belowground and aboveground utility structures. Implementing BMPs would reduce soil erosion and subsequent impacts on surface water quality. These practices include, but are not limited to, minimizing the amount of disturbed land, stockpiling topsoil before ground disturbance, mulching and seeding in disturbed areas, covering loose materials with geotextiles, using silt fences to reduce sediment loading to surface water, using check dams to minimize the erosive power of drainages, and installing proper culvert outlets to direct flows in streams or drainages.

Detailed geotechnical analyses would be required to address the stability of excavations, foundation footings, and slope cuts for building construction, road creation, or other refurbishment-related construction projects. Depending on the plant location and design, riverbank or coastline protection might need to be upgraded, especially at water intake or discharge structures, if natural flows, such as storm surges, cause an increase in erosion. In addition, the Farmland Protection Policy Act [7 U.S. Code 4201 et seq.] requires federal agencies to take into account agency actions affecting the preservation of farmland including prime and other important farmland soils, as described in Section 3.4 of the GEIS.

E4.4.2 SITE-SPECIFIC ANALYSIS FOR NAPS SLR Routine infrastructure, renovation, and maintenance projects would be expected during continued operation. NAPS maintains and implements a stormwater pollution prevention plan (SWPPP) that identifies potential sources of pollution that would reasonably be expected to affect the quality of stormwater, such as erosion, and identifies BMPs that will be used to prevent or reduce the pollutants in stormwater discharges. (Dominion. 2020a) Construction and maintenance activities undertaken during the SLR period that would involve land disturbance may be required to have a Page-E-4-13

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 14 of 90 Virginia Pollutant Discharge Elimination System (VPDES) General Construction Stormwater permit, a SWPPP, a land disturbance permit, and an Erosion and Sedimentation Control Plan depending on the acreage of the land disturbance in accordance with regulatory requirements. In addition, NAPS has a spill prevention, control, and countermeasure (SPCC) plan as well as a fleet chemical control procedure and waste management procedure (Dominion. 2020a, Section E3.6.4.2).

Dominion would continue to conduct ongoing plant operational and maintenance activities, such as maintenance and repair of plant infrastructure (e.g., roadways, piping installations, fencing, and other security infrastructure), during the SLR term. Compliance with VPDES regulatory requirements and permit conditions, and implementation of a SWPPP, implementation of BMPs, and adhering to internal procedures, will ensure that geology and soil impacts from continued plant operations of the SLR term would be SMALL.

Dominion finds that impacts to geology and soils for the proposed SLR term would be SMALL.

Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.5.6 SURFACE WATER USE AND QUALITY (NON-COOLING SYSTEM IMPACTS) - ISSUE 9, TABLE E4.0-1 E4.5.6.1 Generic Analysis for Initial License Renewal [GEIS Section 4.5.1]

Surface Water Use The NRC considered water use during refurbishment activities for concrete production, dust control, washing stations, facility and equipment cleaning, and soil compaction and excavation backfilling. Surface water consumption for non-cooling water-related operational activities is limited to such uses as facility and equipment cleaning. The use of public domestic water would reduce the direct consumptive use impacts on surface water resources. The impacts due to the volume of water consumed from a surface water source would be insignificant when compared with that used and consumed by a plants cooling system. No surface use conflicts would be expected.

Surface Water Quality The NRC considered the potential impacts of land disturbing activities, industrial wastewater, stormwater, residual chlorine due to domestic water runoff, and inadvertent spills resulting from nuclear plants operations on surface water quality in its GEIS for license renewal. The NRC considered the mitigation measures of National Pollutant Discharge Elimination System (NPDES) permits, SWPPPs, BMPs, and pollution control structures such as detention and infiltration basins. The NRC concluded that nuclear power plants operation under NPDES permits and the implementation of BMPs would mitigate surface water quality impacts from non-cooling systems to be SMALL.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 15 of 90 E4.5.6.2 Site-Specific Analysis for NAPS SLR Non-cooling water includes service water, domestic fire protection water, and stormwater. Service water is sourced through a closed-loop system with makeup from North Anna Reservoir. Other non-cooling water is sourced from groundwater wells. The service water component of the Lake Anna withdrawal is estimated at approximately 0.016 percent during recent CWA 316(b) studies for the NAPS VPDES permit renewal application (VEPC. 2021b). The average daily water withdrawals from Lake Anna are about 11.3 percent (2013-2021) of the conservation and active storage volume (see Section E4.5.12.2) (Dominion. 2020a, Section E3.6.3.1). There are no modifications associated with the proposed action that would alter the surface water withdrawal rates; therefore, existing withdrawal rates are expected to continue during the proposed SLR operating term. With the service water component being such a small portion (0.016 percent) and the system is a closed system, the impact would be insignificant. Any surface water use conflicts attributable to non-cooling water uses would be SMALL.

The plants wastewater is discharged through the plants VPDES-permitted outfalls (Dominion.

2020a, Table E3.6-2). Stormwater discharges are also addressed in the VPDES permit and have several permitted outfalls (Dominion. 2020a, Section E3.6.1.2.2). Dominion complies with stormwater regulations, obtains necessary stormwater permits, and develops SWPPPs and implements BMPs. BMPs include nonstructural or administrative approaches, such as training to educate staff on proper handling and disposal of potential pollutants from continued operations.

NAPS maintains an SPCC plan that identifies and describes the procedures, materials, equipment, and facilities that are utilized at the station to minimize the frequency and severity of oil spills. Two reportable spills have occurred since 2013. (Dominion. 2020a)

Through these practices and structural devices designed to remove pollutants, reduce runoff rates and volumes, and protect aquatic habitats, the adverse stormwater-related effects are controlled.

Compliance with current VPDES and stormwater regulatory requirements and permit conditions, and implementation of the SWPPP, SPCC plan, and BMPs, will ensure the continued SMALL impact to surface water and groundwater quality from non-cooling water systems.

Dominion finds that impacts to surface water use and quality for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.5.7 ALTERED CURRENT PATTERNS AT INTAKE AND DISCHARGE -

ISSUE 10, TABLE E4.0-1 E4.5.7.1 Generic Analysis for Initial License Renewal [GEIS Section 4.5.1]

The large flow rates associated with cooling system water use have the potential to alter current patterns. The degree of influence depends on the design and location of the intake and discharge structures and the characteristics of the surface water body. The size of large rivers, lakes, or Page-E-4-15

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 16 of 90 reservoirs precludes significant current alterations, except in the vicinity of the structures. The effect on currents near the intake and discharge locations is expected to be localized, and any problems would have been mitigated during the early operational period of a plant. Impacts from altered current patterns at intake and discharge structures during the license renewal term were considered to be SMALL for all plants.

E4.5.7.2 Site-Specific Analysis for NAPS SLR The North Anna River was impounded to construct Lake Anna as the cooling system for NAPS.

The impoundment delays the southeastern flow of the North Anna River, and the volume of the impoundment is controlled by the North Anna Dam. Releases from the North Anna Dam are regulated in accordance with the stations VPDES Permit No. VA0052451, Part 1, Section D through lake level management and are controlled to target a lake level of 250 feet mean sea level (msl) for the operation of the station (Dominion. 2020a, Section E3.6.1 and Attachment B).

Water released over the dam continues in its southeastern flow to join with the South Anna River to form the Pamunkey River. (Dominion. 2020a, Section E3.3.1)

The NAPS cooling intake draws water from North Anna Reservoir and discharges it through a canal which directs the flow into the first of three lagoons in series that form the waste heat treatment facility (WHTF). Cooled water is released back into the North Anna Reservoir through Dike 3 at the third WHTF lagoon (Dominion. 2020a, Section E3.6.1).

The hydrology of Lake Anna is different from most other lakes and reservoirs in that during station operation the Lower Lake reach has an induced circulation pattern. The cooling water volume discharged at Dike 3 of the WHTF is drawn up-lake by the circulating water pumps. This circulation pattern results in a deepening of the epilimnetic layer and the development of a dynamic system resistant to summer stagnation. The deeper epilimnetic layer also increases the volume of oxygenated water in the lake and decreases the acreage of benthic substrate that would normally be anaerobic during summer months. (VP. 1986)

There are no modifications associated with the proposed action that would alter the existing current pattern, and the system will be operated in compliance with applicable permits; therefore, existing current patterns are expected to continue during the proposed SLR operating term.

Dominion finds that impacts to altered current patterns at intake and discharge for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 17 of 90 E4.5.8 ALTERED THERMAL STRATIFICATION OF LAKES - ISSUE 12, TABLE E4.0-1 E4.5.8.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

Because cooling systems typically withdraw from the deeper, cooler portion of the water column of lakes or reservoirs and discharge to the surface, they have the ability to alter the thermal stratification of the surface water. This is not considered an issue for rivers or oceans because of mixing caused by natural turbulence. Impacts of altered thermal stratification of lakes would be SMALL for all nuclear plants.

E4.5.8.2 Site-Specific Analysis for NAPS SLR The NRC did not find any new and significant information to modify the generic determination of SMALL for this Category 1 issue (NRC. 2002).

Dominion has continued to monitor temperatures in Lake Anna at various locations. As part of continuing the 316(a) demonstration environmental monitoring effort that includes fish population studies, Dominion reports Lake Anna water temperatures, using fixed temperature recorders at seven stations. These long-term temperature data do not indicate an overall warming trend in the lake. Most reservoirs the size of Lake Anna have some natural variability, as discussed below, but Dominions monitoring demonstrates no deleterious impacts from NAPS operations.

Dominion conducts temperature surveys in the spring (generally March and May), late summer (August or September), and fall/winter (November or December) to provide temperature data to assess seasonal thermal stratification patterns in Lake Anna. Temperature is measured at one-meter intervals, from the surface to the bottom. Typically, for the years 2013-2017, temperature readings indicated the lake begins to stratify in March, while the May surveys show a thermocline in the southern third of the lake and gradual changes in temperature from surface to the bottom in the middle and upper thirds of the lake. September readings generally show very little temperature changes with depth, and November and December temperatures show slightly decreasing temperatures with increasing depth. (VEPC. 2021a).

For the years 2019 through 2021, temperature readings indicated the lake begins to stratify in June with a thermocline in the southern third of the lake and gradual changes in temperature from surface to the bottom in the middle and upper thirds of the lake. During 2019, the January, August, and December readings generally show very little temperature changes with depth. Similarly, during 2020, the January, September, and December readings generally show very little temperature changes with depth. During 2021, the March and August surveys showed similar stratification, while November showed very little temperature changes with depth. This is the expected pattern, as lakes do not stratify year-round. As air temperatures decrease in the fall, surface waters cool as well. As the cooler water becomes denser, it begins to sink, and this, in addition to the increases in fall winds, causes lake turnover and mixing, resulting in little temperature change with depth.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 18 of 90 Therefore, Lake Anna demonstrates the natural seasonal pattern of mixing and stratification. No modifications are planned for the proposed SLR operating term that would affect current stratification and seasonal stratification pattern. Thus, the continued operation of the NAPS once-through cooling system during the proposed SLR operating term is not anticipated to significantly alter the thermal stratification of Lake Anna.

Dominion finds that impacts to thermal stratification of Lake Anna for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.5.9 SCOURING CAUSED BY DISCHARGED COOLING WATER - ISSUE 13, TABLE E4.0-1 E4.5.9.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

The high flow rate of water from a cooling system discharge structure has the potential to scour sediments and redeposit them elsewhere. While scouring is possible during reactor startup, operational periods would typically have negligible scouring. Scouring is expected to occur only in the vicinity of the discharge structure where flow rates are high. Scouring has been observed at only three nuclear power plants and the effects were localized and minor. The NRC reviewed the impacts of scouring caused by discharged cooling water and found the impacts during the license renewal term would be SMALL for all plants.

E4.5.9.2 Site-Specific Analysis for NAPS SLR There are no plant operations or modifications planned for the proposed SLR operating term that would alter discharge patterns. As discussed in Section E4.5.7.2, the NAPS cooling intake draws water from North Anna Reservoir and discharges it through a canal which directs the flow into the first of three lagoons in series that form the WHTF. Cooled water is released back into the North Anna Reservoir through Dike 3 at the third WHTF lagoon. Dominions circulating water flow is no different between startup and normal operation. In general, four circulating water pumps are used during both startup and normal operations. There are no modifications associated with the proposed action that would alter the existing current pattern; therefore, existing current patterns are expected to continue during the proposed SLR operating term.

As there are no expected changes in existing current patterns, no scouring impact changes are expected.

Dominion finds that impacts from scouring caused by discharge cooling water for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS Page-E-4-18

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 19 of 90 are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.5.10 DISCHARGE OF METALS IN COOLING SYSTEM EFFLUENT - ISSUE 14, TABLE E4.0-1 E4.5.10.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

Heavy metals such as copper, zinc, and chromium can be leached from condenser tubing and other components of the heat exchange system by circulating cooling water. These metals are normally addressed in NPDES permits because high concentrations of them can be toxic to aquatic organisms. During normal operations, concentrations are normally below laboratory detection levels. However, plants occasionally undergo planned outages for refueling with stagnant water remaining in the heat exchange system. Impacts from the discharge of metals in cooling system effluent during the license renewal term would be SMALL for all plants.

E4.5.10.2 Site-Specific Analysis for NAPS SLR Chemical additives approved by the VDEQ are used to control pH, scale, corrosion, and biofouling of various plant equipment (Dominion. 2020a). Process wastewaters are monitored and discharged either directly to the North Anna Reservoir or to the North Anna Reservoir via the WHTF and VPDES Outfall 001 at Dike 3 in accordance with the NAPS VPDES Permit No.

VA00052451. The current VPDES permit authorizes discharges from 10 external outfalls (seven industrial process wastewater and three stormwater) and 18 internal outfalls (16 industrial process wastewater and two stormwater). The industrial process wastewater outfalls are depicted in the NAPS SLR ER Figure E3.6-3, and their associated effluent limits are listed in the NAPS SLR ER Table E3.6-2. The effluent from the cooling and service water systems (SWS) is subject to the VPDES permit. Internal Outfall 105 for the bearing cooling tower blowdown is subject to monitoring requirements with limits for zinc and chromium and no detectable concentrations of the 126 priority pollutants present in chemical additives to the bearing cooling tower in the final effluent. (Dominion. 2020a, Attachment B) Compliance with the VPDES permit would ensure that impacts are SMALL. The impacts on aquatic organisms are addressed in Section E4.6.15.

The VPDES limits the pH on all discharge outfalls to be between 6.0 and 9.0 standard units (Dominion. 2020a, Table E3.6.2). At the reported pH range of the effluent waters, the solubility of copper and iron is below 1.0 milligram per liter (mg/l), and the solubility of zinc is approximately 10 mg/l (Hoffland. 2022). These lower solubility rates at the NAPSs discharge pH range minimize metal dissolution and the chances of metals entering the North Anna Reservoir.

The comprehensive regulatory controls and permits in place and NAPSs compliance with them, guided by their internal procedures, would mitigate impacts to surface waters from NAPSs continued operations during the proposed SLR term.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 20 of 90 Compliance with current and future VPDES regulatory requirements, permit conditions, and BMPs will ensure the impact of metals in NAPSs cooling system effluent continues to be limited to a SMALL impact during the proposed SLR term.

Dominion finds that impacts from discharge of metals in cooling system effluent for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.5.11 DISCHARGE OF BIOCIDES, SANITARY WASTES, AND MINOR CHEMICAL SPILLS - ISSUE 15, TABLE E4.0-1 E4.5.11.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

In the 2013 license renewal GEIS, the NRC reviewed the discharge of biocides, sanitary wastes, and minor chemical spills. The use of biocides is common and is required to control biofouling and nuisance organisms in plant cooling systems. However, the types of chemicals, their amounts or concentrations, and the frequency of their use may vary. Ultimately, any biocides used in the cooling system are discharged to surface water bodies. The discharge of treated sanitary waste also occurs at plants. Discharge may occur via onsite wastewater treatment facilities, via an onsite septic field, or through a connection to a municipal sewage system. Minor chemical spills collected in floor drains are associated with industry in general and are a possibility at all plants. Each of these factors represents a potential impact on surface water quality. The NRC considered the potential impacts of these factors resulting from nuclear plant operations of surface water quality in its GEIS for license renewal. The NRC concluded that nuclear power plant operation under NPDES permits would mitigate impacts from biocides, sanitary wastes, and minor chemical spills to SMALL significance.

E4.5.11.2 Site-Specific Analysis for NAPS SLR NAPS uses commercially available water treatment chemicals and corrosion inhibitors. Blue dye is also added on occasion to inhibit algae. Plant wastewater and stormwater discharges are governed by the NAPS VPDES permit, which was reissued in 2014 (Dominion. 2020a, Attachment B). No notices of violation (NOVs) have been received from 2013-2021, but a warning letter was received for a missed total suspended solids (TSS) monitoring requirement at Outfall 103 (Dominion. 2020a, Section E9.3). A current listing of water additives was provided in the VPDES permit renewal application (VEPC. 2021b). The VDEQ would incorporate any new permit restrictions indicated by its review of the list in the renewal permit.

Sanitary wastewater is collected in the onsite sewage treatment plant, where it is treated and then discharged to Internal Outfall 111, a subsurface discharge into the cooling water discharge canal, which then discharges to Lake Anna through Outfall 001. Discharge of treated sanitary wastewater from NAPS is regulated by the NAPS VPDES Permit No. VA0052451. (Dominion.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 21 of 90 2020a, Attachment B) NAPS also has septic systems serving the North Anna Nuclear Information Center (NANIC) and the security training building. (Dominion. 2020a)

A review of records showed one reportable spill from 2013-2018 for spill notification and environmental compliance at NAPS. This was reported as a fuel oil leak from an underground feed line serving the plants diesel generators in 2016. All of the fuel oil lines that feed to the plants emergency and station blackout diesel generators were replaced in 2017 following the leak. (Dominion. 2020a) A release of non-polychlorinated biphenyl (PCB) mineral oil from a transformer in the warehouse area occurred in 2021. The impacted soil was remediated, and all waste removed from the site and properly disposed. NAPS has environmental protection programs for the non-radiological hazards of plant operations guided by compliance with state and local environmental permits and requirements. The comprehensive regulatory controls and permits in place and Dominions compliance with them, guided by internal procedures, would mitigate impacts to surface waters from NAPSs continued operations during the proposed SLR term.

Compliance with current VPDES regulatory requirements and permit conditions, and implementation of the SWPPP and BMPs, will mitigate impacts from wastewater and stormwater discharges to SMALL.

Dominion finds that impacts from discharge of biocides, sanitary wastes, and minor chemical spills for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.5.12 SURFACE WATER USE CONFLICTS (PLANTS WITH ONCE-THROUGH COOLING SYSTEMS) - ISSUE 16, TABLE E4.0-1 E4.5.12.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

Nuclear power plant cooling systems may compete with other users relying on surface water resources, including downstream municipal, agricultural, or industrial users. Once-through and closed-cycle cooling systems have different water consumption rates. Once-through cooling systems return most of their withdrawn water to the same surface water body, with evaporative losses of less than 3 percent. Consumptive use by plants with once-through cooling systems during the license renewal term is not expected to change unless power uprates, with associated increases in water use, are proposed. Such uprates would require an environmental assessment by the NRC. The NRC considered that future water availability could be impacted by climate change and drought. Because future agricultural, municipal, and industrial users would continue to share their demands for surface water with power plants, conflicts might arise if the availability of this resource decreased. This situation would then necessitate decisions by local, state, and regional water planning officials. The NRC concluded that the impact on water use conflicts from Page-E-4-21

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 22 of 90 the continued operation and refurbishment activities would be SMALL for plants that utilize once-through cooling.

E4.5.12.2 Site-Specific Analysis for NAPS SLR NAPS uses water from the North Anna Reservoir for once-through cooling and the auxiliary cooling system and returns most of the water back to the reservoir (Dominion. 2020a). The average surface water withdrawal rate by NAPS in 2019 was reported as 1,817.99 million gallons per day (MGD) and averaged 1,836.07 MGD between 2013 and 2019. (Dominion. 2020a, Table E3.6-4a)

As shown in Table E4.5-1a, the average surface water withdrawal rate by NAPS in 2021 was reported as 1,855.57 MGD and averaged 1,845.80 MGD between 2013 and 2021. The 2021 average daily withdrawal amount represents about 11.4 percent of the conservation and active storage volume of the North Anna Reservoir (Dominion. 2020a, Section E3.6.3.1). Please note, in NAPS SLR ER Section E3.6.3.1 and Section E6.3.2, the 2019 NAPS daily average withdrawal value was incorrectly cited as two percent (Dominion. 2020a). The correct daily average withdrawal is about 11.4 percent. Lake Anna is not used as a drinking water source by either NAPS or the community. There are no public water supplies within 5 miles of the outfalls.

A summary of monthly surface water withdrawals reported by NAPS between 2013 and 2021 is provided in Table E4.5-1b (2020 and 2021) and NAPS SLR ER Table E3.6-4b (2013-2019)

(Dominion. 2020a).

Per 9VAC25-210-310, since the surface water intake and withdrawals at NAPS have been in existence before July 1, 1989, they are excluded from permitting (VAC. 2022). There are no surface water withdrawal permits or limits on surface water withdrawals for NAPS.

Releases from the North Anna Dam are regulated by NAPS VPDES Permit No. VA0052451 through the lake level management plan, Part I.D.4 of the permit. The normal pool level for the North Anna Reservoir is maintained at elevation 250 feet msl. The Commonwealth of Virginia requires a minimum discharge of 40 cubic feet per second (cfs) from the North Anna Dam, except under drought conditions. Should the Lake Anna water surface elevations fall below 248 feet msl, releases must be reduced below 40 cfs in accordance with Part I.D.4 (Dominion. 2020a, Attachment B). These minimum flow requirements are established to maintain instream flows and water quality in the North Anna River below the dam, and in the Pamunkey and York rivers further downstream. (Dominion. 2020a, Section E3.6.1)

Dominion requested a change in its 2018 VPDES permit renewal application regarding control of releases from the North Anna Dam. The requested change is for the installation of an automated means of making the releases required by the VPDES permit. An electrical motor-operated valve would control the releases when the hydro units are out of service and can operate in the event of power loss. In conjunction with the valve, an orifice plate is designed to discharge 43 cfs (the required 40 cfs plus a 3 cfs margin). The valve would also be used to decrease flows during drought conditions as allowed under the VPDES permit. These changes were submitted to VDEQ Page-E-4-22

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 23 of 90 for review and approval. (VEPC. 2021b) The VDEQ has administratively continued the VPDES permit, and Dominion expects a draft in early 2023. The continuance of the 316(a) variance will be part of the reissued permit.

Compliance with the VPDES permit dam release requirements protects downstream users and ecological communities, mitigating water use impacts.

Dominion finds that impacts to surface water use conflicts for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.5.13 EFFECTS OF DREDGING ON SURFACE WATER QUALITY - ISSUE 17, TABLE E4.0-1 E4.5.13.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

Dredging activities and the discharge of dredged and/or fill material have the potential to impact surface water quality. Nuclear power plants conduct maintenance dredging to remove accumulated sediments in the vicinity of water intakes, canals, and discharge structures, and to maintain barge shipping lanes. The issue does not concern maintenance dredging of onsite cooling ponds and onsite disposal of dredged material (e.g., mud). In the 2013 license renewal GEIS, the NRC reviewed the potential impacts to surface water quality from dredging operations to support nuclear power plant operations and found the issue to have SMALL impacts to all plants. In general, the NRC found maintenance dredging affects localized areas for a brief period of time. The NRC also recognized that dredging operations are performed under permits issued by the U.S. Army Corps of Engineers (USACE) and possibly state or local agencies.

E4.5.13.2 Site-Specific Analysis for NAPS SLR NAPS does not conduct maintenance dredging for the North Anna Reservoir, the WHTF, the intake area, or the discharge canal (Dominion. 2020a, Section E3.6.1.2.4). No dredging is anticipated by Dominion during the SLR term. As discussed in Section E4.6.17.2, dredging activities conducted by others are small scale and occur in the upper fingers of the lake for recreational navigation purposes. Therefore, this issue is not applicable and further analysis is not required.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 24 of 90 E4.5.14 TEMPERATURE EFFECTS ON SEDIMENT TRANSPORT CAPACITY -

ISSUE 18, TABLE E4.0-1 E4.5.14.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

The GEIS discusses this issue by stating: Increased temperature and the resulting decreased viscosity have been hypothesized to change the sediment transport capacity of water, leading to potential sedimentation problems, altered turbidity of rivers, and changes in riverbed configuration. The NRCs review indicated that there is no evidence that temperature effects on sediment transport capacity have caused adverse environmental effects at any existing nuclear power plant and acknowledged that regulatory agencies have expressed no concerns regarding the impacts of temperature on sediment transport capacity. Furthermore, because of the small area near a nuclear power plant affected by increased water temperature, it is not expected that plant operations would have a significant impact. Effects are considered to be of SMALL significance for all plants. No change in the operation of the cooling system is expected during the license renewal term, so no change in effects on sediment transport capacity is anticipated.

E4.5.14.2 Site-Specific Analysis for NAPS SLR The WHTF allows NAPS discharge to cool before returning it to the North Anna Reservoir.

Temperature monitoring in Lake Anna has not indicated long-term warming trends. (Dominion.

2020a) There are no plant operations or modifications planned for the proposed SLR operating term that would alter discharge structures or thermal discharges.

Dominion finds that impacts to surface water resources including temperature effects on sediment transport capacity for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.5.15 GROUNDWATER CONTAMINATION AND USE (NON-COOLING SYSTEM IMPACTS) - ISSUE 19, TABLE E4.0-1 E4.5.15.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.2]

Among common groundwater uses are extraction or draining of groundwater for dewatering purposes and groundwater extraction for contaminant plume control. Contamination of groundwater and soil can result from leaks or spills of solvents, diesel fuel, gasoline, and other industrial chemicals; heavy metals deposited to soils from industrial activities; leaching of contaminants from wastewater ponds or lagoons; and other sources. The NRC considered the issue in light of the programs and procedures commonly implemented at nuclear plants, including proper chemical and waste storage and handling; secondary containment and leak detection; use of BMPs and SPCC plans; compliance with federal and state regulations and permits; and groundwater monitoring programs. The NRC concluded that implementation of such programs Page-E-4-24

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 25 of 90 and procedures would serve to mitigate any effects to groundwater use or quality to those of a SMALL impact.

E4.5.15.2 Site-Specific Analysis for NAPS SLR There are onsite water supply wells at NAPS (Dominion. 2020a). However, this issue does not address pumping from production wells, which is addressed by the issues concerning a pumping threshold of 100 gallons per minute (gpm) (Section E4.5.16).

With the exception of Unit 1 and Unit 2 containment mat sumps, dewatering is not performed at NAPS. Groundwater at the site, and specifically within the Protected Area, is controlled by geology as well as site structures, active sumps, seasonal recharge, and Lake Anna. At the Unit 1 refueling water storage tank (RWST), groundwater has been encountered at approximately 20 feet bgs or at approximately 250 feet msl, with seasonal variations of up to 2 feet. Although existing wells located outside the Protected Area show flow directions toward Lake Anna, within the Protected Area, groundwater is controlled by containment mat sumps that are designed to control water around the reactor buildings of both units and the auxiliary building. Groundwater is maintained by the Unit 1 and Unit 2 containment mat sumps to an elevation of approximately 240 feet msl, creating a drawdown of the water table that extends out beyond the RWSTs. This is evidenced by the inferred flow direction to the west in wells along the Unit 1 Alleyway and demonstrates that any tritium releases that would occur upgradient (including the Unit 1 RWST) could be captured and would only be discharged via a monitored pathway.

Dominion implemented a Ground Water Protection Program in 2008. As part of this program, NAPS monitors 23 wells and three piezometers and implemented and maintains an underground piping and tank integrity program to provide a broad-based and comprehensive program to reduce the probability and consequences of pipe and tank failure to an acceptable level. Groundwater samples are collected from selected onsite monitoring wells as part of the NAPS radiological groundwater monitoring program and analyzed for radionuclides to detect potential impacts to groundwater from inadvertent leaks or spills. As presented in Section E4.6.7.2, other than tritium in surface or river water, the results for 2013-2021 did not detect radionuclides attributable to NAPS.

As described in Section E4.5.11.2, a review of records from 2013-2021 for spill notification and environmental compliance at NAPS showed two reportable spills. The first was a fuel oil leak from an underground feed line serving the plants diesel generators in 2016. All of the fuel oil lines that feed to the plants emergency and station blackout diesel generators were replaced in 2017 following the leak. The second was a release of non-PCB mineral oil from a transformer in the warehouse area. The impacted soil was remediated, and all waste removed from the site and properly disposed of. There are no ongoing remediation activities for nonradiological spills occurring prior to 2013.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 26 of 90 NAPS has a written SPCC plan that identifies and describes the procedures, materials, equipment, and facilities that are utilized at the station to minimize the frequency and severity of spills. NAPS continues to maintain and implement the SPCC plan. (VEPC. 2021b).

NAPS has controls in place for projects that involve ground disturbance, stormwater controls in place to reduce the potential for stormwater runoff to contaminate soils and groundwater, a SWPPP to prevent the introduction of pollutants to the stormwater and collection in the NAPS stormwater basins, and procedures in place to minimize the potential for spills (Section E4.4.2).

Continuation of groundwater monitoring to detect contamination in order to correct leaks, and compliance with current and future spill control regulatory requirements, will protect against inadvertent spills and releases and prompt action to mitigate leaks.

Dominion finds that impacts to groundwater resources for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.5.16 GROUNDWATER USE CONFLICTS (PLANTS THAT WITHDRAW LESS THAN 100 GPM) - ISSUE 20, TABLE E4.0-1 E4.5.16.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.2]

Water wells are used by nuclear power plants for their potable water system and landscape watering. At some plants, groundwater is the source for the makeup and SWS. The pumping of groundwater creates a cone of depression in the potentiometric surface around the pumping well.

The amount that the water table or potentiometric surface declines and the overall extent of the cone depend on the pumping rate, characteristics of the aquifer (e.g., its permeability), whether the aquifer is confined or unconfined, and certain boundary conditions (including the nearby presence of a hydrologically connected surface water body). Generally, plants with a peak withdrawal rate of less than 100 gpm do not have a significant cone of depression. Their potential for causing conflict with other groundwater users would depend largely on the proximity of the other wells.

E4.5.16.2 Site-Specific Analysis for NAPS SLR NAPS holds Virginia Department of Health (VDH) permits for maximum withdrawal rate of 117.50 gpm but had an average withdrawal rate of 5.60 gpm from 2013-2019 (Dominion. 2020a).

The average groundwater withdrawal rate by NAPS in 2019 was reported as 7,969.86 gallons per day (gpd) (5.53 gpm) and averaged 8,059.80 gpd (5.60 gpm) between 2013 and 2019, well below 100 gpm (Dominion. 2020a). As shown in Table E4.5-2a, the average groundwater withdrawal Page-E-4-26

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 27 of 90 rate by NAPS in 2021 was reported as 5,112.05 gpd (3.55 gpm) and averaged 7,390.81 gpd (5.13 gpm) between 2013 and 2021.

A summary of monthly groundwater withdrawals reported by NAPS between 2013 and 2021 is provided in Table E4.5-2b (2020 and 2021) and the NAPS SLR ER Table E3.6-7b (2013-2019)

The highest recorded average monthly groundwater withdrawal rate between 2013 and 2021 was 11.57 gpm in April 2013. (Dominion. 2020a)

There are no proposed plant operations or modifications planned for the proposed SLR operating term that would significantly alter groundwater withdrawal rates.

Given that NAPS underutilizes its VDH-permitted withdrawal rate by a wide margin, no groundwater use conflicts are anticipated for the proposed SLR operating term, and the impact of continued groundwater use by NAPS would be SMALL.

Dominion finds that impacts to groundwater use conflicts for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.5.17 GROUNDWATER QUALITY DEGRADATION (PLANTS WITH COOLING PONDS IN SALT MARSHES) - ISSUE 22, TABLE E4.0-1 E4.5.17.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.2]

Nuclear plants that use cooling ponds as part of their cooling water system discharge effluent to the pond. The effluents concentration of contaminants and other solids increases relative to that of the makeup water as it passes through the cooling system. These changes include increased total dissolved solids (or TDS), since they concentrate as a result of evaporation, increased heavy metals (because cooling water contacts the cooling system components), and increased chemical additives to prevent biofouling. Because all the ponds are unlined, the water discharged to them can interact with the shallow groundwater system and may create a groundwater mound. In this case, groundwater below the pond can flow radially outward, and this groundwater would have some of the characteristics of the cooling system effluent.

In salt marsh locations, the groundwater is naturally brackish (i.e., with a TDS concentration of about 1,000 to more than 10,000 mg/l) and, thus, is already limited in its uses. As such, this issue concerns only the potential for changing the groundwater use category of the underlying shallow and brackish groundwater due to the introduction of cooling water contaminants. Impacts of groundwater quality degradation for nuclear plants using cooling ponds in salt marshes would be SMALL.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 28 of 90 E4.5.17.2 Site-Specific Analysis for NAPS SLR NAPS does not utilize a cooling pond and is not located in a salt marsh. Salt marshes are coastal wetlands that are flooded and drained by salt water brought in by the tides (NOS. 2022).

Therefore, this issue is not applicable and further analysis is not required.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 29 of 90 Table E4.5-1a NAPS Yearly Surface Water Withdrawal Summary (2020 - 2021)

Monthly Maximum Monthly Average Monthly Minimum Yearly Total Year MGM gpma MGM gpma MGM gpma MGY MGD 2020 73,333.01 1,642,764 58,076.80 1,321,477 42,222.19 961,478 696,921.58 1,904.16 2021 72,700.33 1,631,382 56,440.23 1,286,737 33,377.00 747,693 677,282.79 1,855.57 2013-2021 74,653.18 1,672,338 56,177.30 1,280,140 23,479.88 525,983 674,127.59 1,845.80 MGY = millions of gallons per year MGM = millions of gallons per month gpma - average gallons per minute for the month (rounded to nearest gpm)

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 30 of 90 Table E4.5-1b NAPS Monthly Surface Water Withdrawal Summary (2020 - 2021)

Surface Water Withdrawals (MGM) Total North North Anna North Anna NA3 Mini-SY MGM gpma Anna Dam Unit #1b Unit #2b Construction Construction Month Water Water January-20 2,745.36 20,621.00 19,554.00 (a) 0.00 42,920.36 961,477.60 February-20 2,582.19 20,434.00 19,206.00 (a) 0.00 42,222.19 1,011,067.77 March-20 0.00 23,645.00 25,105.00 (a) 0.00 48,750.00 1,092,069.89 April-20 0.00 32,148.00 29,183.00 (a) 0.01 61,331.01 1,419,699.21 May-20 0.00 34,883.00 35,178.00 (a) 0.01 70,061.01 1,569,467.11 June-20 0.00 33,837.00 34,927.00 (a) 0.00 68,764.00 1,591,759.26 July-20 0.00 36,763.00 36,476.00 (a) 0.00 73,239.00 1,640,658.60 August-20 0.00 36,838.00 36,495.00 (a) 0.01 73,333.01 1,642,764.47 September-20 0.00 35,575.00 13,907.00 (a) 0.00 49,482.00 1,145,416.76 October-20 0.00 35,916.00 17,472.00 (a) 0.00 53,388.00 1,195,967.74 November-20 0.00 33,683.00 28,397.00 (a) 0.00 62,080.00 1,437,037.04 December-20 0.00 26,287.00 25,064.00 (a) 0.00 51,351.00 1,150,336.02 January-21 0.00 19,331.00 19,117.00 (a) 0.00 38,448.00 861,290.32 February-21 0.00 18,524.00 18,309.00 (a) 0.00 36,833.00 913,516.87 March-21 0.00 9,016.00 24,361.00 (a) 0.00 33,377.00 747,692.65 April-21 0.00 14,151.00 30,622.00 (a) 0.00 44,773.00 1,036,412.04 May-21 353.40 31,518.00 35,570.00 (a) 0.00 67,441.40 1,510,784.07 June-21 294.63 34,860.00 34,824.00 (a) 0.00 69,978.63 1,619,875.69 July-21 300.11 35,812.00 36,261.00 (a) 0.00 72,373.11 1,621,261.42 August-21 376.33 35,964.00 36,360.00 (a) 0.00 72,700.33 1,628,591.62 September-21 824.70 34,678.00 34,973.00 (a) 0.00 70,475.70 1,631,382.94 October-21 891.27 35,390.00 34,991.00 (a) 0.00 71,272.27 1,596,601.05 Page-E-4-30

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 31 of 90 Surface Water Withdrawals (MGM) Total North North Anna North Anna NA3 Mini-SY MGM gpma Anna Dam Unit #1b Unit #2b Construction Construction Month Water Water November-21 754.42 27,548.00 27,975.00 (a) 0.00 56,277.42 1,302,718.06 December-21 837.93 20,971.00 21,524.00 (a) 0.00 43,332.93 970,719.76 (a) 2019 to 2021 water usage reports designate this withdrawal the Mini-Switchyard Construction. In previous years, it was designated as Unit 3 Construction.

(b) Water usage reports designate the withdrawals for NAPS as Lake Anna Unit #1 and Lake Anna Unit #2.

gpma - average gallons per minute for the month (rounded to nearest gpm)

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 32 of 90 Table E4.5-2a NAPS Yearly Groundwater Withdrawal Summary (2013-2021)

Monthly Monthly Monthly Yearly Total Year Maximum Average Minimum MGM gpma MGM gpma MGM gpma MGY gpd 2020 0.27 6.35 0.15 3.47 0.08 1.74 1.83 4,986.61 2021 0.32 7.12 0.16 3.56 0.04 1.01 1.87 5,112.05 2013-2021 0.50 11.57 0.22 5.13 0.04 1.01 2.70 7,390.81 MGY = millions of gallons per year MGM = millions of gallons per month gpd = gallons per day gpma = average gallons per minute for the month Page-E-4-32

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 33 of 90 Table E4.5-2b NAPS Monthly Groundwater Withdrawal Summary (2020 - 2021)

Groundwater Wells (MGM) Monthly Total Month NANIC #4 #6 #7 #8 MGM gpma January-20 0.011 (a) 0.107 0.005 0.006 0.129 2.888 February-20 0.012 (a) 0.003 0.000 0.161 0.176 4.219 March-20 0.013 (a) 0.005 0.000 0.137 0.155 3.470 April-20 0.016 (a) 0.032 0.000 0.040 0.088 2.042 May-20 0.017 (a) 0.014 0.046 0.000 0.078 1.738 June-20 0.015 (a) 0.000 0.097 0.000 0.112 2.590 July-20 0.015 (a) 0.001 0.134 0.000 0.150 3.349 August-20 0.015 (a) 0.172 0.008 0.000 0.194 4.355 September-20 0.014 (a) 0.260 0.000 0.000 0.275 6.354 October-20 0.016 (a) 0.213 0.000 0.000 0.229 5.132 November-20 0.016 (a) 0.101 0.000 0.000 0.117 2.701 December-20 0.019 (a) 0.104 0.000 0.000 0.123 2.760 January-21 0.023 (a) 0.142 0.001 0.000 0.166 3.725 February-21 0.022 (a) 0.159 0.000 0.000 0.181 4.487 March-21 0.027 (a) 0.290 0.001 0.000 0.318 7.119 April-21 0.028 (a) 0.269 0.001 0.001 0.299 6.912 May-21 0.036 (a) 0.131 0.004 0.000 0.171 3.822 June-21 0.035 (a) 0.136 0.002 0.000 0.172 3.984 July-21 0.045 (a) 0.029 0.084 0.000 0.159 3.553 August-21 0.046 (a) 0.000 0.057 0.000 0.103 2.305 September-21 0.055 (a) 0.000 0.000 0.000 0.055 1.266 October-21 0.061 (a) 0.004 0.000 0.051 0.116 2.590 November-21 0.049 (a) 0.034 0.000 0.000 0.083 1.919 December-21 0.008 (a) 0.037 0.000 0.000 0.045 1.006 (a) Not installed, not operational, or abandoned gpma - average gallons per minute for the month (rounded to nearest gpm)

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 34 of 90 E4.6.7 EXPOSURE OF TERRESTRIAL ORGANISMS TO RADIONUCLIDES -

ISSUE 23, TABLE 4.0-1 E4.6.7.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.6.1.1]

In the 2013 license renewal GEIS, the NRC reviewed the potential for radionuclides from normal operations to impact terrestrial organisms and concluded that impacts on terrestrial biota would be SMALL. In its review, the NRC considered the various pathways that radionuclides may be released from nuclear power plants into the environment. Releases into terrestrial environments often result from deposition of small amounts of radioactive particulates released from power plant vents during normal operations. These releases typically include krypton, xenon, and argon (which do not contain radioactive particles), tritium, isotopes of iodine, and cesium, and they may also include strontium, cobalt, and chromium. Radionuclides may also be released into the aquatic environment from the liquid effluent discharge line. Radionuclides that enter shallow groundwater from cooling ponds can be taken up by terrestrial plant species, including both upland species and wetland species, where wetlands receive groundwater discharge. Terrestrial biota may be exposed to ionizing radiation from radionuclides through direct contact with water or other media, inhalation, or ingestion of food, water, or soil.

As part of the 2013 GEIS analysis, the NRC conducted a review of all operating nuclear power plants to evaluate the potential impacts of radionuclides on terrestrial biota from continued operations. The NRC selected 15 representative plants to calculate estimated dose rates for terrestrial biota from nuclear plants. The maximum estimated dose rate calculated for any of the nuclear power plants was 0.0354 rad per day (rad/d) (3.54 x 10-4 Gray per day [Gy/d]) (riparian animal at the Browns Ferry plant), which is below the guideline value of 0.1 rad/d (0.001 Gy/d) for a riparian animal receptor. On the basis of these calculations and a review of the available literature, the NRC concluded that the impact of routine radionuclide releases from past and current operations and refurbishment activities on terrestrial biota would be SMALL for all nuclear plants and would not be expected to appreciably change during the proposed LR term.

E4.6.7.2 Site-Specific Analysis for NAPS SLR The NRC conducted a site-specific analysis of potential impacts to non-human biota for two additional units at the NAPS site in the early site permit EIS, NUREG-1811, comparing the estimated whole-body dose to the biota for the proposed Units 3 and 4 to the International Atomic Energy Agency (IAEA) chronic dose rate values for aquatic organisms and terrestrial animals.

The estimated doses were a fraction of the IAEA and National Council on Radiation Protection and Measurements chronic exposure values. NRC also concluded with regard to cumulative impacts inclusive of the effluents from Units 1 and 2 that the cumulative effects would result in dose rates significantly less than the IAEA and National Council on Radiation Protection and Measurements studies. Thus, the analysis showed that the total cumulative dose from gaseous and liquid effluent from four units was well below guideline values for protection of biota populations. (Dominion. 2020a)

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 35 of 90 The proposed action is to continue to operate as currently designed. No refurbishment activities are proposed, so radioactive effluents would be similar to those under current operations. NAPS submits annual radioactive effluent release reports to NRC and calculates the public dose from its liquid and gaseous radioactive releases. NAPS uses its offsite dose calculation manual (ODCM), updated as needed, to provide methods and parameters for calculating offsite doses in accordance with NRC requirements. These methods ensure that radioactive discharges from NAPS meet NRC and EPA regulatory dose standards.

The NAPS Radiological Environmental Monitoring Program (REMP) includes annual sampling of environmental media in a 25-mile radius (Dominion. 2020a). The results for years 2013-2017 show that the annual public dose is a fraction of the regulatory limits and was in accordance with radiation protection standards. The reports for years 2018-2021 likewise indicated that the public dose from the radioactive effluents was a fraction of the regulatory limits (Dominion. 2020a; Dominion. 2020b; Dominion. 2021b; Dominion. 2022a). Because there is no reason to expect effluents to increase in the PEO, annual doses from continued operation are expected to be within regulatory limits.

NAPSs REMP is designed to determine if NAPSs radioactive effluent releases, including radioactive releases from LLRW management and storage at NAPS, are leading to an accumulation of radioactivity both onsite and in the surrounding offsite environment. The REMP sampling reported in the annual radiological environmental operating reports for 2013-2017 did not detect radionuclides attributable to NAPS other than tritium in surface or river water and the operation of NAPS has created no adverse environmental effects or health hazards (Dominion.

2020a). Likewise, the 2018-2021 annual radiological environmental operating reports concluded that the operation of NAPS has created no adverse environmental effects or health hazards (Dominion. 2020a; Dominion. 2020c, Dominion. 2021c; Dominion. 2022b).

Dominion finds that exposure of terrestrial organisms to radionuclides for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.6.8 COOLING SYSTEM IMPACTS ON TERRESTRIAL RESOURCES (PLANTS WITH ONCE-THROUGH COOLING SYSTEMS OR COOLING PONDS) - ISSUE 24, TABLE E4.0-1 E4.6.8.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.6.1.1]

This issue considers potential impacts to terrestrial resources from contaminants and physical alterations of the environment resulting from the operation of the cooling system. Physical alterations include increased water temperatures; humidity and fogging; contaminants in surface water or groundwater; and disturbance of wetlands from maintenance dredging of onsite cooling Page-E-4-35

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 36 of 90 ponds, disposal of dredged material from such dredging, and erosion of shoreline wetlands. Other potential impacts to terrestrial resources considered in this issue include impingement of waterfowl at the cooling water intakes, potential for groundwater quality degradation by contaminants present in cooling ponds and cooling canals, and reduced water availability due to surface water or groundwater withdrawals.

The 2013 GEIS stated no adverse effects on terrestrial plants or animals have been reported as a result of increased water temperatures, fogging, humidity, or reduced habitat quality. Because of the low concentrations of contaminants within the liquid effluents associated with the cooling systems, the uptake and accumulation of contaminants in the tissues of wildlife exposed to the contaminated water or aquatic food sources are not expected to be significant issues, and the impacts are expected to be SMALL for all plants. Potential mitigation measures would include regular monitoring of the cooling systems for water quality and measures to exclude wildlife from contaminated ponds. On the basis of these considerations, the NRC concluded that the impact of continued operation of the cooling systems on terrestrial resources would be SMALL for all nuclear plants.

E4.6.8.2 Site-Specific Analysis for NAPS SLR The NRC identified certain activities or conditions for impacts to terrestrial resources as a consequence of operation of a plants cooling water system. Dominion plans to continue to operate the cooling water system as currently configured through the proposed SLR period.

These activities or conditions are identified below, along with NAPS-specific information.

• Physical alterations include increased water temperatures, humidity, and fogging:

o NAPSs VPDES permit establishes conditions for operation of the cooling water system based on ambient water temperature of Lake Anna and discharge temperature limits. These permit conditions limit the extent that discharge temperature can be above ambient, minimizing humidity and fogging. There have been no NOVs related to the VPDES permit in the past five years, but a warning letter was received for a missed TSS monitoring requirement at Outfall 103.

• Reduced water availability due to surface water use:

o The cooling water source is Lake Anna. The NAPS VPDES permit (No. VA0052451) governs releases from the North Anna Dam. The permit requires Dominion to operate in accordance with standard operating procedures.

• Contaminants in surface water:

o Discharges are governed by NAPSs VPDES permit. There have been no NOVs related to the VPDES permit in the past five years, but a warning letter was received for a missed TSS monitoring requirement at Outfall 103.

• Reduced water availability due to groundwater withdrawals:

o Not applicable to NAPS because the cooling water source is Lake Anna, not groundwater.

• Contaminants in groundwater; potential for groundwater quality degradation by contaminants present in cooling ponds and cooling canals:

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 37 of 90 o Not applicable to NAPS because the cooling system does not have cooling ponds or cooling canals.

• Disturbance of wetlands from maintenance dredging of onsite cooling ponds, disposal of dredged material from such dredging:

o Not applicable to NAPS because the cooling system does not have cooling ponds or cooling canals.

o NAPS does not conduct maintenance dredging for the North Anna Reservoir, the WHTF, the intake area, or the discharge canal (Dominion. 2020a). No dredging is anticipated during the SLR term.

• Erosion of shoreline wetlands:

o Figure E3.7-2 of the NAPS SLR ER shows the National Wetlands Inventory mapped wetlands within the NAPS site (Dominion. 2020a). There are no wetlands along the south bank where the discharge is located.

• Impingement of waterfowl at the cooling water intakes:

o None of the recorded bird deaths/injuries occurring between 2013 and 2022 were a result of impingement at the intake.

In summary, adequate regulatory controls are in place to ensure that terrestrial resources are protected during the proposed NAPS SLR operating term.

Dominion finds that impacts to terrestrial resources for the proposed SLR term would be SMALL.

Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.6.9 BIRD COLLISIONS WITH PLANT STRUCTURES AND TRANSMISSION LINES - ISSUE 26, TABLE E4.0-1 E4.6.9.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.6.1.1]

In the 2013 license renewal GEIS, the NRC reviewed the impact on avian mortality from birds colliding with cooling towers and transmission lines by reviewing the primary literature for avian collision mortality associated with all types of man-made objects, as well as the results of monitoring studies conducted at six nuclear plants. The NRC found that collision mortality associated with nuclear plant structures and transmission lines represents only a fraction of the total annual bird collision mortality from all man-made sources. In addition, there are no reports of relatively high collision mortality occurring at the transmission lines associated with nuclear power plants in the United States.

E4.6.9.2 Site-Specific Analysis for NAPS SLR All in-scope transmission lines subject to the evaluation of environmental impacts for license renewal are located completely within the NAPS site boundaries (Dominion. 2020a). The in-scope transmission lines at NAPS are mainly within industrial areas, where vegetation is sparse. Given Page-E-4-37

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 38 of 90 the lower profile of plant structures and the short distance of the in-scope transmission lines at the site, these structures would not likely pose a bird collision hazard beyond that considered in the 2013 GEIS.

Dominions avian migratory bird guidance document describes the companys practices and measures to avoid and minimize risk of avian collision with transmission lines (Dominion. 2020a).

Avian deaths are recorded, and, per procedures, Dominion Biology is contacted so that any necessary notifications to appropriate agencies can be made. An assessment is conducted to determine if any mitigation measures are warranted. NAPS staff has reported discovery of seven deceased birds at a variety of NAPS structures from 2013-2017. From 2018 to April 2022, there have been 19 recorded bird deaths across the NAPS site. This low occurrence of avian deaths would indicate that none of the NAPS structures have a significant impact on the local or migratory bird populations.

Further, NAPS has not proposed any refurbishment activities or construction of new facilities related to SLR. Therefore, bird collisions with plant structures and transmission lines are not expected to affect local or migratory bird populations during the proposed SLR term.

Given the low occurrence in bird deaths at the NAPS site, Dominions avian protection plan, and NAPSs adherence to regulatory and permit requirements for protected species including migratory birds, Dominion finds that impacts from bird collisions with plant structures and transmission lines for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.6.10 TRANSMISSION LINE RIGHT-OF-WAY MANAGEMENT IMPACTS ON TERRESTRIAL RESOURCES - ISSUE 27, TABLE E4.0-1 E4.6.10.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.6.1.1]

NRC reviewed the impacts of transmission line right-of-way (ROW) management on terrestrial resources and found that, although the initial habitat destruction associated with ROW clearing can have numerous consequences on wildlife populations, the proper management of transmission line ROW areas does not have significant adverse impacts on current wildlife populations and that ROW management can provide valuable wildlife habitats. The NRC noted that continued ROW management during the license renewal term will not lower habitat quality or cause significant changes in wildlife populations in the surrounding habitat. Therefore, the NRC concluded that the impact of continued transmission line ROW management on terrestrial resources is SMALL for all nuclear plants.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 39 of 90 E4.6.10.2 Site-Specific Analysis for NAPS SLR All in-scope transmission lines subject to the evaluation of environmental impacts for license renewal are located completely within the NAPS site boundaries. The in-scope transmission line spans a short distance between the generating units and the switchyard, crossing the intake, the sediment ponds, and industrial areas with sparse vegetation; they do not cross agricultural fields, pastures, or wildlife habitat. (Dominion. 2020a)

In-scope transmission lines at NAPS are maintained for vegetation which includes mowing and selective herbicide application (i.e., an integrated vegetation management program). In areas where mowing is impractical or undesirable (e.g., densely vegetated areas), hand-cutting and/or non-restricted use herbicides are used. Only state-licensed contractors apply commercially approved pesticide/herbicide applications onsite (Dominion. 2020a). Further, Dominion has partnered with the Virginia Department of Conservation and Recreation Natural Heritage Division to protect areas of rare, threatened, and endangered plant species along the transmission ROWs. Locations of rare or sensitive plant species are marked on the cutting sketches that Dominion maintains for all its transmission lines. These cutting sketches, along with specifications regarding herbicide use and brush control, are provided to corridor maintenance contractors so that adverse impacts on rare and sensitive species and habitats can be avoided. (Dominion. 2020a)

NAPS has administrative policies and implements BMPs for preventing erosion from soil disruption related to maintenance and management.

Due to the high levels of disturbance and human presence, wildlife use of areas along the in-scope transmission lines is likely to remain minimal. Because of the highly mobile nature of most wildlife species, any potential displacement from corridor management will be temporary. High levels of disturbance can increase presence of invasive species. Dominion maintains a management plan for invasive species found at their plants (Dominion. 2020a).

Management of the in-scope transmission lines is not likely to affect terrestrial resources.

Implementation of BMPs combined with limited resources within the ROW would mitigate impacts to terrestrial resources from NAPSs continued operations.

Dominion finds that impacts to terrestrial resources from transmission ROW management for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 40 of 90 E4.6.11 ELECTROMAGNETIC FIELDS ON FLORA AND FAUNA (PLANTS, AGRICULTURAL CROPS, HONEYBEES, WILDLIFE, LIVESTOCK) -

ISSUE 28, TABLE E4.0-1 E4.6.11.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.6.1.1]

In the 2013 license renewal GEIS, the NRC reviewed the impacts of EMFs on flora and fauna and concluded that no significant impacts of EMFs emitted on terrestrial biota have been identified.

Although foliage very close to lines can be damaged, the overall productivity and reproduction of native and agricultural plants appear unaffected. Also, no evidence suggests significant impacts on individual animals or wildlife populations that are chronically exposed to EMFs under transmission lines or in the towers. Livestock behavior and production also appear unaffected by line operation. Therefore, the potential impact of EMFs on terrestrial biota is expected to be of SMALL significance for all plants.

E4.6.11.2 Site-Specific Analysis for NAPS SLR The in-scope transmission lines span a distance of approximately 2,700 feet, including the distance between the generating units and the switchyard, crossing the intake, the sediment ponds, and industrial areas with sparse vegetation. Therefore, the in-scope lines do not cross agricultural fields, pastures, and wildlife habitat, and exposure to flora and fauna from EMFs due to the in-scope transmission lines would be incidental and minimal. (Dominion. 2020a)

The highest voltage of the in-scope transmission lines at the NAPS site is 500-kV. Dominion has not proposed any refurbishment activities or construction of new facilities related to SLR. The NRCs 2013 literature search on the issue indicated that the EMFs produced by operating transmission lines up to 1,100-kV have not been reported to have any biologically or economically significant impact on plants, wildlife, agricultural crops, or livestock. (Dominion. 2020a)

Given that in-scope transmission lines are confined to developed areas and are of a voltage not reported to have any biologically significant impact on plants, wildlife, agricultural crops, or livestock, the EMFs emitted by the NAPS in-scope transmission lines would have no impact on flora and fauna.

Dominion finds that impacts to flora and fauna from electromagnetic fields for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 41 of 90 E4.6.12 ENTRAINMENT OF PHYTOPLANKTON AND ZOOPLANKTON (ALL PLANTS) - ISSUE 30, TABLE E4.0-1 E4.6.12.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

In the 2013 license renewal GEIS, the NRC reviewed the entrainment of phytoplankton and zooplankton and found that due to no change in operation of the cooling system during the license renewal term, no change in effects on entrainment of phytoplankton and zooplankton was anticipated. Therefore, the NRC determined that entrainment of phytoplankton and zooplankton is expected to have a SMALL impact on populations of these organisms in source water bodies for all plants.

E4.6.12.2 Site-Specific Analysis for NAPS SLR Previous aquatic community studies during operational years at NAPS demonstrated that entrainment of zooplankton and phytoplankton is not significantly detrimental to zooplankton and phytoplankton populations in Lake Anna. The initial license renewal EIS for NAPS did not identify any new and significant information on this issue (Dominion. 2020a).

Dominion monitors the health of Lake Anna fishery through annual biological sampling required under the NAPS VPDES permit. The latest data from 2019 and 2020, with respect to species richness, diversity, water quality, and relative abundance of fishes, indicate that Lake Anna, WHTF, and river downstream of the lake continue to support a healthy and balanced fisheries community. The annual studies continue to support the 316(a) demonstration that the operation of NAPS has not resulted in significant harm to the biological community and the data do not identify any negative impacts from the operation of NAPS.

Further, the Virginia Department of Game and Inland Fisheries (VDGIF) manages the fisheries of Lake Anna. The VDGIF monitors the abundance of fish species through annual electrofishing or net sampling and makes fish stocking decisions accordingly. Monitoring results from 2016 indicate the fishery to be balanced and diverse with no sustained negative trends in abundance.

(Dominion. 2020a) The State of Lake Anna Report authored by the Lake Anna Advisory Committee in 2019 states fishing on the lake to be very good and has been for several years (LAAC. 2019).

There are no plant operations or modifications planned for the proposed SLR operating term that would alter the cooling water system in a manner that would result in increased impingement and/or entrainment of aquatic organisms (Dominion. 2020a). Further, no plans for SLR-related refurbishment activities have been identified. As such, based on previous impingement and entrainment studies and ongoing annual ecological monitoring (including new information of 2020-2021 environmental monitoring results), Dominion finds that impacts to phytoplankton and zooplankton for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with Page-E-4-41

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 42 of 90 respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.6.13 INFREQUENTLY REPORTED THERMAL IMPACTS (ALL PLANTS) -

ISSUE 32, TABLE E4.0-1 E4.6.13.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

In the 2013 license renewal GEIS, the NRC reviewed infrequently reported thermal impacts for all nuclear plants. Potential effects common to the operation of nuclear power plant cooling systems considered by NRC in the license renewal GEIS as infrequently reported thermal impacts are listed below, along with a description of the effect. The mitigation measures identified for the thermal effect are also included in the description and/or the standard used by NRC to classify the impacts of the effect as being of SMALL significance. The NRCs review revealed only SMALL levels of impact in the aquatic resources due to the infrequently reported thermal impacts and expects the same at all plants.

Cold shock: Cold shock can occur when organisms acclimated to the elevated temperatures of a thermal plume are abruptly exposed to temperature decreases when thermal effluent stops. Such events are most likely to occur during winter. Cold shock events have only rarely occurred at nuclear plants. Gradual shutdown of plant operations generally precludes cold shock events.

Creation of thermal plume migration barriers: The potential exists for thermal plumes to create a barrier to migrating fish if the mixing zone covers an extensive cross-sectional area of a river and exceeds the fish avoidance temperature. A demonstration of the size of the cross section being small enough to allow passage could indicate a SMALL impact.

Changes in the distribution of aquatic organisms: Impacts of thermal discharges on the geographic distribution of aquatic organisms are considered of SMALL significance if populations in the overall region are not reduced.

Accelerated development of aquatic insect maturation: Heated effluents could accelerate the development of immature stages of aquatic insects in freshwater systems, resulting in premature emergence. If adults emerge before the normal seasonal cycle, they may be unable to feed or reproduce. The NRC did not describe any occurrences of this effect at nuclear power plants and acknowledged that the literature search indicated it had not been observed in field investigations.

The NRC also included the stimulation of population growth of macroinvertebrates from heated effluents under this effect.

Stimulation of the growth of aquatic nuisance species: An aquatic nuisance species is a non-indigenous species that threatens the diversity or abundance of native species or the ecological stability of infested waters, or commercial, agricultural, aquacultural, or recreational activities dependent on such waters. Thermal discharges can allow nuisance species, such as the Asiatic clam (Corbicula fluminea) and zebra mussel (Dreissena polymorpha), to become established or Page-E-4-42

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 43 of 90 proliferate. The effects of stimulating the growth of nuisance organisms are considered to be of SMALL significance to aquatic resources if these organisms are restricted to the condenser cooling system (e.g., Asiatic clam; zebra mussel) or do not proliferate beyond the immediate vicinity of the plant.

E4.6.13.2 Site-Specific Analysis for NAPS SLR The activities or conditions NRC identified above in the background discussion for this issue as a consequence of operation of a plants cooling water system thermal discharge are listed below along with applicable NAPS information.

Cold shock: The thermal discharge is directed to the WHTF where it cools before entering the reservoir. By the time it gets to the reservoir, the discharge has cooled to the point that cold shock in the reservoir due to a forced outage at NAPS would be unlikely. Discharges are also governed by the NAPS VPDES permit which establishes conditions for operation of the cooling water system based on ambient water temperature of Lake Anna and discharge temperature limits.

Further, as part of a larger post-316(a) demonstration environmental monitoring effort that includes fish population studies, Dominion has continued to monitor Lake Anna water temperatures, using fixed temperature recorders at various stations. There have been no NOVs related to the VPDES permit in the past five years, but a warning letter was received for a missed TSS monitoring requirement at Outfall 103. The 2020 studies were performed to address the requirements of the VPDES permit for North Anna Power Station and continue to support the 316(a) demonstration for the station that the operation of the power station has not resulted in significant harm to the biological community. The 2020 annual monitoring report states that the temperature data recorded in Lake Anna were within the historical minimum and maximum temperatures and the lake stratifies and mixes seasonally as expected, and that the fisheries are diverse, being represented by multiple species and in numbers that are in balance.

Creation of thermal plume migration barriers: The thermal discharge associated with NAPS discharge has been demonstrated to be protective of the Lake Anna fishery and this demonstration continues to be supported by annual biological studies and temperature readings and trends.

Changes in the distribution of aquatic organisms: Dominions annual monitoring results have no indications of adverse impacts to aquatic biota in Lake Anna.

Accelerated development of aquatic insect maturation: In the LR GEIS, the NRC did not describe any occurrences of this effect at nuclear power plants and acknowledged that the literature search indicated it had not been observed in field investigations. The NRC also included the stimulation of population growth of macroinvertebrates from heated effluents under this effect.

Of the aquatic plants and animals, only the hydrilla, northern snakehead, and Asian clam are known to be present at the NAPS site. These species have wide distributions that are not dependent on warmed waters. In several areas, the occurrence of scattered populations of Asiatic clams is located near power plants, suggesting that other factors like warm water discharge may Page-E-4-43

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 44 of 90 create situations that allow for sustained populations. Further, to address invasive species concerns, Dominion has worked with local stakeholders, including VDGIF, to develop a hydrilla management plan as well as has established practices regarding snakeheads in alignment with VDGIF requirements. (Dominion. 2020a)

There are no plant operations or modifications planned for the proposed SLR operating term that would alter discharge structures or thermal discharges.

Dominion finds that infrequently reported thermal impacts for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.6.14 EFFECTS OF COOLING WATER DISCHARGE ON DISSOLVED OXYGEN, GAS SUPERSATURATION, AND EUTROPHICATION -

ISSUE 33, TABLE E4.0-1 E4.6.14.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

In the 2013 license renewal GEIS, the NRC reviewed the potential effects on aquatic biota from low dissolved oxygen levels, gas supersaturation (gas bubble disease), and eutrophication for nuclear power plant cooling water discharges. The addition of a heat load to an aquatic ecosystem via the discharge of cooling water has the potential to stress aquatic biota by simultaneously increasing metabolic rates and the need for oxygen and by reducing dissolved oxygen concentrations to sub-optimal levels. The potential for effects on biota from a reduction in the dissolved oxygen concentration is greater in ecosystems where dissolved oxygen levels are already approaching sub-optimal levels as a result of other factors that affect the environment.

Thus, organisms in ecosystems where (1) the biological demand for dissolved oxygen is elevated as a result of increased levels of detritus or nutrients (e.g., eutrophication from runoff containing fertilizers or manure or from the release of dead, entrained organisms in the discharge of once-through cooling systems); or (2) low flow levels and high ambient temperatures already exist (e.g.,

as a result of drought conditions or hot weather) may be more susceptible to negative effects if dissolved oxygen levels are reduced further. For this reason, the EPA and states often regulate dissolved oxygen to ensure that minimum levels will be maintained.

In addition to the effects of cooling systems on dissolved oxygen described above, the NRC reviewed the potential for impacts to aquatic organisms from gas bubble disease. The rapid heating of water in the condenser cooling system also decreases the solubility and saturation point for other dissolved gases. Thus, as the water passing through the cooling system is heated, the water becomes supersaturated with gases. Although the levels of dissolved gases will return to normal values as the water cools and mixes with ambient waters, tissues of aquatic organisms that remain in the supersaturated effluent for extended periods can become equilibrated to the Page-E-4-44

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 45 of 90 increased partial pressures of gases within the effluent. If these organisms are subsequently exposed to water with lower partial pressures (which occurs when the water cools or when the organisms move to water in other locations or at other depths), dissolved gas (especially nitrogen) within the tissues may come out of solution and form embolisms (bubbles) within the affected tissues, most noticeably the eyes and fins. The resulting condition is known as gas bubble disease.

In the 2013 GEIS, the NRC concluded that there would be no change in effects of low dissolved oxygen concentrations or gas supersaturation on aquatic biota during the license renewal term in the absence of changes to operation of the cooling system or the ambient conditions. Overall, the NRC concluded that impacts of plant operation on low dissolved oxygen concentrations and gas supersaturation attributable to cooling water discharges would be SMALL for all plants.

E4.6.14.2 Site-Specific Analysis for NAPS SLR Discharges are governed by the NAPS VPDES permit which establishes conditions for operation of the cooling water system based on ambient water temperature of Lake Anna and discharge temperature limits. As part of continuing the 316(a) demonstration environmental monitoring effort that includes fish population studies, Dominion reports Lake Anna water temperatures, using fixed temperature recorders at various stations. These long-term temperature data do not indicate an overall warming trend in the lake. The 2020 studies were performed to address the requirements of the VPDES permit for North Anna Power Station and continue to support the 316(a) demonstration for the station that the operation of the power station has not resulted in significant harm to the biological community. The 2020 annual monitoring report states that the temperature data recorded in Lake Anna were within the historical minimum and maximum temperatures and the lake stratifies and mixes seasonally as expected, and that the fisheries are diverse, being represented by multiple species and in numbers that are in balance.

The VPDES permit also includes limits and monitoring requirements for water quality parameters implicated in eutrophication (nitrogen and biological oxygen demand) (Dominion. 2020a, Table E3.6-2).

Lake Anna experienced harmful algae blooms in several different areas in 2018 during the recreational swimming season (Dominion. 2020a). The VDH issued warnings and no-swimming advisories for select areas in Lake Anna. In addition, Dominion developed a sampling plan and initiated sampling based on the VDHs sampling protocol and issued no-swimming advisories for four WHTF areas. However, as a result of testing and evaluation performed in accordance with current VDH guidelines, all no-swimming advisories for the WHTF have been lifted as of July 25, 2019. Recreational users of the WHTF are advised to remain on alert for all algae blooms.

(Dominion. 2022c)

Harmful algae have occurred in water bodies that drain into upper Lake Anna and other water bodies north of Lake Anna without a confluence during this time period. The VDHs advisory on harmful algae stated that algae blooms can occur when warm water and nutrients combine to Page-E-4-45

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 46 of 90 make conditions favorable for algae growth. These conditions have occurred recently, particularly excessive rain. Rain typically results in nutrient-runoff from the land that can trigger algae blooms in natural waters. The wide occurrence of harmful bacteria in the region surrounding NAPS, particularly in water bodies upstream of Lake Anna and those without a confluence, indicates that the algae blooms were a result of water temperatures and other environmental conditions (e.g.,

nutrient load from runoff) rather than a nexus with thermal discharge from NAPS. (VDH. 2018)

Dominion continues to test, monitor, and communicate with regulatory authorities in order to quickly provide notification if an algal bloom occurs that could pose a health risk.

To summarize, discharges to Lake Anna are subject to NAPSs VPDES permit, and there have been no NOVs related to the VPDES permit in the past five years, but a warning letter was received for a missed TSS monitoring requirement at Outfall 103. Annual monitoring of water quality, water temperatures, and fishery of the lake continues to show compliance with regulatory requirements. Further, occurrence of harmful algae blooms in Lake Anna in 2018 was a result of increased water temperatures and nutrient load as opposed to operations of NAPS. Therefore, compliance with and implementation of regulatory requirements will continue to control the effects of cooling water discharge from NAPS.

Dominion finds that effects of cooling water discharge on dissolved oxygen, gas supersaturation, and eutrophication for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.6.15 EFFECTS OF NON-RADIOLOGICAL CONTAMINANTS ON AQUATIC ORGANISMS - ISSUE 34, TABLE E4.0-1 E4.6.15.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

The potential for nonradiological contaminants to accumulate in sediments or aquatic biota was identified as a Category 1 issue in the 1996 GEIS. This was originally raised as an issue of concern at a few power plants that used copper alloy condenser tubes, but this concern has been successfully mitigated by replacing copper alloy tubes with those made from other metals (e.g.,

titanium). An operating nuclear power plant can contribute other contaminants by concentrating existing constituents from the water body (e.g., in blowdown at closed-cycle plants) or by the addition of chemicals to cooling water during plant operations (e.g., biocides). Concentrations of heavy metals and other contaminants in the discharges of nuclear power plants are normally quickly diluted or flushed from the area by the large volumes of the receiving water. The discharge of metals and other toxic contaminants may also be subject to controls implemented by state or federal agencies through the NPDES permit process. Impacts of contaminant discharges are considered to be of SMALL significance if water quality criteria (e.g., NPDES permits) are not violated and if aquatic organisms in the vicinity of the plant are not bioaccumulating the contaminants.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 47 of 90 E4.6.15.2 Site-Specific Analysis for NAPS SLR Condensers at NAPS are equipped with an Amertap system that circulates sponge rubber balls through the condenser tubes to prevent the accumulation of deposits (such as biofouling organisms). Amertap balls are slightly larger than the inside diameter of the condenser tubes; they are collected from the outlet stream and reused. No chemical biocides are used in the circulating water system (Dominion. 2001, Section 3.1.2.1). Chemical additives approved by the VDEQ are used to control pH, scale, corrosion, and biofouling of various plant equipment. Process wastewaters are monitored and discharged either directly to the North Anna Reservoir or to the North Anna Reservoir via the WHTF in accordance with the NAPS VPDES Permit. The effluent from the cooling and SWS is subject to the VPDES permit. The lack of effluent toxicity is supported by Whole Effluent Toxicity testing per the VPDES permit, which has been performed for the cooling water discharge from NAPS over several years. The internal Outfall 105 for the bearing cooling tower blowdown has limits and monitoring requirements for zinc and chromium (Dominion.

2020a, Attachment B).

A review of records from 2013-2022 for spill notification and environmental compliance at NAPS showed two leaks: one underground fuel leak in 2016 that led to pipe replacement and one mineral oil spill from a pad mounted transformer in 2021 that was remediated to address applicable state and federal regulations. No NOVs were received from 2013-2022, but a warning letter was received for a missed TSS monitoring requirement at Outfall 103. (Dominion. 2020a)

The impacts to surface water from metals and biocides in the cooling water discharge would be SMALL (Dominion. 2020a). There are no plant operations or modifications planned for the proposed SLR operating term that would alter discharge patterns. Compliance with regulatory, permit, and license requirements would ensure small impacts from scouring.

Dominion finds that effects of non-radiological contaminants on aquatic organisms for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.6.16 EXPOSURE OF AQUATIC ORGANISMS TO RADIONUCLIDES - ISSUE 35, TABLE E4.0-1 E4.6.16.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

Pathways for aquatic biota exposure considered by the NRC in 2013 included that aquatic biota can be exposed externally to ionizing radiation from radionuclides in water, sediment, and other biota, and aquatic biota can be exposed internally via ingested food and water and, in certain situations, absorption through the skin and respiratory organs. No evidence of significant differences in sensitivity to radionuclides between marine and freshwater organisms has been reported. Some radionuclides tend to follow pathways similar to their nutrient analogs and can Page-E-4-47

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 48 of 90 therefore be transferred rapidly through the food chain. These include (1) radionuclides such as strontium-90, barium-140, radon-226, and calcium-46 that behave like calcium and are therefore accumulated in bony tissues; (2) radionuclides such as iodine-129 and iodine-131 that act like stable iodine and accumulate in thyroid tissue; (3) radionuclides such as potassium-40, cesium-137, and rubidium-86 that follow the general movement of potassium and can be distributed throughout the body; and (4) radionuclides such as tritium, which resembles stable hydrogen, that is distributed throughout the body of the organism.

In the 2013 GEIS, the NRC conducted a review of all operating nuclear power plants to evaluate the potential impacts of radionuclides on aquatic biota from continued operations. The NRC selected 15 representative plants to calculate estimated dose rates for aquatic biota. The total estimated dose rates for aquatic biota for these plants were all less than 0.2 rad/d (0.002 Gy/d),

considerably less than the U.S. Department of Energys (DOE) guideline value of 1 rad/d (0.01 Gy/d). On the basis of the reviewed literature and the dose rates estimated for aquatic biota from site-specific data, the NRC concluded that the impact of radionuclides on aquatic biota from past operations would be SMALL for all plants, and it would not be expected to change appreciably during the renewal period.

E4.6.16.2 Site-Specific Analysis for NAPS SLR NAPS operates in accordance with its license. Releases are maintained in compliance with 10 CFR Part 20 limits and reported in annual radioactive effluent release reports submitted to the NRC. In addition, NAPS conducts sampling in accordance with its REMP. The NAPS REMP is designed to provide representative measurements of radiation and of radioactive materials through various media exposure pathways. The REMP includes annual water and aquatic exposure pathway samplings including precipitation, surface, river and well water, silt and shoreline sediments, and fish.

Based on the results of the 2021 monitoring, Dominion concluded that the operation of NAPS created no adverse environmental effects, similar to previous years. The average tritium activity in surface water for the last four years (2018-2021) ranged between 2658 and 4980 picoCuries per liter (pCi/l). River water collected from the North Anna River, 5.8 miles downstream of the site, had an average tritium level ranging between 2610 and 5003 pCi/l over the same four-year period.

However, no plant related isotope was detected in fish samples from either Lake Anna or the control location, Lake Orange, during the same time period. Silt and shoreline soil samples indicated the presence of potassium-40 and thorium and uranium decay daughters at levels consistent with the natural background. (Dominion. 2022b)

The NRC conducted a site-specific analysis of potential impacts to non-human biota for two additional units at the NAPS site in the early site permit EIS, NUREG-1811 (Dominion. 2020a).

NRC also concluded with regard to cumulative impacts inclusive of the effluents from Units 1 and 2 that the cumulative effects would result in dose rates significantly less than the IAEA and National Council on Radiation Protection and Measurements studies. Thus, the analysis showed Page-E-4-48

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 49 of 90 that the total cumulative dose from gaseous and liquid effluent from four units was well below guideline values for protection of biota populations. (Dominion. 2020a)

Continued compliance with NRC radiological effluent limits and implementation of the REMP will ensure that aquatic organisms exposure to radionuclides is well within guidelines and adverse trends are detected to implement corrective actions.

Dominion finds that exposure of aquatic organisms to radionuclides for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.6.17 EFFECTS OF DREDGING ON AQUATIC ORGANISMS - ISSUE 36, TABLE E4.0-1 E4.6.17.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

Dredging is an activity that is performed at some power plants to remove accumulated sediments from intake and discharge areas (or, more rarely, to maintain barge slips) and may have localized impacts on aquatic biota. The impacts of dredging were not evaluated in the 1996 GEIS. NRC reviewed potential impacts to aquatic organisms from dredging operations to support nuclear power plant operations and anticipated that maintenance dredging would occur infrequently, would be of relatively short duration, would affect relatively small areas, and would be primarily undertaken in areas containing soft sediments that would be recolonized fairly rapidly by benthic organisms in surrounding areas. NRC also considered that the levels of chemical and radionuclide contamination of sediments in the areas near power plant intakes and discharges that would need to be dredged are likely to be relatively low. The NRC considered compliance with USACE, and applicable state permits sufficient to mitigate any impacts to a SMALL significance.

E4.6.17.2 Site-Specific Analysis for NAPS SLR NAPS does not periodically dredge at Lake Anna and does not anticipate dredging during the proposed SLR operating term. Any dredging proposed is small scale and located at the upper fingers of the lake for recreational navigation purposes. None of the dredging is a Dominion activity: it is all associated with private landowners. However, should any dredging needs arise for plant operations, Dominion would obtain the necessary federal and state permits. Compliance with regulatory requirements and permit conditions will ensure continued minor impact from discharges.

Dominion finds that effects of dredging on aquatic organisms for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as Page-E-4-49

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 50 of 90 supplemented above, materially consistent with the conclusions in the previously submitted environmental report (Dominion. 2020a).

E4.6.18 EFFECTS ON AQUATIC RESOURCES (NON-COOLING SYSTEM IMPACTS) - ISSUE 37, TABLE E4.0-1 E4.6.18.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

Impacts on aquatic resources from continued operations and refurbishment activities could occur at all operating nuclear power plants during the license renewal term as a result of (1) direct disturbance (e.g., ground disturbance, draining ponds, blocking or redirecting streams, and placing riprap along shorelines) of aquatic habitats within project areas; (2) sedimentation of nearby aquatic habitats as a consequence of soil erosion; (3) changes in water quantity or water quality (e.g., grading that affects surface runoff patterns or depletions or discharges of water into aquatic habitats); or (4) releases of chemical contaminants into nearby aquatic systems. In the 2013 license renewal GEIS, the NRC reviewed these activities and their effects under this issue as listed above, with the understanding that permits from various federal, state, and local governmental authorities are typically required for ground-disturbing activities and with proper application of environmental reviews, permitting processes, and BMPs, impacts on sensitive aquatic habitats would likely be avoided. With this understanding, the NRC concluded that the impact of continued operations and refurbishment activities on aquatic resources would be SMALL.

E4.6.18.2 Site-Specific Analysis for NAPS SLR NAPS has procedures and plans in place to address concern for the potential for impacts to onsite and nearby aquatic habitats as a consequence of site disturbance, soil erosion, changes in water quality, or releases of chemical contaminants as detailed below. NAPS has administrative procedures that establish the policies and general requirements for ongoing operations, maintenance, and construction activities to be conducted in accordance with the NAPS environmental protection plan, and applicable federal, state, and local regulations and permit conditions.

NAPS has not proposed any refurbishment activities or construction of new facilities related to SLR. Land disturbance for continued operations at NAPS would be related to routine infrastructure maintenance and renovation activities to maintain and upgrade or replace infrastructure and structures as needed to support NAPS operations. Dominion has established specific procedures and guidance to address ground disturbance from any activity to ensure compliance with regulations and permit requirements for erosion and sediment control, stormwater, and wetlands and wetland buffers (Dominion. 2020a), The VDEQ requires implementation of BMPs to prevent and control sedimentation and silting of waterways and wetlands and stabilization of soils and stormwater management and controls.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 51 of 90 Further, NAPS does not conduct routine dredging at Lake Anna that would result in the release of sediments to aquatic resources. Should any dredging needs arise for plant operations, Dominion would obtain the necessary federal and state permits.

NAPS maintains and implements a SWPPP that identifies potential sources of pollution (such as erosion) that would reasonably be expected to affect the quality of stormwater and identifies BMPs that will be used to prevent or reduce the pollutants in stormwater discharges (Dominion. 2020a).

Construction and maintenance activities undertaken during the SLR period that would involve ground disturbance would be required to have a separate SWPPP, in accordance with a VPDES stormwater permit from construction activities. In addition, NAPS has an SPCC plan and a fleet chemical control procedure and waste management procedure.

A review of records from 2013-March 2022 for spill notification and environmental compliance at NAPS showed two leaks: one underground fuel leak in 2016 that led to pipe replacement and one mineral oil spill from a pad mounted transformer in 2021 that was remediated to address applicable state and federal regulations. These spills did not lead to NOVs (Dominion. 2020a, Sections E9.3 and E9.4).

Compliance with regulatory requirements and permit conditions, implementation of a SWPPP, and implementation of BMPs will ensure that the potential for impacts to nearby aquatic habitats as a consequence of soil erosion, changes in water quality, or releases of chemical contaminants during the SLR term will likely be minor.

Dominion finds that impacts to aquatic resources for the proposed SLR term would be SMALL.

Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.6.19 IMPACTS OF TRANSMISSION LINE RIGHT-OF-WAY MANAGEMENT ON AQUATIC RESOURCES - ISSUE 38, TABLE E4.0-1 E4.6.19.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

This is a new issue added by the 2013 GEIS. Continued operations and refurbishment activities will require management and maintenance of in-scope transmission lines and associated in-scope transmission line ROWs. Continued operations and refurbishment activities could result in negative impacts on aquatic resources within the ROW or from runoff associated with in-scope transmission line management and maintenance. In the 2013 license renewal GEIS, the NRC reviewed the impacts of transmission line ROW management on aquatic species and found that changes in aquatic species diversity, abundance, or health from transmission line ROW maintenance are likely to be SMALL. The continued use of proper management practices with respect to soil erosion and application of herbicides is expected. In addition, license renewal for a specific plant would affect only the portion of the transmission line that connects the power plant to the first substation, so the amount of aquatic habitat crossed is likely to be small.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 52 of 90 E4.6.19.2 Site-Specific Analysis for NAPS SLR The in-scope transmission lines are confined to the NAPS site and do not cross water bodies other than the plants intake area and the sediment ponds (Dominion. 2020a, Figure E2.2-5).

NAPS has administrative policies and implements BMPs for preventing erosion from soil disruption. The VPDES permit requires NAPS to implement BMPs to protect surface water and groundwater from runoff of pollutants and loose soil in industrial areas. In addition, maintenance of vegetation beneath the in-scope transmission line includes herbicide application that follows Dominions chemical control program. Only state-licensed contractors apply commercially approved pesticide/herbicide applications onsite. (Dominion. 2020a)

Subsequent license renewal would not likely affect threatened, endangered, and protected species in the vicinity of NAPS, and mitigation measures beyond Dominions current management programs and existing regulatory controls are not warranted. (Dominion. 2020a)

NAPS has not proposed any refurbishment activities related to in-scope transmission lines as part of SLR.

Continued in-scope transmission line ROW management will maintain aquatic communities and resources in their current condition. Implementation of BMPs and adherence to vegetation management protocols will ensure minimal impact on aquatic resources from ROW management and maintenance.

Dominion finds that impacts of transmission line ROW management on aquatic resources for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.6.20 LOSSES FROM PREDATION, PARASITISM, AND DISEASE AMONG ORGANISMS EXPOSED TO SUBLETHAL STRESSES - ISSUE 39, TABLE E4.0-1 E4.6.20.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.5.1.1]

During the license renewal term, cooling system intake and discharge would continue to affect aquatic resources. Sub-lethal stresses can come from impingement, entrainment, thermal discharge, low dissolved oxygen levels, gas supersaturation in tissues, and exposure to radionuclides and nonradiological contaminants. Impacts such as increased susceptibility to predation, parasitism, and disease can increase for species exposed to sub-lethal stresses. The effects of low dissolved oxygen levels are not expected to be felt by aquatic species beyond the thermal mixing zone. It is anticipated that heavy metal concentrations and radionuclide releases related to normal plant operations would not result in negative effects on aquatic biota. Impacts Page-E-4-52

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 53 of 90 on the susceptibility of aquatic organisms to predation, parasitism, and disease due to sub-lethal stresses are considered to be of SMALL significance if changes are localized and populations of aquatic organisms in the receiving water body are not reduced. Indirect power plant-induced mortality has not been shown to cause reductions in the overall populations of aquatic organisms near any existing nuclear power plants. The level of impact due to sub-lethal stresses has been SMALL at plants reviewed by the NRC in the 2013 GEIS and is expected to be SMALL for all nuclear plants.

E4.6.20.2 Site-Specific Analysis for NAPS SLR The stresses of impingement, entrainment, thermal discharge, low dissolved oxygen levels, gas supersaturation in tissues, and exposure to radionuclides and nonradiological contaminants are discussed under previous sections and summarized below:

• Surface water use and quality (non-cooling system impacts), Section E4.5.6: Compliance with current and future VPDES and stormwater regulatory requirements and permit conditions, and implementation of SWPPP, BMPs, and the SPCC plan will ensure an insignificant impact on surface water quality from non-cooling systems during the proposed SLR operating term. Compliance with water use permits and regulations would ensure an insignificant impact on surface water use.

• Altered current patterns at intake and discharge structures, Section E4.5.7: Based on the size of Lake Anna and the fact that there are no modifications planned that would alter the existing current pattern, impacts to surface water use and quality are SMALL.

• Discharge of metals in cooling system effluent, Section E4.5.10: The effluent from the cooling and SWS is subject to the VPDES permit. Compliance with the VPDES permit would ensure that impacts are SMALL.

• Discharge of biocides, sanitary wastes, and minor chemical spills, Section E4.5.11: Plant wastewater, sanitary wastewater, and stormwater discharges are governed by the NAPS VPDES permit. No chemical biocides, other than chlorine, are used in the circulating water system at NAPS (Dominion. 2020a). A review of records from 2013-2022 for spill notification and environmental compliance at NAPS showed two leaks: one underground fuel leak in 2016 that led to pipe replacement, and one mineral oil spill from a pad mounted transformer in 2021 that was remediated to address applicable state and federal regulations. No NOVs were received from 2013-2022, but a warning letter was received for a missed TSS monitoring requirement at Outfall 103. (Dominion. 2020a). Compliance with current and future VPDES regulatory requirements and permit conditions will ensure the impact of biocides and minor chemical spills to be SMALL.

• Temperature effects on sediment transport capacity, Section E4.5.14: The WHTF allows NAPS discharge to cool before returning it to the North Anna Reservoir. Temperature monitoring in Lake Anna has not indicated long-term warming trends. There are no plant operations or modifications planned for the proposed SLR operating term that would alter discharge structures or thermal discharges. Impacts to surface water resources including temperature effects on sediment transport capacity are SMALL.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 54 of 90

• Entrainment of phytoplankton and zooplankton, Section E4.6.12: Dominion complies with the current VPDES permit and will comply with future renewal of the permit, implementing any best technology available requirements determined necessary to minimize impacts of impingement and entrainment. Further, annual sampling and analysis (including information from the 2019 and 2020 annual environmental monitoring results) indicates that operation of NAPS is not having a negative impact on the fisheries of Lake Anna or the North Anna River. With continued compliance with VDEQ requirements, impacts from impingement and entrainment of aquatic organisms during the proposed SLR operating term would be SMALL.

• Effects of cooling water discharge on dissolved oxygen, gas supersaturation, and eutrophication, Section E4.6.14: Discharges are governed by the NAPS VPDES permit which establishes conditions for operation of the cooling water system based on ambient water temperature of Lake Anna and discharge temperature limits. Annual monitoring conducted does not indicate significant changes in the water quality of the cooling water discharge or any major long-term decreases in overall fish abundance and species diversity in Lake Anna. There have been no NOVs related to the VPDES permit in the past five years, but a warning letter was received for a missed TSS monitoring requirement at Outfall 103. Given that NAPS operates under conditions of a VPDES permit and that no site modifications are planned, the effects of cooling water discharge on dissolved oxygen, gas supersaturation, and eutrophication will be SMALL.

• Effects of nonradiological contaminants on aquatic organisms, Section E4.6.15: NAPS VPDES permit governs water treatment chemicals, and no chemical biocides are used in the circulating water system. The lack of toxicity to aquatic life is also supported by WET testing of the final cooling water discharge. Since no alterations are planned for the proposed SLR term and discharges would continue to be in compliance with the VPDES permit, effects of nonradiological contaminants on aquatic organisms will be SMALL.

• Exposure of aquatic organisms to radionuclides, Section E4.6.16: NAPS operates in compliance with NRC regulations. Based on the results of the 2021 monitoring, Dominion concluded that the operation of NAPS created no adverse environmental effects, similar to previous years. Continued compliance with NRC radiological effluent limits and implementation of the REMP will ensure that aquatic organisms exposure to radionuclides is well within guidelines and adverse trends are detected to implement corrective actions.

• Effects on aquatic resources (non-cooling system impacts), Section E4.6.18: Compliance with regulatory requirements and permit conditions, implementation of a SWPPP, and implementation of BMPs, will ensure minimal impacts to nearby aquatic habitats as a consequence of soil erosion, changes in water quality, or releases of chemical contaminants.

Consideration of the above issues would indicate sub-lethal stresses are not significantly impacting the aquatic resources in the vicinity of NAPS.

Dominion finds that losses from predation, parasitism, and disease among organisms exposed to sub-lethal stresses for the proposed SLR term would be SMALL. Based on the discussion Page-E-4-54

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 55 of 90 provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.8.1 EMPLOYMENT AND INCOME, RECREATION AND TOURISM - ISSUE 40, TABLE E4.0-1 E4.8.1.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.8.1.1]

Employees receive income from the nuclear power plant in the form of wages, salaries, and benefits. Employees and their families, in turn, spend this income on goods and services within the community, thereby creating additional opportunities for employment and income. In addition, people and businesses in the community receive income for the goods and services sold to the power plant. Payments for these goods and services create additional employment and income opportunities in the community. The measure of a communitys ability to support the operational demands of a power plant depends on the ability of the community to respond to changing socioeconomic conditions.

Some communities experience seasonal transient population growth due to local tourism and recreational activities. Income from tourism and recreational activities creates employment and income opportunities in the communities around nuclear power plants.

Nevertheless, the effects of nuclear power plant operations on employment, income, recreation, and tourism are ongoing and have become well established during the current license term for all nuclear power plants. The impacts from power plant operations during the license renewal term on employment and income in the region around each nuclear power plant are not expected to change from what is currently being experienced. In addition, tourism, and recreational activities in the vicinity of nuclear plants are not expected to change as a result of license renewal.

E4.8.1.2 Site-Specific Analysis for NAPS SLR There are no plans to add permanent workers to support plant operations during the license renewal term. No license renewal-related refurbishment activities have been identified.

(Dominion. 2020a) Because of its rural setting and heavily forested surroundings, the site does not visually impact areas that have a high degree of visitor use or recreational areas locally.

Therefore, no changes in employment and income, and recreation and tourism during the proposed SLR operating term are anticipated.

Because there are no anticipated changes to the operational workforce or the sites visual profile associated with plant structures or transmission lines during the SLR term, and no refurbishment is planned, the people living in the vicinity of NAPS are not likely to experience any changes in socioeconomic or aesthetic conditions during the proposed SLR term.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 56 of 90 Dominion finds that impacts to employment and income, recreation, and tourism for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.8.2 TAX REVENUES - ISSUE 41, TABLE E4.0-1 E4.8.2.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.8.1.2]

Nuclear power plants and the workers who operate them are an important source of tax revenue for many local governments and public schools. Tax revenues from nuclear power plants mostly come from property tax payments or other forms of payments such as payments in lieu of (property) taxes, although taxes on energy production have also been collected from several nuclear power plants. County and municipal governments and public-school districts receive tax revenue either directly or indirectly through state tax and revenue-sharing programs.

Counties and municipal governments in the vicinity of a nuclear power plant also receive tax revenue from sales taxes and fees from the power plant and its employees. Changes in the number of workers and the amount of taxes paid to county, municipal governments, and public schools can affect socioeconomic conditions in the counties and communities around the nuclear power plant.

A review of license renewal applications received by the NRC since the 1996 GElS has shown that license renewal-related refurbishment activities, such as steam generator and vessel head replacement, have not had a noticeable effect on the assessed value of nuclear plants, thus changes in tax revenues are not anticipated from future license renewal-related refurbishment activities.

The primary impact of license renewal would be the continuation or change in the amount of taxes paid by nuclear power plant owners to local governments and public schools. The impact of nuclear plant operations on tax revenues in local communities and the impact that the expenditure of tax revenues has on the region are not expected to change appreciably from the amount of taxes paid during the current license term. Tax payments during the license renewal term would be similar to those currently being paid by each nuclear plant.

E4.8.2.2 Site-Specific Analysis for NAPS SLR Tax payments for the years 2020-2022 can be found in Table E4.8-1. No license renewal-related refurbishment activities have been identified. Dominion plans to continue to operate NAPS as currently designed, and no associated changes to plant employment or NAPS taxable property value are anticipated. Therefore, Dominion's annual property taxes are expected to remain stable throughout the PEO with no notable future increases or decreases. This is assuming that certain Page-E-4-56

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 57 of 90 factors beyond Dominion Energys control, such as changes in tax rates and local assessment ratio, also remain stable. (Dominion. 2020a)

Because there are no anticipated changes to the operational workforce, no refurbishment is planned, and tax payments are expected to remain constant with no notable future increases or decreases, the people living in the NAPS region are not likely to experience any changes in socioeconomic conditions during the proposed SLR term.

Dominions finds that impacts to tax revenue for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.8.3 COMMUNITY SERVICES AND EDUCATION - ISSUE 42, TABLE E4.0-1 E4.8.3.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.8.1.3]

Any changes in the number of workers at a nuclear plant will affect the demand for public services from local communities. Environmental reviews conducted by the NRC since the 1996 GEIS have shown, however, that the number of workers at relicensed nuclear plants has not changed significantly because of license renewal, so demand-related impacts on community services, including public utilities, are no longer anticipated from future license renewals.

In addition, refurbishment activities, such as steam generator and vessel head replacement, have not required the large numbers of workers and the months of time that were conservatively analyzed in the 1996 GEIS, so significant impacts on community services are no longer anticipated. Because of the relatively short duration of refurbishment-related activities, workers are not expected to bring families and school-age children with them; therefore, impacts from refurbishment on educational services are also no longer anticipated.

Taxes paid by nuclear power plant owners support a range of community services, including public water, safety, fire protection, health, and judicial, social, and educational services. In some communities, tax revenues from power plants can have a noticeable impact on the quality of services available to local residents. Although many of the community services paid for by tax revenues from power plants are used by plant workers and their families, the impact of nuclear plant operations on the availability and quality of community services and education is SMALL and is not expected to change as a result of license renewal.

E4.8.3.2 Site-Specific Analysis for NAPS SLR No license renewal-related refurbishment activities have been identified. In addition, there are no plans to add workers to support plant operations during the proposed SLR operating term.

Dominion's annual property taxes are expected to remain relatively constant through the Page-E-4-57

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 58 of 90 proposed SLR operating term, and no change is anticipated that would impact local community services and education. (Dominion. 2020a)

Because no changes to employment are expected from continued operations, tax payments are anticipated to remain consistent throughout the SLR term, and no refurbishment activities are planned, the people living in the vicinity of NAPS are not likely to experience any changes in socioeconomic conditions during the proposed SLR term beyond the current conditions.

Dominion finds that impacts to community services and education for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.8.4 POPULATION AND HOUSING - ISSUE 43, TABLE E4.0-1 E4.8.4.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.8.1.4]

Socioeconomic impact analyses of resources (e.g., housing) affected by changes in regional population are based on employment trends at nuclear power plants. Population growth from increased employment and spending at a nuclear power plant is important because it is one of the main drivers of socioeconomic impacts. As previously discussed, however, employment levels at nuclear power plants are expected to remain relatively constant with little or no population growth or increased demand for permanent housing during the license renewal term. The operational effects on population and housing values and availability in the vicinity of nuclear power plants are not expected to change from what is currently being experienced, and no demand-related impacts are expected during the license renewal term.

The increased number of workers at nuclear power plants during regularly scheduled plant refueling and maintenance outages does create a short-term increase in the demand for temporary (rental) housing units in the region around each plant. However, because of the short duration and the repeated nature of these scheduled outages and the general availability of rental housing units (including portable trailers) in the vicinity of nuclear power plants, employment-related housing impacts have had little or no long-term impact on the price and availability of rental housing.

Refurbishment impacts would be similar to what is experienced during routine plant refueling and maintenance outages.

E4.8.4.2 Site-Specific Analysis for NAPS SLR No license renewal-related refurbishment activities have been identified. There are no plans to add permanent workers to support plant operations during the proposed SLR operating term.

(Dominion. 2020a)

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 59 of 90 Because no changes to employment are expected and no refurbishment activities are planned that would require additional workers, the people living in the vicinity of NAPS are not likely to experience any changes in population and housing conditions during the proposed SLR term.

Dominion finds that impacts to population and housing for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.8.5 TRANSPORTATION - ISSUE 44, TABLE E4.0-1 E4.8.5.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.8.1.5]

Transportation impacts depend on the size of the workforce, the capacity of the local road network, traffic patterns, and the availability of alternate commuting routes to and from the plant.

Because most sites have only a single access road, there is often congestion on these roads during shift changes.

Transportation impacts are ongoing and have become well established during the current licensing term for all nuclear power plants. As previously presented, it is unlikely that the number of permanent operations workers would increase at a nuclear power plant during the license renewal term. In addition, refurbishment activities, such as steam generator and vessel head replacement, have not required the numbers of workers and the months of time conservatively estimated in the 1996 GEIS. Consequently, employment at nuclear power plants during the license renewal term is expected to remain unchanged.

E4.8.5.2 Site-Specific Analysis for NAPS SLR Roads in the immediate vicinity of the NAPS plant site would continue to operate at acceptable levels of service. No license renewal-related refurbishment activities have been identified. There are no plans to add permanent workers to support plant operations during the SLR operating term. (Dominion. 2020a)

Because no changes to employment are expected and no refurbishment activities are planned that would require additional workers, the people living in the vicinity of NAPS are not likely to experience any changes in transportation conditions associated with NAPS during the proposed SLR term.

Dominion finds that impacts to transportation for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 60 of 90 Table E4.8-1 Annual Property Tax Payments, FY 2020-2022 FY Total Property Tax Percentage Operating County County FY Paid by of Total Budget for Property Tax Dominion Property Tax County Revenues Louisa County 2020 $63,583,869 $10,310,656 16% $84,064,080 2021 $65,807,819 $10,199,939 15% $91,068,235 2022 NYA NYA NYA NYA Spotsylvania County 2020 $186,098,542 $56,688 0.03% $321,426,447 2021 $190,977,802 $56,612 0.03% $324,037,360 2022 NYA NYA NYA NYA NYA = not yet available FY = fiscal year (LC. 2021; SC. 2020; SC. 2021)

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 61 of 90 E4.9.3 RADIATION EXPOSURES TO THE PUBLIC - ISSUE 45, TABLE E4.0-1 E4.9.3.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.9.1.1]

NRC regulations in 10 CFR Part 20 identify maximum allowable concentrations of radionuclides that can be released from a licensed facility to control radiation exposures of the public. In addition, pursuant to 10 CFR 50.36a, nuclear power reactors have special license conditions requiring minimization of radiological impacts associated with plant operations to as low as reasonably achievable (ALARA) levels. Nuclear power plant releases to the environment must also comply with EPA standards in 40 CFR Part 190. These standards specify limits on the annual dose equivalent from normal operations of uranium fuel-cycle facilities.

In the 2013 license renewal GEIS, the NRC reviewed industry-wide data on radioactive releases from nuclear power operations. NRC concluded based on this body of data and its oversight experience that, for normal operations, radioactivity releases would continue during a PEO similar to that of current operations (i.e., the first 40 years of operation). The NRC also reviewed radiation exposures to the public in the 2013 GEIS and concluded that experience with the design, construction, and operation of nuclear power reactors indicates that compliance with the design objectives of Appendix I to 10 CFR Part 50 will keep average annual releases of radioactive material in effluents at small percentages of the limits specified in 10 CFR Part 20 and 40 CFR Part 190. NRC also concluded that no aspect of future operation has been identified that would substantially alter this situation.

Although NRC concluded that dose rates of millirem per year (mrem/yr) are not expected to change during license renewal, NRC acknowledged that the cumulative dose (total mrem) would increase as a result of 20 more years of operations (i.e., 40-60 years). The cumulative dose (and associated fatal cancer risk) to the hypothetical Maximally Exposed Individual (MEI) would be 50 percent higher for 60 years of operation over the baseline of 40 years of operation. However, NRC acknowledged the unlikelihood of a single MEI (i.e., the same person) being in a position for exposure throughout the entirety of a plants operating years (60 years) (NRC. 2013, p. 4-145).

NRCs GEIS analysis of decommissioning impacts addresses the accumulation of long-lived radionuclides from an additional 20 years of operation in an initial license renewal. NRC concluded that the increase would result in a negligible dose (less than 0.1 person-rem) (NRC.

2013, pg. 4-217)

For initial license renewals, the NRC codified its conclusion that radiation doses to the public from continued operations and refurbishment associated with license renewal would be SMALL. NRC concluded that radiation exposures to the public are expected to continue at current levels and would be well below regulatory limits.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 62 of 90 E4.9.3.2 Site-Specific Analysis for NAPS SLR The proposed action is to continue to operate as currently designed throughout the SLR term, and no refurbishment activities are proposed. NAPS submits annual radioactive effluent release reports to NRC and calculates the public dose from its liquid and gaseous radioactive releases.

NAPS uses its ODCM, updated as needed, to provide methods and parameters for calculating offsite doses in accordance with NRC requirements. These methods ensure that radioactive discharges from NAPS meet NRC and EPA regulatory dose standards. As presented in Section E3.10.3 of the NAPS SLR ER, for years 2013-2017, the annual public dose is a fraction of the regulatory limits and were in accordance with radiation protection standards. The reports for years 2018-2021 likewise indicated that the public dose from the radioactive effluents was a fraction of the regulatory limits (Dominion. 2020a; Dominion. 2020b; Dominion. 2021b; Dominion. 2022a).

Because there is no reason to expect effluents to increase in the PEO, annual doses to the public from continued operation are expected to be within regulatory limits.

As presented above in Section E4.9.3.1, in the GEIS, NRC also considered cumulative dose from an additional 20 years of operation (i.e., 40-60 years), acknowledging the fatal cancer risk from the cumulative dose to the hypothetical MEI would be 50 percent higher for 60 years of operation over the baseline of 40 years of operation. As discussed above, NAPSs annual releases are a fraction of regulatory limits. The maximum MEI dose from 2021 operations was the total body dose from liquid release and was calculated to be 0.3564 millirem (mrem) (Dominion. 2022a). The ALARA annual offsite dose objective is 3 mrem to the whole body for the MEI (Appendix I to 10 CFR 50). This ALARA objective is 3 percent of the annual public radiation dose limit of 100 mrem and a small fraction of the natural background radiation dose. The sum of 20 years of the 2021 exposure level is 7 percent of the public radiation dose limit for a single year. At NAPS, the maximum exposed member of the public (the MEI) for calculation of total body dose from radioactive materials in liquid effluents released to unrestricted area is a child (Dominion. 2022a).

This MEI would be unlikely to have an exposure duration of 40 years, with 60 years being highly unlikely, and 80 years more unlikely. NRC likewise acknowledged the unlikelihood of a single MEI (i.e., the same person) being in a position for exposure throughout the entirety of a plants operating years (60 years) (NRC. 2013, p. 4-145). Thus, while the exposure year over year would result in a cumulative dose, this cumulative dose would be the sum of annual doses that are a small fraction of the regulatory limit.

The REMP is designed to determine if NAPSs radioactive effluent releases, including radioactive releases from LLRW management and storage at NAPS, are leading to an accumulation of radioactivity both onsite and in the surrounding offsite environment. The REMP sampling reported in the annual radiological environmental operating reports for 2013-2017 did not detect radionuclides attributable to NAPS other than tritium in surface or river water and the operation of NAPS has created no adverse environmental effects or health hazards. Likewise, the 2018-2021 annual radiological environmental operating reports concluded that the operation of NAPS has created no adverse environmental effects or health hazards (Dominion. 2020a; Dominion. 2020c; Dominion. 2021c; Dominion. 2022b).

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 63 of 90 As discussed in the GEIS, the concentration of radioactive materials in soils and sediments increases in the environment at a rate that depends on the rate of release and the rate of removal.

Removal can take place through radioactive decay or through chemical, biological, or physical processes. For a given rate of release, the concentrations of longer-lived radionuclides and, consequently, the dose rates attributable to them would continue to increase if license renewal was granted. NRCs GEIS analysis regarding the accumulation of long-lived radionuclides from an additional 20 years of operation in an initial license renewal concluded that the increase would result in a negligible dose (less than 0.1 person-rem). (NRC. 2013, pg. 4-217) NAPSs REMPs results discussed above indicate that radioactivity is not accumulating, thus supporting that the public dose would be negligible from continuing operation. NAPS continues to release radioactive effluents at a fraction of regulatory limits and now, years into its initial license renewal, the REMP results continue to show no adverse trends in levels of radiation and radioactive materials.

Continued operation into a second 20-year renewal term is expected to likewise show that there is not an accumulation of radioactivity. Furthermore, detecting any adverse trends in REMP results would allow for corrective actions to be implemented and ensure that public dose whether from short- or long-lived radionuclides remains within regulatory limits.

Dominion finds that radiation doses to the public for the proposed SLR term would be SMALL.

Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.9.4 RADIATION EXPOSURES TO THE PLANT WORKERS - ISSUE 46, TABLE E4.0-1 E4.9.4.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.9.1.1]

Radiological exposures from nuclear power plants include onsite doses to the workforce. This impact is common to all commercial U.S. reactors. Nuclear power reactors are required to comply with 10 CFR Part 20, Subpart C, Occupational Dose Limits for Adults.

In the 2013 license renewal GEIS, the NRC reviewed radiation exposures to plant workers.

Occupational dose information collected and reviewed by the NRC in the 2013 license renewal GEIS provides evidence that doses to nearly all radiation workers are far below the worker dose limit established by 10 CFR Part 20 and that the continuing efforts to maintain doses at ALARA levels have been successful. As plants age, there may be slight increases in radioactive inventories, which would result in slight increases in occupational radiation doses. However, NRC expected that occupational doses from refurbishment activities associated with license renewal and occupational doses for continued operations during the license renewal term would be similar to the doses during the current operations.

For initial license renewals, the NRC codified its conclusion that radiation doses to plant workers from continued operations and refurbishment associated with license renewal would be SMALL.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 64 of 90 NRC concluded that radiation exposures to plant workers are expected to continue at current levels and would be well below regulatory limits.

E4.9.4.2 Site-Specific Analysis for NAPS SLR The proposed action is to continue to operate NAPS as currently designed throughout the SLR term, and no refurbishment activities are proposed.

The most recent occupational radiation exposure report (NUREG-0713, Volume 41) presents dose data for NRC licensees through 2019. The average collective dose per reactor at pressurized water reactors (PWRs) has trended downward since 2005 (the data year that NRC reviewed in the GEIS) when the average dose per reactor was 79 person-roentgen equivalent man (rem) with the exception of a slight increase in 2006 to 87 person-rem (NRC. 2022, Table 4.2 and Figure 4.1). The data set presented in the most recent NUREG-0713 covers 1994 through 2019 and this longer time frame also shows an overall downward trend for average collective dose per reactor. The middle 50 percent of collective dose per PWRs also trended downward since 2005 as well as since 1994 (NRC. 2022, Figure 4.4b). The dose performance trend presented for NAPS shows that since 2005, NAPSs collective dose per reactor was similar to the PWR average collective dose per reactor (NRC. 2022, Appendix D).

The GEIS presented that in 2005 the individual worker dose at PWRs in 2005 was all below 2 rem, less than half of the 5 rem regulatory limit [10 CFR 20.1201(a)(1)]. This is also the case for 2019, with the highest dose range experienced for PWR workers being 1.0 to 2.0 rem and involving only 16 workers (NRC. 2022, Appendix B). Of the 3,435 workers monitored at NAPS in 2019, only 837 had a measurable dose and six workers were in the highest dose range (1.0 to 2.0 rem) recorded at NAPS (NRC. 2022, Appendix B). The 3-year (2017-2019) average annual occupational dose (total effective dose equivalent) per worker at NAPS was 0.085 rem (NRC.

2022, Table 4.6). The average for PWR workers for the same time frame is 0.072 rem. Continued practice of ALARA principles will ensure NAPS workers exposure from continued operations remains within regulatory limits and ALARA.

NRCs GEIS assessment considered the radiological risk to workers to be SMALL, citing the 2005 dose. In the GEIS, NRC also indicated that as plants age, there may be slight increases in radioactive inventories, which would result in slight increases in occupational radiation doses. But, contrary to that conservative assumption, actual data for 2005-2019 demonstrate a downward trend in occupational radiation doses even though the plants are older and inventories of SNF have increased. Thus, the GEIS analysis remains conservative.

The GEIS assessment also addresses the cumulative dose for its increase in fatal individual cancer risk to a worker. The cumulative dose to a worker would increase with each year worked beyond the baseline of a reactors license term of 40 years. However, as acknowledged by NRC, an individual worker is not likely to be employed for all 60 years of a reactors license term plus initial renewal term. That same logic applies even more so to an SLR term; an individual worker is highly unlikely to be employed for 80 years. Therefore, a second license renewal term would Page-E-4-64

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 65 of 90 not likely have a cumulative dose impact beyond that considered by NRC in the GEIS to be SMALL.

Dominion finds that impacts from radiation exposure to plant workers for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.9.5 HUMAN HEALTH IMPACT FROM CHEMICALS - ISSUE 47, TABLE E4.0-1 E4.9.5.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.9.1.1.2]

Chemical effects could result from discharge of chlorine or other biocides, small-volume discharges of sanitary and other liquid wastes, heavy metals leached from cooling system piping and condenser tubing in plant wastewater effluents, the use and disposal of chemicals and chemical spills, and use and disposal of hazardous chemicals. These chemical effects could pose human health hazards to the public and workers. In the 2013 license renewal GEIS, the NRC reviewed the potential for human health impacts from the chemical effects and these activities.

Federal and state environmental agencies regulate the use, storage, and discharge of chemicals, biocides, and sanitary wastes. These environmental agencies also regulate how facilities like a nuclear power plant manage minor chemical spills. The NRC requires nuclear power plants to operate in compliance with all permits, thereby minimizing adverse impacts to the environment and on workers and the public. In the 2013 license renewal GEIS, NRC anticipated that all plants will continue to operate in compliance with all applicable permits, and no additional mitigation measures would be warranted for the license renewal term. Based on these considerations, the NRC considered the health impact from chemicals to workers and the public to be SMALL for all nuclear plants.

For initial license renewals, the NRC codified its conclusion that human health impacts from chemicals are expected to be SMALL given that Federal and state environmental agencies regulate the use, storage, and discharge (including spills) of chemicals, biocides, and sanitary wastes.

E4.9.5.2 Site-Specific Analysis for NAPS SLR Plant workers may encounter hazardous chemicals when the chemistries of the primary and secondary coolant systems are being adjusted, biocides are being applied to address the fouling of cooling system components, equipment containing hazardous oils or other chemicals is being repaired or replaced, solvents are being used for cleaning, or other equipment is being repaired.

Dominion has a comprehensive occupational safety program covering NAPS workers and activities. NAPS has a chemical control program to oversee the proper use and storage of chemicals onsite and ensure that Safety Data Sheets are available. For 2017-2021, NAPS had Page-E-4-65

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 66 of 90 six Occupational Safety and Health Administration (OSHA) recordable work-related injuries and illnesses. None of the six were injuries involving skin disorders, respiratory conditions, or poisoning, which would be indicative of injuries due to chemical exposure.

NAPS operates in compliance with its various wastewater permits and in compliance with waste and chemical management regulations. There have been no reportable spills or other nonradiological reportable releases at NAPS 2013-2018 other than the December 2016 underground fuel oil leak from the leaking 2H B fuel oil feed line. (Dominion 2020a) A second reportable spill on non-PBC mineral oil occurred in 2021, as presented in Section E4.5.11.2. A records review through March 2022 indicates that no other nonradiological reportable releases have occurred since the ER was written.

The risk of human health impacts from chemicals could increase over time with the accumulation of chemical substances that do not easily biodegrade such as heavy metals and PCBs. With the WHTF and North Anna Reservoir capturing the plants wastewater and stormwater, the fishery would be the environmental setting to see if accumulation of long-lived chemical substances is indicated. Various annual biological studies on the North Anna Reservoir as well as the WHTF and the North Anna River downstream from the North Anna Dam demonstrate that the operation of NAPS has not resulted in significant harm to the biological community. North Anna Reservoir and the WHTFs fishery is found to be healthy and balanced.

There are fish consumption advisories for PCBs for Lake Anna (i.e., North Anna Reservoir) (VDH.

2022). NAPS does not have any transformers or capacitors with PCBs remaining onsite and the only PCB material at NAPS is in fluorescent lamp ballasts manufactured prior to the PCB ban in 1979 (Dominion. 2020a). Thus, with regards to NAPS operations, there are no indications of an increasing risk to human health from chemicals, and operations are unlikely to increase risk to human health from chemicals.

Chemical hazards to plant workers resulting from continued operations associated with license renewal are expected to be minimized by good industrial hygiene practices as required by federal and state regulations. Chemical releases to the environment and the potential for impacts to the public are expected to be minimized by adherence to discharge limitations of VPDES and other permits and regulatory requirements during the proposed SLR term.

Dominion finds that impacts to human health from chemicals for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 67 of 90 E4.9.6 MICROBIOLOGICAL HAZARDS TO PLANT WORKERS - ISSUE 48, TABLE E4.0-1 E4.9.6.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.9.1.1.3]

Some microorganisms associated with nuclear power plant cooling towers and thermal discharges can have deleterious impacts on the health of plant workers and the public. Certain microorganisms can benefit from thermal effluents. The potential for adverse health effects from microorganisms on nuclear power plant workers is an issue for plants that use cooling towers. In the 2013 license renewal GEIS, the NRC reviewed microbiological hazards to plant workers. The GEIS discussion of microbiological hazards focuses on the thermophilic microorganisms of the genus Legionella (which can be a hazard during such activities as cleaning condenser tubes and cooling towers) and the pathogenic amoeba, Naegleria fowleri (which can be a hazard in cooling water discharges). The NRC expected that there would be no change in existing microbiological hazards over the license renewal term. The NRC considered it unlikely that any plants that have not already experienced occupational microbiological hazards would do so during the license renewal term or that hazards would increase over that period. The NRC anticipated that all plants will continue to employ proven industrial hygiene principles so that adverse occupational health effects associated with microorganisms will be of SMALL significance at all sites.

For initial license renewals, the NRC codified its conclusion that microbiological hazards to plant workers would continue to be SMALL if all plants continue to employ proven industrial hygiene principles.

E4.9.6.2 Site-Specific Analysis for NAPS SLR Infections from N. fowleri require the microorganism to enter the nasal passages through direct contact with water (CDC. 2022). Given that infection by N. fowleri requires immersion to the nostrils (e.g., swimming) or another means of introduction of water into the nasal passages (e.g.,

neti pot use) which are activities that are not part of worker tasks, N. fowleri infection is not an occupational hazard at NAPS. A June 2019 sampling in the NAPS bearing cooling tower, associated water lines, and North Anna Reservoir found that Legionella was not detected. The water circulated by the bearing cooling tower is treated with biocide. Disinfection in the sewage treatment facility reduces coliform bacteria (and other microorganisms) to levels that meet state water quality standards and thus its discharge does not provide a seed source or inoculant that would stimulate population growth of microbiological organisms. (Dominion. 2020a)

Occupational health impacts are expected to be controlled by continued application of accepted industrial hygiene practices and NAPS has a comprehensive occupational safety program to minimize worker exposures as required by federal and state regulations. NAPS has been certified as a Virginia STAR Worksite since 2005 under Virginias Occupational Safety and Health Voluntary Protection Program. Dominion finds that microbiological hazards to plant workers during the proposed SLR term would be SMALL.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 68 of 90 Regarding applicability to a second 20-year renewal, Dominion is not proposing changes in the cooling water system or sanitary wastewater treatment and disposal. Further, should the need for changes in these systems arise, they would be carried out under state wastewater permits. The human health impact from the microbiological organisms mentioned above is from acute exposure rather than chronic exposure.

Dominion finds that impacts from microbiological hazards to plant workers for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.9.7 PHYSICAL OCCUPATIONAL HAZARDS - ISSUE 49, TABLE E4.0-1 E4.9.7.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.9.1.1.5]

This issue addresses the potential for workers at a nuclear plant to have human health impacts from physical occupational hazards (e.g., slips and trips, falls from height, and those related to transportation, temperature, humidity, electricity, noise, and vibration). In the 2013 license renewal GEIS, the NRC evaluated the issue of occupational hazards by comparing the rate of fatal injuries and nonfatal occupational injuries and illnesses in the utility sector with the rate in all industries combined. The utility sector rates were lower than those of many other sectors. NRC expected that over the license renewal term, workers would continue to adhere to safety standards and use protective equipment, so adverse occupational impacts would be of SMALL significance at all sites.

For initial license renewals, the NRC codified its conclusion that physical occupational hazards are expected to be SMALL if workers would continue to adhere to safety standards and use protective equipment.

E4.9.7.2 Site-Specific Analysis for NAPS SLR Plant conditions which result in an occupational risk, but do not affect the safety of licensed radioactive materials, are under the statutory authority of OSHA. Work on the NAPS site is governed by a comprehensive industrial safety program. The program addresses electrical safety, use of ladders and portable equipment, etc. NAPS adheres to OSHA standard 29 CFR Part 1910 Subpart R, Special Industries, as it relates to Electric Power Generation, Transmission and Distribution [29 CFR Part 1910.269]. NAPS is certified as a Virginia STAR Worksite through its participation since 2005 in Virginias Occupational Safety and Health Voluntary Protection Program. For the certification, the site undergoes periodic evaluations by the Virginia Department of Labor and Industry and the most recent site evaluation was in 2018 with recertification awarded in May 2019.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 69 of 90 As discussed in Section E4.9.5.2, NAPSs total number of recordable injuries reported to OSHA for 2017-2021 was six.

The human health impact from most physical hazards would be due to singular events (e.g., falls) which do not accumulate to result in a material difference in human health risk from one renewal term to a subsequent one. The exception would be physical hazards that have a chronic exposure component such as sound level exposure. OSHA regulations address precautions to reduce chronic exposure. Continued compliance with OSHA regulations for exposure and use of personal protective equipment would reduce the risk from chronic exposure. Therefore, there would not be a material difference between the physical hazard risk of the initial 20-year renewal and a second 20-year renewal period.

Dominion finds that impacts from physical occupational hazards for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.15.1 DESIGN-BASIS ACCIDENTS - ISSUE 50, TABLE E4.0-1 E4.15.1 CATEGORY 1 ISSUEDESIGN-BASIS ACCIDENTS Section 5.3 of the 1996 GEIS discusses the impacts of potential accidents and their consequences and addresses the general characteristics of design-basis accidents (DBAs),

including characteristics of fission products, meteorological considerations, possible exposure pathways, potential adverse health effects, avoiding adverse health effects, accident experience and observed impacts, and emergency preparedness. In the 2013 license renewal GEIS, the NRC reexamined the information from the 1996 GEIS regarding DBAs and concluded that this information is still valid. The NRC found that the environmental impacts of DBAs are of SMALL significance for all nuclear plants. This conclusion was reached because the plants were designed to successfully withstand these accidents, and a licensee is required to maintain the plant within acceptable design and performance criteria, including during any license renewal term. It is also stated that the environmental impacts during a license renewal term should not differ significantly from those calculated for the DBA assessments conducted as part of the initial plant licensing process. Impacts from DBAs would not be affected by changes in plant environment because such impacts (1) are based on calculated radioactive releases that are not expected to change; (2) are not affected by plant environment because they are evaluated for the hypothetical MEI; and (3) have been previously determined acceptable. (NRC. 1996; NRC. 2013)

During the integrated plant assessment, the license renewal team evaluated NAPS systems, structures, and components, and conducted time-limited aging analyses to ensure that systems, structures, and components remain capable of performing their functions consistent Page-E-4-69

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 70 of 90 with existing plant design and performance criteria specified in the NAPS licensing basis.

Current design and performance criteria will be maintained during the proposed SLR term.

As part of the initial license renewal process, to receive NRC approval to operate a nuclear power facility, an applicant must submit an Updated Safety Analysis Report (UFSAR)

Supplement as part of its application.

The NAPS UFSAR presents the design criteria and design information for the proposed reactor and comprehensive data on the proposed site. The NAPS UFSAR also discusses various hypothetical DBAs and the safety features designed to prevent and mitigate accidents.

The NRC staff reviews the application to determine whether the plant design meets the NRCs regulations and requirements and includes, in part, the nuclear plant design and its anticipated response to an accident.

A number of these postulated accidents are not expected to occur during the life of the plant but are evaluated to establish the design basis for the preventive and mitigative safety systems of the facility. The acceptance criteria for DBAs are described in 10 CFR Part 50 and 10 CFR Part 100. The environmental impacts of DBAs are evaluated during the initial license process, and the ability of the plant to withstand these accidents was demonstrated to be acceptable before issuance of the operating license (OL). The results of these evaluations are found in license documentation such as the staffs safety evaluation report, the final environmental impact statement, and the licensees UFSAR. The licensee is required to maintain the acceptable design and performance criteria throughout the life of the plant, including any extended-life operation. The consequences for these events are evaluated for the hypothetical maximum exposed individual; as such, changes in the plant environment will not affect these evaluations. The requirements for continuous acceptability of the consequences of accidents, and the applicability of aging management programs and other inputs to keeping mitigative equipment available and reliable must be in effect during the license renewal period.

As such, the environmental impacts as calculated for DBAs should not differ significantly over the life of the plant, including the PEO. Accordingly, the design of the plant relative to DBAs during the extended period is considered to remain acceptable and the environmental impacts of those accidents were not examined further in the GEIS (NRC. 2002).

When the 2013 GEIS was issued, the NRCs review of updated external hazards information for all operating power reactors (as ordered by the Commission following the Fukushima Dai-Ichi accident) remained ongoing. On June 9, 2020, the NRC completed its review of such information as to NAPS and concluded that no further regulatory actions were needed to ensure adequate protection or compliance with regulatory requirements, re-confirming the acceptability of NAPSs design basis. (NRC. 2020)

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 71 of 90 The NAPS SLR ER previously provided a site-specific analysis of mitigation alternatives related to Severe Accidents, but the GEIS provides a generic analysis of the impacts of Severe Accidents. Therein, the NRC concluded that:

The probability-weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are SMALL for all plants.

Regarding Severe Accidents, the NRC staff evaluated the information in the NAPS SLR ER in consideration of the probability-weighted consequences of severe accidents and concluded that the aggregate risk increases from the sources of new information when compared to the NAPS specific decrease in internal events core damage frequency resulted in a factor of 20.3 lower environmental impact (as compared to the 1996 GEIS or NAPSs previous SAMA analysis from initial license renewal). These sources of new information are those that the NRC has determined to be important to severe accident impact and include new internal events, new external events, new source term information, use of BEIR VII risk coefficients, spent fuel pool accidents, higher fuel burnup, low power and shutdown events, and population increase. The NRC has determined that all other sources of new information (e.g., new meteorological information, new emergency preparedness information) do not contribute sufficiently to the environmental impacts to warrant their inclusion in severe accident analysis, especially given the factor of 20.3 reduction in environmental impact over the prior analyses and the small likelihood of finding cost-effective plant improvements for other new information sources. This aggregate environmental impact reduction from new sources of information supports the 2013 GEIS conclusions for severe accidents for the PEO.

(NRC. 2021, Appendix F.3.9)

Conclusions The environmental impacts of DBAs are of SMALL significance for NAPS because the plant was designed to successfully withstand these accidents. Due to the requirements for NAPS to maintain the licensing basis (the adequacy of which the NRC recently re-confirmed) and implement aging management programs during the license renewal term, the environmental impacts during the license renewal term are not expected to differ significantly from those calculated for the DBA assessments conducted as part of the initial plant licensing process.

Dominion finds that impacts due to DBAs are SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 72 of 90 E4.11.1 LOW-LEVEL WASTE STORAGE AND DISPOSAL - ISSUE 51, TABLE E4.0-1 E4.11.1.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.11.1.1]

In 2013 GEIS analysis NRC considered the comprehensive regulatory controls in place for management of low-level waste (LLW) and the low public doses achieved at reactors. NRC concludes that the comprehensive regulatory controls and the low public doses experienced at reactors ensured that the radiological impacts on the environment will remain SMALL during the license renewal term.

In the 2013 GEIS, NRC also considered the impact of LLW disposal. NRC concluded that (1) the maximum additional onsite land that may be required for LLW storage during the license renewal term and associated impacts would be SMALL, (2) nonradiological impacts on air and water would be negligible, and (3) the radiological and nonradiological environmental impacts of long-term disposal of LLW from any individual plant at licensed sites are SMALL. NRCs analysis also accounted for the availability of licensed disposal facilities to the nuclear power plant operators.

NRC concludes that there is reasonable assurance that sufficient LLW disposal capacity will be made available when needed for facilities to be decommissioned, consistent with NRC decommissioning requirements.

For initial license renewals, the NRC codified its conclusion that impacts are expected to be SMALL with the comprehensive regulatory controls and use of licensed LLW storage and disposal facilities.

E4.11.1.2 Site-Specific Analysis for NAPS SLR Dominion will continue to manage and store LLRW onsite in accordance with NRC regulations and dispose of LLRW in NRC-licensed treatment and disposal facilities during the proposed SLR operating term (Dominion. 2020a). No increases in LLRW generation rates are expected for the SLR term and no increase in onsite storage capacity is planned. There are comprehensive regulatory controls in place, and Dominions compliance with these regulations and use of only licensed treatment and disposal facilities would allow the impacts to remain SMALL during the proposed SLR operating term. Dominions annual radiological effluent release reports for 2013-2017 indicate that doses to members of the public were negligible and in accordance with NRC and EPA radiation protection standards (Dominion. 2020a). Review of the annual radiological effluent release reports for 2018-2021 indicates that doses to the public are a fraction of the regulatory limits. (Dominion. 2020a; Dominion. 2020b; Dominion. 2021b; Dominion. 2022a)

NAPSs REMP is designed to determine if NAPSs radioactive effluent releases, including radioactive releases from LLRW management and storage at NAPS, are leading to an accumulation of radioactivity both onsite and in the surrounding offsite environment. The REMP sampling reported in the annual radiological environmental operating reports for 2013-2017 did not detect radionuclides attributable to NAPS other than tritium in surface or river water, and the Page-E-4-72

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 73 of 90 operation of NAPS has created no adverse environmental effects or health hazards (Dominion.

2020a). Likewise, the 2018-2021 annual radiological environmental operating reports concluded that the operation of NAPS has created no adverse environmental effects or health hazards (Dominion. 2020a; Dominion. 2020c; Dominion. 2021c; and Dominion. 2022b). Thus, the REMP results indicate that radioactivity is not accumulating in environmental media after 44 years of operation (1978-2021).

The radiological impacts from disposal of waste generated during an SLR term have the potential to increase as long-lived radionuclides accumulate at disposal facilities. However, the disposal facilities would be licensed, which means the facility would be designed, inclusive of design capacity and conditions of operation, to minimize environmental impacts.

Dominion finds that impacts from LLRW waste storage and disposal for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.11.2 ONSITE STORAGE OF SPENT NUCLEAR FUEL - ISSUE 52, TABLE E4.0-1 E4.11.2.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.11.1.2 and NUREG-2157]

As discussed in Section 3.11.1.2 of the GEIS, SNF is currently stored at reactor sites either in spent fuel pools or in independent spent fuel storage installations (ISFSIs). The storage of spent fuel in spent fuel pools was considered for each plant in the safety and environmental reviews at the construction permit and OL stage. This onsite storage of spent fuel and high-level waste (HLW) is expected to continue into the foreseeable future.

Interim storage needs vary among plants, with older units likely to lose pool storage capacity sooner than newer ones. Given the uncertainties regarding the final disposition of spent fuel and HLW, it is expected that expanded spent fuel storage capacity will be needed at all nuclear power plants.

NUREG-2157, Generic EIS for Continued Storage of Spent Nuclear Fuel, concluded on a generic basis for all nuclear power plants that spent fuel can be stored onsite for 60 years following the license term with SMALL environmental effects (NRC. 2014, ES.12 and Table ES-3).

For initial license renewals, the NRC codified its conclusion that, during the license renewal term, the expected increase in the volume of SNF from an additional 20 years of operation can be safely accommodated onsite during the license renewal term with SMALL environmental impacts through dry or pool storage at all plants.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 74 of 90 For the period after the licensed life for reactor operations, the impacts of onsite storage of SNF during the continued storage period are discussed in NUREG-2157 and, as stated in § 51.23(b),

shall be deemed incorporated into this issue. The NRC found the impact for this issue to be SMALL.

E4.11.2.2 Site-Specific Analysis for NAPS SLR The additional 20 years of SNF generated during the proposed SLR operating term would be stored in the NAPS spent fuel pools until adequately cooled and then transferred to dry storage at an ISFSI. The NRC-licensed design and operation of each of these storage options ensures that the increased volume in onsite storage can be safely accommodated with SMALL environmental effects.

For on-site storage of spent fuel during the license renewal term, Table B-1 was amended after the 2013 GEIS by the Continued Storage Rule in 79 Federal Register (FR) 56238 to codify the Commissions determination that the impacts would be SMALL. This rulemaking postdates the LR GEIS rulemaking in 2013, and the Commissions codified impact determination was not overturned by the NRCs CLI-22-02 Order. The Continued Storage Rulemaking explicitly considered SLRs, stating in Footnote 3 at 79 FR 56245: The Commissions regulations provide that renewed OLs may be subsequently renewedThe GEIS [Continued Storage of Spent Nuclear Fuel GEIS] assumes two renewals in evaluating potential environmental impacts.

Pursuant to the Commissions generic analysis and codified conclusion, the impacts of onsite storage of spent fuel during the SLR term at NAPS are SMALL.

Dominion finds that impacts from onsite storage of spent nuclear fuel for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.11.3 OFFSITE RADIOLOGICAL IMPACTS OF SPENT NUCLEAR FUEL AND HIGH-LEVEL WASTE DISPOSAL - ISSUE 53, TABLE E4.0-1 E4.11.3.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.11.1.3]

The NRCs GEIS analysis of the issue was tied to rulemaking for the waste confidence decision, which was pending in 2013 when the license renewal GEIS was issued. Therefore, in the GEIS, the NRC reclassifies this GEIS issue from a Category 1 issue with no assigned impact level to an uncertain. As part of the NRCs NEPA actions associated with the waste confidence decision, the NRC reviewed the environmental impacts of away-from-reactor storage in 2014 and the technical feasibility of disposal in a geologic repository in NUREG-2157, Generic EIS for Continued Storage of Spent Nuclear Fuel (NRC. 2014, Sections ES.7 and ES.16). In the final continued storage of nuclear spent fuel rulemaking [79 FR 56238], the listing and classification of license renewal issues found in 10 CFR 51, Subpart A, Appendix B, Table B-1 was codified to Page-E-4-74

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 75 of 90 reclassify the impact determination for this issue as a Category 1 issue with no impact level assigned, and the NRC concluding:

the impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR part 54 should be eliminated.

Accordingly, while the Commission has not assigned a single level of significance for the impacts of spent fuel and HLW disposal, this issue is considered Category 1.

This re-classification was upheld in May 2016 against petitions [81 FR 31532].

E4.11.3.2 Site-Specific Analysis for NAPS SLR The final continued storage of nuclear spent fuel rulemaking [79 FR 56238] postdates the LR GEIS rulemaking in 2013, and the Commissions codified impact determination was not overturned by the NRCs CLI-22-02 Order. The Continued Storage Rulemaking explicitly considered SLRs, stating in Footnote 3 at 79 FR 56238, pg. 56245: The Commissions regulations provide that renewed OLs may be subsequently renewedThe GEIS [Continued Storage of Spent Nuclear Fuel GEIS] assumes two renewals in evaluating potential environmental impacts. Thus, pursuant to the Commissions codified conclusion, with regard to this issues consideration for NAPSs SLR, the offsite radiological impacts of SNF remain a Category 1 with no impact level assigned.

Dominion finds that offsite radiological impacts of spent nuclear fuel and high-level waste disposal for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.11.4 MIXED WASTE STORAGE AND DISPOSAL - ISSUE 54, TABLE E4.0-1 E4.11.4.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.11.1.4]

Mixed waste is regulated both by the EPA or the authorized state agency under the Resource Conservation and Recovery Act (RCRA) and by the NRC or the agreement state agency under the Atomic Energy Act (AEA) (Public Law 83-703). The waste is either treated onsite or sent offsite for treatment, followed by disposal at a permitted landfill. In the LR GEIS, NRCs analysis considered the comprehensive regulatory controls and the facilities and procedures in place at nuclear power plants, assessing them to be adequate to ensure that the mixed waste is properly handled and stored and that doses of and exposure to toxic materials by the public and the environment are negligible at all plants. NRC concluded that license renewal would not increase the small but continuing risk to human health and the environment posed by mixed waste at all plants. Regarding disposal, NRC concluded that the radiological and nonradiological environmental impacts from the long-term disposal of mixed waste at any individual plant at licensed sites are considered SMALL for all sites.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 76 of 90 For initial license renewals, the NRC codified its conclusion that impacts are expected to be SMALL with the comprehensive regulatory controls and use of licensed mixed low-level waste storage and disposal facilities.

E4.11.4.2 Site-Specific Analysis for NAPS SLR See the discussion in Section E4.11.1.2 on LLRW and its conclusion of SMALL impacts from NAPSs onsite management of LLRW. Dominion has developed guidance documents for managing its hazardous waste streams, including mixed waste. Dominion inspects its waste management areas for compliance with applicable regulations and permits on a weekly basis using a facility waste inspection checklist. Dominions management of its waste streams is in compliance with applicable regulatory standards and has not resulted in any notices of violation for the 2013-2019 timeframe. (Dominion. 2020a) NAPS has not received any NOVs through March 2022, but a warning letter was received for a missed TSS monitoring requirement at Outfall 103. Dominion would continue to store and dispose of hazardous and nonhazardous waste in accordance with EPA and state regulations and dispose of the waste in appropriately permitted treatment and disposal facilities during the proposed SLR operating term.

NAPS does not routinely generate mixed waste and has not generated any in approximately the past 10 years. Dominion does not anticipate an increase in generation of mixed waste for future operations. Should mixed waste be generated at NAPS, as presented above, NAPS has established practices to manage the waste while onsite and would contract with a licensed/permitted vendor for treatment or disposal.

The impacts from disposal of mixed waste generated during an SLR term have the potential to increase as long-lived radionuclides, chemicals, and metals accumulate at disposal facilities.

However, the disposal facilities would be licensed and permitted, which means the facility would be designed, inclusive of design capacity and conditions of operation, to minimize environmental impacts.

Dominion finds that impacts from mixed waste storage and disposal for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.11.5 NONRADIOACTIVE WASTE STORAGE AND DISPOSAL - ISSUE 55, TABLE E4.0-1 E4.11.5.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.11.1.5]

The management of hazardous wastes (generation, storage, and disposal) is strictly regulated by the EPA or the responsible state agencies per the requirements of RCRA.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 77 of 90 As does any industrial facility, nuclear power plants and the rest of the uranium fuel cycle facilities also generate nonradioactive nonhazardous waste. These wastes are managed by following good housekeeping practices and are generally disposed of in local landfills permitted under RCRA Subtitle D regulations.

In the GEIS, NRC anticipated that license renewal would not lead to changes to nonradioactive waste generation at uranium fuel cycle facilities, including nuclear power plants. NRC also acknowledge that systems and procedures are in place to ensure continued proper handling and disposal of the wastes at all plants. NRC found the impacts associated with managing nonradioactive wastes at uranium fuel cycle facilities, including nuclear power plants to be SMALL.

For initial license renewals, the NRC codified its conclusion that impacts are expected to be SMALL with the comprehensive regulatory controls and in place to ensure continued proper handling, storage, and disposal of nonradioactive waste.

E4.11.5.2 Site-Specific Analysis for NAPS SLR Dominion has developed guidance documents for managing its nonradioactive waste streams including hazardous and nonhazardous wastes. In addition, Dominion inspects its waste management areas for compliance with applicable regulations on a weekly basis using a facility waste inspection checklist. Dominions management of its waste streams is in compliance with applicable regulatory standards and has not resulted in any notices of violation for the 2013-2019 timeframe, but a warning letter was received for a missed TSS monitoring requirement at Outfall 103. (Dominion. 2020a)

NAPS has not received any NOVs through March 2022, but a warning letter was received for a missed TSS monitoring requirement at Outfall 103. Dominion would continue to store and dispose of hazardous and nonhazardous wastes in accordance with EPA and state regulations and dispose of the wastes in appropriately permitted treatment and disposal facilities during the proposed SLR operating term.

NAPS is classified as a small quantity generator of hazardous waste and does not expect a change in this status in the foreseeable future. NAPS minimizes its generation of hazardous and universal wastes through the following steps in its waste management procedure:

1. Plan projects and activities in advance with the waste stream in mind,

2. Evaluate all existing waste streams for opportunities to reduce production of waste at its source by methods such as reduction of input materials, treatment (with appropriate permits), use of alternate materials and chemicals, and process changes,

3. Assess used materials for reuse prior to disposal or recycling, and

4. Maximize use of recycling programs to reduce waste and disposal costs.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 78 of 90 NAPS also has a chemical control procedure that ensures approval of chemicals brought onsite, proper handling and storage, and minimizing quantities where practical.

The impacts from disposal of hazardous waste generated during an SLR term have the potential to increase as long-lived toxic metals accumulate at disposal facilities. However, the disposal facilities would be permitted, which means the facility would be designed, inclusive of design capacity and conditions of operation, to minimize environmental impacts.

Dominion finds that impacts from nonradioactive waste storage and disposal for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.13.1 OFFSITE RADIOLOGICAL IMPACTSINDIVIDUAL IMPACTS FROM OTHER THAN THE DISPOSAL OF SPENT FUEL AND HIGH-LEVEL WASTE - ISSUE 56, TABLE 4.0-1 E4.13.1.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.12.1.1]

In the 2013 license renewal GEIS, the NRC reviewed generic issues related to the uranium fuel cycle including offsite radiological impacts. As stated in the 2013 license renewal GEIS, the generic issues related to the uranium fuel cycle would not be affected by continued operations associated with license renewal of nuclear power plants.

The primary indicators of impact are the concentrations of radionuclides in the effluents from the fuel cycle facilities and the radiological doses received by an MEI on the site boundary or at some location away from the site boundary. The basis for establishing the significance of individual effects is the comparison of the releases in the effluents and the MEI doses with the permissible levels in applicable regulations. The analyses performed by the NRC in the preparation of Table S-3 of 10 CFR 51.51 and found in the 1996 GEIS indicate that, as long as the facilities operate under a valid license issued by either the NRC or an agreement state under the AEA (Public Law 83-703), the individual effects will meet the applicable regulations. On the basis of these considerations, in the 2013 GEIS the NRC has concluded that the impacts on individuals from radioactive gaseous and liquid releases during the license renewal term would remain at or below the NRCs regulatory limits. Accordingly, the NRC concludes that offsite radiological impacts of the uranium fuel cycle (individual effects from sources other than the disposal of spent fuel and HLW) are SMALL.

For initial license renewals, the NRC codified its conclusion that the impacts to the public from radiological exposures have been considered by the NRC in Table S-3 of 10 CFR 51.51, and that the impacts would be SMALL. Based on information in the GEIS, impacts to individuals from radioactive gaseous and liquid releases, including radon-222 and technetium-99, would remain at or below the NRCs regulatory limits.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 79 of 90 E4.13.1.2 Site-Specific Analysis for NAPS SLR This issue concerns the direct impacts from facilities involved in supplying nuclear fuel to nuclear power plants and disposing of radioactive waste.

As stated above, impacts to individuals from radioactive gaseous and liquid releases would remain at or below regulatory limits as long as facilities operate under a valid license issued by either the NRC or an agreement state. NAPSs nuclear fuel is supplied by vendors with the appropriate licenses and radioactive waste services are contracted with facilities having the appropriate licenses and permits (Dominion. 2020a).

NRC also stated in the 2013 GEIS that the generic issues related to the uranium fuel cycle would not be affected by continued operations associated with license renewal (NRC. 2013). This determination would apply to a second license renewal term as well, because NAPS would continue to utilize facilities with the appropriate licenses and permits.

Dominion finds that individual offsite radiological impacts from other than the disposal of spent fuel and high-level waste for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.13.2 OFFSITE RADIOLOGICAL IMPACTSCOLLECTIVE IMPACTS FROM OTHER THAN THE DISPOSAL OF SPENT FUEL AND HIGH-LEVEL WASTE - ISSUE 57, TABLE 4.0-1 E4.13.2.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.12.1.1]

In the 2013 license renewal GEIS, the NRC reviewed generic issues related to the uranium fuel cycle including offsite radiological impacts. As stated in the 2013 license renewal GEIS, the generic issues related to the uranium fuel cycle would not be affected by continued operations associated with license renewal of nuclear power plants.

There are no regulatory limits applicable to collective doses to the general public from fuel cycle facilities. All regulatory limits are based on individual doses. All licensed fuel cycle facilities are designed and operated to meet the applicable regulatory limits.

As NRC discussed in the 1996 GEIS, despite the lack of definitive data, some judgment as to the regulatory NEPA implications of these matters should be made and it makes no sense to repeat the same judgment in every case. NRC concluded in the 2013 GEIS that offsite radiological impacts are acceptable, in that these impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR 54 should be eliminated. Accordingly, while the NRC has not assigned a single level of significance for the collective effects of the fuel cycle, this issue was considered Category 1.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 80 of 90 For initial license renewals, the NRC codified its conclusion that offsite collective radiological impacts are not expected to be sufficiently large to preclude the option of extended operation under 10 CFR 54 for any plant. Accordingly, the NRC did not assign a single level of significance for the collective impacts of the uranium fuel cycle, considering this issue a Category 1 issue.

E4.13.2.2 Site-Specific Analysis for NAPS SLR This issue concerns the direct impacts from facilities involved in supplying nuclear fuel to nuclear power plants and disposing of radioactive waste. All licensed fuel cycle facilities are designed to meet the applicable regulatory limits and standards. As long as facilities operate under a valid license issued by either the NRC or an agreement state under the AEA (Public Law 83-703),

regulatory requirements would be met.

NAPSs nuclear fuel is supplied by vendors with the appropriate licenses and radioactive waste services are contracted with facilities having the appropriate licenses and permits (Dominion.

2020a).

NRC also stated in the 2013 GEIS that the generic issues related to the uranium fuel cycle would not be affected by continued operations associated with license renewal (NRC. 2013). This determination would apply to a second license renewal term as well, provided NAPS continues to utilize facilities with the appropriate licenses and permits.

Dominion finds that collective offsite radiological impacts from other than the disposal of spent fuel and high-level waste for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.13.3 NONRADIOLOGICAL IMPACTS OF THE URANIUM FUEL CYCLE -

ISSUE 58, TABLE 4.0-1 E4.13.3.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.12.1.1]

In the 2013 license renewal GEIS, the NRC reviewed generic issues related to the uranium fuel cycle including nonradiological impacts. As stated in the 2013 license renewal GEIS, the generic issues related to the uranium fuel cycle would not be affected by continued operations associated with license renewal of nuclear power plants.

Data on the nonradiological impacts of the fuel cycle are provided in Table S-3 of 10 CFR 51.51.

These data cover land use, water use, fossil fuel use, and chemical effluents. The significance of the environmental impacts associated with these data was evaluated by NRC in the 1996 GEIS on the basis of several relative comparisons. NRC noted that the impacts associated with uses of all of the above resources would be SMALL. Any impacts associated with nonradiological liquid releases from the fuel cycle facilities would also be SMALL. As a result, the aggregate Page-E-4-80

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 81 of 90 nonradiological impact of the uranium fuel cycle resulting from the renewal of an OL for a plant would be SMALL, and it was considered a Category 1 issue in the 1996 GEIS. NRC affirmed these findings in the 2013 GEIS.

For initial license renewals, the NRC codified its conclusion that the nonradiological impacts of the uranium fuel cycle resulting from the renewal of an OL for any plant would be SMALL.

E4.13.3.2 Site-Specific Analysis for NAPS SLR This issue concerns the direct impacts from facilities involved in supplying nuclear fuel to nuclear power plants and disposing of radioactive waste.

Nonradiological environmental impacts would remain at or below regulatory or permit limits as long as facilities operate in accordance with their federal, state, and local environmental permits.

NAPSs nuclear fuel is supplied by vendors with the appropriate licenses and permits and radioactive waste services are contracted with facilities having the appropriate licenses and permits.

NRC also stated in the 2013 GEIS that the generic issues related to the uranium fuel cycle would not be affected by continued operations associated with license renewal (NRC. 2013). This determination would apply to a second license renewal term as well, because NAPS would continue to utilize facilities with the appropriate licenses and permits.

Dominion finds that nonradiological impacts for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.13.4 TRANSPORTATION - ISSUE 59, TABLE E4.0-1 E4.13.4.1 Generic Analysis for Initial License Renewal Background [GEIS Section 4.12.1.1]

The impacts associated with transporting fresh fuel to one 1,000 megawatts electric model light-water reactor and with transporting spent fuel and radioactive waste (LLW and mixed waste) from that light water reactor are provided in Table S-4 in 10 CFR 51.52. Similar to Table S-3, and as indicated in 10 CFR 51.52, every environmental report prepared for the construction permit stage of a commercial nuclear power plant must contain a statement concerning the transport of fuel and radioactive waste to and from the reactor. A similar statement is also required in license renewal applications. Table S-4 forms the basis of such a statement.

In 1999, the NRC issued an addendum to the 1996 GEIS in which the agency evaluated the applicability of Table S-4 to future license renewal proceedings, given that the spent fuel is likely to be shipped to a single repository (as opposed to several destinations, as originally assumed in the preparation of Table S-4) and given that shipments of spent fuel are likely to involve more highly enriched fresh fuel (more than 4 percent as assumed in Table S-4) and higher-burnup Page-E-4-81

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 82 of 90 spent fuel (higher than 33,000 megawatt days per metric ton uranium [MWd/MTU] as assumed in Table S-4). In the addendum, the NRC evaluated the impacts of transporting the spent fuel from reactor sites to the candidate repository at Yucca Mountain and the impacts of shipping more highly enriched fresh fuel and higher-burnup spent fuel. On the basis of the evaluations, the NRC concluded that the values given in Table S-4 in 10 CFR 51.52 would still be bounding, as long as (1) the enrichment of the fresh fuel was 5 percent or less, (2) burnup of the spent fuel was 62,000 MWd/MTU or less, and (3) higher-burnup spent fuel (higher than 33,000 MWd/MTU) was cooled for at least five years before being shipped offsite. NRC affirmed these findings in the 2013 GEIS.

The NRC did not revisit the radiological impact analysis of transporting SNF away from reactor storage locations in the 2014 GEIS for Continued Storage of Spent Nuclear Fuel and again stated that the radiological impact analysis can be found in Table S-4 in 10 CFR 51.52 (NRC. 2014).

For initial license renewals, the NRC codified its conclusion that the transportation impacts of the uranium fuel cycle resulting from the renewal of an OL for any plant would be SMALL provided the following three conditions are met: (1) enrichment of the fresh fuel was 5 percent or less, (2) burnup of the spent fuel was 62,000 MWd/MTU or less, and (3) higher-burnup spent fuel (higher than 33,000 MWd/MTU) was cooled for at least five years before being shipped offsite.

E4.13.4.2 Site-Specific Analysis for NAPS SLR Dominion reviewed its plans and protocols for future fuel enrichment specifications, fuel loading plans, and spent fuel cooling with regard to the three Table S-4 conditions. NAPSs nuclear fuel is supplied by vendors with the appropriate licenses and transported to the site in accordance with NRC and U.S. Department of Transportation (DOT) requirements. Regarding the three Table S-4 conditions, Dominion anticipates the maximum enrichment of fuel to be used at NAPS during the proposed SLR operating term to be below 5 percent. For normal fuel batches, the average burnup level of the peak rod is not planned to exceed 60,000 MWd/MTU during the proposed SLR operating term. Furthermore, as presented in NAPS SLR ER Section E2.2.6, spent fuel is stored onsite in spent fuel pools for adequate cooling prior to transfer to onsite dry storage (Dominion.

2020a). Therefore, the three conditions are met.

As presented in Sections E4.11.1.2 and E4.11.4.2, Dominion has a comprehensive program of managing its radioactive and mixed wastes at NAPS that implements the regulatory requirements for management, storage, inspections, packaging, and shipping.

NAPS would comply with the applicable NRC, DOT, DOE, and state regulatory controls for packaging and transportation of radioactive wastes and SNF. Given that NAPS meets the three criteria discussed above and radioactive waste shipping procedures to implement regulatory requirement, the 2013 GEIS analysis of the incremental effects of a 20-year renewal does not materially differ between an initial 20-year renewal period and a second 20-year renewal period.

The impacts (e.g., direct radiation) of a transportation event would be discrete from other transportation events and accumulation of dose by the public other than persons in the cab of a truck transporting the material on subsequent trips would be unlikely. The packaging of radioactive materials in accordance with NRC and DOT regulations would minimize exposure.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 83 of 90 Further, the transportation events are unlikely to be staffed by the same person throughout a license term and into a second.

Dominion finds that impacts to transportation for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

E4.14 TERMINATION OF NUCLEAR POWER PLANT OPERATIONS AND DECOMMISSIONING - ISSUE 60, TABLE E4.0-1 E4.14.1 GENERIC ANALYSIS FOR INITIAL LICENSE RENEWAL BACKGROUND [GEIS SECTIONS 4.12.2 AND 4.12.2.1]

The impacts of decommissioning nuclear plants were evaluated in the Generic Environmental Impact Statement for Decommissioning Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors (NUREG-0586).

This section describes and discusses the environmental consequences of terminating nuclear power plant operations and decommissioning, but the only impacts attributable to the proposed action (license renewal) are the effects of an additional 20 years of operations on the impacts of decommissioning. The majority of the impacts associated with plant operations would cease with reactor shutdown; however, some impacts would remain unchanged, while others would continue at reduced or altered levels. Some new impacts might also result directly from terminating nuclear power plant operations.

Terminating nuclear power plant operations would result in the cessation of actions necessary to maintain the reactor, as well as a significant reduction in the workforce. The NRC presumes that terminating nuclear power plant operations would not immediately lead to the dismantlement of the reactor or other infrastructure, much of which would still be in use to support other units on site that continued to operate. Even for sites with just one unit, some facilities would remain in operation to ensure that the site was maintained in safe shutdown condition.

E4.14.2 SITE-SPECIFIC ANALYSIS FOR NAPS SLR Only the incremental increase in the impacts of termination of plant operations and decommissioning attributable to continued operation during the proposed SLR operating term is within the scope of this issue. The proposal to continue operation during an SLR operating term does not include construction of additional plant structures that would require decommissioning and additional workers are not anticipated for the license term that would incrementally increase socioeconomic impacts of termination of plant operations. (Dominion. 2020a)

Application of ALARA principles during the operating years of the proposed SLR operating term would minimize increases in radioactivity in the structures and equipment to be decommissioned.

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 84 of 90 Spent fuel removed from the spent fuel pool at NAPS will be stored in an NRC-licensed ISFSI.

The ISFSI used to accommodate the increased spent fuel volume would require decommissioning. Its decommissioning would be a separate licensing action if the ISFSI is not empty prior to plant decommissioning.

Additional workers that would incrementally increase socioeconomic impacts of termination of plant operations are not anticipated for the proposed SLR operating period (Dominion. 2020a).

As stated in Section E4.8.2.2, Dominion expects its tax payments and its beneficial impact on the local taxing entities to continue during the SLR term. The tax revenue socioeconomic impact of termination of operations would not be appreciably affected by the additional years of operation under an SLR.

Dominion would plan and conduct decommissioning activities in accordance with NRC-reviewed methods and evaluate anticipated environmental impacts to ensure that they are bounded by previously issued environmental assessments or are SMALL. Site restoration activities would be conducted in accordance with state and local regulations and permits, ensuring that environmental impacts would be SMALL.

Given Dominions radiation protection and radioactive waste management programs and no appreciable changes in socioeconomic aspects of plant operation, Dominion finds that continued operations during an SLR term would be a SMALL impact on terminating operations and decommissioning on all resources.

NRC determined in the GEIS that only the decommissioning portion of this issue would be impacted by license renewal and that the impact would be SMALL. This determination would apply to a second license renewal term as well. ALARA principles would continue to minimize increases in radioactivity in the structures and equipment to be decommissioned in a second renewal term as in a first. Spent fuel removed from the spent fuel pool at NAPS will be stored in an NRC licensed ISFSI. As presented in Section E4.13.4.2, the ISFSI at NAPS would not accommodate the volume of spent fuel generated during a SLR term, so additional options for fuel storage would be addressed under a separate licensing action as needed and in accordance with regulatory requirements. Finally, as discussed above, tax payments would continue during the SLR, providing relatively the same beneficial impact as during the current license term.

Dominion finds that impacts from termination of nuclear power plant operations and decommissioning for the proposed SLR term would be SMALL. Based on the discussion provided above, no new and significant information was identified, and the impacts for this issue with respect to an SLR term for NAPS are, as supplemented above, materially consistent with the conclusions in the previously submitted ER (Dominion. 2020a).

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Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 88 of 90 Abbreviations, Acronyms, and Symbols AEA Atomic Energy Act ALARA as low as reasonably achievable bgs below ground surface BMP best management practice CFR Code of Federal Regulations cfs cubic feet per second CLI U.S. Nuclear Regulatory Commission Memorandum and Order CZMP Coastal Zone Management Program DBA design-basis accident dBA A-weighted decibels DOE Department of Energy DOT Department of Transportation EFH essential fish habitat EMF electromagnetic field EPA U.S. Environmental Protection Agency ER environmental report ESA Endangered Species Act FR Federal Register FY fiscal year GEIS NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants gpd gallons per day gpm gallons per minute gpma average gallons per minute for the month (rounded to nearest gpm)

Gy/d Gray per day HLW high-level waste IAEA International Atomic Energy Agency ISFSI independent spent fuel storage installation kV Kilovolt LLRW low-level radioactive waste LLW low-level waste

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 89 of 90 LR license renewal MEI maximally exposed individual mg/l milligram per liter MGD million gallons per day MGM million gallons per month MGY millions of gallons per year mrem millirem (milli roentgen equivalent man) msl mean sea level MWd/MTU megawatt days per metric ton uranium NAAQS national ambient air quality standards NANIC North Anna Nuclear Information Center NAPS North Anna Power Station NEPA National Environmental Policy Act NOV notice of violation NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NUREG U.S. Nuclear Regulatory Commission Technical Report Designation NYA not yet available ODCM offsite dose calculation manual OL operating license OSHA Occupational Safety and Health Administration PCB polychlorinated biphenyl pCi/l picoCuries per liter PEO period of extended operation PWR pressurized water reactor rad/d rad per day RCRA Resource Conservation and Recovery Act rem roentgen equivalent man REMP radiological environmental monitoring program ROW right-of-way RWST Refueling Water Storage Tank SEIS supplemental environmental impact statement

Serial No: 22-211 Docket Nos.:50-338/339 Supplement Page 90 of 90 SLR subsequent license renewal SNF spent nuclear fuel SPCC spill prevention, control, and countermeasure SWPPP stormwater pollution prevention plan SWS service water systems TDS total dissolved solids TSS total suspended solids UFSAR Updated Safety Analysis Report USACE U.S. Army Corps of Engineers VDEQ Virginia Department of Environmental Quality VDGIF Virginia Department of Game and Inland Fisheries VPDES Virginia Pollutant Discharge Elimination System WHTF waste heat treatment facility