ML23062A466

License Renewal Second Environmental Site Audit Plan Regarding the North Anna Power Station, Units 1 and 2, Subsequent License Renewal Application

ML23062A466
Person / Time
Site:	North Anna
Issue date:	03/08/2023
From:	Tam Tran NRC/NMSS/DREFS/ELRB
To:	Stoddard D Dominion Energy Virginia
References
EPID L-2020-SLE-0000
Download: ML23062A466 (1)

Text

Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd Glen Allen, VA 23060-6711

SUBJECT:

LICENSE RENEWAL SECOND ENVIRONMENTAL SITE AUDIT PLAN REGARDING THE NORTH ANNA POWER STATION, UNITS 1 AND 2, SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NUMBER: L-2020-SLE-0000) (DOCKET NUMBERS: 50-338 and 50-339)

Dear Daniel Stoddard:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the Dominion Energy Virginia Companys subsequent license renewal application for North Anna Power Station, Units 1 and 2 (North Anna). The second remote environmental audit was conducted during the week of March 6, 2023, by the NRC staff. This remote environmental audit activities were conducted in accordance with the environmental audit plan (Enclosure 1).

To develop the Supplemental Environmental Impact Statement, the NRC staff requests the information described in the environmental audit needs list (Enclosure 2) be made available on the North Anna online reference portal (Agencywide Documents Access and Management System ML20269A465), to the extent possible, prior to the environmental site audit. A draft schedule of site tours by means of photographs and/or videos (Enclosure 3) and tele-meetings (e.g., Microsoft Teams meetings) for the audit is also provided.

The NRC staff transmitted the draft environmental needs to Ellery Baker of your staff by email on February 16, 2023.

March 8, 2023

D. Stoddard If you have any questions, please contact me via e-mail at Tam.Tran@nrc.gov.

Sincerely, Tam Tran, Project Manager Environmental Review License Renewal Branch Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. 50-338 and 50-339

Enclosures:

As stated cc w/encls: Listserv Signed by Tran, Tam on 03/08/23

D.Stoddard

SUBJECT:

LICENSE RENEWAL SECOND ENVIRONMENTAL SITE AUDIT PLAN REGARDING THE NORTH ANNA POWER STATION, UNITS 1 AND 2, SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NUMBER: L-2020-SLE-0000) (DOCKET NUMBERS: 50-338 and 50-339)

DATED:

DISTRIBUTION:

E-MAIL:

PUBLIC RidsNrrPMNorthAnna Resource LGibson, NRR/DNRL TTran, NMSS/REFS TSmith, NMSS/REFS BSmith, NRR/DNRL BThomson, NRR/DNRL EMiller, NRR/DORL DRoth, OGC KGamin, OGC STurk, OGC MMcCoppin, OEDO SBurnell, HQ/OPA LWilkins, OCA DMcIntyre, HQ/OPA RHannah, RII/OPA JPelchat, RII/ORA ELea, RII/ORA KCarrington, RII/DRP MTobin, RII/DRP PCooper; RII/DRS SDowney, RII/DRS BDesai, RII/DRS JDozier; NRR/DRA Paul.Aitken@dominionenergy.com ellery.j.baker@dominionenergy.com ADAMS Accession No.: ML23062A466

• concurrence via email OFFICE PM:REFS LA:REFS BC:REFS NAME TTran

• AWalker-Smith TSmith DATE 03/07/2023 03/08/2023 03/08/2023 OFFICE PM:REFS NAME TTran DATE 03/08/2023 March 8, 2023 LICENSE RENEWAL SECOND ENVIRONMENTAL AUDIT PLAN NORTH ANNA POWER STATION, UNITS 1 AND 2

1. Background By letter dated August 24, 2020 (Agencywide Documents Access and Management Systems Package ML20246G703), Dominion Energy Virginia, submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the North Anna Power Station, Units 1 and 2 (North Anna), renewed facility operating licenses NPF-4 and NPF-7. By letter the staff is reviewing the information contained in the environmental report (ER) of the license renewal application (LRA) per title 10 of the Code of Federal Regulations (10 CFR) part 51.

During the staffs review, the staff is conducting a second remote environmental audit of the North Anna site. This audit is conducted to improve understanding, to verify information, and to identify information that will require docketing to support the preparation of an environmental impact statement. Specifically, the NRC staff will identify pertinent environmental data, review the facility and area, and obtain clarifications regarding information provided in the ER.

2. Environmental Audit Bases License renewal requirements are specified in 10 CFR part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. Licensees are required by 10 CFR 54.23 to submit an ER that complies with the requirements in 10 CFR part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, as part of the LRA.

The NRC staff is required to prepare a site-specific supplement to the 2021 draft Supplemental Environmental Impact Statement (SEIS). Consistent with 87 FR 68522, during the scoping process required in 10 CFR part 51, the NRC staff is required to define the proposed action, identify significant issues which must be studied in depth, and to identify those issues that can be eliminated from further study.

3. Environmental Audit Scope The scope of this environmental audit for the North Anna subsequent license renewal review is to identify those issues which are new and significant and those issues which can be eliminated from further study and to identify the environmental resources that must be adequately described and evaluated in the site-specific SEIS. Audit team members will focus on reviewing the documents and requested information listed in the North Anna Environmental Audit Needs List (Enclosure 2) and discussing the information with the applicants subject matter experts.

4. Information and Other Material Necessary for the Environmental Audit As described in the Site Audit Needs List (Enclosure 2).

5. Environmental Audit Team Members and Resource Assignments The environmental audit team members and their specific discipline assignments are shown in the table below.

Discipline Team Members Environmental Management Oversight Ted Smith, NRC Environmental Project Manager Tam Tran, NRC Historic and Cultural Resources (Section 106 Consultation)

Robert Hoffman w/ Lance Rakovan, NRC Replacement Power Alternatives and Cumulative Impacts Robert Hoffman, NRC Terrestrial Ecology, Land Use, and Visual Caroline Hsu, NRC Groundwater and Geologic Environment Lifeng Guo, NRC Surface Water Lifeng Guo and Nancy Martinez, NRC Aquatic Ecology and Federally Protected Ecological Resources Briana Arlene, NRC Microbiological Hazards Briana Arlene, NRC Termination of Operations and Decommissioning Beth Alferink, NRC Human Health Beth Alferink, NRC Waste Management, Beth Alferink w/ Don Palmrose, NRC Spent Nuclear Fuel and Uranium Fuel Cycle Beth Alferink, NRC Postulated Accidents Jerry Dozier, NRC Air Quality, Noise, Meteorology and Climatology, Greenhouse Gas Emission, Climate Change Nancy Martinez, NRC Socioeconomics and Environmental Justice Jeff Rikhoff

6. Logistics The environmental audit will be conducted during the week of March 6, 2023. An entrance meeting will be held with the applicant management at the beginning of the audit. An exit meeting will be held at the end of this audit. These meetings will be conducted using Microsoft Teams software.

7. Special Requests The staff requests that the applicant make available on the North Anna online reference portal, the information identified on the Environmental Audit Needs List (Enclosure 2) prior to the audit.

Plant staff who are subject matter experts in the disciplines listed on the Environmental Site Audit Needs List should be available for interviews, to be conducted via tele-meetings.

8. Deliverables An audit summary report is scheduled to be issued by the NRC staff within 90 days from the end of the environmental audit.

NORTH ANNA POWER STATION, UNITS 1 AND 2 LICENSE RENEWAL SECOND ENVIRONMENTAL AUDIT NEEDS LIST Please be prepared to discuss the following information/audit needs and make the following available during the environmental site audit.

Questions, Document Needs, and Breakout Sessions Specific questions and document needs are provided below by resource area. In addition, please provide for breakout meeting sessions using Microsoft Team with the subject matter expert(s) and/or the contractor(s) responsible for the following topics who can also discuss the corresponding information requests, as described below. The staff uses these meeting sessions as needed to resolve or clarify any outstanding data needs or questions arising from the environmental audit.

Audit Needs:

General GEN-1 Please provide any relevant updates to table B-2 of the U.S. Nuclear Regulatory Commissions (NRCs) 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 Report for Comment (DSEIS) (ML21228A084) that have transpired since the NRCs issuance of the DSEIS in August 2021. If any permits have expired since submitting the license renewal application to the NRC, please provide the status of those permits and/or renewals.

GEN-2 Have there been any documented unplanned releases of radioactive materials (unplanned/ inadvertent radioactive liquid or gaseous releases) since Dominions most recent environmental request for additional information (RAI) responses dated February 22, 2021 (ML21053A433)? If so, please provide a written description of the releases and be prepared to discuss these releases in relation to the following environmental issues, which were previously dispositioned as generic (Category 1) issues in the DSEIS, as applicable.

A. Aquatic Resources - Exposure of aquatic organisms to radionuclides (Arlene)

B. Groundwater - Radionuclides released to groundwater (including unplanned or inadvertent releases to soil and subsurface) (Guo)

C. Human Health - Radiation exposures to the public (Alferink)

D. Human Health - Radiation exposures to plant workers (Alferink)

E. Surface Water Resources - Discharge of metals in cooling system effluent (Guo)

F. Surface Water Resources - Discharge of biocides, sanitary wastes, and minor chemical spills (Guo)

G. Terrestrial Resources - Exposure of terrestrial organisms to radionuclides (Arlene)

H. Uranium Fuel Cycle - Transportation (Alferink)

I. Waste Management - Low-level waste storage and disposal (Alferink)

J. Waste Management - Mixed-waste storage and disposal (Alferink)

K. Waste Management - Offsite radiological impacts of spent fuel and high-level waste disposal (Alferink)

GEN-3 Have there been any reportable inadvertent releases or spills of nonradioactive contaminants since Dominions Environmental Report, Supplement 1, dated September 28, 2022 (ML22272A041). If so, please provide a written description of the releases or spills and be prepared to discuss these releases or spills in relation to the following environmental issues, which were previously dispositioned as generic (Category 1) issues in the DSEIS, as applicable.

A. Aquatic Resources - Effects of nonradiological contaminants on aquatic organisms (Arlene)

B. Groundwater Resources - Groundwater contamination and use (non-cooling system impacts) (Guo)

C. Human Health - Human health impacts from chemicals (Alferink)

D. Surface Water Resources - Discharge of metals in cooling system effluent (Guo & Martinez)

E. Surface Water Resources - Discharge of biocides, sanitary wastes, and minor chemical spills (Guo & Martinez)

F. Waste Management - Mixed-waste storage and disposal (Alferink)

G. Waste Management - Nonradioactive waste storage and disposal (Alferink)

H. Uranium Fuel Cycle - Transportation (Alferink)

GEN-4 Is Dominion aware of any significant new information that has arisen following the issuance of the DSEIS in August 2021 that could affect the conclusions made in that document concerning the following site-specific (Category 2) environmental issues.

A. Groundwater Resources - Radionuclides released to groundwater (Guo)

B. Terrestrial Resources - Effects terrestrial resources (non-cooling system impacts) (Hsu)

C. Aquatic Resources - Impingement and entrainment of aquatic organisms (plants with once-through cooling systems or cooling ponds) (Arlene)

D. Aquatic Resources - Thermal impacts on aquatic organisms (plants with once-through cooling systems or cooling ponds) (Arlene)

E. Special Status Species and Habitats - Threatened, endangered, and protected species and essential fish habitat (Arlene)

F. Historic and Cultural Resources - Historic and cultural resources (e.g., new cultural resource surveys, new historic properties, new correspondence with SHPO or affected Indian Tribes) (Hoffman w/ Rakovan)

G. Human Health - Microbiological hazards to the public (plants with cooling ponds or canals or cooling towers that discharge to a river) (Arlene)

H. Human Health - Electric shock hazards (Alferink)

I. Postulated Accidents - Severe accidents (Dozier)

J. Environmental Justice - Minority and low-income populations (e.g., subsistence activities) (Hsu & Rikhoff)

L. Cumulative Impacts (Hoffman)

Alternatives ALT-1 Please confirm the continued validity of (or update, as appropriate) the technical bases presented in Dominion Energys August 2020, Environment Report (ER)

(ML20246G698) and associated correspondence used to support the identification of reasonable replacement power alternatives to renewing the operating license for North Anna Power Station Units 3 and 4.

Air Quality and Noise AQN-1 Provide updated estimated air pollutant emissions (2018-present) from operation of permitted sources at North Anna (i.e., SOx, NOx, CO, PM10, and VOCs).

AQN-2 Provide updated (2017-present) estimated greenhouse gas emissions (GHG) from operation at North Anna. As part of the response, include a brief discussion of the sources of greenhouse gas emissions and if Dominion anticipates additional GHG emission sources and emissions during the subsequent license renewal term.

AQN-3 Have field tests concerning ozone and nitrogen oxides emissions generated by North Annas 34.5 kV and 500 kV in-scope transmission lines been conducted? If so please, provide a copy of these tests.

AQN-4 Has Dominion received any notices of violation since 2019 associated with North Annas State Operating Permit (Air Permit No. 40726)?

AQN-5 Section E4.3.2 of the supplemental ER states North Anna Power Station (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. Provide examples of outreach to the public that have been conducted in the past for unplanned noise generating activities.

AQN-6 Has there been any changes in location/distance of nearby noise sensitive receptors since publication of draft NUREG-1437, Supplement 7-Second Renewal.

Surface Water SWR-1 Provide an update on Dominions 2018 National Pollutant Discharge Elimination System (NPDES) permit renewal (AQR-1).

SWR-2 Table E4.5-1a and table E4.5-1b of the ER supplement 1 list NAPS yearly and monthly surface water withdrawal for 2020-2021. Update the tables with 2022 data.

SWR-3 Section E4.6.13 indicates a warning letter was issued for a missed total suspended solids (TSS) monitoring requirement at Outfall 103. Provide a copy of this letter (WM-3).

SWR-4 Section E4.5.8 describes the water temperature measurements in Lake Anna. Water temperature data is provided for 2013-2017 and 2019-2021. Provide water temperature data for 2018 and 2022.

SWR-5 Section E4.5.12 provides water uses from the North Anna Reservoir for once-through cooling and the auxiliary cooling system. Table E4.5-1a and table E4.5-1b list NAPS yearly and monthly surface water withdrawal for 2020-2021. Update the tables with 2022 data.

SWR-6 Section E4.6.13 indicates a warning letter was issued for a missed TSS monitoring requirement at Outfall 103. Provide a copy of this letter.

SWR-7 A copy of the stormwater pollution prevention plan and the spill prevention, control and countermeasure plan Groundwater GWR-1 Update Table E4.5-2a and table E4.5-2b of the ER Supplement 1 to include 2022 data.

Terrestrial TR-1 Are there additional State-listed species for Spotsylvania and Louisa counties that are not listed in the ER or supplement to the ER? Please update the State-listed species list and describe potential impacts to such species from the proposed action.

TR-2 Please provide any surveys or records on the occurrence of the Appalachian grizzled skipper or Bachmans sparrow within the vicinity of the North Anna site.

Aquatic AQR-1 What is the status of Dominions 2018 NPDES permit renewal application? If Dominion has submitted, or the Virginia Department of Environmental Quality has issued, any of the following, please provide copies for the NRC staff review.

a.

NPDES permit application supplements or updates b.

draft NPDES permit c.

permit fact sheet d.

final NPDES permit e.

Clean Water Act 316(b) best technology available determinations on impingement mortality and entrainment AQR-2 In its analysis of Category 1 Issue No. 34, Dominion's September 28, 2022, Environmental Report, Supplement 1 describes compliance with Virginia Pollutant Discharge Elimination System permit limitations as a means of limiting the effects of nonradiological contaminants on aquatic organisms. Has Dominion reported any violations of NPDES permit limits for metals, including zinc, copper, and iron, in wastewater discharges, including stormwater, within the past five years? If so, please provide copies of such Dominion reports and/or notices of violation issued by the permitting authority.

HH-1 Have there been any Occupational Safety and Health Administration recordable injuries since Dominions Environmental Report, Supplement 1, dated September 28, 2022?

Microbiological Hazards MBH-1 Has Dominion observed any harmful algal blooms in the waste heat treatment facility since those described in Dominions February 22, 2021, response to NRC request for additional information on the SLR environmental review (ML21053A433; p. 1011)? If so, please describe the location and duration of these blooms and any steps Dominion took to monitor or mitigate the blooms.

Provide both a narrative description and a diagram or map, if available.

Waste Management WM-1 Are there any proposed changes or upgrades to the radioactive waste management programs (low-level radioactive waste, spent fuel, mixed waste) being considered during the license renewal term since Dominion's September 28, 2022, Environmental Report, Supplement 1?

WM-2 In its analysis of Category 1 Issue Nos. 54 and 55, Dominion's September 28, 2022, Environmental Report, Supplement 1 describes a warning letter for a missed TSS monitoring requirement at Outfall 103. Please summarize this incident, the contents of the letter, and describe what corrective actions were taken, if any following the warning letter.

WM-3 Provide a copy of the warning letter or applicable reference discussed in the analysis of Issue No. 54. Discussion of the same warning letter in Issue No. 55 provides a reference to Dominion 2020a, but the SLR ER does not discuss a warning letter associated with Outfall 103.

Cumulative Impacts CI-1 Please provide the name, description, location, and current status of any past, present, or reasonably foreseeable projects or actions that were newly identified or updated since those discussed in Dominion Energys February 22, 2021.

Response to NRC RAI (ML21053A433).

REMOTE SITE TOURS by MEANS of PHOTOGRAPHS or VIDEOS Please provide photographs and/or video documentation for the following site locations Title or Number Features Observed Essential Participants Optional Participants ST-1 General Site Tour/Plant Orientation

- identify nearby noise sensitive receptors if any ST-2 Groundwater tour:

a.

Potential sources (plant components and buried pipes, RWST, etc.), and relevant monitoring locations.

Lifeng Guo Lloyd Desotell ST-3 Cooling water intake and discharge tour:

a.

Intake and discharge structure, pump locations b.

Accessible permitted outfall locations Beth Alferink Lifeng Guo Nancy Martinez Lloyd Desotell ST-4 Radwaste tour:

a. Liquid radwaste system - discharge canal and discharge locations

b. Interim storage of spent nuclear fuel Beth Alferink Lifeng Guo Lloyd Desotell