ML23136A883
| ML23136A883 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/16/2023 |
| From: | James Holloway Virginia Electric & Power Co (VEPCO) |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 23-136 | |
| Download: ML23136A883 (1) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 16, 2023 10 CFR 50 10 CFR 51 10 CFR 54 United States Nuclear Regulatory Commission Serial No.: 23-136 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 RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION AND REQUEST FOR CONFIRMATION OF INFORMATION REGARDING ENVIRONMENTAL REVIEW OF SUBSEQUENT LICENSE RENEWAL APPLICATION FOR FACILITY OPERATING LICENSES NPF-4 AND NPF-7 By letter dated August 24, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20246G697), 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. The US Nuclear Regulatory Commission (NRC) has been reviewing the subsequent license renewal application (SLRA) for NAPS.
During the week of March 6, 2023, the NRC staff conducted an environmental audit of Dominion's records to confirm information submitted in the NAPS SLRA. During the audit, the NRC staff reviewed documents that contain information which will likely be used in the site-specific Environmental Impact Statement (SEIS) that supplement the 2021 draft Supplemental Environmental Impact Statement (87 FR 68522). As a result of this audit, the NRC provided a request for confirmation of information (RCI) by letter dated April 20, 2023 (ADAMS Package No. ML23081A096). This letter requested information that the staff will likely use to reach a conclusion in the SEIS, but which has not been previously docketed. The NRG staff also transmitted a request for additional information (RAI) by letter dated April 26, 2023 (ADAMS Package No. ML23081A528) to support completion of their review. Dominion agreed to respond to these requests within 30 days from the dates of their respective letters. provides Dominion's response to the RAI. Enclosure 2 provides Dominion's response to the RGI.
Serial No.: 23-136 Docket Nos.: 50-338/339 Page 2 of 6 If there are any questions regarding this submittal or if additional information is needed, please contact Mr. Paul Aitken at (804) 273-2818.
Sincerely, 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.
Acknowledged before me this /1:,~ay of t'/rJ. y , 2023.
My Commission Expires: 12-/3r
, I
/:it CRAIG D SLY Notary Public Commonwealth of Virginia Reg. # 7518653 ~
My Commission Expires December 31, 21_ Notary Public Commitments made in this letter: None
Enclosures:
Serial No.: 23-136 Docket Nos.: 50-338/339 Page 3 of 6 cc:
U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. Vaughn Thomas NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 04 F12 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.: 23-136 Docket Nos.: 50-338/339 Page 4 of 6 NRG 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. 0. 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.: 23-136 Docket Nos.: 50-338/339 Page 5 of 6 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.: 23-136 Docket Nos.: 50-338/339 Page 6 of 6 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.: 23-136 Docket Nos.: 50-338/339 Enclosure 1 Enclosure 1 RESPONSE TO NAPS SLRA REQUEST FOR ADDITIONAL INFORMATION ENVIRONMENTAL REVIEW Virginia Electric and Power Company (Dominion Energy Virginia)
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 1, Page 1 of 8 Response to NRC Request for Additional Information Environmental Review North Anna Power Station, Units 1 and 2 Subsequent License Renewal Application By letter dated August 24, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20246G697), 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. The US Nuclear Regulatory Commission (NRC) has been reviewing the subsequent license renewal application (SLRA) for NAPS.
During the week of March 6, 2023, the NRC staff conducted an environmental audit of Dominion's records to confirm information submitted in the NAPS SLRA. As a result of this audit, the NRC staff transmitted a request for additional information (RAI) by letter dated April 26, 2023 (ADAMS Package No. ML23081A528) to support completion of their review. Dominion agreed to respond to this request within 30 days from the date of the RAI letter.
This enclosure provides Dominions response to the RAI.
GEN-1 RAI:
REQUIREMENT: Title 10 of the Code of Federal Regulations (10 CFR) section 51.53(c)(3)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.
ISSUE: In August 2021, the U.S. Nuclear Regulatory Commission (NRC) staff issued 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 (draft Supplemental Environmental Impact Statement (DSEIS)) (Agencywide Documents Access and Management System ADAMS ML21228A084). The NRC staff is now preparing a site-specific environmental impact statement (EIS) in accordance with Commission Legal Issuance (CLI)-22-02 and CLI-22-03, both dated February 24, 2022, that considers the site-specific environmental impacts of subsequent license renewal (SLR) of North Anna. Table B-2 of the DSEIS, Operating Permits and Other Requirements, lists the permits and licenses issued by Federal, State, and local authorities for activities at North Anna, as identified in chapter E.9 of Virginia Electric and Power Company (Dominion) environmental report, dated August 2020 (ADAMS ML20246G698). As part of preparing the site-specific EIS, the staff must consider whether there have been
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 1, Page 2 of 8 any changes to operating permits or other requirements following the issuance of the DSEIS that could affect the conclusions made in the DSEIS.
REQUEST: Please provide any relevant updates to table B-2 of the DSEIS that have transpired since the NRC issued it in August 2021. If any permits have expired since submittal of the SLR application to the NRC, please provide the status of those permits and/or renewals.
Dominion Response to GEN-1 RAI:
The following permits have been renewed:
- 1. US Fish and Wildlife Service (USFWS) Depredation Permit, MB705136-0, is renewed annually and has a current expiration date of July 31, 2023.
- 2. Virginia Department of Environmental Quality (VDEQ) Above Ground Tank Registration for Facility ID-301265, ODCP No. FC-06-7030, was renewed in September 2020 for five years.
GEN-3 RAI:
REQUIREMENT: 10 CFR 51.53(c)(3)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.
ISSUE: In August 2021, the NRC staff issued the DSEIS. The NRC staff is now preparing a site-specific EIS that considers the site-specific environmental impacts of North Anna SLR on generic (Category 1) license renewal issues in accordance with CLI-22-02 and CLI-22-03. As part of preparing this site-specific EIS, the staff must consider whether any significant new information has arisen following the issuance of the DSEIS that could affect the conclusions made in the DSEIS.
REQUEST: Please provide dates, quantities, and references for any reportable inadvertent releases or spills of nonradioactive contaminants since Dominions Environmental Report, Supplement 1, dated September 28, 2022 (ADAMS ML22272A041), as discussed during the most recent audit held March 7 and 8, 2023.
In your response, please include a description of the releases or spills and a summary of whether or not these releases or spills impact conclusions presented in the supplement in relation to the following environmental issues, which were previously dispositioned as Category 1 issues in the DSEIS, as applicable.
- Aquatic Resources - Effects of non-radiological contaminants on aquatic organisms
- Groundwater Resources - Groundwater contamination and use (non-cooling system impacts)
- Human Health - Human health impacts from chemicals
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 1, Page 3 of 8
- Surface Water Resources - Discharge of metals in cooling system effluent
- Surface Water Resources - Discharge of biocides, sanitary wastes, and minor chemical spills
- Waste Management - Mixed-waste storage and disposal
- Waste Management - Nonradioactive waste storage and disposal Dominion Response to GEN-3 RAI:
- 1) On August 27, 2022, a transformer oil spill occurred below a NAPS Unit 2 transformer following a bushing fire. The volume of the oil spill onto the soil below the transformer was approximately 390 gallons (as of March 1, 2023). The associated condition report indicated that the oil was contained within the berm surrounding the transformer and had not migrated to Lake Anna. Following regulatory and procedural requirements, timely reporting and follow-up actions were taken with VDEQ and the NRC.
- There were no groundwater contamination or usage issues reported as a result of the oil spill.
- Station and remediation safety protocols were followed, there were no human health issues reported.
- Waste management protocols and procedures were followed, there were no storage or disposal issues reported.
- 2) On February 20, 2023, a discharge of hydrostatic test water from the sewage treatment extended aeration tank was commenced to Lake Anna (in accordance with the proper Virginia General Permit) following a successful hydrostatic test. A required sample analysis of the tank water showed a pH value of approximately 9.9, which was out of the permitted pH range of 6.0 - 9.0. Subsequently, the discharge of the tank water was secured, with an estimated discharge volume of approximately 354 gallons.
Following regulatory and procedural requirements, timely reports and actions were taken with VDEQ and the NRC.
- As of March 28, 2023, no aquatic resources impacts have been reported.
- No groundwater resources impacts have been reported.
- Station safety protocols were followed and there were no human health issues reported.
- Discharge of metals in cooling system effluent is not applicable to this release.
- Lake water sampled at the point of discharge prior to tank water release was measured to have a pH of 7.8, with no evidence of negative impacts. The only
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 1, Page 4 of 8 parameter reported outside the permit limits from this release was the measured pH level of approximately 9.9 for the tank water.
- Mixed waste storage and disposal issues are not applicable to this release.
- Discharge of the tank water was secured after discovery of the elevated pH.
No other waste management storage or disposal issues have been reported.
In summary, the two occurrences described above had no impact on the conclusions presented in the supplement, in relation to the identified environmental issues which were previously dispositioned as Category 1 issues in the DSEIS.
GEN-4 RAI:
REQUIREMENT: 10 CFR 51.53(c)(3)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.
ISSUE: In August 2021, the NRC staff issued the DSEIS. The NRC staff is now preparing a site-specific EIS that considers the site-specific environmental impacts of North Anna SLR on license renewal issues in accordance with CLI-22-02 and CLI 03. As part of preparing this site-specific EIS, for those license renewal issues for which the NRC staff performed a site-specific analysis and made site-specific conclusions in the DSEIS (i.e., Category 2 issues), the staff must consider whether any significant new information has arisen following the issuance of the DSEIS that could affect those analyses or result in the staff coming to different conclusions in the site-specific EIS.
REQUEST: 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 Category 2 environmental issues? If so, please describe the significant new information and explain how that information affects DSEIS conclusions. The relevant Category 2 issues are as follows:
- Groundwater- Radionuclides (e.g., tritium and plant-related gamma isotopes or hard-to-detect radionuclides) released to groundwater
- Terrestrial Resources - Effects terrestrial resources (non-cooling system impacts)
- Aquatic Resources - Impingement and entrainment of aquatic organisms (plants with once-through cooling systems or cooling ponds)
- Aquatic Resources - Thermal impacts on aquatic organisms (plants with once-through cooling systems or cooling ponds)
- Special Status Species and Habitats - Threatened, endangered, and protected species and essential fish habitat
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 1, Page 5 of 8
- Historic and Cultural Resources - Historic and cultural resources (e.g., new cultural resource surveys, new historic properties)
- Human Health - Microbiological hazards to the public Dominion Response to GEN-4 RAI:
Dominion has performed a review of environmental issues applicable to the NAPS site for new and significant information since issuance of the DSEIS in August 2021. This review did not identify any new, significant information that could affect the conclusions made in the DSEIS concerning the following environmental issues:
- Groundwater- Radionuclides (e.g., tritium and plan-related gamma isotopes or hard-to-detect radionuclides) released to groundwater
- Terrestrial Resources - Effects terrestrial resources (non-cooling system impacts)
- Aquatic Resources - Impingement and entrainment of aquatic organisms (plants with once-through cooling systems or cooling ponds)
- Aquatic Resources - Thermal impacts on aquatic organisms (plants with once-through cooling systems or cooling ponds)
- Special Status Species and Habitats - Threatened, endangered, and protected species and essential fish habitat
- Historic and Cultural Resources - Historic and cultural resources (e.g., new cultural resource surveys, new historic properties)
- Human Health - Microbiological hazards to the public
- Human Health - Electric shock hazards
- Postulated Accidents - Severe accidents
- Environmental Justice - Minority and low-income populations (e.g.,
subsistence activities)
- Cumulative Impacts AQN-1 RAI:
REQUIREMENT: 10 CFR 51.53(c)(3)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.
ISSUE: In 2021, the NRC staff issued the DSEIS, which analyzed greenhouse gas emissions and climate change impacts. The NRC is now preparing a site-specific environmental impact statement in accordance with Commission Legal Issuance (CLI)
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 1, Page 6 of 8 02 and CLI-22-03, both dated February 24, 2022, that considers the site-specific environmental impacts of subsequent license renewal (SLR) of North Anna on those issues dispositioned as generic (Category 1) issues in table B-1 in appendix B to subpart A of 10 CFR part 51 and the DSEIS. As part of preparing this site-specific EIS, the staff must consider whether any significant new information has arisen following the issuance of the DSEIS.
REQUEST: Provide updated (2017-present) estimated greenhouse gas emissions (GHG) from operation at North Anna. As part of the response include the following:
- for each year of estimated GHG emissions, provide the breakdown of each source that contributed to the annual total emissions and include the supporting calculations.
- as discussed during the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-3, the reason that 2022 annual GHG emissions were greater than prior years.
- identify if Dominion anticipates additional GHG emission sources and emissions during the SLR term.
Dominion Response to AQN-1 RAI:
The CO2e (e for equivalent) emissions account from the sites equipment listed in the air permit is based on runtime hours and diesel fuel usage. The CO2e emissions account from the fire suppression systems is based on the amount of CO2 added to two fire suppression storage tanks (one 6-ton and one 17-ton) by percentage and/or pounds (lbs) to replace what is used or lost through normal, minor equipment leakage.
The CO2e emissions account from onsite refrigerant inventory includes the amount in each unit containing 50 lbs or greater, as well as the inventory in storage tanks.
Refrigerant inventories onsite will also vary year-to-year based on equipment usage.
The Annual Greenhouse Gas Emissions Inventory Summary follows:
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 1, Page 7 of 8 ANNUAL GREENHOUSE GAS EMISSIONS INVENTORY
SUMMARY
, 2017-2022(1)
Carbon Dioxide Equivalent (CO2e) Emissions, Metric Tons Emission Source 2017 2018 2019 2020 2021 2022 Greenhouse Gas Sources (a) 919 1037 989 922 845 639 HFC Emissions 482.08 469.99 461.24 485.21 485.21 466.37 (b)
SF6 Emissions -- -- -- -- -- --
CO2 Other Activities 7.47 4.35 9.38 7.44 11.41 7.48 Station Blackout EDG 54.28 83.08 58.25 80.38 59.40 59.73 Station Primary EDGs 374.84 479.55 460.38 349.28 288.81 105.38 Misc. Emergency Generators -- -- -- -- 0.00 --
Workforce Commuting (c) 4070 4070 4070 4070 4070 4070 TOTAL 4989 5107 5059 4992 4915 4709 (1) GHG emissions are based on the following:
- a. The sources of greenhouse gases associated with the NAPS facility include equipment listed in the air permit, CO2 added to the fire suppression systems, SF6 used for electrical breaker cooling, and hydrofluorocarbon refrigerant used for equipment on site.
- b. SF6 emissions previously included were representative of inventory onsite and not emissions to atmosphere.
- c. Workforce commuting calculations are based on:
- i. Statistical information from U.S. Census Bureau (USCB) indicates that 3.6 percent of Virginia workers in the Transportation and Warehouse and Utilities Industry carpool to work (USCB 2015). The number of NAPS employees as of January 2017 was 903. Utilizing the 3.6 percent USCB carpool statistic, a value of "870 passenger vehicles per day was utilized.
ii. Using the Environmental Protection Agencys (EPA) Greenhouse Gas Equivalencies Calculator, the CO2e/year for 870 vehicles is 4,269 metric tons (EPA 2019).
iii. Carbon dioxide equivalent or CO2e means the number of units of another greenhouse gas that has the same global warming effect as a single unit of carbon dioxide. As an example; 25 metric tons of carbon dioxide emissions has the equivalent global warming effect as a single metric ton of methane emissions.
(Based on Table A-1 to Subpart A of 40 CFR Part 98).
The annual GHG emissions for 2022 were previously presented during the environmental audit as greater than prior year, due to the inclusion of all SF6 inventory onsite rather than SF6 emissions to atmosphere. This has been corrected in the above Table, since only SF6 emissions to atmosphere should have been included (see also Table note (b) above).
Dominion does not anticipate additional GHG emission sources and emissions during the SLR term.
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 1, Page 8 of 8 AQN-2 RAI:
REQUIREMENT: 10 CFR 51.53(c)(3)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.
ISSUE: In 2021, the NRC staff issued the DSEIS, which analyzed greenhouse gas emissions and climate change impacts. The NRC is now preparing a site-specific environmental impact statement in accordance with Commission Legal Issuance (CLI) 02 and CLI-22-03, both dated February 24, 2022, that considers the site-specific environmental impacts of subsequent license renewal (SLR) of North Anna on those issues dispositioned as generic (Category 1) issues in table B-1 in appendix B to subpart A of 10 CFR part 51 and the DSEIS.
REQUEST: Provide updated estimated air pollutant emissions (2018-present) from operation of permitted sources at North Anna (i.e., SOx, NOx, CO, PM10, and VOCs).
Dominion Response to AQN-2 RAI:
Dominion provides the following updated estimated air pollutant emissions (2018-2022) from operation of permitted sources at NAPS.
REPORTED ANNUAL AIR EMISSIONS
SUMMARY
, 2018-2022 NAPS Annual Emissions (tons/year)
YEAR SO2 NOX CO PM10 VOCs HAPs 2018 0.05 10.64 2.63 0.17 0.32 NA 2019 0.04 9.54 2.4 0.16 0.28 NA 2020 0.04 8.4 2.04 0.13 0.26 NA 2021 0.04 8.4 2.07 0.14 0.25 NA 2022 0.04 9.3 2.33 0.15 0.27 NA
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 2 Enclosure 2 RESPONSE TO NAPS SLRA REQUEST FOR CONFIRMATION OF INFORMATION ENVIRONMENTAL REVIEW Virginia Electric and Power Company (Dominion Energy Virginia)
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 2, Page 1 of 8 Response to NRC Request for Confirmation of Information Environmental Review North Anna Power Station, Units 1 and 2 Subsequent License Renewal Application By letter dated August 24, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20246G697), 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. The US Nuclear Regulatory Commission (NRC) has been reviewing the subsequent license renewal application (SLRA) for NAPS.
During the week of March 6, 2023, the NRC staff conducted an environmental audit of Dominion's records to confirm information submitted in the NAPS SLRA. During the audit, the NRC staff reviewed documents that contain information which will likely be used in the site-specific Environmental Impact Statement (SEIS) that supplement the 2021 draft Supplemental Environmental Impact Statement (87 FR 68522). As a result of this audit, the NRC provided a request for confirmation of information (RCI) by letter dated April 20, 2023 (ADAMS Package No. ML23081A096). This letter requested information that the staff will likely use to reach a conclusion in the SEIS, but which has not been previously docketed. Dominion agreed to respond to this request within 30 days from the date of the RCI letter.
This enclosure provides Dominions response to the RCI.
GEN-2 RCI:
Please confirm that there have been no 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).
Dominion Response to GEN-2 RCI:
This information has been confirmed to be correct as stated.
WM-2 (SWR-3) RCI:
Dominion's September 28, 2022, Environmental Report (ER), Supplement 1 analysis of Category 1 Issue Nos. 15, 24, 32, 33, 34, 39, 54 and 55 describes a warning letter for a missed total suspended solids (TSS) monitoring requirement at Outfall 103.
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 2, Page 2 of 8 During the March 2023 environmental audit, the NRC staff reviewed a warning letter from the Virginia Department of Environmental Quality and Dominion Energys response to the warning letter. It is the NRC staffs understanding that the sample was taken at Outfall 103, but the analysis of the sample was delayed beyond the 7-day holding time, which invalidated the results for Outfall 103 for TSS. As discussed during the March audit, North Annas sampling procedure was updated to ensure that: (a) the isotopic analysis report is transmitted with the sample to avoid a potential delay in analysis, (b) laboratory reports are reviewed promptly, and (c) resampling is conducted if samples exceed the allowable holding time. Please confirm that the NRC staff understanding of the missed TSS monitoring requirement, associated letters, and site corrective actions are correct.
Dominion Response to WM-2 (SWR-3) RCI:
This information has been confirmed to be correct as stated.
AQ-2 RCI:
North Annas Virginia Pollutant Discharge Elimination System (VPDES) permit limits metals, including zinc, copper, and iron, in wastewater discharges, including stormwater. From information gathered during the environmental site audit, the NRC staff understands that Dominion has reported no VPDES permit violations related to limits on discharge of metals within the past five years. Please confirm this understanding is correct.
Dominion Response to AQ-2 RCI:
This information has been confirmed to be correct as stated.
MBH-1 RCI:
From information gathered during the environmental site audit, the NRC staff understands that Dominion has observed no harmful algal blooms in the Waste Heat Treatment Facility (WHTF) since those described in Dominions February 22, 2021, response to NRC request for additional information on the subsequent license renewal (SLR) environmental review (ML21053A433; p. 1011). Please confirm this understanding is correct.
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 2, Page 3 of 8 Dominion Response to MBH-1 RCI:
This information has been confirmed to be correct as stated.
GWR-1 RCI:
During the site audit on March 7, 2023, Dominion updated table E4.5-2a and table E4.5-2b of the North Anna Power Station (NAPS) SLR ER Supplement 1 with the 2022 groundwater withdrawal data as shown the tables below. Please confirm that data shown below are correct.
Table E4.5-2a NAPS Yearly Groundwater Withdrawal Summary Monthly Monthly Monthly Yearly Total Year Maximum Average Minimum MGM gpma MGM gpma MGM gpma MGY gpd 2022 0.27 6.13 0.17 3.77 0.05 1.14 1.99 5,443.59 2013- 0.50 11.57 0.22 4.99 0.04 1.01 2.63 7,196.09 2022 MGY = millions of gallons MGM = millions of gallons per month gpd = gallons per day gpma = average gallons per minute for the month Table E4.5-2b NAPS Monthly Groundwater Withdrawal Summary Groundwater Wells (MGM) Monthly Total Month NANIC #4 #6 #7 #8 MGM gpma January-22 0.008 (a) 0.026 0.000 0.017 0.051 1.136 February-22 0.008 (a) 0.074 0.000 0.007 0.088 2.190 March-22 0.008 (a) 0.253 0.005 0.000 0.266 5.968 April-22 0.008 (a) 0.144 0.000 0.000 0.152 3.516 May-22 0.010 (a) 0.131 0.000 0.000 0.141 3.165 June-22 0.011 (a) 0.163 0.001 0.003 0.177 4.104 July-22 0.013 (a) 0.178 0.003 0.000 0.193 4.326
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 2, Page 4 of 8 August-22 0.012 (a) 0.197 0.028 0.000 0.236 5.291 September-22 0.011 (a) 0.225 0.028 0.000 0.265 6.127 October-22 0.011 (a) 0.212 0.005 0.000 0.227 5.092 November-22 0.011 (a) 0.094 0.001 0.000 0.106 2.442 December-22 0.012 (a) 0.072 0.000 0.000 0.084 1.886 (a) Not installed, not operational, or abandoned gpma = average gallons per minute for the month Dominion Response to GWR-1 RCI:
This information has been confirmed to be correct as stated.
SWR-1 (AQ-2) RCI:
During site audit on March 7, 2023, Dominion stated that its VPDES permit has been administratively extended based on the terms and conditions of the existing permit. A confirmation of the extension was provided in the correspondence from the Virginia Department of Environmental Quality dated April 3, 2019. Please confirm that the above statements regarding Dominions VPDES permit are correct.
Dominion Response to SWR-1 (AQ-2) RCI:
This information has been confirmed to be correct as stated.
SWR-2 (SWR-5) RCI:
During site audit on March 7, 2023, Dominion updated table E4.5-1a and table E4.5-1b of the NAPS SLR ER Supplement 1 with the 2022 surface water withdrawal data as shown below. Please confirm that data shown below are correct.
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 2, Page 5 of 8 Table E4.5-1a NAPS Yearly Surface Water Withdrawal Summary Monthly Monthly Average Monthly Minimum Yearly Total Year Maximum MGM gpma MGM gpma MGM gpma MGY MGD 2022 72,784.00 1,630,466 55,315.46 1,262,203 27,678.00 747,693 663,785.46 1,818.59 2013- 74,653.18 1,672,338 56,091.11 1,278,346.6 23,479.88 525,983 673,093.38 1,843.08 2022 MGY = millions of gallons MGM = millions of gallons per month gpma = average gallons per minute for the month (rounded to nearest gpm)
Table E4.5-1b NAPS Monthly Surface Water Withdrawal Summary Month Surface Water Withdrawals (MGM) Total North Anna Lake Anna Lake Anna Unit NA3 Mini-SY MGM gpma Dam Unit #1 #2 CW CW January-22 1709.91 19876.00 20638.00 (a) 0.00 42,223.91 945,876.12 February-22 2001.55 19462.00 19872.00 (a) 0.00 41,335.55 1,025,187.25 March-22 0.00 24102.00 3576.00 (a) 0.00 27,678.00 620,026.88 April-22 0.00 29304.00 24383.00 (a) 0.00 53,687.00 1,242,754.63 May-22 0.00 35899.00 35670.00 (a) 0.00 71,569.00 1,603,248.21 June-22 0.00 33898.00 34479.00 (a) 0.00 68,377.00 1,582,800.93 July-22 0.00 36389.00 35840.00 (a) 0.00 72,229.00 1,618,033.15 August-22 0.00 36716.00 36068.00 (a) 0.00 72,784.00 1,630,465.95 September-22 0.00 24208.00 34350.00 (a) 0.00 58,558.00 1,355,509.26 October-22 0.00 11627.00 34411.00 (a) 0.00 46,038.00 1,031,317.20 November-22 0.00 28293.00 28772.00 (a) 0.00 57,065.00 1,320,949.07 December-22 0.00 26228.00 26013.00 (a) 0.00 52,241.00 1,170,273.30
- 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
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 2, Page 6 of 8 Dominion Response to SWR-2 (SWR-5) RCI:
This information has been confirmed to be correct as stated.
SWR-7 RCI:
During the site audit on March 7, 2023, Dominion provided a copy of the NAPS Stormwater Pollution Prevention Plan (SWPPP) updated in May 2022. Section 7.1 in the SWPPP lists a non-polychlorinated biphenyls transformer oil spill on November 11, 2022. In NAPS SLR ER supplement section E4.5.11.2, a similar spill is described that occurred in 2021. Please confirm that (1) the two spills are the same event, (2) the date of the spill noted to occur on November 11, 2022, in the SWPPP contains an error, and (3) the year in that date should be 2021.
Dominion Response to SWR-7 RCI:
This information has been confirmed to be correct as stated.
SWR-8 RCI:
During the site audit on March 7, 2023, Dominion provided the following update/correction to the text in NAPS SLR ER section 3.6.1.1, Potential for Flooding:
Based on Federal Emergency Management Agency (FEMA) data, the majority of the NAPS property is located within Zone X, outside the 0.2 percent annual chance floodplain (500-year flood level). Small areas along the shores and canals have been designated as within the 1 percent annual chance (100-year flood level, Zone AE) floodplain with base flood elevations of 255 feet (NAVD88) (Figure 3.6-2).
Areas of moderate flooding between the 100-year and 500-year floods are not mapped by FEMA in this area. (FEMA 2019)
Please confirm that the text quoted above is accurate and correct.
Dominion Response to SWR-8 RCI:
This information has been confirmed to be correct as stated.
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 2, Page 7 of 8 AQN-3 RCI:
During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-3, Dominion stated that field tests concerning ozone and nitrogen oxides emissions generated by North Annas 34.5 kV and 500 kV in-scope transmission lines have not been conducted? Confirm that field tests concerning ozone and nitrogen oxides emissions generated by North Annas 34.5 kV and 500 kV in-scope transmission lines have not been conducted.
Dominion Response to AQN-3 RCI:
This information has been confirmed to be correct as stated.
AQN-4 RCI:
During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-4, Dominion stated that it has not received any notices of violation since 2019 associated with North Annas State Operating Permit (Air Permit No. 40726)? Confirm that Dominion has not received any notices of violation since 2019 associated with North Annas State Operating Permit.
Dominion Response to AQN-4 RCI:
This information has been confirmed to be correct as stated.
ALT-1 RCI:
Please confirm that during the March 8, 2023, Alternatives breakout session, Dominion Energy addressed the continued validity of the technical bases presented in their August 2020 ER (ML20246G698) and associated correspondence used to support the identification of reasonable replacement power alternatives to renewing the operating licenses for NAPS Units 1 and 2. Specifically, Dominion Energy confirmed the bases for including advanced nuclear generation as reasonable alternatives. Dominion Energy also confirmed the basis for considering natural gas and other fossil fuel generation as unreasonable for replacement of NAPS. Dominion Energy further indicated that their planning includes substantial additions of solar, wind, and battery resources, and that their projected goal for net zero carbon emissions in 2045 assumes that NAPS is relicensed.
Serial No.: 23-136 Docket Nos.: 50-338/339 Enclosure 2, Page 8 of 8 Dominion Response to ALT-1 RCI:
This information has been confirmed to be correct as stated.
CI-1 RCI:
In association with the March 8, 2023, Cumulative Impacts breakout session, Dominion provided information on three reasonably foreseeable projects being planned at NAPS that updated the information previously provided in Dominion Energys February 22, 2021, correspondence (ML21053A433, pgs. 2-8) regarding NRCs RAI (ML21028A390). Please confirm that the status of each of the following projects is correct, and that no additional projects have been identified in the interim:
- Cyber Security Testing Facility - construction ongoing; completion targeted July 2023.
- Wastewater Treatment Plant Replacement Project - construction ongoing; completion targeted August 2023.
- Main Generator Storage Building - Dominion Energy has subsequently determined that the Main Generator Storage Building would not be needed at North Anna, and that replacement main generators are planned to be stored in the current Generator Rewind Building as needed. Target replacement outages are 2030 for Unit 1 and 2031 for Unit 2.
Dominion Response to CI-1 RCI:
This information has been confirmed to be correct as stated.