ML24045A006

Comment (5) of Bettina Rayfield on Virginia Electric and Power Company; North Anna Power Station Units 1 and 2; Draft Environmental Impact Statement

ML24045A006
Person / Time
Site:	North Anna
Issue date:	02/13/2024
From:	Rayfield B State of VA, Dept of Environmental Quality
To:	Office of Administration
References
NRC-2020-0201, 89FR960 00005
Download: ML24045A006 (1)

Text

2/14/24, 6:44 AM blob:https://www.fdms.gov/43b95038-e915-46f9-88d8-678ec7fee8dc SUNSI Review Complete As of: 2/14/24, 6:44 AM Template=ADM-013 E-RIDS=ADM-03 Received: February 13, 2024 PUBLIC SUBMISSIONADD: Tam Tran, Ashley Status: Pending_Post Waldron, Antoinette Tracking No. lsk-vn1i-x4m2 Walker-Smith Mary Neely Comments Due: February 22, 2024 Comment (5) Submission Type: Web Publication Docket: NRC-2020-0201 Date:1/8/2024 Citation: 89 FR 960 Virginia Electric and Power Company; Dominion Energy Virginia; North Anna Power Station, Units 1 and 2

Comment On: NRC-2020-0201-0008 Virginia Electric and Power Company; North Anna Power Station Units 1 and 2; Draft Environmental Impact Statement

Document: NRC-2020-0201-DRAFT-0009 Comment on FR Doc # 2024-00147

Submitter Information

Email: EIR@deq.virginia.gov Government Agency Type: State Government Agency: Virginia Department of Environmental Quality

General Comment

Commonwealth of Virginia's comments on Docket ID NRC-2020-0201; NUREG-1437, Supplement 7a.

Attachments

02 13 24 signed 24-005F North Anna DEIS

blob:https://www.fdms.gov/43b95038-e915-46f9-88d8-678ec7fee8dc 1/1 February 13, 2024

Tam Tran U.S. Nuclear Regulatory Commission Sent via email: tam.tran@nrc.gov and regulations.gov

RE: U.S. Nuclear Regulatory Commission Draft Supplemental Environmental Impact Statement: Site-Specific Environmental Impact Statement for Subsequent License Renewal for North Anna Power Station Units 1 and 2, Draft Report for Comment (Docket ID NRC-2020-0201; NUREG-1437, Supplement 7a, draft; DEQ 24-005F).

Dear Tam Tran:

The Commonwealth of Virginia has completed its review of the draft supplemental environmental impact statement (DS EIS) for the above-referenced project. The Department of Environmental Quality (DEQ) is responsible for coordinating Virginias review of federal environmental documents prepared pursuant to the National Environmental Policy Act (NEPA) and responding to appropriate federal officials on behalf of the Commonwealth. This letter is in response to the above-referenced DSEIS.

The following agencies participated in this review:

Department of Environmental Quality Department of Wildlife Resources Department of Conservation and Recreation Department of Health Marine Resources Commission Virginia Energy Department of Aviation

The Virgnia Department of Agriculture and Consumer Services, Department of Historic Resources, Department of Forestry, Department of Transportation, Department of North Ann Power Station Units 1 and 2 DEQ 24-005F

Emergency Management, George Washington Planning District Commission, Thomas Jefferson Planning District Commission, Louisa County and Spotsylvania County also were invited to comment.

PROJECT DESCRIPTION

The U.S. Nuclear Regulatory Commission (NRC) issued a site-specific DSEIS for the subsequent license renewal of the North Anna Power Station Units 1 and 2. In 2020, Virginia Electric and Power Company, doing business as Dominion Energy Virginia (Dominion), submitted an application to the NRC, requesting subsequent license renewals. The North Anna, Unit 1 renewed facility operating license (NPF -4) expires at midnight on April 1, 2038; the North Anna, Unit 2 renewed facility operating license (NPF-7) expires at midnight on August 21, 2040. In its application, Dominion requested renewed facility operating licenses for a period of 20 years beyond these expiration dates; that is, to April 1, 2058, for North Anna, Unit 1, and August 21, 2060, for North Anna, Unit 2.

Nuclear power plant operation activities during the subsequent license renewal (SLR) term would be the same as, or similar to, those occurring during the current license term. Normal activities during operation of a nuclear power plant include:

• reactor operation

• waste management

• cooling water intake and discharge

• nuclear fuel receipt and storage

• spent fuel storage security

• office and clerical work; possible laboratory analysis

• surveillance, monitoring, and maintenance

• refueling and other outages.

Dominion states that North Anna will continue to operate during the subsequent license renewal term in the same manner as it would during the current renewed license term except for additional aging management programs, as n ecessary. Such programs would address structure and component aging. North Anna is located on the border of Louisa and Spotsylvania counties on a peninsula along the southern shore of Lake Anna. The principal North Anna nuclear power plant structures are the reactor containments for Units 1 and 2, the auxiliary building, the fuel building, the turbine building, and the main 500 kilovolt switchyard. North Anna fuel is low-enriched uranium dioxide (limited to 5 percent by weight uranium-235) ceramic pellets. The nuclear reactors produce a nominal core power 6 rating of 2,940 megawatts t hermal (MWt).

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In its subsequent license renewal application, Dominion stated that it is no longer pursuing development of, and has made no decision to proceed with, construction of North Anna Unit 3.

Operational activities during the SLR term would be like those already occurring at North Anna. The industrial nature of onsite land use would continue unchanged.

However, land may be needed in the future for the onsite storage of the spent nuclear fuel and low-level radioactive waste generated during the SLR term. The location and the amount of land affected cannot be predicted at this time. Maintenance activities in transmission line rights-of-way during the license renewal term would be the same as or similar to those already occurring and would not affect offsite land use beyond what has already been affected. Although non license renewal-related construction activities are planned, operational and refurbishment projects may include replacing or adding buildings, roads, parking lots, and below-ground and above-ground utility structures.

DEQ reviewed the federal consistency certification for the proposed subsequent license renewal under DEQ 19-124F. DEQ reviewed the generic EIS for the subsequent license renewal under DEQ 21-109F.

ENVIRONMENTAL IMPACTS AND MITIGATION

1. Point Source Air Pollution. The DSEIS (pages 3-14 and 3-15) states that impacts on air quality during normal plant operations can result from operations of fossil-fuel-fired equipment needed for various plant functions. DEQ regulates air emissions at North Anna under a State Operating Permit (Air Permit No. 40726). Impacts on air quality during normal plant 2 operations can result from operations of diesel generators at North Anna.

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

The division ensures the safety and quality of air in Virginia by monitoring and analyzing air quality data, regulating sources of air pollution, and working with local, state and federal agencies to plan and implement strategies to protect Virginias air quality. The appropriate DEQ regional office is directly responsible for the issuance of necessary permits to construct and operate all stationary sources in the region as well as monitoring emissions from these sources for compliance. As a part of this mandate, environmental impact reviews (EIRs) of projects to be undertaken in the state are also

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reviewed. In the case of certain projects, additional evaluation and demonstration must be made under the general conformity provisions of state and federal law.

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

• Open burning: 9VAC5-130 et seq.

• Fugitive dust control: 9VAC5-50-60 et seq.

• Permits for fuel-burning equipment: 9VAC5-80-1100 et seq.

1(b) Requirements.

1(b)(i) Fugitive Dust. During land-disturbing activities, fugitive dust must be kept to a minimum by using control methods outlined in 9VAC5-50-60 et seq. of the Regulations for the Control and Abatement of Air Pollution. These precautions include, but are not limited to, the following:

• Use, where possible, of water or suitable chemicals for dust control during the proposed demolition and construction operations and from material stockpiles;

• Installation and use of hoods, fans and fabric filters to enclose and vent the handling of dusty materials;

• Covering of open equipment for conveying materials; and

• Prompt removal of spilled or tracked dirt or other materials from paved streets and removal of dried sediments resulting from soil erosion.

1(b)(ii) Open Burning. Should any open burning or use of special incineration devices be employed in the disposal of land clearing debris during demolition and construction, the operation would be subject to the Open Burning Regulation 9 VAC 5-130-10 through 9 VAC 5-130-60 and 9 VAC 5-130-100. The regulations provide for, but do not require, the local adoption of a model ordinance concerning open burning. Contact officials with the locality to determine what local requirements, if any, exist.

1(b)(iii) Fuel-Burning Equipment. Fuel-burning equipment (generators, compressors, etc.) or any other air-pollution-emitting equipment may be subject to registration or permitting requirements.

1(b)(iv) Stationary Source. Stationary air emissions sources constructed at this location may be subject to 9 VAC 5-80-1120. The regulation requires obtaining an air permit before starting actual construction of, or operation of any new stationary source.

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Any changes that affect the impact of the facilities on air quality may require an air permit.

1(b)(v) Synthetic Minor Permit. The DEQ Northern Virginia Regional Office (NRO) states that the facility holds Synthetic Minor 80% Air Permit No. 40726, reissued June 13, 2019. Any changes to emissions or source as permitted may require an air permit modification and should be coordinated with DEQ NRO.

2. Wetlands and Water Quality. The DSEIS (page 3-42) states that wastewater from North Anna is discharged through Virginia Pollutant Discharge Elimination System Permit-permitted (VPDES) outfalls. Stormwater discharges are also addressed in the VPDES permit. The DSEIS does not indicate that activities under the SLR term would affect wetlands.

The DSEIS (page 3-31) states that since North Anna has been in operation since before July 1, 1989, Dominion is exempt from needing a Virginia Water Protection Permit for North Anna Unit 1 and 2 operations 12 (VEPCO 2020-TN8099). In addition, Dominion does not plan to increase North Annas surface water withdrawals, and it would not be required to obtain a water protection permit absent an increase in withdrawals.

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

• Clean Water Act, §401;

• Section 404(b)(i) Guidelines Mitigation Memorandum of Agreement (2/90);

• State Water Control Law, Virginia Code section 62.1-44.15:20 et seq.; and

• State Water Control Regulations, 9VAC25-210-10.

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Tidal wetlands are regulated by the Virginia Marine Resources Commission (VMRC) under the authority of Virginia Code §28.2-1301 through §28.2-1320.

2(b) Agency Findings. DEQ NRO states that the facility holds VWP permits Nos. 10 -

2001, 10-1496, and 10 -1256 associated with Unit 3.

If operational and refurbishment projects are proposed to affect surface waters or wetlands, measures should be taken to avoid and minimize impacts to surface waters and wetlands during construction activities. Even if there will be no intentional placement of fill material in jurisdictional waters, potential water quality impacts resulting from construction site surface runoff must be minimized. This can be achieved by using Best Management Practices (BMPs).

2(c) Requirements. If operational and refurbishment projects are proposed to affect wetlands and impacts would occur in or along any streams (perennial, intermittent, or ephemeral), open water or wetlands, the responsible party should contact DEQ NRO VWPP staff to determine the need for any permits prior to commencing work that could impact surface waters or wetlands. A VWP permit from DEQ may be required should impacts to surface waters be necessary.The disturbance of surface waters or wetlands may require prior approval by DEQ and/or the U.S. Army Corps of Engineers (Corps).The Corps is the authority for an official confirmation of whether there are federal jurisdictional waters, including wetlands, which may be impacted by the proposed project.DEQ may confirm additional waters as jurisdictional beyond those under federal authority.Review of National Wetland Inventory maps or topographic maps for locating wetlands or streams may not be sufficient; there may need to be a site-specific review of the site by a qualified professional.

A construction project may require coverage under the VAG83 permit for discharges from petroleum contaminated sites, groundwater remediation, and hydrostatic tests for any hydrostatics tests on any new piping installed, or for any potential dewatering during construction if petroleum contamination is encountered.The facility holds VPDES Major Industrial Individual Permit No. VA0052451, which is currently under review for reissuance.

3. Chesapeake Bay Preservation Areas. The DSEIS (page 3-6) states that North Anna is in Louisa County, which is not within the coastal zone.

3(a) Agency Jurisdiction. The DEQ Office of Watershed and Local Government Assistance Programs administers the Chesapeake Bay Preservation Act (Virginia Code

§62.1-44.15:67 et seq.) and Chesapeake Bay Preservation Area Designation and Management Regulations (9VAC25-830-10 et seq.). Each Tidewater locality must

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adopt a program based on the Chesapeake Bay Preservation Act and the Chesapeake Bay Preservation Area Designation and Management Regulations. The Act and regulations recognize local government responsibility for land use decisions and are designed to establish a framework for compliance without dictating precisely what local programs must look like. Local governments have flexibility to develop water quality preservation programs that reflect unique local characteristics and embody other community goals. Such flexibility also facilitates innovative and creative approaches in achieving program objectives. The regulations address nonpoint source pollution by identifying and protecting certain lands called Chesapeake Bay Preservation Areas.

The regulations use a resource-based approach that recognizes differences between various land forms and treats them differently.

3(b) Agency Findings. The DEQ Office of Watershed and Local Government Assistance Programs (OWLGAP) states that Figure E-4 (NAPS Site Layout) of the submitted documents shows a small area of Spotsylvania County identified as land owned by the applicant (Dominion Energy) and considered to be part of the Lake Anna Power Station. The land in question on the northeast shore of Lake Anna is heavily wooded, undeveloped and lies west/southwest of Belair Plantation Drive. The total acreage of the land is not known.

The proposed license renewal will not result in any land disturbance activity on lands located in Spotsylvania County and, accordingly, DEQ has no comments related to the above-referenced land in that county and compliance with the Chesapeake Bay Preservation Act and the Chesapeake Bay Preservation Area Designation and Management Regulations.

Louisa County is not a Tidewater Virginia locality and is not identified as a Chesapeake Bay Preservation Act locality and is therefore not subject to the requirements of the Act or Regulations.

4. Erosion and Sediment Control and Stormwater Management. The DSEIS (page 3-25) states that although no license renewal-related construction activities are planned or anticipated, the impact of continued operation and any refurbishment associated with license renewal at the North Anna site could include soil disturbance for projects, such as replacing or adding buildings, roads, parking lots, and below-ground and above-ground utility structures.

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

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• Virginia Erosion and Sediment Control Law (VESCL) (§ 62.1-44.15:51 et seq.)

and Regulations (VESCL&R) (9VAC25-840);

• Virginia Stormwater Management Act (VSMA) (§ 62.1-44.15 et seq.);

• Virginia Stormwater Management Program (VSMP) regulation (9VAC25-870);

and

• 2014 General Virginia Pollutant Discharge Elimination System (VPDES) Permit for Discharges of Stormwater from Construction Activities (9VAC25-880).

In addition, DEQ is responsible for the VSMP General Permit for Stormwater Discharges from Construction Activities related to Municipal Separate Storm Sewer Systems (MS4s) and construction activities for the control of stormwater discharges from MS4s and land disturbing activities under the Virginia Stormwater Management Program (9VAC25-890-40).

4(b) Requirements.

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

Reference:

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

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

Reference:

Virginia Stormwater Management Act §62.1-44.15 et seq.; Virginia Stormwater Management (VSMP) Permit Regulations 9VAC25-870-10 et seq.).

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

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discharges from MS4s and land disturbing activities under the Virginia Stormwater Management Program.

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

Reference:

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

5. Public Drinking Water. The DSEIS (page 2-4) states that seven groundwater wells supply North Annas domestic and miscellaneous water needs across the nuclear power plant site.

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

5(b) Agency Findings. The VDH ODW states that the following public groundwater wells are approximately between a 1,000-foot radius and within a 1-mile radius of the project site:

PWS ID Number City/County System Name Facility Name 2109600 LOUISA CO NORTH ANNA POWER STATION WELL 6 2109600 LOUISA CO NORTH ANNA POWER STATION WELL 7 2109600 LOUISA CO NORTH ANNA POWER STATION WELL 8 LOUISA CO NORTH ANNA NUCLEAR 2109610 INFORMATION CENTER WELL SPOTSYLVANIA 6177235 CO LAKE ANNA MARINA WELL SPOTSYLVANIA DRILLED 6177245 CO ANNA CABANA, THE WELL

There are no surface water intakes located within a 5-mile radius of the project site.

The project is not within the watershed of any public surface water intakes.

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5(c) Agency Recommendations.

• Implement best management practices, including erosion and sedimentation controls and spill prevention controls and countermeasures, on the project site.

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

6. Pesticides and Herbicides. In general, when pesticides or herbicides must be used, their use should be strictly in accordance with manufacturers recommendations. In addition, DEQ recommends that the responsible agent use the least toxic pesticides or herbicides effective in controlling the target species. For more information on pesticide or herbicide use, please contact the Virginia Department of Agriculture and Consumer Services (804-371-6560).

7. Natural Heritage Resources. The DSEIS (page 3-59) states that significant habitat on the North Anna site includes wetlands and Lake Anna.

7(a) Agency Jurisdiction.

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

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

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

7(b) Agency Findings - Natural Heritage. According to the information currently in the Biotics Data System, natural heritage resources have not been documented within the submitted project boundary, including a 100-foot buffer. The absence of data may

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indicate that the project area has not been surveyed, rather than confirm that the area lacks natural heritage resources. In addition, the project boundary does not intersect any of the predictive models identifying potential habitat for natural heritage resources.

7(c) Agency Findings - Threatened and Endangered Plant and Insect Species.

The current activity will not affect any documented state-listed plants or insects.

7(d) Agency Findings - State Natural Area Preserves. There are no State Natural Area Preserves under DCRs jurisdiction in the project vicinity.

7(e) Agency Recommendations. Contact the DCR DNH and resubmit project information and a map if the scope of the project changes and/or six months has passed before it is utilized.

8. Solid and Hazardous Waste Management. The DSEIS (pages 3-180 to 3-181) states that like any operating nuclear power plant, North Anna will produce both radioactive and nonradioactive waste during the SLR period. North Anna has a nonradioactive waste management program to handle nonradioactive waste in accordance with federal, state, and corporate regulations and procedures. At North Anna, low-level radioactive waste is stored temporarily onsite before being shipped offsite for treatment or disposal at licensed treatment and disposal facilities.

8(a) Agency Jurisdiction. On behalf of the Virginia Waste Management Board, the DEQ Division of Land Protection and Revitalization is responsible for carrying out the mandates of the Virginia Waste Management Act (Virginia Code §10.1-1400 et seq.), as well as meeting Virginia's federal obligations under the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response Compensation Liability Act (CERCLA), commonly known as Superfund. The DEQ Division of Land Protection and Revitalization also administers those laws and regulations on behalf of the State Water Control Board that govern Petroleum Storage Tanks (Virginia Code

§62.1-44.34:8 et seq.), including Aboveground Storage Tanks (9VAC25-91 et seq.) and Underground Storage Tanks (9VAC25-580 et seq. and 9VAC25-580-370 et seq.), also known as Virginia Tank Regulations, and § 62.1-44.34:14 et seq. which covers oil spills.

Virginia:

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

• Virginia Solid Waste Management Regulations, 9VAC20-81 o (9VAC20-81-620 applies to asbestos-containing materials)

• Virginia Hazardous Waste Management Regulations, 9VAC20 -60 o (9VAC20-60-261 applies to lead-based paints)

• Virginia Regulations for the Transportation of Hazardous Materials, 9VAC20-110.

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Federal:

• Resource Conservation and Recovery Act (RCRA), 42 U.S. Code sections 6901 et seq.

• U.S. Department of Transportation Rules for Transportation of Hazardous Materials, 49 Code of Federal Regulations, Part 107

• Applicable rules contained in Title 40, Code of Federal Regulations.

8(b) Database Search. The DEQ Division of Land Protection and Revitalization (DLPR) conducted a search (200-foot radius) of the project area of solid and hazardous waste databases (including petroleum releases) to identify waste sites in close proximity to the project area. DLPR identified one RCRA small quantity generator within the project area which might impact the project:

Hazardous Waste/RCRA Facilities

1. Registry ID 110001891114, Virginia Electric - North Anna Power Station, 1022 Haley Dr, Mineral, VA 23117, Small Quantity Generator, Active Status: Y

DLPR states that solid and hazardous waste issues and sites were adequately addressed in the report.

8(c) Agency Findings. DEQ NRO states that the facility holds EPA ID No.

VAD065376279 for a Small Quantity Generator of Hazardous Waste. For additional Land Protection/Waste questions, please contact the regional waste program manager Jim Datko at 571.866.6446 orjames.datko@deq.virginia.gov.

8(d) Agency Recommendations. DEQ encourages all projects to implement pollution prevention principles, including:

• the reduction, reuse and recycling of all solid wastes generated; and

• the minimization and proper handling of generated hazardous wastes.

8(e) Requirements.

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

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• The removal, relocation or closure or installation/operation of any regulated petroleum storage tanks, aboveground storage tank (AST) or underground storage tank (UST), must be conducted in accordance with the requirements of the Virginia Tank Regulations 9 VAC 25-91-10 et seq. (AST) and / or 9 VAC 25-580-10 et seq. (UST). Submit appropriate documentation to DEQ.

• Test and dispose of any soil/sediment that is suspected of contamination or wastes that are generated during construction-related activities in accordance with applicable federal, state, and local laws and regulations.

• Any future site activities involving excavation or disturbance of formerly petroleum contaminated soils and or groundwater must be reported to DEQ, as authorized by Virginia Code § 62.1-44.34.8 through 9 and 9 VAC 25-580-10 et seq.

• Petroleum-contaminated soils and ground water generated during implementation of this project must be properly characterized and disposed of properly.

• All construction and demolition waste, including any excess soil, must be characterized in accordance with the Virginia Hazardous Waste Management Regulations and disposed of at an appropriate facility as applicable.

• If evidence of a petroleum release is discovered during implementation of this project, it must be reported to DEQ, as authorized by Code of Virginia 62.1-44.34.8 through 19 and 9VAC 25-580-10 et seq.

• All structures being demolished or removed should be checked for asbestos-containing materials (ACM) and lead-based paint (LBP) prior to demolition. If ACM and LBP are found, in addition to the federal waste-related regulations mentioned above, state regulations 9VAC20-81-640 for ACM and 9VAC20 261 for LBP must be followed.

9. Floodplain Management. The EA (page 3-28) states there are flood hazard areas within the North Anna site.

9(a) Agency Jurisdiction. DCR is the lead coordinating agency for the Commonwealths floodplain management program and the National Flood Insurance Program (Code of Virginia § 10.1-602).

9(b) Agency Findings. The National Flood Insurance Program (NFIP) is administered by Federal Emergency Management Agency (FEMA) and communities who elect to participate in this voluntary program manage and enforce the program on the local level through that communitys local floodplain ordinance. Each local floodplain ordinance must comply with the minimum standards of the NFIP, outlined in 44 CFR 60.3; however, local communities may adopt more restrictive requirements in their local

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floodplain ordinance, such as regulating the 0.2% annual chance flood zone (Shaded X Zone).

The DCR Floodplain Management Program does not have regulatory authority for projects in the Special Flood Hazard Area (SFHA). The applicant/developer must contact the local floodplain administrator for an official floodplain determination and comply with the communitys local floodplain ordinance, including receiving a local permit. Failure to comply with the local floodplain ordinance could result in enforcement action from the locality. For federal projects, the applicant/developer is encouraged to contact the local floodplain administrator and comply with the communitys local floodplain ordinance.

9(c) Requirements.

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

• Projects conducted by federal agencies within the SFHA must comply with federal Executive Order 11988: Floodplain Management.

10. Subaqueous Lands. The DSEIS (pages 3-42 and 3-43) does not indicate that state-owned subaqueous lands would be impacted.

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

10(b) Agency Findings. VMRC states that the proposed project does not impact resources within its jurisdiction and will not require a permit.

10(c) Requirements. Should the proposed project change, contact VMRC as a new review may be required relative to its jurisdictional areas. VMRC, pursuant to §28.2-1200 et seq of the Code of Virginia, has jurisdiction over encroachments in, on, or over the beds of the bays, ocean, rivers, streams, or creeks which are the property of the Commonwealth. Accordingly, if any portion of the subject project involves any encroachments channelward of ordinary high water along non-tidal, natural rivers and streams with a drainage area greater than 5-square miles, a permit may be required

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from our agency or the Department of Environmental Quality. Any jurisdictional impacts will be reviewed by the VMRC during the JPA process.

12. Aviation Impacts. Appendix E states that there is a helipad located at North Anna and there are other airports and airfields within 10 miles.

12(a) Agency Jurisdiction. The Virginia Department of Aviation (DOAV) is a state agency that plans for the development of the state aviation system; promotes aviation; grants aircraft and airports licenses; and provides financial and technical assistance to cities, towns, counties and other governmental subdivisions for the planning, development, construction and operation of airports, and other aviation facilities.

12(b) Agency Findings. DOAV states that the nearest public-use airports of concern to the North Anna power station are the Lake Anna airport, about 6.9 miles to the southeast, and Louise County airport, about 10.4 miles to the southwest. As the power plant is beyond 20,000 linear feet from both airports, DOAV takes no exception to the findings of this report. Additionally, the report contains no new construction of 200 feet above ground level or higher that is of a concern to the safety of aerial navigation.

13. Geological Resources. The DSEIS (pages 3-25 to 3-26) states that the impacts of natural phenomena, including geologic hazards, on nuclear power plant systems, structures, and components are outside the scope of the NRCs license renewal environmental review. Nonetheless, the NRC considers the risk to reactors from seismicity in its evaluation of severe accidents. North Anna was originally sited, designed, and licensed in consideration of applicable geologic and seismic criteria, and seismic issues are assessed as part of the nuclear power plant safety review. Geologic and soil conditions at North Anna and associated transmission lines have been well established during the current licensing term. These conditions are expected to remain unchanged during the 20-year SLR term.

13(a) Agency Jurisdiction. The Virginia Department of Energy (Virginia Energy) regulates the mineral industry, provides mineral research and offers advice on wise use of resources. The Department's mission is to enhance the development and conservation of energy and mineral resources in a safe and environmentally sound manner in order to support a more productive economy in Virginia.

13(b) Agency Comments. Virgina Energy states that there are new geologic maps in the vicinity of the Lake Anna plants and several recent studies on the 2011 earthquake and seismicity in the eastern U.S. Links to relevant publications are available below:

Comprehensive report related to the 2011 earthquake

15 North Ann Power Station Units 1 and 2 DEQ 24-005F

https://pubs.geoscienceworld.org/gsa/books/book/682/The-2011-Mineral-Virginia-Earthquake-and-Its

Geology of the Mineral and Lake Anna West quadrangles https://www.energy.virginia.gov/commerce/ProductDetails.aspx?productID=3026

Geologic map of the Pendleton quadrangle (epicentral area for 2011 earthquake) https://www.energy.virginia.gov/commerce/ProductDetails.aspx?productID=3052

Seismological investigation of active faults in the Central Virginia Seismic Zone https://earthquake.usgs.gov/cfusion/external_grants/reports/G17AP00035.pdf

Earthquake potential of the Central Virginia Seismic Zone https://earthquake.usgs.gov/cfusion/external_grants/reports/G13AP00045.pdf

14. Wildlife Resources. The DSEIS (page 3-59) states that Dominion states that it will conduct ongoing operational and maintenance activities at the North Anna site throughout the SLR term, including landscape maintenance activities, stormwater management, piping installation, and fencing. Dominion states that it would confine these activities to previously disturbed areas. The NRC staff concurs with Dominion that the anticipated activities would have only minimal effects on terrestrial resources. In addition, Dominion maintains an avian monitoring plan in cooperation with the U.S. Fish and Wildlife Service (FWS) and state agencies to establish and evaluate monitoring protocols based on specific Dominion activities for impacts to migratory birds (page 3-62). Dominion follows a vegetation management plan and maintains a three-year cycle of right-of-way corridor maintenance primarily with mowers, and in areas not accessible to mowers, by use of selective herbicides or hand-cutting where sensitive habitats are nearby such as wetlands (page 3-63).

14(a) Agency Jurisdiction. The Virginia Department of Wildlife Resources (DWR), as the Commonwealths wildlife and freshwater fish management agency, exercises enforcement and regulatory jurisdiction over wildlife and freshwater fish, including state-or federally listed endangered or threatened species, but excluding listed insects (Virginia Code, Title 29.1). DWR is a consulting agency under the U.S. Fish and Wildlife Coordination Act (16 U.S. Code §661 et seq.) and provides environmental analysis of projects or permit applications coordinated through DEQ and several other state and federal agencies. DWR determines likely impacts upon fish and wildlife resources and habitat, and recommends appropriate measures to avoid, reduce or compensate for those impacts. For more information, see the DWR website at www.dwr.virginia.gov.

16 North Ann Power Station Units 1 and 2 DEQ 24-005F

14(b) Agency Findings. DWR states that it provided scoping comments on the relicensing of Units 1 and 2 on 9/27/21. Those comments are reiterated below. They remain valid and continue to apply. DWR has not been contacted by Dominion about the Comprehensive Aquatic Vegetation Management Plan described in its scoping comments from 9/27/21.

DWR does currently document any listed wildlife or designated resources from the project area. DWR has no significant concerns with the relicensing of NAPS Units 1 and 2.

DWR does have any significant concerns regarding the surface water intake (cooling water intake) from, and resulting thermal discharge to, Lake Anna, assuming no significant changes are proposed to the operation and all currently required monitoring continues to be performed. However, DWR will review the 316(b) assessment as part of the VPDES renewal package for this facility and will provide specific comments on this aspect of the project to DEQ VPDES staff once DWR has had the opportunity to review that information.

14(c) Agency Recommendations.

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

While DWR will review the 316(b) assessment as part of the VPDES renewal package for this facility and will provide specific comments on this aspect of the project to DEQ, DWR has the following general recommendations:

• DWR typically recommends that to protect resident aquatic species from impingement and entrainment, surface water intakes be fitted with a 1mm mesh screen and that the intake velocity not exceed 0.25 fps.

• To ensure continued access to necessary instream habitats by resident aquatic species, DWR recommends that the intake not withdraw more than 10%

instantaneous flow (90% flowby).

17 North Ann Power Station Units 1 and 2 DEQ 24-005F

DWR understands that these standards are not practicable or necessary at every surface water intake to ensure the protection of resources under its jurisdiction.

REGULATORY AND COORDINATION NEEDS

1. Air Quality Regulations. The following regulations may apply during construction or operation:

• fugitive dust and emissions control (9VAC5-50-60 et seq.)

• permits for fuel-burning equipment (9VAC5-80-110 et seq.)

• open burning restrictions (9VAC5-130 et seq.)

• stationary air emissions (9 VAC 5-80-1120)

Contact DEQ NRO (David Hartshorn at 571.408.1778 or r.david.hartshorn@deq.virginia.gov) to determine if a permit modification will be necessary if there any changes to emissions or source as permitted by Synthetic Minor 80% Air Permit No. 40726.

2. Water Quality and Wetlands. If activities change and impacts would occur in or along any streams (perennial, intermittent, or ephemeral), open water or wetlands, the applicant should contact DEQ NRO VWPP staff (Natasha Nahas at natasha.nahas@deq.virginia.gov) to determine the need for any permits prior to commencing work that could impact surface waters or wetlands.

The facility holds VPDES Major Industrial Individual Permit No. VA0052451, which is currently under review for reissuance. Coordinate with DEQ NRO (Rebecca Johnson atrebecca.johnson@deq.virginia.gov) as necessary for compliance.

3. Erosion and Sediment Control and Stormwater Management Plans. The following may apply to land disturbing activities.

3(b)(i) Erosion and Sediment Control and Stormwater Management Plans. The applicant is responsible for submitting a project-specific erosion and sediment control (ESC) plan to the locality in which the project is located for review and approval pursuant to the local ESC requirements, if the project involves a land-disturbing activity of 10,000 square feet or more. Depending on local requirements the area of land disturbance requiring an ESC plan may be less. Local ESC program requirements must be requested through the locality (

Reference:

Virginia Erosion and Sediment Control Law §62.1-44.15 et seq.; Virginia Erosion and Sediment Control Regulations 9VAC25-840-10 et seq.). Depending on local requirements, a Stormwater Management (SWM)

18 North Ann Power Station Units 1 and 2 DEQ 24-005F

plan may be required. Local SWM program requirements must be requested through the locality (

Reference:

Virginia Stormwater Management Act §62.1-44.15 et seq.; Virginia Stormwater Management (VSMP) Permit Regulations 9VAC25-870-10 et seq.).

3(b)(ii) General Permit for Stormwater Discharges from Construction Activities (VAR10). The operator or owner of a construction project involving land-disturbing activities equal to or greater than 1 acre is required to register for coverage under the General Permit for Discharges of Stormwater from Construction Activities and develop a project-specific stormwater pollution prevention plan (SWPPP). The SWPPP must be prepared prior to submission of the registration statement for coverage under the General Permit and the SWPPP must address water quality and quantity in accordance with the VSMP Permit Regulations (

Reference:

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

4. Water Supply. Contact VDH (Arlene Warren at Arlene.Warren@vdh.virginia.gov) for additional information about its comments if necessary.

5. Natural Heritage Resources. Submit project information and a map to DCR DNH (Allison Tillett at allison.tillett@dcr.virginia.gov) for an update on natural heritage information if the scope of the project changes and/or six months has passed before it is utilized.

6. Solid Waste and Hazardous Substances. All solid waste, hazardous waste, and hazardous materials must be managed in accordance with all applicable federal, state, and local environmental regulations. If free product, discolored soils, or other evidence of contaminated soils are encountered, contact DEQ NRO (Jim Datko at 571-866-6446 or james.datko@deq.virginia.gov). Any future site activities involving excavation or disturbance of formerly petroleum contaminated soils and or groundwater must be reported to DEQ, as authorized by Code of Virginia 62.1-44.34.8 through 19 and 9VAC25-580-10 et seq.

6(a) Asbestos-Containing Material. It is the responsibility of the owner or operator of a renovation or demolition activity, prior to the commencement of the renovation or demolition, to thoroughly inspect the affected part of the facility where the operation will occur for the presence of asbestos, including Category I and Category II nonfriable asbestos-containing material (as applicable). Upon classification as friable or non-friable, all asbestos-containing material shall be disposed of in accordance with the Virginia Solid Waste Management Regulations (9VAC20-81-640) and transported in accordance with the Virginia regulations governing Transportation of Hazardous Materials (9VAC20-110-10 et seq.). Contact the DEQ Division of Land Protection and

19 North Ann Power Station Units 1 and 2 DEQ 24-005F

Revitalization (Nikolas Churchill at Nikolas.Churchill@deq.virginia.gov) and the Department of Labor and Industry (804-371-2327) for additional information.

6(b) Lead-Based Paint. If applicable, this project must comply with the U.S.

Department of Labor Occupational Safety and Health Administration (OSHA) regulations and with the Virginia Lead-Based Paint Activities Rules and Regulations.

For additional information regarding these requirements, contact the Department of Professional and Occupational Regulation (804-367-8500).

7. Floodplain. The federal agency should ensure compliance with applicable floodplain requirements. To find community NFIP participation and local floodplain administrator contact information, use DCRs Local Floodplain Management Directory:

www.dcr.virginia.gov/dam-safety-and-floodplains/floodplain-directory.

8. Subaqueous Lands. Should the proposed project change, contact VMRC (Claire Gorman at Claire.Gorman@mrc. virginia.gov) as a new review may be required relative to its jurisdictional areas.

9. Wildlife Resources. It is recommended that Dominion coordinate with DWR (John Odenkirk, DWR Regional Aquatic Biologist, at 504-899-4169 or John.Odenkirk@DWR.virginia.gov) on the development of a Comprehensive Aquatic Vegetation Management Plan for Lake Anna. Contact DWR (Lee Brann at Lee.Brann@dwr.virginia.gov) for additional information about its comments if necessary.

Thank you for the opportunity to comment on this DSEIS. The detailed comments of reviewers are attached. If you have questions, please do not hesitate to call me at 804-659-1915 or Julia Wellman at (804) 774-8237.

Sincerely,

Bettina Rayfield, Manager

Environmental Impact Revie w and Long Range Priorities Program

Enclosures

20 North Ann Power Station Units 1 and 2 DEQ 24-005F

ec: Lee Brann, DWR Keith Tignor, VDACS Allison Tillett, DCR Arlene Warren, VDH Roger Kirchen, DHR Matt Heller, Virginia Energy Clint Folks, DOF Claire Gorman, VMRC Allison Wishon, VDOT Stephen Smiley, DOAV Lisa Hutcherson, VDEM Chip Boyles, GWRC Christine Jacobs, TJPDC Christian Goodwin, Louisa County Ed Petrovitch, Spotsylvania County

21 1/29/24, 3:00 PM Mail - Wellman, J ulia (DEQ) - Outlook

Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2,DEQ #24-005F

Mann, Katherine (DEQ) <Katherine.Mann@deq.virginia.gov>

Mon 1/29/2024 10:57 AM To: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

Cc: Miller, Mark (DEQ) <Mark.Miller@deq.virginia.gov>

Northern Regional Offic e c omments regarding theenv ironmental as s es s mentreques t forSite-Spec ific Env ironmental Impac t Statement for Lic ens e Renewal of Nuc lear Plants Regarding Subs equent Lic ens e Renewal for North Anna Power Station Units 1 and 2,DEQ #24-005F,are as follows :

Land Protection Division-The project manager is reminded that if any solid or hazardous waste is generated/encountered during construction,the project manager would follow applicable federal, state, and local regulations for their disposal. The Facility holds EP A ID No.

VAD065376279 for a Small Quantity Generator of Hazardous W aste. For additional Land Protection/W aste questions, please contact the regional waste program manager Jim Datko at 571.866.6446 orjames.datko@deq.virginia.gov.

Air Compliance/Permitting-The project manager is reminded that during the construction phases that occur with this project; the project is subject to the Fugitive Dust/Fugitive Emissions Rule 9 VAC 5-50-60 through 9 VAC 5-50-120.In addition,should any open burning or use of special incineration devices be employed in the disposal of land clearing debris during demolition and construction, the operation would be subject to the Open Burning Regulation 9 VAC 5-130-10 through 9 VAC 5-130-60 and 9 VAC 5-130-100.Additionally, the project manager is reminded, stationary air emissions sources constructed at this location may be subject to 9 VAC 5-80-1120. The regulation requires obtaining an air permit before starting actual construction of, or operation of any new stationary source. The Facility holds Synthetic Minor 80% Air Permit No. 40726, reissued June 13, 2019. Any changes to emissions or source as permitted may require an air permit modification.For additional air questions please contact the regional air compliance manager David Hartshornat 571.408.1778 orr.david.hartshorn@deq.virginia.gov.

Virginia Water Protection Permit (VWPP) Program-The project manager is remindedthat a VWP permit from DEQ may be required should impacts to surface waters be necessary. The Facility holds VWP permits Nos. 10-2001, 10-1496, and 10-1256. Measures should be taken to avoid and minimize impacts to surface waters and wetlands during construction activities. The disturbance of surface waters or wetlands may require prior approval by DEQ and/or the U.S.

Army Corps of Engineers. The Army Corps of Engineers is the authority for an of ficial confirmation of whether there are federal jurisdictional waters, including wetlands, which may be impacted by the proposed project. DEQ may confirm additional waters as jurisdictional beyond those under federal authority. Review of National W etland Inventory maps or topographic maps for locating wetlands or streams may not be suf ficient; there may need to be a site-specific review of the site by a qualified professional. Even if there will be no intentional placement of fill material in jurisdictional waters, potential water quality impacts resulting from construction site surface runof f must be minimized. This can be achieved by using Best Management Practices (BMPs). If construction activities will occur in or along any streams (perennial, intermittent, or

https ://outlook.offic e365.c om/mail/inbox /id/AQMk AGMz N2Y5ZTMwLTk 4N2UtNDdjYS1hYjVmLTI5ZTYwYTI0MTM2OABGAAADL5y 7x qUXuEuC%2Bu1/2 1/29/24, 3:00 PM Mail - Wellman, J ulia (DEQ) - Outlook ephemeral), open water or wetlands, the applicant should contact DEQ-NRO VWPP staf f to determine the need for any permits prior to commencing work that could impact surface waters or wetlands. Upon receipt of a Joint Permit Application for the proposed surface water impacts, DEQ VWP Permit staf f will review the proposed project in accordance with the VWP permit program regulations and current VWP permit program guidance. VWPP staf f reserve the right to provide comment upon receipt of a permit application requesting authorization to impact state surface waters, and at such time that a wetland delineation has been conducted and associated jurisdiction determination made by the U.S. Army Corps of Engineers. For additional VWP questions, please contact the regional VWP compliance manager Natasha Nahas at 571.866.6496 or natasha.nahas@deq.virginia.gov.

Erosion and Sediment Control, Storm Water Management-DEQ has regulatory authority for the Virginia Pollutant Discharge Elimination System (VPDES) programs related to municipal separate storm sewer systems (MS4s) and construction activities. Erosion and sediment control measures are addressed in local ordinances and State regulations. Additional information is available athttp://www.deq.virginia.gov/Programs/W ater/StormwaterManagement.aspx. Non-point source pollution resulting from this project should be minimized by using ef fective erosion and sediment control practices and structures. Consideration should also be given to using permeable paving for parking areas and walkways where appropriate, and denuded areas should be promptly revegetated following construction work. If the total land disturbance exceeds 10,000 square feet, an erosion and sediment control plan will be required. Some localities also require an E&S plan for disturbances less than 10,000 square feet. A stormwater management plan may also be required. For any land disturbing activities equal to one acre or more, you are required to apply for coverage under the VPDES General Permit for Discharges of Storm W ater from Construction Activities. The Virginia Stormwater Management Permit Authority may be DEQ or thelocality.For additional storm water construction questions please contact the regional storm water program manager Mark Remsbergat 703.583.3874 ormark.remmsberg@deq.virginia.gov.

Other VPDES Permitting-A construction project may require coverage under the V AG83 permit for discharges from petroleum contaminated sites, groundwater remediation, and hydrostatic tests for any hydrostatics tests on any new piping installed, or for any potential dewatering during construction if petroleum contamination is encountered.The Facility holds VPDES Major Industrial Individual Permit No. V A0052451, which is currently under review for reissuance. For additional water permitting/compliance questions please contact the regional water compliance manager Rebecca Johnson at571.866.6500orrebecca.johnson@deq.virginia.gov.

Katherine Mann Enforcement Specialist, Northern Regional Oce Virginia Department of Environmental Quality 13901 Crown Court Woodbridge, VA 22193 (m) (571) 866-6095 (o) (703) 583-3800

https ://outlook.offic e365.c om/mail/inbox /id/AQMk AGMz N2Y5ZTMwLTk 4N2UtNDdjYS1hYjVmLTI5ZTYwYTI0MTM2OABGAAADL5y 7x qUXuEuC%2Bu2/2 2/13/24, 12:59 PM Mail - Wellman, J ulia (DEQ) - Outlook

Re: Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2,DEQ #24-005F

Mann, Katherine (DEQ) <Katherine.Mann@deq.virginia.gov>

Tue 2/13/2024 12:52 PM To: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

Hey Julia,

All three permit are still active. The 10-2001 is referenced a couple of times in the report, they're stating it contains the 401 certification needed. All three are associated with Unit 3. Hope that helps, but let me know if you need more!

Katherine

Katherine Mann Enforcement Specialist, Northern Regional Oce Virginia Department of Environmental Quality 13901 Crown Court Woodbridge, VA 22193 (m) (571) 866-6095 (o) (703) 583-3800

From: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

Sent: Tuesday, February 13, 2024 12:29 PM To: Mann, Katherine (DEQ) <Katherine.Mann@deq.virginia.gov>

Subject:

Re: Site-Speci"c Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Staon Units 1 and 2,DEQ #24-005F

Hi Katherine,

Are the VWP permits s till v alid for North Anna or are they from an old projec t? Thank s !!

Julia Wellman Environmental Impact Review Coordinator Oce of En vironmental Impact Review and Long Range Priories Division of Environmental Enhancement Virginia Department of Environmental Quality 1111 East Main Street, Suite 1400 Richmond, Virginia 23219 (804) 774-8237

For program updates and public noces, please sub scribe to Constant

Contact:

hp s://lp.constantcontact.com/su/MVcCump/EIR.

From: Mann, Katherine (DEQ) <Katherine.Mann@deq.virginia.gov>

Sent: Monday, January 29, 2024 10:57 AM

https ://outlook.offic e365.c om/mail/inbox /id/AQMk AGMz N2Y5ZTMwLTk 4N2UtNDdjYS1hYjVmLTI5ZTYwYTI0MTM2OABGAAADL5y 7x qUXuEuC%2Bu1/3 Commonwealth of Virginia VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY 1111 E. Main Street, Suite 1400, Richmond, Virginia 23219 P.O. Box 1105, Richmond, Virginia 23218 (800) 592-5482 FAX (804) 698-4178 www.deq.virginia.gov Travis A. Voyles Michael S. Rolband, PE, PWD, PWS Emeritus Acting Secretary of Natural and Historic Resources Director (804) 698-4020

MEMORANDUM

TO: Julia Wellman, DEQ Environmental Impact Review Coordinator

FROM: Daniel Moore, DEQ Principal Environmental Planner

DATE: January 23, 2024

SUBJECT:

DEQ #24-005F: U.S. Nuclear Regulatory Commission: Site-specific Environmental Impact Statement for License Renewal North Anna Power Stations Units 1 and 2, Louisa and Spotsylvania Counties, Virginia

We have reviewed information submitted regarding the Draft Supplemental Environmental Impact Statement for the above-referenced project and offer the following comments regarding consistency with the provisions of the Chesapeake Bay Preservation Area Designation and Management Regulations (Regulations):

In Spotsylvania County, the areas protected by the Chesapeake Bay Preservation Act, as locally implemented, require conformance with performance criteria. These areas include Resource Protection Areas (RPAs) and Resource Management Areas (RMAs) as designated by the County.

RPAs include tidal wetlands, certain non-tidal wetlands and tidal shores. RPAs also include a 100-foot vegetated buffer area located adjacent to and landward of these features and along both sides of any water body with perennial flow. All areas of the County not included in the RPA are designated as RMAs.

Figure E-4 (NAPS Site Layout) of the submitted documents shows a small area of Spotsylvania County identified as land owned by the applicant (Dominion Energy) and considered to be part of the Lake Anna Power Station. The land in question on the northeast shore of Lake Anna is heavily wooded, undeveloped and lies west/southwest of Belair Plantation Drive. The total acreage of the land is not known. The proposed license renewal will not result in any land disturbance activity on lands located in Spotsylvania County and, accordingly, we have no comments related to the above-referenced land in that County and compliance with the Act and Regulations.

Louisa County is not a Tidewater Virginia locality and is not identified as a Chesapeake Bay Preservation Act locality and is therefore not subject to the requirements of the Act or Regulations.

2 1/10/24, 2:33 PM Mail - Wellman, J ulia (DEQ) - Outlook

Re: NEW PROJECT NRC License Renewal of Nuclear Plants, DEQ 24-005F

Gavan, Larry (DEQ) <Larry.Gavan@deq.virginia.gov>

Wed 1/10/2024 2:28 PM To: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

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

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

Local ESC program requirements must be requested through the locality. [

Reference:

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

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

Reference:

Virginia Stormwater Management Act §62.1-44.15 et seq.; Virginia Stormwater Management ( VSMP) Permit Regulations 9 VAC25-870-10 et seq.]

(d) General Permit for Stormwater Discharges from Construction Activities (VAR10).

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

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

(

Reference:

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

Larry Gavan Site Plan Review Coordinator Office of Stormwater Management Department of Environmental Quality 1 1 1 1 East Main Street, Suite 1400

https ://outlook.offic e365.c om/mail/inbox /id/AQMk AGMz N2Y5ZTMwLTk 4N2UtNDdjYS1hYjVmLTI5ZTYwYTI0MTM2OABGAAADL5y 7x qUXuEuC%2Bu1/3 1/10/24, 2:33 PM Mail - Wellman, J ulia (DEQ) - Outlook Richmond, VA 23219 Work Number (804) 965-3320 larry.gavan@deq.vir ginia.gov

From: Fulcher, Valerie (DEQ) <Valerie.Fulcher@deq.virginia.gov>

Sent: Tuesday, January 9, 2024 4:57 PM To: dgif-ESS Projects (DWR) <ESSProjects@dwr.virginia.gov>; Tignor, Keith (VDACS)

<Keith.Tignor@vdacs.virginia.gov>; DCR-PRR Environmental Review (DCR) <envreview@dcr.virginia.gov>;

odwreview (VDH) <odwreview@vdh.virginia.gov>; Churchill, Nikolas (DEQ) <Nikolas.Churchill@deq.virginia.gov>;

Ballou, Thomas (DEQ) <Thomas.Ballou@deq.virginia.gov>; Lovain, Anna (DEQ) <Anna.Lovain@deq.virginia.gov>;

Gavan, Larry (DEQ) <Larry.Gavan@deq.virginia.gov>; Moore, Daniel (DEQ) <Daniel.Moore@deq.virginia.gov>;

Campbell, Brian (DEQ) <Brian.Campbell@deq.virginia.gov>; Cloe, William (DEQ) <William.Cloe@deq.virginia.gov>;

Seavey, Eric (DEQ) <Eric.Seavey@deq.virginia.gov>; Miller, Mark (DEQ) <Mark.Miller@deq.virginia.gov>; Kirchen, Roger (DHR) <Roger.Kirchen@dhr.virginia.gov>; Spears, David (Energy) <David.Spears@energy.virginia.gov>; Folks, Clint (DOF) <Clint.Folks@dof.virginia.gov>; Lasher, Terrance J. (DOF) <Terry.Lasher@dof.virginia.gov>; MRC -

Scoping (MRC) <Scoping@mrc.virginia.gov>; EIR Coordinaon (VDOT) <EIR.Coordinaon@vdot.virginia.gov>; Chip Boyles <boyles@gwregion.org>; Chrisne Jacobs <cjacobs@tjpdc.org>; info@louisa.org (info@louisa.org)

<info@louisa.org>; Hutcherson, Lisa (VDEM) <Lisa.Hutcherson@vdem.virginia.gov>;

nwoodard@spotsylvania.va.us (nwoodard@spotsylvania.va.us) <nwoodard@spotsylvania.va.us>; Harrington, Rusty N. (DOAV) <Rusty.Harrington@doav.virginia.gov>; Simms, Danielle (DEQ)

<Danielle.Simms@deq.virginia.gov>

Cc: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

Subject:

NEW PROJECT NRC License Renewal of Nuclear Plants, DEQ 24-005F

Good aernoon-this is a new OEIR r eview request/project:

Document Type: Dra Supplemen tal Environmental Impact Statement Project Sponsor: U.S. Nuclear Regulatory Commission Project

Title:

Sit e-Speci"c En vironmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Staon Units 1 and 2, Dr a R eport for Comment Locaon: Louisa and Spots ylvania Counes Project Number: DE Q #24-005F

The document is available at hp s://public.deq.virginia.gov/OEIR/ in the NRC f older.

The due date for comments is FEBRUARY 6, 2024. You can send your comments either directly to JULIA WELLMAN by email (Julia.Wellman@deq.virginia.gov), or you can send your comments by regular interagency/U.S. mail to the Department of Environmental Quality, Oce of En vironmental Impact Review, P.O. Box 1105, Richmond, VA 23218.

https ://outlook.offic e365.c om/mail/inbox /id/AQMk AGMz N2Y5ZTMwLTk 4N2UtNDdjYS1hYjVmLTI5ZTYwYTI0MTM2OABGAAADL5y 7x qUXuEuC%2Bu2/3 1/22/24, 9:51 AM Mail - Wellman, J ulia (DEQ) - Outlook

RE: NEW PROJECT NRC License Renewal of Nuclear Plants, DEQ 24-005F

Warren, Arlene (VDH) <Arlene.Warren@vdh.virginia.gov>

Wed 1/17/2024 12:15 PM To: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

Cc: Environmental Impact Review (DEQ) <eir@deq.virginia.gov>

Project #: 24-005F Project Name: Site-Speci"c Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Staon Units 1 and 2, Dra Report for Comment UPC #: N/A Locaon: Louisa and Spotsylvania Counes

VDH - Oce of Drinking Water has reviewed the above project. Below are our comments as they relate to proximity to public drinking water sources (groundwater wells, springs and surface water intakes). Potenal impacts to public water distribuon systems or sanitary sewage collecon systems must be veri"ed by the local ulity.

The following public groundwater wells are approximately between a 1,000-foot radius and within a 1-mile radius of the project site:

PWS ID Number City/County System Name Facility Name 2109600 LOUISA CO NORTH ANNA POWER STATION WELL 6 2109600 LOUISA CO NORTH ANNA POWER STATION WELL 7 2109600 LOUISA CO NORTH ANNA POWER STATION WELL 8 LOUISA CO NORTH ANNA NUCLEAR INFORMATION 2109610 CENTER WELL 6177235 SPOTSYLVANIA CO LAKE ANNA MARINA WELL 6177245 SPOTSYLVANIA CO ANNA CABANA, THE DRILLED WELL

There are no surface water intakes located within a 5-mile radius of the project site.

The project is not within the watershed of any public surface water intakes.

Best Management Pracces should be employed, including Erosion & Sedimentaon Controls and Spill Prevenon Controls & Countermeasures on the project site.

Well(s) within a 1,000-foot radius from project site should be "eld marked and protected from accidental damage during construcon.

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

Best Regards,

Arlene F. Warren GIS Program Support Technician Mobile 804-389-2167 (oce/cell/text)

Email [arlene.warren@vdh.virginia.gov]arlene.warren@vdh.virginia.gov VDH, Oce of Drinking Water 109 Governor Street, 6th Floor

https ://outlook.offic e365.c om/mail/inbox /id/AQMk AGMz N2Y5ZTMwLTk 4N2UtNDdjYS1hYjVmLTI5ZTYwYTI0MTM2OABGAAADL5y 7x qUXuEuC%2Bu1/4 Travis A. Voyles Frank N. Stovall Secretary of Natural and Historic Resources Deputy Director for Operations

Matthew S. Wells Darryl Glover Director Deputy Director for Dam Safety, Floodplain Management and Soil and Water Conservation Andrew W. Smith Chief Deputy Director Laura Ellis Deputy Director for Administration and Finance

MEMORANDUM

DATE: February 2, 2024

TO: Julia Wellman

FROM: Allison Tillett, Environmental Impact Review Coordinator

SUBJECT:

DEQ 24-005F, North Anna Power Station Units 1 & 2 License Renewal Draft EIS

Division of Planning and Recreation Resources

The Department of Conservation and Recreation (DCR), Division of Planning and Recreational Resources (PRR),

develops the Virginia Outdoors Plan and coordinates a broad range of recreational and environmental programs throughout Virginia. These include the Virginia Scenic Rivers program; Trails, Greenways, and Blueways; Virginia State Park Master Planning and State Park Design and Construction. PRR also administers the Land & Water Conservation Fund (LWCF) program in Virginia.

Division of Natural Heritage

The Department of Conservation and Recreation's Division of Natural Heritage (DCR) has searched its Biotics Data System for occurrences of natural heritage resources from the area outlined on the submitted map. Natural heritage resources are defined as the habitat of rare, threatened, or endangered plant and animal species, unique or exemplary natural communities, and significant geologic formations.

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

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

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

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

State Parks

• Soil and Water Conservation

• Planning and Recreation Resources Natural Heritage

• Dam Safety and Floodplain Management

• Land Conservation

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

The Virginia Department of Wildlife Resources (VDWR) maintains a database of wildlife locations, including threatened and endangered species, trout streams, and anadromous fish waters that may contain information not documented in this letter. Their database may be accessed https://services.dwr.virginia.gov/fwis/ or contact Amy Martin at 804-367-2211 or amy.martin@dwr.virginia.gov.

Thank you for the opportunity to comment on this project.

Division of State Parks

DCRs Division of State Parks is responsible for acquiring and managing, state parks. Park development and master planning are managed by the Division of Planning and Recreation Resources. Master plans are required prior to a parks opening and are updated every ten years (Virginia Code § 10.1-200 et seq.).

Division of Dam Safety and Floodplain Management

Dam Safety Program:

The Dam Safety program was established to provide proper and safe design, construction, operation and maintenance of dams to protect public safety. Authority is bestowed upon the program according to The Virginia Dam Safety Act, Article 2, Chapter 6, Title 10.1 (10.1-604 et seq) of the Code of Virginia and Dam Safety Impounding Structure Regulations (Dam Safety Regulations), established and published by the Virginia Soil and Water Conservation Board (VSWCB).

Floodplain Management Program:

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

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

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

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

B. If any state-owned property is located in a community that does not participate in the NFIP, all development, including buildings, on such state-owned property shall comply with the NFIP

requirements as defined in 44 CFR §§ 60.3, 60.4, and 60.5 and any flood-related standards identified in the Virginia Uniform Statewide Building Code.

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

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

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

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

The following definitions are from Executive Order 45:

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

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

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

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

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

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

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

Floodplain Management.

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

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

www.dcr.virginia.gov/vfris

To find community NFIP participation and local floodplain administrator contact information, use DCRs Local Floodplain Management Directory: www.dcr.virginia.gov/dam-safety-and-floodplains/floodplain-directory

The remaining DCR divisions have no comments regarding the scope of this project. Thank you for the opportunity to comment.

MEMORANDUM

TO: Julia Wellman, DEQ/EIR Environmental Program Planner

FROM: Nikolas I. Churchill, Division of Land Protection & Revitalization Review Coordinator

DATE: February 2, 2024

COPIES: Sanjay Thirunagari, Division of Land Protection & Revitalization Review Manager; file

SUBJECT:

Environmental Impact Review: 24-005F Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2, Draft Report for Comment in Louisa and Spotsylvania Counties, Virginia.

The Division of Land Protection & Revitalization (DLPR) has completed its review of the U.S.

Nuclear Regulatory Commissions January 9, 2024 EIR for 24-005F Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2, Draft Report for Comment in Louisa and Spotsylvania Counties, Virginia.

DLPR staff conducted a search (200 ft. radius) of the project area of solid and hazardous waste databases (including petroleum releases) to identify waste sites in close proximity to the project area. DLPR identified one (1) RCRA small quantity generator within the project area which might impact the project.

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

Hazardous Waste/RCRA Facilities - One (1) found in close proximity to the project area.

1. Registry ID 110001891114, Virginia Electric - North Anna Power Station, 1022 Haley Dr, Mineral, VA 23117, Small Quantity Generator, Active Status: Y

CERCLA Sites - none in close proximity to the project area.

Formerly Used Defense Sites (FUDS) - none in close proximity to the project area.

Solid Waste - none in close proximity to the project area.

Virginia Remediation Program (VRP) - none in close proximity to the project area.

Petroleum Releases - none in close proximity to the project area.

Please note that the DEQs Pollution Complaint (PC) cases identified should be further evaluated by the project engineer or manager to establish the exact location, nature and extent of the petroleum release and the potential to impact the proposed project. In addition, the project engineer or manager should contact the DEQs Northern Regional Office at (703) 583-3800 (Tanks Program) for further information about the PC cases.

PROJECT SPECIFIC COMMENTS

Solid and hazardous waste issues and sites were adequately addressed in the report.

GENERAL COMMENT

S

Soil, Sediment, Groundwater, and Waste Management

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

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

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

Asbestos and/or Lead-based Paint

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

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

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

If you have any questions or need further information, please contact Nikolas Churchill by phone at (804) 659-2663 or email nikolas.churchill@deq.virginia.gov.

January 30, 2024

Department of Environmental Quality Attn: Julia Wellman 1111 East Main Street Richmond, VA 23219 Re: License Renewal for North Anna Power Station Units 1 and 2, DEQ #24-005F, Site-Specific Draft Supplemental Environmental Impact Statement

Dear Ms. Wellman:

This will respond to the request for comments regarding the draft supplemental Environmental Impact Statement for the North Anna Power Station Units 1 and 2 License Renewal Project (DEQ #24-005F),

prepared by the U.S. Nuclear Regulatory Commission, on behalf of Virginia Electric and Power Company (Dominion Energy). Specifically, Dominion Energy has proposed to renew operating licenses for North Anna Power Station for a period of 20 years at facilities located along Lake Anna in Louisa and Spotsylvania counties in Virginia.

We reviewed the provided project documents and found the proposed project will not impact resources within the jurisdictional areas of the Virginia Marine Resources Commission (VMRC) and will therefore not require a permit from this agency. Please be advised that the VMRC, pursuant to

§28.2-1200 et seq of the Code of Virginia, has jurisdiction over encroachments in, on, or over the beds of the bays, ocean, rivers, streams, or creeks which are the property of the Commonwealth.

Accordingly, if any portion of the subject project involves any encroachments channelward of ordinary high water along non-tidal, natural rivers and streams with a drainage area greater than 5-square miles, a permit may be required from our agency or the Department of Environmental Quality. Any jurisdictional impacts will be reviewed by the VMRC during the JPA process. Should the proposed project change, a new review by this agency may be required relative to these jurisdictional areas.

Please contact me at (757) 247-2285 or by email at claire.gorman@mrc.virginia.gov if you have questions. Thank you for the opportunity to comment.

Sincerely,

Claire Gorman Environmental Engineer, Habitat Management Department of Environmental Quality January 30, 2024 Page Two

CG/dd HM COMMONWEALTH of VIRGINIA

Greg Campbell Department of Aviation V/TDD - (804) 236-3624 Director FAX - (804) 236-3635 5702 Gulfstream Road Richmond, Virginia 23250-2422

January 11, 2024

Ms. Julia Wellman Department of Environmental Quality Office of Envrionmental Impact Review P.O. Box 1105 Richmond, VA 23218

RE: Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2, Draft Report for Comment, DEQ #24-005F

Dear Ms. Wellman,

The Virginia Department of Aviation has received and reviewed the draft report for the site-specific Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2

The nearest public-use airports of concern to the North Anna power station are the Lake Anna airport, about 6.9 miles to the Southeast and Louise County airport, about 10.4 miles to the Southwest. As the power plant is beyond 20,000 linear feet from both airports, the Department of Aviation takes no exception to the findings of this report. Additionally, the report contains no new construction of 200 feet above ground level or higher that is of a concern to the safety of aerial navigation.

Should you have any questions or concerns, feel free to contact me at Stephen.smiley@doav.virginia.gov or (804) 236-3627.

Sincerely, Stephen Smiley

Stephen Smiley Senior Aviation Planner

2/8/24, 10:02 AM Mail - Wellman, J ulia (DEQ) - Outlook

RE: NEW PROJECT NRC License Renewal of Nuclear Plants, DEQ 24-005F

Heller, Matthew (Energy) <matt.heller@energy.virginia.gov>

Thu 2/8/2024 8:47 AM To: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

Here are some relevant publicaons

Comprehensive report related to the 2011 earthquake hps://pubs.geoscienceworld.org/gsa/books/book/682/The-2011-Mineral-Virginia-Earthquake-and-Its

Geology of the Mineral and Lake Anna West quadrangles hps://www.energy.virginia.gov/commerce/ProductDetails.aspx?productID=3026

Geologic map of the Pendleton quadrangle (epicentral area for 2011 earthquake) hps://www.energy.virginia.gov/commerce/ProductDetails.aspx?productID=3052

Seismological invesgaon of acve faults in the Central Virginia Seismic Zone hps://earthquake.usgs.gov/cfusion/external_grants/reports/G17AP00035.pdf

Earthquake potenal of the Central Virginia Seismic Zone hps://earthquake.usgs.gov/cfusion/external_grants/reports/G13AP00045.pdf

From: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

Sent: Thursday, February 8, 2024 8:26 AM To: Heller, Mahew (Energy) <ma.heller@energy.virginia.gov>

Subject:

Re: NEW PROJECT NRC License Renewal of Nuclear Plants, DEQ 24-005F

Good morning,

I am happy to inc lude the link s if y ou would lik e to email them to me.

Thank y ou!

Julia Wellman Environmental Impact Review Coordinator

Office of Environmental Impact Review and Long Range Priorities

Division of Environmental Enhancement Virginia Department of Environmental Quality 1111 East Main Street, Suite 1400 Richmond, Virginia 23219 (804) 774-8237

For program updates and public notices, please subscribe to Constant

Contact:

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

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From: Heller, Mahew (Energy) <ma.heller@energy.virginia.gov>

Sent: Thursday, February 8, 2024 8:24 AM To: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

Subject:

RE: NEW PROJECT NRC License Renewal of Nuclear Plants, DEQ 24-005F

Hi Julia,

My only comments are to note there are new geologic maps in the vicinity of the Lake Anna plants and several recent studies on the 2011 earthquake and seismicity in the eastern U.S.

I am happy to provide links to some of these if you think it is helpful.

Sincerely, Ma Heller

From: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

Sent: Wednesday, February 7, 2024 4:14 PM To: Heller, Mahew (Energy) <ma.heller@energy.virginia.gov>

Subject:

Fw: NEW PROJECT NRC License Renewal of Nuclear Plants, DEQ 24-005F Importance: High

Good afternoon,

DEQ is c onduc ting a c oordinated rev iew of the draft s upplemental EIS for the s ubs equent lic ens e renewal for North Anna Units 1 and 2.

Dav id Spears has been our c ontac t at Virginia Energy on National Env ironmental Polic y Ac t rev iews and other planning doc uments. Unfortunately, we did not rec eiv e a undeliv erable or bounc e bac k email from his ac c ount when this projec t was dis tributed in J anuary. We were jus t notified that he has retired, s o I am forwarding this rev iew reques t to y ou.

Unfortunately, the c ommenting deadline to us was y es terday, and the federal NRC deadline is quic k ly approac hing.

I am reac hing out in c as e y ou hav e any c omments on this propos al. If y ou think that y ou would lik e to c omment, will y ou pleas e let me k now this week and we c an arrange for a new deadline? Otherwis e, we will s ubmit our rev iew to the NRC.

Pleas e feel free to reac h out if y ou hav e any ques tions. Thank y ou!

Regards, J ulia

Julia Wellman Environmental Impact Review Coordinator

Office of Environmental Impact Review and Long Range Priorities

Division of Environmental Enhancement Virginia Department of Environmental Quality 1111 East Main Street, Suite 1400

https ://outlook.offic e365.c om/mail/inbox /id/AQMk AGMz N2Y5ZTMwLTk 4N2UtNDdjYS1hYjVmLTI5ZTYwYTI0MTM2OABGAAADL5y 7x qUXuEuC%2Bu2/5 2/13/24, 8:21 AM Mail - Wellman, J ulia (DEQ) - Outlook

ESSLog# 41133/44792_24-005F_NRC License Renewal of Nuclear Plants_DWR_HLB20240212

Brann, Lee (DWR) <Lee.Brann@dwr.virginia.gov>

Mon 2/12/2024 8:36 PM To: Wellman, Julia (DEQ) <Julia.Wellman@deq.virginia.gov>

Cc: Strawderman, Nicole (DWR) <Nicole.Strawderman@dwr.virginia.gov>; Odenkirk, John (DWR)

<John.Odenkirk@dwr.virginia.gov>; Reeser, Stephen (DWR) <Steve.Reeser@dwr.virginia.gov>; Martin, Amy (DWR)

<amy.martin@dwr.virginia.gov>; Bednarski, Michael (DWR) <Mike.Bednarski@dwr.virginia.gov>

1 attachments (109 KB) 41133_21-109F_NAPS Units 1 and 2 Relicensing_DWR_AEM20210927.pdf;

Ms. Wellman, We have reviewed the USNRC Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2 in Louisa and Spotsylvania Counties. DWR provided scoping comments on the relicensing of Units 1 and 2 on 9/27/21. Those comments are attached. They remain valid and continue to apply. We note that DWR was not contacted by Dominion about the Comprehensive Aquatic Vegetation Management Plan described in our scoping comments from 9/27/21.

Please reach out if you have any additional questions or concerns.

Thank you,

Lee Bra nn En v iro n men tal Serv ices Bio lo g ist Wildlife Info rma tio n a nd Env iro nmenta l Serv ices

P 8 0 4.3 6 7.1 2 9 5

C 8 0 4.4 8 1.1 9 3 4

Depa rtment o f Wildlife Reso urces CONSERVE. CONNECT. PROTECT.

A 7 8 7 0 Villa Park Driv e, P.O. Bo x 9 0 7 7 8, Hen rico, VA 2 3 2 2 8 www.Virg inia Wildlife.g o v

https ://outlook.offic e365.c om/mail/inbox /id/AQMk AGMz N2Y5ZTMwLTk 4N2UtNDdjYS1hYjVmLTI5ZTYwYTI0MTM2OABGAAADL5y 7x qUXuEuC%2Bu1/1 9/27/21, 3:59 PM Commonwealth of Virginia Mail - ESSLog# 41133_21-109F_NAPS Units 1 and 2 Relicensing_DWR_AEM20210927

Martin, Amy <amy.martin@dwr.virginia.gov>

ESSLog# 41133_21-109F_NAPS Units 1 and 2 Relicensing_DWR_AEM20210927 1 message

Martin, Amy <amy.martin@dwr.virginia.gov> Mon, Sep 27, 2021 at 3:59 PM To: John Fisher <john.fisher@deq.virginia.gov>

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

<mike.bednarski@dwr.virginia.gov>

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

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

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

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

Thanks, Amy

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

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

https://mail.google.com/mail/u/1?ik=e7bfecb2f8&view=pt&search=all&permthid=thread-a%3Ar-5955574523664893768%7Cmsg-a%3Ar242729961898 1/1