ML24052A367
| ML24052A367 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/21/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 89FR960 | |
| Download: ML24052A367 (11) | |
Text
From:
Willson, Matthew (he/him/his)
<Willson.Matthew@epa.gov>
Sent:
Wednesday, February 21, 2024 3:04 PM To:
tam Tran; Stacy Schumann; NorthAnnaEnvironmental Resource Cc:
Witman, Timothy
Subject:
[External_Sender] EPA Comments for DSEIS Virginia Electric and Power Company North Anna Power Station Units 1 and 2 Attachments:
20240221_NorthAnna-SEIS_EPACommentLetterfinalsigned.pdf Mr. Tran and Ms. Schumann, Attached are EPAs comments for the Draft Supplemental Environmental Impact Statement (DSEIS) for the Virginia Electric and Power Company North Anna Power Station Units 1 and 2 submitted in December 2023.
Please reach out if you have any questions or concerns.
Thank you, Matthew Willson NEPA Specialist-Environmental Assessment Branch Office of Communities, Tribes and Environmental Assessment EPA Region 3 Philadelphia, PA Phone: 215-814-5795 Email: willson.matthew@epa.gov Pronouns: He/Him Pronouns: He/Him/His
Federal Register Notice:
89FR960 Comment Number:
3 Mail Envelope Properties (SA9PR09MB4766FCBA6444708D71D1507BEA572)
Subject:
[External_Sender] EPA Comments for DSEIS Virginia Electric and Power Company North Anna Power Station Units 1 and 2 Sent Date:
2/21/2024 3:04:15 PM Received Date:
2/21/2024 3:04:30 PM From:
Willson, Matthew (he/him/his)
Created By:
Willson.Matthew@epa.gov Recipients:
"Witman, Timothy" <witman.timothy@epa.gov>
Tracking Status: None "tam Tran" <Tam.Tran@nrc.gov>
Tracking Status: None "Stacy Schumann" <Stacy.Schumann@nrc.gov>
Tracking Status: None "NorthAnnaEnvironmental Resource" <NorthAnnaEnvironmental.Resource@nrc.gov>
Tracking Status: None Post Office:
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February 21, 2024 VIA ELECTRONIC MAIL ONLY Mr. Tam Tran Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Tam.Tran@nrc.gov
Dear Mr. Tran:
Pursuant to the National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act (CAA),
the U.S. Environmental Protection Agency (EPA) has reviewed and provides our enclosed detailed comments on the December 2023 Draft Supplemental Environmental Impact Statement (DSEIS) for the Virginia Electric and Power Company North Anna Power Station Units 1 and 2 (Study). The CAA Section 309 role is unique to EPA. It requires EPA to review and comment on the environmental impact of any proposed federal action subject to NEPAs environmental impact statement requirement and to make its comments public.
This DSEIS proposes to renew the operating licenses for North Anna Power Station, Units 1 and 2 (North Anna) for an additional 20 years. The Study includes the site-specific evaluation of the environmental impacts of the proposed action, and alternatives. As alternatives, the (Nuclear Regulatory Commission (NRC) considered a new nuclear (small modular reactor) generation, a combination of solar photovoltaic, offshore wind, small modular reactor, and demand-side management, and no action.
This DSEIS supersedes a previously submitted EIS entitled, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 7, Second Renewal, Regarding Subsequent License Renewal for North Anna Power Station Units 1 and 2 published in August 2021. The Study was drafted because the NRC determined that the previously published EIS was not adequately site specific.
EPA identified public health, welfare, or environmental quality concerns in the analysis that EPA recommends be addressed in the final EIS. EPAs primary concerns and recommendations are summarized below and detailed in the enclosure. EPA makes these recommendations to improve the usefulness of the EIS for agency decision making and to reduce potential environmental impacts of the proposed action. Please note that the order of EPAs Detailed Comments in the enclosure reflects the organization of the DSEIS and not the degree of EPAs priority.
2
- Alternatives Analysis (pp. 2-24 through 2-31). Due to the advance nature of the DSEIS and the rapid pace of technological innovation, EPA recommends NRC and Dominion conduct a re-evaluation of conditions before commencement of the proposed action.
- Aquatic Resources (pp. 3-69 through 3-119). EPA recommends the EIS clarify how the waste heat treatment facility (WHTF) lagoons may impact tributaries to Lake Anna.
- Impacts Common to All Alternatives (pp. 3-185 through 3-195). EPA recommends an expanded discussion of the control and mitigation of Sulfur Hexafluoride use at the facility.
- Environmental Justice (EJ) Appendix D. EPA encourages NRC to expand its public outreach efforts to the public, with a focus on communities with Environmental Justice concerns.
Sincerely, Timothy Witman Environmental Assessment Branch Chief, Office of Communities, Tribes and Environmental Assessment US EPA Region 3 ENCLOSURES
- 1. EPA Detailed Comments on the December 2023 Draft Supplemental Environmental Impact Statement for Virginia Electric and Power Company; North Anna Power Station Units 1 and 2 TIMOTHY WITMAN Digitally signed by TIMOTHY WITMAN Date: 2024.02.21 14:11:16 -05'00'
3 EPA Detailed Comments Draft Supplemental Environmental Impact Statement for Virginia Electric and Power Company; North Anna Power Station Units 1 and 2, December 2023 Submitted to NRC on February 21, 2024 The U.S. Environmental Protection Agency (EPA) has identified environmental impacts for the proposed action, as described in the Draft Supplemental Environmental Impact Statement (DSEIS) for the Virginia Electric and Power Company; North Anna Power Station Units 1 and 2 (Study), specifically to aquatic resources and communities with environmental justice (EJ) concerns.
- 1. Alternatives Analysis-Section 2.4 The DSEIS states alternatives were dismissed due to technical, resource availability, or commercial limitations that currently exist and that the NRC staff believes are likely to still exist when the current North Anna licenses expire. As technologies continue to evolve in capabilities and cost, EPA continues to recommend, due to the advance nature of the DSEIS, NRC and Dominion conduct a re-evaluation of conditions before commencement of the proposed action. New information may be available, and other alternatives or combination of alternatives may be more commercially viable. Furthermore, a re-evaluation may capture unforeseen area population growth or additional stressors on the air or water resources that may not have been accounted for in the DSEIS.
- 2. Aquatic Resources-Section 3.7.3.2 Although NRC has included additional language in Section 3.7.3.2, clarifying that due to the direction of discharge flow, thermal effluent would not impact aquatic organisms in certain creeks that are hydrologically connected to the waste heat treatment facility (WHTF), EPA continues to recommend the DSEIS clarify how the WHTF lagoons are constructed and configured at the site. A detailed schematic would be useful to better understand how the WHTFs interact with the reservoir and how flow moves through the interconnected lagoons to the reservoir. A discussion regarding the relationship between the tributaries and the lagoons and the impacts of the flow would help clarify potential impacts to the tributaries. EPA recommends an analysis be conducted on the impact these facilities have on the tributaries' aquatic organisms and ecosystem, including appropriate mitigation analysis.
- 3. Impacts Common to All Alternatives-Section 3.14.3.1 North Ana currently uses Sulfur Hexafluoride for electrical breaker cooling. Sulfur Hexafluoride is among the most potent greenhouse gases known. EPA recommends an expanded discussion of the use of Sulfur Hexafluoride in the facility, including the measures used to control leakage, the potential phase out of Sulfer Hexafluoride and other mitigation measures.
The text in Lines 38-41 on page 3-190 are unclear. EPA recommends reviewing and revising the text for clarity.
- 4. Environmental Justice (EJ) Appendix D EPA recognizes that NRC intends to continue its established practice of performing public outreach by providing notices in the Federal Register, local newspapers and through the county Louisa County Public Library. However, EPA encourages the NRC to conduct further community outreach for meaningful public engagement and participation, particularly with low income, minority and/or
4 linguistically isolated communities in the study area. EPA encourages the NRC to provide notices of public meetings, notices of informational events, and/or other related resources at frequently visited community locations. These locations may include, but may not be limited to, schools, faith centers, community centers, barbershops, salons, and medical centers. This includes engagement through electronic mediums such as on-line community bulletin boards and social media. These efforts should be documented in the EIS.