ML24108A039

Letter to E Carr-V.C. Summer Unit 1- Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application

ML24108A039
Person / Time
Site:	Summer
Issue date:	04/18/2024
From:	Kimberly Conway NRC/NMSS/DREFS/ELRB
To:	Carr E Dominion Energy South Carolina
References
EPID L-2023-SLE-0003
Download: ML24108A039 (1)

Text

Eric S. Carr President - Nuclear Operations and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - LICENSE RENEWAL REGULATORY AUDIT REGARDING THE ENVIRONMENTAL REVIEW OF THE SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NUMBER:

L-2023-SLE-0003)

Dear Eric Carr:

By letter dated August 17, 2023 (Agencywide Documents Access and Management System Package ML23233A179), Dominion Energy South Carolina, Inc. (Dominion Energy, the applicant) submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for the subsequent renewal of Facility Operating License No. NPF-12 for Virgil C. Summer Nuclear Station, Unit 1, (V.C. Summer, VCSNS) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and Part 54 of Title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants.

The NRC staff has initiated its environmental review for the application. An environmental audit will be conducted by NRC staff in May 2024: a virtual audit the week of May 13, 2024, and a site visit the week of May 20, 2024. The environmental audit activities will be conducted in accordance with the enclosed Environmental Audit Plan (Enclosure 1).

To the extent possible, the NRC staff requests the information identified in the Environmental Audit Needs List (Enclosure 2) be made available on the V.C. Summer online reference portal prior to the audit. A draft schedule of tours and meetings is provided in Enclosure 3.

April 18, 2024 E. Carr If you have any questions, please contact me via email at kimberly.conway@nrc.gov.

Sincerely, Kimberly Conway Environmental Project Manager Environmental Project Management Branch 1 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. 50-395

Enclosures:

As stated cc w/encls: Listserv Signed by Conway, Kimberly on 04/18/24

ML24108A039 OFFICE PM:REFS/EPMB1 LA:REFS/EPMB2 BC:REFS/EPMB1 PM:REFS/EPMB1

NAME KConway AWalker-Smith SKoenick KConway

DATE 04/17/2024 04/17/2024 04/18/2024 04/18/2024

Audit Plan

Subsequent License Renewal Environmental Review Virgil C. Summer Nuclear Station, Unit 1

May 2024

Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission

Enclosure 1 2

Subsequent License Renewal Environmental Review Virgil C. Summer Nuclear Station, Unit 1

1. Background

By letter dated August 17, 2023 (Agencywide Documents Access and Management System Package ML23233A179), Dominion Energy South Carolina, Inc. (Dominion Energy, the applicant) submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for the subsequent renewal of Facility Operating License No. NPF-12 for Virgil C. Summer Nuclear Federal RegisterStation, Unit 1, (V.C. Summer, VCSNS). A notice (88 FR 62409) dated September 11, 2023, noted the receipt and availability of the application, including the environmental report (ER).

The NRC staff is conducting an environmental audit of the V.C. Summer site to improve understanding, to verify information, and to identify information for docketing to support the preparation of an Environmental Impact Statement (EIS). Specifically, the NRC staff will be identifying pertinent environmental data, reviewing the facility, and seeking clarifications regarding information provided in the ER.

2. Environmental Audit Bases

License renewal requirements for ERs are specified in title 10 of the Code of Federal Regulations (10 CFR) Part 51, Postconstruction environmental reports. As specified by 10 CFR 51.53(c): Operating license renewal stage, (1) Each applicant for renewal of a license to operate a nuclear power plant under Part 54 of this chapter shall submit with its application a separate document entitled "Applicant's Environmental ReportOperating License Renewal Stage." Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 -

Operating License Renewal.

The NRC staff intends to gather the information necessary to prepare a site-specific EIS related to the subsequent license renewal application for V.C. Summer. During the scoping process required in 10 CFR Part 51, the NRC staff is required to define the proposed action, identify significant issues which must be studied in depth, and to identify those issues that can be eliminated from further study.

3. Environmental Audit Scope

The scope of this environmental audit is to identify new and significant issues and issues which can be eliminated from further study. The NRC staff will also identify environmental resources that must be described and evaluated in the EIS. Audit team members will review the documents and other requested information made available on the V.C. Summer online reference portal identified on the environmental audit needs list (Enclosure 2) and discuss any questions and additional information needs with the applicants subject matter experts.

4. Information and Other Material Necessary for the Environmental Audit

As identified on the environmental audit needs list (Enclosure 2).

5. Environmental Audit Team Members and Resource Assignments

The environmental audit team members and their assignments are shown in the table below.

3

Discipline NRC Team Members Environmental Review Supervisor Steve Koenick Environmental Project Manager Kim Conway Environmental Supper Project Manager Karen Loomis Air Quality Nancy Martinez Aquatic Resources Briana Arlene Cumulative Impacts Jeff Rikhoff Environmental Justice Jeff Rikhoff Federally Protected Ecological Resources Briana Arlene Geologic Environment Gerry Stirewalt Greenhouse Gases/Climate Change Nancy Martinez Groundwater (Hydrology and Hydrogeology) Gerry Stirewalt Historic and Cultural Resources Nancy Martinez Human Health Beth Alferink Land Use and Visual Resources Caroline Hsu Meteorology and Climatology Nancy Martinez Noise Nancy Martinez Postulated Accidents Elijah Dickson Replacement Power Alternatives Jeff Rikhoff Severe Accident Mitigation Alternatives Elijah Dickson Socioeconomics Caroline Hsu Spent Nuclear Fuel Leah Parks Surface Water Lloyd Desotell Termination of Operations and Decommissioning Beth Alferink Terrestrial (Land Cover and Habitat) Caroline Hsu Uranium Fuel Cycle Beth Alferink Waste Management (Rad and Non-Rad) Leah Parks

6. Logistics

An environmental audit will be conducted remotely during the week of May 13, 2024, followed by a site-visit the week of May 20, 2024. An entrance meeting will be held with plant management at the beginning of the audit and an exit meeting will be held at the end of this audit following the site visit.

7. Special Requests

Dominion Energy staff and contractors who are subject matter experts in the disciplines identified on the environmental audit needs list should be available for interviews and tours.

8. Deliverables

An audit summary report will be issued by the NRC staff within 90 days from the end of the environmental audit.

Virgil C. Summer Nuclear Station, Unit 1 Environmental Audit and Information Needs

Described below in three categories (i.e., tours, meetings, and information needs) are the information needs of the U.S. Nuclear Regulatory Commission (NRC) staff, supported by Pacific Northwest National Laboratory (PNNL), related to the subsequent license renewal (SLR) application for Virgil C. Summer Nuclear Station, Unit 1 (V.C. Summer, VCSNS). Information needs are identified as either resource-specific questions or document requests. Please arrange for the tours and meetings to occur during the either the virtual environmental audit or site visit, as specified below. Additionally, we ask that you provide responses to the information needs on the electronic portal and make subject matter experts available to discuss these items with the NRC staff.

Virtual Tours

Please arrange for, and provide appropriate subject matter experts to contribute to, the following virtual tours.

Title or Number Features Observed NRC PNNL Participants Participants

1. General site Virtual walk-through of the following via All All tour photographs, 3D tour, and/or diagrams:

• Exterior grounds

• Transmission lines, including transition from in-scope to offsite and the Parr 115-kV transmission corridor noting the separation from the owner-controlled area (OCA) to the area under ownership but not within the OCA.

• Historic and cultural sites

• Possible alternative power generation locations

• Independent Spent Fuel Storage Installation (ISFSI)

• Plant views from publicly accessible areas

2. Plant intake Virtual walk-through of the following via All All and discharge photographs and/or diagrams:

tour

• Submerged multi-port intake and intake tunnel, including depiction of location of intake

• Traveling screens

• Service water pumphouse

• Emergency service water forebay

• Cooling towers and cooling tower basin

• Discharge tunnel and discharge outfall

3. Radwaste tour Virtual walk-through of the following via Beth Alferink Rebecka Bence photographs and/or diagrams: Leah Parks

• Liquid radwaste system - discharge Gerry Stirewalt locations

Enclosure 2 2

• Gaseous radwaste system - discharge locations

• Low-Level Radioactive Waste Storage Area (Radwaste Building)

4. Geologic Virtual walk-through via photographs, maps, Gerry Stirewalt Rebecka Bence Environment and/or diagrams of any features or Lloyd Desotell Rajiv Prasad structures that provide sediment and erosion Kazi Tamaddun controls at the site (Related to Needs GE-1 and GE-2)

5. Groundwater Virtual walk-through of the following via Gerry Stirewalt Rebecka Bence Resources photographs, maps, and/or diagrams: Lloyd Desotell Rajiv Prasad

• Any exposures of fractured crystalline Kazi Tamaddun bedrock that forms the primary aquifer (Related to Need GW-4)

• Locations of monitoring wells B-22 and B-36 that showed groundwater mounding and maps of the stormwater drainage system near these wells (Related to Need GW-5)

• Locations of the SSCs being monitored as part of the Groundwater Protection Plan and the monitoring wells, with maps showing the locations (Related to Need GW-6)

• Locations of groundwater wells affected by the historical release of tritium in July 2011 and the source, with maps showing the locations (Related to Need GW-9)

In-person Tours

Please arrange for, and provide appropriate subject matter experts to contribute to, the following in-person tours as part of the NRCs site visit.

Title or Number Features Observed NRC PNNL Participants Participants (Tentative) (Tentative)

1. General site

• Exterior grounds All tour

• Transmission lines, including transition from in-scope to offsite and the Parr 115-kV transmission corridor noting the separation from the OCA to the area under ownership but not within the OCA.

• Possible alternative power generation locations

• ISFSI Plant views from publicly accessible areas

2. Historic and

• 10 archaeological sites within the Nancy Martinez Lindsey Renaud Cultural VCSNS site Resources

• Location and vicinity of the 600-ft buried portion of the 115-kV 3

transmission line within the Parr transmission corridor

3. Geologic

• Any features or structures that provide Gerry Stirewalt Rebecka Bence Environment sediment and erosion controls at the site Lloyd Desotell Kazi Tamaddun (Related to Needs GE-1 and GE-2)

4. Groundwater

• Any exposures of fractured crystalline Gerry Stirewalt Rebecka Bence Resources bedrock that forms the primary aquifer Lloyd Desotell Kazi Tamaddun (Related to Need GW-4)

• Locations of accessible dewatering wells and location(s) of groundwater dewatering discharge (Related to Needs GW-1 and GW-2)

• Locations of monitoring wells B-22 and B-36 that showed groundwater mounding supported by maps of the stormwater drainage system near the wells (Related to Need GW-5)

• SSCs being monitored as part of the Groundwater Protection Plan and the monitoring wells, supported by maps.

Include the wastewater treatment area facilities and associated groundwater monitoring wells (Related to Need GW-6)

• Locations of groundwater wells affected by the historical release of tritium in July 2011 and the source, supported by maps (Related to Need GW-9)

5. Plant intake To the extent that these components of the Gerry Stirewalt Rebecka Bence and discharge intake and discharge systems are Lloyd Desotell Kazi Tamaddun tour accessible/viewable: Caitlin Wessel

• Submerged multi-port intake and intake tunnel, including depiction of location of intake

• Traveling screens

• Service water pumphouse

• Emergency service water forebay

• Cooling towers and cooling tower basin

• Discharge tunnel and discharge outfall

Meetings

Please provide for breakout meetings with the appropriate subject matter expert(s) and/or the contractor(s) regarding the following topics. Those in attendance should be prepared to discuss the corresponding questions as described in the Information Needs and Document Requests section below. The staff intends to use these meetings, as needed, to resolve or clarify any outstanding data needs or questions arising from the hybrid environmental audit. NRC intends to leverage virtual breakouts to the extent possible.

• Air Quality and Noise

• Aquatic Resources

• Cumulative Impacts 4

• Environmental Justice

• Federally Protected Ecological Resources

• Geologic Environment

• Greenhouse Gas Emissions and Climate Change

• Groundwater

• Historic and Cultural Resources

• Human Health

• Land Use and Visual Resources

• Meteorology and Climatology

• Replacement Energy Alternatives

• Severe Accident Mitigation Alternatives

• Socioeconomics

• Surface Water

• Terrestrial Resources

• Waste Management

Information Needs and Document Requests

Information needs and document requests are identified below by resource area.

General Requests

The following requests are generic to more than one environmental review area. Issues applicable to these questions are provided below along with the responsible NRC subject matter expert, as appropriate.

GEN-1Please provide any relevant updates to table E9.1-1. If any authorizations have expired since Dominion Energys Application for Subsequent Renewed Operating License, dated August 17, 2023 (Agencywide Documents Access and Management System (ADAMS) ML23233A179), please provide the status of those permits and/or renewals.

GEN-2Have there been any documented unplanned releases of radioactive materials (unplanned/ inadvertent radioactive liquid or gaseous releases) since Dominion Energys Environmental Report dated August 17, 2023 (ML23233A174)? If so, please provide a written description of the releases and be prepared to discuss these releases in relation to the following environmental issues, which were previously dispositioned as generic (Category 1), as applicable.

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

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

Human Health - Radiation exposures to the public (Alferink)

Human Health - Radiation exposures to plant workers (Alferink) 5

Surface Water Resources - Discharge of metals in cooling system effluent (Desotell)

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

Terrestrial Resources - Exposure of terrestrial organisms to radionuclides (Hsu)

Uranium Fuel Cycle - Transportation (Alferink)

Waste Management - Low-level waste storage and disposal (Parks)

Waste Management - Mixed-waste storage and disposal (Parks)

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

Topic-Specific Requests

The following requests are specific to a single environmental review area. If a topic is not provided below, the discussion held in response to the generic requests above are expected to fully cover that topic.

Air Quality (Nancy Martinez, NRC)

Audit Needs

AQN-1Section E3.3.3.2 of the environmental report (ER) states that [a] list of estimated diesel generator emissions at VCSNS is provided in table E3.3-9. And [t]he emission sources at VCSNS include power generators, an auxiliary boiler used during outages, and other miscellaneous sources such as storage tanks and a paint booth. Table E3.3-9 of the ER provides maximum carbon dioxide equivalent emissions for various generators. However, table E3.3-9 of the ER does not provide maximum annual criteria pollutant emissions (e.g., carbon monoxide, sulfur dioxide) for the on-site generators.

Provide maximum annual criteria air pollutant emissions for the sources listed in table E3.3-9 and the auxiliary boiler.

AQN-2VCSNS utilizes a mechanical draft cooling tower. Are particulate matter emissions available? If so, please provide quantified particulate matter emissions for the mechanical draft cooling tower. Does the mechanical draft cooling tower have a drift eliminator?

AQN-3Have field tests concerning ozone and nitrogen oxide emissions generated by VCSNSs in-scope transmission lines been conducted? If so, please provide a copy.

Aquatic Resources (Briana Arlene, NRC; Caitlin Wessel, PNNL)

Audit Needs

AQU-1Has Dominion Energy reported any violations of the National Pollutant Discharge Elimination System (NPDES) permit limits for temperature in the last 10 years? If so, please provide copies of the reports or notices of violation.

6

AQU-2ER Section E3.7.1.3.2 discusses fish kills in the late 1980s and early 1990s. Have there been any fish kills in the VCSNS discharge bay or adjacent areas in the last 10 years? If there have, please provide information on the fish kills, their causes, and any actions to prevent future fish kills.

Document Needs

AQU-3Ichthyoplankton survey data from 1983-1985 (different years are listed in different areas of ER), 2008-2009, and 2016-2017 entrainment monitoring (listed on p. E-3-151).

• 1984-1985: Entrainment study conducted in support of the Clean Water Act 316(a) demonstration for VCSNS and summarized in the 2004 supplemental environmental impact statement for VCSNS (ML040540718).

• 2008-2009: Entrainment study conducted at the proposed Units 2 and 3 Raw Water Intake Structure (discussed on p. E-3-151 through E-3-154).

• 2016-2017: Entrainment study conducted at the Unit 1 Cooling Water Intake Structure (discussed on p. E-3-156 through E-3-160).

AQU-4Ichthyoplankton survey data from the 2005-2006 impingement monitoring (listed on p.

E-3-151 and discussed on p. E-3-154).

AQU-5Monthly water quality monitoring data collected at all 3 locations in Monticello Reservoir for the last 5 years, including monthly temperature averages (referenced on p. E 161).

Cumulative Impacts (Jeff Rikhoff, NRC; Dave Goodman, PNNL)

Audit Needs

CI-1 In the ER, Dominion Energy reported that, as of 2019, the anticipated location of a proposed wastewater treatment plant is the southern part of Fairfield County with the specific site and funding still undetermined. Has there been an update about the status of the proposed wastewater treatment plant (e.g., location, funding, capacity)? If so, please provide this information.

CI-2 Per Title 10 of the Code of Federal Regulations (10 CFR) Part 51.53(c)(3)(ii)(O), please provide information about other past, present, and reasonably foreseeable future actions occurring in the vicinity of the nuclear plant that may result in a cumulative effect that may have occurred since the ER was submitted.

Environmental Justice (Jeff Rikhoff, NRC; Dave Anderson, PNNL; Lin Zeng, PNNL)

Audit Needs

EJ-1 What community engagement has Dominion Energy conducted to learn about the potential impacts and concerns that the local communities might have about the continued operation of the V.C. Summer nuclear plant?

7

EJ-2 Section E3.11.3.1 of the ER stated that As reported in the 2004 NUREG-1437 Supplement 15, the NRC found no unusual resource dependencies or practices, such as subsistence agriculture through which the minority and low-income populations could experience disproportionately high and adverse impacts. Have there been any more recent studies about subsistence activities near the V.C. Summer nuclear plant?

What has Dominion Energy learned from engagement with the local environmental justice communities? What new environmental justice information has been identified since the environmental review for Units 2 and 3?

Federally Protected Ecological Resources (Briana Arlene, NRC; Tracy Fuentes, PNNL)

Audit Needs

FPE-1The U.S. Fish and Wildlife Service published a proposed rule to list the tricolored bat (Perimyotis subflavus) as endangered under the Endangered Species Act on September 14, 2022 (87 FR 56381). This species range includes Fairfield, Richland, and Newberry Counties. Please provide an analysis of the potential impacts of the proposed license renewal on tricolored bat.

FPE-2Based on the analysis of FPE-1, please provide details about tricolored bat habitat on site, as well as its potential management, to include the following.

a) Please provide a map or illustration of any tricolored bat roosting or maternity habitat that could occur on site.

b) Does Dominion Energy plan to undertake tree removal or conduct any other activities during license renewal that would disturb this habitat?

c) Describe Dominion Energys best management practices (BMPs) and procedures to ensure that actions, such as removing hazard trees, would not adversely affect bats, if present.

FPE-3ER Section 3.7.8.1.9 states that suitable habitat for the monarch butterfly is likely present in undeveloped portions of the VCSNS site that are not maintained by mowing.

Monarch butterflies rely on milkweeds (Asclepias spp.) for ovipositing and for larval food. Adults rely on a variety of plants for nectar sources. Does Dominion Energy have any records of milkweed occurring on the VCSNS site? If so, when was the last time milkweed was documented on site. Does Dominion Energy have a list of vascular plants occurring on the site? If so, when was the plant list collected?

FPE-4ER Section 9.6 states: VCSNS has environmental guidance in place to ensure all environmentally sensitive areas at VCSNS, if present, are adequately protected during site operation and project planning and [a]ppropriate agencies are consulted on matters involving state and federally listed threatened, endangered, and protected species; BMPs are implemented to minimize impacts to these species. Please describe this environmental guidance in more detail as it pertains to Federally protected ecological resources and provide copies of relevant site plans and procedures for NRC staff review.

Document Needs

FPE-5Please provide copies of agency responses to the Dominion Energy letters concerning federally protected ecological resources provided in ER attachment B.

8

Geologic Environment (Gerry Stirewalt, NRC; Becka Bence, PNNL; Phil Meyer, PNNL)

Audit Needs

GE-1ER Section E3.5.3.2 (Erosion Potential), page E-3-54, states that BMPs associated with the Stormwater Protection Plan related to erosion control in the geologic environment include a sediment and erosion control program, a site-wide storm water drainage system, and other features that provide sediment and erosion controls at the site. Briefly describe the sediment and erosion control program or identify the section of the ER that contains this information. Include a description of any situations where the program effectively handled issues related to sediment and erosion control. If spills were of concern for any of those situations, please outline the BMPs used to address them.

Document Needs

GE-2If available, provide the report that describes the sediment and erosion control program and explains how any situations that occurred were handled.

Greenhouse Gas and Climate Change (Nancy Martinez, NRC)

Audit Needs

GHG-1Table E3.3-9 of the ER presents maximum carbon dioxide equivalent emissions for various on-site generators. The total maximum carbon dioxide equivalent emissions for the sources in table E3.3-9 equals 2,050 metric tons of carbon dioxide equivalents.

Table E3.3-10 of the ER presents a greenhouse gas (GHG) emissions inventory for VCSNS. GHG emissions presented in table E3.3-10 include the combustion sources in table 3.3-9 and are based on fuel usage. GHG emission presented in table 3.3-10 for combustion sources total 2,484 metric tons of carbon dioxide equivalents. Discuss why the GHG emissions for combustion sources in table E3.3-10 (2,484 metric tons of carbon dioxide equivalents) exceed the maximum carbon dioxide equivalent emissions for the same combustion sources presented in table E3.3-10 (2,050 metric tons of carbon dioxide equivalents).

GHG-2Table E3.3-10 of the ER presents a greenhouse gas emissions inventory for VCSNS for combustion sources based on fuel usage. Identify the year that this inventory refers to. Additionally, provide annual GHG emissions for on-site diesel generators and the auxiliary boiler for the most recent 5 years.

GHG-3Does VCSNS use sulfur hexafluoride onsite? If so, provide annual quantified GHG emissions.

GHG-4Section E4.12.4.4.3 of the ER states that An increase in ambient temperature of one degree Fahrenheit in a century would not affect water temperatures through the SLR period. As such, no changes in the Monticello Reservoir water temperatures are reasonably foreseeable.

a) Provide a source to support this statement and basis for concluding that there would be no changes in Monticello Reservoir water temperatures.

9

b) Has a warming trend been observed of monthly average intake, daily maximum intake, monthly average discharge, or daily maximum discharge temperatures for the available period of record? Provide data to support the conclusions reached (e.g., time series analysis).

Water Resources - Groundwater (Gerry Stirewalt, NRC; Becka Bence, PNNL; Phil Meyer, PNNL)

Audit Needs

GW-1Please provide monthly rates of dewatering over the last 5 years.

GW-2Please explain why the dewatering system was expanded from two dewatering wells (DW-1 and DW-2) in 2003 to 14 additional dewatering wells in 2008. Discuss what changes in the groundwater system made the additional wells necessary.

GW-3Describe the purpose, conduct, and results of the July 29-August 4, 2022, groundwater gauging event discussed in ER Section E3.6.2.3 (Potentiometric Surfaces).

GW-4ER figure E3.5-3a shows two geologic cross section lines (A-A and B-B) on the VCSNS site. Section E3.5.2 indicates that water table elevations depicted in the cross sections were recorded in July and August 2022 and post-date dewatering activities.

The water table shown in figure E3.5-3(b) and E3.5-3(c) occurs in fill materials and saprolite. However, ER Section E3.6.2.1 (Groundwater Aquifers), page E-3-86, states that the groundwater table at and around the VCSNS site generally occurs in jointed bedrock. Explain the apparent discrepancy in the occurrence of the water table in ER Sections E3.5.2 and E3.6.2.1. Confirm whether there are areas of perched water above the jointed bedrock.

GW-5ER Section E3.6.2.3 notes that groundwater mounding effects in the vicinity of monitoring locations B-22 and B-36, located on Figure E3.6-7, were observed during the 2022 gauging event and the effects likely resulted from surface water drainage leaking from a breach in the adjacent stormwater drainage system. Confirm the duration of this leak. Please confirm that no additives were detected in the samples collected since Section E3.6.2.1 (Groundwater Aquifers) states that pumped water is discharged into the storm drainage system and ultimately by storm sewers into the Broad River.

GW-6The table of SSCs monitored as part of the Groundwater Protection Plan lists 8 SSCs.

The text states that 9 SSCs are monitored. Please clarify whether 8 or 9 SSCs are monitored and supplement the table, if needed.

GW-7Provide the frequency of sampling for wells in the Groundwater Protection Plan monitoring, and list the analytes evaluated for this monitoring.

GW-8Provide the monitoring results (or a document containing those results) for the groundwater wells affected by the No. 2 fuel oil spill in 1978, discussed in ER Section E3.6.4.2 (Groundwater Quality), to clarify the extent of groundwater contamination.

Considering the corrective actions that have been in place since 1993, confirm whether any constituents of the fuel oil have been detected in downgradient monitoring well GW-2 above their respective maximum contaminant levels.

10

GW-9The historical maximum tritium level in groundwater at V.C. Summer is listed as 23,000 pCi/L in July 2011 as shown in the 2023 List of Leaks and Spills at Operating U.S.

Commercial Nuclear Power Plants (ML23284A164). Provide a description of this event and the response, including monitoring results for affected groundwater wells, investigation of the source, and any modifications to equipment, processes, or procedures made as a result of the event.

GW-10Please confirm whether there have been any abnormal releases of radioactive materials or tritium detections in groundwater monitoring since 2022.

GW-11Please confirm whether there have been any releases of non-radioactive materials since 2021 that have affected groundwater quality, including for the offsite domestic water supply wells located within two miles of VCSNS Center Point as shown in ER figure E3.6-8.

Document Needs

GW-12Please provide a copy of the Groundwater Protection Plan for review.

GW-13Please provide a copy for review of the report from the recent review of the Groundwater Protection Plan, as discussed in ER Section E3.6.2.4.

Historic and Cultural Resources (Nancy Martinez, NRC; Lindsey Renaud, PNNL)

Audit Needs

HCR-1 Figure E3.1-6 of the ER shows the Catawba Reservation and Catawba Off-Reservation Trust Land inside the 50 -mile radius. Section E3.1.3 of the ER, however, states that no Federal or State recognized Native American Indian Tribes with reservations or identified lands are located within the VCSNS 50-mile region. Discuss the inconsistency between figure E3.1-6 and Section E3.1.3 and confirm the proximity of the Catawba Reservation and Off-Reservation Trust Lands within the 50-mile radius of VCSNS.

HCR-2 Figures E3.8-4 through E3.8-8 of the ER show the progression of construction of the VCSNS; however, the ER does not state when construction was completed. Provide the date when construction was finalized. Additionally, provide images of the construction of the Monticello reservoir, if available.

HCR-3 Attachment C to the ER, Cultural Resource Consultation Letters, provided copies of letters Dominion Energy sent to Federally-recognized Tribes seeking input on the current license renewal. Provide all correspondence and other communication documents Dominion Energy has received from Federally-recognized Tribes since August 3, 2022. Additionally, if state-recognized Tribes were consulted, provide that correspondence.

HCR-4 Table E3.8-1 of the ER identifies 7 previous cultural resource surveys that have been conducted within the 2,200-acre area of potential effects (APE). Provide a copy of these 7 cultural resource surveys.

11

HCR-5 Approximately what percentage of the 2,200-acre APE has been archaeologically surveyed?

HCR-6 Section E3.8 of the ER states that construction of the VCSNS facility and Monticello Reservoir would have impacted any archaeological resources that may have been located within their respective footprints, much of the surrounding area remains largely undisturbed. Approximately what percentage of the 2,200-acre APE is disturbed?

HCR-7 Section E3.8.1 of the ER states that the land use history for VCSNS and the surrounding region was developed as part of a Phase 2A literature review and archaeological sensitivity assessment of the VCSNS property. Provide a copy of the Phase 2A literature review and archaeological sensitivity assessment.

HCR-8 Section E2.2.5.1 of the ER identifies that the in-scope transmission lines are those from the Turbine Building to the 230-kilovolt switchyard and a 115-kV line. The 115-kV line extends 2.6 miles from the Parr 115-kV substation to VCSNS and a 600-foot segment of this line is underground. Section E3.8 of the ER states that for purposes of the SLR, the above ground area of potential effect is defined as the entire VCNS property and everything within a 6-mile radius of VCSNS and the archaeological APE is considered bounded by the approximately 2,200-acre VCSNS site where ground disturbance, though unanticipated during the license renewal period of extended operation, might compromise the physical integrity of archaeological data.

a) Why was the 600-foot underground segment of the 115-KV transmission line not considered as part of the archaeological APE?

b) Provide a copy of VCSNS procedures in place that govern line clearing specifications and herbicide management on transmission rights of way.

c) Discuss maintenance activities performed on the underground segment of the 115-kV transmission line.

d) Have any archaeological surveys been conducted along the 115-kV transmission line corridor? If so, please identify the survey and provide a copy.

Document Needs

HCR-9 Provide the following documents and procedures:

a) Documentation or updated citation/link for the SCE&G 2022a reference:

SCE&G. 2022a. Documenting 13,000 Years of Human Occupation Along the Saluda River b) The Historic Properties Management Plan for the Fairfield Pump Storage Facility (referenced in the March 17, 2023, letter from Dominion Energy to the South Carolina State Historic Preservation Office) c) The Dominion Energy corporate procedure that addresses protection of historic and archaeological resources and handling of inadvertent discovery of human remains (referenced in Section 3.8.6 of the ER) d) All administrative procedures that define and prescribe protective measures for historic and archaeological resources e) Final Report of the V.C. Summer Nuclear Station Architectural Survey and Evaluation

12

Human Health (Beth Alferink, NRC)

Audit Needs

HH-1Please provide any updates concerning waterborne diseases in the vicinity of the plant since the submission of the subsequent license renewal environmental report, including any updates from the Centers for Disease Control and Preventions National Outbreak Reporting System Dashboard and/or subsequent local information since 2014/2020 as discussed in E.3.10.1.

HH-2Have there been any Occupational Safety and Health Administration (OSHA) recordable injuries since those reported through 2021 as noted in Section E.4.9.3.4 and E.4.9.6.4?

HH-3Please provide an overview of the radiation control program with emphasis on the as low as reasonably achievable (ALARA) program to control worker radiation exposure (annual dose goals and status). Are there any proposed changes or upgrades to the program being considered during the subsequent license renewal term?

HH-4Please have V.C. Summer subject matter experts available to discuss the electrical safety program and safety-specific policies along with related OSHA regulations as implemented at the site under the industrial safety program. Plan to discuss the safety specific policies for work conducted at electrical transmission locations as noted in E2.2.5.1, E2.2.5.4, E2.2.5.5, figure E2.2-1, E3.10.2 and E4.9.7.4 and a walk-through of the workplace hazards identification process and jobsite analysis noting how change evaluations would identify electric shock hazards or potential human error to eliminate risk during work on the in-scope transmission lines.

Document Needs

HH-5Section 3.10.2 discusses two studies performed to determine compliance with National Electrical Safety Code (NESC) guidance. Please provide a copy of the 2011 Parr 115-kV transmission line survey and the 2015 survey for the in-scope transmission lines as discussed showing the conclusion that the lines surveyed were compliant with the applicable NESC criteria at the time of the survey and concluded that there were no clearance issues.

Land Use and Visual Resources (Caroline Hsu, NRC; Dave Goodman, PNNL)

Audit Needs

LV-1 On Page E4-13, the ER describes the site of the canceled Unit 2 and Unit 3 projects.

There is a 3-year project to sell equipment followed by a 3-year salvage period to sell materials (scrap metal). Please describe any plans for land going forward, including whether it would be restored under a native vegetation plan or remain cleared and paved.

LV-2 Please describe the land use/land cover of the Unit 2 and Unit 3 land areas prior to commencement of those projects. What was the area temporarily and permanently disturbed from construction and operations?

13

LV-3 Page E4-13 of the ER discusses planned onsite construction activities that would result in a change to the appearance of the site including warehouse renovation, expansion of combined maintenance shop, additions of permanent buildings at the new security training facility, removal of the head assembly building, disassembly of heavy lifting devices at the Unit 2 and Unit 3 site (which was scheduled to be completed by April 2023). Please provide aerial/overhead photo map of construction locations before and after construction. Where on the site will these construction activities will take place?

Will all of these construction activities take place on already cleared, developed, industrial land or will sections of previously non-developed land (such as forest, or field) be cleared for these construction projects. What acreage will be temporarily and permanently disturbed in construction and operations? Please provide heights of newly constructed buildings.

LV-4 How will the planned construction described above affect visual resources. Will these new construction facilities be visible from public roadway, private residences, or other publicly accessible areas?

LV-5 Page E3-8 of the ER describes the tallest onsite structure as the reactor containment building at 166 feet. Please describe the lighting regime for this building. Please also describe light visible at night.

Meteorology and Climatology (Nancy Martinez, NRC)

Audit Needs

MET-1Section E2.2.4 of the ER states that there is one meteorological tower at VCSNS, and parameters measured include temperature, wind speed, wind direction and precipitation. The ER provides wind speed, wind direction, and temperature measured at VCSNS for 1992-2021. However, precipitation measurements at VCSNS were not provided. If precipitation measurements (including monthly average temperature, highest daily maximum, lowest daily minimum) are available for 1992-2021, please provide. If precipitation measurements from the VCSNS meteorological tower are not available for this period, please discuss why.

Noise (Nancy Martinez, NRC)

Audit Needs

NOI-1Please identify the primary off-site noise sources in the vicinity of VCSNS.

NOI-2Section E3.4 of the ER identifies that sound level measurements are recorded near employee workstations or in common work areas. Have any noise surveys been conducted offsite but in the vicinity of VCSNS? If so, please provide a copy.

NOI-3Section E3.4 of the ER states that the nearest resident is located approximately within 1.04 miles east-southeast of the plant. Identify the reference point this distance was measured from.

14

NOI-4Section E3.4 of the ER states that VCSNS has not received noise complaints between 2018 and 2022. Were any noise complaints received in 2023?

Replacement Energy Alternatives (Jeff Rikhoff, NRC; Dave Goodman, PNNL)

Audit Needs

ALT-1Section E.7.2.1 of the ER describes the composition of the two combination alternatives considered as reasonable. The natural gas combined cycle (NGCC) combination alternative includes solar panels with associated battery backup at both the abandoned Units 2 and 3 site as well as offsite. The small modular reactor (SMR) combination alternative includes solar panels with associated battery backup at the abandoned Units 2 and 3 site but no additional solar panels offsite. Why would no offsite solar be included in the SMR combination alternative?

ALT-2Section E.7.2.1 of the ER introduces the energy alternatives considered as reasonable.

What amount of battery storage would be considered for both combination alternatives?

ALT-3Section E7.2.3.3 of the ER states that under Combination Alternative 1, offsite solar installations would be constructed in South Carolina. Could such alternatives be installed elsewhere in the Dominion service area?

ALT-4Per Section E.7.2.1 of the ER, were offsite locations considered for the NGCC and SMR portions of the alternatives considered as reasonable?

Severe Accident Mitigation Alternatives (Elijah Dickson, NRC; Jerry Dozier, NRC; Steve Short, PNNL; Bill Ivans, PNNL)

Audit Needs

SAMA-1Section E4.15.2.2.1 of the ER states that [t]he VCSNS internal events PRA

[probabilistic risk assessment] model used to determine the significance of new information in the license renewal analysis has a CDF [core damage frequency] of approximately 2.72E-06/year. Later sections of the ER (e.g., Sections E4.15.3.2.1 and E4.15.3.2.2) reference the current VCSNS PRA as being inclusive of internal events plus flooding, fire, and seismic PRA models. However, it is unclear whether the 2.72E-06/year estimate accounts for internal flooding events. Please confirm that the CDF for internal events of 2.72E-06/year includes the contribution from internal flooding events and provide the relative contribution of these events to the total internal events CDF.

SAMA-2Section E4.15.2.2.1 of the ER states that there is approximately a factor of 1.8 decrease in newer internal and external event information from those calculated in the previous LRA [license renewal application]. Please clarify the basis for the factor of 1.8 decrease stated in Section E.4.15.2.2.1 of the ER.

15

SAMA-3The Stage 1 assessment described in Section E4.15.3.2.2 indicates that a total of 330 industry severe accident mitigation alternatives (SAMAs) and 18 VCSNS-specific SAMAS were collected for evaluation in the SLR, and all but 62 of these SAMAs (57 industry SAMAs and 5 VCSNS-specific SAMAs) were qualitatively screened. Provide information (e.g., SAMA description, source of the SAMA, basis for screening of each SAMA) that informs the approach used in the Stage 1 assessment to qualitatively screen each identified SAMA from further consideration. Include a description of the criteria used to support qualitative screening.

SAMA-4The Stage 1 assessment within Nuclear Energy Institute (NEI) 17-04 includes consideration of any unimplemented Final Plant-Specific SAMAs, whose status was determined through a costbenefit analysis comparing plantspecific averted costrisk to projected implementation cost. Section E4.15.3.2.1 of the ER states that [o]f the potential SAMAs identified in the initial license renewal; a detailed cost-benefit analysis was performed on the 12 SAMAs that could not be otherwise screened.

However, Section E4.15.3.2.2 of the ER states that 18 VCSNS-specific SAMAs were collected for evaluation in the SLR as part of the Stage 1 assessment.

Furthermore, Section G.3.1 of NUREG-1437, Supplement 15, identified 32 candidate SAMAs for further evaluation in Phase 2 of which 20 were screened because, based on plant-specific PRA insights, they did not provide a significant safety benefit, or because the cost of implementation would be greater than the benefits associated with implementing the SAMA. Moreover, Section G.4.0 of NUREG-1437, Supplement 15, clarifies that the risk-reduction potential of several additional SAMAs proposed by the NRC staff were also evaluated. It is also noted that SAMA Cost-Benefit Screening Analysis summarized in Table G-3 of NUREG-1437, Supplement 15, identifies 18 Phase 2 SAMAs, 5 of which were not originally part of the Phase 2 SAMA process.

Please clarify the process used to identify any unimplemented Final Plant-Specific SAMAs for consideration within the Stage 1 assessment for SLR.

SAMA-5NEI 17-04 states that an alternate quantification process is required for any SAMAs that reduce the consequences of accidents without reducing the CDF or release category frequencies. Based on Section E4.15.3 and Table E4.15-1 of the ER, the quantitative screening of SAMAs within the Stage 1 assessment for SLR appears to have only considered the impact of SAMA implementation on the CDF and/or the Level 2 release category frequencies. Please clarify whether an alternate quantification process, as discussed in Section 3.2.2 of NEI 17-04, was applied within the Stage 1 assessment for SLR, and if not, discuss the basis for not doing so.

SAMA-6Section E4.15.3.2.2 of the ER describes that the 62 SAMAs that were not qualitatively screened were grouped into 19 SAMA cases for quantitative screening. Describe the process and criteria used for grouping SAMAs, discussing how each resulting group bounds the potential benefits of associated individual SAMAs.

SAMA-7Section E4.15.3.2.1 of the ER states that [t]he current VCSNS PRA models (internal events plus flooding, fire, and seismic PRA models) were used to determine the level of significance of new information. However, Section E4.15.3.2.1 of the ER indicates that only [the] current VCSNS PRA models (internal events plus flooding) were used in the quantitative evaluation of MB [Maximum Benefit] to determine the level of significance of new information and that [e]xternal hazard frequencies are calculated by applying a multiplier of 2 to the internal events benefits. In addition, [b]ase values in table E4.15-1 of the ER (e.g., 2.75E-06) suggest that only internal events were 16

considered for all but one SAMA evaluation case (EFWP). Moreover, it is not clear if the percentage reductions in table E4.15-1, for SAMA evaluation cases other than EFWP, already reflect the multiplier of 2.

Please describe how each risk contributor (e.g., internal events, internal flooding, fire, seismic) was addressed in the evaluation of risk reduction performed as part of the Stage 1 assessment. If one or more risk contributors were not explicitly considered, clarify the treatment applied and discuss the basis for doing so.

SAMA-8Section E4.15.3.2 of the ER indicates that in one SAMA evaluation case (EFWP), a refined quantification was performed because the initial assessment, using a conservative estimate for external events, showed that the SAMA would reduce the MB by 50 percent or more. This refined quantification assumed that the additional EFW [emergency feedwater] pump [postulated by the SAMA] would have similar seismic capabilities and dependencies as the other EFW pumps and would be expected to be considered correlated to the existing pumps. Please describe the refined quantification and how it differs from the initial assessment. Also, discuss the basis for assuming seismic correlation of the additional EFW pump with the existing pumps and the impact of this assumption on the evaluation of risk reduction.

SAMA-9As discussed in Section 3.2.1 of NEI 17-04, the Stage 1 assessment involves "demonstrating that SAMA implementation would not reduce the CDF or any of the Level 2 release category frequencies by 50 percent or more. Furthermore, NEI 17-04 clarifies that as an alternative to calculating the percent reduction in each Level 2 release category frequency subgroup, it would be sufficient to group release category results into high level categories and that [a]nother alternative, if a technical basis is provided that demonstrates the overall risk reduction for the plant can be adequately quantified using a subset of Level 2 release categories, would be to perform the demonstration for that subset of the Level 2 release categories. Section E4.15.3.2.2 of the ER indicates that Intact, small early release frequency (SERF),

large early release frequency (LERF), and Late release categories were evaluated; however, in table E4.15-1, only values for total Level 2 results, i.e., Total L2 (Intact, LEF, LRF), are presented. Please clarify the approach for evaluating Level 2 release category frequencies and provide a technical basis that demonstrates that the overall risk reduction for the plant is adequately quantified using the selected Level 2 release categories consistent with NEI 17-04. In addition, for all SAMAs evaluated for risk reduction as part of the Phase 1 assessment, provide the impact on CDF and each of the Level 2 release category frequencies considered.

SAMA-10The base value presented in table E4.15-1 of the ER for all but one of the SAMA evaluation cases is 2.75E-05/year, and for the one SAMA evaluation case (EFWP) that involves a refined quantification owing to external events considerations, a base value of 9.38E-05/year appears. These base values exceed the internal events CDF of 2.72E-06/year and the estimated all-hazards CDF of 8.86E-05/year (2.72E-06/year for internal events + 5.07E-06/year for fire + 3.52E-05/year for seismic) obtained from Section E4.15.2.2 of the ER. Please clarify this difference and confirm that all aspects of the ER make use of the latest risk models that are available for internal events (including internal flooding) and for each of the external events contributors, as discussed in Section 3.1 of NEI 17-04.

SAMA-11The total Level 2 result provided in table E4.15-1 of the ER for one SAMA evaluation case (IND_SGTR) is negative (i.e., -1.32 percent). Please discuss and explain this result.

17

Document Needs

SAMA-12In the ER, VCSNS indicated that it is following the guidance in NEI 17-04, Model SLR New and Significant Assessment Approach for SAMA, Revision 1, for providing SAMA new and significant information. NEI 17-04 specifies that [f]urther documentation of the new and significant information review is listed in Section 3.5.2.

Furthermore, NEI 17-04 indicates that [s]uch documentation should be available to the NRC either in the SLR ER (at the SLR applicant's discretion), or in supplemental information for review via E-document reading room, audit, and RAIs [requests for additional information]. Please provide the SAMA basis.

Socioeconomics (Caroline Hsu, NRC; Dave Anderson, PNNL; Lin Zeng, PNNL)

Audit Needs

SOC-1 Please provide any update of tax revenue payments for 2022 and 2023. Additionally, please explain the difference between the first and the third columns in the table E3.9-2 of the ER: total nuclear taxes paid by Dominion Energy and the VCSNS property tax.

Its not clear whether the VCSNS property tax (column 3) is part of the total nuclear taxes paid by DE (column 1). Please clarify. Also, does the entire amount in column one all goes to Fairfield County and if not, which other jurisdictions receive revenue payments?

SOC-2As stated in the ER, DE provides annual funding for South Carolina Emergency Management Division. This was $387,555 in FY 2022. Please provide DE funding to SC Emergency Management Division for 2018-2021 and 2023 if available.

Surface Water Resources (Lloyd Desotell, NRC; Rajiv Prasad, PNNL; Kazi Tamaddun, PNNL)

Audit Needs

SW-1Provide a knowledgeable person to discuss the following notices of violations and/or exceedances and any related corrective actions. Additionally, please provide any correspondence between the State and Dominion Energy related to these issues.

a) April 6, 2022, NOV AI-0005261 and its resolution.

b) March 2022 total suspended solids limit exceedance.

SW-2Have any NPDES permit violations or exceedances occurred after March 2022? If yes, discuss dates, locations, parameters, and amounts/concentrations/frequencies.

SW-3Has tritium been detected in plant discharges since January 1, 2022? If yes, discuss dates, locations, and measured concentrations.

SW-4Please update ER table E3.6-1 with Parr Shoals Reservoir water levels data since December 2021.

SW-5Please update ER tables E3.6-4a and E3.6-4b for water withdrawals since December 2021.

18

SW-6ER figures E3.6-4 and E3.6-5 are missing one of the axes - please provide updated figures and include more recent data since 2021. Additionally, please clarify what the averages in this figure represent, e.g. monthly average.

SW-7Mean sea level and NGVD29 datums are both used in the ER. Please provide the correlation between these two datums.

SW-8Section 4.5.9.4 of the ER states: During normal plant operation, evaporation from Monticello Reservoir has been estimated to be 33 cfs, with an additional 22 cfs from condenser water. Please provide a reference or basis for this statement.

SW-9Section 4.5.9.4 of the ER states: Annually, evaporative losses from Monticello Reservoir are offset by precipitation. Please provide a reference or basis for this statement.

Document Needs

SW-10Please provide a copy of surface water withdrawal permit 20PN001.

SW-11Please provide a copy the Stormwater Pollution Prevention Plan.

SW-12Please provide a copy of the Spill Prevention Control and Countermeasure Plan.

SW-13Please provide a copy of hazardous substance spill contingency plan.

SW-14Section E3.6.1.2.6 of the ER states that a thermal mixing zone evaluation was conducted in 2012 as part of the NPDES wastewater permit renewal application (SC0030856) to support a decision of maintaining the current temperature limits for VCSNS. The ER also states that VCSNS submitted an addendum in February 2014 and November 2018. Please provide a copy of the 2014 thermal mixing zone evaluation and the 2014 and 2018 addenda.

SW-15Please provide a copy of General Industrial Stormwater Permit No. SCR005713.

SW-16Please provide a copy of Safe Drinking Water Act Permit 27383.

SW-17Please provide the annual stormwater management reports for the last 5 years of referenced in ER Section E4.5.1.4.

SW-18Please provide the annual discharge monitoring reports referenced in ER Section E3.6.1.2.5 for the last 5 years.

SW-19Please provide the annual monitoring reports referenced in ER Section E4.6.14.4 for the last 5 years.

19

Terrestrial Resources (Caroline Hsu, NRC; Dana Vesty, PNNL; Tracy Fuentes, PNNL; Ann Miracle, PNNL)

Audit Needs

TER-1ER Section 2.2.4 states that V.C. Summer has one meteorological (MET) tower that is self-supporting and is 62m tall. Please state whether the MET tower is lit or unlit. If lit, please state lighting colors and whether lights are steady or blinking.

TER-2ER Section 4.6.5.4 states that there was a total of 16 bird mortalities on site from 2018-2022. Please provide all incidents of bird mortality and injuries from 2013-2023. For bird mortality and injuries, please summarize in chronological order, incidents by date, species, counts, cause, and infrastructure if relevant (e.g., cooling towers, buildings, transmission or distribution lines, meteorological towers, screens, etc.). If there are individual reports for each incident, please provide these as well.

TER-3ER Section 2.2.5.3 states that Dominion Energy incorporates guidelines from industry standards to create more avian-safe distribution poles and lines, that visibility is incorporated to reduce collision risk, that nesting is deterred on towers, and that Dominion is installing plastic coils on power lines to reduce wildlife entanglement.

Please provide industry standards and guidelines relating to avian safe distribution poles and lines, visibility, deterring nesting, if they are not already incorporated in Dominion Energys Avian Protection Plan (TER-9). Please state whether or not plastic coils are installed or will be installed on in-scope transmission lines. If so, state which lines and how many, and provide photos of these plastic coils. Please provide any information on wildlife entanglements that have occurred onsite. If any wildlife entanglements have occurred, please summarize in chronological order, incidents by date, species, counts, and cause.

TER-4ER Sections 3.7.8.4 and 4.6.5.4 state that Dominion Energy has a Migratory Bird Special Use Permit (SPUT) with an expiration date of March 31, 2024, and a Migratory Bird Permit from South Carolina Department of Natural Resources (SCDNR) with an expiration date of December 31, 2023. These permits cover handling of nest, eagles, and other migratory birds. Under terms of these permits, DE submits annual reports of activities conducted under the SPUT to U.S. Fish and Wildlife Service (FWS). Please provide copies of most recent permits (current or expired) migratory bird permits from FWS and SCDNR. If expired, please state whether or not these permits are in the process of being renewed. Please provide the last 5 years of FWS SPUT reports.

TER-5ER Section 3.7.8.2.2 states that there was one known eagle nest on the V.C. Summer property and that a fledgling bald eagle was found on the ground in April 2021. Please provide the following information: a) Where is the eagle nest onsite and is it currently active? b) Please provide any incident reports regarding the 2021 eagle fledgling on the ground, if not already covered in TER-2. c) Please provide any site-specific standards and practices to protect the eagle nest if not already covered under TER-9 or TER-10.

TER-6ER Section 3.7.8.4 states that there was one osprey nest observed on the MET Tower in 2021. Please provide the following information: a) Is the osprey nest still present on the MET tower, and if so, is it currently active? b) Please provide any incident reports regarding osprey nest, if not already covered in TER-2. c) Please provide any site-specific standards and practices to protect the nest if not already covered under TER-9 or TER-10.

20

TER-7ER Section 3.7.2.5 states that Dominion Energy conducted a waterfowl survey in 2015-2017. Please provide the waterfowl survey reports from 2015, 2016 and 2017. Can Dominion Energy confirm that there are no other recent terrestrial surveys (within 10 years) for birds, bats, other wildlife, plants, wetlands, or other species or terrestrial habitats? If other terrestrial studies exist, please provide them.

TER-8ER Section 4.6.6 states the water level in Monticello Reservoir can vary as much as 4.5 feet and water levels in the Parr Reservoir can vary as much as 10 feet. The range of impacts for surface water conflicts with terrestrial resources requires a site-specific analysis of surface water use conflicts on terrestrial riparian resources for the term of the SLR, including onsite wetland habitats and affected water bodies. Please provide the range of impacts on terrestrial resources.

TER-9ER Section 3.7.2.3 states that forested areas within the VCSNS site were managed by SCANA Service Forestry Operations group and timber was harvested in the past to remove diseased and damaged trees. Can Dominion Energy confirm if diseased and/or damaged trees currently are removed from the site and replanted with trees characteristic of the area? Can Dominion Energy confirm if the forest is actively managed at the site and if so, what are the methods of management?

Document Needs

TER-10Sections 2.2.5.3, 3.7.2.6, and 4.6.5.4 state that Dominion Energy has a corporate Avian Protection Plan (APP). Please provide Dominions APP for NRCs review.

TER-11Sections 3.7.6, 3.7.8, and 9.6 of the ER state that V.C. Summer relies on administrative controls and other regulatory programs to ensure habitats and wildlife are protected.

Please provide a copy of relevant administrative control documents and BMPs relating to species and habitat protection, including storm water management, spill prevention, vegetation management, and pesticide applications (herbicide, insecticide, rodenticide, fungicide).

Waste Management (Rad and Non-Rad) (Leah Parks, NRC)

Audit Needs

WM-1As part of the effluent control systems, plan to discuss the provisions made to sample and analyze fluids before discharge as discussed in E2.2.6.1 Liquid Waste Systems.

For example, plan to discuss the decision process for pumping waste to the Fairfield Pumped Storage Facility penstocks versus discharging waste through the discharge canal. Section E2.2.6.1 states that liquid fluids are either released under controlled conditions via the penstocks of the Fairfield Pumped Storage Facility or retained for further processing with eventual release to the circulating discharge canal or the Fairfield Pumped Storage Facility penstocks, which is located approximately one-half of a mile from the northwest corner of the plant. In addition, plan to discuss how the plant processes radioactive effluents to maintain radiation doses to the public to levels that are ALARA. Are there any proposed changes or upgrades to the program being considered during the license renewal term?

21

WM-2ER Section E2.2.6.5 notes that VCSNS is a generator of mixed waste and if generated, low-level mixed waste is stored in RCA RMB 436. Are any other wastes besides mixed waste stored in this location? What are the plans and procedures associated with long-term storage of mixed waste?

WM-3ER Section E2.2.6.5 discusses low-level radioactive waste. What are the plans to store or ship low-level waste (e.g., are there minimum quantity shipment plans or procedures for decision making)? In addition, plan to discuss how the plant plans to handle low-level radioactive waste (Class A, B, and C, and mixed waste) during the license renewal term (onsite storage, potential expansion of storage facilities, and disposal options). Are there any proposed changes or upgrades to the program being considered during the license renewal term? Is the site currently storing any greater-than-Class C waste?

WM-4 ER Section E2.2.7 discusses nonradioactive waste. VCSNS is classified by the Environmental Protection Agency and the South Carolina Department of Health and Environmental Control as a Large Quantity Generator of hazardous waste. Table E2.2-2 shows that in 2018, the site generated 770,217 pounds of hazardous waste in comparison to 47,157 pounds in 2107 and 9,497 pounds in 2019. Please plan to discuss the general sources of hazardous waste generated, the fluctuations in the amount of hazardous waste generated over the 5-year period from 2016-2021, and the storage locations for nonradioactive hazardous wastes. Are there any proposed changes or upgrades to the program being considered during the license renewal term?

WM-5VCSNS is subject to the reporting provisions of 40 CFR Part 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. In section E9.5.3.6 of the ER, the applicant discusses reportable spills and states that for the period of 2017-2021, there were two reportable releases at VCSNS that have triggered this notification requirement. If there have been any reportable releases which would trigger this notification requirement since the ER was written, please provide a description of the releases.

WM-6If there have been any reportable inadvertent releases or spills of nonradioactive contaminants which would trigger a notification requirement since the ER was written, please provide a description of spills/releases. Please be prepared to discuss your plan to handle inadvertent nonradioactive releases.

Document Needs

WM-7Provide procedures related to the radioactive and nonradioactive waste management programs, waste minimization program, and Stormwater Pollution Prevention Plan, including the Chemical Control Procedure.

WM-8Drawings and photos that are highlighted/marked showing the flow paths for releases for both radiological and non-radiological waste paths. Please have subject matter experts available to discuss the flow paths.

V.C. Summer Subsequent License Renewal Environmental Audit Schedule (Tentative)

Tuesday, May 14, 2024 START END ACTIVITY 9:00 am ET 9:30 am ET Entrance meeting between U.S. Nuclear Regulatory Commission (NRC), Dominion Energy, and contractors 9:30 am ET 4:00 pm ET Virtual tours/virtual meetings between NRC, Dominion Energy, and contractor subject matter experts (SMEs)

Wednesday, May 15, 2024 START END ACTIVITY 9:00 am ET 4:00 pm ET Virtual meetings between NRC, Dominion Energy, and contractor SMEs

Thursday, May 16, 2024 START END ACTIVITY 9:00 am ET 4:00 pm ET Virtual meetings between NRC, Dominion Energy, and contractor SMEs

Friday, May 17, 2024 START END ACTIVITY 9:00 am ET 2:00 pm ET Virtual meetings between NRC, Dominion Energy, and contractor SMEs

Tuesday, May 21, 2024 START END ACTIVITY 8:00 am ET 4:00 pm ET NRC site visit

Wednesday, May 29, 2024 START END ACTIVITY 10:00 am ET 10:30 am ET Exit meeting between NRC, Dominion Energy, and contractors

Enclosure 3