ML25042A553
| ML25042A553 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/11/2025 |
| From: | James Holloway Dominion Energy South Carolina |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 25-010 | |
| Download: ML25042A553 (1) | |
Text
Dominion Energy South Carolina. Inc.
5000 Dominion Boulevard. Glen Allen, VA 23060 Domin,onEnergy.com February 11, 2025 United States Nuclear Regulatory Commission Attention: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 DOMINION ENERGY SOUTH CAROLINA. INC.
VIRGIL C. SUMMER NUCLEAR STATION UNIT 1 Dominion Energy' Serial No.:
NRA/NDM:
Docket Nos.:
License Nos.:
10 CFR 50 10 CFR 51 10 CFR54 25-010 RO 50-395 NPF-12 COMMENTS ON DRAFT GENERIC ENVIRONMENTAL IMPACT STATEMENT FOR LICENSE RENEWAL OF NUCLEAR PLANTS REGARDING SUBSEQUENT LICENSE RENEWAL FOR FACILITY OPERATING LICENSE NPF-12 By letter dated August 17, 2023 [Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML23233A179], Dominion Energy South Carolina, Inc. (Dominion, Dominion Energy South Carolina, or DESC) submitted an application for the subsequent license renewal of Renewed Facility Operating License No. NPF-12 for Virgil C. Summer Nuclear Station (VCSNS) Unit 1.
In a Federal Register Notice dated December 6, 2024 (ADAMS Accession No. ML24323A058), the NRC issued for public comment, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Subsequent License Renewal of Virgil C. Summer Nuclear Station, Unit 1, Draft Report for Comment, 11 and indicated that public comments would be accepted.
The enclosure of this letter provides Dominion's written comments related to the VCSNS Draft Supplemental Environmental Impact Statement (DSEIS).
If there are any questions regarding this submittal or if additional information is needed, please contact Mr. Keith Miller at (804} 273-2569.
Sincerely, rP~
James E. Holloway Vice President - Nuclear Engineering and Fleet Support
Commitments made in this letter: None.
Serial No.: 25-010 Docket No.: 50-395 Page 2 of 6
Enclosure:
Dominion Comments on VCSNS Draft Supplemental Environmental Impact Statement.
cc:
U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Virgil C. Summer Nuclear Station Ms. Lauren Gibson NRC Branch Chief U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 11 E11 11555 Rockville Pike Rockville, Maryland 20852-2738 Ms. Kim Conway NRC Project Manager U. S. Nuclear Regulatory Commission Two White Flint North Mail Stop A 1 OM 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Ted Smith NRC Branch Chief U. S. Nuclear Regulatory Commission Two White Flint North Mail Stop B 72M 11555 Rockville Pike Rockville, Maryland 20852-2738 Ms. Marieliz Johnson NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 7 E1 11555 Rockville Pike Rockville, Maryland 20852-2738 Serial No.: 25-010 Docket No.: 50-395 Page 3 of 6
Mr. G. Edward Miller NRG Senior Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop O-9E3 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Gregory Lindamood Santee Cooper - Nuclear Coordinator Virgil C. Summer Nuclear Station P. 0. Box 88 Jenkinsville, SC 29065 Stephen R. Pelcher Santee Cooper - Deputy General Counsel One Riverwood Drive Moncks Corner, SC 29461 Elizabeth Johnson Director, Historical Services, D-SHPO South Carolina Department of Archives and History 8301 Parklane Road Columbia, SC 29233 Johnathan Leader State Archaeologist South Carolina Institute of Archaeology and Anthropology 1321 Pendleton St, 1st Floor, Suite 16 Columbia, SC 29208 Fran Marshall Director, Office of Environmental and Public Health Serial No.: 25-010 Docket No.: 50-395 Page4 of6 South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Myra Reese Director, Office of Environmental Affairs South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201
Chuck Hightower Water Quality Division Serial No.: 25-010 Docket No.: 50-395 Page 5 of 6 South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Lorianne Riggin Director of Environmental Programs South Carolina Department of Natural Resources 1000 Assembly Street Columbia, SC 29201-3117 Duane Parrish Director, South Carolina Parks, Recreation, and Tourism 1205 Pendleton St. Ste 248 Columbia, SC 29201 Florence Belser Chair, Public Service Commission of South Carolina 101 Executive Center Drive #100 Columbia, SC 29210 Christy Hall Secretary of Transportation South Carolina Department of Transportation 955 Park Street Columbia, SC 29201 Kim Stenson Director, South Carolina Emergency Management Division 2779 Fish Hatchery Rd West Columbia, SC 29172 Rhonda Thompson Chief, Bureau of Air Quality South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Renee Shealy Chief, Bureau of Environmental Health Services South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201
Henry Porter Chief, Bureau of Land and Waste Management Serial No.: 25-010 Docket No.: 50-395 Page 6 of 6 South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Jennifer Hughes Chief, Bureau of Water South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Chris Stout Chief, Office of Ocean & Coastal Resource Management South Carolina Department of Health and Environmental Control 1362 McMillan Avenue North Charleston, SC 29405
Enclosure Serial No.: 25-010 Docket No.: 50-395 DOMINION COMMENTS ON VCSNS DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT Dominion Energy South Carolina, Inc.
(Dominion Energy South Carolina, or DESC)
Virgil C. Summer Nuclear Station Unit 1
No.
Section Page Line
- 1.
3.5.1.3 3-32 40-43
- 2.
3.8.1.2.2 3-94 18
- 3.
3.8.5.1 3-103 1-2
- 4.
3.6.9 3-67 31-35 Comments on Draft VCSNS SEIS Comment Serial No.: 25-010 Docket No.: 50-395 Enclosure, Page 1 of 3 The draft SEIS Section 3.5.1.3 states: "The current N PDES permit for the OWS ( currently Permit No.
SCG646000, formerly Permit No. 41 SCG646072 Version 3.2) authorizes effluent limitations for discharges to the Monticello Reservoir at Outfalls 01A, 01 B, 01 C, 02A, 02B, 02C, 03A, 03B, 03C, 04A, 04B, 04C, 05A, 05B, DSC, 06A, 06B, 07A, 08A, 088, and 09A (Dominion 2023-TN10387)."
As described in the VCSNS SLR Environmental Report (ER) Section 3.6.1.2.1 and listed in Table 3.6-2, the NPDES permit for the Offsite Water Treatment Facility (OWS) is a general permit. The VCSNS OWS uses a reverse osmosis water treatment plant. Due to this, 5 of the 21 outfalls listed in the general permit apply to the OWS: 01A, 05A, 06A, 07A, and 09A.
Recommend updating the outfall list in the SEIS for consistency with the ER.
In the draft SEIS Section 3.8.1.2.2, recommend that the monarch butterfly's listing status be updated from 'candidate' to 'potential threatened' based on the December 12, 2024, U.S. Fish and Wildlife Service press release.
(see:
In the draft SEIS Section 3.8.5.1, recommend that the monarch butterfly's listing status be updated from
'candidate' to 'potential threatened' based on the December 12, 2024, U.S. Fish and Wildlife Service press release. (see: https://www.federalregister.gov/documents/2024/12/12/2024-28855/endangered-and-threatened-wildlife-and-plants-threatened-soecies-status-with-section-4d-rule-for)
The draft SEIS states "... the new natural gas facility in this alternative would have less generation capacity (700 MWe vs. 1,110 MWe) and require less land (<19.4 ac [7.85 ha] vs. <48 ac [19.42 ha])
than the natural gas only alternative, the NRC assumes that the impacts of this portion of the alternative would be less than that of the natural gas only alternative." No reference is provided for these values; however, the Subsequent License Renewal (SLR) ER does state that required land for a 1,110 MW Natural Gas-Fired Combined Cycle (NGCC) plant would be approximately 48 acres.
It is unclear how the acreage value used for the 700 MWe plant was determined - if acreage required for a 1,110 MWe plant is proportional to that of the 700 MWe plant, it should be 30 acres, not 19.4. If NRC believes 19.4 is the more appropriate acreage value, it is recommended that a reference be provided.
Comments on Draft VCSNS SEIS No.
Section Page Line Comment Serial No.: 25-010 Docket No.: 50-395 Enclosure, Page 2 of 3
- 5.
3.2.5.2 3-10 Table 3-5 The third row ofTable 3-5 in the draft SEIS for the Natural Gas and Solar Combination Alternative states "NGCC: 48 ac at the abandoned V.C. Summer Units 2 and 3 project site."
This is not consistent with the statement in Section 3.6.9 (see comment #4 above) which indicates the combination alternative would require reduced acreage (<48 ac). The 48 ac value is applicable to a 1,110 MWe plant, not a 700 MWe plant as proposed in this combination alternative.
- 6.
3.7.7 3-89 33-37 The draft SEIS states "The SMR power plant would be built at the abandoned V.C. Summer Units 2 and 3 project site so they could use existing V. C. Summer infrastructure. The NRC staff concludes that these effects would be SMALL to MODERATE, depending on the extent to which construction would degrade, modify, or permanently alter nearby aquatic habitats."
However, in Section 3.5.6.1, the conclusion was reached that the impact to surface water resources would be SMALL for the NGCC alternative, which would also require modification to the intake/discharge structure. The same determination was reached for the Natural Gas and Solar Combination Alternative, and the New Nuclear and Solar Combination Alternative.
Further, Section 3. 7.9, New Nuclear and Solar Combination Alternative, concludes"... that the impacts of construction and operation of the Small Modular Reactor (SMR) portion of the combination alternative on aquatic resources would be SMALL."
It is therefore unclear as to why the SMR alternative elicits a SMALL to MODERATE determination rather than SMALL for this section. Could additional information be provided as to why the impact is different when the other alternatives have a findinq of SMALL?
- 7.
3.3.3 3-13 28-31 The draft SEIS Section 3.3.3 states: "In a nonresidential area, maximum sound levels should not exceed 70 dBA between the hours of 6 a.m. and 10:00 p.m. or 65 dBA between the hours of 10:00 p.m. and 6:00 a.m." The ER Section E3.4 states: "The Fairfield County noise ordinance identifies specific sound levels for non-residential areas of 75 A-weighted decibels (dBA) as a daytime level and 70 dBA as a niQhttime level... " Recommend revisinQ the draft SEIS Section 3.3.3 for consistency with the ER.
No.
Section Page line
- 8.
3.17.3 3-175 24
- 9.
3.13.1.1 3-149 25 Comments on Draft VCSNS SEIS Comment Serial No.: 25-010 Docket No.: 50-395 Enclosure, Page 3 of 3 The draft SEIS states "The implementation of any of the replacement power alternatives considered in this SEIS would entail the irreversible and irretrievable commitments of energy, water, chemicals, and-in some cases-fossil fuels."
The previous paragraph, last sentence, states "Irreversible and irretrievable commitments of resources for electrical power generation include the commitment of land, water, energy...
II For consistency, recommend adding "land" to the sentence beginning on Line 24 regarding implementation of replacement power alternatives.
The draft SEIS Section 3.13.1.1 states "Waste released from the three units is... " Since VCSNS is a sinQle operatinQ unit station, recommend correctinQ the statement.