ML25134A007
| ML25134A007 | |
| Person / Time | |
|---|---|
| Site: | North Anna, 99902135  |
| Issue date: | 05/23/2025 |
| From: | Dominion Energy, Virginia Electric & Power Co (VEPCO) |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25134A005 | List: |
| References | |
| Download: ML25134A007 (1) | |
Text
White Paper North Anna Early Site Permit Renewal Application Draft
White Paper North Anna Early Site Permit Application Dominion Energy 1
May 2025 Table of Contents Acronyms................................................................................................................................... 3 1.0 Executive Summary - White Paper ESP Renewal............................................................ 5 2.0 Key Regulatory Policy Considerations - White Paper ESP Renewal................................ 6 2.1 Introduction.................................................................................................................. 6 2.2 CFR Part 2, Subpart A, Procedure for Issuance, Amendment, Transfer, or Renewal of a License, and Standard Design Approval............................................................................ 6 2.2.1 10 CFR 2.109(c) - Effect of Timely Renewal Application:.................................... 6 2.3 10 CFR 50.47, Emergency Plans................................................................................. 6 2.3.1 10 CFR 50.47(a)(1)(iii)........................................................................................ 6 2.4 10 CFR Part 51, Environmental Protection................................................................... 7 2.4.1 10 CFR 51.20(b), Criteria Requiring Environmental Impact Statements.............. 7 2.4.2 10 CFR 51.30(a), Environmental Assessment..................................................... 7 2.4.3 10 CFR 51.50(b), Environmental Report............................................................. 8 2.4.4 10 CFR 51.91, Environmental Impact Statement................................................. 8 2.5 10 CFR 52 Subpart A, Early Site Permits..................................................................... 9 2.5.1 10 CFR 52.12, Scope of Subpart......................................................................... 9 2.5.2 10 CFR 52.13, Relationship to Other Subparts.................................................... 9 2.5.3 10 CFR 52.17, Content of Application; General Information................................ 9 2.5.4 10 CFR 52.26(a), Duration of Permit..................................................................10 2.5.5 10 CFR 52.26(b), Duration of Permit..................................................................10 2.5.6 10 CFR 52.31(a), Criteria for Renewal...............................................................11 2.5.7 10 CFR 52.33 Duration of Renewal....................................................................11 2.6 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants...................................................................................................................................12 2.6.1 10 CFR 54.4, Scope...........................................................................................12 2.6.2 10 CFR 54.19 Contents of Application - General Information............................12 2.6.3 10 CFR 54.21, Contents of Application - Technical Information.........................12 2.6.4 10 CFR 54.23, Contents of Application - Environmental Information..................13 2.6.5 10 CFR 54.29, Standards for Issuance of a Renewed License...........................13 2.6.6 10 CFR 54.31, Issuance of a Renewed License.................................................14 2.7 NUREG-1555 Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Environmental Standard Review Plan.......................................................................15 2.7.1 Guidance............................................................................................................15 2.7.2 Dominion Summary............................................................................................15 Draft
White Paper North Anna Early Site Permit Application Dominion Energy 2
May 2025 2.8 NUREG-1800 Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants...........................................................................................................15 2.8.1 Guidance............................................................................................................15 2.8.2 Dominion Summary............................................................................................15 2.9 NRC Regulatory Guide 1.188......................................................................................16 2.9.1 Guidance............................................................................................................16 2.9.2 Dominion Summary............................................................................................16 2.10 NRC Regulatory Guide 1.208.................................................................................16 2.10.1 Guidance.......................................................................................................16 2.10.2 Dominion Summary.......................................................................................17 2.11 Regulatory Issue Summary RIS 01-016, Update of Evacuation Time Estimates.....17 2.11.1 Guidance.......................................................................................................17 2.11.2 Dominion Summary.......................................................................................17 3.0 First of a Kind Regulatory Approach - White Paper ESP Renewal..................................18 3.1 Introduction.................................................................................................................18 3.2 Existing ESP-003 Conditions, Commitments, Assumptions, and Unresolved Issues...18 3.3 Summary of the Impact from NAPS Unit 3 Combined License NFP-103 (2017) and NUREG-1835 Supplement 1 on an ESP-003 Renewal.........................................................18 3.4 Use of the NAPS Units 1 and 2 Site-Specific Environmental Reports and Documents for the ESP-003 Renewal Application...................................................................................19 3.4.1 Annual Radioactive Effluent Release Reports (ARERRs)...................................19 3.4.2 Annual Radiological Environmental Operating Report (AREORs)......................19 3.4.3 Final Site-Specific EIS for Licensing Renewal Regarding Subsequent License Renewal for NAPS Units 1 and 2.....................................................................................19 3.5 Summary of the Impact from the NAPS Units 1 and 2 Emergency Plan on an ESP-003 Renewal...............................................................................................................................19 3.6 Use of Existing NAPS Information from other Regulatory Submittals for Inclusion/Exclusion into the ESP Renewal Application.........................................................19 3.7 Summary of 10 CFR Part 51 Methodologies Applied to the ESP-003 Renewal Application............................................................................................................................20 3.8 Summary of 10 CFR Part 54 Methodologies Applied to the ESP-003 Renewal Application............................................................................................................................20 3.9 Summary of NUREG-1800, NUREG-1801 Methodologies Applied to the ESP-003 Renewal Application.............................................................................................................20 4.0 ESP Permit Renewal Application Format and Content Approach.....................................21 4.1 Introduction.................................................................................................................21 4.2 Application Format......................................................................................................21.............................................................................................................................22 Draft
White Paper North Anna Early Site Permit Application Dominion Energy 3
May 2025 Acronyms ABWR Advanced BWR ACS American Community Survey AEA Atomic Energy Act AREOR Annual Radiological Environmental Operating Report ARERR Annual Radiological Effluent Release Report ASME American Society of Mechanical Engineers BTP Branch Technical Paper CFR Code of Federal Regulations COL combined license COLA combined license application CPA construction permit application CWA Clean Water Act DBA Design Basis Accident DC Design Certification DCD design control document DWR Department of Wildlife Resources EA Environmental Assessment EAB exclusion area boundary EIS Environmental Impact Statement EJ environmental justice EP emergency plan EPRI Electric Power Research Institute EPZ emergency planning zone ER environmental report ESBWR economic simplified boiling water reactor ESP early site permit FEIS final environmental impact statement FONSI finding of no significant impact FSAR final safety analysis report GEIS Generic Impact Environmental Statement GMRS Ground Motion Response Spectrum gpm gallons per minute GT-MHR Gas Turbine Modular Helium Reactor IFIM Instream Flow Incremental Methodology IRIS International Reactor Innovative and Secure ITAAC inspections, tests, analyses, and acceptance criteria LPZ low population zone LWR light-water-cooled reactor NAPS North Anna Power Station NEI Nuclear Energy Institute NMS national marine sanctuaries NOAA National Oceanic and Atmospheric Administration Draft
White Paper North Anna Early Site Permit Application Dominion Energy 4
May 2025 NQA National Quality Assurance NRC U.S. Nuclear Regulatory Commission ODCM Onsite Dose Calculation Manual OL Operating License PBMR Pebble Bed Modular Reactor PPE plant parameter envelope PSHA Probabilistic Seismic Hazards Analysis PWR Pressurized Water Reactor QA Quality Assurance RCTS resonant column torsional shear REMP Radiological Environmental Monitoring Program RG Regulatory Guide RFI request for Information RIS Regulatory Issue Summary ROW right-of-way SAR Safety Analysis Report SEIS Site Environmental Impact Statement SER Safety Evaluation Report SLR subsequent license renewal SLRA subsequent license renewal application SMR small modular reactor SRP standard review plan SRP-LR standard review plan for license renewal SSAR Site Safety Analysis Report SSC structures, systems, and components SSE Safe Shutdown Earthquake SSER Site Safety Evaluation Report SWPPP storm water pollution prevention plan TEDE total effective dose equivalent TR Topical Report UFSAR updated final safety analysis report USACE U.S. Army Corps of Engineers USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey VDCR Virginia Department of Conservation and Recreation VDEQ Virginia Department of Environmental Quality VDGIF Virginia Department of Game and Inland Fisheries VPDES Virginia Pollutant Discharge Elimination System VWP Virginia Water Protection Draft
White Paper North Anna Early Site Permit Application Dominion Energy 5
May 2025 1.0 EXECUTIVE
SUMMARY
- WHITE PAPER ESP RENEWAL All nuclear power reactors are required to comply with the applicable standards and requirements of the Atomic Energy Act (AEA) of 1954 (NUREG-0980) as amended and Commission regulations as set forth in Title 10 of the Code of Federal Regulations (10 CFR).
Virginia Electric and Power Company, doing business as Dominion Virginia Power (now Dominion Energy Virginia), herein referred to as Dominion or "the licensee, currently holds a combined license (COL) for North Anna Power Station (NAPS) Unit 3 at the NAPS site. The COL incorporated by reference 10 CFR Part 52, Appendix E, "Design Certification Rule for the ESBWR Design," and incorporated by reference 10 CFR Part 52, Subpart A, Early Site Permit (ESP) No. ESP-003. ESP-003 will expire on November 27, 2027. Dominion intends to submit a renewal application to extend the duration of ESP-003 for an additional 20 years.
The purpose of this white paper is to present the NRC with the Dominion position on the level of effort expected for ESP Renewal. Dominion believes that the level of effort should be similar to that required in an Environmental Report (ER) for Subsequent License Renewal Application (SLRA) and that the review should only require an Environmental Assessment (EA) and not an Environmental Impact Statement (EIS) for the North Anna Site ESP Renewal. This paper will address 10 CFR 52.26(a), Duration of Permit, requirements as well as provide a detailed feasibility study to develop an acceptable regulatory structure and address the licensing options available under the AEA for Dominions intended path forward to renew the ESP-003 permit under 10 CFR Part 52.31. This paper establishes a comprehensive outline plan to be used by Dominion to facilitate the efficient, cost-effective permit renewal of ESP-003, while minimizing NRC resources. The Dominion ESP is unique to other ESPs at this time because of its association with an issued COLA, recent EIS for an SLRA, and is collocated with operating nuclear plants, and as such should require less detail and use of resources for its ESP renewal application.
Section 2 of this paper examines the key regulatory policy issues and defines Dominions position with respect to the renewal of an ESP. Section 3 describes in detail the first-of-a-kind licensing approach Dominion intends to take, and Section 4 will provide the proposed formatting for the renewal application itself.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 6
May 2025 2.0 KEY REGULATORY POLICY CONSIDERATIONS - WHITE PAPER ESP RENEWAL 2.1 Introduction This section provides an overview of the alignment of the existing Title 10 regulatory framework relative to renewing an ESP. This evaluation will be of particular importance in making the permit renewal licensing process more efficient and effective and will provide the NRC with a better understanding of Dominions intended path forward. Only sections of regulations determined relevant and applicable to the Dominion permit renewal are cited herein.
Dominion has performed a regulatory gap analysis to clearly identify a position with respect to each regulation as part of the white paper.
2.2 CFR Part 2, Subpart A, Procedure for Issuance, Amendment, Transfer, or Renewal of a License, and Standard Design Approval 2.2.1 10 CFR 2.109(c) - Effect of Timely Renewal Application:
2.2.1.1 Regulation:
If the holder of an early site permit licensed under subpart A of part 52 of this chapter files a sufficient application for renewal under § 52.29 of this chapter at least 12 months before the expiration of the existing early site permit, the existing permit will not be deemed to have expired until the application has been finally determined.
2.2.1.2 Dominion Summary Dominion will submit the ESP renewal application in time to meet the requirements of this section.
2.3 10 CFR 50.47, Emergency Plans 2.3.1 10 CFR 50.47(a)(1)(iii) 2.3.1.1 Regulation:
If an application for an early site permit under subpart A of part 52 of this chapter includes complete and integrated emergency plans under 10 CFR 52.17(b)(2)(ii), no early site permit will be issued unless a finding is made by the NRC that the emergency plans provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
2.3.1.2 Dominion Summary Dominion intends to submit the major features of the Emergency Plan (EP) as identified in 10 CFR 52.17(b)(2)(i) as a part of the Site Safety Analysis Report (SSAR) in the ESP renewal Draft
White Paper North Anna Early Site Permit Application Dominion Energy 7
May 2025 application. Dominion does not intend to submit complete and integrated EPs as indicated in 10 CFR 52.17(b)(2)(ii) as a part of the ESP renewal application. Details of the planned updates to the ESP renewal application are included in Part 5A of Attachment 1 to this report.
2.4 10 CFR Part 51, Environmental Protection 2.4.1 10 CFR 51.20(b), Criteria Requiring Environmental Impact Statements 2.4.1.1 Regulation (b) The following types of actions require an environmental impact statement or a supplement to an environmental impact statement:
(1) Issuance of a limited work authorization or a permit to construct a nuclear power reactor, testing facility, or fuel reprocessing plant under part 50 of this chapter, or issuance of an early site permit under part 52 of this chapter.
2.4.1.2 Dominion Summary The regulations do not explicitly identify the required type of environmental review to be performed by the NRC for the ESP renewal application. Considering the recent environmental licensing work on the same nuclear site property documented in NUREG 1437, Supplement 7a, Second Renewal, Dominions position is that an EA is acceptable for this effort. Site characterization requirements are expected to be reduced because the ESP is for a site within the owner-controlled area of an existing operating nuclear plant and the site has recently been characterized in the NAPS Units 1 and 2 application for renewed operating license.
Considering the above, Dominions position is that preparation of an EA for the ESP renewal application would provide an adequate technical review of the environmental impacts of ESP renewal and desired improvement in licensing process efficiency.
2.4.2 10 CFR 51.30(a), Environmental Assessment 2.4.2.1 Regulation (a) An environmental assessment for proposed actions, other than those for a standard design certification under 10 CFR part 52 or a manufacturing license under part 52, shall identify the proposed action and include:
(1) A brief discussion of:
(i) The need for the proposed action; (ii) Alternatives as required by section 102(2)(E) of NEPA; (iii) The environmental impacts of the proposed action and alternatives as appropriate; and (2) A list of agencies and persons consulted, and identification of sources used.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 8
May 2025 2.4.2.2 Dominion Summary The regulations do not explicitly identify the required type of environmental review to be performed by the NRC for the ESP renewal application. If the NRC concludes that an EA will be prepared for ESP renewal, Dominion intends to support the review of the EA.
2.4.3 10 CFR 51.50(b), Environmental Report 2.4.3.1 Regulation (b) Early site permit stage. Each applicant for an early site permit shall submit with its application a separate document, entitled "Applicant's Environmental ReportEarly Site Permit Stage," which shall contain the information specified in §§ 51.45, 51.51, and 51.52.
2.4.3.2 Dominion Summary Dominion intends to prepare an ER as a part of the ESP renewal application. The ER will contain the information specified in 10 CFR 51.45, 51.51, and 51.52. Because the Duration of Renewal in 10 CFR 52.33 was changed to be consistent with the NRCs regulations concerning renewal of nuclear power plant operating licenses (OLs) as specified in 10 CFR 54.31 [72 FR 49377, Aug. 28, 2007], Dominion intends to supplement the information in the ER in a manner and level of detail similar to that identified for the operating license renewal stage in 10 CFR 51.53(c). Additional details about the expected information in the ER for the ESP renewal application is included in Part 3 of Attachment 1 to this report.
2.4.4 10 CFR 51.91, Environmental Impact Statement 2.4.4.1 Regulation (a)(1) The final environmental impact statement will include responses to any comments on the draft environmental impact statement or on any supplement to the draft environmental impact statement.
(b) The final environmental impact statement will discuss any relevant responsible opposing view not adequately discussed in the draft environmental impact statement or in any supplement to the draft environmental impact statement and respond to the issues raised.
(c) The final environmental impact statement will state how the alternatives considered in it and decisions based on it will or will not achieve the requirements of sections 101 and 102(1) of NEPA and of any other relevant and applicable environmental laws and policies.
(d) The final environmental impact statement will include a final analysis and a final recommendation on the action to be taken.
2.4.4.2 Dominion Summary If the NRC concludes that an EIS will be prepared for ESP renewal, Dominion intends to support the review of the EIS.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 9
May 2025 2.5 10 CFR 52 Subpart A, Early Site Permits 2.5.1 10 CFR 52.12, Scope of Subpart 2.5.1.1 Regulation This subpart sets out the requirements and procedures applicable to Commission issuance of an early site permit for approval of a site for one or more nuclear power facilities separate from the filing of an application for a construction permit or combined license for the facility.
2.5.1.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.12 for the ESP renewal application.
2.5.2 10 CFR 52.13, Relationship to Other Subparts 2.5.2.1 Regulation This subpart applies when any person who may apply for a construction permit under 10 CFR part 50, or for a combined license under this part seeks an early site permit from the Commission separately from an application for a construction permit or a combined license.
2.5.2.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.13 for the ESP renewal application.
2.5.3 10 CFR 52.17, Content of Application; General Information 2.5.3.1 Regulations (a) For applications submitted before September 27, 2007, the rule provisions in effect at the date of docketing apply unless otherwise requested by the applicant in writing. The application must contain:
(1)
A site safety analysis report (xi) For applications submitted after September 27, 2007, a description of the quality assurance program applied to site-related activities for the future design, fabrication, construction, and testing of the structures, systems, and components of a facility or facilities that may be constructed on the site. Appendix B to 10 CFR part 50 sets forth the requirements for quality assurance programs for nuclear power plants. The description of the quality assurance program for a nuclear power plant site shall include a discussion of how the applicable requirements of appendix B to part 50 of this chapter will be satisfied.
(2)
A complete environmental report as required by 10 CFR 51.50 (b)
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 10 May 2025 (3)
Emergency Plans (b)(2)(i) Propose major features of the emergency plans, in accordance with either the requirements in § 50.160 of this chapter, or the requirements in appendix E to part 50 of this chapter and § 50.47(b) of this chapter, as applicable, such as the exact size and configuration of the emergency planning zones, for review and approval by the NRC, in consultation with the Federal Emergency Management Agency (FEMA), as applicable, in the absence of complete and integrated emergency plans.
(b)(2)(ii) Propose complete and integrated emergency plans for review and approval by the NRC, in consultation with FEMA, as applicable in accordance with either the requirements in § 50.160 of this chapter, or the requirements in appendix E to part 50 of this chapter and § 50.47(b) of this chapter. To the extent approval of emergency plans is sought, the application must contain the information required by § 50.33(g) and (j) of this chapter.
2.5.3.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.17 for the ESP renewal application. Additional details about the expected information in the ESP renewal application are included in Attachment 1 to this report.
2.5.4 10 CFR 52.26(a), Duration of Permit 2.5.4.1 Regulation (a) Except as provided in paragraph (b) of this section, an early site permit issued under this subpart may be valid for not less than 10, nor more than 20 years from the date of issuance.
2.5.4.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.33 (Duration of Renewal) for the ESP renewal application, which differs from the requirements of 10 CFR 52.26(a). Dominion intends to request that the renewed ESP be valid for 20 years plus any remaining years on the ESP then in effect before renewal, as allowed by 10 CFR 52.33.
2.5.5 10 CFR 52.26(b), Duration of Permit 2.5.5.1 Regulation (b) An early site permit continues to be valid beyond the date of expiration in any proceeding on a construction permit application or a combined license application that references the early site permit and is docketed before the date of expiration of the early site permit, or, if a timely application for renewal of the early site permit has been docketed, before the Commission has determined whether to renew the permit.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 11 May 2025 2.5.5.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.26(b) for the ESP renewal application. Details of the expected use of existing information from recent regulatory submittals and NRC response documents associated with NAPS are provided in Section 3 of this report.
2.5.6 10 CFR 52.31(a), Criteria for Renewal 2.5.6.1 Regulation a) The Commission shall grant the renewal only if it determines that:
(1) The site complies with the Act, the Commissions regulations, and orders applicable and in effect at the time the site permit was originally issued; and (2) Any new requirements the Commission may wish to impose are:
(i) Necessary for adequate protection to public health and safety or common defense and security; (ii) Necessary for compliance with the Commissions regulations, and orders applicable and in effect at the time the site permit was originally issued; or (iii) A substantial increase in overall protection of the public health and safety or the common defense and security to be derived from the new requirements, and the direct and indirect costs of implementation of those requirements are justified in view of this increased protection.
2.5.6.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.31(a) for the ESP renewal application.
2.5.7 10 CFR 52.33 Duration of Renewal 2.5.7.1 Regulation Each renewal of an ESP may be for not less than 10, nor more than 20 years, plus any remaining years on the ESP then in effect before renewal.
2.5.7.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 52.33 for the ESP renewal application. Dominion intends to request that the renewed ESP be valid for 20 years plus any remaining years on the ESP then in effect before renewal.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 12 May 2025 2.6 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants 2.6.1 10 CFR 54.4, Scope 2.6.1.1 Regulation (a) Plant systems, structures, and components within the scope of this part are (1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events.
(2) All non-safety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in paragraph (a)(1) of this section.
(3) All systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61), anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63).
2.6.1.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 54.4 as applicable for the ESP renewal application, but notes that there are no systems, structures, and components (SSCs) applicable to the ESP renewal application.
2.6.2 10 CFR 54.19 Contents of Application - General Information 2.6.2.1 Regulation (a) Each application must provide the information specified in 10 CFR 50.33(a) through (e), (h),
and (i). Alternatively, the application may incorporate by reference other documents that provide the information required by this section.
(b) Each application must include conforming changes to the standard indemnity agreement, 10 CFR 140.92, Appendix B, to account for the expiration term of the proposed renewed license.
2.6.2.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 54.19.
2.6.3 10 CFR 54.21, Contents of Application - Technical Information 2.6.3.1 Regulation Each application must contain the following information:
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 13 May 2025 (a) An integrated plant assessment (IPA).
(b) CLB changes during NRC review of the application. Each year following submittal of the license renewal application and at least 3 months before scheduled completion of the NRC review, an amendment to the renewal application must be submitted that identifies any change to the CLB of the facility that materially affects the contents of the license renewal application, including the FSAR supplement.
(c) An evaluation of time-limited aging analyses.
(d) An FSAR supplement. The FSAR supplement for the facility must contain a summary description of the programs and activities for managing the effects of aging and the evaluation of time-limited aging analyses for the period of extended operation determined by paragraphs (a) and (c) of this section, respectively.
2.6.3.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 54.21.
2.6.4 10 CFR 54.23, Contents of Application - Environmental Information 2.6.4.1 Regulation Each application must include a supplement to the environmental report that complies with the requirements of Subpart A of 10 CFR Part 51.
2.6.4.2 Dominion Summary Dominion intends to prepare an ER as a part of the ESP renewal application. The ER will contain the information specified in 10 CFR 51.45, 51.51, and 51.52. Because the Duration of Renewal in 10 CFR 52.33 was changed to be consistent with the NRCs regulations concerning renewal of nuclear power plant OLs as specified in 10 CFR 54.31 [72 FR 49377, Aug. 28, 2007],
Dominion intends to supplement the information in the ER in a manner and level of detail similar to that identified in Subpart A of 10 CFR 51 as specified for the operating license renewal stage in 10 CFR 51.53(c). Additional details about the expected information in the ER for the ESP renewal application are included in Part 3 of Attachment 1 to this report.
2.6.5 10 CFR 54.29, Standards for Issuance of a Renewed License 2.6.5.1 Regulation:
A renewed license may be issued by the Commission up to the full term authorized by § 54.31 if the Commission finds that:
(a) Actions have been identified and have been or will be taken with respect to the matters identified in Paragraphs (a)(1) and (a)(2) of this section, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in Draft
White Paper North Anna Early Site Permit Application Dominion Energy 14 May 2025 accordance with the CLB, and that any changes made to the plant's CLB in order to comply with this paragraph are in accord with the Act and the Commission's regulations.
b) Any applicable requirements of Subpart A of 10 CFR Part 51 have been satisfied.
(c) Any matters raised under § 2.335 have been addressed.
2.6.5.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 54.29 as applicable for the ESP renewal application. Dominion intends to request that the renewed ESP be valid for 20 years plus any remaining years on the ESP then in effect before renewal, as allowed by 10 CFR 52.33.
2.6.6 10 CFR 54.31, Issuance of a Renewed License 2.6.6.1 Regulation:
(a) A renewed license will be of the class for which the operating license or combined license currently in effect was issued.
(b) A renewed license will be issued for a fixed period of time, which is the sum of the additional amount of time beyond the expiration of the operating license or combined license (not to exceed 20 years) that is requested in a renewal application plus the remaining number of years on the operating license or combined license currently in effect. The term of any renewed license may not exceed 40 years.
(c) A renewed license will become effective immediately upon its issuance, thereby superseding the operating license or combined license previously in effect. If a renewed license is subsequently set aside upon further administrative or judicial appeal, the operating license or combined license previously in effect will be reinstated unless its term has expired, and the renewal application was not filed in a timely manner.
(d) A renewed license may be subsequently renewed in accordance with all applicable requirements.
2.6.6.2 Dominion Summary Dominion intends to comply with the requirements of 10 CFR 54.31 for the ESP renewal application. Dominion intends to request that the renewed ESP be valid for 20 years plus any remaining years on the ESP then in effect before renewal, as allowed by 10 CFR 52.33.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 15 May 2025 2.7 NUREG-1555 Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Environmental Standard Review Plan 2.7.1 Guidance This document provides guidance to the Nuclear Regulatory Commission (NRC) staff in implementing provisions of 10 CFR 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, related to nuclear power plants. It supersedes Environmental Standard Review Plan NUREG-1555, Vol. 1 & 2 issued in 2000. The document reflects new regulatory requirements and guidance that have appeared since 2000 and also the NRCs experience with applications for early site permits. Supplement 1 to this document should be used by the staff for review of environmental reports related to applications for renewal of nuclear power plant operating licenses.
2.7.2 Dominion Summary Dominion intends to comply with the guidance of the latest version of NUREG-1555 and NUREG-1437 as applicable for the ESP renewal application.
2.8 NUREG-1800 Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants 2.8.1 Guidance The Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) provides guidance to U.S. Nuclear Regulatory Commission (NRC) staff reviewers in the Office of Nuclear Reactor Regulation. These reviewers perform safety reviews of applications to renew nuclear power plant licenses in accordance with Title 10 CFR Part 54.
The principal purposes of the SRP-LR are to ensure the quality and uniformity of staff reviews and to present a well-defined base from which to evaluate applicant programs and activities for the period of extended operation. The SRP-LR also is intended to make regulatory information widely available to enhance communication with interested members of the public and the nuclear power industry and to improve public and industry understanding of the staff review process. The safety review is based primarily on the information provided by the applicant in a license renewal application. Each of the individual SRP-LR sections addresses (a) who performs the review, (b) the matters that are reviewed, (c) the basis for review, (d) the way the review is accomplished, and (e) the conclusions that are drawn.
2.8.2 Dominion Summary Dominion intends to comply with the guidance of the latest version of NUREG-1800 as applicable for the ESP renewal application.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 16 May 2025 2.9 NRC Regulatory Guide 1.188 2.9.1 Guidance This regulatory guide (RG) describes an approach that is acceptable to the staff of the U.S.
Nuclear Regulatory Commission (NRC) for the format and content of an application to renew or subsequently renew an NRC-issued operating license under Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. This RG endorses Revision 6 of Nuclear Energy Institute (NEI) 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54The License Renewal Rule, and NEI 17-01, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal.
2.9.2 Dominion Summary Dominion intends to comply with the guidance of the latest version of NRC Regulatory Guide 1.188 as applicable for the ESP renewal application.
2.10 NRC Regulatory Guide 1.208 2.10.1 Guidance Investigations of the site and region around the site are necessary to identify capable tectonic sources and to determine their potential for generating earthquakes and causing surface deformation. If it is determined that surface deformation need not be taken into account at the site, sufficient data to clearly justify this determination should be presented in the application for an early site permit or license. Generally, any tectonic deformation at the earths surface within the Site Area [8 km (5 mi) of the site] will require detailed examination to determine its significance. Potentially active tectonic deformation within the seismogenic zone beneath a site will have to be assessed using geological, geophysical, and seismological methods to determine its significance. Engineering solutions are generally available to mitigate the potential vibratory effects of earthquakes through design. However, engineering solutions cannot always be demonstrated to be adequate for mitigation of the effects of permanent ground displacement phenomena such as surface faulting or folding, subsidence, or ground collapse. For this reason, it is prudent to select an alternative site when the potential exists for permanent ground displacement at the proposed site (Ref. C.4).
The level of detail for investigations should be governed by knowledge of the current and late Quaternary tectonic regime and the geological complexity of the site and region. The investigations for determining seismic sources should be carried out in all the following levels, with areas described by radii of 320 km (200 mi), 40 km (25 mi), and 8 km (5 mi) and 1 km (0.6 mi) from the site. The investigations should provide increasingly detailed information as they proceed from the regional level down to the site. Whenever faults or other structures are encountered at a site in either outcrop or excavations, it is necessary to perform many of the investigations described below to determine whether or not they are capable tectonic sources.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 17 May 2025 2.10.2 Dominion Summary Dominion intends to comply with the guidance of the latest version of RG 1.208 as applicable for the ESP renewal application. It is expected that much of the information required to comply with this guidance is present in multiple recent applications and their corresponding NRC safety and environmental evaluations (e.g., the NAPS Unit 3 COL NFP-103, SLRA, SLR ER, and Site Environmental Impact Statement [SEIS]), which addressed the recent seismic event experienced at the site.
2.11 Regulatory Issue Summary RIS 01-016, Update of Evacuation Time Estimates 2.11.1 Guidance The U.S. Nuclear Regulatory Commission (NRC) is issuing this Regulatory Issue Summary (RIS) to alert addressees to the possible need to update emergency planning evacuation time estimates as the results of the year 2000 census are published. This RIS does not transmit any new requirements or staff positions. No specific action or written response is required.
2.11.2 Dominion Summary Dominion intends to consider the latest census information (2020) when determining if changes are necessary for the ESP renewal application.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 18 May 2025 3.0 FIRST OF A KIND REGULATORY APPROACH - WHITE PAPER ESP RENEWAL 3.1 Introduction The regulatory guidance regarding renewal of an ESP is not precise. The requirements contained in 10 CFR 52.29 and 10 CFR 52.31 only specify that: (1) all the information that was in the original permit be updated and conforms with the Commissions regulations, and (2) that the ESP complies with orders applicable and in effect at the time the site permit was originally issued and any new orders or regulations as deemed necessary by the Commission.
Dominion intends to take a conservative path forward and renew ESP-003 with the intent to keep the renewed version available for possible reference in a different future combined license application (COLA) or Construction Permit Application (CPA) at the NAPS site.
3.2 Existing ESP-003 Conditions, Commitments, Assumptions, and Unresolved Issues Dominion intends to review all of the conditions incorporated by amendments through ESP-003 Amendment 3. Dominion will evaluate the ESP-003 assumptions to determine if they are still valid and review the unresolved issues to determine if they require modifications as part of the submission of the ESP renewal. Conditions that are no longer applicable, or if in Dominions opinion require modifications or deletion, may be addressed under 10 CFR 50.90.
3.3 Summary of the Impact from NAPS Unit 3 Combined License NFP-103 (2017) and NUREG-1835 Supplement 1 on an ESP-003 Renewal The NAPS Unit 3 COL references specific technologies and methods of compliance with NRC regulations and conformance to NRC RGs and industry codes based on the ESBWR design.
The COL contains specific additional departures, variances, exemptions, and proposed license conditions (NFP-103 Part 7 and Part 10, respectively). In NUREG-1835, Supplement 1, the staff based their acceptance and made specific conclusions with respect to the COL based on the COLs and ESP-003 content. Where Dominion intends to use NRC-approved information from the COL for the ESP renewal application, Dominion will perform a gap analysis to determine which, if any, technology-based compliances and conformances are required to be removed or modified from the ESP renewal application. Dominion will review and evaluate NUREG-1835, Supplement 1, to determine the information that was relied upon by the NRC for the safety evaluation, as well as proposed license conditions based on the specific technologies described in the COL. License conditions that are no longer applicable or, if in Dominions opinion, require modifications or deletion, may be addressed under 10 CFR 50.90.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 19 May 2025 3.4 Use of the NAPS Units 1 and 2 Site-Specific Environmental Reports and Documents for the ESP-003 Renewal Application Dominion will review the contents of the NAPS Unit 1 and Unit 2 site-specific Environmental Report and its associated SEIS and incorporate by reference relevant information into the ESP permit renewal application.
3.4.1 Annual Radioactive Effluent Release Reports (ARERRs)
The latest available ARERRs will be reviewed, and any applicable information will be incorporated into the ESP renewal application.
3.4.2 Annual Radiological Environmental Operating Report (AREORs)
The latest available AREORs will be reviewed, and any applicable information will be incorporated into the ESP renewal application.
3.4.3 Final Site-Specific EIS for Licensing Renewal Regarding Subsequent License Renewal for NAPS Units 1 and 2 Dominion will follow the requirements denoted in 10 CFR Part 51 to develop a site-specific ER for the ESP-003 renewal application. After an evaluation, Dominion may incorporate by reference data that was previously submitted to the NRC in recent regulatory submittals and their associated safety evaluations and environmental impact statements.
3.5 Summary of the Impact from the NAPS Units 1 and 2 Emergency Plan on an ESP-003 Renewal Since the North Anna ESP-003 applies to the site where currently operating NAPS Units 1 and 2 are co-located, Dominion will review the emergency planning documents to determine the extent that the Unit 1 and 2 EP should be referenced or depended upon in lieu of preparing a stand-alone EP submittal for the ESP renewal application. Dominion will ensure that the basis documents of the existing EP have been reviewed against current NRC requirements and industry guidance.
3.6 Use of Existing NAPS Information from other Regulatory Submittals for Inclusion/Exclusion into the ESP Renewal Application Dominion will review recent regulatory submittals and their associated safety evaluations and environmental impact statements to determine if any information from these sources should be included or referenced in the ESP renewal application. This review will consider the appropriateness of the information for inclusion into the ESP renewal application. Specifically, Dominion will determine if any information being considered for reference or inclusion from other submittals could be incorporated by reference and/or meet the new and significant threshold.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 20 May 2025 3.7 Summary of 10 CFR Part 51 Methodologies Applied to the ESP-003 Renewal Application Activities associated with 10 CFR Part 51 will be included in the proposed ESP-003 renewal application. Dominion will follow the requirements denoted in the regulation to develop a site-specific ER for the proposed ESP-003 renewal application. Dominion may incorporate by reference data that was previously submitted to the NRC in recent regulatory submittals and their associated safety evaluations and environmental impact statements.
3.8 Summary of 10 CFR Part 54 Methodologies Applied to the ESP-003 Renewal Application Dominions proposed ESP-003 renewal application does not fall under the jurisdiction of 10 CFR Part 54. This regulation only governs the issuance of renewed OLs and renewed COLs pursuant to Sections 103 or 104b of the AEA of 1954. The renewal of an ESP permit is governed by 10 CFR 52, Subpart A.
3.9 Summary of NUREG-1800, NUREG-1801 Methodologies Applied to the ESP-003 Renewal Application Dominion will utilize Nuclear Energy Institute (NEI) 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, as guidance.
The development of the format and content of the ESP renewal application will be described in Section 4.0.
Draft
White Paper North Anna Early Site Permit Application Dominion Energy 21 May 2025 4.0 ESP PERMIT RENEWAL APPLICATION FORMAT AND CONTENT APPROACH 4.1 Introduction Dominion is seeking to renew ESP-003. As detailed in ESP-003, Dominion has selected a site but has not yet finalized a choice of technology and has not yet committed to the COLA process. Dominion is evaluating long-term generation and intends to reserve the NAPS site for possible future development. Because the North Anna ESP-003 was reviewed and approved by the NRC, Dominion believes that the timeframe for the ESP permit renewal preparation and NRC review should be much shorter than for a new ESP. The value of renewing the ESP permit is tied to the early resolution of siting issues than can then be utilized in future licensing applications.
4.2 Application Format For the purposes of the proposed North Anna ESP-003 permit renewal application, Dominion will follow a modified version that incorporates the guidance in NEI 95-10, Revision 3, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule Section 6.2, and includes the guidance in NEI 08-03, Revision 0, Lessons Learned from Initial Early Site Permit Experience. The following will be the format and content of the ESP renewal application:
Table of Contents Part 1: Administrative Section Part 2: Site Safety Analysis Part 3: Environmental Report Part 4: Programs and Plans Part 5A: Emergency Plan (Site Boundary EPZ)
Part 6: Exemptions and Departures Appendices:
Appendix A - Summary of Proposed License Conditions, Assumptions and Unresolved Issues Appendix B - Summary of ESP-003 Gap Analyses and Evaluations Appendix C - Acronyms/Abbreviations/Initialisms Appendix D - References Appendix E - List of Figures Appendix F - Lists of Tables Draft
White Paper North Anna Early Site Permit Application Dominion Energy 22 May 2025 ATTACHMENT 1 Draft
North Anna Early Site Permit Application Annotated Outline Part 1: Administrative Information Page 1 of 77 May 2025 PART 1: ADMINISTRATIVE INFORMATION 1.0 CHAPTER 1 This section DOES require an update to address changes in the ownership description and perhaps changes in site location and layout as shown in Figure 1.0-1 of the ESPA.
1.1 Purpose of an Early Site Permit Renewal Application Section 1.1 establishes the basis for the ESPA per the requirements of 10 CFR Part 52. No changes to the intended purpose were identified during this review.
This section DOES NOT require an update because this section meets the applicable guidance in NUREG-0800.
1.2 Early Site Permit Renewal Application Format and Content 1.2.1 Format and Content This section DOES require revision.
Part 1 references RIS 2001-05 instead of 10 CFR 50.33(a)-(d).
Part 2 references RS-002 instead of 10 CFR 52.17(a)1 on general corporate information.
It also references draft RS-002 instead of NUREG-800 on section numbering for the SSAR.
A list of the regulatory bases for the SSAR and a brief description of individual chapters in the SSAR should be included.
Part 3, a discussion of ER, its regulatory bases, and a brief description of individual chapters in the ER should be included. This section DOES NOT require an update, but the addition of the information noted above is recommended.
1.2.2 Labeling Conventions This section DOES NOT require an update because this section provides generally accepted industry conventions for labeling headers and footers, pagination, section numbering, and references.
1.2.3 Industry Coordination This section DOES NOT require an update because this section provides historical perspective on the development of the ESPA but is not required by regulatory statute or industry guidance.
Draft
North Anna Early Site Permit Application Annotated Outline Part 1: Administrative Information Page 2 of 77 May 2025 1.3 Information Required by 10 CFR 50.33(a) through (d)
Section 1.3, and the corresponding Table 1.3-1, DOES require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 3 of 77 May 2025 PART 2: SITE SAFETY ANALYSIS REPORT CHAPTER 1
1.0 INTRODUCTION
AND GENERAL DESCRIPTION 1.1 Introduction This section provides introductory material contained in Chapter 1 of the SSAR. This is a general chapter for an ESP. The general information provided enables the reader to obtain a basic understanding of the overall facility without having to refer to the subsequent chapters.
Review of the remainder of the application can be accomplished with a better perspective and recognition of the relative safety-significance of each individual item in the overall plant description. However, since March 2012, ODEC no longer co-owns the ESP site and SSAR Chapter 11 needs to be added to the content description.
This section DOES require an update.
1.2 General Site Description 1.2.1 Site Location The location of the site is presented in several figures. These figures depict the location of the site relative to the existing North Anna plants as well as the overall ESPA site. Plan view figures in sufficient number and detail provide a reasonable understanding of the general layout of the plant.
This section DOES NOT require an update because this general description of the site location and layout is consistent with the intent of this section.
1.2.2 Site Development This section identifies the structures located on the developed NAPS site that support the operation of the two Westinghouse reactors located there. Plan view figures are provided that depict the layout of structures on the developed site as well as the undeveloped ESPA site.
This section DOES NOT require an update because this site-specific description of the existing plants and associated structures is consistent with the intent of this section.
1.3 Plant Parameters Envelope Part 2, Chapter 1, Section 1.3, Comparison with Other Facilities, is not applicable to an ESPA using the plant parameter envelope (PPE) approach. However, where practicable, the SSAR section numbers should correspond to those identified in NUREG-0800, Standard Review Plan Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 4 of 77 May 2025 for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition (SRP), to afford consistency between the combined license (COL) and the ESPA.
Therefore, the North Anna ESPA SHALL be updated to include a section titled Comparison with Other Facilities.
Part 2, Chapter 1, Section 1.3, Plant Parameter Envelope, of the North Anna ESPA provides guidance for the development of a PPE in support of the North Anna ESPA. This guidance provides a logical, consistent, and workable framework for developing a PPE that supports finality on siting issues prior to selecting a specific reactor technology.
This section DOES NOT require an update because the guidance provided here is consistent with the requirements of 10 CFR 52.17.
1.3.1 Plant Parameters Envelope Approach The PPE was developed based on data from selected reactor designs of two types, light-water-cooled reactors (LWRs) and helium-cooled reactors. To ensure that the resulting PPE has the flexibility to bound multiple reactor designs, these designs were selected to provide a broad cross section of available reactors. The resulting Generic PPE table, Part 2, Chapter 1, Table 1.3-1, of the North Anna ESPA lists both the single-and two-unit values for each parameter.
The bounding parameters are the single largest (or smallest) value for each category, using engineering, safety, and environmental conservatism to select the appropriate value. Additional supporting information to support this table is included in Table 1.3-3 through Table 1.3-8.
This section DOES NOT require an update because this section describes the PPE development methodology utilized for the North Anna ESPA consistent with that accepted by the NRC.
1.3.2 Overview of Reactor Types Used for PPE Development Seven reactor designs have been used to develop the PPE bounding values.
ACR-700, LWR, developed by Atomic Energy Canada Limited Advanced Boiling Water Reactor, developed by General Electric (ABWR)
AP1000, Pressurized Water Reactor, developed by Westinghouse Electric Company (PWR)
Economic Simplified Boiling Water Reactor, developed by General Electric (ESBWR)
Gas Turbine Modular Helium Reactor (GT-MHR), developed by General Atomics International Reactor Innovative and Secure (IRIS) next generation PWR, developed by a consortium led by Westinghouse Electric Company Pebble Bed Modular Reactor (PBMR), developed by PBMR (Pty) Limited Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 5 of 77 May 2025 These reactor types are specific to the North Anna ESPA and are utilized to develop a North Anna-specific PPE. In the future other reactor types may be evaluated and assessed relative to the PPE bounding values.
However, until this occurs, the North Anna ESPA DOES NOT require an update because the seven reactor designs used to develop the PPE are intended to establish bounding values for the ESP site consistent with NRC-accepted PPE development methodology.
1.3.3 Use of the Generic PPE Tables The Generic PPE tables presented in Part 2, Tables 1.3-1 through 1.3-8 of the North Anna ESPA, are based on information supplied by the reactor vendors for the plant designs listed above in Section 1.3.2. Site-dependent PPE data is based on a typical site (not a specific site and not the ESP site) and chosen to bound approximately 85 percent of all existing sites. In some cases, where designs are not mature, the data supplied is based on engineering judgement, prior experience, or a calculation based on non-site-specific assumptions. The data is reasonable and bounds most applications.
This section DOES NOT require an update because the generic tables presented here are consistent with NRC accepted PPE development methodology.
1.4 Identification of Agents and Contractors The primary agents or contractors associated with the preparation of the ESPA are identified. In addition, principal consultants and outside service organizations are also identified. The division of responsibility between contractors and consultants is clearly defined. However, Part 2, Chapter 1, Section 1.4, does not clearly identify the applicant for the North Anna ESPA.
This section DOES require an update to state the applicant for the North Anna ESPA.
1.4.1 Bechtel Power Corporation Part 2, Chapter 1, Section 1.4.1 of the North Anna ESPA does not identify Dominion as the applicant for the North Anna ESPA. Where practicable, the SSAR section numbers should correspond to those identified in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition (SRP), to afford consistency between the COL and the ESPA. Therefore, the North Anna ESPA SHALL be revised to include a section titled Applicant/Program Manager. Also, depending on the location of the new section Applicant/Program Manager, Section 1.4.1, Bechtel Power Corporation, may be renumbered.
1.4.2 Other Contractors The primary agents or contractors associated with the development of the ESPA are identified.
The principal consultants and outside service organizations are also identified. The division of responsibility between the contractors and consultants is delineated by Dominion.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 6 of 77 May 2025 This section DOES NOT require an update because the section meets the requirements for identification of agents and contractors per SRP Section 1.0, Introduction and Interfaces.
1.5 Requirements for Further Technical Information NUREG-0800 Section 1.0, Introduction and Interfaces, indicates that additional technical information to be provided in support of the North Anna ESPA be identified therein. There are no technical information development programs remaining to be performed to support the North Anna ESPA.
Therefore, Part 2, Chapter 1, Section 1.5 the North Anna ESPA DOES NOT require an update because this section meets the requirements relative to additional technical information (none) cited in the SRP Section 1.0.
1.6 Material Incorporated by Reference NUREG-0800, Section 1.0, Introduction and Interfaces, indicates that a table or listing of material incorporated by reference such as topical reports (TRs) and technical reports in support of the North Anna ESPA be provided. No material has been incorporated by reference in the North Anna ESPA.
Therefore, Part 2, Chapter 1, Section 1.6, of the North Anna ESPA DOES NOT require an update because this section meets the requirements relative to material incorporated by reference (none) cited in the SRP Section 1.0.
1.7 Drawings and Other Detailed Information NUREG-0800 Section 1.0, Introduction and Interfaces, indicates that a table of drawings and system designators that are cross-referenced to the related section(s) of the application be provided. This information should include the applicable drawing legends and notes. No such information has been submitted separately as part of the North Anna ESPA.
Therefore, Part 2, Chapter 1, Section 1.7 of the North Anna ESPA DOES NOT require an update because this section meets the requirements relative to drawings and other detailed information cross-referenced to related ESPA sections (none) cited in the SRP, Section 1.0.,
Conformance to NRC Regulations and Regulatory Guidance.
1.8 Conformance to NRC Regulations and Regulatory Guidance NUREG-0800, Section 1.0, Introduction and Interfaces, indicates that information be provided that identifies conformance with regulatory guidance as well as deviation from regulatory guidance. This information is provided.
Therefore, Part 2, Chapter 1, Section 1.8, of the North Anna ESPA DOES NOT require an update. (Note that as part of the ESPA renewal; information will be provided to bring the Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 7 of 77 May 2025 approved application up to date. As part of this effort compliance with regulatory requirements will be assessed and expressed in this section of the ESPA).
1.8.1 Conformance with NRC Regulations See Section 1.8.
1.8.2 Conformance to NRC Regulatory Guides See Section 1.8.
1.8.3 Conformance to NRC Review Standard See Section 1.8.
1.9 Bounding Site-Specific Plant Parameters Envelope A PPE in support of the North Anna ESPA is provided. The PPE provides a logical, consistent, and workable framework that supports finality on siting issues prior to selecting a specific reactor technology. The listing of plant parameters necessary to define the plant-site interface -
the PPE - was developed in the early 1990s based on work sponsored by the U.S. Department of Energy and the nuclear industry, which included reactor vendors and utilities. The effort was intended to provide a comprehensive list of plant parameters to accurately characterize a plant at a site. Over time this list has evolved to encompass information needed to support development of an ESP application, including the SSAR and the ER. The PPE was developed based on data from selected reactor designs of two types, LWRs and helium-cooled reactors.
This section DOES NOT require an update because the bounding site-specific PPEs presented in Table 1.9-1 are the result of the NRC accepted PPE development methodology.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 8 of 77 May 2025 CHAPTER 2 2.0 SITE CHARACTERISTICS 2.1 Introduction 2.1.1 Site Location and Description According to RG 1.70 and RG 1.206, the specification of location should include the location of each reactor at the site by latitude and longitude to the nearest second and by Universal Transverse Mercator Coordinates (zone number, northing, and easting, as found on topographical maps prepared by the U.S. Geological Survey [USGS]) to the nearest 100 meters (328 feet). This information is not in the ESPA SSAR Section 2.1.1.1 but needs to be included.
The existing figures suggest the center point information is known and is centered on the abandoned Unit 3 containment center.
Other information such as state, county, and the location of the site with respect to surrounding features is included in the subsection, as well as Figures 2.1-1, 2.1-2, and 2.1-3.
This subsection DOES require an update.
2.1.2 Exclusion Area Authority and Control The North Anna ESPA SSAR includes a full discussion of exclusion authority and control.
This section DOES NOT require an update.
2.1.3 Population Distribution According to RG 1.70 and RG 1.206, the population distribution should be based on the latest decennial census through the plant life. The population distribution in the North Anna ESPA SSAR is based on the 2000 decennial census with projection information based on previous decennial census.
This section DOES require an update.
2.2 Nearby Industrial, Transportation, and Military Facilities Based on RG 1.70 and RG 1.206, the purpose of this section is to evaluate the potential effects of accidents in the vicinity of the site and provide design parameters related to potential accidents. Due to the age of the information found in the North Anna ESPA SSAR, the information needs to be evaluated for changes and updated, as necessary. Although much of the information will remain the same, industrial development is expected to increase. As mentioned in the North Anna ESPA SSAR, Louisa County has been actively seeking industrial growth within 10 miles.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 9 of 77 May 2025 This section DOES require an update.
2.2.1 Location and Routes The North Anna ESPA SSAR contains a full discussion of locations and routes. The information is not expected to change. However, based on the age of the information, location and routes needs to be evaluated for changes with updates provides as they are identified.
This section MAY require an update.
2.2.2 Descriptions Potential new facilities added in response to the future zoning changes described in the North Anna ESPA SSAR need to be identified. The ESPA SSAR will need to be updated with any identified new facilities as well as the outcome of the industrial development mentioned in the ESPA.
This section DOES require an update.
2.2.3 Evaluation of Potential Accidents The NAPS Unit 3 Combined License Application (COLA) incorporates the SSAR Section 2.2.3 by reference. Based on the industrial zoning changes, control room habitability for postulated releases of chemicals stored within 5 miles of the site may need to be evaluated based on new hazards. Changes in vehicle traffic patterns (e.g., truck, train, and airplane) will be evaluated based on the most recent plant survey and census information. The conclusions provided in the NAPS Unit 3 COLA on the effects of spills, collisions, toxic chemicals, and fires will inform potential updates to the ESPA in concert with updated site information.
This section DOES require an update.
2.3 Meteorology New meteorological data will be considered representative of the meteorological data used in the North Anna ESPA if the average wind direction and speed, wind direction persistence, and the atmospheric stability are consistent. If the new meteorological data is determined to be representative, a brief discussion will be added to the North Anna ESPA detailing the process used to confirm the meteorological data is consistent.
If the new meteorological data is determined to be inconsistent and not representative of the meteorological data used in the North Anna ESPA, the new meteorological data will be used in an update to the short term and long-term diffusion estimates. The Chapter 15 site specific X/Q values MAY require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 10 of 77 May 2025 2.3.1 Regional Climatology NUREG-0800, Section 2.3.1, also states that suitable information should be compiled from at least 30 years of meteorological data found in databases for nearby representative locations and that the bases and procedures used to select critical meteorological data should be provided and justified. NUREG-0800, Section 2.3.1, does not indicate any other restrictions on the 30 years of meteorological data. Section 2.3.1 of the North Anna SSAR uses 30 years of meteorological data to describe relevant regional meteorological conditions of the site. However, more recent meteorological data should be evaluated to confirm the new data is representative of the meteorological data used in North Anna SSAR Section 2.3.
This section DOES require an update. Information will be provided to bring the North Anna ESPA up to date and will include a new subsection on climate change to address the requirements in Section 7.1 of RG 4.2.
2.3.2 Local Meteorology NUREG-0800, Section 2.3.2, states that local summaries of meteorological data which are based on onsite measurements, should comply with RG 1.23. RG 1.23 indicates that the minimum amount of onsite meteorological data to be provided at the time of an ESPA is a consecutive 24-month period of data that is defendable, representative, and complete, but not older than 10 years from the date of the application.
This section DOES require an update.
2.3.3 Onsite Meteorological Measurements Program The Onsite Meteorological Measurements Program of the North Anna ESPA is not likely to change, however new meteorological data will be evaluated to determine if the data is representative of the ESPA meteorological data.
This section MAY require an update.
2.3.4 Short-Term (Accident) Diffusion Estimates If updated meteorological data is determined to be representative of established meteorological analyses, it is expected that the short-term and long-term X/Q values will remain valid, and this section of the North Anna SSAR will not require a significant update.
This section MAY require an update.
2.3.5 Long Term (Routine) Diffusion Estimates If updated meteorological data is determined to be representative of established meteorological analyses, it is expected that the short-term and long-term X/Q values will remain valid, and this section of the North Anna SSAR will not require a significant update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 11 of 77 May 2025 This section MAY require an update.
2.4 Hydrology 2.4.1 Hydrologic Description This section identifies the interface of the new units with the hydrosphere, the hydrological causal mechanisms that may require special plant design bases or operating limitations with regard to floods and water supply requirements, and the surface water and groundwater uses that may be affected by operation of new units at the ESP site.
The current revision to NUREG-0800, Section 2.4.1, was in effect for the original North Anna ESP. Since Lake Anna is maintained, no changes are expected to the interface of the new units with the hydrosphere. However, site-specific information, such as inventories of current and likely future water users, would need to be updated, along with reviewing any changes to hydrologic statistics presented in this chapter.
This section DOES require an update.
2.4.2 Floods This section identifies historical flooding at the proposed site or in the region of the site. It summarizes and identifies the individual types of flood-producing phenomena, and combinations of flood-producing phenomena, considered in establishing the flood design bases for safety-related plant features. It also covers the potential effects of local intense precipitation.
The current revision to NUREG-0800, Section 2.4.2, was in effect for the original North Anna ESP. The design basis for the flood design considerations in this section will be updated to include the supplemental information from the NAPS Unit 3 COLA. No new flood modeling is expected to be needed for the ESP renewal.
This section DOES require an update.
2.4.3 Probable Maximum Flood on Streams and Rivers In this section, the hydrometeorological design basis is developed to determine the extent of any flood protection required for those SSC necessary to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition.
The current revision to NUREG-0800, Section 2.4.3, was in effect for the original North Anna ESP. The design basis for the flood design considerations in this section will be updated to include the supplemental information from the NAPS Unit 3 COLA. The items to include are a revised PMF analysis for Lake Anna using the increased normal pool elevation, and an updated model to use the U.S. Army Corps of Engineers (USACE) HEC-HMS code and USACE Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 12 of 77 May 2025 guidance on the use of peaked hydrographs to account for a nonlinear response to large storms. No new flood modeling is expected to be needed for the ESP renewal.
This section DOES require an update.
2.4.4 Potential Dam Failures In this section, the hydrological design basis is developed to ensure that any potential hazard to the safety-related facilities due to the failure of onsite, upstream, and downstream water control structures are considered in plant design.
The current revision to NUREG-0800, Section 2.4.4, was in effect for the original North Anna ESP. Site-specific information may need to be updated to supplement the ESP during renewal; however, any changes would be minor.
This section MAY require an update.
2.4.5 Probable Maximum Surge and Seiche Flooding In this section of the safety analysis report (SAR), the hydrometeorological design basis is developed to ensure that any potential hazard to the safety-related facilities due to the effects of probable maximum surge and seiche are considered in plant design.
The current revision to NUREG-0800, Section 2.4.5, was in effect for the original North Anna ESP. Given the location of the ESP site and the analysis done as part of the original ESPA, no changes to this section are expected during renewal.
This section DOES NOT require an update.
2.4.6 Probable Maximum Tsunami Flooding In this section, the site characteristic flood elevation is reviewed, taking into account the effects of the tsunami flood-causing mechanism by considering all plausible tsunamigenic sources to ensure that those SSCs important to safety can perform their intended functions.
Since the ESP site is at an inland location and not located on an estuary or open coast, tsunami flooding is not a design consideration. Although the current revision to NUREG-0800, Section 2.4.6, was not in effect for the original North Anna ESP, no change to the applicability of this ESP site was changed. No changes to this section are expected during renewal.
This section DOES NOT require an update.
2.4.7 Ice Effects In this section, the hydrometeorological design basis is developed to ensure that safety-related facilities and water supply are not affected by ice-induced hazards.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 13 of 77 May 2025 The current revision to NUREG-0800, Section 2.4.7, was in effect for the original North Anna ESP. Given the location of the ESP site and the analysis done as part of the original ESPA, no changes to this section are expected during renewal.
This section DOES NOT require an update.
2.4.8 Cooling Water Canals and Reservoirs In this section, the hydraulic design basis is developed for canal and reservoirs used to transport and impound water supplied to the SSC important to safety.
The current revision to NUREG-0800, Section 2.4.8, was in effect for the original North Anna ESP. Site-specific information included as supplemental information from the NAPS Unit 3 COLA will be updated during renewal. No other changes are anticipated.
This section DOES require an update.
2.4.9 Channel Diversions In this section, the site characteristic flood elevation is evaluated by staff, taking into account the potential flooding effects due to the migration or diversion of some type of channel of flowing water, such as a stream or river, to ensure that SSCs important to safety can perform their intended safety functions.
The current revision to NUREG-0800, Section 2.4.9, was in effect for the original North Anna ESP. While a Draft Revision 4 was published in 2018, the changes do not influence the original North Anna ESP, as the possibility of an upstream diversion of the North Anna River is considered extremely remote. Site-specific information included as supplemental information from the NAPS Unit 3 COLA will be updated during renewal. No changes to this section are expected during renewal.
This section DOES NOT require an update.
2.4.10 Flooding Protection Requirements In this section, the locations, and elevations of safety-related facilities and those of structures and components required for protection of safety-related facilities are compared with design-basis flood conditions to determine if flood effects need to be considered in plant design or in emergency procedures.
The current revision to NUREG-0800, Section 2.4.10, was in effect for the original North Anna ESP. Site-specific information included as supplemental information from the NAPS Unit 3 COLA will be updated during renewal. No other changes are anticipated.
This section DOES require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 14 of 77 May 2025 2.4.11 Low Water Considerations In this section, natural events that may reduce or limit the available safety-related cooling water supply, are identified and the applicant ensures that an adequate water supply will exist to shut down the plant under conditions requiring safety-related cooling.
The current revision to NUREG-0800, Section 2.4.11, was in effect for the original North Anna ESP. Site-specific information included as supplemental information from the NAPS Unit 3 COLA will be updated during renewal. No other changes are anticipated.
This section DOES require an update.
2.4.12 Groundwater In this section, the hydrogeological characteristics of the site are to describe the effects groundwater on plant foundations and reliability of safety-related water supply and dewatering systems.
The current revision to NUREG-0800, Section 2.4.12, was in effect for the original North Anna ESP. Site-specific information included as supplemental information from the NAPS Unit 3 COLA will be updated during renewal. No other changes are anticipated.
This section DOES require an update.
2.4.13 Accidental Releases of Liquid Effluents to Ground and Surface Waters In this section, the hydrogeological characteristics of the site are evaluated to describe the effects of accidental releases of radioactive liquid effluents in ground and surface waters on existing uses and known and likely future uses of ground and surface water resources.
The current revision to NUREG-0800, Section 2.4.13, was in effect for the original North Anna ESP. The NAPS Unit 3 COLA will inform the ESPA update to address Branch Technical Paper (BTP) 11-6, Postulated Radioactive Releases Due to Liquid-Containing Tank Failures; DC/COL-ISG-013, Assessing the Radiological Consequences of Accidental Releases of Radioactive Materials from Liquid Waste Tanks for Combined License Applications; and DC/COL-ISG-014, Assessing the Radiological Consequences of Accident Releases of Radioactive Materials from Liquid Waste Tanks in Ground and Surface Waters for Combined License Applications.
This section DOES require an update.
2.4.14 Technical Specifications and Emergency Operation Requirements In this section, identification of the bases for technical specifications and emergency procedures that are required to implement protection against floods for safety-related facilities and to ensure that an adequate supply of water for shutdown and cooldown purposes is available.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 15 of 77 May 2025 This section was not in the original North Anna ESP, although it is required for an ESPA. This section was included in the NAPS Unit 3 COLA, which will be used to inform the ESPA during renewal.
This section DOES require an update.
2.5 Geology, Seismology, and Geotechnical Engineering Based on RG 1.70 and RG 1.206, the purpose of this section is to present information on the geological, seismological, and geotechnical engineering properties of the ESP site and the region surrounding the site. Section 2.5.1 describes basic geological and seismologic data.
Section 2.5.2 describes the vibratory ground motion at the site. Section 2.5.3 describes the potential for surface faulting in the site area, and Section 2.5.4, Section 2.5.5, and Section 2.5.6 describe the stability of surface materials and foundations at the site.
This section DOES NOT require an update.
2.5.1 Basic Geologic and Seismic Information Section 2.5.1 presents information on geologic and seismic characteristics of the site and region surrounding the site. For sites in the central and eastern United States, the acceptable starting-point regional model for Probabilistic Seismic Hazard Analysis (PSHA) studies is NUREG-2115, Central and Eastern United States Seismic Source Characterization for Nuclear Facilities. This model replaces Electric Power Research Institute (EPRI) ground motion models from 1986, which formed the basis for the original North Anna ESP. This section will need to be updated.
The NAPS Unit 3 COLA applied the approach described in NUREG-2115, which will be utilized to inform the ESPA update. The NAPS Unit 3 COLA utilized the current revision of NUREG-0800, so therefore should be adequate to inform the ESPA update.
This section DOES require an update.
2.5.2 Vibratory Ground Motion Section 2.5.2 describes the vibratory ground motion assessment for the site through a PSHA and develops the Safe Shutdown Earthquake (SSE) ground motion. The vibratory ground motion is evaluated based on seismological, geological, geophysical, and geotechnical investigations carried out to determine the site-specific ground motion response spectrum (GMRS), which must meet the regulations for the SSE provided in 10 CFR 100.23. The GMRS is defined as the free-field horizontal and vertical response spectra at the plant site. The development of the GMRS is based on a detailed evaluation of earthquake potential, taking into account the regional and local geology, Quaternary tectonics, seismicity, and site-specific geotechnical engineering characteristics of the site subsurface material.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 16 of 77 May 2025 As part of the ESPA update, ENERCON will review the most recent earthquake catalog published. The ESP renewal will be informed by the NAPS Unit 3 COLA.
The NAPS Unit 3 COLA provided supplemental information on additional subsurface details discovered during the COL site investigations. As such, the COLA developed the GMRS using the performance-based approach recommended in RG 1.208 and updated the selection of GMM from the EPRI (2004, 2006) model to the most recent EPRI (2013) model. The NAPS Unit 3 COLA utilized the current revision of NUREG-0800, so therefore should be adequate to inform the ESPA update.
This section DOES require an update.
2.5.3 Surface Faulting Section 2.5.3 evaluates the potential for surface tectonic and non-tectonic deformation at the ESP site. The ESP renewal will be informed by the NAPS Unit 3 COLA.
The NAPS Unit 3 COLA provided supplemental information on additional borehole data from NAPS Unit 3 borings. The COLA is consistent with RG 1.208 and satisfies 10 CFR 100.23.
The NAPS Unit 3 COLA did not utilize the current revision of NUREG-0800. The current revision reflects risk-informed regulation to focus on causes of surface deformation that affect the site.
The NAPS Unit 3 COLA will inform the ESPA update.
This section DOES require an update.
2.5.4 Stability of Subsurface Materials and Foundations Section 2.5.4 describes the subsurface and foundation material stability at the ESP site. The ESP renewal will be informed by the NAPS Unit 3 COLA.
The NAPS Unit 3 COLA provided supplemental information on additional borehole data from NAPS Unit 3 borings. The COL field investigations, a supplement to the ESP investigations, included additional exploratory borings, observation wells, CPTs, packer tests, geophysical loggings, and electrical resistivity tests. The COLA also completed additional laboratory testing, such as chemical and resonant column torsional shear (RCTS) tests, which further constrained the material properties that were determined from similar tests completed as part of the ESP.
The COLA then used the results of the field investigations and the laboratory testing to further constrain the engineering properties of the subsurface materials, as determined during the ESP investigation. The COLA provided more detailed description of an excavation and backfill program compared to what was provided as part of the ESP.
The NAPS Unit 3 COLA utilized the current revision of NUREG-0800, so therefore should be adequate to inform the ESPA update. Information associated with the relevant requirements of ESBWR standard design will not need to be included in the ESPA update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 17 of 77 May 2025 This section DOES require an update.
2.5.5 Stability of Slopes Section 2.5.5 describes the slope stability information related to the ESP site. The ESP renewal will be informed by the NAPS Unit 3 COLA.
The NAPS Unit 3 COLA utilized the current revision of NUREG-0800, so therefore should be adequate to inform the ESPA update. Information associated with the relevant requirements of ESBWR standard design will not need to be included in the ESPA update.
This section DOES require an update.
2.5.6 Embankments and Dams Section 2.5.6 describes the embankments and dams in the site area. Lake Anna is used for normal plant cooling of the existing unit. The North Anna Dam is designed and constructed to meet the requirements for a seismic Category I structure in support of the existing units. There is an existing 55-foot-high embankment to the north of the Service Water Reservoir (SWR) and to the south of the new units. A similar embankment may be constructed to the west of the SWR to accommodate certain reactor designs that might be constructed on the ESP site. These are described and presented in Section 2.5.5, which will be updated.
This section DOES NOT require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 18 of 77 May 2025 CHAPTER 3 3.0 DESIGN OF STRUCTURES, COMPONENTS, EQUIPMENT, AND SYSTEMS 3.5.1.6 Aircraft Hazards This section addresses aircraft hazards as required by NUREG-0800 Section 3.5.1.6 and references SSAR Sections 2.2.2.6 and 2.2.3.2.1.
This section DOES NOT require an update because this section meets the SRP requirements.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 19 of 77 May 2025 CHAPTER 11 11.0 RADIOACTIVE WASTE MANAGEMENT 11.2.3 Liquid Radioactive Releases The section should be added to the North Anna ESPA referencing NAPS COLA Sections 11.2.3.1 and 11.2.3.2 to address radioactive liquid effluent releases and dose calculations as required by NUREG-0800, Section 11.2. This SRP section was issued in March 2007 after the submittal of the North Anna ESPA. Prior to this revision, the SRP section had not addressed ESP applications under 10 CFR 52, but rather 10 CFR 50 and CP/OL process.
This section DOES require an update.
11.3.3 Gaseous Radioactive Releases The section should be added to the North Anna ESPA referencing NAPS COLA Sections 11.3.3.1 and 11.3.3.2 to address radioactive gaseous effluent releases and dose calculations as required by NUREG-0800, Section 11.3. This SRP section was issued in March 2007 after the submittal of the North Anna ESPA. Prior to this revision, the SRP section had not addressed ESP applications under 10 CFR 52, but rather 10 CFR 50 and CP/OL process.
This section DOES require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 20 of 77 May 2025 CHAPTER 13 13.0 Conduct of Operations 13.3 Emergency Planning Part 2, Chapter 13, of the North Anna ESPA provides the emergency planning information required by NRC regulations necessary to support an ESP application. That includes information required by 10 CFR 52.17(b)(1) regarding identification of potential impediments to emergency planning, and information required by 10 CFR 52.17(b)(3) regarding descriptions of contacts and arrangements made with local, state, and federal governmental agencies with emergency planning responsibilities. At a minimum, this includes physical characteristics unique to the proposed site that could pose a significant impediment to the development of emergency plans, and the description of contacts and arrangements made with local, State, and Federal governmental agencies with emergency planning responsibilities.
Emergency planning information provided for the North Anna ESPA is founded upon information pertaining to the reactor types presented in Section 1.3.2.
This section DOES NOT require an update because this section provides the information required by 10 CFR 52.17(b)(1) and 10 CFR 52.17(b)(3) cited above.
13.3.1 Emergency Planning Overview The North Anna ESP site is adjacent to a preexisting nuclear facility with existing State and local emergency plans. The SSAR, relies on and refers to the information contained in these existing plans. The ESPA does not identify any significant differences between the major features of emergency plans proposed in the ESPA and the major features discussed in existing plans and, therefore, relied on this information in the application.
This section DOES NOT require an update because this section provides the information required by 10 CFR 52.17(b)(1) and 10 CFR 52.17(b)(3) cited above.
13.3.2 Major Features Emergency Plan SSAR Section 13.3.2 states that the proposed emergency plan takes advantage of the emergency planning resources, capabilities, and organization that Virginia Power has already established and currently maintains at the North Anna site. The ESPA extends the existing emergency planning and preparedness activities to include the proposed new unit(s). SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with existing State and local emergency plans. The SSAR, therefore, relies on, and refers to, information contained in these existing plans. There are no significant differences between the major features proposed in the North Anna ESPA and the major features discussed in existing plans and relied on in the application.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 21 of 77 May 2025 This section DOES NOT require an update because this section provides the information required by 10 CFR 52.17(b)(1) and 10 CFR 52.17(b)(3) cited above.
13.3.3 Contracts and Arrangements Part 2, Chapter 13, Section 13.3.2, states that the proposed emergency plan takes advantage of the emergency planning resources, capabilities, and organization that Virginia Power has already established, and currently maintains, at the North Anna site. The ESPA extends the existing emergency planning and preparedness activities to include the proposed new unit(s).
SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with existing State and local emergency plans. The SSAR, therefore, relies on and refers to information contained in these existing plans.
A description of contacts and arrangements made with local, state, and federal governmental agencies with emergency planning responsibilities, and documentation thereof, is provided in Part 2, Chapter 13, Section 13.3.3.
This section DOES NOT require an update because this section provides the information required by 10 CFR 52.17(b)(1) and 10 CFR 52.17(b)(3) cited above.
13.3.4 Conformance with NUREG-0654 Supplement 2 Differences between emergency planning information relative to the North Anna ESPA and the guidance provided by NUREG-0654, Supplement 2, are cross-referenced and described in Part 2, Chapter 13, Section 13.3.4.
This section DOES NOT require an update because this section provides the information required by 10 CFR 52.17(b)(1) and 10 CFR 52.17(b)(3) cited above.
13.6 Industrial Security Part 2, Chapter 13, Section 13.6 of the SSAR, states that the site characteristics are such that the applicable NRC regulations, guidance documents, and orders can be met. This conclusion is based on the size of the North Anna site, which is sufficiently large to provide adequate distances between vital areas and the probable location of a security boundary.
This section DOES NOT require an update because this section provides the information required by 10 CFR 52.17(b)(1) and 10 CFR 52.17(b)(3) cited above.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 22 of 77 May 2025 CHAPTER 15 15.0 ACCIDENT ANALYSES 15.1 Selection of Accidents The radiological consequences of accidents are assessed to demonstrate that new units could be sited at the North Anna-specific accident meteorology with radiological analyses in selected reactor designs to analyze the suitability of the ESP site. The assessment uses a robust and conservative set of surrogate Design Basis Accidents (DBA) that is representative of the range of reactor designs being considered for the ESP site. The set of accidents selected focuses on three LWR designs: AP1000, ABWR, and ESBWR. The accidents for some of the newer reactor types being considered are not as well defined as those for LWRs and, hence, the accepted analytical methodologies and assumptions applied to LWRs may not apply to these reactors.
However, because of their greater potential for inherent safety, the accident radiological consequences of the other reactors being considered for the site are expected to be bounded by the AP1000, the ABWR, and the ESBWR.
This section DOES NOT require an update unless the proposed technologies change because the North Anna ESPA accident selection is based upon conservative information which will be used to demonstrate the adequacy of the ESPA site.
15.2 Evaluation Methodology A PPE is a set of plant design parameters that are expected to bound the characteristics of a reactor or reactors that may be constructed at the North Anna site, and it serves as a surrogate for actual reactor design information. The PPE values are selected by the applicant to bound a range of possible current and future reactor designs. The PPE values and associated information in the ESP application must contain sufficient information to allow the NRC to make a determination regarding the acceptability of the proposed site using the radiological consequence evaluation factors identified in 10 CFR 50.34(a)(1). For the North Anna site, the accident doses are expressed as total effective dose equivalent (TEDE), consistent with 10 CFR 50.34.
Site meteorological data as described in Section 2.3 is used in the calculation of site-specific X/Q values. This section MAY require an update if the new, more recent meteorological data is determined to be inconsistent and not representative of the meteorological data used in the North Anna ESPA, the new meteorological data will be used to determine site specific X/Q values.
15.3 Source Terms Refer to NAPS COLA Chapter 15, Safety Analysis, Sections 15.3, Analysis of Infrequent Events, 15.4.1, Fuel Handling Accident, and Section 15.6, ESP Information, for additional Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 23 of 77 May 2025 information pertaining to evaluation methodology and conclusions. Note that the ESPA SSAR Chapter 15 is incorporated by reference except that information related to the ESBWR is replaced by design control document (DCD) Chapter 15.
This section DOES NOT require an update unless the proposed technology changes because the North Anna ESPA uses conservative source term information provided by reactor vendors to develop the PPE and demonstrate the adequacy of the ESPA site.
15.4 Radiological Consequences For the North Anna ESPA, doses for the representative DBAs are evaluated at the exclusion area boundary (EAB) and the low population zone (LPZ). These doses meet the site acceptance criteria provided in 10 CFR 50.34 and 10 CFR 100. The accident doses are expressed as TEDE, consistent with 10 CFR 50.34.
This section DOES NOT require an update unless the proposed technology changes.
If the new, more recent meteorological data as described in Section 2.3 is determined to be not representative of the meteorological data used in the North Anna ESPA, the new meteorological data will be used to determine site specific X/Q values provided in Section 15.2.
The ratio of the DC X/Q values and the site-specific X/Qs MAY require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 24 of 77 May 2025 CHAPTER 17 17.0 QUALITY ASSURANCE 17.1 Quality Assurance During Design and Construction This section delineates the Quality Assurance (QA) Plan for the development of an ESPA for the addition of new nuclear generation. It has been developed with guidance from American Society of Mechanical Engineers (ASME)-National Quality Assurance (NQA)-1-2000. The QA Program outlines the organization, programs and procedural requirements that will assure that the application is developed in a quality manner and, where appropriate, in accordance with 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants. This section should be revised to address the references to additional regulatory and industry standards applicable to the ESP QA Program cited in the COL.
This section SHOULD require an update because industry and regulatory guidance has changed.
17.1.1 Organization This section provides a detailed organizational description including an organizational structure, functional responsibilities, levels of authority, and interfaces to establish, execute, and verify QA Program implementation.
This section SHOULD require an update because of changes to organization and functional responsibilities.
17.1.2 Quality Assurance Program This section states that the objective of the Dominion QA Program for Early Site Permit Applications is to comply with the criteria as expressed in 10 CFR 50, Appendix B, as amended, and with the QA program requirements for nuclear power plants as described in the Operational Quality Assurance Program Topical Report, VEP-1-5A. This program, its policies and procedures are described in the Early Site Permit Quality Assurance Program; the Nuclear Business Unit Standard; and the corporate and station procedures. This program applies to those quality-related activities that involve the functions of safety-related structures, systems, and components (SSC) associated with the construction of nuclear power stations and those non-safety-related components described in the SSAR.
The program provides written policies, standards, procedures, and instructions covering engineering, design, procurement, periodic surveillance, and supporting tests, for the development of the Application. Nuclear Business Unit policies establish commitments to the QA Program. Audits and inspection programs have been implemented to assure that the Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 25 of 77 May 2025 procedures are correctly applied. The program also addresses the qualification and training of personnel.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion II.
17.1.3 Design Control This section calls out the Nuclear Design Control Program that provides the procedures required to assure that design basis, regulatory requirements, codes and standards are correctly translated into specifications, drawings, procedures, or instructions for those items classified as safety related and that design changes, including field changes, are subject to design control measures commensurate with those applied to the original design and the applicable specified design requirements. Nuclear Standards describe the design control program.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion III.
17.1.4 Procurement Document Control This section describes the program that provides administrative procedures to ensure procurement documents include reference applicable regulatory, technical, and QA Program requirements. These requirements (such as specifications, codes, standards, tests, inspections, and special processes are invoked for procurement of items and services. Any non-conforming conditions identified shall be documented and corrected in accordance with the Corrective Action Process (Section 17).
Procurement documents incorporate the design basis technical and quality requirements including the applicable regulatory requirements, component and material identification requirements, drawings, specifications, codes and industrial standards, test and inspection requirements, and special instructions for special processes such as welding, heat treating, non-destructive testing and cleaning as applicable.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion IV.
17.1.5 Instructions, Procedures and Drawings This section describes the program that ensures detailed written procedures are established, approved, implemented, and maintained to control development of the application and assure necessary measures and governing procedures for ESP activities affecting quality are prescribed by and performed in accordance with documented instructions, procedures, and drawings.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 26 of 77 May 2025 This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion V.
17.1.6 Document Control This section describes the program that ensures measures are established and documented preparation, review, approval, issuance, and changes of documents that specify quality requirements or prescribe measures for controlling activities that affect quality, including organizational interfaces. The program provides measures to ensure that the same organization that performed the original review and approval also reviews and approves changes unless other organizations are specifically designated. A listing of all controlled documents that identify the current approved revision or date is maintained so personnel can readily determine the appropriate document for use.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion VI.
17.1.7 Control of Purchased Material, Equipment, and Services This section describes the program that provides measures for evaluating prospective suppliers and selecting only those that are qualified. In addition, the program provides guidelines for auditing and evaluating suppliers to ensure that qualified suppliers continue to provide acceptable products and services. The program provides for acceptance actions (e.g., source verification, receipt inspection, pre-and post-installation tests) and review of documentation (e.g., conformance certificates) to ensure that the procurement, inspection, and test requirements have been satisfied before relying on the item to perform its intended safety function.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion VII.
17.1.8 Identification and Control of Materials, Parts, and Components This section states that during the development of an ESPA, no safety-related materials, parts or components will be procured or used. For this reason, this criterion is not applicable to the development of an ESPA. However, this criterion may be applicable to important-to-safety (augmented quality) procurement such that measures should be established for the identification and control of items such as materials, including consumables and items with limited shelf life, parts, components, and partially fabricated subassemblies. Identification of items is maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation.
The section SHOULD be considered for an update to assure that materials, parts, and components important to safety or quality augmented are properly identified and controlled.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 27 of 77 May 2025 17.1.9 Control of Special Processes This section states that the non-safety-related scope of the development of the ESP application will not involve the use of special processes. For this reason, this criterion is not applicable to the development of an ESPA.
This section SHOULD require an update to assure special processes are controlled when important to safety issues are involved.
17.1.10 Inspection This section describes program provisions for ensuring items, services, and activities that affect safety meet requirements and conform to specifications, instructions, procedures, and design documents. The inspection program establishes requirements for planning inspections, determining applicable acceptance criteria, setting the frequency of inspection, and identifying special tools needed to perform the inspection. Inspectors are properly qualified personnel who are independent of those who performed or directly supervised the work.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion X.
17.1.11 Test Control This section describes program provisions for controlling testing to demonstrate that items will perform satisfactorily in service and can be operated safely as designed.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion XI.
17.1.12 Control of Measuring and Test Equipment This section describes program provisions for controlling the calibration, maintenance, and use of measuring and test equipment used in activities affecting the quality of safety-related SSC.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion XII.
17.1.13 Handling, Storage, and Shipping This section describes program provisions for controlling the handling, storage, packaging, shipping, cleaning, and preserving items to prevent inadvertent damage or loss and to minimize deterioration.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion XIII.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 28 of 77 May 2025 17.1.14 Inspection, Test, and Operating Status This section describes program measures provided for the identification and documentation of the inspection and test status for items to prevent inadvertent bypassing of specified inspection and tests established in administrative procedures and in station operating procedures.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion XIV.
17.1.15 Nonconforming Materials, Parts, or Components This section describes program measures established for the identification and control of non-conformances observed during receipt inspection, storage, fabrication and erection, installation, initial and/or acceptance testing, or initial operation. The program provides for the preparation, issuance, and distribution of deviation reports documenting any such non-conformances and provides for segregation of affected materials, parts, or components to prevent inadvertent use.
In addition, the program should provide for the necessary measures to implement a reporting program to identify, evaluate, and report defects and non-compliances in accordance with the requirements of 10 CFR 50.55(e) and/or 10 CFR Part 21, as applicable.
The section SHOULD require an update to assure that the program provides for the necessary measures to implement a reporting program to identify, evaluate, and report defects and non-compliances in accordance with the requirements of 10 CFR 50.55(e) and/or 10 CFR Part 21, as applicable.
17.1.16 Corrective Action This section describes the program measures established to promptly identify, control, document, classify, and correct conditions adverse to quality. Corrective action measures are established as an integral part of processing and resolving non-conformances and failures in service. Through these measures, assurance is confirmed that significant adverse quality conditions are identified, documented, their cause determined, and corrective actions have been taken that preclude repetition of the adverse quality conditions. Stop work authority is also described.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion XVI.
17.1.17 Quality Assurance Records This section describes the program measures established for the requirements and responsibilities for QA records transmittal, retention, and maintenance.
This section DOES NOT require an update because this section addresses 10 CFR 50, Appendix B, Criterion XVII.
Draft
North Anna Early Site Permit Application Annotated Outline Part 2: Site Safety Analysis Report Page 29 of 77 May 2025 17.1.18 Quality Assurance Audits This section provides for the conduct of periodic internal and external audits. Internal audits determine the adequacy and effectiveness of the QA Program. Internal audits are performed with a frequency commensurate with safety significance. The audit frequency for internal audits is stated as biennial and for supplier audits triennial, accordance with ASME-NQA-1-2000.
However, internal audit frequency stated in COL is annual per current NQA-1 guidance from 2008 edition. The difference in the NQA-1 guidance is that the audit frequency is annual prior to the facility going into operation and biennial thereafter.
This section SHOULD require an update to revise the audit frequency from biennial to annual consistent with the revised ASME-NQA-1 guidance.
17.2 Non-Safety-Related SSC Quality Controls This section provides for revision and issuance of the ESPA Development QA Manual and SHOULD be incorporated into QAP Section 2 on Organization under responsibilities for the Project Manager, Director Nuclear Oversight, and Vice-President Nuclear Support Services.
This section could then be used to address Non-Safety-Related SSC Quality Controls.
This section SHOULD be revised to address Non-Safety-Related SSC Quality Controls.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 30 of 77 May 2025 PART 3: ENVIRONMENTAL REPORT
1.0 INTRODUCTION
North Anna ESPA Part 3, ER Chapter 1, provides an introduction to the ER and lists NRC guidance documents used in the preparation of the ER. The section should be updated to reference current NRC documents.
This section DOES need an update.
1.1 The Proposed Action North Anna ESPA ER Section 1.1 discusses the nature of the proposed action and the constraints that are placed on the review because of the type of action.
This section DOES NOT need an update.
1.1.1 The Applicant and Owner North Anna ESPA ER Section 1.1.1 provides full names of all organizations (e.g., utilities, municipalities) sharing ownership of the proposed project and the name of the organization designated as the applicant.
This section MAY need an update if any of the ownership information has changed from the 2006 North Anna ESPA ER.
1.1.2 Site Location North Anna ESPA ER Section 1.1.2 provides site location with respect to nearby towns and natural features.
This section DOES NOT need an update.
1.1.3 Reactor Information North Anna ESPA ER Section 1.1.3 section states the number and type of reactors, highest anticipated gross thermal megawatt output, and net electrical output. This section may require an update if Dominion considers small modular reactors (SMR) or other new nuclear technologies as part of the ESPA PPE. The NAPS COLA for Unit 3 reactor power conversion system consists of an ESBWR, a turbine generator set, and its auxiliaries. The design characteristics of the Unit 3 reactor power conversion system were shown to fall within the ESPA PPE).
This section DOES need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 31 of 77 May 2025 1.1.4 Cooling System Information This section provides the cooling system description (intake type, heat dissipation type, discharge type, source of cooling water). The North Anna ESPA ER states a closed-cycle, dry and wet cooling tower system with makeup water from Lake Anna would be used for Unit 3, and a closed-cycle cooling, using dry towers, would be used for Unit 4. If this assumption is still valid, no new analysis is required. If this assumption has changed, then section updates may be required.
This section MAY need an update.
1.1.5 Transmission System Information North Anna ESPA ER Section 1.1.5 provides a description of the transmission system (distance of new rights-of-way [ROW], new towers, or conductors on existing ROWs). The current section states that the NAPS site is interconnected with the regional power grid system via three 500 kV transmission lines and one 230 kV transmission line. The NAPS COLA provides updated transmission system information. This section should be reviewed and updated to state current transmission system configuration and any potential changes associated with the new nuclear units.
This section DOES need an update.
1.1.6 Pre-Application Public Involvement North Anna ESPA ER Section 1.1.6 provides a discussion of public involvement in the process, specifically involvement of minority and low-income populations. This section does require an update to include updated examples of stakeholder interactions that Dominion has initiated since the 2006 North Anna ESPA.
This section DOES need an update.
1.1.7 Construction Start Date North Anna ESPA ER Section 1.1.7 provides a general discussion of proposed dates for start and completion of major activities.
This section DOES NOT need an update.
1.2 Status of Reviews, Approvals, and Consultations North Anna ESPA ER Section 1.2 provides a list of the environmentally related authorizations required by Federal, State, regional, local, and affected Native American tribal agencies and should be reviewed as part of the renewal process. The type of data and information needed may be affected by any changes or updates to site-and station-specific factors. The degree of detail should be modified according to the anticipated magnitude of the potential impacts.
Table 1.2-1 MAY need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 32 of 77 May 2025 2.0 ENVIRONMENTAL DESCRIPTION North Anna ESPA ER Section 2.0 will require a revision. The updates in this section will be based on the changes made throughout Chapter 2 of the North Anna ESPA ER renewal. For example, a subsection on noise will likely be added based on NRC RG 4.2, Revision 3; therefore, it will need to be included as a bullet point in this overview section.
This section description DOES need an update.
2.1 Site Location Section 2.1 of the North Anna ESPA may require a revision. Figure 2.1-1 illustrates the plant envelope area for which the two new units would be confined. Though the plant envelope area has not changed, the figure may need updated based on any changes to the layout (e.g., new infrastructure) that has occurred within the envelope area since the 2006 ESPA. The 2010 COLA offers a similar figure (Figure 2-1). However, additional information from the plant may be necessary to complete the updated figure, if applicable.
Per NRC RG 4.2, Revision 3, coordinates for the proposed center point for the nuclear island for each proposed new unit and total acreage of the proposed site should be included in this section. This information can be obtained via a formal request for information (RFI).
This section DOES need an update depending on infrastructure changes onsite or potential changes to the design (i.e., smaller, or larger envelope).
2.2 Land Section 2.2 of the North Anna ESPA is an overview section. Information pertaining to land use is described in the following subsections.
2.2.1 The Site and Vicinity Information in Section 2.2.1.1 related to land cover, including changes to active and commercially valuable mines, will likely need updated. Further, land use and population sizes described in Section 2.2.1.2 will need updated based on the latest census information. The land cover, land use, and population sizes can be updated using the 2024 NAPS SEIS and other publicly available information.
Figures either need to be updated in Section 2.0 or new figures added in this section that are prepared according to NRC RG 1.206 and include the following information:
areas occupied by the principal land uses for the site, vicinity, and region existing topography Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 33 of 77 May 2025 existing highways, railroad lines, waterways, and utility corridors located on, or the cross, the site, vicinity, and region major public and trust land areas in the region floodplains and wetlands on the site A discussion on the above points, including existing topography, floodplains, wetlands, and other physical descriptions should be added to this section. This information can be retrieved through publicly available resources.
This section DOES need an update.
2.2.2 Transmission Corridors and Offsite Areas North Anna ESPA ER Section 2.2.2 will require a revision. There have been minor changes in the vegetation management of transmission corridors and offsite areas. For example, management now includes collaboration with Virginia Department of Conservation and Recreation (VDCR) Natural Heritage Division to identify and protect areas within the ROWs that have protected species. This information can be updated using the 2024 NAPS SEIS.
A figure should be provided for the existing transmission routing, if not already provided in a previous figure (i.e., figures added in Section 2.2.1 above).
This section DOES need an update.
2.2.3 The Region North Anna ESPA ER Section 2.2.3 will require a revision. Specifically, land use and crop production will need updated. This information can be updated using the 2024 NAPS SEIS and other publicly available information. Information updates from Section 2.2.1 can be referenced as well.
This section DOES need an update.
2.3 Water Data updates for Section 2.3 are summarized in the following subsections. There are no changes in content for water/hydrology between RG 4.2, Revision 3, and DG-4032. Descriptions of hydrology, water use, and water quality are based, in part, on a prior Revision 38 of the NAPS updated final safety analysis report (UFSAR) and the ER Supplement dated 1972. The NAPS UFSAR is in Revision 60 (dated September 2024), the subsequent license renewal (SLR)
ER (dated August 2020), and other reputable public sources will be used to update the section content as appropriate.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 34 of 77 May 2025 2.3.1 Hydrology The hydrology section of the North Anna ESPA ER is subdivided into descriptions of surface water and groundwater hydrology.
Surface water hydrology is described in Section 2.3.1.1 of the North Anna ESPA ER and Section 2.6.1.1 of the final environmental impact statement (FEIS). There are no new ESPA ER content requirements in RG 4.2, Revision 3, or DG-4032. Updates to the data in this section of the North Anna ESPA ER are required to reflect current conditions using publicly available and site-specific data. More specifically, data to be updated are listed as follows:
Update Table 2.3-1, Lake Anna Storage Allocation, if any changes.
Update gauge periods of record in Table 2.3-2, USGS Stream Gauge Data.
Update Table 2.3-3, Monthly Water Level Statistics for Lake Anna.
Update Table 2.3-8, Monthly Streamflow Statistics.
Virginia Pollutant Discharge Elimination System (VPDES) permit conditions. The Virginia Department of Environmental Quality (VDEQ) reissued Permit No. VA0052451 on March 13, 2024. The reissued permit includes the most recent Lake Level Contingency Plan.
Further, it is stated within the permit that the Virginia Water Protection (VWP) issued a surface water withdrawal permit (VWP Permit No. 10-2001) in 2012 for activities associated with construction and operation of Unit 3. The project proposed a change to shoreline wetlands and an increase in the normal pool elevation of Lake Anna. Both the VPDES and VWP permits have Lake Level Contingency Plan requirements.
Update Figure 2.3-2, Elevation-storage curve, if any changes.
Descriptions of floodplains and wetlands are included in Section 2.4 of the North Anna ESPA ER. As described in the NAPS Unit 3 COLA ER Section 2.3.1, 31 wetlands and 26 waterways along a proposed transport route were identified. Inclusion of this information in Section 2.4 should be verified.
Groundwater hydrology is described in Section 2.3.1.2 of the North Anna ESPA ER and Section 2.6.1.2 of the FEIS. There are no new ESPA ER content requirements in RG 4.2, Revision 3, or DG-4032. Updates to the data in this section of the North Anna ESPA ER are required to reflect current conditions using publicly available and site-specific data. More specifically, data to be updated are listed as follows:
Update Table 2.3-9, Quarterly Groundwater Level Elevations, with recent groundwater level elevation data collected onsite.
Update Figure 2.3-7, Ground Water Level Hydrographs, with recent groundwater level elevations from onsite observation wells.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 35 of 77 May 2025 Update Figure 2.3-8, Piezometric Head Contour Map, with recent groundwater level elevations and piezometric contours.
Updates to aquifer hydraulic properties (e.g., hydraulic conductivity, porosity) and Table 2.3-10, Hydraulic Conductivity Values, using data from the 2016 NAPS Unit 3 COLA final safety analysis report (FSAR) Revision 9, which are also summarized in Section 3.6.2.2 of the SLR ER.
This section DOES need an update.
2.3.2 Water Use There are no new ESPA ER content requirements in RG 4.2, Revision 3, or DG-4032. The NAPS Unit 3 COLA ER Section 2.3.2 did not identify any new and significant information for this section. Updates to the data in this section of the North Anna ESPA ER are required to reflect current conditions using publicly available and site-specific data. The North Anna ESPA ER is further subdivided into descriptions of surface water and groundwater use.
Surface water use is described in North Anna ESPA ER Section 2.3.2.1 and in FEIS Section 2.6.2.1. There are no new ESPA ER content requirements in RG 4.2, Revision 3, or DG-4032 regarding surface water use. Updates to the data in this section of the North Anna ESPA ER are required to reflect current conditions using publicly available and site-specific data.
VDEQ Water Supply Planning Regulation 9 VAC 25-780 was approved with an effective date of October 9, 2024. Surface water withdrawal data and planned future surface water withdrawals should be updated using data from the most recent Annual Water Resources Report and Virginia State Water Resources Plan. Data from these reports/plans can be used to update Table 2.3-4, Consumptive Surface Water Users, in the Affected Hydraulic System and Table 2.3-5, Consumptive Surface Water Use Statistics for the Affected Hydrologic System.
Groundwater use is described in North Anna ESPA ER Section 2.3.2.2 and in FEIS Section 2.6.2.2. There are no new ESPA ER content requirements in RG 4.2, Revision 3, or DG-4032 regarding groundwater use. Updates to the data in this section of the North Anna ESPA ER are required to reflect current conditions using publicly available and site-specific data.
Local groundwater use o Update Louisa County groundwater use based on the most recent USGS national water use report and VDEQ Annual Water Resources Report.
o Updated permitted water supply wells in Louisa County and Table 2.3-11, Public Groundwater Supplies in Louisa County. There are no available maps of water supply well locations specific to Louisa County, and no wells were mapped within 2 miles of NAPS in the SLR ER using data from the USGS. Review USGS data Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 36 of 77 May 2025 to determine whether there are additional water supply wells in Louisa County since the 2020 SLR ER was completed.
o Determine whether there have been any regulatory groundwater withdrawal limit exceedances in Louisa County since the ESPA ER was completed and update as needed.
o Groundwater withdrawal data and planned future groundwater withdrawals should be updated using data from the most recent VDEQ water resources report and water resources plan.
Onsite groundwater use o Update the names and locations of active water supply wells, which are described in the SLR ER and ER Supplement and mapped in the SLR ER.
Update Figure 2.3-11, Existing Water Supply Wells.
o Update groundwater withdrawal rates and Table 2.3-12, North Anna Groundwater Use, with recent groundwater withdrawal data.
This section DOES need an update.
2.3.3 Water Quality There are no new ESPA ER content requirements in RG 4.2, Revision 3, or DG-4032. Updates to the data in this section of the North Anna ESPA ER are required to reflect current conditions using publicly available and site-specific data. The North Anna ESPA ER is further subdivided into descriptions of surface water and groundwater quality.
Surface water quality is described in North Anna ESPA ER Section 2.3.3.1 and in FEIS Section 2.6.3.1. There are no new ESPA ER content requirements in RG 4.2, Revision 3, or DG-4032 regarding surface water quality. Updates to the data in this section of the North Anna ESPA ER are required to reflect current conditions using publicly available and site-specific data.
The VDEQ reissued Permit No. VA0052451 on March 13, 2024. There were no changes in the reissued permit regarding the requirement for continuous temperature monitoring at 11 stations. An update to Table 2.3-7, Daily Water Temperature Statistics, for Lake Anna and Figure 2.3-13, Temporal Variation in Lake Anna Water Temperature at Selected Locations is needed. Also, information regarding Clean Water Act (CWA)
Section 401 water quality certification from the reissued permit should be updated.
VDEQs list of 303(d) impaired waters is updated every 2 years. An update of the description of aquatic environmental stressors and the source and nature of existing impairments is needed.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 37 of 77 May 2025 The CWA 316(a) demonstration report was updated in 2018 and described in the SLR ER. An update to the water quality data in Table 2.3-13 is necessary.
Groundwater quality is described in North Anna ESPA ER Section 2.3.3.2 and in FEIS Section 2.6.3.2. There are no new ESPA ER content requirements in RG 4.2, Revision 3, or DG-4032 regarding groundwater quality. Updates to the data in this section of the North Anna ESPA ER are required to reflect current conditions using publicly available and site-specific data.
The North Anna ESPA ER states that there are no site-specific data available to establish physical, chemical, and biological water quality characteristics of groundwater at the ESP site. Table 3.6-9a of the SLR ER includes water quality data for three onsite water supply wells collected in 2016 and 2017. Further, the NAPS Unit 3 COLA FSAR includes groundwater chemistry test data collected in 2007. Add groundwater quality data collected from onsite wells.
The USGS National Water Quality Assessment Program periodically publishes groundwater reports for aquifers across the United States. Update Table 2.3-14, Water Quality Data, for the Piedmont Crystalline Aquifers with data from the most recent groundwater quality report for piedmont aquifers in the eastern United States.
RG 4.2, Revision 3, and DG-4032, Section 2.2.4, include descriptions of the pre-application monitoring program. Monitoring at North Anna is described in North Anna ESPA ER Section 2.3.3.1 and 2.3.3.2 and in FEIS Sections 2.6.1.3, 2.6.3.3, and 2.6.3.4. Flow measurements from the existing units at NAPS are collected as required in the VPDES permit, and there are USGS streamflow gauges near the plant. Any updates to monitoring programs are included in the updates listed in subsections to Section 2.3 of this white paper.
This section DOES need an update.
2.4 Ecology North Anna ESPA ER Section 2.4.1 will require revisions.
North Anna ESPA ER Section 2.4.1.6 should be updated based on recent ESA-listed species evaluations under Section 3.8.1.2 of the 2024 SEIS. Species in this evaluation include northern long-eared bat, tricolored bat, Monarch butterfly, and dwarf wedge mussel (to be included in 2.4.2 Aquatic Ecology below).
Virginia Department of Game and Inland Fisheries (VDGIF) has been renamed Department of Wildlife Resources (DWR). State species listed in Sections 2.4.1.6, 2.4.1.7, and 2.4.1.9 of the North Anna ESPA should be updated based on Section 3.6.3 of the 2024 North Anna SEIS and reviewed using resources available through State and federal agency websites.
In addition, identification and description of the U.S. Environmental Protection Agency ecoregion following NRC RG 4.2, Revision 3, should be included. This information is publicly available.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 38 of 77 May 2025 This section DOES need an update.
2.4.1 Aquatic Ecology North Anna ESPA ER Section 2.4.2 will need revisions.
North Anna ESPA ER Section 2.4.2 will need updated based on recent species information, including ESA (e.g., dwarf wedgemussel), State-protected, and nuisance species provided in the 2024 SEIS. This will include a review of the SEIS as well as publicly available information through U.S. Fish and Wildlife Service (USFWS), VA DWR (formerly VDGIF), and other relevant agencies.
Information in North Anna ESPA ER Section 2.4.2 related to recent years should also be validated and updated if applicable (e.g., Lake Anna temperatures in Section 2.4.2.). This information can be retrieved from publicly available studies, including the annual Environmental Study of Lake Anna and the Lower North Anna River reports.
This section DOES need an update.
2.5 Socioeconomics As stated in RG 4.2, Revision 3, and DG-4032, the ER should provide data and information to establish the environmental baseline for socioeconomics including the 50-mile region and an economic region defined by the counties where most of the economic activities related to the plant occur. The North Anna ESPA ER, the NAPS SLR ER, and NUREG-1437, Supplement 7, contain updated information that can be used to supplement this section. The following section describe the information that needs to be updated.
2.5.1 Demography RG 4.2, Revision 3, and DG-4032 suggest that reasonable population projections for the 50-mile region and a discussion of the methodologies used to produce the projection should be provided. The North Anna ESPA offers a growth rate-based approach that used a growth rate derived from the 1990 and 2000 U.S. Census data. The NAPS SLR presented information from U.S. Census for 2010 and state sources for projection information that were based on the 2010 U.S. Census. The 2020 U.S. Census count data are available as well as population projection information based on 2020 U.S. Census data.
In addition to the population projections, the population in sector format, population density, and the low population zone can be updated. Other information such as county demographic information, principal city information, and population centers can also be updated with later census data.
This section DOES need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 39 of 77 May 2025 2.5.2 Community Characteristics RG 4.2, Revision 3, and DG-4032 suggest providing detailed information covering the site labor force, housing, current and historic economic base, education, government services such as police, fire, utilities, zoning, and tax revenue. Applicable updated information is reported in the North Anna SLR ER and NUREG-1437, Supplement 7, which can be used to supplement this section.
This section DOES need an update.
2.5.3 Historic Properties Updated information in the NAPS SLR ER and NUREG-1437, Supplement 7, can be used to update this section with recent information.
This section DOES need an update.
2.5.4 Environmental Justice RG 4.2, Revision 3, and DG-4032 recommend using the latest American Community Survey (ACS) 5-year data to identify U.S. Census Block Groups that contain minority and low-income populations. The North Anna ESPA was written prior to the development of the ACS. The NAPS SLR ER reported ACS data for the 5-year (2012-2016) timeframe. Currently, the ACS 5-year 2018-2022 data is available. The ACS 5-year 2019-2023 data is scheduled to be available in December of 2024. This section will need to be updated with the more recent ACS information.
This section DOES need an update.
2.6 Geology The North Anna ESPA ER was written to RG 4.2, Revision 2, which includes in Section 2.5, a description of major geological aspects of the site and its immediate environs in a level of detail corresponding with proposed station design. RG 4.2, Revision 3, and DG-4032 do not include a separate description of geology within the affected environment chapter. The description of aquifers and confining units in Section 2.2.1 of RG 4.2, Revision 3, and DG-4032 includes a description of geology from a hydrogeological standpoint, which is provided in Section 2.3.1.2 of the North Anna ESPA ER and Section 2.4 of the FEIS.
In Section 2.6 of NUREG-1555, there are no data and information needs or acceptance criteria regarding geology. It is stated that the NRC would incorporate by reference descriptions of site and vicinity geology in the environmental impact statement (EIS) from the safety evaluation report (SER) or site safety evaluation report (SSER).
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 40 of 77 May 2025 There is no regulatory requirement to include or update this section in the North Anna ESPA ER. Further, geologic, seismologic, and geotechnical data are included in the NAPS Unit 3 COLA FSAR Revision 9.
This section DOES NOT need an update.
2.6.1 Geological Conditions As described in Section 2.6 of this white paper, RG 4.2 and NUREG-1555 do not require descriptions of geology in an ESPA ER.
This section DOES NOT need an update or inclusion in the North Anna ESPA ER.
2.6.2 Seismological Conditions As described in Section 2.6 of this white paper, RG 4.2 and NUREG-1555 do not require descriptions of geology in an ESPA ER.
This section DOES NOT need an update or inclusion in the North Anna ESPA ER.
2.6.3 Geotechnical Conditions As described in Section 2.6 of this white paper, RG 4.2 and NUREG-1555 do not require descriptions of geology in an ESPA ER.
This section DOES NOT need an update or inclusion in the North Anna ESPA ER.
2.6.4 Environmental Impact Evaluation This section of the North Anna ESPA ER includes additional detail to the information provided in Sections 2.6.2 and 2.6.3 of the ESPA ER and assessments of potential impacts to the site to plant structures from various potential sources, including geotechnical properties of soils, offsite mining, seismological impacts, and onsite excavation. This section of the North Anna ESPA ER concluded that either impacts would be small or that no impacts would be anticipated.
Section 2.6 of NUREG-1555 specifies that the potential for geological impacts is small and will be evaluated as part of the safety evaluation. As described in Section 2.6 of this white paper, RG 4.2, Revision 3, DG-4032, and NUREG-1555 do not require descriptions of geology in an ESPA ER.
This section DOES NOT need an update or inclusion in the North Anna ESPA ER.
2.7 Meteorology and Air Quality New meteorological data will be considered representative of the meteorological data used in the North Anna ESPA if the average wind direction and speed, the wind direction persistence, Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 41 of 77 May 2025 and the atmospheric stability are consistent. In the event the more recent meteorological data is determined to not be representative of the meteorological data used in the North Anna ESPA, the new data will be used in the North Anna ESPA renewal.
2.7.1 General Climate RG 4.2, Revision 3, and DG-4032 state in Subsection 2.7.1 that Summaries of onsite monthly and annual wind roses and comparisons to nearby representative stations using the wind speed classes defined of RG 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, for a consecutive 24-month period of data that is not older than 10 years from the date of the application (and preferably three or more years of data if available) should be provided. This information is not provided in the North Anna ESPA, the NAPS SLR ER, or the NAPS COLA.
This data will have to be added to the ESPA.
RG 4.2, Revision 3, and DG-4032 state in Subsection 2.7.1 that, "Summaries of onsite monthly and annual precipitation and snowfall amounts and comparisons to climatic averages and extremes be provided. Typically, snowfall is not measured onsite so the ESPA will have to take exception to this and provide alternative data.
New meteorological data will be considered representative of the meteorological data used in the North Anna ESPA if the average wind direction and speed, wind direction persistence, and the atmospheric stability are consistent. If the new meteorological data is determined to be representative, a brief discussion will be added to the North Anna ESPA detailing the process used to confirm the meteorological data is consistent.
If the new meteorological data is determined to be inconsistent and not representative of the meteorological data used in the North Anna ESPA, the new meteorological data will be used in an update to the short term and long-term diffusion estimates. The SSAR Chapter 15 site specific X/Q values may also be updated.
RG 4.2, Revision 3, and DG-4032 also recommend a discussion of climate change as follows:
Discussion of potential climate change in the vicinity of the site over the period encompassing the licensing action and impacts on relevant meteorological parameters (e.g., temperature, precipitation, and the frequency and severity of storms). A climate change discussion is not provided in the North Anna ESPA and will need to be added.
This section DOES need an update.
2.7.2 Regional Air Quality RG 4.2, Revision 3, and DG-4032 recommends a discussion of greenhouse gases which is not provided in the North Anna ESPA. This will have to be added and the current description of site and regional air quality, nonattainment areas, and location of nearest Mandatory Class 1 areas will need to be confirmed with current data.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 42 of 77 May 2025 This section DOES need an update.
2.7.3 Severe Weather RG 4.2, Revision 3, and DG-4032 recommends a discussion of severe weather but does not specify a time period over which the data is obtained. The North Anna ESPA may be acceptable. Meteorological extremes should be updated or confirmed based on recent data.
This section MAY need an update.
2.7.4 Local Meteorology The acceptance criteria of NUREG-1555 states that, At least one annual cycle from the onsite meteorological program should be used to relate local meteorological conditions to local and regional climatology. However, RG 4.2, Revision 3, and DG-4032 state that, The applicant should provide meteorological data from at least two consecutive annual cycles (and preferably three or more entire years), including the most recent one-year period, at the time of application submittal."
RG 1.23 indicates that the minimum amount of onsite meteorological data to be provided at the time of an ESPA is a consecutive 24-month period of data that is defendable, representative, and complete, but not older than 10 years from the date of the application.
This North Anna ESPA Renewal ER section may require an update if new meteorological data is not considered representative of the data used in the application.
This section MAY need an update.
2.7.5 Short-Term Diffusion Estimates If the current meteorological data is determined to be inconsistent and not representative of the meteorological data used in the North Anna ESPA, the new meteorological data will be used in an update to the short term and long-term diffusion estimates. The site-specific X/Q values may also be updated along with Chapter 7.
This section MAY need an update.
2.7.6 Long-Term (Routine) Diffusion Estimates If the current meteorological data is determined to be inconsistent and not representative of the meteorological data used in the North Anna ESPA, the new meteorological data will be used in an update to the short term and long-term diffusion estimates. The site-specific X/Q values may also be updated along with Chapter 7 and SSAR Chapter 15.
This section MAY need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 43 of 77 May 2025 2.8 Related Federal Project Activities The NAPS SLR ER Section E3.1.4 reviewed federal and non-federal related project activities within the NAPS vicinity through February 2019. The North Anna ESPA Renewal ER will need to be updated to include a desktop level review of any new identified related federal projects since 2019 through the time of ER development.
This section DOES need an update.
2.9 Noise There is no comparable general characterization section on noise in the North Anna ESPA ER.
The NAPS SLR ER includes summary information about onsite noise associated with the existing operating nuclear plant in Section E3.4. This information was further updated in the NAPS SLR ER Supplement. Noise related impacts were discussed in the North Anna ESPA ER Section 4.4.1.2.1, 4.4.1.3 and 5.3.3.2.3.
For the North Anna ESPA Renewal ER, baseline information on noise, utilizing the NAPS SLR ER information, and identification of any sensitive offsite receptors will need to be evaluated.
This section DOES need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 44 of 77 May 2025 3.0 PLANT DESCRIPTION RG 4.2, Revision 3, and DG-4032 suggest that the ESPA ER provide a description of the proposed action that includes a description of the site layout, design, and activities required to construct and operate the plant and associated structures and facilities. North Anna ESPA ER Section 3.0 introduces the plant design, and in its place a list of parameters describing a bounding plant design, the PPE.
North Anna ESPA ER Chapter 3.0 follows the outline of NUREG-1555, Revision 0, with supplemental information from RG 4.2, Revision 2. The following sections were reviewed with consideration to the information suggested by RG 4.2, Revision 3, and DG-4032.
In addition, this section does require an update to include information suggested by RG 4.2, Revision 3, and DG-4032. Consideration should be given to amend Chapter 3 of the North Anna ESPA ER to include sections on building activities and operational activities.
Information described in these sections may be contained in existing sections of North Anna EPSA ER Chapter 3, NAPS Unit 3 COLA, and EIS for an ESP at the North Anna ESP Site (North Anna ESP EIS). The following new sections should be developed for the North Anna ESPA Renewal ER.
RG 4.2, Revision 3, suggests a section on building activities, which should include a description of activities needed to build or install the proposed structures and associated facilities described in the section on Proposed Plant Structures, Systems, and Components. This section should include the sequencing and estimate duration of activities and include considerations for seasonal constraints on building activity.
RG 4.2, Revision 3, suggests a section on operational activities, which should include these subsections: plant-environment interfaces during operation, radioactive waste management, and nonradioactive waste management.
3.1 External Appearance and Plant Layout RG 4.2, Revision 3, and DG-4032 suggest providing a description of the overall appearance of the proposed plant and all associated facilities to assess the physical scope of the proposed project and visual impacts. This information is partially provided in the North Anna ESPA ER in the following subsections.
3.1.1 Existing Site Development RG 4.2, Revision 3, and DG-4032 suggest that the ESPA ER provides a description of the relationship between the proposed plant and any existing units, structures, or facilities, including any removal or modification of existing structures. Topographic maps of the proposed site and vicinity showing the layout of the proposed plant relative to the site and vicinity including the EAB, site boundary, waterbodies, existing and planned roads, rail lines, and utility corridors. The North Anna ESPA ER Section 3.1.1 provides a description of the existing NAPS units. The Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 45 of 77 May 2025 existing NAPS site development is shown in Figure 3.1-1. This figure should be reviewed and updated to include a topographic map and reflect any relocated support buildings or development that has occurred since the 2006 North Anna ESPA ER. This information can be collected from the NAPS SLR ER.
This section DOES need an update.
3.1.2 Power Plant Design DG-4032 suggests that the ESPA ER provides a description of the proposed plant including the design and layout of the proposed facilities. North Anna ESPA ER Section 3.1.2 describes the PPE approach presented to envelop the ESP site development. The section also includes module and new unit descriptions.
This section DOES NOT need an update.
3.1.3 Generic Plant Parameters Envelope DG-4032 suggests that the ESPA ER provides a description of the proposed plant and all associated facilities including any proposed new structures or structure modifications. North Anna ESPA ER Section 3.1.3 provides a description of the Generic PPE that was developed for the ESP and references and incorporates PPE bounding site characteristics and design parameters from Section 1.3 of the North Anna ESPA SSAR.
This section DOES NOT need an update.
3.1.4 Plant Appearance DG-4032 suggests that the ESPA ER provides a description of the proposed plant and provide representative photographs of the site with major station features and architectural renderings of the proposed project. North Anna ESPA ER Section 3.1.4 provides a written description of this information and an architectural rendering in Figure 3.1-3.
This section DOES NOT need an update.
3.1.5 Site Development and Improvements DG-4032 suggests that the ESPA ER provides a description of the proposed plant and all associated facilities including any proposed new structures or structure modifications. North Anna ESPA ER Section 3.1.5 provides a description of the developments and improvements to the ESP site. This section references dry and wet cooling towers for Unit 3 and dry cooling towers for Unit 4. The NAPS COLA ER references the closed-cycle, hybrid cooling system described in North Anna ESPA ER Section 3.4.
This section DOES NOT need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 46 of 77 May 2025 3.1.6 Bounding Site-Specific Plant Parameters Envelope The North Anna ESPA ER Section 3.1.6 provides a description of the bounding site-specific PPE that are established by analyses presented in the ESPA ER and summarized in Table 3.1-
- 9. It is understood that no changes to the PPE is anticipated.
This section DOES NOT need an update.
3.2 Reactor Power Conversion System The North Anna ESPA ER was written to RG 4.2, Revision 2, and NUREG-1555, Revision 0, which includes a section on the reactor-power-conversion system. RG 4.2, Revision 3, and DG-4032 deviates from the NUREG outline, suggesting the title of Section 3.2, Proposed Plant Structures, Systems, and Component. The guidance documents suggest that this section of the ESPA ER provides a description of the overall proposed nuclear energy generating system to assist in the evaluation of environmental impacts resulting from the project. This section should include a description of the reactor-power-conversion system and a description of all proposed plant SSCs. The North Anna ESPA ER provides this information in the following sections.
3.2.1 Reactor Description RG 4.2, Revision 3, and DG-4032 suggest providing a description of the reactor-power-conversion system, including the manufacturer and the design status. The section should also include the number of units and description of each reactor, the reactor type, architect-engineer, contractor, fuel assembly description, total quantities of uranium, and percentage uranium-235 enrichment. North Anna ESPA ER Section 3.2.1 provides a description of the proposed reactors. As there are no proposed changes to the reactor designs considered in the PPE, no updates to this section are anticipated.
This section DOES NOT need an update.
3.2.2 Engineered Safety Features The North Anna ESPA ER Section 3.2.2 describes engineered safety systems that could be used at the ESP site. This section was written to RG 4.2, Revision 2, and NUREG-1555, Revision 0, which includes a description of the engineered safety features. RG 4.2, Revision 3, and DG-4032 do not include a discussion of the engineered safety features; however, NUREG-1555, Revision 0, includes engineered safety features as data and information needs for the section on the reactor-power-conversion system. As there are no proposed changes to the reactor designs considered in the PPE, no updates to this section are anticipated.
This section DOES NOT need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 47 of 77 May 2025 3.2.3 Power Conversion Systems RG 4.2, Revision 3, and DG-4032 suggest providing a description of the reactor-power-conversion system turbine and condensers. NUREG-1555, Revision 0, expands the description of the turbines and condensers to include tubing material and total heat transfer area. This information is discussed in the North Anna ESPA ER Section 3.2.3, which provides a general description of the turbine and condensers and includes statement on tubing material. As there are no proposed changes to the reactor designs considered in the PPE, no updates to this section are anticipated.
This section DOES NOT need an update. No change to this section is needed unless the proposed technologies change.
3.3 Plant Water Use The North Anna ESPA ER was written to RG 4.2, Revision 2, and NUREG-1555, Revision 0, to include a description of the plant water use, water consumption, and water treatment in Section 3.3 and its subsections. This section is comparable to Section 3.4.1 of RG 4.2, Revision 3, and DG-4032 suggest providing a description of the plant-environment interfaces during operation relating to water interfaces. As there are no proposed changes to the reactor designs considered in the PPE, no updates to this section are anticipated.
This information contained in this section DOES NOT need an update.
3.4 Cooling System The North Anna ESPA ER Section 3.4.1 was written to Section 3.4.1 of NUREG-1555, Revision 0, to include a description of the proposed plant cooling system and its operational modes. This information should include a system description, a description of anticipated operational modes, and for each operational mode the quantities of heat generated, dissipated to the atmosphere, and released in liquid discharges. This should also include a description of the water source and quantities of water withdrawn, consumed, and discharged including the status of the NPDES permit and any 316 (a/b) demonstrations.
The North Anna ESPA ER Section 3.4.2 was written to Section 3.4.2 of NUREG-1555, Revision 0, to include a description of the proposed intake, discharge, and heat dissipation system design and performance characteristics.
Section 3.2 and Section 3.4.1 of RG 4.2, Revision 3, and DG-4032 suggest that the ESPA ER include descriptions of heat-dissipation systems, the creation or modification of any water storage (reservoir) or cooling pond, water-intake system, water discharge system, and other water systems. This information is included in North Anna ESPA ER Section 3.4.
This section DOES NOT need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 48 of 77 May 2025 3.5 Radioactive Waste Management System The North Anna ESPA ER Section 3.5 was written to Section 3.5 of NUREG-1555, Revision 0, to include a description of the design of the radioactive waste management and effluent control systems. This section is comparable to Section 3.4.2 of RG 4.2, Revision 3, and DG-4032. As there are no proposed changes to the reactor designs considered in the PPE, no updates to this section are anticipated.
This section DOES NOT need an update.
3.6 Nonradioactive Waste Systems The North Anna ESPA ER Section 3.6 was written to Section 3.6 of NUREG-1555, Revision 0, to include a description of the nonradioactive waste system including effluents containing chemicals or biocides, sanitary system effluents, and other effluents. This section is comparable to Section 3.4.3 of RG 4.2, Revision 3, and DG-4032. As there are no proposed changes to the reactor designs considered in the PPE, no updates to this section are anticipated.
This section DOES NOT need an update.
3.7 Power Transmission System The North Anna ESPA ER Section 3.7 was written to Section 3.7 of NUREG-1555, Revision 0, to include a description of design characteristics of the proposed power transmission system.
This section is comparable to descriptions suggested in Section 3.2 and Section 3.4.1 of RG 4.2, Revision 3, and DG-4032. As there are no proposed changes to the proposed transmission systems considered in the PPE and North Anna ESPA, no updates to this section are anticipated.
This section DOES NOT need an update.
3.8 Transportation of Radioactive Materials RG 4.2, Revision 3, states that, If the transportation of fuel and waste to and from nuclear power reactors meets the criteria listed in 10 CFR 51.52(a), the ER need only contain a statement that the environmental impacts are as set forth in Table S-4 of 10 CFR Part 51. This statement is in the North Anna ESPA ER and is anticipated to not change as part of the renewal application.
This section DOES NOT need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 49 of 77 May 2025 4.0 ENVIRONMENTAL IMPACTS OF CONSTRUCTION North Anna ESPA ER Section 4.0 will need a revision. The updates in this section will be based on the changes made throughout Chapter 5 of the North Anna ESPA ER renewal. Further, definitions of impacts significance in accordance with 10 CFR Part 51 (i.e., SMALL, MODERATE, LARGE) should be added.
This section DOES need an update.
4.1 Land-Use Impacts 4.1.1 The Site and Vicinity Section 4.1.1 of the North Anna ESPA ER will need a revision. Specifically, information updated in Section 2.2.1 above related to land cover, land use, active mines, and population sizes, and other relevant information will need updated in this section, accordingly. This information can be obtained using the NUREG-1437, Supplement 7, and other publicly available information.
Figures associated with land use will subsequently need updated.
This section DOES need an update.
4.1.2 Transmission Corridors and Offsite Areas There are no anticipated changes to transmission corridors as described in the North Anna ESPA.
This section DOES NOT need an update.
4.1.3 Historic Properties and Cultural Resources If Section 2.5 is updated with new historic and cultural resource sites, the potential construction related impacts to those sites would need to be evaluated and updated in this section. If no changes from the ESPA are identified, this section will not need an update.
This section MAY need an update.
4.2 Water-Related Impacts Data updates for Section 4.2 are summarized in the following subsections. There are no changes in content for water/hydrology impacts associated with building activities between RG 4.2, Revision 3, and DG-4032.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 50 of 77 May 2025 4.2.1 Hydrologic Alterations Hydrologic alterations are described in North Anna ESPA ER Section 4.2.1 and FEIS Section 4.3.1. This section of the North Anna ESPA ER is further subdivided with subsections describing surface water and groundwater alterations and mitigation measures to reduce adverse impacts.
Surface water impacts from hydrologic alterations are described in North Anna ESPA ER, Section 4.2.1.1. The North Anna ESPA ER needs updates based on the information provided in the NAPS Unit 3 COLA ER Section 4.2.1.1 and Appendix 4A. Updates from the Unit 3 COLA ER are summarized as follows.
In the North Anna ESPA ER, it is stated that hydrologic alterations would occur to two ephemeral streams, A and B. The NAPS Unit 3 COLA ER reports that Unit 3 construction activities would alter two ephemeral streams, Streams B and C. Once construction is complete, the area would continue to drain to wetlands through stream beds to Lake Anna. Impacts would be small. An update to Figure 4.2-1 is recommended to show the three ephemeral streams (A, B, and C), and the PJM System Impact Study should be referenced.
An additional transmission line would be required as a system reinforcement associated with the interconnection of Unit 3. The new transmission line would be installed on an existing corridor.
Impacts to wetlands and shorelines from construction of overhead transmission lines and towers would be minimized with various practices and procedures. Permits and approvals, if required, would be obtained from the USACE and other appropriate agencies, as necessary. No significant hydrologic alterations are anticipated from installation of the new transmission line and impacts to surface water would be small.
As presented in the NAPS Unit 3 COLA ER, Appendix 4A and 4A.5, Dominion Energy owns approximately 111 acres of property contiguous to the existing NAPS site, which will be used to provide supplemental space for Unit 3 construction activities, such as laydown areas, spoils storage, and access roads. Wetlands and streams on this offsite property were delineated.
Approximately 133,700 square feet of wetlands within the property will be impacted by spoils storage, material laydown, and aggregate storage. Impacts to wetlands are expected to be moderate. Most wetland areas were located in valleys with intermittent or perennial streams totaling approximately 3,700 linear feet. Impacts of streams are expected to be small.
Dominion plans to develop a mitigation plan to minimize impacts to wetlands and streams.
Mitigation measures considered to compensate for stream and wetland losses may include preservation of other onsite streams or purchasing credits from an approved mitigation bank.
Any structures installed on the offsite property are planned to be removed and the area would be stabilized.
The Virginia Stormwater Management Handbook was updated to Version 1.1, effective July 1, 2024. The reference should be updated. It is noted that the Virginia Erosion and Stormwater Management Regulation (9VAC25-875-10 through 9VAC25-875-1420, effective July 1, 2024, combines the requirements in the Virginia Stormwater Management Program Regulation, the Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 51 of 77 May 2025 Erosion and Sediment Control Regulations, and Erosion and Sediment Control and Stormwater Management Certification Regulations.
Groundwater impacts from hydrologic alterations are described in North Anna ESPA ER Section 4.2.1.2. Dewatering is required during construction in excavations extending below the water table until construction is raised to a point above the water table and backfill is placed in the excavation.
The NAPS Unit 3 COLA ER Section 4.2.1.2 indicates there are plans to install five domestic water wells within the EAB: two for batch plant operations, and three domestic water wells to be part of the permanent potable water system, two of which are expected to be used during construction activities. The expected average aggregate water withdrawal rate on the construction wells is approximately 130 gallons per minute (gpm). As described in the NAPS Unit 3 COLA ER, Appendix 4A.6, two or three domestic wells are planned to be installed on an offsite property contiguous with the existing NAPS site to provide supplemental space for Unit 3 construction activities. The wells will provide water to support construction activities and are expected to have a water withdrawal rate of approximately 2 gpm each. The North Anna ESPA Renewal ER should be updated to include these additional water supply wells.
This section DOES need an update.
4.2.2 Water-Use Impacts Water use requirements and impacts for construction activities are described in North Anna ESPA ER Section 4.2.2 and FEIS Section 4.3.2. The North Anna ESPA ER includes a discussion of water use impacts to surface water and groundwater.
No new and significant information was identified in the NAPS Unit 3 COLA ER Section 4.2.2. It is noted, however, that Section 4.2.2 of the North Anna ESPA ER indicates that construction activities for the new units would be limited to the ESPA site adjacent to Lake Anna, but as summarized in Section 4.2.1 of this white paper, there are plans to use an offsite contiguous property to provide supplemental space for Unit 3 construction activities, including installation of two water supply wells. This information should be added to the North Anna ESPA ER.
Surface water and groundwater users that could be impacted by changes in the quantity and/or availability of water from hydrologic alterations preconstruction and construction activities are identified Section 4.2.2 of the North Anna ESPA ER and Section 4.3.3 of the FEIS. The North Anna ESPA ER requires updates to reflect current conditions. Any additional surface water or groundwater users should also be identified in this section of the North Anna ESPA ER.
RG 4.2, Revision 3, and DG-4032, Sections 4.2.3 and 4.2.4, include discussions of water quality impacts and a plan for protecting waterbodies that may be affected by building activities.
Section 4.2.2 of the North Anna ESPA ER includes a brief discussion of water quality impacts and planned use of an Erosion and Sediment Control Plan, an approved construction storm water pollution prevention plan (SWPPP), and compliance with applicable permit requirements Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 52 of 77 May 2025 to minimize impacts to water quality. The FEIS Section 4.3.3 does not identify additional water quality impacts.
This section DOES need an update.
4.2.3 Future Growth and Development Impacts This section of North Anna ESPA ER describes projected future surface water and groundwater availability for several counties within the North Anna River basin and the impact of future growth and development on regional water use and water budget. The NAPS Unit 3 COLA ER Section 4.2.3 did not identify new and significant information for this section.
There is no corresponding section in the FEIS. An assessment of projected water availability in the regional watershed is not included RG 4.2, Revision 3, or DG-4032, Section 4.2. There is no regulatory basis to include this section in the North Anna ESPA ER.
The effects of reasonably foreseeable changes in the hydrologic environment (e.g., climate, land use, and water use) over the duration of the license for the resource impact area are included in Section 5.2 of RG 4.2, Revision 3, and DG-4032.
As described in Section 2.3.2 of this white paper, the VDEQ publishes a Virginia State Water Resources Plan. The most recent version was published in 2020 and includes projected surface water and groundwater demands through 2040. The Virginia State Water Resources Plan is updated every 5 years.
This section DOES need an update.
4.3 Ecological Impacts 4.3.1 Terrestrial Ecosystems North Anna ESPA ER Section 4.3.1 will need to be updated based on any updated information provided in Section 2.4.1. This includes a review of important species, USFWS threatened and endangered species, USFWS critical habitat, and other terrestrial ecological resources.
North Anna ESPA ER information related to avian-related mortality (including bats) needs to be updated in accordance with 2024 SEIS. The North Anna ESPA ER states that there have been no avian collisions with existing structures; however, the 2024 NAPS SEIS reports 26 avian deaths between 2013-2022 near structures and over the site. Further, information related to bird or bat incidents would need updated to capture those that have occurred since the 2024 SEIS, if applicable. The 2006 ESPA states that 80 acres of forest will need to be removed. This assumption should also be confirmed as potential impacts to newly listed species are considered.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 53 of 77 May 2025 Per RG 4.2, Revision 3, effects on each terrestrial identified as important that occurs onsite, including ESA listed species, should be analyzed using the criteria in Table 2-1 of the guideline document.
This section DOES need an update.
4.3.2 Aquatic Ecosystems The construction design information (e.g., intake structure dimensions, absence of modifications to shoreline or short intake channel, removal material estimate, etc.) described in the North Anna ESPA ER will need to be verified. If any changes to the original design are proposed, updates will need to likely be captured via a formal RFI.
Section 4.3.2 of the North Anna ESPA ER may need updated based on findings associated with Section 2.4.2 above. This includes updates to important species, threatened and endangered species, and critical habitat. This information can be retrieved from publicly available resources, including the NUREG-1437, Supplement 7 (2024).
Per NRC RG 4.2, Revision 3, effects on each aquatic species identified as important that occurs onsite, including ESA listed species, should be analyzed using the criteria in Table 2-1 of the guideline document. Further, any recent correspondence with federal and state agencies should be summarized if applicable.
This section DOES need an update.
4.4 Socioeconomic Impacts RG 4.2, Revision 3, and DG-4032 suggest describing the socioeconomic impacts that could occur in the region and counties associated with construction of a new nuclear facility. The following subsections should be updated if new information was provided in Section 2.5, above.
4.4.1 Physical Impacts According to RG 4.2, Revision 3, and DG-4032, the physical impacts of construction include impacts due to noise, air emissions, vibration, road realignment, road deterioration and the degradation of the aesthetic qualities of the area. If any of the applicable content in Chapter 2 is updated, construction-related impacts may also require an update here. If no changes are identified from what was discussed in the North Anna ESPA Section 4.4.1.2.1 and 4.4.1.3, then no updates to this section will be necessary.
This section MAY need an update.
4.4.2 Social and Economic Impacts RG 4.2, Revision 3, and DG-4032 suggest addressing impacts on the community from the inflow of construction workers, impacts of construction on local economies, impacts on Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 54 of 77 May 2025 infrastructure, traffic, recreation, housing, public services, and tax revenue. It has been identified that Section 2.5 will require an update. As such, it is anticipated that the construction related impacts associated evaluated using the updated information will need to be included in this section.
This section DOES need an update.
4.4.3 Environmental Justice Impacts RG 4.2, Revision 3, and DG-4032 suggests identifying the potential for a disproportionally high and adverse impact on environmental justice (EJ) populations due to construction impacts. EJ construction related impacts should be reanalyzed using the updated information that will be provided in Section 2.5.
This section DOES need an update.
4.5 Radiation Exposure to Construction Workers The North Anna ESPA ER Section 4.5.4 considers the dose to construction worker from the existing units. If any of that information has changed, then this section may require an update. If no changes are identified, then this section will not be updated.
This section MAY need an update.
4.6 Measures and Controls to Limit Adverse Impacts During Construction Table 4.6-1 lists the elements identified in NUREG-1555, Section 4.6, that relate to potential adverse environmental impacts of construction and the measures and controls selected to limit adverse impacts.
RG 4.2, Revision 3, and DG-4032, Section 4.11 recommend providing details of the programs planned to monitor activities affecting site-related environmental resources and quality during construction. Using information from other updated Chapter 4 sections, Table 4.6-1 should be updated to describe the measures designed to mitigate or reverse undesirable effects due to construction for each resource area.
This section DOES need an update.
4.7 Cumulative Impacts Related to Construction Activities The North Anna ESPA ER does not contain a comparable section; however, some of the information can be obtained from other ESPA sections (e.g., ESPA ER Section 4.5). NUREG-1555 directs the NRC staff to summarize the potential cumulative environmental impacts associated with construction activities for the proposed project. An assessment of cumulative impacts is also recommended per RG 4.2, Revision 3, and DG-4032. Furthermore, per CEQ Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 55 of 77 May 2025 guidelines, past, present, and reasonably foreseeable Federal, non-Federal, and private actions that could have meaningful cumulative impacts with the proposed project should be identified and described. It is recommended that this section be added.
This section DOES need an addition.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 56 of 77 May 2025 5.0 ENVIRONMENTAL IMPACTS OF STATION OPERATION The updates in this section will be based on the changes made throughout Chapter 2 of the North Anna ESPA ER renewal. Further, definitions of impacts significance in accordance with 10 CFR Part 51 (i.e., SMALL, MODERATE, LARGE) should be added.
This section description DOES need an update.
5.1 Land-Use Impacts 5.1.1 The Site and Vicinity Onsite and offsite impacts related to new information updated in Section 2.2.1, above, related to land cover, land use, active mines, and population sizes, and other relevant information will need updated in this section, accordingly. This information can be obtained using the NAPS SLR ER and NUREG-1437, Supplement 7, and other publicly available information. Figures associated with land use will subsequently need updated.
This section DOES need an update.
5.1.2 Transmission Corridors and Offsite Areas There are no anticipated changes to transmission corridors or offsite areas as described in the North Anna ESPA.
This section DOES NOT need an update.
5.1.3 Historic Properties If Section 2.5 is updated with new historic and cultural resource sites, the potential operation related impacts to those sites would need to be evaluated and updated in this section. If no changes from the ESPA are identified, this section will not require an update.
This section MAY need an update.
5.2 Water-Related Impacts Data updates for Section 5.2 are summarized in the following subsections. There are no changes in content for water/hydrology impacts associated with station operation between RG 4.2, Revision 3, and DG-4032. These guidance documents include analyses of hydrologic alterations, water use impacts, water quality impacts, and a description of the plan to protect waterbodies that may be affected by station operations. These elements are included in the North Anna ESPA ER, as described below; however, Section 5.2 of RG 4.2, Revision 3, and DG-4032 indicate the applicant should consider the effects of reasonably foreseeable changes in the hydrologic environment (e.g., climate, land use, and water use) over the duration of the license for the resource impact area. Section 4.2.3 of the North Anna ESPA ER includes a Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 57 of 77 May 2025 summary of future growth and development impacts. As described in Section 2.3.2 of this white paper, the VDEQ publishes a Virginia State Water Resources Plan, which is updated every 5 years. Impacts on current and future water supplies should be incorporated into the impact analysis in Section 5.2.2.
5.2.1 Hydrologic Alterations and Plant Water Supply The operational activities considered Section 5.2.1.1 through 5.2.1.5 of the North Anna ESPA ER include surface water withdrawals for plant cooling, consumptive loss from Unit 3 wet cooling tower operation (evaporation and drift), returns of cooling water, and cooling tower blowdown. The identified hydrologic alterations were a reduction of volume of water available to release from the North Anna Dam and reductions of reservoir water levels during periods of extended drought due to operation of the Unit 3 wet cooling towers.
As described in the NAPS Unit 3 COLA ER Sections 5.2.1 and 5.10.1.3, an additional mitigation action of increasing the normal pool level of Lake Anna by 3 inches to 250.25 feet MSL to reduce the potential frequency of occurrence and duration of low-flow conditions was considered. An Instream Flow Incremental Methodology (IFIM) study was performed, which resulted in different evaporation rates from operation of the Unit 3 cooling towers. It was concluded that a higher normal pool elevation would introduce small changes to the physical attributes and hydrologic characteristics of the lake, but that the impacts of these hydrologic alterations would be small. Updates are required to include the impacts associated with this additional mitigation measure.
This section DOES require an update.
5.2.2 Water-Use Impacts Water use impacts are described in Section 5.2.2 of the North Anna ESPA ER. A water balance model was developed to assess the impacts of adding the new units. Because operation of the Unit 4 cooling system would have no measurable impact on water availability, the model considered evaporation of cooling water from operation of Unit 3 only.
As described in Section 5.3.2 of the FEIS, the NRC concluded that during normal water use, water use impacts, including impacts on downstream users, would be small. During severe droughts, however, the impact to the water level could be temporarily moderate. As indicated in the NAPS Unit 3 COLA ER, Table 3.0-2 and Section 5.10.1.3, an IFIM study was conducted including data through October 2007, whereas the North Anna ESPA ER included data through April 10, 2003, and the study evaluated the impacts of raising the pool level elevation of Lake Anna to mitigate the impacts of water use during low-flow conditions.
Using data collected through October 2007, the IFIM study calculated higher Unit 3 cooling tower evaporations rates with and without a normal pool elevation increase. The calculated evaporation rate without a normal pool level increase exceeded the ESP value due to Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 58 of 77 May 2025 incorporation of more recent data. The evaporation rate with an increased pool elevation was higher; however, the impact to water user of raising the pool elevation was small.
These results of the IFIM study and impacts on water use should be included in the North Anna ESPA ER. An update to the IFIM study may be required to reflect more recent conditions in Lake Anna, changes in water use since October 2007, and anticipated changes in water use over time, as described in the Virginia State Water Resources Plan, may be included in the evaluation.
Water quality impacts are described in Section 5.2.2.3 of the North Anna ESPA ER. The primary impact on water quality was identified as discharge of Unit 3 cooling tower blowdown, which would include elevated levels of dissolved solids, various anti-fouling chemicals, and a small amount of waste heat. In the FEIS Section 5.3.3, the NRC concluded that thermal impacts from operation on Units 3 and 4 would be negligible (<0.1°F); however, the impact of water treatment systems was not included in the analysis since a design had not been selected.
In the NAPS Unit 3 COLA ER Sections 3.3 and 3.6, water treatment and nonradioactive effluents, including sanitary waste from a separate Unit 3 sanitary waste treatment system and cooling tower blowdown, were included in the Unit 3 design, and the impacts were identified in Section 5.2.2 and compared to the Virginia Surface Water Quality Criteria, and VPDES permit water quality criteria, as applicable. The results of the effluent analysis demonstrated that constituent concentrations would remain within VPDES permit water quality criteria, except two constituents, which are already present in lake water at concentrations greater than or equal to the current VPDES water quality criteria. The North Anna ESPA ER requires an update to incorporate the Unit 3 water treatment and effluent evaluation. Further, the Virginia Water Quality Standards (9 VAC 25-260) were updated with an effective date of April 18, 2023, and the VPDES permit was reissued in 2024. The impacts should be evaluated to these more recent standards and permit conditions.
Regulatory compliance and practices to minimize water quality impacts are described in Sections 5.2.2.4 and 5.2.2.5 of the North Anna ESPA ER. These sections specify that compliance would be demonstrated in the COL application and modification of the VPDES permit and that thermal discharges are subject to CWA Section 316(a) regulations. The NAPS Unit 3 COLA ER Sections 5.2.2 and 5.10 indicates that water quality impacts of Unit 3 effluent would be mitigated by operation of a dechlorination system and VPDES permit limits. These sections should be updated to include the information in the NAPS Unit 3 COLA ER.
This section DOES require an update.
5.3 Cooling System Impacts There are no anticipated changes to the cooling system impacts as there are no planned changes to the reactor designs considered as part of the PPE.
This section DOES NOT need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 59 of 77 May 2025 5.4 Radiological Impacts of Normal Operation Based on the information provided in Chapters 2, 4 and 5 above, and the offsite receptor information presented in the NAPS UFSAR, this section will be reviewed to see if updates are necessary. It is understood that the PPE and reactor designs described in the North Anna ESPA will not be updated.
This section MAY need an update.
5.5 Environmental Impact of Waste RG 4.2, Revision 3, and DG-4032 suggest that ESPA ER provides a description of the impacts of operating the proposed plant as required in 10 CFR 51.45(c). Because this is an overview section, it should outline the following sections (5.5.1 through 5.5.3). Therefore, updates to this section may be required.
This section MAY need an update.
5.5.1 Nonradioactive-Waste-System Impacts RG 4.2, Revision 3, and DG-4032 suggest that the ESPA ER provides a description of the environmental impacts that could result from the generation, handling, and disposal of nonradioactive waste during operation of the proposed plant. North Anna ESPA ER Section 5.5.1 provides a description of the environmental impacts from nonradioactive waste systems.
The information in this section can be reviewed with the NAPS SLR ER for consistency and may require updates.
This section MAY need an update.
5.5.2 Mixed Waste Impacts RG 4.2, Revision 3, and DG-4032 suggest that ESPA ER provides a description of the environmental impacts that could result from the generation, handling, and disposal of mixed waste that may be generated during operation of the proposed plant. North Anna ESPA ER Section 5.5.2 provides a description of the environmental impacts from mixed waste systems.
The information in this section can be reviewed with the NAPS SLR ER for consistency and may require updates.
This section MAY need an update.
5.5.3 Conclusions This is a conclusion section and will summarize the results of any updates Section 5.5.1 and 5.5.2.
This section MAY need an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 60 of 77 May 2025 5.6 Transmission System Impacts 5.6.1 Terrestrial Ecosystems North Anna ESPA transmission ROW vegetation management procedures will need to be updated based on findings from Section 2.1.2 above. For example, management now includes collaboration with VDCR Natural Heritage Division to identify and protect areas within the ROWs that have protected species. This information can be updated using the 2024 NAPS SEIS.
North Anna ESPA species and critical habitat in transmission ROW may need updated based on Section 2.4.1 updates. This information can be retrieved from the 2024 NAPS SEIS and reviewed using resources available through State and federal agency websites.
Herbicide procedures will need to be verified and updated, if applicable. The 2024 NAPS SEIS is not very descriptive on herbicide use; thus, information related to herbicide application and procedures can be captured via a formal RFI.
Finally, a review of publicly available information should be conducted to confirm transmission line corridors do not cross protected areas (e.g., wildlife management areas, critical habitat, etc.).
This section DOES need an update.
5.6.2 Aquatic Ecosystems The same information updates applicable to Section 5.6.1 above are applicable to Section 5.6.2.
In addition, a review of National Oceanic and Atmospheric Administration (NOAA) resources, including fisheries and national marine sanctuaries (NMS), should be assessed for impacts related to the transmission system. If no NMS are present in the action area, a statement should be added to clarify. This information can be retrieved publicly through the NOAA NMS website.
This section DOES need an update.
5.6.3 Impacts to Members of the Public This section should be updated using language consistent with the 2024 NAPS SEIS related to electrical shock as more recent information has become available (e.g., information related to Dominion safety documents as described in Section 3.11.5 of the SEIS).
This section DOES need an update.
5.7 Uranium Fuel Cycle Impacts The current North Anna ESPA meets the requirements of RG 4.2, Revision 3, and DG-4032 Section 6.1, in that it references Table S-3 as the basis for uranium fuel cycle impacts.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 61 of 77 May 2025 5.7.1 Light-Water-Cooled Reactors The current North Anna ESPA meets the requirements of RG 4.2, Revision 3, and DG-4032 Section 6.1, in that it references Table S-3 as the basis for uranium fuel cycle impacts.
This section DOES NOT need an update.
5.7.2 Gas-Cooled Reactors The current North Anna ESPA meets the requirements of RG 4.2, Revision 3, and DG-4032 Section 6.1, in that it references Table S-3 as the basis for uranium fuel cycle impacts.
This section DOES NOT need an update.
5.7.3 Methodology Assessment The current North Anna ESPA meets the requirements of RG 4.2, Revision 3, and DG-4032 Section 6.1, in that it references Table S-3 as the basis for uranium fuel cycle impacts.
This section DOES NOT need an update.
5.8 Socioeconomic Impacts RG 4.2, Revision 3, and DG-4032 suggests describing the socioeconomic impacts that could occur in the region and counties that could experience the majority of the impacts due to the operation of the plant. The following sections should be updated where new information was updated in Section 2.5.
5.8.1 Physical Impacts of Station Operation According to RG 4.2, Revision 3, and DG-4032, the physical impacts of construction include impacts due to noise, air emissions, vibration, road realignment, road deterioration and the degradation of the aesthetic qualities of the area. A review of the potential sensitive offsite receptors will be conducted and if changes are identified, then the section will be updated. If no changes in offsite receptors are identified, no update to this section is necessary.
This section MAY need an update.
5.8.2 Social and Economic Impacts of Station Operation RG 4.2, Revision 3, and DG-4032 suggest addressing impacts on the community from the inflow of operation workers, impacts of operation on local economies, impacts on infrastructure, traffic, recreation, housing, public services, and tax revenue. U.S. Census data updates in Section 2.5 change the metrics that are compared to the population, such as most of the socioeconomic impacts. As such, the section should be revised.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 62 of 77 May 2025 This section DOES require an update.
5.8.3 Environmental Justice Impacts RG 4.2, Revision 3, and DG-4032 suggests identifying the potential for a disproportionally high and adverse impact on EJ populations due to operation impacts. EJ impact should be reanalyzed using the U.S. Census data updates in Section 2.5.
This section DOES require an update.
5.9 Decommissioning The planned decommissioning actions and alternatives would remain unchanged from the originally submitted ESP. The only new information is including the Decommissioning Generic Impact Environmental Statement (GEIS) as a reference.
5.10 Measures and Controls to Limit Adverse Impacts During Operation Table 5.10-1 lists the elements identified in NUREG-1555, Section 5.10, that relate to potential adverse environmental impacts of operation and the measures and controls selected to limit adverse impacts. RG 4.2, Revision 3, Section 5.12, having been revised at a later date than NUREG-1555, is formatted differently; however, the content provided in the North Anna ESPA provides the detail outlined in each guidance document. That said, if any portion of the Chapter 5 impact analyses are updated, then this section would also need to be updated accordingly.
This section MAY require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 63 of 77 May 2025 6.0 ENVIRONMENTAL MEASUREMENTS AND MONITORING PROGRAMS NUREG-1555 suggests that an EIS include an introductory paragraph for this section that includes a description of the environmental measurements and monitoring program. RG 4.2, Revision 3, does not include any additional information of this section.
This is section is an introductory paragraph and as such does not require an update. The section should be updated to reflect any changes to the subsections.
6.1 Thermal Monitoring NUREG-1555 suggests that the EIS include an introductory paragraph for this section that includes a description of the preoperational and operational thermal monitoring program. RG 4.2, Revision 3, and DG-4032 do not include any additional information of this section.
This section is an introductory statement to Subsections 6.1.1 and 6.1.2, as such this section DOES NOT require an update.
6.1.1 Existing Thermal Monitoring Program NUREG-1555 suggests the following information should be included including maps showing the features of the plant and site including boundaries and bathymetry of all water bodies adjacent to the site before and after construction activities. The section should also include the location of all thermal, hydrological, or aquatic biological monitoring stations and the predicted extent of the thermal plume. This information should be provided for existing thermal monitoring programs and pre-application and operational thermal monitoring programs. The North Anna ESPA ER Section 6.1.1 provides a discussion of the existing thermal monitoring program at NAPS.
This section DOES NOT require an update. This section meets the requirements of NUREG-1555 and does not require any updates.
6.1.2 Pre-Application, Pre-Operational, and Operational Thermal Monitoring NUREG-1555 suggests that the ESPA ER provide the same information describing existing thermal monitoring programs for pre-application and operational thermal monitoring programs.
The North Anna ESPA ER describes the pre-application and operational thermal monitoring programs as provided in the existing NAPS thermal monitoring program, as such no new information is provided in this section.
This section DOES NOT require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 64 of 77 May 2025 6.2 Radiological Monitoring The North Anna ESPA ER Radiological Monitoring program is based on the current established North Anna site Radiological Environmental Monitoring Program (REMP) and onsite dose calculation manual (ODCM). As a result, no changes are necessary.
This section DOES NOT require an update.
6.3 Hydrological Monitoring This section discusses the hydrological monitoring program that would be implemented to monitor the effects of the new units at the ESP site, including monitoring of flow rates, water levels, sediment loads, and groundwater levels. The hydrological measurements required by permit at the operating site and other site characteristics would need to be reviewed and possibly updated. Since the permitted site is a nuclear power station, it is anticipated that the monitoring requirements of the new/amended permit would be similar to the existing permit.
The current North Anna ESPA meets the requirements of RG 4.2, Revision 3, and DG-4032 Section 6.3. This section MAY require an update based on a review of site permit conditions.
6.4 Meteorological Monitoring North Anna ESPA ER sections on meteorological monitoring are based on the existing system and program as described in the NAPS UFSAR. This program meets the guidance of RG 1.23.
This section DOES NOT require an update.
6.5 Ecological Monitoring North Anna ESPA ER Section 6.5 may require a revision. The environmental description should be reviewed and updated, as applicable, based on information updated in the following sections (6.5.1 and 6.5.2). Therefore, updates to this section may be required.
This section MAY require an update.
6.5.1 Terrestrial Ecology and Land Use North Anna ESPA ER Section 6.5.1 will require revisions.
This section will require updates based on Section 2.4.1 updates (e.g., threatened, and endangered species, vegetation management, avian communities, small mammals, etc.).
Further, information provided in North Anna ESPA 6.5.1.2 (construction monitoring) and 6.5.1.3 (operational monitoring) may need updated based on updates to previous terrestrial ecology sections. This information can be pulled from previous sections, or from the 2024 NAPS SEIS to Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 65 of 77 May 2025 update terrestrial ecology monitoring, if applicable. Any monitoring data collected after the 2024 that is not publicly available would be captured via a formal RFI.
Chapter 6 states that some of the programs at the existing units would constitute the primary monitoring efforts that would be relied on. Therefore, it may be appropriate to retrieve REMP info from the latest Annual Radiological Operating Reports (AREORs) and summarize the information. These reports are available publicly on the NRC website.
This section DOES require an update.
6.5.2 Aquatic Ecology North Anna ESPA ER Section 6.5.2 DOES require an update.
This section will require updates based on Section 2.4.2 updates (e.g., threatened, and endangered species). Further, existing monitoring programs (e.g., quarterly electro-fishing sampling, semi-annual Asiatic clam sampling, Hydrilla inspections) should be confirmed that they are still active. If monitoring programs remain active, the results provided in Section 6.5.2 need to be updated. Some of this information can be retrieved from the SEIS; however, a formal RFI may be needed to capture the most recent information.
This section DOES require an update.
6.6 Chemical Monitoring The NAPS Unit 3 COLA ER Section 6.6 and FEIS Section 2.6.3.4 provide updated information that can be used for this section update. Additional information on recent site surface and groundwater monitoring and groundwater protection programs can be found in the NAPS SLR ER Section E3.6 and NUREG-1437, Supplement 7, Section 3.5. While it is not anticipated that any of the findings will change, this section can be updated to reflect the most recent information.
This section DOES require an update.
6.7 Summary of Monitoring Programs NUREG-1555 suggests that this section include a summary of monitoring to be conducted during site preparation and project construction, preoperational monitoring, and operational monitoring. RG 4.2, Revision 3, and DG-4032 do not include any additional information regarding the summary of monitoring programs. This section is an introductory statement to Subsections 6.7.1 through 6.7.3.
This section DOES NOT require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 66 of 77 May 2025 6.7.1 Pre-Application Monitoring NUREG-1555 suggests that this section should include a description of the existing or proposed environmental monitoring program for site preparation and construction in tabular form. The North Anna ESPA ER Section 6.7.1 provides this information in Tables 6.7-1 through 6.7-6. The information on existing thermal, radiological, hydrological, meteorological, ecological, and chemical monitoring programs should be reviewed and updated to reflect any changes.
Information on monitoring programs is included in Chapter 6 of the NAPS Unit 3 COLA.
This section MAY require updates.
6.7.2 Construction and Pre-Operational Monitoring NUREG-1555 suggests that this section should include a description of the existing or proposed pre-operational environmental monitoring program. The review plan states that when an element of a monitoring program has been described earlier and that element of the program will continue unchanged, a note referring to the previous description will be sufficient. RG 4.2, Revision 3, and DG-4032 do not include any additional information for this section. The North Anna ESPA ER Section 6.7.2 provides reference to the information provided in Tables 6.7-1 through 6.7-6.
This section DOES NOT require updates.
6.7.3 Operational Monitoring NUREG-1555 suggests that this section should include a description of the existing or proposed pre-operational environmental monitoring program. The review plan states that because the program may be proposed well before the initiation of operations and potential changes based on new regulations, the information is likely to change. RG 4.2, Revision 3, and DG-4032 do not include any additional information for this section. The North Anna ESPA ER Section 6.7.2 provides reference to the information provided in Tables 6.7-1 through 6.7-6 regarding existing monitoring programs with a statement regarding future consultations with regulatory agencies.
This section DOES NOT require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 67 of 77 May 2025 7.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS 7.1 Design Basis Accidents The North Anna ESPA ER sections consider the entire range of postulated accidents to demonstrate compliance with 10 CFR 52.17. The ESPA section and source terms used comply with the guidance of RG 4.2, Revision 3, and DG-4032, which requires a range of DBAs. There are no proposed changes to the PPE and the evaluation methodology and TEDE doses used were realistic (50th percentile X/Qs). Because the evaluated site X/Qs are below the DC X/Qs, the previously reported results are acceptable and do not require update.
This section DOES NOT need an update.
7.2 Severe Accidents North Anna ESPA ER makes extensive use of NUREG-1437. Because NUREG 1437 was revised in 2013, all sections in 7.2 should be updated to reflect changes in this NUREG.
This section MAY need an update.
7.2.1 Applicability of Existing Generic Severe Accident Studies North Anna ESPA ER makes extensive use of NUREG-1437. Because NUREG 1437 was revised in 2013, all sections in 7.2 should be updated to reflect changes in this NUREG.
This section MAY need an update.
7.2.2 Evaluation of Site-Specific Potential Severe Accident Releases North Anna ESPA ER makes extensive use of NUREG-1437. Because NUREG 1437 was revised in 2013, all sections in 7.2 should be updated to reflect changes in this NUREG.
This section MAY need an update.
7.2.3 Evaluation of Economic Impacts of Severe Accidents North Anna ESPA ER makes extensive use of NUREG-1437. Because NUREG 1437 was revised in 2013, all sections in 7.2 should be updated to reflect changes in this NUREG.
This section MAY need an update.
7.2.4 Consideration of Commission Severe Accident Policy North Anna ESPA ER makes extensive use of NUREG-1437. Because NUREG 1437 was revised in 2013, all sections in 7.2 should be updated to reflect changes in this NUREG.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 68 of 77 May 2025 This section MAY need an update.
7.2.5 Conclusion North Anna ESPA ER makes extensive use of NUREG-1437. Because NUREG 1437 was revised in 2013, all sections in 7.2 should be updated to reflect changes in this NUREG.
This section MAY need an update.
7.3 Severe Accident Mitigation Alternatives The purpose of severe accident mitigation alternatives is to review and evaluate plant-design alternatives that could significantly reduce the radiological risk from a severe accident by preventing substantial core damage or by limiting releases from containment in the event that substantial core damage does occur. This information is not required to be evaluated in an ESPA and therefore is also not required for an ESPA renewal. This evaluation will be included in downstream licensing submittals (e.g., CPA / OLA or COLA).
This section DOES NOT require an update.
7.4 Transportation Accidents Section 7.4 refers to Section 3.8 for this information.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 69 of 77 May 2025 8.0 NEED FOR POWER Title 10 of the Code of Federal Regulations 51.50(b)(2) does not require a need for power discussion be included in an ESPA. The need for power discussion will be included in downstream licensing submittals (e.g., CPA / OLA or COLA).
This chapter DOES NOT require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 70 of 77 May 2025 9.0 ALTERNATIVES TO THE PROPOSED ACTION 9.1 No-Action Alternative The no-action alternative on a proposed ESP is non-issuance of that permit (i.e., NRC declining to determine whether a proposed site is suitable for new nuclear plants). In this context, no-action would accomplish none of the benefits intended by the ESP process. The no-action alternative is not expected to change during the renewal process.
This section DOES NOT require an update.
9.2 Energy Alternatives This section is not required for an ESPA.
9.3 Alternative Sites For the ESP stage, 10 CFR 51.50 (b)(1) states that the ER, must address all environmental effects of construction and operation necessary to determine whether there is any obviously superior alternative to the site proposed. A siting study was performed by Dominion Energy in support of the original ESPA and an evaluation performed of the preferred and alternative sites.
The issuance of the ESP eliminates the need for further evaluation of alternative sites.
This section DOES NOT require an update.
9.4 Alternative Plant and Transmission Systems This section describes the evaluation of the alternative plant and transmission systems for heat dissipation, circulating water, and power transmission.
9.4.1 Heat Dissipation Systems No change is expected to the plan for two independent systems: 1) a closed-cycle, dry and wet tower cooling system for Unit 3, and 2) a closed-cycle dry tower system for Unit 4. Therefore, the following alternatives already discussed in the original submission will remain unchanged:
Once-through system Once through system with helper tower Natural draft cooling tower system Mechanical draft cooling tower system Spray ponds Dry tower system (Unit 3 only)
This section DOES NOT require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 71 of 77 May 2025 9.4.2 Circulating Water Systems Since the proposed systems for Units 3 and 4 do not comprise an open-loop circulating water system, there is no need to evaluate circulating water system alternatives. The closed-loop circulating water system for Unit 3 would, however, require continuous makeup water to the wet cooling tower basin to compensate for the evaporative losses and cooling tower blowdown when waste heat cannot be rejected via the dry towers alone, which is in the original submission.
This section DOES NOT require an update.
9.4.3 Transmission Systems No change in the conclusion to the original ESP is expected. Based on the initial evaluation, the current ESP site transmission lines and corridors have sufficient capacity for the total output of the existing and new units. There are no environmentally equivalent or more advantageous alternatives to no action.
This section DOES NOT require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 72 of 77 May 2025 10.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION The North Anna ESPA ER was formatted to match NUREG-1555. RG 4.2, Revision 3, and DG-4032 provides later guidance on the Chapter 10 content and formats the section differently.
Specifically, it includes some additional summary sections:
Impacts of the Proposed Actions - A summary of the impacts of the proposed action from Chapters 4, 5 and 7.
Alternatives to the Proposed Action - A summary of the Chapter 9 alternatives analyses.
The NAPS Unit 3 COLA ER Chapter 10 provides some key updated information that will also be used to support the development of these sections.
10.1 Unavoidable Adverse Environmental Impacts 10.1.1 Unavoidable Adverse Environmental Impacts During Construction This section will require an update to summarize any updates in the ESPA Renewal ER Chapter 4 analyses sections.
This section DOES need an update to document the updated analyses confirming no change or summarize the newly identified unavoidable adverse environmental impacts during construction.
10.1.2 Unavoidable Adverse Environmental Impacts During Operation This section will require an update to summarize any updates in the ESPA Renewal ER Chapter 5 analyses sections.
This section DOES require an update to document the updated analyses confirming no change or summarize the newly identified unavoidable adverse environmental impacts during operation.
10.1.3 Summary of Adverse Environmental Impacts This section will require an update to summarize any updates in the ESPA Renewal ER Chapters 4 and 5 analyses sections. Information reported in the NAPS Unit 3 COLA will be incorporated as applicable.
This section DOES require an update.
10.1.4 Irreversible and Irretrievable Commitment of Resources This section will require an update to summarize any updates in the ESPA Renewal ER Chapters 4 and 5 analyses sections.
This section DOES require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 3: Environmental Report Page 73 of 77 May 2025 10.2 Irreversible and Irretrievable Commitments of Resources 10.2.1 Irreversible Environmental Commitments This section will require an update to summarize any updates in the ESPA Renewal ER Chapters 4 and 5 analyses sections.
This section DOES require an update to document the updated analyses confirming no change or summarize the newly identified irreversible environmental commitments.
10.2.2 Irretrievable Commitments of Resources This section will require an update to summarize any updates in the North Anna ESPA Renewal ER Chapters 4 and 5 analyses sections.
This section DOES require an update to document the updated analyses confirming no change or summarize the newly identified irretrievable commitments of resources.
10.3 Relationship Between Short-Term Uses and Long-Term Productivity of the Human Environment The NAPS Unit 3 COLA ER Chapter 8 and Sections 10.4 and 10.6 of NUREG-1917 provide updated information that can be used for this section of the ESPA Renewal. Unless something new is identified in the ESPA Renewal ER Chapters 4 and 5 analyses, it is not anticipated that this section will require a significant update.
This section MAY need an update depending upon the findings of the Chapters 4 and 5 analyses.
10.4 Benefit - Cost Balance In accordance with the 10 CFR 52.17(a)(2), an assessment of the benefits (need for power) of new units is not required for an ESPA.
This section DOES NOT require an update.
Draft
North Anna Early Site Permit Application Annotated Outline Part 4: Programs and Plans Page 74 of 77 May 2025 PART 4: PROGRAMS AND PLANS CHAPTER 1 1.0 SITE REDRESS This chapter describes ESP activities that might occur after the NRC issuance of an ESP. The chapter also describes the site redress plan that would be implemented if those site preparation activities were performed. The NAPS COLA did not reference the ESP redress plan.
Amendment 3 to ESP-003 was issued in January 2013 to add the site redress plan.
This section DOES NOT require an update because the site redress plan was addressed in Part 4 of the North Anna ESPA. Amendment 3 to ESP-003 subsequently was issued in January 2013 to add the site redress plan in January 2013. There is no reason to change the plan.
1.1 Description of Site Preparation Activities This section describes site preparation activities allowed under the ESP and 10 CFR50.10e(1).
This section DOES NOT require an update because the description of the site preparation activities provided in the North Anna ESPA and Amendment 3 to ESP-003 have not changed.
1.2 Site Redress Plan This site redress plan provides reasonable assurance that redress carried out under the plan would achieve an environmentally stable and aesthetically acceptable site condition suitable for whatever non-nuclear use may conform with local zoning laws.
This section DOES NOT require an update because the site redress plan provided in the North Anna ESPA and in Amendment 3 to ESP-003 has not changed.
1.2.1 Site Redress Plan Objective and Considerations This section describes site redress plan objectives.
This section DOES NOT require an update because the site redress plan objectives provided in the North Anna ESPA and in Amendment 3 to ESP-003 have not changed.
1.2.2 Description of Site Redress This section describes the site redress actions that would be taken should pre-construction work not proceed to full construction.
This section DOES NOT require an update because the site redress plan objectives provided in the North Anna ESPA and in Amendment 3 to ESP-003 have not changed.
Draft
North Anna Early Site Permit Application Annotated Outline Part 4: Programs and Plans Page 75 of 77 May 2025 1.2.3 NRC Notification Upon Completion This section states that Dominion will notify the NRC upon completion of activities addressed by the Site Redress Plan.
This section DOES NOT require an update because the site redress plan objectives provided in the North Anna ESPA and in Amendment 3 to ESP-003 have not changed.
Draft
North Anna Early Site Permit Application Annotated Outline Part 5A: Emergency Plan (Site Boundary EPZ)
Page 76 of 77 May 2025 PART 5A: EMERGENCY PLAN (SITE BOUNDARY EPZ)
Part not included in North Anna ESPA A major features emergency plan is included in accordance with 10 CFR 52.17(b)(2)(I) as part of North Anna ESPA, which is discussed in Part 2, Section 13.3.2 of the North Anna ESPA. The Major Features Emergency Plan takes advantage of the emergency planning resources, capabilities, and organization that has already been established and currently maintained at the NAPS site. If Dominion were to proceed with the development of new units at the ESP site, it would enter into an arrangement with the licensee for the NAPS site to coordinate and implement an integrated emergency plan, in effect extending the existing emergency planning and preparedness to the new units. However, because some aspects of emergency preparedness require detailed design information which does not yet exist, some details of the plan that would be specific to the new units cannot be fully described at this time. Thus, only the major features of the emergency plan that are provided at this time are discussed in Part 2, Section 13.3.2 of the North Anna ESPA.
A revision to this section SHALL be prepared which addresses the scope of the integrated emergency plan.
It is noted that if an SMR is planned for the ESP, it needs to meet the requirements of 10 CFR 50.160, Emergency preparedness for small modular reactors, non-light-water reactors, and non-power production or utilization facilities.
NAPS Unit 3 Combined License Application Part 10: Tier 1/ITAAC/Proposed License Conditions, 3.1 Emergency Planning Actions.
Draft
North Anna Early Site Permit Application Annotated Outline Part 6: Exemptions and Departures Page 77 of 77 May 2025 PART 6: EXEMPTIONS AND DEPARTURES Part not included in North Anna ESPA The following conditions, commitments, assumptions, unresolved issues, and departures MAY be included in the renewed ESPA.
- 1. NAPS Unit 3 Combined License Application, Part 7: Departures Report.
- 2. Supplemental Environmental Impact Statement for the Combined License (COL) for NEI Unit 3, Appendix J - Early Site Permit Site Permit Conditions, Commitments, Assumptions, and Unresolved Issues.
- 3. NAPS Unit 3 Combined License Application Part 10: Tier 1/ITAAC/Proposed License Conditions.
Draft