ML23081A096

Requests for Confirmation of Information for the Environment Review of the North Anna Power Station, Units 1 and 2, Subsequent License Renewal Application (EPID Number: L?2020?SLE?0000) (Docket Numbers: 50?338 and 50?339

ML23081A096
Person / Time
Site:	North Anna
Issue date:	04/20/2023
From:	Tam Tran NRC/NMSS/DREFS/ELRB
To:	Stoddard D Virginia Electric & Power Co (VEPCO)
Shared Package
ML23081A096	List: ML23081A096
References
EPID L-2020-SLE-0000
Download: ML23081A096 (8)

Text

April 20, 2023 Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd Glen Allen, VA 230606711

SUBJECT:

REQUESTS FOR CONFIRMATION OF INFORMATION FOR THE ENVIRONMENTAL REVIEW OF THE NORTH ANNA POWER STATION, UNITS 1 AND 2, SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NUMBER:

L2020SLE0000) (DOCKET NUMBERS: 50338 AND 50339)

Dear Daniel Stoddard:

By letters dated August 24, 2020, (Agencywide Documents Access and Management System ML20246G703), Dominion Energy submitted an application for subsequent license renewal of Renewed Facility Operating License Nos. NPF-4 and NPF-7 for the North Anna Power Station, Unit Nos. 1 and 2 (North Anna) to the U.S. Nuclear Regulatory Commission (NRC) pursuant to section 103 of the Atomic Energy Act of 1954, as amended, and part 54 of title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants.

During the week of March 6, 2023, the NRC staff conducted an environmental audit of Dominion Energy's records to confirm information submitted in the North Anna license renewal application. During the audit, the staff reviewed documents that contain information which will likely be used in the Site-specific Environmental Impact Statement (SEIS) that supplement the 2021 draft Supplemental EIS (87 FR 68522). To the best of the staff's knowledge, this information is not on the docket or accessible in the public domain. Any information used to reach a conclusion in the SEIS must be included on the docket by the applicant. Therefore, we request that you submit confirmation that the information gathered during the audit and listed in the enclosure is correct or provide the associated correct information.

These requests for confirmation of information were discussed with Ellery Baker of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter.

D. Stoddard If you have any questions on this matter, please contact Tam Tran via email at Tam.Tran@nrc.gov.

Sincerely, Signed by Tran, Tam on 04/20/23 Tam Tran, Project Manager Environmental Review License Renewal Branch Division of Rulemaking, Environment, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. 50338 and 50339

Enclosure:

As stated cc w/encl.: Distribution via Listserv

ML23081A096 *via email OFFICE PM:REFS LA:REFS BC:REFS PM:REFS NAME TTran *AWalker-Smith TSmith TTran DATE 04 /04 /2023 4/20/2023 4/20/2023 4/20/2023 NORTH ANNA POWER STATION, UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION REQUESTS FOR CONFIRMATION OF INFORMATION ENVIRONMENTAL REVIEW Regulatory Basis:

License renewal requirements are specified in title 10 of the Code of Federal Regulations (10 CFR) part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. Licensees are required by 10 CFR 54.23 to submit an Environmental Report (ER) that complies with the applicable requirements in 10 CFR part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, as part of the subsequent license renewal application. The U.S. Nuclear Regulatory Commissions (NRC) regulations at 10 CFR part 51, which implement Section 102(2) of the National Environmental Policy Act (NEPA) of 1969, include requirements for applicants to provide information as may be useful in aiding the NRC staff in complying with NEPA. The NRC staff is required to prepare a Site-specific Environmental Impact Statement (SEIS) that supplements the 2021 draft Supplemental Environmental Impact Statement (Supplement 7, second renewal) to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 -

Operating License Renewal.

Request for Confirmation of Information:

During the audit, the staff (a) reviewed several documents on the applicant electronic information portal (Agencywide Documents Access and Management System (ADAMS)

ML20269A465), in response to the staff audit needs (ML23062A466) and (b) interviewed the applicant personnel for information that will likely be used in the SEIS. To the best of the staff's knowledge, this information is not on the docket or accessible from the public domain. The NRC staff requests that the applicant submits confirmation that the information gathered from the audit and listed below is correct or provides the associated corrected information.

GEN-2 RCI: Please confirm that there have been no unplanned releases of radioactive materials (unplanned/inadvertent radioactive liquid or gaseous releases) since Dominions most recent environmental request for additional information (RAI) responses dated February 22, 2021 (ML21053A433).

WM2 (SWR-3) RCI: Dominion's September 28, 2022, Environmental Report (ER), Supplement 1 analysis of Category 1 Issue Nos. 15, 24, 32, 33, 34, 39, 54 and 55 describes a warning letter for a missed total suspended solids (TSS) monitoring requirement at Outfall 103. During the March 2023 environmental audit, the NRC staff reviewed a warning letter from the Virginia Department of Environmental Quality and Dominion Energys response to the warning letter. It is the NRC staffs understanding that the sample was taken at Outfall 103, but the analysis of the sample was delayed beyond the 7-day holding time, which invalidated the results for Outfall 103 for TSS. As discussed during the March audit, North Annas sampling procedure was updated to ensure that: (a) the isotopic analysis report is transmitted with the sample to avoid a potential delay in analysis, (b) laboratory reports are reviewed promptly, and (c) resampling is Enclosure

conducted if samples exceed the allowable holding time. Please confirm that the NRC staff understanding of the missed TSS monitoring requirement, associated letters, and site corrective actions are correct.

AQ2 RCI: North Annas Virginia Pollutant Discharge Elimination System (VPDES) permit limits metals, including zinc, copper, and iron, in wastewater discharges, including stormwater. From information gathered during the environmental site audit, the NRC staff understands that Dominion has reported no VPDES permit violations related to limits on discharge of metals within the past five years. Please confirm this understanding is correct.

MBH1 RCI: From information gathered during the environmental site audit, the NRC staff understands that Dominion has observed no harmful algal blooms in the Waste Heat Treatment Facility (WHTF) since those described in Dominions February 22, 2021, response to NRC request for additional information on the subsequent license renewal (SLR) environmental review (ML21053A433; p. 1011). Please confirm this understanding is correct.

GWR-1 RCI: During the site audit on March 7, 2023, Dominion updated table E4.5-2a and table E4.5-2b of the North Anna Power Station (NAPS) SLR ER Supplement 1 with the 2022 groundwater withdrawal data as shown the tables below. Please confirm that data shown below are correct.

Table E4.5-2a NAPS Yearly Groundwater Withdrawal Summary Monthly Maximum Monthly Average Monthly Minimum Yearly Total Year MGM gpma MGM gpma MGM gpma MGY gpd 2022 0.27 6.13 0.17 3.77 0.05 1.14 1.99 5,443.59 2013-2022 0.50 11.57 0.22 4.99 0.04 1.01 2.63 7,196.09 MGY = millions of gallons per year MGM = millions of gallons per month gpd = gallons per day gpma = average gallons per minute for the month Table E4.5-2b NAPS Monthly Groundwater Withdrawal Summary Groundwater Wells (MGM) Monthly Total Month NANIC #4 #6 #7 #8 MGM gpma January-22 0.008 (a) 0.026 0.000 0.017 0.051 1.136 February-22 0.008 (a) 0.074 0.000 0.007 0.088 2.190 March-22 0.008 (a) 0.253 0.005 0.000 0.266 5.968 April-22 0.008 (a) 0.144 0.000 0.000 0.152 3.516 May-22 0.010 (a) 0.131 0.000 0.000 0.141 3.165 June-22 0.011 (a) 0.163 0.001 0.003 0.177 4.104 July-22 0.013 (a) 0.178 0.003 0.000 0.193 4.326 August-22 0.012 (a) 0.197 0.028 0.000 0.236 5.291 September-22 0.011 (a) 0.225 0.028 0.000 0.265 6.127

October-22 0.011 (a) 0.212 0.005 0.000 0.227 5.092 November-22 0.011 (a) 0.094 0.001 0.000 0.106 2.442 December-22 0.012 (a) 0.072 0.000 0.000 0.084 1.886 (a) Not installed, not operational, or abandoned gpma = average gallons per minute for the month SWR-1 (AQ-2) RCI: During site audit on March 7, 2023, Dominion stated that its VPDES permit has been administratively extended based on the terms and conditions of the existing permit. A confirmation of the extension was provided in the correspondence from the Virginia Department of Environmental Quality dated April 3, 2019. Please confirm that the above statements regarding Dominions VPDES permit are correct.

SWR-2 (SWR-5) RCI: During site audit on March 7, 2023, Dominion updated table E4.5-1a and table E4.5-1b of the NAPS SLR ER Supplement 1 with the 2022 surface water withdrawal data as shown below. Please confirm that data shown below are correct.

Table E4.5-1a NAPS Yearly Surface Water Withdrawal Summary Monthly Maximum Monthly Average Monthly Minimum Yearly Total Year MGM gpma MGM gpma MGM gpma MGY MGD 2022 72,784.00 1,630,466 55,315.46 1,262,203 27,678.00 747,693 663,785.46 1,818.59 2013-2022 74,653.18 1,672,338 56,091.11 1,278,346.6 23,479.88 525,983 673,093.38 1,843.08 MGY = millions of gallons per year MGM = millions of gallons per month gpma = average gallons per minute for the month (rounded to nearest gpm)

Table E4.5-1b NAPS Monthly Surface Water Withdrawal Summary Surface Water Withdrawals (MGM) Total Month North Anna Lake Anna Unit #1 Lake Anna Unit #2 NA3 CW Mini-SY CW MGM gpma Dam January-22 1709.91 19876.00 20638.00 (a) 0.00 42,223.91 945,876.12 February-22 2001.55 19462.00 19872.00 (a) 0.00 41,335.55 1,025,187.25 March-22 0.00 24102.00 3576.00 (a) 0.00 27,678.00 620,026.88 April-22 0.00 29304.00 24383.00 (a) 0.00 53,687.00 1,242,754.63 May-22 0.00 35899.00 35670.00 (a) 0.00 71,569.00 1,603,248.21 June-22 0.00 33898.00 34479.00 (a) 0.00 68,377.00 1,582,800.93 July-22 0.00 36389.00 35840.00 (a) 0.00 72,229.00 1,618,033.15 August-22 0.00 36716.00 36068.00 (a) 0.00 72,784.00 1,630,465.95 September-22 0.00 24208.00 34350.00 (a) 0.00 58,558.00 1,355,509.26 October-22 0.00 11627.00 34411.00 (a) 0.00 46,038.00 1,031,317.20 November-22 0.00 28293.00 28772.00 (a) 0.00 57,065.00 1,320,949.07 December-22 0.00 26228.00 26013.00 (a) 0.00 52,241.00 1,170,273.30

a. 2019 to 2021 water usage reports designate this withdrawal the "Mini-Switchyard Construction". In previous years, it was designated as "Unit 3 Construction"

b. Water usage reports designate the withdrawals for NAPS as "Lake Anna Unit #1" and "Lake Anna Unit #2" gpma = average gallons per minute for the month

SWR7 RCI: During the site audit on March 7, 2023, Dominion provided a copy of the NAPS Stormwater Pollution Prevention Plan (SWPPP) updated in May 2022. Section 7.1 in the SWPPP lists a non-polychlorinated biphenyls transformer oil spill on November 11, 2022. In NAPS SLR ER supplement section E4.5.11.2, a similar spill is described that occurred in 2021.

Please confirm that (1) the two spills are the same event, (2) the date of the spill noted to occur on November 11, 2022, in the SWPPP contains an error, and (3) the year in that date should be 2021.

SWR-8 (New) RCI: During the site audit on March 7, 2023, Dominion provided the following update/correction to the text in NAPS SLR ER section 3.6.1.1, Potential for Flooding:

Based on Federal Emergency Management Agency (FEMA) data, the majority of the NAPS property is located within Zone X, outside the 0.2 percent annual chance floodplain (500-year flood level). Small areas along the shores and canals have been designated as within the 1 percent annual chance (100-year flood level, Zone AE) floodplain with base flood elevations of 255 feet (NAVD88) (Figure 3.6-2). Areas of moderate flooding between the 100-year and 500-year floods are not mapped by FEMA in this area. (FEMA 2019)

Please confirm that the text quoted above is accurate and correct.

AQN-3 RCI: During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-3, Dominion stated that field tests concerning ozone and nitrogen oxides emissions generated by North Annas 34.5 kV and 500 kV in-scope transmission lines have not been conducted? Confirm that field tests concerning ozone and nitrogen oxides emissions generated by North Annas 34.5 kV and 500 kV in-scope transmission lines have not been conducted.

AQN-4 RCI: During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-4, Dominion stated that it has not received any notices of violation since 2019 associated with North Annas State Operating Permit (Air Permit No.

40726)? Confirm that Dominion has not received any notices of violation since 2019 associated with North Annas State Operating Permit.

ALT-1 RCI: Please confirm that during the March 8, 2023, Alternatives breakout session, Dominion Energy addressed the continued validity of the technical bases presented in their August 2020 ER (ML20246G698) and associated correspondence used to support the identification of reasonable replacement power alternatives to renewing the operating licenses for NAPS Units 1 and 2. Specifically, Dominion Energy confirmed the bases for including advanced nuclear generation as reasonable alternatives. Dominion Energy also confirmed the basis for considering natural gas and other fossil fuel generation as unreasonable for replacement of NAPS. Dominion Energy further indicated that their planning includes substantial additions of solar, wind, and battery resources, and that their projected goal for net zero carbon emissions in 2045 assumes that NAPS is relicensed.

CI-1 RCI: In association with the March 8, 2023, Cumulative Impacts breakout session, Dominion provided information on three reasonably foreseeable projects being planned at NAPS that updated the information previously provided in Dominion Energys February 22, 2021, correspondence (ML21053A433, pgs. 2-8) regarding NRCs RAI (ML21028A390). Please confirm that the status of each of the following projects is correct, and that no additional projects have been identified in the interim:

Cyber Security Testing Facility - construction ongoing; completion targeted July 2023.

Wastewater Treatment Plant Replacement Project - construction ongoing; completion targeted August 2023.

Main Generator Storage Building - Dominion Energy has subsequently determined that the Main Generator Storage Building would not be needed at North Anna, and that replacement main generators are planned to be stored in the current Generator Rewind Building as needed. Target replacement outages are 2030 for Unit 1 and 2031 for Unit 2.

Acronyms and Abbreviations ALT Alternatives AQ Aquatic Resource AQN Air Quality and Noise CI Cumulative Impacts ER Environmental Report GEN General gpd Gallons per day gpma Average gallons per minute GWR Groundwater Resource kV Kilo volt MBH Micro Biological Hazard MGM Millions of gallons per month MGY Millions of gallons per year NAPS North Anna Power Station NEPA National Environmental Policy Act NRC Nuclear Regulatory Commission PCB polychlorinated biphenyls RCI Request for Confirmation of Information SEIS Site-specific Environmental Impact Statement SLR Subsequent License Renewal SWPPP Stormwater Pollution Prevention Plan SWR Surface Water Resource TSS Total suspended solids VPDES Virginia Pollutant Discharge Elimination System WHTF Waste Heat Treatment Facility WM Waste Management