ML20322A052

From kanterella
Revision as of 04:29, 3 September 2023 by StriderTol (talk | contribs) (StriderTol Bot insert)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search

License Renewal Environmental Site Audit Plan Regarding the North Anna Power Station, Units 1 and 2, Subsequent License Renewal Application
ML20322A052
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 11/19/2020
From: Tam Tran
NRC/NMSS/DREFS/ELRB
To: Stoddard D
Virginia Electric & Power Co (VEPCO)
Tam Tran
References
EPID L-2020-SLE-0000
Download: ML20322A052 (15)


Text

November 19, 2020 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd Glen Allen, VA 23060-6711

SUBJECT:

LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT PLAN REGARDING THE NORTH ANNA POWER STATION, UNITS 1 AND 2, SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NUMBER: L-2020-SLE-0000) (DOCKET: 50-338 and 50-339)

Dear Mr. Stoddard:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the Dominion Energy Virginia Companys subsequent license renewal application for North Anna Power Station, Units 1 and 2 (North Anna). The remote environmental audit will be conducted during the week of December 1, 2020, by NRC staff. The remote environmental audit activities will be conducted in accordance with the environmental audit plan (Enclosure 1).

To develop the Supplemental Environmental Impact Statement, the NRC staff requests the information described in the environmental audit needs list (Enclosure 2) be made available on the North Anna online reference portal (Agencywide Documents Access and Management System Accession Number ML20269A465), to the extent possible, prior to the environmental site audit. A draft schedule of site tours by means of photographs and/or videos (Enclosure 3) and tele-meetings (e.g., Microsoft Teams meetings) for the audit is also provided The NRC staff transmitted the draft environmental needs to Mr. Keith Miller of your staff by e-mail on November 3, 2020.

D.G. Stoddard If you have any questions, please contact me via e-mail at Tam.Tran@nrc.gov.

Sincerely, Digitally signed by Tam M.

Tam M. Tran Tran Date: 2020.11.19 14:22:58

-05'00' Tam Tran, Project Manager Environmental Review License Renewal Branch Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. 50-338 and 50-339

Enclosures:

As stated cc w/encls: Listserv

D.G. Stoddard

SUBJECT:

LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT PLAN REGARDING THE NORTH ANNA POWER STATION, UNITS 1 AND 2, SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NUMBER: L-2020-SLE-0000) (DOCKET: 50-338 and 50-339)

DATED: November 19, 2020 DISTRIBUTION:

E-MAIL:

PUBLIC RidsNrrPMNorthAnna Resource LGibson, NRR/DNRL LWilkins, OCA TTran, NMSS/REFS DMcIntyre, HQ/OPA RElliott, NMSS/REFS RHannah, RII/OPA ABradford, NRR/DNRL JPelchat, RII/ORA BCaldwell, NRR/DNRL ELea, RII/ORA EMiller, NRR/DORL KCarrington, RII/DRP DRoth, OGC MTobin, RII/DRP KGamin, OGC PCooper; RII/DRS JMcManus, OGC SDowney, RII/DRS AGhosh-Naber, OGC BDesai, RII/DRS STurk, OGC JDozier; NRR/DRA MMcCoppin, OEDO Paul.Aitken@dominionenergy.com SBurnell, HQ/OPA Keith.J.Miller@dominionenergy.com ADAMS Accession No.:ML20322A052 *concurrence via email OFFICE PM:REFS LA:REFS BC:REFS NAME TTran *AWalker-Smith RElliott DATE 11/19/2020 11/16/2020 11/17/20

ENCLOSURE 1 LICENSE RENEWAL ENVIRONMENTAL AUDIT PLAN NORTH ANNA POWER STATION, UNITS 1 AND 2

1. Background

By letter dated August 24, 2020 (Agencywide Documents Access and Management Systems (ADAMS) Package Accession No. ML20246G703), Dominion Energy Virginia (Dominion Energy or the applicant), submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the North Anna Power Station, Units 1 and 2 (North Anna), renewed facility operating licenses NPF-4 and NPF-7. The staff is reviewing the information contained in the environmental report (ER) of the license renewal application (LRA) per Title 10 of the Code of Federal Regulations Part 51 (10 CFR Part 51).

During the staffs review, the staff is conducting a remote environmental audit of the North Anna site. This audit is conducted to improve understanding, to verify information, and to identify information that will require docketing to support the preparation of an environmental impact statement. Specifically, the NRC staff will identify pertinent environmental data, review the facility and area, and obtain clarifications regarding information provided in the ER.

2. Environmental Audit Bases License renewal requirements are specified in 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 ER that complies with the requirements in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, as part of the LRA.

Review guidance for the staff is provided in NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License Renewal.

The NRC staff is required to prepare a site-specific supplement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. During the scoping process required in 10 CFR Part 51, NRC staff is required to define the proposed action, identify significant issues which must be studied in depth, and to identify those issues that can be eliminated from further study.

3. Environmental Audit Scope The scope of this environmental audit for the North Anna subsequent license renewal review is to identify those issues which are new and significant and those issues which can be eliminated from further study and to identify the environmental resources that must be adequately described and evaluated in the site-specific Supplemental Environmental Impact Statement.

Audit team members will focus on reviewing the documents and requested information listed in the North Anna Environmental Audit Needs List (Enclosure 2) and discussing the information with the applicants subject matter experts.

Enclosure 1

4. Information and Other Material Necessary for the Environmental Audit As described in the Site Audit Needs List (Enclosure 2).
5. Environmental Audit Team Members and Resource Assignments The environmental audit team members and their specific discipline assignments are shown in the table below.

Discipline Team Members Environmental Review Supervisor Robert Elliott, NRC Environmental Project Manager Tam Tran, NRC Historic and Cultural Resources (Section 106 Consultation), Alternatives, and Robert Hoffman, NRC Cumulative Impacts Terrestrial Ecology, Land Use, and Visual Caroline Hsu, NRC Terrestrial Ecology, Land Use, and Visual Peyton Doub, NRC Groundwater Joe Giacinto, NRC Surface Water, Geologic Environment, Termination of Operations, Kevin Folk, NRC Decommissioning, Greenhouse Gases/Climate Change Human Health Jeff Rikhoff, NRC Waste Management, Uranium Fuel Cycle, Phyllis Clark, NRC and Postulated Accidents Air Quality, Noise, Meteorology, Greenhouse Gases/Climate Change, Nancy Martinez, NRC Historic and Cultural Resources (Section 106 Consultation), and Surface Water Aquatic Ecology and Special Status Species Briana Grange, NRC and Habitats Socioeconomics and Environmental Justice Jeff Rikhoff Socioeconomics, Environmental Justice, Uranium Fuel Cycle, and Postulated Margie Kotzalas Accidents

6. Logistics The environmental audit will be conducted during the week of December 1, 2020. An entrance meeting will be held with the applicant management at the beginning of the audit. An exit meeting will be held at the end of this audit. These meetings will be conducted using Microsoft Teams software.
7. Special Requests The staff requests that the applicant make available on the North Anna online reference portal, the information identified on the Environmental Audit Needs List (Enclosure 2) prior to the audit.

Plant staff who are subject matter experts in the disciplines listed on the Environmental Site Audit Needs List should be available for interviews, to be conducted via tele-meetings.

8. Deliverables An audit summary report is scheduled to be issued by NRC staff within 90 days from the end of the environmental audit.

ENCLOSURE 2 NORTH ANNA POWER STATION, UNITS 1 AND 2 LICENSE RENEWAL ENVIRONMENTAL AUDIT NEEDS LIST Please be prepared to discuss the following issues and make the following available during the environmental site audit.

Questions, Document Needs, and Breakout Sessions Specific questions and document needs are provided below by resource area. In addition, please provide for breakout meeting sessions using Microsoft Team with the subject matter expert(s) and/or the contractor(s) responsible for the following topics who can also discuss the corresponding information requests, as described below. The staff uses these meeting sessions as needed to resolve or clarify any outstanding data needs or questions arising from the environmental audit.

Audit Needs:

Alternatives ALT-1 Section E.2.6 of the ER indicates that no action regarding license renewal of NAPS would require the consideration of 1,672 MWe of replacement power. This value appears to be used for the basis of the alternative analyses presented in ER Sections E.7 and E.8. However, other sources reviewed by NRC suggest that the total replacement power value for NAPS should be closer to 1,892 MWe. Please clarify the basis for the replacement power value(s) presented in the NAPS ER.

Aquatic A-1 Section E3.7.7, Studies and Monitoring, of the ER describes a semi-annual sampling program to monitor Asiatic clams in the reservoir. Please provide copies for NRC staff review of results or any reports associated with this sampling program for the past 5 years.

A-2 The ER references annual reports titled, Environmental Study of Lake Anna, Waste Heat Treatment Facility and the Lower North Anna River, through 2018. Are more recent reports now available (i.e., 2019 or 2020)? If so, please provide copies of these reports for NRC staff review.

A-2 (A-3) The ER describes several aquatic studies and monitoring programs in connection with NAPS. Is Dominion aware of any other aquatic studies or monitoring not associated with NAPS that are occurring in Lake Anna Reservoir or in the Lake Anna River near NAPS? For instance, such monitoring could include initiatives by the U.S. Army Corps of Engineers, conservation-focused organizations, or other Federal, State, or private entities.

Cumulative Impacts CI-1 Please provide name, description, location, and status of any additional past, present, or reasonably foreseeable projects or actions that have been identified since the ER was prepared.

Groundwater GW-1 Some hyperlinks in the reference list are no longer accessible. Please provide updated and accessible links for these references and update the ER reference list with these new links.

GW-2 Table footnote contains gpd but gpd is not used in table. Please confirm/correct text in table and/or footnotes.

Enclosure 2

GW-3 In the ER, Actions are ongoing to investigate and mitigate potential tritium pathways to ground in the area of GWP-18.

(a) Please provide as-built information on the Mat sumps including the U-1 Mat Sump East sump and locations of other sumps relative to elevations of residual soils, fractured subsurface bedrock and groundwater levels.

(b) Please include a description of any ongoing or completed remediation actions and the residual activity remaining after the remediation was completed, if it is not ongoing and, any additional actions taken related to characterize elevated 2019 tritium concentrations in GWP-3, GWP-18 and the U-1 Mat Sump East.

(c) GWP-18 is screened in the fractured rock (Haley and Aldrich, 2015). This zone is noted as a preferred groundwater pathway. Please provide information on any additional tritium detections downgradient of GWP-18 in bedrock and soil and, characterization of the hydraulic connection of the U-1 Mat Sump East and the groundwater flow system.

(d) Please provide information on the likely tritium sources and the presence of boron in the 2019 groundwater sampling results and, characterize the significance of boron if present.

(e) Is the water sampled from theU-1 Mat Sump East considered to be groundwater?

If so, has the State of Virginia been notified of the tritium groundwater standard exceedance (i.e., 20,000 pCi/L) for the 2019 sampling period?

GW-4 NAPS 2019 groundwater sampling results note that Increased tritium concentrations are due to the draining of 1-SI-P-1B to the Unit 1 Safeguards Valve Pit. 1-SI-P-1B was drained to the U-1 Safeguards Valve pit due to 1-DA-P-lA/1B Safeguards Sump pumps being out of service. Tritium in the U-1 East Mat Sump was released as liquid effluent via the station liquid waste system.

(a) Please characterize the effluent quality drained from 1-SI-P-1B.

(b) Please provide as-built information and map locations of the U-1 Safeguards Valve pit relative to groundwater levels and the groundwater flow system and, any information related to the interaction of water levels in the pit to groundwater levels.

(c) Is the U1B Mat Sump (Haley and Aldrich, 2015) also known as the U-1 Sump East sump as listed in the NAPS Radiological Environmental Monitoring Program (REMP) reports? If not, which sump in the Haley and Aldrich report is also known as the U-1 Mat Sump East as referred to in the REMP reports?

(d) Please provide a map that includes site features and legible labels for all sampling locations listed in Attachment 8, "RESULTS OF GROUND WATER PROTECTION INITIATIVE SAMPLE ANALYSIS" within the REMP report.

GW-5 Based on groundwater level contour patterns as characterized in the Haley and Aldrich (2015), page 37, the Pipe Tunnel appears to be losing (contributing) water to the groundwater flow system.

(a) Please provide information on the as-built characteristics of the tunnel with respect to groundwater table levels and the surrounding soils and bedrock.

(b) Please characterize the effluent within the pipes of the Pipe Tunnel with respect to elevated 2019 tritium groundwater concentrations.

(c) Please identify any aliases within the ER for the Pipe Tunnel as identified in Haley and Aldrich (2015).

(d) Please provide information or documented investigations that characterize hydraulic connection of the potential Pipe Tunnel leakage with the groundwater flow system and the influence of potential tunnel leakage on the flow system.

(e) Please identify any recent investigations that further characterize the historical tritium sources releasing to the groundwater system that emanate from small lenses both above the water table in the vadose zone and below the water table as described in Haley and Aldrich (2015).

(f) Please comment on the precipitation during time frame of 2019 REMP sampling and any potential relationship to the elevated tritium sampling data for 2019 from sources in the small lenses given the relatively wet period in the 4th quarter of 2019.

GW-6 In the ER, No unplanned radioactive liquid releases were reported between 2012 and 2019. Other areas of ER indicate no unplanned releases 2012 and 2017 (e.g., Table E6.1-1 Environmental Impacts Related to SLR at NAPS; SMALL impact. No unplanned radioactive liquid releases were reported between 2012 and 2017.)

(a) Please provide the rationale for the statement in Table E8.0-3, Page E-8-12 of No unplanned radioactive liquid releases were reported between 2012 and 2019 and including different periods time elsewhere in the ER.

(b) Please provide the rationale for not including the more recent 2018 or 2019 sampling data regarding unplanned releases in the ER and identify any updates to the ER that may be needed for inclusion of the 2019 sampling data.

GW-7 In the ER, Based on the review of site records from the seven years from 2013-2019, there has been no inadvertent nonradioactive release that would not be classified as an incidental spill as defined by OSHA. This statement appears to be inconsistent with the reporting period in the previous paragraph in Section E3.6.4.2.1 History of Radioactive Releases which states that No unplanned radioactive liquid releases were reported between 2012 and 2019. Please account for the potential inconsistency in these two reporting periods here and elsewhere in the ER.

GW_Doc-1 Please provide the report supporting the NEI 07-07 initiative which characterizes the hydrogeology of the site and establishes the conceptual site model and include recent groundwater contour maps and boring information as available.

Breakout Breakout session meeting with subject matter expert responsible for the groundwater Session hydrology and use and, water quality sections of the ER and who can discuss the corresponding information requests.

Land Use and Visual LU-1 Provide a copy of (or link to) the comprehensive land use plans for Louisa and Spotsylvania counties, if they exist.

LU-2 Provide information on the possible presence of mineral resources on the NAPS site or immediately adjacent to the site.

LU-3 Does Dominion currently allow hunting on the NAPS property?

LU-4 PENDING: If the NRC is not able to visit the site to take photos, we would request the applicant provide photos from various locations from which the plant is visible from the public.

Microbiological Hazards MBH-1 Sections E3.10.1 and E4.9.1 of the ER describe harmful algal blooms in Lake Anna in 2018 and an associated sampling plan that Dominion developed and performed through October 2018. Has Dominion observed harmful algal blooms in 2019 or 2020? If so, has Dominion performed any associated sampling?

Air Quality and Noise NOI-1 Section E3.4 of the ER identifies that NAPS received one noise complaint for the five-year period from 2013-2017.

(a) Did NAPS make a public announcement or notification regarding the 24-hr emergency diesel generator test run?

(b) Provide the documentation of the complaint.

(c) Has NAPS received noise complaints prior to 2013 or since 2017?

NOI-2 Section E3.4 of the ER identifies that NAPS monitors noise at and around the plant for occupational and ambient effects on an as-needed basis and performs noise surveys.

Provide a summary of noise surveys or monitoring that have been conducted; identify in the discussion the areas surveyed and provide sound levels measured. Provide copies of noise surveys conducted for review.

NOI-3 Describe the NAPS off-site noise environment and identify primary off-site noise sources in the vicinity of NAPS.

NOI_Doc-1 Document Needs. The following ER Air Quality

References:

(a) VDEQ. 2019b. Stationary Source Permit to Operate, North Anna Power Station, Registration Number 40726. June 13, 2019.

(b) Dominion. 2014a. Annual Update and Air Emissions Statements for 2013, Dominion North Anna Power Station, Registration No. 40726. Submitted to Virginia Department of Environmental Quality, Northern Virginia Regional Office, Woodbridge, Virginia. April 12, 2014.

(c) Dominion. 2015c. Annual Update and Air Emissions Statements for 2014, Dominion North Anna Power Station, Registration No. 40726. Submitted to Virginia Department of Environmental Quality, Northern Virginia Regional Office, Woodbridge, Virginia. April 12, 2015.

(d) Dominion. 2016c. Annual Update and Air Emissions Statements for 2015, Dominion North Anna Power Station, Registration No. 40726. Submitted to Virginia Department of Environmental Quality, Northern Virginia Regional Office, Woodbridge, Virginia. March 15, 2016.

(e) Dominion. 2017a. Annual Update and Air Emissions Statements for 2016, Dominion North Anna Power Station, Registration No. 40726. Submitted to Virginia Department of Environmental Quality, Northern Virginia Regional Office, Woodbridge, Virginia. April 10, 2017.

(f) Dominion. 2018b. Annual Update and Air Emissions Statements for 2017, Dominion North Anna Power Station, Registration No. 40726. Submitted to Virginia Department of Environmental Quality, Northern Virginia Regional Office, Woodbridge, Virginia, March 7, 2018.

(g) Dominion. 2019b. 2018 Annual Update and Air Emissions Statement. Dominion Energy - North Anna Power Station. DEQ Air Registration No. 40726. Submitted to Virginia Department of Environmental Quality, Northern Virginia Regional Office, Woodbridge, Virginia, March 15, 2019.

Breakout Breakout session meeting with subject matter expert responsible for the Noise Session sections of the ER and who can discuss the corresponding information requests: would like the SME that developed the meteorological sections of the ER to be present (do not have any specific items to discuss pertaining to air quality emissions - currently reviewing the photos on the portal and would like to discuss with the SME the noted difference in the ER regarding precipitation measurements from NAs onsite primary met tower and that measured at Richmonds, and any potential gaps in precipitation measurements for the 1988-2017 period of record).

Waste Management WM-1 Provide procedures related to the radioactive and nonradioactive Waste Management Program, Waste Minimization Program, Chemical Control Program, General Industrial Safety Requirements, and Electrical Safety.

WM-2 In section 3.6.4.2.1 of the ER, Dominion stated that between 2012 and 2019, there have been no inadvertent radioactive liquid releases. However, on March 2, 2014, there was one inadvertent gaseous release. referenced in the ER. Have there been any reportable unplanned releases of radioactive materials which would trigger a notification requirement since the ER was written? Provide a description of releases (How does Dominion plan to handle unplanned releases?)

WM-3 In section 3.6.4.2.2 of the ER North Anna stated that based on the review of site records for the most recent 7 years (2013-2019), there has been no inadvertent nonradioactive release that would not be classified as an incidental spill as defined by OSHA. Provide the most current records to see if there has been any reportable inadvertent release which would trigger a notification requirement since the ER was written.

WM-4 North Anna is subject to the reporting provisions of 40 CFR Part 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. Any discharges of oil in such quantities that

may be harmful to the public health or welfare or the environment must be reported to the National Response Center. In section 9.5.3.6 of the ER, the applicant discusses reportable spills, and states that for the 7-year period of 2012-2018 there were no reportable spills. Have there been any reportable spills which would trigger this notification requirement since the ER was written? Please provide a description of any spills.

WM-5 North Anna is subject to the reporting provisions of State Water Control Law §62.1-44.34:19. This reporting provision requires that any release of regulated substance from an underground storage tank containing a petroleum product be reported to the VDEQ.

In section 9.5.5.12.6 of the ER, the applicant discusses reportable the only reportable spill occurring between 2013 and 2018 was an underground fuel oil leak from the leaking 2H B fuel oil feed line which occurred in December 2016. The applicant states that the amount of fuel oil that leaked was not quantified. Please provide additional information on the spill. Have there been any reportable spills which would trigger this notification requirement since the ER was written? Please provide a description of any spills.

Breakout (a) Radiation Protection Program: Overview of the program with emphasis on the Session ALARA program to control worker radiation exposure (annual dose goals and status).

Are there any proposed changes or upgrades to the program being considered during the license renewal term?

(b) Radioactive solid waste: review how the plant plans to handle low-level radioactive waste (Class A, B, and C, mixed waste, and spent nuclear fuel) during the license renewal term (onsite storage, potential expansion of storage facilities, and disposal options). Are there any proposed changes or upgrades to the program being considered during the license renewal term?

(c) Radioactive gaseous and liquids effluents: review how the plant processes radioactive effluents to maintain radiation doses to the public to levels that are ALARA.

Are there any proposed changes or upgrades to the program being considered during the license renewal term?

Historic Preservation Act HC-1 Provide consultation letters and other communication documents indicating correspondence to and from the Virginia SHPO/VDHR, and to and from Federally or State recognized Indian tribes that were either not included in the ER or were received/sent since submittal of the ER. Describe the status of any architectural surveys of NAPS structures being conducted to determine National Register of Historic Places eligibility.

Breakout Breakout session meeting with subject matter expert responsible for the historic and Session cultural resources sections of the ER and who can discuss the corresponding information request: dont anticipate needing to discuss Dominions architectural survey of plant structures at a level of detail that would require the surveyors participation; however, would like to have an SME available who can generally discuss 1) the current status of the survey; 2) whether any resources have been determined eligible for nomination to the National Register of Historic Places (NRHP); and 3) any consultations between Dominion and the SHPO that have occurred on this or any related historic and cultural resource matters since the ER was submitted).

Special Status Species SSH-1 Did the Virginia Marine Resource Commission (VMRC), Virginia Department of Game and Inland Fisheries (VDGIF), Virginia Department of Conservation and Recreation (VDCR), or U.S. Fish and Wildlife Service (FWS) respond to Dominions July 2019 letters including in Attachment C to the ER? If so, please provide copies of those responses for NRC staff review.

SSH-2 Section E3.7.6, Procedures and Protocols, of the ER describes guidance that Dominion has developed concerning the review of proposed construction and changes to existing equipment or processes for environmental impacts and permitting requirements. Please provide a copy of this guidance for NRC staff review.

SSH-3 Section E3.7.7, Studies and Monitoring, of the ER states: Dominion performs terrestrial ecological monitoring as required for permitting and permit compliance.

Please further describe this ecological monitoring and provide copies of any associated monitoring reports for NRC staff review.

SSH-4 Sections E.3.7.7.3, Bat Monitoring, and E3.7.7.4, Rare and Endangered Plant Monitoring, of the ER describe a 2018 waiver granted by the U.S. Army Corps of Engineers for a commitment to conduct biennial surveys for the northern long-eared bat (Myotis septentrionalis), small whorled pogonia (Isotria medeoloides), and other threatened and endangered species in connection with the Clean Water Act Section 404 permit for NAPS Unit 3. Does the 2018 waiver continue to be the most recent waiver? If a more recent waiver has been granted, please provide a copy for NRC staff review.

SSH-5 Section E3.7.7.4, Rare and Endangered Plant Monitoring, states: Monitoring of rare and endangered plant species along transmission ROWs generally occurs annually for selected sites. Is Dominion aware of the discovery of federally endangered, threatened, or proposed species during such monitoring? If so, please provide a list of the species identified and supporting monitoring reports or records for NRC staff review.

SSH-6 Section E3.7.8.1, Federally Listed Species, states: A total of six species in Louisa County and adjacent Spotsylvania County are listed as federally endangered, threatened, under review, or species identified as in recovery. However, this section only discusses five species (northern long-eared bat, dwarf wedge mussel, yellow lance, green floater, and small whorled pogonia). Please clarify whether there is a sixth species that should be discussed within this section.

Socioeconomics None Surface Water SW-1 The ER summarizes historical regulatory infractions including notices of violation issued to NAPS for the period 2013-2019. As applicable, provide an updated summary of and describe any Notices of Violation; nonconformance notifications; or related infractions received from regulatory agencies associated with permitted effluent discharges, sanitary sewage systems, groundwater or soil contamination, as well as any involving spills, leaks, and other inadvertent releases (e.g., petroleum products, chemicals, or radionuclides) received since 2019. In addition, summarize any self-reported VPDES permit infractions over the last five years (2016-2020) (i.e., including any disclosed in Discharge Monitoring Reports). Provide copies of relevant correspondence to and from the responsible regulatory agencies.

SW-2 The ER summarizes surface water withdrawals and usage by NAPS for the period 2012-2019, as summarized in Tables E3.6-4(a) and (b). Provide surface water withdrawal data for 2020, when available.

SW-3 Table E3.6-4(b) in the ER summarizes monthly surface water withdrawals and usage by NAPS Units 1 and 2 and "North Anna Dam" for the period 2012-2019. For North Anna Dam, clarify whether this volume represents flow over (releases from) the North Anna Dam (or some other withdrawals). If other, describe.

SW-4 The ER describes the circulating water intake bay and screenwell configuration.

Provide an illustration, if available, that shows the internal arrangement of a representative intake bay, rack, screens, and pump(s).

SW-5 The ER references and briefly describes the circulating water outlet. Provide an illustration of this structure, if available.

SW_Doc-1 VPDES permit renewal application (dated 10/15/18) and addendum submitted 3/12/19.

SW_Doc-2 Letter from VA DEQ (dated Sept 16, 2020) regarding Dominions request for proof of Clean Water Act Section 401 certification to support relicensing SW_Doc-3 VDH. 1991. Waterworks Operation Permit, North Anna Nuclear Power Station, Louisa County. DEQ Permit # 2109610. June 24, 1991.

SW_Doc-4 VDH. 2014. Waterworks Operation Permit, North Anna Nuclear Information Center, Louisa County. DEQ Permit #2109600. May 13, 2014.

Breakout Breakout session meeting with subject matter expert responsible for the surface water Session hydrology and use sections of the ER and who can discuss the corresponding information requests. Groundwater staff will attend the Surface water session.

Terrestrial T-1 Describe the current use of herbicides in grounds maintenance.

T-2 Provide 2020 data on the four bald eagle nests onsite. Please include a map showing the four bald eagle nests.

T-3 Provide a copy or link to Dominions internal guidance on complying with the Migratory Bird Treaty Act.

ENCLOSURE 3 REMOTE SITE TOURS by MEANS of PHOTOGRAPHS or VIDEOS Please provide photographs and/or video documentation for the following site locations Title or Features Observed Essential Optional Number Participants Participants ST-2 Circulating water intake structure (exterior and K. Folk, B.

interior). Grange ST-3 Discharge structure and discharge canal (exterior K. Folk, B.

and interior) and dikes. Grange ST-4 Outfall 001 at dike 3 (general area) K. Folk ST-5 Storm drain outfall sampling locations J. Giacinto ST-6 Subsurface drain sampling locations J. Giacinto ST-7 As part of the NA general site tour and vicinity, N. Martinez identify nearby noise sensitive receptors ST-8 Tour of the primary and back-up of the N. Martinez meteorological tower ST-9 Tour of various natural terrestrial and aquatic B. Grange habitats on the North Anna site, including: (1)

North Anna Reservoir and North Anna River regions where Dominion collects samples for annual aquatic studies, (2) forested areas where 2016 bat survey was conducted, (3) areas of site where 2010 and 2012 endangered plant surveys were conducted, and (4) any other areas of the site on which Dominion is actively monitoring, managing, or restoring natural habitat.

ST-10 The radiation protection/access control area to P. Clark observe a walkdown of the liquid and gaseous radwaste systems inside the plant to get a sense of the components listed in the ER and how they are routed.

ST-11 The radiation protection/access control area to P. Clark observe the low-level radioactive waste storage and processing areas, including mixed waste.

ST-12 The radiation protection/access control area to P. Clark observe the radiological environmental monitoring program (REMP) - a small, representative sample of monitoring stations (e.g., air monitoring stations, TLD stations, drinking water, surface water, sediment, groundwater, milk, and vegetation, including monitoring stations co-located with State monitoring stations).

ST-14 Non-Rad waste storage sites/RCRA permitted P. Clark storage (if any)

ST-15 Independent spent fuel storage installation P. Clark (ISFSI).

ST-16 Various locations from which the plant is visible C. Hsu, P. Doub from the public.

Enclosure 3

ST-17 During general site tour, identify location for the R. Hoffman proposed North Anna Unit 3 (onsite location considered for replacement power alternatives).