Supplemental Environmental 

Impact Statement for the 

Combined License (COL) for 

North Anna Power Station Unit 3 

Final Report 

Office of New Reactors

NUREG-1917
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Supplemental Environmental 

Impact Statement for the 

Combined License (COL) for 

North Anna Power Station Unit 3 

Final Report 

Manuscript Completed: February 2010 

Date Published: February 2010 

Division of Site and Environmental Review 

Office of New Reactors 

NUREG-1917 

February 2010 iii NUREG-1917, SEIS 

Abstract 

This supplemental environmental impact statement (SEIS) includes the U.S. Nuclear Regulatory 

Commission (NRC) staff’s analysis that considers and weighs the environmental impacts of 

constructing and operating a new nuclear unit (Unit 3) at the North Anna Power Station (NAPS) 

site near Mineral, Virginia, and the mitigation measures available for reducing or avoiding 

adverse impacts. 

On November 27, 2007, the NRC issued Early Site Permit (ESP)-003 to Dominion Nuclear 

North Anna, LLC for the NAPS ESP site (the site of the proposed Unit 3). An ESP is an NRC 

approval of a site as suitable for construction and operation of one or more new nuclear units. 

The NRC’s detailed review of the environmental impacts of constructing and operating new 

units at the NAPS ESP Site is documented in Environmental Impact Statement for an Early Site 

Permit (ESP) at the North Anna ESP Site (NUREG-1811), which was published in December 

2006. Coincidentally, on November 27, 2007, Dominion submitted an application for a 

combined license (COL) for the NAPS site, referencing this ESP. A COL is a Commission 

approval for the construction and operation of one or more nuclear power facilities. For a COL 

application that references an ESP, the NRC staff, pursuant to Title 10 of the Code of Federal 

Regulations (CFR) 51.75(c), prepares a supplement to the ESP EIS in accordance with 

10 CFR 51.92(e). 

NRC regulations related to the environmental review of COL applications are contained in 10 CFR 

Part 51 and 10 CFR Part 52, Subpart C. Pursuant to NRC regulations in 10 CFR 51.50(c)(1), a 

COL applicant referencing an ESP need not submit information or analyses regarding 

environmental issues that were resolved in the ESP EIS, except to the extent the COL applicant 

has identified new and significant information regarding such issues. In addition, pursuant to 

10 CFR 52.39, matters resolved in the ESP proceedings are considered to be resolved in any 

subsequent proceedings, absent identification of new and significant information. 

The NRC staff’s recommendation to the Commission, considering the environmental aspects of 

the proposed action, is that the COL be issued. This recommendation is based on (1) the 

application, including the Environmental Report (ER), submitted by Virginia Electric Power 

Company, doing business as Dominion Virginia Power and the Old Dominion Electric 

Cooperative, collectively referred to as Dominion; (2) the staff’s review conducted for the ESP 

application and documented in the ESP EIS; (3) consultation with Federal, State, Tribal, and 

local agencies; (4) the staff’s own independent review of potential new and significant 

information available since preparation and publication of the ESP EIS; (5) the staff’s 

consideration of comments related to the environmental review that were received during the 

review process; and (6) the assessments summarized in this SEIS, including the potential 
Abbreviations/Acronyms 

NUREG-1917, SEIS iv February 2010 

mitigation measures identified in Dominion’s ER and in the SEIS. The staff’s evaluation of the 

safety and emergency preparedness aspects of the proposed action will be addressed in the 

staff’s Safety Evaluation Report. 
February 2010 v NUREG-1917, SEIS 

Contents 

Abstract ......................................................................................................................................... iii

Executive Summary .................................................................................................................... xix

Abbreviations/Acronyms ........................................................................................................... xxiii

Linking North Anna ESP EIS Sections to SEIS Sections ......................................................... xxxi

1.0 Introduction ....................................................................................................................... 1-1

1.1 Background ............................................................................................................ 1-1

1.1.1 COL Application and Review ................................................................... 1-2

1.1.2 Concurrent Reviews ................................................................................. 1-4

1.2 The Proposed Federal Action ................................................................................ 1-5

1.3 The Purpose and Need for the Proposed Action ................................................... 1-5

1.4 Alternatives to the Proposed Action ....................................................................... 1-6

1.5 Compliance and Consultations .............................................................................. 1-6

1.6 Report Contents ..................................................................................................... 1-6

1.7 References ............................................................................................................. 1-7

2.0 Environment ..................................................................................................................... 2-1

2.1 Site Location .......................................................................................................... 2-1

2.2 Land Use ................................................................................................................ 2-3

2.2.1 The Site and Vicinity ................................................................................ 2-4

2.2.2 Transmission Line Rights-of-Way ............................................................ 2-4

2.2.3 The Region ............................................................................................... 2-5

2.3 Meteorology and Air Quality ................................................................................... 2-5

2.4 Geology .................................................................................................................. 2-6

2.5 Radiological Environment ...................................................................................... 2-7

2.6 Water ..................................................................................................................... 2-8

2.6.1 Hydrology ................................................................................................. 2-8

2.6.2 Water Use .............................................................................................. 2-10

2.6.3 Water Quality ......................................................................................... 2-10

2.7 Ecology ................................................................................................................ 2-13

2.7.1 Terrestrial Ecology ................................................................................. 2-13

2.7.1.1 Biological Communities of the NAPS Site ............................ 2-13

2.7.1.2 Biological Communities within the North Anna to 

Ladysmith Transmission Line Right-of-Way ......................... 2-15
Contents 

NUREG-1917, SEIS vi February 2010 

2.7.1.3 Threatened and Endangered Terrestrial Species ................. 2-15

2.7.1.4 Terrestrial Ecological Monitoring .......................................... 2-19

2.7.2 Aquatic Ecology ..................................................................................... 2-19

2.7.2.1 Aquatic Communities in the Vicinity of the NAPS Site ......... 2-19

2.7.2.2 Threatened and Endangered Aquatic Species ..................... 2-24

2.7.2.3 Aquatic Ecology Monitoring .................................................. 2-26

2.7.2.4 Instream Flow Incremental Methodology Study ................... 2-27

2.8 Socioeconomics ................................................................................................... 2-30

2.8.1 Demographics ........................................................................................ 2-30

2.8.1.1 Resident Population ............................................................. 2-31

2.8.1.2 Transient Population ............................................................. 2-33

2.8.1.3 Migrant Labor ....................................................................... 2-33

2.8.2 Community Characteristics .................................................................... 2-33

2.8.2.1 Economy ............................................................................... 2-34

2.8.2.2 Transportation ...................................................................... 2-38

2.8.2.3 Property Taxes ..................................................................... 2-39

2.8.2.4 Aesthetics and Recreation .................................................... 2-39

2.8.2.5 Housing ................................................................................ 2-40

2.8.2.6 Public Services ..................................................................... 2-40

2.8.2.7 Education .............................................................................. 2-45

2.9 Historic and Cultural Resources .......................................................................... 2-46

2.9.1 Cultural Background ............................................................................... 2-46

2.9.2 Historic and Cultural Resources at the NAPS Site ................................. 2-46

2.9.3 Native American Consultation ................................................................ 2-47

2.10 Environmental Justice.......................................................................................... 2-48

2.10.1 Analysis .................................................................................................. 2-50

2.10.2 Scoping and Outreach ........................................................................... 2-52

2.10.3 Health Preconditions and Special Circumstances of the Minority 

and Low-Income Populations ................................................................. 2-54

2.10.4 Migrant Populations ............................................................................... 2-54

2.10.5 Environmental Justice Summary ............................................................ 2-56

2.11 Related Federal Projects and Consultations ........................................................ 2-56

2.12 References ........................................................................................................... 2-56
Contents 

February 2010 vii NUREG-1917, SEIS 

3.0 Site Layout and Plant Description .................................................................................... 3-1

3.1 External Appearance and Site Layout ................................................................... 3-1

3.2 Plant Description .................................................................................................... 3-2

3.2.1 Plant Water Use ....................................................................................... 3-2

3.2.1.1 Plant Water Consumption ....................................................... 3-3

3.2.1.2 Plant Water Treatment ........................................................... 3-3

3.2.2 Cooling System ........................................................................................ 3-3

3.2.2.1 Description and Operational Modes ....................................... 3-4

3.2.2.2 Component Descriptions ........................................................ 3-4

3.2.3 Radioactive Waste Management System ................................................ 3-8

3.2.3.1 Liquid Radioactive Waste-Management System .................... 3-8

3.2.3.2 Gaseous Radioactive Waste-Management System ............... 3-9

3.2.3.3 Solid Radioactive Waste-Management System ..................... 3-9

3.2.4 Nonradioactive Waste Management Systems ....................................... 3-10

3.2.4.1 Effluents Containing Chemical and Biocides ........................ 3-10

3.2.4.2 Sanitary System Effluents .................................................... 3-11

3.2.4.3 Other Effluents ...................................................................... 3-12

3.3 Power Transmission System ............................................................................... 3-12

3.4 References ........................................................................................................... 3-13

4.0 Environmental Impacts of Construction ............................................................................ 4-1

4.1 Land-Use Impacts .................................................................................................. 4-2

4.1.1 The Site and Vicinity ................................................................................ 4-2

4.1.2 Offsite Transmission Line Rights-of-Way ................................................. 4-3

4.2 Meteorological and Air-Quality Impacts ................................................................. 4-3

4.3 Water-Related Impacts .......................................................................................... 4-4

4.3.1 Hydrological Alterations ........................................................................... 4-4

4.3.2 Water-Use Impacts .................................................................................. 4-6

4.3.3 Water-Quality Impacts .............................................................................. 4-6

4.4 Ecological Impacts ................................................................................................. 4-7

4.4.1 Terrestrial Ecosystem Impacts ................................................................. 4-7

4.4.2 Aquatic Ecosystem Impacts ..................................................................... 4-9

4.4.3 Threatened and Endangered Species ................................................... 4-12
Contents 

NUREG-1917, SEIS viii February 2010 

4.5 Socioeconomic Impacts ....................................................................................... 4-13

4.5.1 Physical Impacts .................................................................................... 4-14

4.5.1.1 Workers and the Local Public ............................................... 4-14

4.5.1.2 Buildings ............................................................................... 4-14

4.5.1.3 Roads ................................................................................... 4-15

4.5.1.4 Aesthetics and Recreation .................................................... 4-15

4.5.2 Demography ........................................................................................... 4-16

4.5.3 Community Characteristics .................................................................... 4-16

4.5.3.1 Economy ............................................................................... 4-16

4.5.3.2 Taxes .................................................................................... 4-17

4.5.4 Infrastructure and Community Service Impacts ..................................... 4-17

4.5.4.1 Transportation ...................................................................... 4-17

4.5.4.2 Recreation ............................................................................ 4-18

4.5.4.3 Housing ................................................................................ 4-18

4.5.4.4 Public Services ..................................................................... 4-19

4.5.4.5 Education .............................................................................. 4-19

4.5.5 Summary of Socioeconomic Impacts ..................................................... 4-20

4.6 Historic and Cultural Resources .......................................................................... 4-20

4.7 Environmental Justice .......................................................................................... 4-22

4.8 Nonradiological Health Impacts ........................................................................... 4-23

4.8.1 Public and Occupational Health ............................................................. 4-24

4.8.2 Noise Impacts ........................................................................................ 4-24

4.8.3 Impacts of Transporting Construction Materials and Personnel 

to the Proposed Unit 3 Site .................................................................... 4-25

4.8.4 Summary of Nonradiological Health Impacts ......................................... 4-26

4.9 Radiological Health Impacts ................................................................................ 4-27

4.9.1 Direct Radiation Exposures .................................................................... 4-27

4.9.2 Radiation Exposures from Gaseous Effluents ....................................... 4-28

4.9.3 Radiation Exposures from Liquid Effluents ............................................ 4-28

4.9.4 Total Dose to the Construction Workers ................................................ 4-28

4.9.5 Summary of Radiological Health Impacts .............................................. 4-29

4.10 Measures and Controls to Limit Adverse Impacts During Construction ............... 4-29

4.11 Summary of Construction Impacts ....................................................................... 4-30

4.12 References ........................................................................................................... 4-30
Contents 

February 2010 ix NUREG-1917, SEIS 

5.0 Environmental Impacts of Operation ................................................................................ 5-1

5.1 Land-Use Impacts .................................................................................................. 5-2

5.1.1 The Site and Vicinity ................................................................................ 5-2

5.1.2 Offsite Transmission Line Rights-of-Way ................................................. 5-2

5.2 Meteorological and Air-Quality Impacts ................................................................. 5-3

5.3 Water-Related Impacts .......................................................................................... 5-3

5.3.1 Hydrological Alterations ........................................................................... 5-4

5.3.2 Water-Use Impacts .................................................................................. 5-4

5.3.3 Water-Quality Impacts .............................................................................. 5-5

5.4 Ecological Impacts ................................................................................................. 5-7

5.4.1 Terrestrial Ecosystem .............................................................................. 5-7

5.4.1.1 Cooling Tower Impacts on Terrestrial Ecological 

Resources .............................................................................. 5-7

5.4.1.2 Noise ...................................................................................... 5-8

5.4.1.3 Avian Collisions ...................................................................... 5-8

5.4.1.4 Shoreline and Riparian Habitat ............................................... 5-8

5.4.1.5 Transmission Line Rights-of-Way ........................................... 5-9

5.4.1.6 Summary of Terrestrial Ecosystems Impacts ....................... 5-10

5.4.2 Aquatic Impacts ...................................................................................... 5-10

5.4.2.1 Intake and Discharge Systems ............................................. 5-10

5.4.2.2 Impingement and Entrainment ............................................. 5-11

5.4.2.3 Aquatic Thermal Impacts ...................................................... 5-12

5.4.2.4 Downstream Impacts ............................................................ 5-12

5.4.2.5 Summary of Aquatic Impacts ................................................ 5-14

5.4.3 Threatened and Endangered Species ................................................... 5-15

5.4.3.1 Terrestrial Species ................................................................ 5-15

5.4.3.2 Aquatic Species .................................................................... 5-16

5.5 Socioeconomic Impacts ....................................................................................... 5-17

5.5.1 Physical Impacts .................................................................................... 5-17

5.5.1.1 Workers and the Local Public ............................................... 5-18

5.5.1.2 Buildings ............................................................................... 5-18

5.5.1.3 Roads ................................................................................... 5-18

5.5.1.4 Aesthetics and Recreation .................................................... 5-18

5.5.2 Demography ........................................................................................... 5-21

5.5.3 Community Characteristics .................................................................... 5-22

5.5.3.1 Economy ............................................................................... 5-22

5.5.3.2 Taxes .................................................................................... 5-22
Contents 

NUREG-1917, SEIS x February 2010 

5.5.4 Infrastructure and Community Service Impacts ..................................... 5-23

5.5.4.1 Transportation ...................................................................... 5-23

5.5.4.2 Recreation ............................................................................ 5-23

5.5.4.3 Housing ................................................................................ 5-26

5.5.4.4 Public Services ..................................................................... 5-27

5.5.4.5 Education .............................................................................. 5-28

5.5.5 Summary of Socioeconomic Impacts ..................................................... 5-28

5.6 Historic and Cultural Resource Impacts ............................................................... 5-28

5.7 Environmental Justice Impacts ............................................................................ 5-29

5.8 Nonradiological Health Impacts ........................................................................... 5-31

5.8.1 Public Health .......................................................................................... 5-31

5.8.2 Occupational Health ............................................................................... 5-33

5.8.3 Noise Impacts ........................................................................................ 5-34

5.8.4 Acute Effects of Electromagnetic Fields ................................................. 5-34

5.8.5 Chronic Effects of Electromagnetic Fields ............................................. 5-34

5.8.6 Impacts of Transporting Operations Personnel to the Site .................... 5-35

5.8.7 Summary of Nonradiological Health Impacts ......................................... 5-36

5.9 Radiological Impacts of Normal Operations ......................................................... 5-36

5.9.1 Exposure Pathways ............................................................................... 5-36

5.9.2 Radiation Doses to Members of the Public ............................................ 5-41

5.9.2.1 Liquid Effluent Pathway ........................................................ 5-41

5.9.2.2 Gaseous Effluent Pathway ................................................... 5-43

5.9.2.3 External Radiation Pathway ................................................. 5-43

5.9.3 Impacts to Members of the Public .......................................................... 5-45

5.9.3.1 Maximally Exposed Individual .............................................. 5-45

5.9.3.2 Population Dose ................................................................... 5-47

5.9.3.3 Summary of Radiological Impacts to the Public ................... 5-48

5.9.4 Occupational Doses to Workers ............................................................. 5-48

5.9.5 Impacts to Biota Other than Members of the Public ............................... 5-48

5.9.6 Radiological Monitoring .......................................................................... 5-49

5.10 Environmental Impacts of Postulated Accidents .................................................. 5-50

5.10.1 Design Basis Accidents .......................................................................... 5-52

5.10.2 Severe Accidents ................................................................................... 5-55

5.10.3 Severe Accident Mitigation Alternatives ................................................. 5-56

5.10.4 Summary of Postulated Accident Impacts ............................................. 5-57
Contents 

February 2010 xi NUREG-1917, SEIS 

5.11 Global Warming, Climate Change, and Greenhouse Gas Impacts ..................... 5-57

5.12 Measures and Controls to Limit Adverse Impacts During Operation ................... 5-59

5.13 Summary of Operational Impacts ........................................................................ 5-60

5.14 References ........................................................................................................... 5-60

6.0 Fuel Cycle, Transportation, and Decommissioning .......................................................... 6-1

6.1 Fuel Cycle Impacts and Solid Waste Management ............................................... 6-1

6.2 Transportation of Radioactive Materials ................................................................ 6-3

6.2.1 Impacts of Crud on Spent Fuel Transportation Accident Impacts ............ 6-3

6.2.2 Nonradiological Impacts ........................................................................... 6-6

6.2.3 Conclusions .............................................................................................. 6-7

6.3 Decommissioning ................................................................................................... 6-8

6.4 References ............................................................................................................. 6-9

7.0 Cumulative Impacts .......................................................................................................... 7-1

7.1 Land Use ................................................................................................................ 7-2

7.2 Air Quality .............................................................................................................. 7-2

7.3 Water Use and Quality ........................................................................................... 7-2

7.4 Terrestrial Ecosystem ............................................................................................ 7-4

7.5 Aquatic Ecosystem ................................................................................................ 7-5

7.6 Socioeconomics, Environmental Justice, Historic and Cultural Resources ........... 7-5

7.7 Nonradiological Health ........................................................................................... 7-6

7.8 Radiological Impacts of Normal Operation ............................................................ 7-7

7.9 Severe Accidents ................................................................................................... 7-7

7.10 Fuel Cycle, Transportation, and Decommissioning ............................................... 7-8

7.11 Staff Conclusions and Recommendations ............................................................. 7-8

7.12 References ............................................................................................................. 7-9

8.0 Need for Power ................................................................................................................. 8-1

8.1 Description of the Power System ........................................................................... 8-3

8.2 Power Demand/Integrated Resource Planning ...................................................... 8-3

8.3 Power Demand/Integrated Resource Planning in the PJM Region ....................... 8-5

8.4 Assessment of Need for Power ............................................................................. 8-6

8.4.1 Programs Affecting Demand .................................................................... 8-8

8.4.2 Comparison of PJM/Dominion Studies with NRC Criteria ...................... 8-10

8.4.2.1 Systematic ............................................................................ 8-10

8.4.2.2 Comprehensive .................................................................... 8-11
Contents 

NUREG-1917, SEIS xii February 2010 

8.4.2.3 Subject to Confirmation ........................................................ 8-12

8.4.2.4 Responsive to Forecasting Uncertainty ................................ 8-13

8.4.3 Need for NAPS Unit 3 ............................................................................ 8-14

8.4.3.1 Need for Base-Load Capacity .............................................. 8-14

8.4.3.2 Other Potential Sources of Capacity .................................... 8-15

8.4.3.3 Need for Reserve Margin ..................................................... 8-18

8.5 NRC Conclusions ................................................................................................. 8-20

8.6 References ........................................................................................................... 8-21

9.0 Alternatives to the Proposed Action ................................................................................. 9-1

9.1 No-Action Alternative ............................................................................................. 9-1

9.2 Energy Alternatives ................................................................................................ 9-2

9.2.1 Alternatives Not Requiring New Generating Capacity ............................. 9-2

9.2.2 Alternatives Requiring New Generating Capacity .................................... 9-5

9.2.2.1 Coal-Fired Generation ............................................................ 9-6

9.2.2.2 Natural Gas-Fired Generation .............................................. 9-11

9.2.3 Other Alternatives .................................................................................. 9-16

9.2.3.1 Oil-Fired Generation ............................................................. 9-16

9.2.3.2 Wind Power .......................................................................... 9-18

9.2.3.3 Solar Power .......................................................................... 9-19

9.2.3.4 Hydropower .......................................................................... 9-20

9.2.3.5 Geothermal Energy .............................................................. 9-20

9.2.3.6 Wood Waste ......................................................................... 9-21

9.2.3.7 Municipal Solid Waste .......................................................... 9-21

9.2.3.8 Other Biomass-Derived Fuels .............................................. 9-22

9.2.3.9 Fuel Cells .............................................................................. 9-22

9.2.4 Combination of Alternatives ................................................................... 9-23

9.2.5 Summary Comparison of Alternatives .................................................... 9-25

9.3 System Design Alternatives ................................................................................. 9-25

9.3.1 Alternative Intake Structure Designs ...................................................... 9-26

9.3.1.1 Proposed Intake Structure .................................................... 9-26

9.3.1.2 Alternative Intake Structures ................................................ 9-26

9.3.2 Alternative Discharge Structure Designs ............................................... 9-27

9.3.2.1 Proposed Discharge Structure ............................................. 9-27

9.3.2.2 Alternative Discharge Structures .......................................... 9-27

9.3.3 Alternative Water Supplies ..................................................................... 9-28

9.3.3.1 Proposed Water Supply ........................................................ 9-28

9.3.3.2 Alternative Water Supplies ................................................... 9-28
Contents 

February 2010 xiii NUREG-1917, SEIS 

9.3.4 Alternative Water-Treatment Systems ................................................... 9-29

9.3.4.1 Proposed Water Treatment System ..................................... 9-29

9.3.4.2 Alternative Water Treatment Systems .................................. 9-29

9.4 Region of Interest and Site-Selection Process .................................................... 9-30

9.5 Alternative Sites ................................................................................................... 9-30

9.6 References ........................................................................................................... 9-30

10.0 Conclusions and Recommendations .............................................................................. 10-1

10.1 Impacts of the Proposed Action ........................................................................... 10-3

10.2 Unavoidable Adverse Environmental Impacts ..................................................... 10-4

10.2.1 Unavoidable Adverse Impacts During Construction ............................... 10-4

10.2.2 Unavoidable Adverse Impacts During Operation ................................... 10-7

10.3 Alternatives to the Proposed Action ..................................................................... 10-7

10.4 Relationship Between Short-Term Uses and Long-Term Productivity 

of the Human Environment .................................................................................. 10-8

10.5 Irreversible and Irretrievable Commitments of Resources ................................... 10-8

10.6 Benefit-Cost Balance ........................................................................................... 10-9

10.6.1 Benefits ................................................................................................ 10-12

10.6.1.1 Societal Benefits ................................................................. 10-12

10.6.1.2 Regional Benefits ............................................................... 10-13

10.6.2 Costs .................................................................................................... 10-15

10.6.2.1 Internal Costs ..................................................................... 10-15

10.6.2.2 External Costs .................................................................... 10-19

10.6.3 Benefit-Cost Summary ......................................................................... 10-19

10.7 Staff Conclusions and Recommendations ......................................................... 10-20

10.8 References ......................................................................................................... 10-20

Appendix A – Contributors to the Supplemental Environmental Impact Statement ................. A-1 

Appendix B – Organizations Contacted ................................................................................... B-1 

Appendix C – Chronology of NRC Staff Environmental Review Correspondence 

Related to the Dominion Virginia Power and Old Dominion Electric 

Cooperative’s Application for a Combined License for Unit 3 at 

the North Anna Power Station Site .................................................................... C-1 

Appendix D – Scoping Comments and Responses ................................................................. D-1 

Appendix E – Comments and Responses on the Draft Supplemental Environmental 

Impact Statement .............................................................................................. E-1 
Contents 

NUREG-1917, SEIS xiv February 2010 

Appendix F – Key Consultation Correspondence ..................................................................... F-1 

Appendix G – Environmental Impacts of Transportation .......................................................... G-1 

Appendix H – Supporting Documentation on Radiological Dose Assessment ........................ H-1 

Appendix I – Early Site Permit Site Characteristics and Plant Parameter Envelope ................ I-1 

Appendix J – Early Site Permit Site Permit Conditions, Commitments, Assumptions, 

and Unresolved Issues ....................................................................................... J-1 

Appendix K – Staff’s Independent Review of Water Budget Impacts ...................................... K-1 

Appendix L – Authorizations and Consultations ....................................................................... L-1 

Appendix M – Severe Accident Mitigation Alternatives ............................................................ M-1 
Contents 

February 2010 xv NUREG-1917, SEIS 

Figures 

2-1 ESP Site Boundaries within the Existing NAPS Site ...................................................... 2-2

2-2 Location of NAPS, 80-km Region .................................................................................. 2-3

2-3 Lake Anna, the Waste Heat Treatment Facility, and the Rivers and Creeks 

in the Vicinity of NAPS ................................................................................................... 2-9

2-4 North Anna Census 2000 Environmental Justice Minority Populations 

Within an 80-km Radius of the NAPS ESP Site ........................................................... 2-52

2-5 North Anna Census 2000 Environmental Justice Low Income Populations 

Within an 80-km Radius of the NAPS ESP Site ........................................................... 2-53

5-1 North Anna Site, Looking Northeast Along the Plant Access Road, with 

Outlines of Hybrid Cooling Tower ................................................................................ 5-20

5-2 North Anna Site, Looking Northeast from Final Approach After Main Gate ................. 5-20

5-3 North Anna Site with Unit 3 Looking Southwest from Unit 1 and Unit 2 

Intake Area ................................................................................................................... 5-21

5-4 Source and Receptor Locations ................................................................................... 5-40

8-1 Map of PJM South, Showing Major Transmission Lines into the Dominion Zone .......... 8-2
Contents 

NUREG-1917, SEIS xvi February 2010 

Tables 

2-1 Federally or State Listed Terrestrial Species Known or Likely to Occur in 

Counties Adjacent to or Downstream from the Lake Anna Reservoir .......................... 2-17

2-2 Fish and Selected Benthic Macroinvertebrates Reported from Lake Anna .................. 2-21

2-3 Fish Species Reported from the North Anna River ...................................................... 2-23

2-4 Federal or State Listed Threatened or Endangered Species Known or 

Likely to Occur in Counties Adjacent to or Downstream from Lake Anna .................... 2-25

2-5 Estimated Age Distribution of Population in 2000 ........................................................ 2-31

2-6 Population Growth in Henrico, Louisa, Orange, Spotsylvania, Caroline, 

Hanover, and King William Counties and the City of Richmond – 

1980 to 2030 ................................................................................................................ 2-32

2-7 Population Growth in the Socioeconomic Impact Area – 2000 to 2006 ....................... 2-32

2-8 Percent Unemployment, Individual Poverty, and Median Household Income.............. 2-34

2-9 Regional Employment Trends – 1990 and 2000 .......................................................... 2-35

2-10 County Full-Time and Part-Time Employment by Type and by Industry ...................... 2-35

2-11 County Full-Time and Part-Time Employment by Type, 2006 ..................................... 2-36

2-12 Aggregated Full-Time and Part-Time Employment by Industry or Business 

Type for Caroline, Hanover, Henrico, King William, Louisa, Orange, and 

Spotsylvania Counties, Fredericksburg, and the City of Richmond, 

1990 to 2006 ................................................................................................................ 2-36

2-13 Housing Units and Housing Units Vacant by County – 1990 and 2000 ....................... 2-41

2-14 Vacant Housing Units for Caroline, Hanover, and King William 

Counties – 2000 ........................................................................................................... 2-42

2-15 Selected County Housing Statistics for 2006 ............................................................... 2-43

2-16 Major Public Water Supply Systems in Caroline, Hanover, Henrico, 

King William, Louisa, Orange, and Spotsylvania Counties .......................................... 2-44

2-17 Summary of County-Level Changes in Population and Minority and 

Low-Income Status of Populations near the NAPS Site, 2000 to 2006 ....................... 2-51

2-18 Selected Health and Mortality Statistics for Minority and White Population 

in Selected Jurisdictions near North Anna, and the Commonwealth of 

Virginia, 1999 and 2006 ............................................................................................... 2-55

4-1 Impacts of Transporting Workers and Construction Materials to/from the 

Proposed Unit 3 Site .................................................................................................... 4-26
Contents 

February 2010 xvii NUREG-1917, SEIS 

5-1 Impact of North Anna Unit 3 and Normal Lake Elevation Increase of 8 cm 

on the Probability of Lake Anna Elevation, Lake Depth at the End of 

Public Launch Ramps, and Height Above Water of Publicly Accessible Docks ........... 5-25

5-2 Nonradiological Impacts of Transporting Workers to/from the Proposed 

Unit 3 Site ..................................................................................................................... 5-36

5-3 Liquid Effluent Release Source Term from Proposed Unit 3 ........................................ 5-37

5-4 Gaseous Effluent Release Source Term from Proposed Unit 3 ................................... 5-39

5-5 Estimated Liquid Pathway Doses for MEIs at Lake Anna from Unit 3 

Liquid Effluents ............................................................................................................. 5-42

5-6 Estimated Gaseous Pathway Doses for MEIs from Unit 3 Gaseous Effluents ............. 5-44

5-7 Comparison of MEI Dose Estimates from Liquid and Gaseous Effluents to 

10 CFR Part 50, Appendix I, Design Objectives .......................................................... 5-46

5-8 Comparison of MEI Dose Estimates from Liquid and Gaseous Effluents 

from Existing Units 1 and 2 and the Proposed Unit 3 to 40 CFR Part 190 

Standards ..................................................................................................................... 5-47

5-9 Collective Total Body Dose within 80 km of the Proposed Unit 3 ................................ 5-48

5-10 Estimated Biota Doses from Proposed Unit 3 .............................................................. 5-49

5-11 Atmospheric Dispersion Factors for NAPS COL Site DBA Calculations ...................... 5-53

5-12 DBA Doses for an ESBWR Reactor ............................................................................. 5-54

6-1 Release Characteristic for Spent Fuel Assembly Crud .................................................. 6-5

6-2 Annual Nonradiological Impacts of Transporting Fuel and Waste to and 

From the NAPS Site, Normalized to the Reference LWR .............................................. 6-7

8-1 Dominion’s Estimated Need for Base-Load Capacity from NAPS Unit 3 ..................... 8-17

8-2 Determination of Installed Reserve Margin .................................................................. 8-19

9-1 Summary of Environmental Impacts of Coal-Fired Power Generation ......................... 9-12

9-2 Summary of Environmental Impacts of Natural Gas-Fired Power Generation ............. 9-17

9-3 Summary of Environmental Impacts of a Combination of Power Sources ................... 9-24

9-4 Summary of Environmental Impacts of Construction and Operation of New 

Nuclear, Coal-Fired, and Natural Gas-Fired Generating Units, and a 

Combination of Alternatives at the NAPS Site ............................................................. 9-25

10-1 Newly Identified Unavoidable Adverse Environmental Impacts from 

Construction ................................................................................................................. 10-5

10-2 Newly Identified Unavoidable Adverse Environmental Impacts from Operation .......... 10-7

10-3 Monetary and Nonmonetary Benefits of the Proposed Unit 3 .................................... 10-10

10-4 Internal and External Costs of Proposed Unit 3 ......................................................... 10-17

February 2010 xix NUREG-1917, SEIS 

Executive Summary 

On November 27, 2007, the U.S. Nuclear Regulatory Commission (NRC) received an 

application from Virginia Electric and Power Company, doing business as Dominion Virginia 

Power (DVP), and Old Dominion Electric Cooperative (ODEC) (collectively Dominion), for a 

combined license (COL) for a nuclear facility to be located at the North Anna Power Station 

(NAPS). DVP and ODEC currently own NAPS as tenants in common, including the existing 

Units 1 and 2 and the Independent Spent Fuel Storage Installation. DVP is the licensed 

operator of the existing nuclear units, with control of the NAPS site and existing facilities and 

authority to act as ODEC’s agent. Dominion will own the proposed Unit 3 with the same 

ownership as the existing nuclear Units 1 and 2 at NAPS, and DVP will construct and operate 

the proposed Unit 3. 

The proposed Unit 3 site is located adjacent to existing nuclear Units 1 and 2 and wholly within 

the NAPS site, which is located in Louisa County, Virginia, approximately 10 km (6 mi) northeast 

of the town of Mineral. In an early site permit (ESP) issued on November 27, 2007, the NRC 

approved the NAPS site for two additional units. The proposed Unit 3 reactor specified in the 

application is an Economic Simplified Boiling Water Reactor design, which is being reviewed by 

the NRC. 

Section 102 of the National Environmental Policy Act of 1969 (NEPA) (42 USC 4321) directs 

that an environmental impact statement (EIS) be prepared for major Federal actions that 

significantly affect the quality of the human environment. The NRC has implemented 

Section 102 of NEPA in Title 10 of the Code of Federal Regulations (CFR) Part 51. Further, in 

10 CFR 51.20, the NRC has determined that the issuance of a COL under 10 CFR Part 52 is an 

action that requires an EIS. 

The purpose of Dominion’s requested action, issuance of the COL that encompasses both a 

construction permit and an operating license, is to obtain from the NRC a license to construct 

and operate a nuclear power plant. A license from the NRC to construct and operate nuclear 

power plants is necessary but not sufficient to build and operate the power plant. Dominion 

must obtain and maintain permits from other Federal, State, and local agencies and permitting 

authorities. Therefore, the purpose of the NRC environmental review of the Dominion 

application is to determine if a nuclear power plant of the design proposed can be constructed 

and operated at the NAPS site without unacceptable adverse impacts on the human 

environment. 

The Dominion application incorporates information from both the ESP Site Safety Analysis 

Report and Environmental Report (ER). Subpart A of 10 CFR Part 52 contains NRC regulations 

related to ESPs. In November 2007, the NRC issued Early Site Permit (ESP)-003 to Dominion 
Executive Summary 

NUREG-1917, SEIS xx February 2010 

Nuclear North Anna, LLC for the North Anna ESP Site (the site of the proposed Unit 3). An ESP 

is a Commission approval of a site as suitable for construction and operation of one or more 

new nuclear units. The NRC’s detailed review of the environmental impacts of constructing and 

operating new units at the North Anna ESP Site is documented in the Environmental Impact 

Statement for an Early Site Permit (ESP EIS) at the North Anna ESP Site (NUREG-1811), 

which was published in December 2006. For a COL application that references an ESP, the 

NRC staff, pursuant to 10 CFR 51.75(c), prepares a supplement to the ESP environmental 

impact statement (SEIS) in accordance with 10 CFR 51.92(e). 

NRC regulations related to the environmental review of COL applications are contained in 

10 CFR Part 51 and 10 CFR Part 52, Subpart C. Pursuant to NRC regulations in 

10 CFR 51.50(c)(1), a COL applicant referencing an ESP need not submit information or 

analyses regarding environmental issues that were resolved in the ESP EIS, except to the 

extent the COL applicant has identified new and significant information regarding such issues. 

In addition, pursuant to 10 CFR 52.39, matters resolved in the ESP proceedings are considered 

to be resolved in any subsequent proceedings, absent identification of new and significant 

information. 

Upon acceptance of the Dominion application, the NRC began the environmental review 

process described in 10 CFR Part 51 by publishing in the Federal Register a Notice of Intent 

(73 FR 13589 and 73 FR 41132) to prepare an EIS and conduct scoping. The staff held a 

public scoping meeting in Mineral, Virginia, on April 16, 2008, and visited the NAPS site during 

April 2008. Subsequent to the scoping meeting and the site visit and in accordance with the 

provisions of NEPA and 10 CFR Part 51, the staff identified and evaluated the potential 

environmental impacts of constructing and operating a new unit at the NAPS site. Included in 

this supplemental EIS (SEIS) are (1) the results of the NRC staff’s analyses, which consider and 

weigh the environmental effects of the proposed action (i.e., issuance of the COL) and of 

constructing and operating one additional nuclear unit at the NAPS site; (2) mitigation measures 

for reducing or avoiding adverse effects; (3) the environmental impacts of alternatives to the 

proposed action; and (4) the staff’s recommendation regarding the proposed action. 

The draft SEIS was published in December 2008 (NRC 2008). A 75-day comment period 

commenced on January 2, 2009, when the U.S. Environmental Protection Agency (EPA) Notice 

of Filing appeared in the Federal Register (74 FR 106) to allow members of the public to 

comment on the results of the NRC staff’s review. The comment period was later extended 

(74 FR 4475). The NRC held a public meeting in Mineral, Virginia, on February 3, 2009, to 

describe the preliminary results of the environmental review, to answer questions, and to 

provide members of the public with information to assist them in formulating comments on the 

draft SEIS. When the comment period ended on March 20, 2009, the staff considered all of the 

comments received. All comments received on the draft SEIS are included in Appendix E. 
Executive Summary 

February 2010 xxi NUREG-1917, SEIS 

To guide its assessment of environmental impacts of a proposed action or alternative actions, 

the NRC has established a standard of significance for impacts based on guidance developed 

by the Council on Environmental Quality (40 CFR 1508.27). The three significance levels 

established by the NRC – SMALL, MODERATE, or LARGE – are defined as follows: 

SMALL – Environmental effects are not detectable or are so minor that they will neither 

destabilize nor noticeably alter any important attribute of the resource. 

MODERATE – Environmental effects are sufficient to alter noticeably, but not to 

destabilize, important attributes of the resource. 

LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize 

important attributes of the resource. 

Mitigation measures were considered for environmental issues and are discussed in the 

appropriate sections of the SEIS. 

In preparing this SEIS, the staff reviewed Dominion’s application, including the ER; reviewed the 

ESP EIS; consulted with Federal, State, Tribal, and local agencies; and followed the guidance 

set forth in the Standard Review Plans for Environmental Reviews for Nuclear Power Plants 

(NUREG-1555) (ESRP). In addition, the staff considered the public comments related to the 

environmental review received during the scoping process and the comment period for the draft 

SEIS. These comments are provided in Appendices D and E, respectively. 

The staff’s recommendation to the Commission related to the environmental aspects of the 

proposed action is that the COL be issued as proposed. This recommendation is based on 

(1) the application, including the ER submitted by Dominion; (2) the staff’s review conducted for 

the ESP application and documented in the ESP EIS; (3) consultation with Federal, State, 

Tribal, and local agencies; (4) the staff’s own independent review of potential new and 

significant information available since preparation and publication of the ESP EIS; (5) the staff’s 

consideration of comments related to the environmental review that were received during the 

review process; and (6) the assessments summarized in this SEIS, including the potential 

mitigation measures identified in the Dominion ER and in the SEIS. 

The staff’s evaluation of the safety and emergency preparedness aspects of the proposed 

action will be addressed in the staff’s Safety Evaluation Report. As an aid to assist the reader, 

specific information has been included in this document linking the information presented in the 

ESP EIS document and this SEIS document. That information is presented in a table that 

follows the Abbreviations/Acronyms section. 

February 2010 xxiii NUREG-1917, SEIS 

Abbreviations/Acronyms 

ABWRs Advanced Boiling Water Reactors 

AC alternating current 

ac acre(s) 

ALWR Advanced Light Water Reactor 

AEC Atomic Energy Commission 

AEO Nuclear Energy Agency 

ANL Argonne National Laboratory 

ANS American Nuclear Society 

APE Area of Potential Effect 

BEIR Biological Effects of Ionizing Radiation 

BMP best management practices 

BWR boiling water reactor 

°C degree Celsius 

CDC Centers for Disease Control and Prevention 

CDF(s) core damage frequency 

CEQ Council on Environmental Quality 

CETL capacity emergency transfer limit 

CETO capacity emergency transfer objective 

CFR Code of Federal Regulations 

cfs cubic feet per second (water flow) 

Ci curies 

Ci/MTU curies per metric ton uranium 

Ci/yr curies per year 

cm centimeter(s) 

CO2 carbon dioxide 

CO carbon monoxide 

COL combined license 

CPCN Certificate of Public Convenience and Necessity 

CSTE Council of State and Territorial Epidemiologists 

CTRs Capacity Transfer Rights 

CZMA Coastal Zone Management Act 

d day 

dB standard decibel(s) 

dBA A-weighted decibel (where A is a weighting factor for sensitivity) 

DBA Design Basis Accidents 
Abbreviations/Acronyms 

NUREG-1917, SEIS xxiv February 2010 

DC direct current 

DCD Design Control Document 

DECOM Decommissioning 

DECON Decontamination 

DMME Virginia Department of Mines, Minerals, and Energy 

DOE U.S. Department of Energy 

DOT U.S. Department of Transportation 

D/Q Dispersion unit 

DSEIS draft supplemental environmental impact statement 

DSM demand-side management 

DVP or Dominion Dominion Virginia Power 

EA environmental assessment 

EAB Exclusion Area Boundary 

EC energy conservation 

EEI Edison Electric Institute 

EHS Electromagnetic Hypersensitive 

EIA Energy Information Administration 

EIS environmental impact statement 

EMF(s) electromagnetic fields 

ENTOMB Entombment 

EPA U.S. Environmental Protection Agency 

EPP Environmental Protection Plan 

ER Environmental Report 

ESA Endangered Species Act 

ESBWR Economic Simplified Boiling Water Reactor 

ESE east-southeast 

ESP early site permit 

ESRP Environmental Standard Review Plan 

oF degree Fahrenheit 

FAA Federal Aviation Administration 

FEIS final environmental impact statement 

FHWA Federal Highway Administration 

FR Federal Register 

FSAR Final Safety Analysis Report 

ft foot/feet 

ft/s feet per second 

ft3

/yr cubic feet per year 
Abbreviations/Acronyms 

February 2010 xxv NUREG-1917, SEIS 

gal gallon 

GEH General Electric-Hitachi Nuclear Energy 

GEIS generic environmental impact statement 

GIT Georgia Institute of Technology 

gpd gallons per day 

gpm gallons per minute 

ha hectare(s) 

Hg mercury 

hr hour(s) 

I-95 Interstate Highway 95 

ICNIRP International Commission on Non-Ionizing Radiation Protection 

IEEE Institute of Electrical and Electronic Engineers 

IFIM instream flow incremental methodology 

IGCC integrated gasification combined cycle 

IHA Indicators Hydrological Alteration 

in. inch(es) 

Inc. Incorporated 

INEEL Idaho National Engineering and Environmental Laboratory 

IPCC Intergovernmental Panel on Climate Change 

IRM installed reserve margin 

ISFSI Independent Spent Fuel Storage Installation 

IWSA Integrated Waste Services Association 

kg kilogram 

KKN Kashiwazaki-Kariwa Nuclear Power Station 

km kilometer(s) 

km/h kilometer(s) per hour 

kV kilovolt 

kW kilowatt 

kWe kilowatt-electric 

kWh kilowatt-hours 

L/d liter(s) per day 

L/s liter(s) per second 

LACA Lake Anna Civic Association 

LAS Load Analysis Subcommittee 

LDA Locational Deliverability Areas 

LLC Limited Liability Company 

LLW low-level waste 
Abbreviations/Acronyms 

NUREG-1917, SEIS xxvi February 2010 

LOLE loss of load expectation 

LOS Level-of-Service 

LPZ low population zone 

LR license renewal 

LSE load serving entity 

LWR light-water reactor 

m meter(s) 

mm millimeter(s) 

m/s meter(s) per second 

m3

 cubic meter(s) 

m3

/d cubic meter(s) per day 

m3

/s cubic meter(s) per second 

m3

/y cubic meters(s) per year 

MDPSC Maryland Public Service Commission 

MEI maximally exposed individual 

MGD million gallons per day 

mg/L milligram(s) per liter 

mGy/yr milligray per year 

mi mile(s) 

mi2

 square mile(s) 

MIT Massachusetts Institute of Technology 

MLD million gallons per day 

MMS Minerals Management Service 

mph miles per hour 

mrad/yr millirad(s) per year 

mrem millirem(s) 

mrem/hr millirem(s) per hour 

mrem/yr millirem(s) per year 

MSL mean sea level 

mSv millisievert(s) 

mSv/yr millisievert(s) per year 

MT metric ton(s) (or tonne[s]) 

MT/yr metric ton(s) per year 

MTU metric ton(s)-uranium 

MW megawatt(s) 

MWC maximum water conservation 

MWd/MTU megawatt-days per metric ton of uranium 

MW(e) megawatts electric 

MWh megawatt hour(s) 

MW(t) megawatts thermal 
Abbreviations/Acronyms 

February 2010 xxvii NUREG-1917, SEIS 

NAICS North American Industrial Classification System 

NAPS North Anna Power Station 

NCDC National Climatic Data Center 

NCEMCS North Carolina Electric Cooperatives 

NCRP National Council on Radiation Protection and Measurements 

NCUC North Carolina Utilities Commission 

NEA Nuclear Energy Agency 

NEI Nuclear Energy Institute 

NEPA National Environmental Policy Act of 1969 

NESC National Electrical Safety Code 

NHPA National Historic Preservation Act of 1966 

NLCD National Land Cover Dataset 

NOI Notice of Intent 

NOx nitrogen oxide 

NPCC Northwest Power and Conservation Council 

NPDES National Pollutant Discharge Elimination System 

NRC U.S. Nuclear Regulatory Commission 

NSPS new source performance standards 

ODCM Offsite Dose Calculation Manual 

ODEC Old Dominion Electric Cooperative 

OECD Organization for Economic Co-Operation and Development 

PAM Primary Amoebic Meningoencephalitis 

PCBs polychlorinated biphenyls 

PJM PJM Interconnection, LLC 

PM particulate matter 

PM2.5 particulate matter smaller than 2.5 micrometers 

PM10 particulate matter smaller than 10 micrometers 

PNNL Pacific Northwest National Laboratory 

POA property owner association 

PPAs Power Purchase Agreements 

PPE plant parameter envelope 

ppm parts per million 

PRA probabilistic risk assessment 

RAA Reliability Assurance Agreement 

RADTRAN Radiation Material Transportation (computer code) 

RAI Request(s) for Additional Information 

rem(s) Roentgen equivalent man (a special unit of radiation dose) 

REMP radiological environmental monitoring program 
Abbreviations/Acronyms 

NUREG-1917, SEIS xxviii February 2010 

RFC Reliability First Corporation 

RIS Regulatory Issue Summary 

RPM Reliability Pricing Model 

RTO regional transmission organization 

RTEPP Regional Transmission Expansion Planning Process 

Ryr-1 per reactor year 

SACTI Seasonal and Annual Cooling Tower Impacts 

SAFSTOR Safe Storage 

SAMA severe accident mitigation alternatives 

SAMDAs severe accident mitigation design alternatives 

SCR selective catalytic reduction 

SEIS supplemental environmental impact statement 

SER safety evaluation report 

SERC South Eastern Reliability Council 

SHPO State Historic Preservation Office/Officer 

SIC Standard Industrial Classification 

SO2 sulphur dioxide 

SOx sulphur oxide 

SR State Route 

SSAR Site Safety Analysis Report 

Sv sievert 

Sv/yr sievert per year 

TBT tributyltin 

TEDE total effective dose equivalent 

TLD thermoluminescent dosimeter 

USACE U.S. Army Corps of Engineers 

USC United States Code 

USCB U.S. Census Bureau 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

VAC Virginia Administrative Code 

VEPCo Virginia Electric & Power Company (Virginia Power) 

VDCR Virginia Department of Conservation and Recreation 

VDEQ Virginia Department of Environmental Quality 

VDGIF Virginia Department of Game and Inland Fisheries 

VDH Virginia Department of Health 

VDHR Virginia Department of Historic Resources 
Abbreviations/Acronyms 

February 2010 xxix NUREG-1917, SEIS 

VDOT Virginia Department of Transportation 

VNHP Virginia Natural Heritage Program 

VPDES Virginia Pollutant Discharge Elimination System 

Virginia-SCC Virginia State Corporation Commission 

VOC volatile organic compound 

WHO World Health Organization 

WHTF Waste Heat Treatment Facility 

χ/Q dispersion values 

yd yard(s) 

yd3

 cubic yard(s) 

yr year(s) 

February 2010 xxxi NUREG-1917, SEIS 

Linking North Anna ESP EIS Sections 

to SEIS Sections 

ESP EIS Chapter and Section SEIS Chapter and Section 

Abstract Abstract 

Executive Summary Executive Summary 

Abbreviations/Acronyms Abbreviations/Acronyms 

1.0 Introduction 1.0 Introduction 

1.1 Background 

1.1.1 Plant Parameter Envelope 

1.1.2 Site Preparation and Preliminary Construction 

Activities 

1.1.3 ESP Application and Review 

1.1 Background 

1.1.1 COL Application and Review 

1.1.2 Concurrent Reviews 

1.2 The Proposed Federal Action 1.2 The Proposed Federal Action 

1.3 The Purpose and Need for the Proposed Action 1.3 The Purpose and Need for the Proposed Action

1.4 Alternatives to the Proposed Action 1.4 Alternatives to the Proposed Action 

1.5 Compliance and Consultations 1.5 Compliance and Consultations 

1.6 Report Contents 1.6 Report Contents 

1.7 References 1.7 References 

2.0 Affected Environment 2.0 Environment 

2.1 Site Location 2.1 Site Location 

2.2 Land 

2.2.1 The Site and Vicinity 

2.2.2 Transmission Line Rights-of-Way and Offsite 

Areas 

2.2.3 The Region 

2.2 Land Use 

2.2.1 The Site and Vicinity 

2.2.2 Transmission Line Rights-of-Way 

2.2.3 The Region 

2.3 Meteorology and Air Quality 

2.3.1 Climate 

2.3.1.1 Wind 

2.3.1.2 Atmospheric Stability 

2.3.1.3 Temperature 

2.3.1.4 Atmospheric Moisture 

2.3.1.5 Severe Weather 

2.3.1.6 Meteorological Monitoring 

2.3.2 Air Quality 

2.3 Meteorology and Air Quality 

2.4 Geology 2.4 Geology 

2.5 Radiological Environment 2.5 Radiological Environment 

2.6 Water 

2.6.1 Hydrology 

2.6.1.1 Surface Water Hydrology 

2.6.1.2 Groundwater Hydrology 

2.6.1.3 Hydrological Monitoring 

2.6.2 Water Use 

2.6.2.1 Surface Water Use 

2.6.2.2 Groundwater Use 

2.6 Water 

2.6.1 Hydrology 

2.6.2 Water Use 
Linking ESP EIS to SEIS 

NUREG-1917, SEIS xxxii February 2010 

ESP EIS Chapter and Section SEIS Chapter and Section 

2.6.3 Water Quality 

2.6.3.1 Surface Water Quality 

2.6.3.2 Groundwater Quality 

2.6.3.3 Thermal Monitoring 

2.6.3.4 Chemical Monitoring 

2.6.3 Water Quality 

2.7 Ecology 

2.7.1 Terrestrial Ecology 

2.7.1.1 Biological Communities of the North Anna Site 

2.7.1.2 Threatened and Endangered Species 

2.7.1.3 Terrestrial Monitoring 

2.7.2 Aquatic Ecology 

2.7.2.1 Biological Communities of the North Anna Site 

2.7.2.2 Biological Communities of the WHTF 

2.7.2.3 Biological Communities of the North Anna River

2.7.2.4 Threatened and Endangered Species 

2.7.2.5 Aquatic Monitoring 

2.7 Ecology 

2.7.1 Terrestrial Ecology 

2.7.1.1 Biological Communities of the NAPS Site 

2.7.1.2 Biological Communities within the North Anna 

to Ladysmith Transmission Line Right-of-Way 

2.7.1.3 Threatened and Endangered Terrestrial 

Species 

2.7.1.4 Terrestrial Ecological Monitoring 

2.7.2 Aquatic Ecology 

2.7.2.1 Aquatic Communities in the Vicinity of the 

NAPS Site 

2.7.2.2 Threatened and Endangered Aquatic Species 

2.7.2.3 Aquatic Ecology Monitoring 

2.7.2.4 Instream Flow Incremental Methodology Study 

2.8 Socioeconomics 

2.8.1 Demographics 

2.8.1.1 Transient Population 

2.8.1.2 Migrant Labor 

2.8.2 Community Characteristics 

2.8.2.1 Economy 

2.8.2.2 Transportation 

2.8.2.3 Property Taxes 

2.8.2.4 Aesthetics and Recreation 

2.8.2.5 Housing 

2.8.2.6 Public Services 

2.8.2.7 Education 

2.8 Socioeconomics 

2.8.1 Demographics 

2.8.1.1 Resident Population 

2.8.1.2 Transient Population 

2.8.1.3 Migrant Labor 

2.8.2 Community Characteristics 

2.8.2.1 Economy 

2.8.2.2 Transportation 

2.8.2.3 Property Taxes 

2.8.2.4 Aesthetics and Recreation 

2.8.2.5 Housing 

2.8.2.6 Public Services 

2.8.2.7 Education 

2.9 Historic and Cultural Resources 

2.9.1 Cultural Background 

2.9.2 Historic and Cultural Resources at the North 

Anna Site 

2.9.3 Native American Consultation 

2.9 Historic and Cultural Resources 

2.9.1 Cultural Background 

2.9.2 Historic and Cultural Resources at the NAPS 

Site 

2.9.3 Native American Consultation 

2.10 Environmental Justice 2.10 Environmental Justice 

2.10.1 Analysis 

2.10.2 Scoping and Outreach 

2.10.3 Health Preconditions and Special 

Circumstances of the Minority and Low-Income 

Populations 

2.10.4 Migrant Populations 

2.10.5 Environmental Justice Summary 

2.11 Related Federal Projects 2.11 Related Federal Projects and Consultations 

2.12 References 2.12 References 

3.0 Site Layout and Plant Parameter Envelope 3.0 Site Layout and Plant Description 

3.1 External Appearance and Site Layout 3.1 External Appearance and Site Layout 
Linking ESP EIS to SEIS 

February 2010 xxxiii NUREG-1917, SEIS 

ESP EIS Chapter and Section SEIS Chapter and Section 

3.2 Plant Parameter Envelope 

3.2.1 Plant Water Use 

3.2.1.1 Plant Water Consumption 

3.2.1.2 Plant Water Treatment 

3.2.2 Cooling System 

3.2.2.1 Description and Operational Modes 

3.2.2.2 Component Descriptions 

3.2.3 Radiological Waste Management System 

3.2.4 Nonradioactive Waste Management Systems 

3.2 Plant Description 

3.2.1 Plant Water Use 

3.2.1.1 Plant Water Consumption 

3.2.1.2 Plant Water Treatment 

3.2.2 Cooling System 

3.2.2.1 Description and Operational Modes 

3.2.2.2 Component Descriptions 

3.2.3 Radioactive Waste Management System 

3.2.3.1 Liquid Radioactive Waste Management 

System 

3.2.3.2 Gaseous Radioactive Waste Management 

System 

3.2.3.3 Solid Radioactive Waste Management System

3.2.4 Nonradioactive Waste Management Systems 

3.2.4.1 Effluents Containing Chemicals and Biocides 

3.2.4.2 Sanitary System Effluents 

3.2.4.3 Other Effluents 

3.3 Power Transmission System 3.3 Power Transmission System 

3.4 References 3.4 References 

4.0 Construction Impacts at the Proposed Site 4.0 Environmental Impacts of Construction 

4.1 Land-Use Impacts 

4.1.1 The Site and Vicinity 

4.1.2 Transmission Line Rights-of-Way and Offsite 

Areas 

4.1 Land-Use Impacts 

4.1.1 The Site and Vicinity 

4.1.2 Offsite Transmission Line Rights-of-Way 

4.2 Meteorological and Air-Quality Impacts 

4.2.1 Construction Activities 

4.2.2 Transportation 

4.2 Meteorological and Air-Quality Impacts 

4.3 Water-Related Impacts 

4.3.1 Hydrological Alterations 

4.3.2 Water-Use Impacts 

4.3.3 Water-Quality Impacts 

4.3 Water-Related Impacts 

4.3.1 Hydrological Alterations 

4.3.2 Water-Use Impacts 

4.3.3 Water-Quality Impacts 

4.4 Ecological Impacts 

4.4.1 Terrestrial Ecosystem Impacts 

4.4.2 Aquatic Ecosystem Impacts 

4.4.3 Threatened and Endangered Species 

4.4 Ecological Impacts 

4.4.1 Terrestrial Ecosystem Impacts 

4.4.2 Aquatic Ecosystem Impacts 

4.4.3 Threatened and Endangered Species 

4.5 Socioeconomic Impacts 

4.5.1 Physical Impacts 

4.5.1.1 Workers and the Local Public 

4.5.1.2 Buildings 

4.5.1.3 Roads 

4.5.1.4 Aesthetics 

4.5.2 Demography 

4.5.3 Community Characteristics 

4.5.3.1 Economy 

4.5.3.2 Transportation 

4.5.3.3 Taxes 

4.5.3.4 Recreation 

4.5.3.5 Housing 

4.5.3.6 Public Services 

4.5.3.7 Education 

4.5 Socioeconomic Impacts 

4.5.1 Physical Impacts 

4.5.1.1 Workers and the Local Public 

4.5.1.2 Buildings 

4.5.1.3 Roads 

4.5.1.4 Aesthetics and Recreation 

4.5.2 Demography 

4.5.3 Community Characteristics 

4.5.3.1 Economy 

4.5.3.2 Taxes 
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NUREG-1917, SEIS xxxiv February 2010 

ESP EIS Chapter and Section SEIS Chapter and Section 

4.5.4 Infrastructure and Community Service Impacts

4.5.4.1 Transportation 

4.5.4.2 Recreation 

4.5.4.3 Housing 

4.5.4.4 Public Services 

4.5.4.5 Education 

4.5.5 Summary of Socioeconomic Impacts 

4.6 Historic and Cultural Resources 4.6 Historic and Cultural Resources 

4.7 Environmental Justice Impacts 4.7 Environmental Justice 

4.8 Nonradiological Health Impacts 

4.8.1 Public Health 

4.8.2 Occupational Health 

4.8.3 Noise Impacts 

4.8.4 Summary of Nonradiological Health Impacts 

4.8 Nonradiological Health Impacts 

4.8.1 Public and Occupational Health 

4.8.2 Noise Impacts 

4.8.3 Impacts of Transporting Construction 

Materials and Personnel to the Proposed 

Unit 3 Site 

4.8.4 Summary of Nonradiological Health Impacts 

4.9 Radiological Health Impacts 

4.9.1 Direct Radiation Exposures 

4.9.2 Radiation Exposures from Gaseous Effluents 

4.9.3 Radiation Exposures from Liquid Effluents 

4.9.4 Total Dose to the Site Preparation Workers 

4.9.5 Summary of Radiological Health Impacts 

4.9 Radiological Health Impacts 

4.9.1 Direct Radiation Exposures 

4.9.2 Radiation Exposures from Gaseous Effluents 

4.9.3 Radiation Exposures from Liquid Effluents 

4.9.4 Total Dose to Construction Workers 

4.9.5 Summary of Radiological Health Impacts 

4.10 Measures and Controls to Limit Adverse Impacts 

during Construction 

4.10 Measures and Controls to Limit Adverse 

Impacts During Construction 

4.11 Site Redress Plan 4.11 Summary of Construction Impacts 

4.12 Summary of Construction Impacts 4.12 References 

4.13 References 

5.0 Operational Impacts at the Proposed Site 5.0 Environmental Impacts of Operation 

5.1 Land-Use Impacts 

5.1.1 The Site and Vicinity 

5.1.2 Transmission Line Rights-of-Way and Offsite 

Areas 

5.1 Land-Use Impacts 

5.1.1 The Site and Vicinity 

5.1.2 Offsite Transmission Line Rights-of-Way 

5.2 Meteorological and Air-Quality Impacts 5.2 Meteorological and Air-Quality Impacts 

5.3 Water-Related Impacts 

5.3.1 Hydrological Alterations 

5.3.2 Water-Use Impacts 

5.3.3 Water-Quality Impacts 

5.3 Water-Related Impacts 

5.3.1 Hydrological Alterations 

5.3.2 Water-Use Impacts 

5.3.3 Water-Quality Impacts 

5.4 Ecological Impacts 

5.4.1 Terrestrial Ecosystem Impacts 

5.4.1.1 Cooling Tower Impacts on Terrestrial Ecological 

Resources 

5.4.1.2 Noise 

5.4.1.3 Avian Collisions 

5.4.1.4 Shoreline and Riparian Habitat 

5.4.1.5 Summary of Terrestrial Ecosystem Impacts 

5.4.2 Aquatic Ecosystem Impacts 

5.4.2.1 Intake System 

5.4.2.2 Impingement 

5.4.2.3 Entrainment 

5.4 Ecological Impacts 

5.4.1 Terrestrial Ecosystem 

5.4.1.1 Cooling Tower Impacts on Terrestrial 

Ecological Resources 

5.4.1.2 Noise 

5.4.1.3 Avian Collisions 

5.4.1.4 Shoreline and Riparian Habitat 

5.4.1.5 Transmission Line Rights-of-Way 

5.4.1.6 Summary of Terrestrial Ecosystem Impacts 

5.4.2 Aquatic Impacts 

5.4.2.1 Intake and Discharge Systems 

5.4.2.2 Impingement and Entrainment 

5.4.2.3 Aquatic Thermal Impacts 
Linking ESP EIS to SEIS 

February 2010 xxxv NUREG-1917, SEIS 

ESP EIS Chapter and Section SEIS Chapter and Section 

5.4.2.4 Aquatic Thermal Impacts 

5.4.2.5 Striped Bass 

5.4.2.6 Downstream Impacts 

5.4.2.7 Shoreline Erosion and Other Physical Impacts 

5.4.2.8 Summary of Aquatic Impacts 

5.4.3 Threatened and Endangered Species 

5.4.3.1 Terrestrial Species 

5.4.3.2 Aquatic Species 

5.4.2.4 Downstream Impacts 

5.4.2.5 Summary of Aquatic Impacts 

5.4.3 Threatened and Endangered Species 

5.4.3.1 Terrestrial Species 

5.4.3.2 Aquatic Species 

5.5 Socioeconomic Impacts 

5.5.1 Physical Impacts 

5.5.1.1 Workers and the Local Public 

5.5.1.2 Buildings 

5.5.1.3 Roads 

5.5.1.4 Aesthetics 

5.5.2 Demography 

5.5.3 Community Characteristics 

5.5.3.1 Economy 

5.5.3.2 Transportation 

5.5.3.3 Taxes 

5.5.3.4 Recreation 

5.5.3.5 Housing 

5.5.3.6 Public Services 

5.5.3.7 Education 

5.5 Socioeconomic Impacts 

5.5.1 Physical Impacts 

5.5.1.1 Workers and the Local Public 

5.5.1.2 Buildings 

5.5.1.3 Roads 

5.5.1.4 Aesthetics and Recreation 

5.5.2 Demography 

5.5.3 Community Characteristics 

5.5.3.1 Economy 

5.5.3.2 Taxes 

5.5.4 Infrastructure and Community Service Impacts

5.5.4.1 Transportation 

5.5.4.2 Recreation 

5.5.4.3 Housing 

5.5.4.4 Public Services 

5.5.4.5 Education 

5.5.5 Summary of Socioeconomic Impacts 

5.6 Historic and Cultural Resources 5.6 Historic and Cultural Resource Impacts 

5.7 Environmental Justice Impacts 5.7 Environmental Justice Impacts 

5.8 Nonradiological Health Impacts 

5.8.1 Public Health 

5.8.2 Occupational Health 

5.8.3 Noise Impacts 

5.8.4 Acute Effects of Electromagnetic Fields 

5.8.5 Chronic Effects of Electromagnetic Fields 

5.8.6 Summary of Nonradiological Health Impacts 

5.8 Nonradiological Health Impacts 

5.8.1 Public Health (effects of thermophilic 

organisms) 

5.8.2 Occupational Health 

5.8.3 Noise Impacts 

5.8.4 Acute Effects of Electromagnetic Fields 

5.8.5 Chronic Effects of Electromagnetic Fields 

5.8.6 Impacts of Transporting Operations Personnel 

to the Site 

5.8.7 Summary of Nonradiological Health Impacts 

5.9 Radiological Health Impacts 

5.9.1 Exposure Pathways 

5.9.2 Radiation Doses to Members of the Public 

5.9.2.1 Liquid Effluent Pathway 

5.9.2.2 Gaseous Effluent Pathway 

5.9.3 Impacts to Members of the Public 

5.9.3.1 Maximally Exposed Individual 

5.9.3.2 Population Dose 

5.9.3.3 Summary of Radiological Impacts 

5.9 Radiological Impacts of Normal Operations 

5.9.1 Exposure Pathways 

5.9.2 Radiation Doses to Members of the Public 

5.9.2.1 Liquid Effluent Pathway 

5.9.2.2 Gaseous Effluent Pathway 

5.9.2.3 External Radiation Pathway 

5.9.3 Impacts to Members of the Public 

5.9.3.1 Maximally Exposed Individual 

5.9.3.2 Population Dose 

5.9.3.3 Summary of Radiological Impacts to the Public
Linking ESP EIS to SEIS 

NUREG-1917, SEIS xxxvi February 2010 

ESP EIS Chapter and Section SEIS Chapter and Section 

5.9.4 Occupational Doses to Workers 

5.9.5 Impacts to Biota 

5.9.5.1 Liquid Effluent Pathway 

5.9.5.2 Gaseous Effluent Pathway 

5.9.5.2 Impact of Estimated Biota Disease 

5.9.6 Radiological Monitoring 

5.9.4 Occupational Doses to Workers 

5.9.5 Impacts to Biota Other than Members of the 

Public 

5.9.6 Radiological Monitoring 

5.10 Environmental Impacts of Postulated Accidents 

5.10.1 Design Basis Accidents 

5.10.2 Severe Accidents 

5.10.2.1 Air Pathway 

5.10.2.2 Surface Water Pathway 

5.10.2.3 Groundwater Pathway 

5.10.2.4 Summary of Severe Accident Impacts 

5.10 Environmental Impacts of Postulated 

Accidents 

5.10.1 Design Basis Accidents 

5.10.2 Severe Accidents 

5.10.3 Severe Accident Mitigation Alternatives 

5.10.4 Summary of Postulated Accident Impacts 

5.11 Measures and Controls to Limit Adverse Impacts 

during Operation 

5.11 Global Warming, Climate Change, and 

Greenhouse Gas Impacts 

5.12 Summary of Operational Impacts 5.12 Measures and Controls to Limit Adverse 

Impacts During Operation 

5.13 References 5.13 Summary of Operational Impacts 

 5.14 References 

6.0 Fuel Cycle, Transportation, and 

Decommissioning 

6.0 Fuel Cycle, Transportation, and 

Decommissioning 

6.1 Fuel Cycle Impacts and Solid Waste 

Management 

6.1.1 Light-Water Reactors 

6.1.1.1 Land Use 

6.1.1.2 Water Use 

6.1.1.3 Fossil Fuel Use 

6.1.1.4 Chemical Effluents 

6.1.1.5 Radiological Effluents 

6.1.1.6 Radioactive Wastes 

6.1.1.7 Occupational Dose 

6.1.18 Transportation 

6.1.1.9 Conclusion 

6.1.2 Gas-Cooled Reactors 

6.1.2.1 Fuel Fabrication 

6.1.2.2 Enrichment 

6.1.2.3 Uranium Hexafluoride Production – Conversion 

6.1.2.4 Uranium Mining 

6.1.2.5 Uranium Mining 

6.1.2.6 Solid Low-Level Radioactive 

Waste – Operations 

6.1.2.7 Solid Low-Level Waste – Decontamination and 

Decommissioning 

6.1.2.8 Conclusions 

6.1 Fuel Cycle Impacts and Solid Waste 

Management 

6.2 Transportation of Radiological Materials 

6.2.1 Transportation of Unirradiated Fuel 

6.2.1.1 Normal Conditions 

6.2.1.2 Accidents 

6.2 Transportation of Radioactive Materials 

6.2.1 Impact of Crud on Spent Fuel Transportation 

Accident Impacts 
Linking ESP EIS to SEIS 

February 2010 xxxvii NUREG-1917, SEIS 

ESP EIS Chapter and Section SEIS Chapter and Section 

6.2.2 Transportation of Spent Fuel 

6.2.2.1 Normal Conditions 

6.2.1.2 Accidents 

6.2.2.3 Conclusion 

6.2.3 Transportation of Radioactive Waste 

6.2.4 Conclusions 

6.2.2 Nonradiological Impacts 

6.2.3 Conclusions 

6.3 Decommissioning Impacts 6.3 Decommissioning 

6.4 References 6.4 References 

7.0 Cumulative Impacts 7.0 Cumulative Impacts 

7.1 Land-Use 7.1 Land Use 

7.2 Air Quality 7.2 Air Quality 

7.3 Water Use and Quality 7.3 Water Use and Quality 

7.4 Terrestrial Ecosystem 7.4 Terrestrial Ecosystem 

7.5 Aquatic Ecosystem 7.5 Aquatic Ecosystem 

7.6 Socioeconomics, Historic and Cultural, 

Environmental Justice 

7.6 Socioeconomics, Environmental Justice, 

Historic and Cultural Resources 

7.7 Nonradiological Health 7.7 Nonradiological Health 

7.8 Radiological Impacts of Normal Operation 7.8 Radiological Impacts of Normal Operation 

7.9 Fuel Cycle, Transportation, and 

Decommissioning 

7.9 Severe Accidents 

7.10 Staff Conclusions and Recommendations 7.10 Fuel Cycle, Transportation, and 

Decommissioning 

7.11 References 7.11 Staff Conclusions and Recommendations 

 7.12 References 

8.0 Impacts of Alternatives 8.0 Need for Power 

8.1 No-Action Alternative 8.1 Description of the Power System 

8.2 System Design Alternatives 

8.2.1 Plant Cooling System System: Unit 3 OnceThrough Cooling System 

8.2.2 Plant Cooling System System: Unit 3 Wet 

Cooling System 

8.2.3 Plant Cooling System System: Unit 3 Dry 

Cooling System 

8.2 Power Demand/Integrated Resource Planning 

8.3 Alternative Sites, Region of Interest, and 

Selection and Evaluation Process 

8.3.1 Dominion’s Region of Interest 

8.3.2 Dominion’s Alternative Site Selection Process 

8.3.3 NRC’s Evaluation of Alternative Sites 

8.3.4 Greenfield and Brownfield Alternative Sites 

8.3 Power Demand/Integrated Resource Planning 

in the PJM Region 

8.4 Generic Issues Consistent among Alternative 

Sites 

8.4.1 Air Quality Impacts 

8.4.2 Nonradiological Health Impacts 

8.4.2.1 Acute Effects of Electromagnetic Fields 

8.4.2.2 Chronic Effects of Electromagnetic Fields 

8.4 Assessment of Need for Power 

8.4.1 Programs Affecting Demand 

8.4.2 Comparison of PJM/Dominion Studies with 

NRC Criteria 

8.4.2.1 Systematic 

8.4.2.2 Comprehensive 

8.4.2.3 Subject to Confirmation 

8.4.2.4 Responsive to Forecasting Uncertainty 
Linking ESP EIS to SEIS 

NUREG-1917, SEIS xxxviii February 2010 

ESP EIS Chapter and Section SEIS Chapter and Section 

8.4.3 Radiological Health Impacts 

8.4.3.1 Radiological Doses and Health Impacts to 

Members of the Public 

8.4.3.2 Occupational Doses to Workers 

8.4.3.3 Impacts to Biota 

8.4.4 Postulated Accidents 

8.4.3 Need for NAPS Unit 3 

8.4.3.1 Need for Base-Load Capacity 

8.4.3.2 Other Potential Sources of Capacity 

8.4.3.3 Need for Reserve Margin 

8.5 Evaluation of Surry Power Station Site 

8.5.1 Land Use Including Site and Transmission Lines 

8.5.2 Water Use and Quality 

8.5.3 Terrestrial Resources Including Endangered 

Species 

8.5.4 Aquatic Resources Including Endangered 

Species 

8.5.5 Socioeconomics, Historic and Cultural 

Resources, Environmental Justice 

8.5.5.1 Physical Impacts 

8.5.5.2 Demography 

8.5.5.3 Community Characteristics 

8.5.5.4 Historic and Cultural Resources 

8.5.5.5 Environmental Justice 

8.5 Conclusions 

8.6 Evaluation of the Portsmouth Site 

8.6.1 Land Use Including Site and Transmission Lines 

8.6.2 Water Use and Quality 

8.6.3 Terrestrial Resources Including Endangered 

Species 

8.6.4 Aquatic Resources Including Endangered 

Species 

8.6.5 Socioeconomics, Historic and Cultural 

Resources, Environmental Justice 

8.6.5.1 Physical Impacts 

8.6.5.2 Demography 

8.6.5.3 Community Characteristics 

8.6.5.4 Historic and Cultural Resources 

8.6.5.5 Environmental Justice 

8.6 References 

8.7 Nonradiological Health 

8.7.1 Land Use Including Site and Transmission Lines 

8.7.2 Water Use and Quality 

8.7.3 Terrestrial Resources Including Endangered 

Species 

8.7.4 Aquatic Resources Including Endangered 

Species 

8.7.5 Socioeconomics, Historic and Cultural 

Resources, Environmental Justice 

8.7.5.1 Physical Impacts 

8.7.5.2 Demography 

8.7.5.3 Community Characteristics 

8.7.5.4 Historic and Cultural Resources 

8.7.5.5 Environmental Justice 

8.8 Summaries of Alternative Site Impacts 

8.9 References 
Linking ESP EIS to SEIS 

February 2010 xxxix NUREG-1917, SEIS 

ESP EIS Chapter and Section SEIS Chapter and Section 

9.0 Comparison of the Impacts of the Proposed 

Action and Alternative Sites 

9.0 Alternatives to the Proposed Action 

9.1 Comparison of the Proposed Site with the 

Alternatives 

9.1 No-Action Alternative 

9.2 Environmentally Preferable Sites 

9.2.1 Construction 

9.2.2 Operations 

9.2 Energy Alternatives 

9.2.1 Alternatives Not Requiring New Generating 

Capacity 

9.2.2 Alternatives Requiring New Generating 

Capacity 

9.2.2.1 Coal-Fired Generation 

9.2.2.2 Natural Gas-Fired Generation 

9.2.3 Other Alternatives 

9.2.3.1 Oil-Fired Generation 

9.2.3.2 Wind Power 

9.2.3.3 Solar Power 

9.2.3.4 Hydropower 

9.2.3.5 Geothermal Power 

9.2.3.6 Wood Waste 

9.2.3.7 Municipal Solid Waste 

9.2.3.8 Other Biomass-Derived Fuels 

9.2.3.9 Fuel Cells 

9.2.4 Combination of Alternatives 

9.2.5 Summary Comparison of Alternatives 

9.3 Obviously Superior Sites 9.3 System Design Alternatives 

9.3.1 Alternative Intake Structure Designs 

9.3.1.1 Proposed Intake Structure 

9.3.1.2 Alternative Intake Structures 

9.3.2 Alternative Discharge Structure Designs 

9.3.2.1 Proposed Discharge Structure 

9.3.2.2 Alternative Discharge Structures 

9.3.3 Alternative Water Supplies 

9.3.3.1 Proposed Water Supply 

9.3.3.2 Alternative Water Supplies 

9.3.4 Alternative Water-Treatment Systems 

9.3.4.1 Proposed Water-Treatment System 

9.3.4.2 Alternative Water-Treatment Systems 

9.4 Comparison with the No-Action Alternative 9.4 Region of Interest and Site-Selection Process 

9.5 References 9.5 Alternative Sites 

 9.6 References 

10.0 Conclusions and Recommendation 10.0 Conclusions and Recommendations 

10.1 Environmental Impacts of the Proposed Action 10.1 Impacts of the Proposed Action 

10.2 Adverse Environmental Effects that cannot be 

Avoided if the Proposal is Implemented 

10.2 Unavoidable Adverse Environmental Impacts 

10.2.1 Unavoidable Adverse Impacts During 

Construction 

10.2.2 Unavoidable Adverse Impacts During 

Operation 

10.3 Alternatives to the Proposed Action 10.3 Alternatives to the Proposed Action 
Linking ESP EIS to SEIS 

NUREG-1917, SEIS xl February 2010 

ESP EIS Chapter and Section SEIS Chapter and Section 

10.4 Relationship between Short-Term and LongTerm Productivity of the Human Environment 10.4 Relationship between Short-Term Uses and 

Long-Term Productivity of the Human 

Environment 

10.5 Irreversible and Irretrievable Commitments of 

Resources 

10.5 Irreversible and Irretrievable Commitments of 

Resources 

10.6 Staff Conclusions and Recommendations 10.6 Benefit-Cost Balance 

10.6.1 Benefits 

10.6.1.1 Societal Benefits 

10.6.1.2 Regional Benefits 

10.6.2 Costs 

10.6.2.1 Internal Costs 

10.6.2.2 External Costs 

10.6.3 Benefit-Cost Summary 

10.7 References 10.7 Staff Conclusions and Recommendations 

 10.8 References 

Appendix A Contributors to the Environmental Impact 

Statement Related to Dominion Nuclear 

North Anna, LLC’s Application for an Early 

Site Permit at the North Anna ESP Site 

Appendix A Contributors to the Supplemental 

Environmental Impact Statement 

Appendix B Organizations Contacted Appendix B Organizations Contacted 

Appendix C Chronology of NRC Staff Environmental 

Review Correspondence Related to 

Dominion Nuclear North Anna, LLC’s 

Application for an Early Site Permit at the 

North Anna ESP Site 

Appendix C Chronology of NRC Staff Environmental 

Review Correspondence Related to 

Dominion Virginia Power and Old 

Dominion Electric Cooperative’s 

Application for a Combined License for 

Unit 3 at the North Anna Power Station 

Site 

Appendix D Scoping Meeting Comments and Responses Appendix D Scoping Comments and Responses 

Appendix E Comments and Responses on the Draft 

Environmental Statement and the 

Supplement to the Draft Environmental 

Impact Statement 

Appendix E Comments and Responses on the Draft 

Supplemental Environmental Statement 

Appendix F Key Correspondence Appendix F Key Consultation Correspondence 

Appendix G Environmental Impacts of Transportation Appendix G Environmental Impacts of Transportation 

Appendix H Supporting Documentation on Radiological 

Dose Assessment 

Appendix H Supporting Documentation on Radiological 

Dose Assessment 

Appendix I ESP Site Characteristics and Plant 

Parameter Envelope 

Appendix I Early Site Permit Site Characteristics and 

Plant Parameter Envelope 

Appendix J Dominion Nuclear North Anna, LLC, Permit 

Conditions, Commitments, Assumptions, and 

Unresolved Issues 

Appendix J Early Site Permit Conditions, 

Commitments, Assumptions, and 

Unresolved Issues 

Appendix K Staff’s Independent Review of Water Budget 

and Water Temperature Impacts 

Appendix K Staff’s Independent Review of Water 

Budget 

Appendix L Authorizations and Consultations Appendix L Authorizations and Consultations 

Appendix M Severe Accident Mitigation Alternatives 
February 2010 1-1 NUREG-1917, SEIS 

1.0 Introduction 

On November 27, 2007, the U.S. Nuclear Regulatory Commission (NRC) received an 

application from Virginia Electric Power Company, doing business as Dominion Virginia Power 

(DVP), and the Old Dominion Electric Cooperative (ODEC), collectively referred to as Dominion, 

for a combined license (COL). The proposed action in the application is NRC issuance of a 

COL for construction and operation of a power reactor at the North Anna Power Station (NAPS) 

in Louisa County, Virginia. The location of the proposed nuclear reactor, Unit 3, is adjacent to 

the existing NAPS Units 1 and 2. Dominion is the licensee and operator of the existing two units 

at the NAPS site. The NAPS site and existing facilities are owned by DVP and ODEC as 

tenants in common. DVP has been authorized by the NAPS co-owner (ODEC) to act as its 

agent to apply for a COL for one additional nuclear unit at the NAPS site. 

The COL application references an early site permit (ESP) for the North Anna ESP site, which 

is located at NAPS. In November 2007, NRC issued an ESP for two additional nuclear units at 

the North Anna ESP site. This ESP was supported by information contained in the ESP final 

environmental impact statement, NUREG-1811 (ESP EIS) (NRC 2006). The permit, ESP-003, 

was issued to Dominion by the NRC on November 27, 2007 (NRC 2007a). For a COL 

application that references an ESP, the NRC staff, pursuant to Title 10 of the Code of Federal 

Regulations (CFR) 51.75(c), prepares a supplement to the ESP EIS in accordance with 

10 CFR 51.92(e). Therefore, the staff relies upon the analysis in the ESP EIS as the basis in 

preparation of this supplemental EIS (SEIS). 

1.1 Background 

A COL is a Commission approval for the construction and operation of one or more nuclear 

power facilities. NRC regulations related to COLs are found in Subpart C of 10 CFR Part 52. 

Section 102 of the National Environmental Policy Act of 1969 (NEPA) (42 USC 4321) directs 

that an EIS be prepared for major Federal actions that significantly affect the quality of the 

human environment. The NRC has implemented Section 102 of NEPA in 10 CFR Part 51. 

Further, in 10 CFR 51.20, the NRC has determined that the issuance of a COL under 

10 CFR Part 52 is an action that requires an EIS. The NRC regulations setting standards for a 

review of a COL application are listed in 10 CFR 52.81. Detailed procedures for conducting the 

environmental portion of the review are found in guidance set forth in the Standard Review 

Plans for Environmental Reviews for Nuclear Power Plants (NUREG-1555) (NRC 2000) and 

recent updates. 

According to 10 CFR 52.80(b), an application for a COL must contain an Environmental Report 

(ER), which provides the applicant’s input to the NRC’s EIS. NRC regulations related to ERs 

and EISs are found in 10 CFR Part 51. 
Introduction 

NUREG-1917, SEIS 1-2 February 2010 

1.1.1 COL Application and Review 

The purpose of Dominion’s requested action, issuance of the COL, is to obtain from the NRC a 

combined license to construct and operate a base-load nuclear power plant. In addition to the 

COL, Dominion must obtain and maintain permits from other Federal, State, and local agencies 

and permitting authorities. The purpose of the NRC environmental review of Dominion’s 

application is to determine if a nuclear power plant of the proposed design can be constructed 

and operated at the NAPS site without unacceptable adverse impacts on the human 

environment. 

Dominion submitted an ER as part of its COL application (Dominion 2009). In accordance with 

10 CFR 51.50(c)(1), the ER submitted with the COL application is not required to contain 

information or analysis that was previously submitted in the ER for the ESP application or 

address issues that were resolved in the ESP EIS. The ER for the COL stage is required to 

provide the following information: 

• Information to demonstrate that the chosen design of the facility falls within the site 

characteristics and design parameters specified in the ESP 

• Sufficient information to resolve any significant environmental issues that were not resolved 

in the ESP EIS 

• New and significant information related to impacts of construction and operation that were 

resolved in the ESP process 

• A description of the process used to identify new and significant information regarding 

conclusions presented in the ESP EIS 

• Information that demonstrates that all environmental terms and conditions included as part 

of the ESP will be satisfied by the date of issuance of the COL. 

The SEIS together with the ESP EIS provides the staff’s evaluation of the environmental effects 

of constructing and operating a single Economic Simplified Boiling-Water Reactor (ESBWR) at 

the NAPS site. In addition to considering the environmental effects of the proposed action, the 

SEIS addresses alternative technologies to the proposed action and the benefits of the 

proposed action (e.g., the need for power). The Dominion application for a COL references an 

ESP; therefore, in accordance with 10 CFR 52.83, issues resolved as part of the ESP 

proceeding remain resolved except under conditions set forth in 10 CFR 52.39(a)(2). 

Environmental impacts not considered or unresolved in the ESP proceeding are evaluated and 

documented in this SEIS. In addition, measures and controls previously identified to limit 

adverse impacts are evaluated along with any new or significant information that would have the 

potential to affect the finding or conclusions reached in the ESP EIS. In accordance with 

10 CFR 51.92(e)(3), the SEIS does not contain a separate discussion of alternative sites. The 

NRC’s detailed evaluation of alternative sites is in Chapter 9 of the ESP EIS (NRC 2006). 
Introduction 

February 2010 1-3 NUREG-1917, SEIS 

During the NAPS ESP review, the staff evaluated a set of values of plant design parameters for 

the reactors and associated facilities. This set of values, or plant parameter envelope (PPE), 

serves as a surrogate for actual reactor design information. The approval of the ESP bound 

these values and assumptions for the COL review. In the COL application, Dominion provided 

the actual values for most parameters when it chose a reactor design. The staff’s analysis of 

the environmental impacts associated with the COL will confirm the reactor design values 

provided in the COL application and necessary PPE values are bounded by the ESP and other 

required NRC regulations. The PPE values and assumptions can be found in Appendices I 

and J of the ESP EIS (NRC 2006). 

Upon acceptance of Dominion’s COL application, the NRC began the environmental review 

process by publishing in the Federal Register on March 13, 2008, a Notice of Intent to prepare 

an SEIS and conduct scoping in compliance with requirements set forth in 10 CFR Part 51 

(73 FR 13589). Because of some inaccuracies in the original Notice of Intent, a revised notice 

was published in the Federal Register on July 17, 2008 (73 FR 41132). 

The NRC project staff and staff from its contractor, Pacific Northwest National Laboratory 

(PNNL), visited the NAPS site in April 2008 (NRC 2008a). The NAPS site visit consisted of the 

following: (1) meeting with Dominion staff, its contractors, and State and local officials; 

(2) conducting an independent evaluation of subject areas not covered in the ESP EIS, 

unresolved issues, and new and significant information; and (3) reviewing Dominion’s 

implementation of its process for identifying new and significant information. At the conclusion 

of the audit, the staff determined that Dominion’s process for evaluating potentially new and 

significant information was adequate to meet the requirements of 10 CFR 51.50(c)(1)(iv). The 

staff used the guidance set forth in the Statements of Consideration revising 10 CFR 51.50(c) 

(72 FR 49352) and Combined License Applications for Nuclear Power Plants (NRC 2007b) in 

making this determination. 

On April 16, 2008, the NRC held a scoping meeting in Mineral, Virginia, to obtain public input 

on the scope of the environmental review. While developing the draft SEIS, the staff also 

reviewed the comments received during the scoping process and contacted Federal, State, 

Tribal, regional, and local agencies to solicit comments. A list of the organizations contacted is 

provided in Appendix B. Other documents related to the NAPS site were reviewed and are 

listed as references where appropriate. All of the information collected through these processes 

was used in developing the draft SEIS. 

The draft SEIS was published in December 2008 (NRC 2008b). A 75-day comment period 

commenced on January 2, 2009, when the U.S. Environmental Protection Agency (EPA) Notice 

of Filing appeared in the Federal Register (74 FR 106) to allow members of the public to 

comment on the results of the NRC staff’s review. The comment period was later extended 

(74 FR 4476). The NRC held a public meeting in Mineral, Virginia, on February 3, 2009, to 

describe the preliminary results of the environmental review, to answer questions, and to 
Introduction 

NUREG-1917, SEIS 1-4 February 2010 

provide members of the public with information to assist them in formulating comments on the 

draft SEIS. When the comment period ended on March 20, 2009, the staff considered all of the 

comments received. All comments received on the draft SEIS are included in Appendix E. 

To guide its assessment of environmental impacts of a proposed action or alternative actions, 

the NRC has established a standard of significance for impacts based on guidance developed 

by the Council on Environmental Quality (40 CFR 1508.27). The three significance levels 

established by the NRC – SMALL, MODERATE, or LARGE – are defined as follows: 

SMALL – Environmental effects are not detectable or are so minor that they will neither 

destabilize nor noticeably alter any important attribute of the resource. 

MODERATE – Environmental effects are sufficient to alter noticeably, but not to 

destabilize, important attributes of the resource. 

LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize 

important attributes of the resource. 

This SEIS presents the staff’s analysis, which considers and weighs the environmental impacts 

of the proposed action at the NAPS site, including the environmental impacts associated with 

construction and operation of Unit 3 at the site, the environmental impacts of alternatives to 

granting the COL, and the mitigation measures available for reducing or avoiding adverse 

environmental effects. The SEIS also provides the NRC staff’s recommendation to the 

Commission regarding the issuance of the COL for the NAPS site. 

In the course of its evaluation, the NRC staff (1) met with Dominion staff, its contractors, and 

State and local officials; (2) conducted an independent evaluation of subject areas not covered 

in the ESP EIS, unresolved issues, and new and significant information; and (3) reviewed 

Dominion’s implementation of its process for identifying new and significant information, which 

the staff determined was adequate. While developing the SEIS, the staff also reviewed public 

comments it received and contacted Federal, State, Tribal, regional, and local agencies to solicit 

comments. A list of the organizations contacted is provided in Appendix B. Other documents 

related to the NAPS site were reviewed and are listed as references where appropriate. All of 

the information collected through these processes was used in developing this SEIS. 

1.1.2 Concurrent Reviews 

In reviews separate from the environmental review process, the NRC analyzes the safety 

characteristics of the proposed site and emergency planning information. These analyses will 

be documented in a Safety Evaluation Report (SER). The SER presents the conclusions 

reached by the NRC regarding (1) whether there is reasonable assurance that an ESBWR can 

be constructed and operated at the NAPS site without undue risk to the health and safety of 

the public and (2) whether the emergency preparedness program meets the applicable 
Introduction 

February 2010 1-5 NUREG-1917, SEIS 

requirements in 10 CFR Part 50, 10 CFR Part 52, 10 CFR Part 73, and 10 CFR Part 100. The 

ESBWR reactor design referenced in the application is a standard design that is undergoing 

certification review pursuant to 10 CFR Part 52, Subpart B. This review will be the subject of 

later rulemaking by the NRC. 

1.2 The Proposed Federal Action 

The proposed Federal action is issuance, under the provisions of 10 CFR Part 52, of a COL

for the NAPS site for an ESBWR reactor. The SEIS incorporates information from the ESP 

action by reference and discloses the staff’s analysis of the environmental impacts that could 

result from the construction and operation of a new unit at the NAPS site. These impacts are 

analyzed to resolve any issues deferred from the ESP proceeding and to determine if there is 

new and significant information regarding issues that were resolved in the ESP proceeding. In 

the context of a COL application that references an ESP, the term ‘‘new’’ in the phrase ‘‘new 

and significant information’’ is defined as any information that was both (1) not considered in 

preparing the ESP ER or EIS (as may be evidenced by references in these documents, 

applicant responses to NRC requests for additional information, comment letters, etc.) and 

(2) not generally known or publicly available during the preparation of the ESP EIS (such as 

information in reports, studies, and treatises). For new information to be ‘‘significant,’’ it must be 

material to the issue being considered; that is, it must have the potential to affect the finding or 

conclusions of the NRC staff’s evaluation of the issue. The applicant for a COL need only 

provide information in the application about a previously resolved environmental issue if it is 

both new and significant (72 FR 49352). 

The site for the proposed Unit 3 is located in Louisa County, Virginia, near the town of Mineral 

and approximately 64 km (40 mi) north-northwest of Richmond. The proposed site is 

completely within the confines of the current NAPS site, with the proposed Unit 3 to be adjacent 

to the existing Units 1 and 2. 

In the SEIS, the staff evaluated the impacts of construction and operation of an ESBWR, with a 

thermal power rating of 4500 megawatts thermal (MW(t)). The proposed unit would use a 

closed-cycle, combination dry and wet cooling tower system, with makeup water supplied from 

Lake Anna. 

1.3 The Purpose and Need for the Proposed Action 

The purpose and need for the proposed action (i.e., issuance of a COL) is to provide for 

additional base-load electrical generating capacity for Dominion customers. Dominion indicated 

the need for the proposed action will assist them in fulfilling their native-load obligations as 

required by Senate Bill 1416 (SB 1416 2007) that was signed into law by the governor of the 

Commonwealth of Virginia in 2007. 
Introduction 

NUREG-1917, SEIS 1-6 February 2010 

The ultimate decision about whether or not to build a facility and the schedule for any 

construction are not within the purview of the NRC and would be determined by the license 

holder if the authorization is granted. A license from the NRC to construct and operate a 

nuclear power plant is necessary but not sufficient to build and operate of the power plant. 

Certain long lead-time activities, such as ordering and procuring certain components and 

materials necessary to construct the plant, may begin before the COL is granted. Dominion 

must obtain and maintain permits or authorizations from other Federal, State, and local 

agencies and permitting authorities before undertaking certain activities. 

1.4 Alternatives to the Proposed Action 

Section 102(2)(C)(iii) of NEPA states that EISs are to include a detailed statement on 

alternatives to the proposed action. The SEIS addresses the following categories of 

alternatives: (1) the no-action alternative, (2) energy source alternatives, and (3) system design 

alternatives. In accordance with 10 CFR 51.92(e)(3), the SEIS does not contain a separate 

discussion of alternative sites. The NRC’s detailed evaluation of alternative sites is documented 

in Chapters 8 and 9 of the ESP EIS (NRC 2006). 

1.5 Compliance and Consultations 

Prior to construction and operation of the new unit, Dominion is required to hold certain Federal, 

State, and local environmental permits, as well as meet applicable statutory and regulatory 

requirements. Dominion (2009) provided a list of environmental approvals and consultations 

associated with the NAPS proposed Unit 3. Potential authorizations and consultations relevant 

to the proposed COL are included in Appendix L. 

Before it can obtain a COL from the NRC, Dominion must obtain a Clean Water Act Section 401 

Certification. This certification would be issued by the Commonwealth of Virginia and would 

ensure that the project does not conflict with water quality management programs in the 

Commonwealth. Upon receipt of the permit, Dominion would notify NRC. 

The staff has contacted the appropriate Federal, State, Tribal, and local agencies to identify any 

compliance, permit, or significant environmental issues of concern to the reviewing agencies 

that relate to the construction and operation of the proposed ESBWR reactor. A list of 

organizations contacted is included in Appendix B. 

1.6 Report Contents

The subsequent chapters of this SEIS are organized as follows. Chapter 2 describes the 

proposed site and discusses the environment that would be affected by the addition of the new 

unit. Chapter 3 describes the power plant characteristics to be used as the basis for evaluating 
Introduction 

February 2010 1-7 NUREG-1917, SEIS 

the environmental impacts. Chapters 4 and 5 examine the environmental impacts of 

construction (Chapter 4) and operation (Chapter 5) of the proposed Unit 3. Chapter 6 analyzes 

the environmental impacts of the uranium fuel cycle, transportation of radioactive materials, and 

decommissioning, while Chapter 7 discusses the cumulative impacts of the proposed action as 

defined in 10 CFR 51.75(c). Chapter 8 addresses the need for power. Chapter 9 discusses 

alternatives to the proposed action, and Chapter 10 summarizes the findings of the preceding 

chapters and presents the staff’s recommendation with respect to issuance of the COL. 

The appendices to the SEIS provide the following additional information. 

• Appendix A – Contributors to the Supplemental Environmental Impact Statement 

• Appendix B – Organizations Contacted 

• Appendix C – Chronology of NRC Staff Environmental Review Correspondence Related to 

Dominion Virginia Power and Old Dominion Electric Cooperative’s Application for a 

Combined License for Unit 3 at the North Anna Power Station Site 

• Appendix D – Scoping Comments and Responses 

• Appendix E – Comments and Responses on the Draft Supplemental Environmental Impact 

Statement 

• Appendix F – Key Consultation Correspondence 

• Appendix G – Environmental Impacts of Transportation

• Appendix H – Supporting Documentation on Radiological Dose Assessment 

• Appendix I – Early Site Permit Site Characteristics and Plant Parameter Envelope 

• Appendix J – Early Site Permit Conditions, Commitments, Assumptions, and 

Unresolved Issues 

• Appendix K – Staff’s Independent Review of Water Budget Impacts 

• Appendix L – Authorizations and Consultations 

• Appendix M – Severe Accident Mitigation Alternatives. 

1.7 References 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 
Introduction 

NUREG-1917, SEIS 1-8 February 2010 

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses 

Certifications and Approvals for Nuclear Power Plants.” 

10 CFR Part 73. Code of Federal Regulations, Title 10, Energy, Part 73, “Physical Protection of 

Plants and Materials.” 

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site 

Criteria.” 

40 CFR Part 1508. Code of Federal Regulations, Title 40, Protection of Environment, 

Part 1508, “Terminology and Index.” 

72 FR 49352. “Licenses, Certifications, and Approvals for Nuclear Power Plants.” Vol. 72, 

No. 166. August 28, 2007. 

73 FR 13589. “Dominion Nuclear Power, LLC; North Anna Power Station Combined License 

Application; Notice of Intent to Prepare and Environmental Impact Statement and Conduct 

Scoping Process.” Vol. 73, No. 50. March 13, 2008. 

73 FR 41132. “Virginia Electric and Power Company, D/B/A Dominion Virginia Power, and 

Old Dominion Electric Cooperative North Anna Nuclear Station Unit 3 Combined License 

Application; Correction and Supplement to Notice of Intent to Prepare an Environmental Impact 

Statement and Conduct Scoping Process.” Vol. 73, No. 138. July 17, 2008. 

74 FR 106. “Environmental Impacts Statements: Notice of Availability, EIS No. 20080536 North 

Anna Power Station Unit 3 Combined License (COL) for Construction of a Base-Load Nuclear 

Power Plant.” Vol. 74, No. 1. January 2, 2009. 

74 FR 4476. “Virginia Electric and Power Company, D/B/A Dominion Virginia Power, and Old 

Dominion Electric Cooperative; Correction to Notice of Availability of the Draft Supplemental 

Environmental Impact Statement and Public Meeting for North Anna Power Station Unit 3 

Combined License Application.” Vol. 74, No. 15. January 26, 2009. 

Dominion Virginia Power (Dominion). 2009. North Anna 3 Combined License Application 

Part 3: Environmental Report – Combined License Stage. Revision 2, July 2009. Accession 

No. ML092160490. 

National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq. 

Senate Bill 1416 (SB 1416). 2007. Electric Utility Service; advances scheduled expiration of 

capped rate period. Virginia General Assembly, Commonwealth of Virginia, Richmond, Virginia. 

Accessed at http://leg1.state.va.us./cgi-bin/legp504.exe?ses=071&typ=bil&val=sb1416 on 

October 14, 2008. Accession No. ML083260587. 
Introduction 

February 2010 1-9 NUREG-1917, SEIS 

U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental 

Reviews for Nuclear Power Plants. NUREG-1555, Vol. 1, Washington, D.C. Includes 2007 

revisions. 

U.S. Nuclear Regulatory Commission (NRC). 2006. Environmental Impact Statement for an 

Early Site Permit (ESP) at the North Anna ESP Site – Final Report. NUREG-1811, Vols. 1 

and 2, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2007a. North Anna Early Site Permit 

No. ESP-003. Accession No. ML073180440. 

U.S. Nuclear Regulatory Commission (NRC). 2007b. Regulatory Guide 1.206 – Combined 

License Applications for Nuclear Power Plants. Washington. D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2008a. Summary of Environmental Site Audit 

Related to the Review of the Combined License Application for North Anna Power Station, 

Unit 3. Accession No. ML082970800. 

U.S. Nuclear Regulatory Commission (NRC). 2008b. Environmental Impact Statement for the 

Combined License (COL) for North Anna Power Station Unit 3 – Draft Report for Comment. 

NUREG-1917, Washington, D.C. 

February 2010 2-1 NUREG-1917, SEIS 

2.0 Environment 

The site proposed by Virginia Electric and Power Company, doing business as Dominion 

Virginia Power (DVP), and the Old Dominion Electric Cooperative (ODEC), collectively known 

as Dominion, for a combined license (COL), is located in Louisa County, Virginia, within the 

existing boundaries of the currently operating North Anna Power Station (NAPS) site (Dominion 

2009a). The NAPS property is owned by DVP and ODEC as tenants in common. The NAPS 

site is located on the shore of Lake Anna approximately 64 km (40 mi) north-northwest of 

Richmond. Two operating nuclear generating units, Units 1 and 2 are located within the NAPS 

site. DVP is the licensed operator of the existing units, controls the existing site, and has the 

authority to act as ODEC’s agent in matters related to licensing and operating the proposed 

Unit 3 station. 

The station location is described in Section 2.1, with the land, meteorology and air quality, 

geology, radiological environment, water, ecology, socioeconomics, historic and cultural 

resources, and environmental justice aspects (or conditions) of the site presented in 

Sections 2.2 through 2.10, respectively. Section 2.11 examines related Federal projects, and 

references are presented in Section 2.12. 

2.1 Site Location 

As shown in Figure 2-1, the proposed location for NAPS Unit 3 is wholly within the NAPS site 

and is west of and adjacent to the existing Unit 1 and 2 facilities. The centerline of the proposed 

Unit 3 would be located approximately in the center of the NAPS site. 

The NAPS site is located in rural Louisa County, Virginia, which had a population of about 

25,000 in 2000 (NRC 2006a). Figure 2-2 shows the location of the NAPS site in relationship to 

the counties and surrounding cities and towns within an 80-km (50-mi) radius of the site. The 

NAPS site is located within a triangle formed by the cities of Richmond, Charlottesville, and 

Fredericksburg, Virginia. Interstate Highway 95 (I-95) passes within 26 km (16 mi) of the site, 

and Interstate 64 passes within 29 km (18 mi). Access to the site is from Virginia State Route 

(SR) 700. The community of Mineral is located approximately 10 km (6 mi) southwest of the 

NAPS site. Louisa, the county seat, is 19 km (12 mi) west of the NAPS site. The NAPS site 

occupies approximately 422.1 ha (1043 ac) of land, and it is located on a peninsula on the 

southern shore of Lake Anna, approximately 8 km (5 mi) upstream of the North Anna Dam 

(NRC 2006a). 

The staff did not identify any new information for this section since preparation of the Final 

Environmental Impact Statement for an Early Site Permit (ESP) for the North Anna ESP Site, 

(ESP EIS) (NUREG-1811) (NRC 2006a). 
Environment 

NUREG-1917, SEIS 2-2 February 2010 Figure 2-1. ESP Site Boundaries within the Existing NAPS Site (Adapted from Dominion 2009a)
Environment 

February 2010 2-3 NUREG-1917, SEIS 

Figure 2-2. Location of NAPS, 80-km (50-mi) Region (NRC 2006a) 

2.2 Land Use 

This section discusses land-related issues for the NAPS site. Section 2.2.1 describes the site 

and the vicinity around the site. Section 2.2.2 discusses the existing transmission line rights-ofway. Section 2.2.3 discusses the region, defined as the area within an 80-km (50-mi) radius of 

the site boundary. 
Environment 

NUREG-1917, SEIS 2-4 February 2010 

2.2.1 The Site and Vicinity 

The NAPS site and vicinity are described in Section 2.2.1 of the ESP EIS (NRC 2006a). The 

ESP EIS assumed the location of two new nuclear units at the North Anna site which was 

consistent with the ESP application (Dominion Nuclear North Anna, LLC 2006a). Revision 0 of 

the COL application submitted by Dominion was for one new nuclear unit (Dominion 2007a). 

New information in Revision 2 of the Environmental Report (ER) states that Dominion would use 

an approximately 38.8 ha (96-ac) tract of land northwest of and contiguous with the NAPS site 

for certain construction-related activities such as laydown areas, spoils storage, a concrete 

batch plant, and access roads (Dominion 2009a). The tract of land was recently purchased by 

Dominion. 

Section 307(c)(3)(A) of the Coastal Zone Management Act (16 USC 1456(c)(3)(A)) requires 

an applicant seeking a Federal permit to conduct an activity that affects a coastal zone area 

to provide to the permitting agency a certification that the proposed activity complies with the 

enforceable policies of the state’s coastal zone program. The Virginia Department of 

Environmental Quality (VDEQ) oversees this program for the Chesapeake Bay Coastal Zone 

Management Area. The NAPS site is not within Virginia’s coastal zone for purposes of the 

Coastal Zone Management Act. However, Spotsylvania County and the associated portion 

of Lake Anna within Spotsylvania County are included within the Virginia coastal zone 

(VDEQ 2008a). Therefore, Dominion is required to provide a Coastal Zone Management 

Act certification to the Commonwealth of Virginia for proposed Unit 3 at the NAPS site 

(VDEQ 2008b). 

2.2.2 Transmission Line Rights-of-Way 

The North Anna transmission line rights-of-way are described in Section 2.2.2 of the ESP EIS 

(NRC 2006a). 

A study conducted in 2007 by PJM Interconnection (Dominion 2009a) determined that a new 

24-km (15-mi) 500-kV transmission line to support the proposed Unit 3 would need to be 

constructed (Dominion 2009a). The line would be constructed from the existing North Anna 

Substation to the Ladysmith Switching Substation located east of the North Anna Substation. 

The line would be installed on new transmission towers built in the existing right-of-way 

(Dominion 2009a). PJM Interconnection is a regional transmission organization that 

coordinates the movement of wholesale electricity in all or parts of Delaware, Illinois, Indiana, 

Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, 

Virginia, West Virginia, and the District of Columbia (PJM 2008). 
Environment 

February 2010 2-5 NUREG-1917, SEIS 

2.2.3 The Region 

The region surrounding the NAPS site is described in Section 2.2.3 of the ESP EIS 

(NRC 2006a). The staff did not identify any new information regarding land use since 

preparation of the ESP EIS (NRC 2006a). 

2.3 Meteorology and Air Quality 

The climate for the geographic area in which the site is located has been characterized as 

modified continental, with mild winters, warm, moist summers, and relatively uniform rainfall 

throughout the year. Snow is relatively uncommon, occurring primarily in January and 

February. Light winds are perhaps the most important feature of this area in terms of reactor 

construction and operation because they will affect the dispersion of any releases to the 

environment. Much of the quantitative information on the meteorology for the NAPS site was 

based on historical observations made at the National Weather Service station at the Richmond, 

Virginia, airport. 

No new and significant information was identified for meteorological data collected at the 

NAPS site as part of the ongoing operational monitoring program for Units 1 and 2. Specific 

information regarding wind speed and direction, atmospheric stability, ambient temperature, 

and moisture is available in Section 2.3 of the ESP EIS (NRC 2006a). The staff reviewed 

independent data sources and found no new and significant information regarding severe 

weather events beyond that reported in the ESP EIS. 

The county in which the NAPS site is located, Louisa County, is within the Northeastern Virginia 

Intrastate Air Quality Control Region (AQCR). With the exception of Stafford County, the 

counties in this AQCR had previously been designated as “in attainment or unclassified” for all 

criteria pollutants for which National Ambient Air Quality Standards had been established 

(40 CFR 81.347). Attainment areas are areas where the ambient air quality levels are better 

than designated by the U.S. Environmental Protection Agency (EPA). Louisa County and 

Spotsylvania County (70 FR 76165) had been classified as in attainment of the ozone standard 

(40 CFR 81.347). 

In a letter from VDEQ to the U.S. Environmental Protection Agency (EPA) (VDEQ 2009), the 

Commonwealth of Virginia recommended that Spotsylvania County, Stafford County, the City of 

Fredericksburg, and parts of Caroline County be classified as the Fredericksburg nonattainment 

area as it relates to the EPA 8-hour ozone standard. Although neighboring Spotsylvania County 

would be a nonattainment area under this recommendation, no change to the existing status of 

“in attainment or unclassified” was proposed for Louisa County. Although the final status of all 

regions in Virginia will not be determined by EPA until 2010, the staff has determined that no 

changes to the description of the NAPS site regional air quality are needed at the present time.
Environment 

NUREG-1917, SEIS 2-6 February 2010 

Long-term estimates of air concentration and deposition to the ground, normalized by release 

rate (χ/Q and D/Q) for sensitive receptors had been calculated in the ESP ER (Dominion 

Nuclear North Anna, LLC 2006a) and evaluated in the ESP EIS (NRC 2006a). These earlier 

values were based on sensitive receptors, each of which had a unique distance and direction. 

A review by Dominion of the location of the nearest receptors, conducted as part of the annual 

Radiological Environmental Monitoring Program review (Dominion 2009b) showed that the 

closest receptor was now a resident located 1.357 km (4453 ft) northwest of the plant facility 

boundary. As a result, Dominion conservatively assumed that one of each type of receptor 

(residence, vegetable garden, and meat animal) were located 1.198 km (3930 ft) in each 

compass direction and reanalyzed χ/Q and D/Q calculations with this assumption. This 

changed the expected values at the newly selected sites. However, the differences are 

consistent with what would be expected by moving these locations, and while this is new 

information, it is not significant and will not have any bearing on the earlier assessment 

presented in the ESP EIS (NRC 2006a). 

2.4 Geology 

Consideration of geology for the proposed Unit 3 site at NAPS and the surrounding area is 

limited in the environmental review. This section also provides information on key 

physiographic feature that are relevant in other sections. Readers are referred to the Final 

Safety Analysis Report (FSAR) for a more detailed description of geology, including seismic and 

geotechnical issues. 

The proposed Unit 3 site lies within the Piedmont Physiographic Province (Trapp and Horn 

2000). Detailed characteristics regarding this Province can be found in Section 2.4 of the 

ESP EIS (NRC 2006a). 

The proposed Unit 3 site is underlain by rocks of the Ta River Metamorphic Suite, which 

extends thousands of feet below the ground surface. The crystalline metamorphic rocks near 

the ground surface have undergone extensive weathering to create a layer of saprolite about 

30 m (100 ft) thick beneath the site. The geotechnical properties of the saprolite are unsuitable 

for use as a structural fill material for plant construction, and excavated material will have to be 

removed to another location (NRC 2006a). The ESP EIS addressed the mining deposits in the 

vicinity of the NAPS site (NRC 2006a). 

The staff did not identify any new and significant information for this section since preparation of 

the ESP EIS (NRC 2006a). 
Environment 

February 2010 2-7 NUREG-1917, SEIS 

2.5 Radiological Environment 

A radiological environmental monitoring program (REMP) has been conducted around the 

NAPS site since 1976 (NRC 1976). The REMP includes monitoring of the airborne exposure 

pathway, the direct exposure pathway, the water exposure pathway, the aquatic exposure 

pathway from Lake Anna and the North Anna River, and the ingestion exposure pathway within 

a 40-km (25-mi) radius of the NAPS site. The preoperational environmental radiation monitoring 

program sampled various media in the environment to establish a baseline to determine the 

magnitude and fluctuation of radioactivity in the environment once the Units 1 and 2 began 

operation (USAEC 1973). The preoperational monitoring program included collection and 

analysis of samples of air particulates, precipitation, milk, crops, soil, well water, surface water, 

fish, and silt as well as measurement of ambient gamma radiation. After operation of Units 1 

and 2 began at NAPS, the monitoring program continued to assess the radiological impacts to 

workers, the public, and the environment. Modifications to the monitoring program are made 

based on changes in the area such as milk production, agricultural uses, and changes in lake 

use. Radiological releases are summarized in the reports entitled Annual Radiological 

Environmental Operating Program and Annual Radioactive Effluent Release Report; reports are 

issued annually. The 2007 North Anna Power Station, Annual Environmental Operating Report, 

January 1, 2007 to December 31, 2007 (VEPCo 2008a) reported the estimated maximum dose 

to a hypothetical individual at the station boundary because of liquid and gaseous effluents 

released during 2007 to be 0.0062 mSv (0.62 mrem). This dose is small compared to the 

approximately 3.0-mSv (300-mrem) dose received from background radiation (NCRP 1987, 

2009). This estimated dose is similar to those of recent years. The limits for all radiological 

releases for Units 1 and 2 are specified in the Offsite Dose Calculation Manual (ODCM) 

(Dominion 2007c). 

The annual effluent monitoring report and the annual environmental operating report for 2007 

(VEPCo 2008a,b) summarized results of groundwater sampling performed by Dominion around 

NAPS Units 1 and 2 and the Independent Spent Fuel Storage Installation (ISFSI) in support of 

the Nuclear Energy Institute (NEI) Ground Water Protection Initiative (NEI 2007). This initiative 

was developed in response to the U.S. Nuclear Regulatory Commission’s Lessons Learned 

Task Force Report (NRC 2006b). Samples were analyzed for tritium, and in a few locations, 

for gamma emitters and strontium-89/90. VEPCo (2008a) reported that tritium results were 

indicative of lake to groundwater communication and not indicative of a leak from a radioactive 

system. 

The Virginia Department of Health (VDH) also performs environmental monitoring around 

NAPS. The VDH samples airborne particulates, fish, milk, shellfish, silt, surface water, and 

vegetation. In addition, it measures external radiation around the NAPS site using 

thermoluminescent dosimeters (TLDs). Results of the VDH program were similar to those of 

Dominion’s environmental monitoring program (VDH 2008). 
Environment 

NUREG-1917, SEIS 2-8 February 2010 

The NRC staff reviewed historical data on releases and estimated occupational and population 

doses and did not identify any new and significant information regarding the radiological 

environment since issuance of the North Anna ESP. The data and analysis showed that doses 

to the maximally exposed individuals around the NAPS site were a small fraction of the limits 

specified in Federal environmental radiation standards – Title 10 of the Code of Federal 

Regulations (CFR) Part 20; 10 CFR Part 50, Appendix I; and 40 CFR Part 190. 

2.6 Water 

This section presents a summary of the hydrological processes governing the movement and 

distribution of water in the existing environment at the proposed Unit 3 site at NAPS. The full 

description of hydrology, water use, water quality, and monitoring can be found in Section 2.6 

of the ESP EIS (NRC 2006a). The NRC staff incorporates information by reference from the 

ESP EIS for this section. New information obtained since the ESP EIS was published is 

included where applicable in the following summary. 

2.6.1 Hydrology 

The site-specific and regional hydrological features of the existing environment that could 

be altered by the construction or operation of the proposed Unit 3 are shown in Figure 2-3 

and are described in Section 2.6 of the ESP EIS (NRC 2006a). A description of the site’s 

hydrological features was presented in Section 2.3.1 of the ESP ER (Dominion Nuclear North 

Anna, LLC 2006a); the COL ER stated that no new and significant information was identified for 

this section. The hydrological features of the site related to site safety (e.g., flood protection) 

are described by Dominion in the Final Safety Analysis Report (FSAR) portion of the COL 

application (Dominion 2009b). 

A description of surface and groundwater hydrology is found in Section 2.6.1 of the ESP EIS 

(NRC 2006a). The hydrological monitoring data collected prior to preparation of the ESP EIS 

are discussed in Section 2.6.1.3 of the ESP EIS. Dominion provided no new information related 

to hydrologic monitoring. The staff independently reviewed U.S. Geological Survey (USGS) 

streamflow gauge data for the period after the preparation of the ESP EIS and determined they 

were consistent with past flows. Dominion calculates discharge released through the North 

Anna Dam using rating curves. These curves relate forebay stage and release structure 

settings to outflow discharge. Dominion does not take direct measurements of outflow 

discharge, and these rating curve estimates are the only discharge measurements available for 

the North Anna River immediately downstream of the North Anna Dam since the Partlow gauge 

(on the North Anna River near Partlow, Virginia) was discontinued in 1995. Staff identified new 

information that the Partlow gauge was reinstated and is being operated by USGS in 

cooperation with Dominion Virginia Power as of March 27, 2007 (USGS 2008). 
Environment 

February 2010 2-9 NUREG-1917, SEIS Figure 2-3. Lake Anna, the Waste Heat Treatment Facility (WHTF), and the Rivers and Creeks in the Vicinity of NAPS (NRC 2006a) 

z ... ~ __ 

il 

1 

~, 

§§ 

-1-

• 
Environment 

NUREG-1917, SEIS 2-10 February 2010 

The COL FSAR (Dominion 2009b) reports quarterly groundwater-level measurements from 

December 17, 2002, to September 29, 2003; a single measurement date of February 1, 2005; 

and quarterly measurements from November 29, 2006 to May 30, 2007. The latter set of data 

includes measurements made at the seven wells completed as part of the proposed Unit 3 

subsurface field investigation. The FSAR states that some observation wells may need to be 

closed prior to site earthwork activities and that an evaluation will be conducted to determine 

whether new wells will be required to provide adequate evaluation of construction impacts on 

site groundwater levels. Regarding the frequency of monitoring, Dominion states that 

groundwater levels will be measured monthly during any construction-related dewatering, 

quarterly for 2 years following the completion of construction, and semi-annually or annually 

during plant operations. 

2.6.2 Water Use 

Consumptive water use during plant operation is a key element of the affected environment 

for the proposed Unit 3, and forms the basis for evaluation of impacts of plant operation. 

Therefore, this section incorporates by reference the ESP EIS (NRC 2006a) and any new 

information identified by staff since the ESP EIS was prepared. In Section 2.3.2 of the COL ER, 

Dominion (2009a) identified no new and significant information relative to water use.

Dominion revised the water budget model that was used for the calculations in the ESP ER to 

incorporate more detailed information provided by the proposed cooling tower vendor. The 

results did not significantly change the conclusions that were presented in the ESP ER. The 

calculation did not result in a change in the plant parameter envelope (PPE) values that were 

the basis of the ESP ER. The staff had done an independent calculation using an alternative 

modeling approach at the ESP stage. The staff’s independent calculation relied on long-term 

PPE values and, therefore, would remain unchanged with the new information from the cooling 

tower vendor. The staff also considered the minor changes in water use described in Revision 2 

of the Dominion’s COL ER (Dominion 2009a).

2.6.3 Water Quality 

The description of water quality of surface water and groundwater resources in the vicinity of the 

NAPS site in Section 2.6.3 of the ESP EIS (NRC 2006a) is incorporated by reference into this 

SEIS. The ESP EIS also describes pre-application monitoring programs for thermal and 

chemical water quality. 

The water quality of Lake Anna, the tributaries draining into Lake Anna, and the North Anna 

River downstream of the dam are described in Section 2.6.3.1 of the ESP EIS (NRC 2006a), 

and Section 2.3.3.1 of the ESP ER (Dominion Nuclear North Anna, LLC 2006a). Dominion 

provided a table summarizing more recent Lake Anna water quality data in Section 2.3.3.1 of 

the COL ER (Dominion 2009a). 
Environment 

February 2010 2-11 NUREG-1917, SEIS 

Localized elevated temperatures resulting from the thermal load discharge from operating 

Units 1 and 2 at NAPS remain the most significant water-quality concern associated with both 

the existing units and the proposed Unit 3. Operational impacts of proposed Unit 3 on Lake 

Anna water quality are discussed in Section 5.3.3 of this SEIS. Monitoring programs for thermal 

and chemical water quality are discussed in ESP EIS Sections 2.6.3.3 and 2.6.3.4, respectively. 

Units 1 and 2 have a Virginia Pollutant Discharge Elimination System (VPDES) permit from the 

VDEQ. Before Unit 3 could begin to operate, Dominion would be required to obtain a VPDES 

permit for discharges from this unit. Dominion would also be required to demonstrate to VDEQ 

that the thermal effluent limitation for Unit 3 is adequate to ensure protection and propagation of 

a balanced, indigenous population of shellfish, fish, and wildlife through a Clean Water Act 

Section 316(a) demonstration. If determined to be necessary, VDEQ may require additional 

monitoring prior to issuance of a VPDES permit. VDEQ may also require ongoing monitoring as 

a condition of the VPDES permit. 

There were no site-specific data available for the nonradiological chemistry of the groundwater 

underlying the NAPS site at the time of the ESP EIS (NRC 2006a), and no new and significant 

groundwater quality information was identified in the COL ER (Dominion 2009a). In 

Section 2.3.3.2 of the ESP ER and in response to a request, Dominion provided a summary of 

published studies that characterize the water quality of crystalline aquifers in the Piedmont 

Province (Dominion Electric Environmental Services Environmental Biology 2004; Dominion 

Nuclear North Anna, LLC 2006a). The Piedmont region aquifers provide good quality water 

(USGS 2000). As with most crystalline rocks, the rocks of the Piedmont Province contribute 

relatively high levels of naturally occurring radioactivity to the groundwater (Zapecza and Szabo

1988). 

Dominion is able to consider an ongoing thermal monitoring program associated with the 

existing Units 1 and 2 as part of the pre-application and pre-operational monitoring program for 

the Unit 3 site. It is expected that many of the same monitoring activities would be continued if 

Unit 3 were completed and would become part of Unit 3 operational monitoring. In Section 6.1 

of the ESP ER, Dominion Nuclear North Anna, LLC describes the existing lake temperature 

measurements directly associated with the current site operation that were required under terms 

of its existing VPDES permit (Dominion Nuclear North Anna, LLC 2006a). Dominion’s VPDES 

permit was reissued in October 2007 with continued terms for thermal monitoring in the Lake 

Anna Reservoir (VDEQ 2007a). 

The current temperature monitoring program in Lake Anna and the Waste Heat Treatment 

Facility (WHTF) includes both continuous temperature stations and temperature profile 

locations. Temperature is recorded continuously at seven stations in the main body of Lake 

Anna, three stations in the WHTF, and one in the North Anna River below the dam. A 

requirement of the renewed VPDES permit is that Dominion is required to monitor temperature 

daily at the cooling water intake for Units 1 and 2, and at Outfall 101 where the once-through 
Environment 

NUREG-1917, SEIS 2-12 February 2010 

cooling water from Units 1 and 2 enters the discharge canal (VDEQ 2007a). The 2007 VPDES 

permit also added weekly temperature monitoring at the location where the WHTF discharges to 

the main body of the lake (Outfall 001, Dike 3). Temperature profiles are measured periodically 

(at least two quarters per year) at seven or more stations in the main body of the lake, as 

described in the ESP EIS (NRC 2006a). 

As with the thermal monitoring, Dominion is able to consider its ongoing operational monitoring 

program for Units 1 and 2 as part of the pre-application and pre-operational monitoring program 

for the proposed Unit 3. Many of these same monitoring activities would be continued if Unit 3 

were completed and would likely become part of the operational monitoring. In Section 6.6 of 

the ESP ER (Dominion Nuclear North Anna, LLC 2006a), Dominion Nuclear North Anna, LLC 

describes the chemical monitoring that is required under terms of its existing VPDES permit. 

Section 3.6.1 of the COL ER provides results of surface-water quality monitoring near the intake 

for Units 1 and 2 since preparation of the ESP ER (Dominion 2009a). Copper and tributyltin are 

noted because their concentrations are at or above water quality criteria. Dominion’s VPDES 

permit was renewed by VDEQ in October 2007, with similar chemical monitoring requirements. 

The NAPS Units 1 and 2 VPDES permit establishes chemical discharge limits at a variety of 

locations internal to the NAPS facility and at the discharge from the WHTF into Lake Anna at 

Dike 3. Chemical monitoring of a variety of constituents is required including pH, chlorine, 

copper, nickel, chromium, zinc, suspended solids, oil and grease, and biological oxygen 

demand. Water quality monitoring of effluent from NAPS Units 1 and 2 is required once per 

year; this monitoring has both chemical and biological (toxicity) components. While temperature 

is monitored both inside and outside the WHTF, no chemical monitoring is required outside the 

WHTF. 

The Commonwealth of Virginia monitors Lake Anna, Lake Anna’s tributaries, and the North 

Anna River downstream from Lake Anna. Results from this monitoring program provide the 

basis for the list of impaired waters in the Virginia Clean Water Act Section 303(d), which 

implements the Clean Water Act. Sampling by the Commonwealth has resulted in a public 

health advisory regarding the consumption of certain fish in Lake Anna and its tributaries. The 

advisory was triggered because polychlorinated biphenyls (PCBs) were detected in the tissues 

of certain fish. While the fish consumption use is categorized as impaired, the VDEQ considers 

the water quality of Lake Anna to be fully supportive of aquatic life, wildlife, and recreation uses 

(VDEQ 2007b). 

Community-based monitoring of Lake Anna and WHTF water quality has been performed by 

volunteers from the Lake Anna Civic Association. Water samples are collected and analyzed 

for several standard water-quality metrics, such as the fecal coliform bacteria, Escherichia coli, 

and dissolved oxygen. Results from this monitoring program were provided to the 

Commonwealth of Virginia and the EPA, and also were reviewed by the staff. 
Environment 

February 2010 2-13 NUREG-1917, SEIS 

2.7 Ecology 

A detailed description of the terrestrial and aquatic ecology in the vicinity of the NAPS site is 

presented in Section 2.7 of the ESP EIS (NRC 2006a) and Section 2.4 of the ESP ER (Dominion 

Nuclear North Anna, LLC 2006a). The following sections update the description where 

appropriate with information developed since the ESP EIS was prepared, including information 

from the COL ER (Dominion 2009a), supplemental information provided by Dominion, the results 

of the Instream Flow Incremental Methodology (IFIM) study (Dominion 2009c), and reviews of 

current information available from Commonwealth and Federal agencies. 

2.7.1 Terrestrial Ecology 

A detailed description of the terrestrial and aquatic ecology in the vicinity of the NAPS site is 

presented in Section 2.7.1 of the ESP EIS (NRC 2006a) and in Section 2.4 of the ESP ER 

(Dominion Nuclear North Anna, LLC 2006a). Dominion provided the staff with new information 

about the layout of the proposed facilities, the amount and distribution of wetlands onsite that 

may be affected by construction and operation of the proposed Unit 3, wildlife usage in the 

vicinity of the NAPS site, and the proposed new transmission line from NAPS to the Ladysmith 

Substation. Dominion has provided information regarding the ecological resources within the 

adjacent property of approximately 38.8 ha (96 ac) southwest of the ESP site boundary that it 

has acquired. Dominion will use this property to support construction and for a proposed haul 

route for transporting heavy components to the site. Additionally, Dominion, as part of the IFIM 

study (Dominion 2009c), evaluated the effect of raising the Lake Anna pool elevation on wetland 

areas located in five coves. A description of this study is presented in Section 2.7.2.4. 

2.7.1.1 Biological Communities of the NAPS Site 

As described in the ESP EIS, the NAPS site is located within the Piedmont Physiographic 

Province as described by Omernik (1987). Although forests in the Piedmont Province are 

nominally characterized by oak-hickory pine forest (Woods et al. 2003), this portion of 

northeastern Virginia has been settled since the colonial era and therefore no longer contains 

virgin forests. Vegetative cover surrounding NAPS is an irregular patchwork of row crops, 

pastures, pine plantations, abandoned (old) fields, and second-growth forests of hardwoods and 

mixed pine-hardwoods (Dominion Nuclear North Anna, LLC 2006a). 

The overall proposed Unit 3 site footprint is approximately 120 ha (300 ac). Dominion classified 

the habitats within the construction footprint using National Land Cover Dataset (NLCD) data, 

and found that the COL site consisted of approximately 25 percent deciduous forest, 15 percent 

evergreen forest, 19 percent mowed grass areas, 33 percent developed areas and open space, 

and 8 percent wetlands (Dominion 2008d). 
Environment 

NUREG-1917, SEIS 2-14 February 2010 

The amount of wetlands within the NAPS site footprint based on the NLCD data (approximately 

9.7 ha [24 ac]) appears to be an overestimate. There is very little hydrophytic or wetland 

vegetation along most of the Lake Anna shoreline except at the upper or western end where the 

shorelines are shallower (Dominion Nuclear North Anna, LLC 2006a). In 2006, Dominion 

Nuclear North Anna, LLC completed a wetland delineation that identified 2.70 ha (6.68 ac) of 

nontidal wetlands, 1680 m (5500 ft) of streams, and approximately 1.017 ha (2.49 ac) of open 

water (within a beaver pond) in the ESP construction footprint (Dominion Nuclear North Anna, 

LLC 2006c). In a September 2006 letter, the U.S. Army Corps of Engineers (USACE) verified 

this delineation (USACE 2006). In the ESP EIS, two intermittent streams were identified within 

the construction footprint. Dominion has since identified an additional intermittent stream 

flowing north into an unnamed arm of Lake Anna. Since publication of the draft SEIS, Dominion 

has identified the need to move several small facilities associated with the operation of Units 1 

and 2 such as offices, fabrication shop, and communications tower, so that construction of 

Unit 3 will not affect operations of the existing units. Dominion identified three small wetland 

areas within or adjacent to the new locations for these facilities (Dominion 2009a). 

The description of common wildlife species at the NAPS site that was provided in the ESP EIS 

(NRC 2006a) is updated with the following information. In the ESP ER (Dominion Nuclear North 

Anna, LLC 2006a), Dominion Nuclear North Anna, LLC stated that although great blue herons 

were commonly observed at Lake Anna and the NAPS site, there were no known rookeries in 

the area. During its review for new and significant information for the COLA, Dominion indicated 

that there is now a rookery with approximately 20 nests located near Thurman Island, 

approximately 3.2 km (2 mi) from the existing NAPS site boundary (Dominion 2008e). 

The approximately 38.8 ha (96 ac) of property recently acquired by Dominion to support 

construction of Unit 3 was not considered in the draft COL SEIS. Habitat maps based on the 

2001 NLCD indicate that approximately 35.6 ha (88 ac) of this property were forest (both 

deciduous and evergreen), a little over 2.4 ha (6 ac) were classified as barren land, and about 

0.6 ha (1.5 ac) were classified as developed or pasture (Dominion 2009a). However, since 

2001, the previous owner harvested most of the forests. In a 2008 habitat assessment, 

Dominion estimated that there are only about 1.6 ha (4 ac) of forest left along the northwest 

edge of the new property. Approximately 25 ha (62 ac) were classified as recently cut, and 

9.3 ha (23 ac) were young mixed pine/hardwood (Dominion 2009a). 

Dominion performed a wetland area delineation within the additional property (Dominion 2009a). 

Nine wetlands and stream boundaries were identified, totaling approximately 1.2 ha (3 ac), with 

total stream length approximately 1130 linear m (3700 linear ft). These delineations were 

confirmed by the USACE in August 2008 (Dominion 2009a). 

Dominion also performed a wetland delineation along the proposed route for transporting large 

components from a barge unloading facility to the NAPS site. Approximately 31 wetland areas 

were identified, 7 of which are potentially affected by route modifications (Dominion 2009a). 
Environment 

February 2010 2-15 NUREG-1917, SEIS 

2.7.1.2 Biological Communities within the North Anna to Ladysmith Transmission Line 

Right-of-Way 

In the ESP ER (Dominion Nuclear North Anna, LLC 2006a), Dominion Nuclear North Anna, LLC 

stated that no alterations to the transmission system would be required. In its COL ER 

(Dominion 2009a), Dominion indicated that an additional 500-kV transmission line, within the 

existing North Anna to Ladysmith right-of-way would be required to ensure system reliability. 

The new transmission line is expected to be approximately 24 km (15 mi) long; the existing 

corridor is approximately 84 m (275 ft) wide, and will not need to be cleared to accommodate 

the new proposed transmission line. 

The North Anna to Ladysmith right-of-way starts at the NAPS site, crosses an unnamed arm of 

Lake Anna on the north side of the site, and then turns east across Lake Anna into Spotsylvania 

County. The right-of-way then travels generally east-south-east for approximately 19 km (12 mi) 

until it reaches the Ladysmith substation, located approximately 3.2 km (2 mi) beyond the 

Caroline County line. 

The North Anna to Ladysmith right-of-way crosses approximately 20 small tributaries, and 

several wetland areas. The largest wetlands within the right-of-way are along Northeast Creek, 

approximately 4.8 km (3 mi) north of Lake Anna Dam, and along a tributary of South River, 

about 4.8 km (3 mi) west of the Ladysmith Substation (Dominion 2009a). 

The right-of-way is currently cleared, and there are a variety of land uses within the right-of-way 

including grazing, agriculture, and silviculture typical of central Virginia. Vegetative cover types 

along and adjacent to the North Anna to Ladysmith right-of-way were characterized by Dominion 

using NLCD data (Dominion 2008d). Dominion estimated that the habitats within 46 m (150 ft) 

of either side of the right-of-way centerline consisted of approximately 41 percent deciduous 

forests, 19 percent evergreen forests, 16 percent pasture or hay, 13 percent cultivated crops, 

5 percent developed lands, 4 percent open water, and less than 3 percent wetlands. 

Wetlands were delineated along the North Anna to Ladysmith right-of-way in August 2008 

(Dominion 2009a), and a jurisdictional determination was received from the USACE in 

September 2008 (Dominion 2009a). A total of 39 potential nontidal wetlands were identified 

within the North Anna to Ladysmith corridor. A wetland impact analysis will be required prior to 

receiving Virginia State Corporation Commission certification of the proposed new transmission 

line (Dominion 2008f). 

2.7.1.3 Threatened and Endangered Terrestrial Species 

A detailed description of the threatened and endangered terrestrial species in the vicinity of the 

NAPS site is presented in Section 2.7.1 of the ESP EIS (NRC 2006a) and Section 2.4 of the 

ESP ER (Dominion Nuclear North Anna, LLC 2006a). 
Environment 

NUREG-1917, SEIS 2-16 February 2010 

The list of threatened and endangered terrestrial species in the vicinity of the NAPS site and the 

Ladysmith transmission line right-of-way is provided in Table 2-1. Differences between the 

current list and that provided in the ESP EIS (NRC 2006a) include deletion of the cerulean 

warbler (Dendroica cerulea) and regal fritillary (Speyeria idlaia). Both species were removed 

from the U.S. Fish and Wildlife Service (USFWS) list of species of concern for Virginia (USFWS 

2008) and neither have state status in Virginia. Additionally, the State-protected Dismal Swamp 

southeastern shrew (Sorex longirostris fisheri) was deleted because Virginia Department of 

Game and Inland Fisheries (VDGIF) no longer has records of its occurrence in Caroline County 

(VDGIF 2008b). The Canebrake rattlesnake (Crotalus horridus) was added to the list because it 

is now known to occur in Hanover County downstream from Lake Anna (VDGIF 2008b). 

Animals 

The Bald eagle (Haliaeetus leucocephalus) was removed from the Federal list of threatened or 

endangered species, but is still a State-threatened species. Bald eagles are occasionally 

observed along Lake Anna (seven were observed during the 2007/2008 Christmas Bird Count) 

(Audubon Society 2008). However, there are no known eagle nests at the NAPS site. The 

nearest known bald eagle nest is approximately 4.2 km (2.6 mi) to the west in the Contrary 

Creek drainage (Dominion 2008e). No eagle nests are known to occur along the NAPS to 

Ladysmith transmission line right-of-way (VDGIF 2008a). The loggerhead shrike (Lanius 

ludoviciana), a State-threatened species, is likely to occur in the vicinity (VDGIF 2008b), but 

nesting near the NAPS site or the transmission line rights-of-way, including the NAPS to 

Ladysmith transmission line right-of-way, has not been recorded (Dominion Nuclear North Anna, 

LLC 2006a). Other species, such as the upland sandpiper (Bartramia longicauda) may 

occasionally migrate through the area (VDGIF 2008a). The eastern big-eared bat (Plecotus 

rafinesquii macrotis) and tiger salamander (Ambystoma tigrinum) have been reported in 

Hanover County, which is downstream from Lake Anna. The red-cockaded woodpecker 

(Picoides borealis) and Bachman’s sparrow (Aimophila aestivalis) have been reported in 

Caroline County (VDCR 2008, VDGIF 2008a). However, the presence of these species at the 

NAPS site is unlikely, and reported observation sites are well away from the transmission lines, 

or portions of the North Anna River potentially affected by construction and operation of the 

proposed Unit 3 at the NAPS site. 

Plants 

There are no known populations of any plants species listed as threatened or endangered 

by the USFWS or the Commonwealth on the NAPS site (Dominion Nuclear North Anna, LLC 

2006a; VDGIF 2008a; VDCR 2008). In addition, there are no known populations of such 

species in Louisa County (VDCR 2008; USFWS 2008). 
Environment 

February 2010 2-17 NUREG-1917, SEIS 

Table 2-1. Federally or State Listed Terrestrial Species Known or Likely to Occur in Counties 

Adjacent to or Downstream from the Lake Anna Reservoir (Louisa, Orange, 

Spotsylvania, Caroline, and Hanover Counties) 

Scientific Name Species Counties Status(a) Source 

Birds 

Haliaeetus 

leucocephalus 

Bald eagle Louisa, Orange, 

Spotsylvania, Caroline, 

Hanover 

ST VDGIF 2008a, 

VDCR 2008, 

USFWS 2008 

Picoides borealis Red-cockaded 

woodpecker 

Caroline FE/SE VDGIF 2008a 

Lanius ludovicianus Loggerhead 

shrike 

Louisa, Orange, 

Spotsylvania, Caroline, 

Hanover 

ST VDGIF 2008a 

Aimophila aestivalis Bachman’s 

sparrow 

Caroline ST VDGIF 2008a, 

VDCR 2008 

Bartramia longicauda Upland sandpiper Louisa, Orange, 

Spotsylvania, Caroline, 

Hanover 

ST VDGIF 2008a 

Mammals 

Plecotus rafinesquii 

macrotis

Eastern big-eared 

bat 

Hanover SE VDGIF 2008a 

Amphibians and Reptiles 

Ambystoma tigrinum Tiger salamander Hanover SE VDCR 2008 

Crotalus horridus Canebrake 

rattlesnake 

Hanover SE VDGIF 2008a 

Vascular Plants 

Isotria medeoloides(b) Small whorled 

pogonia 

Spotsylvania, Hanover, 

Caroline, Louisa 

FT/SE VDGIF 2008a, 

USFWS 2008, 

VDCR 2008 

Helonias bullata Swamp pink Caroline, Hanover, 

Spotsylvania 

FT/SE VDGIF 2008a, 

VDCR 2008, 

USFWS 2008 

Aeschynomene 

virginica 

Sensitive jointvetch Caroline, Hanover FT USFWS 2008 

Juncus caesariensis New Jersey rush Caroline FS/ST VDCR 2008 

(a) FE = Federally endangered, FT = Federally threatened, FS = Federal species of concern, SE = State 

endangered, ST = State threatened. 

(b) In a September 29, 2009 letter, the Virginia Department of Conservation and Recreation (VDCR), Division of 

Natural Heritage, informed the NRC staff of the possibility that the NAPS site may contain suitable habitat for this 

species. 
Environment 

NUREG-1917, SEIS 2-18 February 2010 

The SEIS prepared for the license renewal of NAPS Units 1 and 2 (NRC 2002b) described three 

Federally listed plant species that could potentially occur in the North Anna transmission line 

rights-of-way: the small whorled pogonia (Isotria medeoloides), swamp pink (Helonias bullata), 

and the sensitive joint-vetch (Aeschynomene virginica). One additional rare plant species has 

been reported to occur in Caroline County; the New Jersey rush (Juncus caesariensis), a State 

threatened and Federal species of concern, which occurs in shaded stream banks and other 

wet areas (VDCR 2008). 

The small whorled pogonia inhabits upland mixed deciduous or mixed deciduous-conifer 

forested areas with sparse ground cover and a relatively open understory. It often occurs near 

the edges of forest stands adjacent to logging roads or other features that cause persistent 

breaks in the canopy (USFWS 1992). It is known from the vicinity of Fort A.P. Hill in Caroline 

County (VDGIF 2008b) and is considered to potentially occur in Spotsylvania County. In a 

September 29, 2009 letter, the VDCR Division of Natural Heritage informed the NRC staff of the 

possibility that the NAPS site may contain suitable habitat for this species (VDCR 2009a). 

The swamp pink occurs in wetlands from New Jersey to Georgia. In Virginia, its habitat is 

described as “perennially saturated, spring-fed, nutrient-poor, shrub swamps and forested 

wetlands” (VDCR 2009b). The species is known from Caroline County and potentially occurs in 

Spotsylvania County, east of Interstate 95 (USFWS 2008). 

The sensitive joint-vetch is a large annual member of the pea family that occurs in the slightly 

brackish tidal marshes of the mid-Atlantic states. In Virginia, it is known to occur in the lower 

reaches of several of the major river systems, including the Mattaponi and Pamunkey Rivers 

(VDCR 2009c). The USFWS indicates that there is a potential for this species to occur in 

Hanover and Caroline Counties because it is present in neighboring counties (USFWS 2008). 

New Jersey rush habitat in Virginia occurs in very acidic, sphagnous springs or seeps that are 

wet, but without standing water (Schuyler 1990). It is known to occur in the Mattaponi 

watershed in Caroline County (Nature Serve 2009). 

An additional set of towers and a transmission line will be added to the existing NAPS to 

Ladysmith right-of-way (Dominion 2009a). Although Dominion has not performed a site-specific 

survey of this transmission line right-of-way, it has worked with the Virginia Natural Heritage 

Program to identify plants of conservation concern on its right-of-ways. Although several rare 

plant species have been located along other Virginia Power transmission line rights-of-way, no 

endangered or threatened plants were noted along the rights-of-way associated with the NAPS 

site (Dominion Nuclear North Anna, LLC 2006a). The NAPS to Ladysmith transmission line 

right-of-way has not been selected for specific field review because there are no known rare 

plant populations in the area, and the soils, topography, and habitats present within the right-ofway are not likely to support populations of rare plants (Dominion 2008g). However, in a 

September 2009 letter, the VDCR informed the NRC staff of the presence of one rare plant 
Environment 

February 2010 2-19 NUREG-1917, SEIS 

species, Epling’s hedge-nettle (Stachys eplingii) in a wetland area within the North Anna to 

Ladysmith right-of-way in western Caroline County (VDCR 2009a). Although not currently listed 

by the Commonwealth, this species is considered critically imperiled in Virginia. 

2.7.1.4 Terrestrial Ecological Monitoring 

As stated in the ESP EIS (NRC 2006a), Dominion was not performing terrestrial ecological 

monitoring (Dominion Nuclear North Anna, LLC 2006a), and none was proposed in the COL ER 

(Dominion 2009a). However, Dominion does cooperate with private organizations, such as the 

local chapter of the Audubon Society, to allow informal monitoring of selected resources at and 

near NAPS, and has worked with the VDCR Natural Heritage Program to conduct rare plant 

surveys in transmission line rights-of-way. The NRC expects Dominion to work with the 

Commonwealth on development and implementation of any required monitoring programs. 

2.7.2 Aquatic Ecology 

A detailed description of the aquatic ecology in the vicinity of the NAPS site is presented in 

Section 2.7.2 of the ESP EIS (NRC 2006a) and Section 2.4 of the ESP ER (Dominion Nuclear 

North Anna, LLC 2006a). Dominion provided the staff with the results of aquatic monitoring 

studies in Lake Anna and downstream of the North Anna Dam conducted since the ESP EIS 

was prepared (NRC 2006a). Additionally, the staff reviewed VDGIF fisheries management 

reports during this time period. 

2.7.2.1 Aquatic Communities in the Vicinity of the NAPS Site 

The aquatic communities of Lake Anna, the WHTF, and the North Anna River downstream of 

Lake Anna are described in detail in Section 2.7.2 of the ESP EIS (NRC 2006a). A brief 

summary is provided here. Lake Anna is typical of many shallow reservoirs found in the 

southern and mid-Atlantic states. Since impoundment, Lake Anna has gone through a typical 

ecological succession of reservoirs, with productivity and aquatic communities stabilizing by 

1975 and remaining relatively stable since 1985 (VEPCo 1986, 1989, 2001a,b; NRC 2003; 

Dominion Nuclear North Anna, LLC 2006a,b). 

Aquatic Communities of Lake Anna 

Over 40 species of fish representing 16 families have been reported in Lake Anna (Table 2-2) 

(VEPCo 1986; Dominion Nuclear North Anna, LLC 2006a, 2006b; Dominion 2007b, 2008a). 

Striped bass are stocked annually at variable rates by the VDGIF. Walleye were stocked 

annually in Lake Anna between 1972 and 2007, but stocking was discontinued because of poor 

post-stocking survival (VDGIF 2007). Sterile triploid herbivorous grass carp (Ctenopharyngodon 

idella) were stocked in the WHTF in 1994 by Virginia Power (NRC 2002b). The sterile grass 

carp were stocked (with the approval of the VDGIF) in the WHTF to control the growth of the 
Environment 

NUREG-1917, SEIS 2-20 February 2010 

nuisance aquatic plant hydrilla (Hydrilla verticillata). VDGIF (2007) notes aquatic plants are 

generally considered to be desirable in aquatic systems, and reports that “... it has taken years 

for the grass carp population to decline through natural mortality and only recently have small 

amounts of aquatic vegetation begun to emerge.” Since the ESP EIS was prepared, annual 

monitoring of Lake Anna and WHTF fish populations by gill net and electrofishing has continued, 

and data suggest that fish species composition and abundance has remained relatively 

unchanged (Dominion Nuclear North Anna, LLC 2006b; Dominion 2007b, 2008a; VDGIF 2007). 

As described in Section 2.7.2.1 of the ESP EIS, there is no commercial fishing on Lake Anna or 

the North Anna River. However, recreational fishing is very popular and professional fishing 

guides regularly take clients fishing on the lake. The warmer water that flows from the WHTF 

into Lake Anna at Dike 3 creates conditions conducive to good fishing during the winter, making 

the lake a popular fishing spot when cold weather slows or stops fishing at other ponds and 

lakes in the region. The VDGIF (2007) reported that fishing preferences in 2005 were similar to 

those in 2000, with most anglers seeking largemouth bass, striped bass, crappie, and catfish. 

Recreational fish species and supporting forage fish population structures, catch rates, and 

fishery management are described in detail in Section 2.7.2.1 of the ESP EIS (NRC 2006a). 

Lake Anna fisheries continue to be managed by the VDGIF with a focus on striped bass and 

largemouth bass. 

Nuisance Species of Lake Anna 

Asiatic clams are considered a nuisance species because once they are introduced, their high 

reproductive rate allows them to quickly occupy suitable habitat. Dominion continues to monitor 

clams twice per year in Lake Anna and the WHTF using an Ekman dredge sampler. In the 

course of monitoring Asiatic clam populations, Dominion also has looked for evidence that the 

zebra mussel (Dreissena polymorpha) has invaded Lake Anna, but this species has not been 

observed. 

Aquatic Communities of the WHTF 

The WHTF presently receives waste heat from the NAPS Units 1 and 2 once-through cooling 

system via the discharge canal. As described in Section 3.4.1.1 of the ESP ER (Dominion 

Nuclear North Anna, LLC 2006a), blowdown water from the proposed Unit 3 will be mixed with 

circulating water from Units 1 and 2 in the discharge canal prior to release into the WHTF. The 

same aquatic communities generally exist in the WHTF and Lake Anna, but Dominion’s annual 

fish monitoring shows that fewer species are collected in the WHTF. Typically in the WHTF, 

bluegill and green sunfish are numerically dominant; fish biomass continues to be dominated by 

channel catfish, common carp, and gizzard shad (Dominion 2007b, 2008a). 
Environment 

February 2010 2-21 NUREG-1917, SEIS 

Table 2-2. Fish and Selected Benthic Macroinvertebrates Reported from Lake Anna 

Family Scientific Name Common Name 

Anguillidae Anguilla rostrata American eel 

Clupeidae Dorosoma cepedianum Gizzard shad 

Dorosoma petenense Threadfin shad 

Alosa aestivalis Blueback herring 

Esocidae Esox niger Chain pickerel 

Esox lucius Northern pike 

Umbridae Umbra pygmaea Eastern mudminnow 

Cyprinidae Ctenopharyngodon idella Grass carp 

Cyprinus carpio Common carp 

Nocomis leptocephalus Bluehead chub 

Nocomis micropogon River chub 

Notemigonus crysoleucas Golden shiner 

Cyprinella analostana Satinfin shiner 

Notropis procne Swallowtail shiner 

Notropis hudsonius Spot tail shiner 

Catostomidae Carpiodes cyprinus Quillback 

Catostomus commersoni White sucker 

Erimyzon oblongus Creek chubsucker 

Moxostoma macrolepidotum Shorthead redhorse 

Hypentelium nigricans Northern hog sucker 

Ictaluridae Ameiurus nebulosus Brown bullhead 

Ameiurus natalis Yellow bullhead 

Ameiurus catus White catfish 

Ictalurus punctatus Channel catfish(a)

Ictalurus furcatus Blue catfish 

Noturus insignis Margined madtom 

Fundulidae Fundulus diaphanus Banded killifish 

Aphredoderidae Aphredoderus sayanus Pirate perch 

Poeciliidae Gambusia affinis Mosquitofish 

Moronidae Morone americana White perch(a)

Morone saxatilis Striped bass(a,b)

Centrarchidae Enneacanthus gloriosus Bluespotted sunfish 

Lepomis auritus Redbreast sunfish 

Lepomis gibbosus Pumpkinseed 

Lepomis gulosus Warmouth 

Lepomis macrochirus Bluegill 

Lepomis microlophus Redear sunfish 

Lepomis cyanellus Green sunfish 

Acantharchus pomotis Mud sunfish 
Environment 

NUREG-1917, SEIS 2-22 February 2010 

Table 2-2. (contd)

Family Scientific Name Common Name 

Micropterus salmoides Largemouth bass(a)

Pomoxis nigromaculatus Black crappie(a)

Percidae Perca flavescens Yellow perch(a)

Sander vitreus Walleye(a,c)

Etheostoma olmstedi Tessellated darter 

Corbiculidae Corbicula sp. Asiatic clam(d)

Unionidae Elliptio complanatus Unionid mussel 

Elliptio productus Unionid mussel 

Sphaeriidae Sphaerium striatum Fingernail clam 

(a) Recreationally important fishery. 

(b) VDGIF stocks striped bass in Lake Anna annually. 

(c) VDGIF stocked walleye in Lake Anna until 2007, but ceased after 2007. 

(d) Asiatic clams (Corbicula sp.) are considered nuisance species. 

Sources: VEPCo 1986; Dominion Nuclear North Anna, LLC 2006a,b; Dominion 2007b, 2008a. 

Aquatic Communities of the North Anna River 

A detailed description of the aquatic communities of the North Anna River below the dam are 

described in Section 2.7.2.3 of the ESP EIS (NRC 2006a), and Section 2.7.2.4 of the ESP ER 

(Dominion Nuclear North Anna, LLC 2006a). Information provided through staff consultation 

with VDGIF and Dominion is summarized below. 

During an extended drought in 2001 and 2002, discharges at the North Anna Dam were 

maintained at 0.6 m3

/s (20 cfs) from November 3, 2001 to December 18, 2002, and gradually 

increased to 1.2 m3

/s (40 cfs) from December 19 to 22, 2002, after a period of significant 

rainfall. During that period, Dominion monitored fish and invertebrate communities in the North 

Anna River below the dam and concluded that aquatic community structure and abundance 

both during and after low flows were comparable to historical measurements (Dominion Electric 

Environmental Services Environmental Biology 2004). 

The North Anna River supports a diverse assemblage of stream fishes, with over 35 species 

representing 13 families reported (Table 2-3) (Dominion Electric Environmental Services 

Environmental Biology 2004; Dominion Nuclear North Anna, LLC 2006b; Dominion 2007b, 

2008a). Redbreast sunfish (Lepomis auritus) have consistently been among the most abundant 

species in the North Anna River since 1981 (VEPCo 2001a; Dominion Electric Environmental 

Services Environmental Biology 2004; Dominion Nuclear North Anna, LLC 2006b; Dominion 

2007b, 2008a). Other abundant fish species are American eel (Anguilla rostrata), satinfin shiner 

(Cyprinella analostana), rosyface shiner (Notropis rubellus), swallowtail shiner (N. procne), and 

margined madtom (Noturus insignis) (Dominion 2008b). Dominion continues to monitor fish in 
Environment 

February 2010 2-23 NUREG-1917, SEIS 

Table 2-3. Fish Species Reported from the North Anna River 

Family Scientific Name Common Name 

Petromyzontidae Lampetra appendix American brook lamprey 

Amiidae Amia calva Bowfin 

Anguillidae Anguilla rostrata American eel 

Esocidae Esox niger Chain pickerel 

Cyprinidae Cyprinella analostana Satinfin shiner 

Lythrurus ardens Rosefin shiner 

Nocomis leptocephalus Bluehead chub 

Nocomis micropogon River chub 

Notropis amoenus Comely shiner 

Notropis procne Swallowtail shiner 

Notropis rubellus Rosyface shiner 

Notropis hudsonius Spottail shiner 

Notemigonus crysoleucas Golden shiner 

Semotilus corporalis Fallfish or American chub 

Catostomidae Erimyzon oblongus Creek chubsucker 

Hypentelium nigricans Northern hog sucker 

Catostomus commersoni White sucker 

Ictaluridae Ameiurus natalis Yellow bullhead 

Ameiurus nebulosus Brown bullhead 

Ictalurus punctatus Channel catfish(a)

Noturus gyrinus Tadpole madtom 

Noturus insignis Margined madtom 

Aphredoderidae Aphredoderus sayanus Pirate perch 

Fundulidae Fundulus diaphanus Banded killifish 

Poeciliidae Gambusia holbrooki Eastern mosquitofish 

Centrarchidae Lepomis auritus Redbreast sunfish 

Lepomis macrochirus Bluegill(a)

Lepomis gulosus Warmouth 

Micropterus dolomieu Smallmouth bass(a)

Micropterus salmoides Largemouth bass(a)

Pomoxis nigromaculatus Black crappie(a)

Acantharchus pomotis Mud sunfish 

Percidae Etheostoma olmstedi Tessellated darter 

Etheostoma vitreum Glassy darter 

Percina peltata Shield darter 

Percina notogramma Stripeback darter 

Achiridae Trinectes maculatus Hogchoker 

(a) Recreationally important fishery. 

Sources: Dominion Electric Environmental Services Environmental Biology 2004; 

Dominion Nuclear North Anna, LLC 2006b; Dominion 2007b, 2008a. 
Environment 

NUREG-1917, SEIS 2-24 February 2010 

the North Anna River by electrofishing (seine and backpack) at four stations between the dam 

and about 39 km (14 mi) downstream. Fish assemblage and abundance data collected since 

the ESP EIS are consistent with previous surveys (Dominion 2008b). 

Since 1987, Virginia Power (now Dominion) biologists have gathered data on the abundance 

and distribution of bass species in the lower North Anna River. Dominion continues to conduct 

snorkel surveys at four stations during the summer months, observing number and size of 

smallmouth bass and largemouth bass along with substrate and cover type used by the fish. 

Historically, largemouth bass (Micropterus salmoides) have dominated the fish counts at 

upstream locations, while smallmouth bass (M. dolomieu) have been more prevalent at 

downstream locations. Recent monitoring data suggest that both species are found throughout 

the study area, with largemouth bass being more abundant in the upstream stations and 

smallmouth bass more abundant at the downstream stations (Dominion Nuclear North Anna, 

LLC 2006b; Dominion 2007b, 2008a). Recent VDGIF surveys have indicated that despite the 

limited supply of forage in the river, largemouth bass and smallmouth bass populations are 

healthy (Dominion Nuclear North Anna, LLC 2006a). 

Aquatic Communities Associated with New Land Acquisition 

As described in Section 2.7.1.1, Dominion recently acquired approximately 38.8 ha (96 ac) 

acres of property adjoining the NAPS Unit 3 site, and intends to use this property to temporarily 

support construction. The results of habitat mapping and wetland delineation conducted 

recently indicate that approximately 1130 linear m (3700 linear ft) of intermittent or perennial 

streams are present and could be affected by construction (Dominion 2009a). 

2.7.2.2 Threatened and Endangered Aquatic Species 

Using information provided in Section 2.4.2.3.5 of the ESP ER (Dominion Nuclear North Anna, 

LLC 2006a), Section 2.7.2.4 of the ESP EIS (NRC 2006a) states that 

Virginia Power has monitored fish populations in Lake Anna and the North Anna River 

for more than 25 years. No Federally or State-listed fish species has been collected in 

any of these monitoring studies, nor has any listed species been observed in creel 

surveys or occasional special studies conducted by Virginia Power biologists. No 

Federally or State-listed fish species’ range includes Lake Anna or the North Anna River, 

and none are believed to occur in counties adjacent to Lake Anna or the North Anna 

River (i.e., Caroline, Hanover, Louisa, Orange, and Spotsylvania Counties). 

A similar statement is provided regarding aquatic plants, based on information provided in the 

ESP ER, suggesting that no listed aquatic plant species have been collected in any of the 

routine monitoring surveys or in special studies, the ranges of listed aquatic plant species do not 

include Lake Anna or the North Anna River, and no listed aquatic plant species are likely to 
Environment 

February 2010 2-25 NUREG-1917, SEIS 

occur on the new land recently acquired adjoining the NAPS Unit 3 site (Dominion 2009a) or in 

the adjacent counties. New fish monitoring studies from Lake Anna and the North Anna River 

provided by Dominion since preparation of the ESP EIS confirm that no listed fish species are 

known to occur in this study area (Dominion Electric Environmental Services Environmental 

Biology 2004; Dominion Nuclear North Anna, LLC 2006b; Dominion 2007b, 2008a); however, 

monitoring of aquatic plant species was not conducted. 

Three species of aquatic invertebrates that could occur in counties adjacent to or downstream of 

the Lake Anna reservoir were identified as Federally or State-listed endangered or threatened in 

the ESP EIS (NRC 2006a): the dwarf wedgemussel (Alasmidonta heterodon), the James 

spinymussel (Pleurobema collina), and the Atlantic pigtoe (Fusconaia masoni) (Table 2-4). Two 

additional species – the green floater (mussel) (Lasmigona subviridis) and the Virginia Piedmont 

Waterboatman, Sigara depressa. an aquatic insect – were identified as occurring in the upper 

Pamunkey River watershed on the VDCR Natural Heritage website (VDCR 2008), but neither 

species were included on USFWS species lists by county (USFWS 2008). Based on the 

information provided to the staff by Dominion in support of the COL action, none of the species 

listed in Table 2-4 have been observed or collected in Lake Anna or the North Anna River 

Table 2-4. Federal or State Listed Threatened or Endangered Species Known or Likely to 

Occur in Counties Adjacent to or Downstream from Lake Anna 

Scientific Name Common Name Counties Status Source 

Alasmidonta heterodon Dwarf 

wedgemussel 

Hanover, Louisa, 

Spotsylvania 

FE(a), 

SE(b) 

VDGIF 2008b 

USFWS 2008 

Pleurobema collina James spinymussel 

Orange, 

Hanover, Louisa, 

Caroline, 

Spotsylvania 

FE, SE VDGIF 2008b 

USFWS 2008 

Fusconaia masoni(c) Atlantic pigtoe 

Orange, 

Hanover, Louisa, 

Caroline, 

Spotsylvania 

FSOC(d), 

SE 

VDGIF 2008b 

USFWS 2008 

Lasmigona subviridis(c) Green floater Not specified FSOC, 

ST(e) 

VDGIF 2008b 

VDCR 2008 

Sigara depressa Virginia Piedmont 

water boatman Not specified SE VDGIF 2008b VDCR 2008 

(a) FE - Federal endangered. 

(b) SE - State endangered. 

(c) Added since publication of ESP EIS (NRC 2006a). 

(d) FSOC - Federal species of concern. 

(e) ST - State threatened. 
Environment 

NUREG-1917, SEIS 2-26 February 2010 

during pre-impoundment surveys or in more recent routine monitoring surveys. Although no 

new information on threatened or endangered species in the vicinity of the ESP site was 

identified in the applicant’s COL ER (Dominion 2009a), there is potential for all or any of these 

species to occur in streams that border Lake Anna or the North Anna River. No information was 

provided by Dominion on the presence or absence of Federally or State-listed aquatic species 

inhabiting streams potentially affected by construction of new transmission lines in the NAPS to 

Ladysmith transmission line right-of-way. The staff expects that future monitoring studies and 

subsequent management actions, such as the one proposed for mussels in Lake Anna by 

Dominion (2008b) will assist resource agencies in determining the potential of threatened and 

endangered species occurring in Lake Anna, the North Anna River, or their tributaries. 

2.7.2.3 Aquatic Ecology Monitoring 

A description of the aquatic ecology monitoring program conducted in the vicinity of the NAPS 

site is provided in Section 2.7.2.5 of the ESP EIS (NRC 2006a) and Section 2.4.2 of the 

ESP ER (Dominion Nuclear North Anna, LLC 2006a). Dominion (or Virginia Power) has 

monitored fish populations in Lake Anna reservoir and the WHTF since the early 1970s, and in 

the North Anna River below the dam since the early 1980s. Consistent methods used over 

many years allow comparisons to be made between years and trends over time to be evaluated. 

As previously discussed, Dominion also completed invertebrate and fish surveys in the North 

Anna River during a period of drought to determine the effect of extended 0.6 m3

/s to 1.2 m3/s 

(20 to 40 cfs) releases from the North Anna Dam on fish and invertebrate assemblages. Study 

results suggested that the biological assemblages observed during and after the drought event 

were comparable to those observed in previous surveys (Dominion Electric Environmental 

Services Environmental Biology 2004). Based on information provided in the COL ER 

(Dominion 2009a) Dominion expects to continue its regular aquatic ecology monitoring program 

of quarterly fish surveys, semi-annual shellfish surveys, and Hydrilla sp. inspections. Dominion 

also updated its monitoring plan in February 2008, proposing to add a smallmouth bass 

population study in the North Anna River below the dam and to search for mussels in Lake 

Anna to determine whether subsequent shellfish monitoring is necessary (Dominion 2008c). 

Dominion also expects that the VDGIF will continue its aquatic ecology monitoring in Lake Anna 

as part of its fishery management responsibilities. Therefore, aquatic ecological monitoring 

during operation of the proposed Unit 3 most likely would be an extension of the existing 

Dominion and VDGIF existing monitoring programs, and Dominion does not intend to add any 

monitoring specific to Unit 3 construction activities, except as discussed above (Dominion 

Nuclear North Anna, LLC 2006a; Dominion 2009a). Other new information provided since the 

publication of the draft SEIS includes a final report on the IFIM study conducted on the North 

Anna and Pamunkey Rivers (Dominion 2009c). A summary of this study is presented below. 
Environment 

February 2010 2-27 NUREG-1917, SEIS 

2.7.2.4 Instream Flow Incremental Methodology Study 

As stated in Section 1.5 of the ESP EIS (NRC 2006a), Dominion agreed to conduct an IFIM 

study of the North Anna River below the dam for those river segments most likely to be 

influenced by operation of any new reactors on Lake Anna or the dam. This study was required 

by the Commonwealth of Virginia’s Coastal Consistency Certification and was a condition of 

NRC’s ESP to be completed prior to the issuance of a COL (Dominion 2009c; NRC 2006a; 

NRC 2007). Study design, analysis, and interpretation were done in cooperation and 

consultation with the VDGIF and the VDEQ. The IFIM study on the North Anna and Pamunkey 

Rivers were designed to assess: 

1. How changes in water flow over the North Anna Dam could influence aquatic communities 

2. Recreational activities in portions of the North Anna River below the dam and in nontidal 

sections of the Pamunkey River 

3. Potential impacts of the operation of Unit 3 and lake level management options on wetland 

resources 

4. Effect of lake level on boat docks and ramps around Lake Anna. 

What follows is a summary of the approach and methodology used for each major study 

component; a detailed description is provided in the IFIM study final report (Dominion 2009c). 

The IFIM study results are summarized in Chapter 5. 

North Anna and Upper Pamunkey River Field Studies 

The IFIM study area comprised 110 km (70 mi) of stream and 27 representative transects 

between North Anna Dam and the nontidal portion of the upper Pamunkey River, which is 

located at the Route 360 bridge crossing. Physiologic provinces included in the study were as 

follows: 

• Piedmont – covering approximately 27 km (17 mi) or one-half the length of the North Anna 

River below the dam, and characterized by a low gradient, sand substrate, and long runs 

• Fall Zone – a transitional zone approximately 10.5 km (6.5 mi) long between the Piedmont 

and Coastal Plain provinces, characterized by rocky substrate, riffles, and pools 

• Coastal Plain – covering the lower 16 km (10 mi) of the North Anna River and all 58 km 

(36 mi) of the nontidal portions of the Pamunkey River, characterized by sand or soft 

substrates and long runs or pools. 
Environment 

NUREG-1917, SEIS 2-28 February 2010 

Prior to the field effort, a mix of species and life stages representing the range-of-habitat 

requirement of resident aquatic communities likely to be affected in the study area were chosen 

through consultation with VDGIF and Dominion personnel. The final list included the following 

species and life stages: 

• American shad (Alosa sapidissima) – juvenile and spawning individuals 

• Smallmouth bass (Micropterus dolomieu) – juvenile, adult, spawning individuals 

• Redbreast sunfish (Lepomis auritus) – spawning individuals 

• Northern hogsucker (Hypentelium nigricans) – adult and spawning individuals 

• Shallow-slow guild – all 

• Shallow-fast guild – all 

• Deep-slow guild – all 

• Deep-fast guild – all 

• Benthic macrovertebrates 

• Eastern elliptio freshwater mussel (Elliptio complanata) 

• Eastern lampmussel freshwater mussel (Lampsilis radiata) 

Dominion and its contractors used the USFWS Physical Habitat Simulation Model (PHABSIM) 

to integrate data from field characterization of habitat parameters (water velocity, water depth, 

substrate, and cover) for low, middle, and high river flows to quantify the amount of preferred 

habitat available for selected species and life stages, expressed as weighted usable area 

(WUA) (Dominion 2009c; Waddle 2001). During the initial study design, target flows over the 

North Anna Dam of 1.1 m3/s (40 cfs), 4.0 m3/s (140 cfs), and 7.1 m3/s (250 cfs) were chosen to 

enable modeling of the range of flow regimes likely to occur. Because of short- and long-term 

weather trends, measurement of North Anna River flow below the Partlow gage during the field 

studies was 1.7 m3/s (60 cfs) during the low-flow evaluation conducted from July 22-27, 2007; 

5.4 m3/s (190 cfs) during the middle-flow evaluation on April 8-11 and May 3-4, 2008; and 

12.1 m3/s (430 cfs) during the high-flow evaluation May 1-2, 2008. These flows were sufficient 

to support the PHABSIM modeling effort. 
Environment 

February 2010 2-29 NUREG-1917, SEIS 

After the PHABSIM model was calibrated to relate flow to availability of suitable habitat for 

aquatic species, life stages, and guilds, the model was run for the range of flows under three 

operational scenarios: 

• Units 1 and 2 existing baseline conditions 

• Proposed Unit 3 operating in energy conservation (EC)/maximum water conservation 

(MWC) mode at the current 76.2 m (250.0 ft) target Lake Anna elevation 

• Proposed Unit 3 operating in EC/MWC mode at a raised 76.3 m (250.25 ft) target Lake 

Anna elevation. 

North Anna and Pamunkey Rivers Recreational Study 

A preliminary review determined that the use of the PHABSIM model did not adequately 

simulate the relationship between flow and conditions for recreational canoeing on the North 

Anna River. In consultation with VDCR, Dominion and its contractors developed an alternative 

approach that includes the use of cross-sectional transect data from the field study combined 

with best professional judgment to relate river width, depth, velocity, and length to canoeing 

experience. The resulting evaluation used a frequency analysis of depth and velocities across 

individual transect cells measured during the field portion of the IFIM study and extrapolated 

these results to other flows of interest. The final analysis focused on flow requirements to 

support recreational canoeing through the riffles and shallow runs in the Piedmont and Fall 

Zone reaches of the study area. 

Wetland Studies 

This series of studies was designed to evaluate the relationship between the lake level and 

wetland areas in Lake Anna, and to assess how the lake level affected the functionality of 

existing boat ramps and docks (Dominion 2009c). Five coves within Lake Anna were surveyed, 

including Christopher Creek, Contrary Creek, Crafton Creek, Freshwater Creek, and Goldmine 

Creek. These coves were located at the interface between tributary streams and the normal 

full-pool elevation of the lake, and represented a range of topographic features common to the 

area. At each cove, a light detection and ranging (LIDAR) remote-sensing application was used 

to determine water surface and land area elevations, and the resulting information was used to 

create geographic information system (GIS) layers that enabled an assessment of the aerial 

extent of changes in inundation. This information was augmented with a field survey of 

30 transects within the 5 coves, which included bathymetric surveys to determine the depths of 

inundation for the wetlands currently present. In addition, 19 of the 30 transects were assessed 

for wetland communities (emergent or forested wetland) using procedures described by 

USACE (1987) with regard to the identification and delineation of wetland communities. Field 

survey observations were combined with digital elevation maps created from LIDAR data to 

assign elevation ranges to the wetland communities present in the study coves. Using the 
Environment 

NUREG-1917, SEIS 2-30 February 2010 

estimated wetland areas and contoured areas of potential inundation, the study team estimated 

the percentages of surveyed wetlands inundated at lake levels ranging from 73 m (240.0 ft) to 

76.3 m (250.25 ft). 

Lake Anna Boat Docks and Ramps 

To evaluate the relationship between lake level and the functionality of existing boat ramps and 

docks, 11 publicly accessible boat ramps and 15 publicly accessible docks were evaluated 

using the digital elevation maps created from LIDAR data. Distance measurements were 

collected between the lake water surface and the top of the docks, and the lake water surface 

and bottom of the skirt boards or existing bumper guards, if present. Water depth 

measurements were also obtained at the paved end of the public boat ramps to determine if 

trailer tires would extend beyond the limits of the paved ramp surface at lower water elevations. 

2.8 Socioeconomics 

This section describes the socioeconomic resources that could be potentially impacted by the 

construction, operation, and decommissioning of the proposed Unit 3. The discussion is 

organized into two major subsections that provide details on demographics and community 

characteristics. New information has become available since the ESP EIS (NRC 2006a) was 

prepared and the Commission Order (CLI-07-27) (NRC 2007) was issued. This information is 

described, and differences that may affect the conclusions concerning impact levels reached in 

the ESP EIS are discussed. 

2.8.1 Demographics 

For the purposes of this analysis, the staff divided the total population within the analytical area 

into three major groups: (1) residents who live permanently in the area; (2) transients who may 

temporarily live in the area but have a permanent residence elsewhere; and (3) migrant workers 

who travel into the area to work and then leave after their job is done. Transients and migrant 

workers are not characterized fully by the U.S. Census, which generally captures only resident 

populations. Detailed characteristics regarding the demographics of the region can be found in 

Section 2.8.1 of the ESP EIS (NRC 2006a). 

New information is presented in the following sections in two ways. First, later population 

estimates were identified that were not available during the ESP EIS process on the original 

socioeconomic impact area. Second, this analysis expands the original socioeconomic area to 

include three new counties. With respect to the more recent estimates, the staff compared the 

same information between the original ESP EIS (2000 Census) and the more recent population 

estimates (e.g., 2006 Census estimates) and determined the difference between the two data 

sources was not large enough to affect the staff’s conclusions. Therefore the staff determined 

that while new, such new data sources were not significant. 
Environment 

February 2010 2-31 NUREG-1917, SEIS 

As part of the review of new information, the staff included in the scope of the socioeconomic 

analysis data for three counties in the socioeconomic impact area that were not previously 

discussed in detail, to determine whether there might be impacts further downstream from the 

proposed site. A characterization of these counties is included in this section. 

2.8.1.1 Resident Population

The information in this section is from the ESP EIS, Section 2.8.1, for the original 

socioeconomic impact area (NRC 2006a). Table 2-5 lists the age distribution of the population 

in three additional downstream jurisdictions – Caroline, Hanover, and King William Counties in 

2000 – and compares the populations with the population of Virginia. The age-distributed 

populations of these counties closely track within 2 to 3 percent of each other. The exception is 

King William County’s 18-to-24 age group (5.9 percent versus 9.6 percent for Virginia). 

Table 2-6 contains data on population, projected population, and annual growth rates for the 

new area, as well as updated projections for the original socioeconomic impact area. Between 

1990 and 2000, Hanover County population increased 36 percent. During the same period, 

Caroline and King William Counties experienced a 15 percent and 20 percent population 

increase, respectively. 

Table 2-5. Estimated Age Distribution of Population in 2000 

Age Group

Hanover County Caroline County

King William 

County Virginia

People % People % People % People %

Under 18 23,363 27.1 5476 24.8 3433 26.1 1,738,262 24.6 

18 to 24 5921 6.9 1643 7.4 781 5.9 679,398 9.6 

25 to 44 26,486 30.7 6611 29.9 4140 31.5 2,237,655 31.6 

45 to 64 21,391 24.8 5534 25.0 3259 24.8 1,630,867 23.0 

65 and over 9159 10.6 2857 12.9 1533 11.7 792,333 11.2 

Totals 86,320 100.0 22,121 100.0 13,146 100.0 7,078,515 100.0 

Source: USCB 2000b. 

Table 2-7 presents updated population estimates for 2006. As shown in this table, all areas, 

with the exception of Henrico County and the City of Richmond, are experiencing growth at a 

rate higher than that generally seen in of Virginia. Historically, Caroline and King William 

Counties both grew more slowly than Louisa, and Orange Counties, while Hanover County grew 

faster than Louisa and Orange Counties but not as fast as Spotsylvania County. Population 

projections for the area show growth in Hanover County slowing considerably relative to the 

growth rates in the other counties. Louisa, Orange, and Spotsylvania Counties still are the 
Environment 

NUREG-1917, SEIS 2-32 February 2010 

centers of population growth near Lake Anna. Generally speaking, all areas are now projected 

to grow faster than when the analysis in the ESP EIS (NRC 2006a) was prepared. 

Table 2-6. Population Growth in Henrico, Louisa, Orange, Spotsylvania, Caroline, Hanover, 

and King William Counties and the City of Richmond – 1980 to 2030 

Year 

Henrico County Louisa County Orange County City of Richmond

Population

Annual 

% 

Growth Population

Annual 

% 

Growth Population

Annual 

% 

Growth Population

Annual 

% 

Growth

1970 154,465 14,004 13,792 249,431 

1980 180,735 1.6 17,825 2.4 18,063 2.7 219,214 -1.3 

1990 217,880 1.9 20,325 1.3 21,421 1.7 203,056 -0.8 

2000 262,300 1.9 25,627 2.3 25,881 1.9 197,790 -0.3 

2010 301,658(a)

 1.4 33,923 2.8 34,127 2.8 190,039 -0.4 

2020 339,703(a)

 1.2 41,889 2.1 42,021 2.1 187,066 -0.2 

2030 379,041(a)

 1.1 50,739 1.9 50,732 1.9 187,066 0.0 

Spotsylvania County Caroline County Hanover County King William

1970 16,424 13,925 37,479 7497 

1980 34,435 7.7 17,904 2.5 50,398 3.0 9334 2.2 

1990 57,405 5.2 19,217 0.7 63,306 2.3 10,913 1.6 

2000 90,395 4.6 22,121 1.4 86,320 3.1 13,146 1.9 

2010 134,163 4.0 29,201(a)

 2.8 105,762 2.1 16,187 2.1 

2020 175,402 2.7 36,058 2.1 124,097 1.6 19,119 1.7 

2030 217,797 2.2 43,662 1.9 143,959 1.5 22,227 1.5 

(a) Projected population for 2010 to 2030; values for 1970 through 2000 are actual census population numbers. 

Sources: Weldon Cooper Center 2008; Virginia Workforce Connection 2008 

Table 2-7. Population Growth in the Socioeconomic Impact Area – 2000 to 2006 

July 1, 2006 2000 Census % Change 2000-06

Virginia 7,642,884 7,078,515 8.0

.Caroline County 26,731 22,121 20.8 

.Hanover County 98,983 86,320 14.7 

.Henrico County 284,399 262,300 8.4 

.King William County 15,381 13,146 17.0 

.Louisa County 31,226 25,627 21.8 

.Orange County 31,740 25,881 22.6 

.Spotsylvania County 119,529 90,395 32.2 

.Richmond City 192,913 197,790 -2.5 

Source: USCB 2007. 
Environment 

February 2010 2-33 NUREG-1917, SEIS 

2.8.1.2 Transient Population 

The transient population includes people who work in or visit large workplaces, schools, 

hospitals and nursing homes, correctional facilities, hotels and motels, and who appear at 

recreational areas or special events where there may be seasonal and workday variations in 

population. 

The transient population was characterized in the ESP EIS, Section 2.8.1.1 (NRC 2006a). 

Dominion has since contacted the VDCR, Louisa County, and King’s Dominion Amusement 

Park, and has received updated information indicating that annual usage has increased at a rate 

consistent with the increase in population in the area. Staff has examined that data and 

believes that the new transient population data does not significantly affect the demand for 

community services in the socioeconomic impact area. 

2.8.1.3 Migrant Labor 

Migrant workers are typically members of minority or low-income populations. Because migrant 

workers travel and can temporarily spend a significant amount of time in an area without being 

actual residents, they may be unavailable for counting by census takers. If this occurred, 

migrant workers would be under-represented in the minority and low-income population counts 

in the U.S. Census Bureau (USCB) data. 

Migrant labor is characterized in the ESP EIS, Section 2.8.1.2 (NRC 2006a). Louisa County 

remains representative of the region, with 474 individual farms (USDA 2002). No new 

information was found to indicate the number of migrant workers in the area is different from the 

description in the ESP EIS. 

2.8.2 Community Characteristics 

The communities potentially most impacted by activities at the NAPS site are Henrico, Louisa, 

Orange, Spotsylvania Counties, and the City of Richmond, all of which are located in central 

Virginia. Community characteristics for those areas are provided in the ESP EIS, Section 2.8.2 

(NRC 2006a). Additional information on Caroline, Hanover, and King William Counties is 

presented in this section, but because of the greater commuting distances and times involved in 

reaching these three counties, it is likely that the areas impacted by construction and operations 

of the proposed Unit 3 would remain in the counties considered originally. Some changes also 

have occurred in the community characteristics of the counties considered originally, and those 

also are considered in this section. However, the staff determined that these changes are not 

large or extensive enough to affect any impact levels previously determined, and, therefore, are 

not significant. 
Environment 

NUREG-1917, SEIS 2-34 February 2010 

2.8.2.1 Economy 

The information for the original socioeconomic impact area is provided in the ESP EIS, 

Section 2.8.2.1 (NRC 2006a). Brief discussions of the economy of each of the counties not 

considered originally follow, along with updated statistics for the counties considered originally. 

Some comparative economic statistics for the three additional counties, along with updated 

information for original areas considered in the ESP EIS, are presented in Tables 2-8, 2-9, 2-10, 

2-11, and 2-12. Table 2-8 presents information on the unemployment rate (updated for the 

entire region to include December 2007), the percentage of individuals below the poverty line for 

2000 and 2005, and median household income for 2000 and 2005. Table 2-9 presents 

information on regional employment trends for Caroline, Hanover, and King William Counties. 

Table 2-10 contains county employment by proprietorship and industry (1990 and 2000) for the 

three additional counties. Table 2-11 contains employment by type of employer for 2006 for all 

counties. Table 2-12 is an aggregation of Table 2-10 and totals employment by industry or 

business type across the three counties for 1990 and 2000. 

Table 2-8. Percent Unemployment, Individual Poverty, and Median Household Income

Unemployment 

(% December 

2003) 

Unemployment 

(% December 

2007) 

Poverty 

(% Estimated 

2000/2005) 

Median 

Household 

Income, $ 

(2000/2005) 

Caroline County 3.8 4.2 9.4/NA 39,845/46,301 

Hanover County 2.7 2.6 3.6/5.4 59,223/68,219 

Henrico County 3.0 3.0 6.2/8.2 49,185/57,154 

King William 

County 

3.3 3.1 5.5/NA 49,876/57,957 

Louisa County 4.8 3.5 10.2/NA 39,402/45,786 

Orange County 3.5 3.5 9.2/NA 42,889/49,838 

City of Richmond 5.3 4.7 21.4/18.5 31,121/34,396 

Spotsylvania 

County 

1.9 2.8 4.7/5.7 57,525/66,846 

Virginia 3.3 3.2 9.6/10.0 46,677/54,240 

Note: Low income was defined as being in a household having an income below the official poverty level. 

Sources: USCB 2000b; NRC 2006a; Virginia Employment Commission 2008; city-data.com 2008. 
Environment 

February 2010 2-35 NUREG-1917, SEIS 

Table 2-9. Regional Employment Trends – 1990 and 2000

County, City, 

and State

Workers 

Employed FullTime and PartTime 1990

Workers 

Employed FullTime and PartTime 2000

% Change in 

Workers 

Employed 

1990 – 2000

Unemployment 

Rate 1990 

%

Unemployment 

Rate 2000 

%

Caroline 5733 8033 40.1 7.5 2.2 

Hanover 36,586 48,421 32.3 2.8 1.6 

King William 4650 4796 3.1 3.1 1.9 

Sources: BEA 2000 and NRC 2006a. 

Table 2-10. County Full-Time and Part-Time Employment by Type and by Industry 

Industry

Caroline County Hanover County King William County

1990 2000 1990 2000 1990 2000

Total employment 5733 8033 36,586 48,421 4650 4796 

Wage and salary employment 4421 5180 30,205 41,121 3760 3929 

Proprietors employment 1312 2853 6381 7300 890 867 

Nonfarm proprietor employment 5476 2642 5792 6703 750 711 

Farm proprietor employment 195 211 589 597 140 156 

By Industry 

Farm employment 257 263 758 783 212 205 

Agriculture services, fishing, and 

other 

73 (D) 450 (D) 61 117 

Mining 16 (D) 133 (D) 10 52 

Construction 733 776 5912 6880 372 473 

Manufacturing 637 508 4029 4681 1448 866 

Transportation and public utilities 352 533 1435 1565 99 80 

Wholesale trade 122 131 4284 5248 119 198 

Retail trade 959 1420 5620 7684 909 693 

Finance, insurance, and real 

estate 

282 713 1828 2808 201 298 

Services 916 2076 8935 12,894 664 1073 

Government and government 

enterprises 

1386 1487 3202 4783 555 741 

D – Not shown to avoid disclosure of confidential information, but the estimates for this item are included in the totals.

L – Fewer than 10 jobs, but the estimates for this item are included in the totals. 

Source: BEA 2000. 
Environment 

NUREG-1917, SEIS 2-36 February 2010 

Table 2-11. County Full-Time and Part-Time Employment by Type, 2006 

Industry

Caroline 

County 

Hanover 

County 

Henrico 

County 

King 

William 

County 

Louisa 

County

Orange 

County

Spotsylvania 

County & 

Fredericksburg 

City of 

Richmond

Total employment 10,007 56,717 210,999 5180 15,414 12,115 75,896 184,176 

Wage and salary 

employment 

5811 46,874 187,019 3972 7540 9856 61,857 174,412 

Proprietors employment 4196 9843 23,980 1208 7874 2259 14,039 9764 

Nonfarm proprietor 

employment 

3997 9278 23,813 1061 7436 1785 13,749 9764 

Farm proprietor 

employment 

199 565 167 147 438 474 290 0 

Total Employment, Year 

2000 

8033 48,421 194,787 4796 11,641 10,558 59,872 196,175 

Percent Growth in Total 

Employment, 2000 to 

2006 

12.5% 17.1% 8.3% 8.0% 32.4% 14.7% 26.8% -6.1% 

Source: BEA 2006. 

Table 2-12. Aggregated Full-Time and Part-Time Employment by Industry or Business Type 

for Caroline, Hanover, Henrico, King William, Louisa, Orange, and Spotsylvania 

Counties, Fredericksburg, and the City of Richmond, 1990 to 2006

Industry or Business Type 

1990 

Employment 

2000 

Employment 

2006 

Employment 

% Increase 

or Decrease, 

1990-2000 

% Increase 

or Decrease, 

2000-2006 

Total employment 469,287 534,283 560,497 13.8% 4.9% 

Wage and salary employment 419,218 475,978 491,530 13.5% 3.2% 

Proprietors employment 50,069 58,305 68,967 16.4% 18.3% 

Nonfarm proprietor employment 52,175 55,929 66,886 7.2% 19.6% 

Farm proprietor employment 2253 2376 2081 5.5% -12.4% 

By Industry 

Nonfarm Employment 464,045 528,954 555,855 14.0% 5.1% 

Farm employment 2989 2953 2561 -1.2% -13.3% 

(a) Summations and percentages are for numbers shown in Table 2-8 (i.e., as with Table 2-8, some county data 

are not reported because of confidentiality issues). Data at the individual industry level are not comparable 

between 2006 and the earlier years due to the reorganization of national economic accounts from Standard 

Industrial Classification (SIC) to the North American Industrial Classification System (NAICS). 

Sources: BEA 2000, 2006. 
Environment 

February 2010 2-37 NUREG-1917, SEIS 

Most of the counties showed unemployment rates in December 2007 below those in December 

2003. The single exception was Spotsylvania County, whose extraordinarily low unemployment 

rate in December 2003 approached the rates in other nearby areas and in Virginia by 

December 2007. Estimated poverty rates increased after 2000 in all local jurisdictions where 

estimates were available for 2005. However, median household incomes increased in all the 

local jurisdictions. As well, 2006 data show that employment continued to grow in all of the 

jurisdictions except Richmond between 2000 and 2006, the last year for which these data 

were available. 

Employment in Caroline County was approximately 8033 in 2000 (see Table 2-9), but 

almost 68 percent of working adults commuted out of the county to work (Virginia Employment 

Commission 2008). The existing employment base in Caroline County represents an increase 

of 40.1 percent over the 1990 level (Table 2-9). The largest employers in Caroline County are 

the Caroline County School Board, County of Caroline, U.S. Department of Defense, Highway 

Service Venture, and Union Bankshares Corporation (Virginia Employment Commission 2008). 

The unemployment rate in Caroline County was 4.2 percent in December 2007 (Table 2-8), an 

increase from the annual unemployment rate of 2.2 percent in 2000 (Table 2-7). Caroline 

County had the third lowest median household income and third highest individual poverty 

rate of the eight jurisdictions studied (Table 2-8). In percentage terms, the fastest growing 

employment sectors in Caroline County during the decade of the 1990s were finance, 

insurance, and real estate (152.8 percent); services (126.6 percent); and transportation 

and public utilities (51.4 percent) (Table 2-10). The towns of Bowling Green and Port Royal 

are the only two incorporated towns in Caroline County. 

Employment in Hanover County was approximately 48,421 in 2000 (see Table 2-9), but almost 

65 percent of working adults commuted out of the county to work (Virginia Employment 

Commission 2008). The existing employment base in Hanover County represents an increase 

of 32.3 percent over the 1990 level (Table 2-9). The largest employer (2616 people) is Hanover 

County Schools. The second largest employer (1200 workers) is Supervalu Eastern Region, a 

food distribution center (Hanover County Economic Development 2006). The unemployment 

rate in Hanover County was 2.6 percent in December 2007 (Table 2-8), an increase from the 

annual unemployment rate of 1.6 percent in 2000 (Table 2-9). Hanover County had the highest 

median household income and lowest individual poverty rate of the eight jurisdictions studied 

(Table 2-8). In percentage terms, the fastest growing employment sectors in Orange County 

during the decade of the 1990s were finance, insurance, and real estate (53.6 percent), 

government and government enterprises (49.4 percent), and services (44.3 percent) 

(Table 2-10). The town of Ashland is the only incorporated town in Hanover County. 

Employment in King William County was approximately 4796 in 2000 (see Table 2-9), but about 

70 percent of working adults commuted out of the county to work (Virginia Employment 

Commission 2008). The existing employment base in King William County represents an 
Environment 

NUREG-1917, SEIS 2-38 February 2010 

increase of 3.1 percent over the 1990 level (Table 2-9). The largest employer (over 500 people) 

is Smurfit Stone, a paperboard mill. Other large employers (100 to 199 employees) are Nestle 

Purina Pet Care, Food Lion, and West Point Veneer (King William County 2008). The 

unemployment rate in King William County was 3.1 percent in December 2007 (Table 2-8), an 

increase from the annual unemployment rate of 1.9 percent in 2000 (Table 2-9). King William 

County had the third highest median household income and sixth highest individual poverty rate 

of the eight jurisdictions studied (Table 2-8). In percentage terms, the fastest growing 

employment sectors in King William County during the decade of the 1990s were mining 

(420 percent), agricultural services (91.8 percent), and wholesale trade (66.4 percent) 

(Table 2-10). The town of West Point is the only incorporated town in King William County. 

Table 2-11 shows that employment in the region grew steadily during the 1990s and continued 

this growth trend in the post-2000 period. With growth in population and urban growth, the post2000 period has continued the earlier trend of displacement of the farm economy by nonfarm 

activity. Economic trends identified in the ESP EIS (NRC 2006a) have continued and are not 

significantly affected by including the details for three additional counties. 

2.8.2.2 Transportation 

A characterization of the transportation system is provided in the ESP EIS, Section 2.8.2.2 

(NRC 2006a). Dominion reviewed highway plans within updated comprehensive county plans 

for Hanover, Louisa, and Spotsylvania counties, and did not find any new information indicating 

a timetable for upgrades to existing routes (although interest in upgrades is still indicated) or 

new sources of funds for upgrades. The NRC staff has reviewed the record of Dominion’s 

efforts to obtain new information concerning highway traffic counts, level-of-service information, 

and construction plans. 

Specifically, the ESP EIS identifies U.S. Highway 522 and State Routes 208, 618, 652, and 700 

as having a level-of-service (LOS) designation of B. State Route 606 has been designated a 

LOS generally of D or better. Dominion reported that they contacted the Virginia Department of 

Transportation (VDOT) in July 2007 regarding new and/or updated information on traffic counts 

and LOS information for these commuting routes leading to the NAPS site. VDOT responded in 

August 2007 that it did not have specific information on the LOS for these routes. In addition, 

no new traffic counts had been completed since preparation of the ESP EIS. 

Road improvements for U.S. Highways 33 and 522 and SRs 22, 208, 606, 618, 652, and 

700 are recommended in the Louisa County Draft Comprehensive Plan of 2001 and the 

Spotsylvania County Approved 2002 Comprehensive Plan. Traffic resulting from additional 

people commuting to the NAPS site would increase on these routes but would be alleviated with 

the implementation of a construction traffic management plan prior to the start of general plant 

construction and road improvements outlined in the comprehensive county plans. The Louisa 

County Comprehensive Plan was updated in 2006. This plan does not provide new and 
Environment 

February 2010 2-39 NUREG-1917, SEIS 

significant information on the schedule or funding of the recommended road improvements and 

is consistent with the conclusions provided in the North Anna ESP EIS. 

While upgrading to SR 208 has been initiated, and Phase I has been completed (VDOT 2009a, 

2009b) as projected in the ESP EIS, the staff believes that no additional information has 

become available that would significantly change the description of the local road network or the 

ability of the jurisdictions in the region to upgrade them. 

2.8.2.3 Property Taxes 

A detailed characterization of property taxes is provided in the ESP EIS, Section 2.8.2.3 

(NRC 2006a). Dominion did not present any new information since preparation of the ESP EIS. 

2.8.2.4 Aesthetics and Recreation 

A detailed characterization of aesthetics and recreation is provided in the ESP EIS, 

Section 2.8.2.4 (NRC 2006a). Dominion contacted officials in the area and determined that no 

noise complaints had been filed, and that the site remains screened from public view. Staff has 

reviewed this new information and believes that there is no significant change to site noise or 

visual aesthetics of the NAPS site. 

Since the publication of the draft SEIS, additional information bearing on recreation has 

emerged. First, in December 2008, the Lake Anna Civic Association (LACA) published the 

results of a membership survey (LACA 2008), which described the effects of low water levels on 

the recreation experience of survey respondents. The survey is described briefly in this chapter. 

The second item of information is the published findings of the IFIM study (Dominion 2009c), 

described in Section 2.7.2.4. The findings of both of these studies that are relevant to 

recreation are discussed in Section 5.5.4.2. Both studies provide additional insight into the

relationship between water levels and recreation at Lake Anna and in the North Anna River 

downstream from the lake. 

LACA Survey 

LACA surveyed its 909 members in 2008, and 151 responses were received. Eight of the 

responses were from property owner associations (POAs), and 143 from individuals. LACA 

believes that impacts on common areas (e.g., users of shared dock facilities and slips) of the 

POAs were not adequately represented and noted that some POAs did not report. Although the 

response rate was low and it is not known how statistically representative the results are, some 

useful insights can be inferred. Responders indicated significant problems with docks, lifts, 

watercraft, and recreational activities when water levels fall below the normal elevation of 

76.2 m (250.0 ft). For perspective, LACA provided the surveyed members with numerical 

values for the low point of the water level during 2007 of 75.4 m (247.5 ft) 0.76 m [2.5 ft] low) 
Environment 

NUREG-1917, SEIS 2-40 February 2010 

and the low water level in the 2001 of 74.7 m (245 ft) (1.5 m [5 ft] low). Sixty-two percent of 

respondents indicated that they first experienced problems when water levels fell to 75.6 m 

(248 ft), (0.76 m [2 ft]) lower than the normal elevation of 76.2 m (250.0 ft). This increased to 

88 percent at 0.9 m (3 ft) below normal elevation, and to 92 percent at 1.5 m (5 ft) below normal 

elevation; 8 percent reported no impact even when the water level was 1.5 m (5 ft) low. 

2.8.2.5 Housing 

A detailed characterization of housing in the area is provided in the ESP EIS, Section 2.8.2.5. 

(NRC 2006a) Dominion contacted county officials and determined that the issuance of housing 

permits in Louisa County is higher than reported in the ESP EIS (NRC 2006a). Updated 

information on building permit data was obtained from the Louisa County Community 

Development Director in July 2007. According to this source, more than 400 single-family housing 

permits have been issued each year since 2004. The number has fluctuated, as would be 

expected, with approximately 700 units in 2004, 800 in 2005, 600 in 2006. If trends continue, 

approximately 550 new building permits could be expected in 2007. These changes represent 

higher numbers than reported in the ESP EIS, and indicate an overall positive trend. The 2005 

Orange County Comprehensive Plan (amended in both 2006 and 2007) (Orange County 

Comprehensive Plan 2007) indicates a 2005 housing stock of 13,436 units, 2082 more than in the 

year 2000. Data for housing in these additional counties is included in Tables 2-13 and 2-14, and 

updated data for 2006 in selected counties is included in Table 2-15. Except as discussed above, 

updated data were not available for the counties with lesser populations (Louisa, Orange, 

Caroline, and King William Counties). Though not all increased vacant housing stock would be 

appropriate housing for in-migrants drawn by the construction and operation of the proposed 

Unit 3, the available data show significant growth in the housing stock and available housing stock 

(vacancies) in Hanover, Henrico, and Spotsylvania Counties and a continued increase in available 

stock in the City of Richmond, mainly because of population declines. 

2.8.2.6 Public Services 

A characterization of public services was provided in the ESP EIS, Section 2.8.2.6 (NRC 2006a). 

That analysis has been expanded to include the additional three downstream counties and new 

data that has become available since the ESP EIS was completed. The NRC staff has decided 

to further evaluate water consumption plans in Hanover, Caroline, and King William Counties. 

Water Supply 

Updated information on the major public water systems in the region is contained in Table 2-16. 

Hanover County’s water system provides water to about 19,292 water customers through 

11 wells (one of which is currently out of service), two surface water treatment plants (one of 

which is currently out of service), and purchases from the City of Richmond and Henrico 
Environment 

February 2010 2-41 NUREG-1917, SEIS 

Table 2-13. Housing Units and Housing Units Vacant (Available) by County – 1990 and 2000 

1990 2000

Approximate Percentage 

Change

Caroline County 

Total housing units 7292 8889 21.9 

Occupied units 6631 8021 21.0 

 Owner occupied 5303 6571 23.9 

 Renter occupied 1328 1450 9.2 

Vacant units 661 868 31.3 

Hanover County 

Total housing units 23,727 32,196 35.7 

Occupied units 22,628 31,121 37.5 

 Owner occupied 18,892 21,918 16.0 

 Renter occupied 3767 9203 44.3 

Vacant units 1099 1075 -2.1 

King Williams County 

Total housing units 4193 5189 23.8 

Occupied units 3834 4846 26.4 

 Owner occupied 3114 4118 32.2 

 Renter occupied 720 728 1.1 

Vacant units 359 343 -4.5 

Sources: USCB 1990, 2000b. 

County. The Doswell Water Treatment Plant is rated at 15,142 m3/d (4 MGD) and draws from 

the North Anna River. The South Anna Water Treatment Plant, rated at 7571 m3

/d 

(2.0 MGD),and drawing from the South Anna River is currently out of service, and would require 

substantial upgrades and rehabilitation before it could be returned to service. There are a total 

of 11 wells with a capacity of 4164 m3

/d (1.1 MGD), although the 2461 m3/d (0.65-MGD) 

Garthright well facility is currently out of service. Hanover County receives additional water 

supplies through long-term contracts with the City of Richmond for 56,481 m3

/d (15 MGD) 

(for service to the Suburban Service Area) and Henrico County for 2934 m3

/d (0.775 MGD) (for 

service to the SR 33 area). The Henrico County contract extends through June 2014, and the 

City of Richmond contract extends through June 2035, with an additional 18,927 m3

/d (5 MGD) 

incremental capacity purchase available beginning in 2010. While groundwater resources are 

restricted by quality and quantity concerns, the county estimates that the incremental increase 

of 18,927 m3

/d (5 MGD) from the City of Richmond, along with other water sources, should be 

sufficient for the county through the 2020 to 2025 time period (Hanover County Comprehensive 

Plan 2007-2027, Section 3: Public Utilities 2007). 
Environment 

NUREG-1917, SEIS 2-42 February 2010 

Table 2-14. Vacant Housing Units for Caroline, Hanover, and King William Counties – 2000 

Number Percent of Vacant Units 

Caroline County 

Vacant housing units 868 

 For rent 92 10.6 

 For sale only 137 15.8 

 Rented or sold, not occupied 33 3.8 

 For seasonal, recreational or occasional use 273 31.5 

 For migratory workers 15 1.7 

 Other vacant 318 36.6 

Hanover County 

Vacant housing units 1075 

 For rent 253 23.5 

 For sale only 258 24.0 

 Rented or sold, not occupied 142 13.2 

 For seasonal, recreational or occasional use 73 6.8 

 For migratory workers 2 0.2 

 Other vacant 347 32.3 

King Williams County 

Vacant housing units 343 

 For rent 33 9.6 

 For sale only 50 14.6 

 Rented or sold, not occupied 31 9.0 

 For seasonal, recreational or occasional use 85 24.8 

 For migratory workers 1 0.3 

 Other vacant 143 41.7 

Source: USCB 2000b. 

Caroline County is served by two systems, the Caroline County Utility System and the Milford 

Sanitary System. The Caroline County Utility System draws from six wells, with a capacity of 

0.03 m3

/s (0.68 MGD). The Milford Sanitary System draws from two wells with a capacity of 

0.009 m3/s (0.21 MGD). The Towns of Bowling Green and Port Royal operate their own public 

water systems. There also are a number of private central water distribution systems scattered 

throughout the county, mostly associated with subdivision development. The three largest 

private systems draw 2194 m3

/d (0.5796 MGD), with 1802 m3/d (0.476 MGD) drawn from 
Environment 

February 2010 2-43 NUREG-1917, SEIS 

Table 2-15. Selected County Housing Statistics for 2006(a)

Hanover 

County 

Change 

Since 

2000 

Henrico 

County 

Change 

Since 

2000 

Spotsylvania 

County 

Change 

Since 2000 

City of 

Richmond 

Change 

Since 2000

Total housing 

units 

37,033 4837 124,595 12,025 43,544 10,215 93,811 1529 

Occupied 

units 

35,000 3879 115,445 7324 41,381 10,073 81,193 -3336 

Owner 

occupied 

28,492 7024 78,757 7668 33,839 8104 37,339 -1669 

Renter 

occupied 

6508 -2695 36,688 -344 7542 1969 43,854 -1687 

Vacant units 2033 958 9150 4701 2163 142 12,618 4885 

(a) Data not available for all areas. 

Sources: USCB 2006a; NRC 2006a. 

surface water sources, while the rest rely on groundwater. While groundwater sources are most 

likely sufficient in the near future, Caroline County is beginning to explore surface water 

sources, including the Rappahannock, Mattaponi, and Pamunkey Rivers for long-term water 

needs (Caroline County Comprehensive Plan 2006-2026, Section 6: Public Facilities 2008). 

The Town of Bowling Green is served by four wells and three storage tanks totaling 1363 m3

(360,000 gal) of storage (Town of Bowling Green 2005). The Town of Port Royal serves 

199 people with one well with a pumping capacity of 0.005 to 0.007 m3

/s (80 to 110 GPM), 

producing about 74 m3

/d (19,600 GPD) (Port Royal Community Plan 2004). 

King William County is primarily served by private wells, although there are three small public 

systems that draw from groundwater sources. These three areas are supplied by three storage 

tanks of 1134, 38, and 7.6 m3

 (300,000, 10,000, and 2000 gal) capacities that draw from wells. 

Only the 1134 m3

 (300,000-gal) storage tank is treated (King William County Comprehensive 

Plan. Chapter VI - Community Assets and Facilities 2003). 

Police, Fire, and Medical 

No new and significant information was identified for the counties discussed in the ESP EIS 

(NRC 2006a). 

In Hanover County, there is no hospital, but there are medical facilities. The fire department is a 

combination of professional and volunteer personnel. The sheriff’s department provides most of 

the law enforcement within the county. 
Environment 

NUREG-1917, SEIS 2-44 February 2010 

Table 2-16. Major Public Water Supply Systems in Caroline, Hanover, Henrico, King William, 

Louisa, Orange, and Spotsylvania Counties 

Water System Source

Daily Capacity 

m3/day (MGD)

Average Daily Use 

m3

/day (MGD) Area Served

Henrico County James River NA 130,000 (35) Henrico, Hanover and 

Goochland Counties 

City of Richmond James River 484,000 (128) 310,000 (83) Richmond, Chesterfield, 

Hanover, and Henrico Counties 

Louisa County Water 

Authority 

Groundwater/NE 

Creek Reservoir 

3800 (1) 1100 (0.3) Towns of Louisa, Mineral, and 

some County residents 

Town of Orange Rapidan River 7600 (2) 5700 (1.5) Town of Orange 

Rapidan Service 

Authority 

Groundwater NA 75 (0.02) Town of Grodonsville, plus 50 to 

60 homes on Route 20 

Wilderness Treatment 

Plant 

Rapidan River 6100 (1.6) 1500 (0.4) Town of Wilderness/Lake of the 

Woods 

Spotsylvania County Ni River 23,000 (6) 17,000 (4.5) Supplies most residential, 

commercial, and industrial areas 

in the county 

Hanover County North Anna River, 

Ground Water, 

City of Richmond, 

Henrico County 

(7.1), with 

purchase 

capacity of 

(15.775) 

(3.59) Hanover County 

Caroline County Groundwater (527.5 gpm) (330,000 GPD) Caroline County minus Towns of 

Bowling Green and Port Royal 

Town of Bowling 

Green 

Groundwater (189,000 GPD) (140,000 GPD) Town of Bowling Green, Rt. 2 

corridor north to Rt. 631 and 

south to Maury Heights 

subdivision 

Port Royal Groundwater (19,600 GPD) (12,000 GPD) Town of Port Royal 

King William County Groundwater 312,000 gallon 

water storage 

tanks 

(530,000 GPD) Central Garage Area, King 

William County Industrial Park, 

King William County Courthouse 

complex 

NA = not available. 

Sources: NRC 2002a; Hanover County Comprehensive Plan 2007 to 2027, Section 3: Public Utilities 2007; Caroline 

County Comprehensive Plan 2006 to 2026, Section 6: Public Facilities 2008; Town of Bowling Green 2005; County of 

Caroline 2006; Port Royal Community Plan 2004; King William County Comprehensive Plan. Chapter VI - 

Community Assets and Facilities 2003; City-Data.Com 2008. 

In Caroline County, there is no hospital but there are medical facilities. The fire department is 

headed by a professional, but relies on volunteers for fire and rescue operations. A sheriff’s 

department and state police officers assigned to the county provide police protection to the 

county; additionally, the Town of Bowling Green maintains its own police department. 
Environment 

February 2010 2-45 NUREG-1917, SEIS 

The information for this section for the previously considered counties is provided in the 

ESP EIS, Section 2.8.2.6 (NRC 2006a). Dominion did not find any new information for those 

counties that would be likely to change the level of impacts previously stated in the ESP EIS. 

2.8.2.7 Education 

A detailed characterization on education is included in the ESP EIS, Section 2.8.2.7 

(NRC 2006a). Updated information on public schools is included in this section. 

Henrico County School District enrolled 47,958 students in the school year 2007 to 2008 (up 

6965 from the 41,000 figure in the school year 2000 to 2001, as discussed in the ESP EIS) and 

has 44 elementary schools, 13 middle schools, 9 high schools, and 2 technical centers (Henrico 

County Public Schools 2008). Richmond City schools declined in enrollment from 27,237 in the 

school year 2000 to 2001 to 23,771 in the school year 2007 to 2008, a net loss of 3466 students 

(Virginia Department of Education 2008). 

Louisa County Public Schools project an enrollment of 4695 in the school year 2008 to 2009 (up 

463 from 4232 in 2000 to 2001 discussed in the ESP EIS), and are in the process of building a 

new elementary school (Louisa County Public Schools 2008). The new elementary school is 

currently scheduled to open in November 2009. 

Orange County Public Schools enrolled 5167 students in the school year 2007 to 2008 (up 869 

from 4200 discussed in the ESP EIS), with 5 elementary schools, 2 middle schools, and 1 high 

school (Virginia Department of Education 2008). 

Spotsylvania County Public Schools enrolled 24,465 students in the 2007 to 2008 school year 

(up 3765 from the total of about 20,700 reported in the ESP EIS), with 16 elementary schools, 

7 middle schools, 5 high schools, and 3 technical/alternative schools (Spotsylvania County 

Public Schools 2008). 

Hanover County has 14 elementary, 1 alternative, 4 middle schools, and 4 high schools which 

service the needs of about 20,000 students (Hanover County Public Schools 2008). 

Caroline County serves more than 4400 students with 4 elementary, 1 middle school, and 

1 high school (Caroline County Public Schools 2008). 

King William County annually instructs approximately 2800 students in its middle school, high 

school, and 2 elementary schools. King William County also offers an alternative school for 

at-risk students, as well as a providing a center specifically for adult education (King William 

County Public Schools 2008). 
Environment 

NUREG-1917, SEIS 2-46 February 2010 

2.9 Historic and Cultural Resources 

This section discusses the cultural background and the known and potential historic and cultural 

resources at the NAPS site and the immediate surrounding area. 

2.9.1 Cultural Background 

The area surrounding the NAPS site has a variety of prehistoric and historic Native American 

and historic Euro-American resources. For more specific details as to the variability and cultural 

context of these resources refer to the ESP EIS (NRC 2006a). 

2.9.2 Historic and Cultural Resources at the NAPS Site 

Previous cultural resource investigations at the NAPS site have established the presence of 

both historic and pre-contact resources. Several existing literature and database sources were 

consulted, along with direct contacts to several organizations. 

Cultural resource investigations from 1969 to 2006 are referenced in the ESP EIS. The findings 

of these investigations within both the NAPS site boundary and the lake-bed area yielded few 

resources, and none that were discovered were recommended eligible for the National Register 

of Historic Places (NRHP). The 2006 investigation for the ESP site reported no cultural 

resources with the exception of two previously recorded historic cemeteries. These cemeteries 

(44LS0221 and 44LS0222) were identified in the ESP ER (Dominion Nuclear North Anna, 

LLC 2006a). 

Further efforts within the direct area potentially affected identified an additional historic cemetery 

and one historic site in the proposed Unit 3 site area, and select high probability locations within 

the defined area. The third cemetery (44LS0227) and the historic site (44LS0226) were 

identified in the COL ER (Dominion 2009a). 

Additional Field investigations and associated background research was completed by The 

Louis Berger Group in 2007 to 2009 for the COL ER (The Louis Berger Group 2007). Field 

investigations covered the 500-kV Ladysmith transmission line and the added 38.8 ha (96 ac) 

plot west of the proposed Unit 3 area. Background research and desktop investigations 

covered these areas in addition to the proposed Heavy Haul Road route and the “Haley East” 

plot south of the proposed Unit 3 area. 

The newly identified resources from the 2006 to 2009 Group investigations include 11 isolated 

finds, 12 archaeological sites, and 36 architectural resources (The Louis Berger Group 2006). 

Five of these resources and the three previously identified cemeteries were recommended 

eligible for the NRHP. These cultural resources are historic archaeological sites 44LS0226, 

44LS0233, 44SP0618; historic cemeteries 44LS0221, 44LS0222, and 44LS0227; and 
Environment 

February 2010 2-47 NUREG-1917, SEIS 

architectural resource Virginia Department of Historic Resources (VDHR) No. 016-5042/ 

Blanton’s Road Farm (Dominion Nuclear North Anna, LLC 2006a; Dominion 2009a, d, e). 

Cultural resources that are identified in the proposed or alternate heavy haul road area of 

potential effect, once the route is completed, will be addressed through the National Historic 

Preservation Act Section-106 process (Dominion 2009d, e). 

Through COL ER-related field investigation, and map verification at the COL site audit, it was 

determined that one of the previously identified cemeteries (44LS0222) had been mapped 

incorrectly in the ESP ER, and both The Louis Berger Group and VDHR records had the 

cemetery placed in one of the NAPS site substation switchyards. The VDHR was notified and 

appropriate records were corrected. 

For a more detailed description of historic and cultural resources at the proposed Unit 3 site, 

refer to the ESP EIS (NRC 2006a). 

2.9.3 Native American Consultation 

Following the precedent established during the North Anna ESP process, the following groups 

were consulted in association with the COL for the proposed Unit 3. 

• Chickahominy Indian Tribe 

• Chickahominy Indians – Eastern Division 

• Mattaponi Indian Tribe 

• Monacan Indian Nation 

• Nansemond Indian Tribe 

• Pamunkey Indian Tribe 

• Rappahannock Tribe 

• Upper Mattaponi Indian Tribe 

• Tuscarora Nation (Sanborn, New York) 

• Virginia Council on Indians 

In addition, further consultation with the VDHR resulted in an additional six groups added to this 

list for consultation. Those groups were: 

• United Keetoowah Band of Cherokee Indians in Oklahoma 

• Catawba Indian Nation 

• Eastern Band of Cherokee Indians in Oklahoma 
Environment 

NUREG-1917, SEIS 2-48 February 2010 

• Shawnee Tribe 

• Eastern Shawnee Tribe of Oklahoma 

• Tuscarora Indian Tribe (Lewiston, New York) 

The Pamunkey Tribal Government responded to NRC with comments on the draft SEIS 

concerning potential impacts to cultural resources by letter dated February 3, 2009.(a) The 

Pamunkey Tribe expressed concern the proposed Unit 3 might have a negative effect on the 

head waters of the Pamunkey River, which is the North and South Anna Rivers. The Pamunkey 

River is an important part of the Pamunkey tribal cultural heritage. 

The Pamunkey Indian Reservation lies along the Pamunkey River in King William, Virginia. It 

contains approximately 485.6 ha (1200 ac) of land, 202.3 ha (500 ac) of which are wetlands, 

and is a Virginia Historic Landmark. The Pamunkey Indian Tribe was officially recognized by 

the Commonwealth of Virginia in the Treaty of 1677 with the King of England, acting through the 

Governor of Virginia; although the Governor, the Council, and the General Assembly of Virginia 

confirmed the Pamunkey Tribe's reservation lands in 1658. An annual tribute to the Governor 

by the Pamunkey Tribe fulfills their obligation as defined in the treaty. This annual tribute has 

been accomplished every year since the treaty’s inception. 

Currently, 28 families reside on the Pamunkey reservation. The Pamunkey are both 

subsistence fishers and fishing guides for the river, with a cultural importance placed upon the 

shad population. Fishing is seen an integral part of their culture and defines who they are as a 

people. The reservation is approximately 80 km (50 mi) downstream of the NAPS site. 

The NRC met with council members of the Pamunkey Tribal Government on October 29, 2009 

to discuss, in more detail, the concerns outlines in the February 3, 2009 letter. As a result of 

this meeting, the information provided by the Pamunkey has been evaluated in Chapter 2, 4 and 

5 of this SEIS. A summary of this meeting is documented on the NRC website in ADAMS and 

can be accessed using Accession Number ML093500380. 

2.10 Environmental Justice 

Environmental justice refers to a Federal policy under which each Federal agency identifies and 

addresses, as appropriate, disproportionately high and adverse human health or environmental 

 

(a) The February 3, 2009, letter with the concerns of the Pamunkey Tribe is available at NRC’s 

Agencywide Document Access and Management System (ADAMS) (Accession No. ML090540397). 

The letter also is listed in Appendix F of this SEIS. 
Environment 

February 2010 2-49 NUREG-1917, SEIS 

effects of its programs, policies, and activities on minority or low-income populations.(a) Through 

an Executive Order, the Council on Environmental Quality (CEQ) has provided guidance for 

addressing environmental justice (CEQ 1997). Although it is not subject to the Executive Order, 

the Commission has voluntarily committed to undertake environmental justice reviews. On 

August 24, 2004, the Commission issued its policy statement on the treatment of environmental 

justice matters in licensing actions (69 FR 52040). 

Section 2.10 of the ESP EIS (NRC 2006a) described the existing demographic and geographic 

characteristics of the proposed NAPS site and its surrounding communities. It offered a general 

description of minority and low-income populations within the region surrounding the site. The 

characterization in this section updates that discussion and considers any new data that 

available on minority and low-income populations. The characterization of populations of 

interest includes an assessment of “populations of particular interest or unusual circumstances” 

such as minority communities exceptionally dependent on subsistence resources or identifiable 

in compact locations, such as Native American settlements. The scope of the following 

environmental justice analysis includes an evaluation of Dominion’s process for identifying new 

and significant information and an independent evaluation of the potential changes that may 

have taken place between the completion of the ESP process and the commencement of the 

COL application. For its independent review, the staff conducted a limited number of telephone 

contacts with community leaders in potentially affected counties, including Louisa, King William, 

Hanover, and Caroline Counties (attempts to reach officials in Hanover County were 

unsuccessful). King William, Hanover, and Caroline Counties were added to the socioeconomic 

impact area because they were the nearest downstream counties with significant minority and 

low-income populations.(b) The evaluation of Dominion’s new and significant information 

process and its own outreach process provided support for the staff’s impact determinations 

discussed in Sections 4.7 and 5.7. 

 

(a) Minority categories are defined as American Indian or Alaskan Native; Asian; Native Hawaiian or 

other Pacific Islander; Black races; or Hispanic ethnicity; “other” may be considered a separate 

minority category. Low income refers to individuals living in households meeting the official poverty 

measure. To see the U.S. Census definition and values for 2000, visit the U.S. Census website at: 

http://ask.census.gov/. 

(b) NRC telephone interviews with Paul G. Oswell (Louisa County Department of Social Services, 

Director), Donna Ison (Louisa County Community Cupboard, Director), Ben Owen (King William 

County Department of Social Services, Director), Cynthia J. Green (Caroline County Department of 

Social Services, Director), Chief Kevin Brown (Pamunkey Tribal Government). Subject: 

“Environmental and social issues impacting low-income and/or minority populations related to 

activities proposed at the North Anna Power Station Unit 3.” January 20 to February 3, 2009. 

Accession No. ML100340045. 
Environment 

NUREG-1917, SEIS 2-50 February 2010 

2.10.1 Analysis 

The staff considered population data that have become available since the ESP EIS was 

prepared. The new data indicate that there has been growth in the minority and low-income 

populations, but do not provide any additional information concerning the locations of these 

populations. The best location indicator is still the 2000 Census of Population and the figures 

found in Section 2.10 of the ESP EIS (NRC 2006a). The data in the ESP EIS indicated that 

concentrations of minority and low-income populations exist in within an 80-km (50-mi) radius of 

the NAPS site. 

Repeating a summary of that analysis: 

Within 32 km (20 mi) of NAPS, a minority population is concentrated to the southwest of 

the site in Louisa County. Black minority populations exist within approximately 24 km to 

48 km (15 mi to 30 mi) east-southeast of the site on Caroline County’s boundary with 

Hanover County and extending to King William County. Between approximately 64 km 

(40 mi) and 80 km (50 mi) east of the ESP site, minority populations exist in Essex and 

Westmoreland Counties. A concentration of minority census block groups exists in 

Charles County (Maryland) and Prince William County (Virginia), east-northeast of the 

NAPS site. Between 64 km (40 mi) and 80 km (50 mi) southeast of NAPS, there is a 

concentration of minority census block groups in the Richmond area, and to the 

south-southwest a concentration in Buckingham, Fluvanna, Goochland, and Cumberland 

Counties. Minority populations also appear in Culpeper County northwest of the North 

Anna site. All minority block groups are more than 16 km (10 mi) from NAPS 

(NRC 2006a). 

Concerning low-income populations, the ESP EIS reported: 

Census block groups containing low-income populations are concentrated in the City 

of Richmond. Also, Henrico and Chesterfield Counties, to the southeast between 

approximately 65 km and 80 km (40 mi and 50 mi) from the North Anna site, have lowincome populations. Other areas of low-income populations include Buckingham County 

southwest of the site and Charlottesville. 

The closer proximity low-income populations were located in the same locations (same census 

block groups) as the closer proximity minority populations, so none are within 16 km (10 mi) of 

the NAPS site. Based on the estimated property values around Lake Anna, it is unlikely that 

there is a concentration of low-income persons living at Lake Anna itself. 

Table 2-17 shows the estimated changes in population, minority population, and low-income 

population for the nearest counties to the NAPS site since the 2000 Census. 
Environment 

February 2010 2-51 NUREG-1917, SEIS 

Table 2-17. Summary of County-Level Changes in Population and Minority and Low-Income 

Status of Populations near the NAPS Site, 2000 to 2006 

Jurisdiction 

Estimated 

Total 

Population 

2006 

Percent 

Minority 

2006 

Percent 

Minority 

2000 

Census 

Percent 

Growth in 

Population 

2000-2006 

Percent 

Growth in 

Minority 

Population 

2000-2006 

Percent 

Low 

Income 

2006 

Percent 

Low 

Income 

2000 

Census 

Caroline County 26,731 34.2% 38.1% 20.8% 8.3% NA 9.4% 

Hanover County 98,983 13.3% 12.3% 14.7% 23.6% 5.4% 3.6% 

Henrico County 284,399 36.6% 32.3% 8.4% 23.0% 8.2% 6.2% 

King William County 15,381 23.5% 26.7% 17.0% 3.1% NA 5.5% 

Louisa County 31,226 21.6% 23.9% 21.8% 10.4% NA 10.2% 

Orange County 31,740 16.8% 16.6% 22.6% 24.5% NA 9.2% 

City of Richmond 192,913 60.3% 62.2% -2.5% -5.5% 18.5% 21.4% 

Spotsylvania County 119,529 23.9% 18.8% 32.2% 68.4% 5.7% 4.7% 

Fredericksburg City 21,273 30.6% 28.9% 10.3% 17.0% NA 15.5% 

Virginia 7,642,884 31.3% 29.9% 8.0% 13.0% 10.0% 9.6% 

Sources: USCB 2000a,b; USCB 2006a,b. 

Although detailed geographical estimates of the changes in minority and low-income status of 

populations are not available in the geographic detail available in the 2000 Census and used in 

the ESP EIS to identify minority and low-income populations, Table 2-17 indicates that at the 

county level, despite significant population growth, the overall picture concerning minority and 

low-income populations has not changed dramatically. Based on the data available, all of the 

local jurisdictions shown in the table have grown faster than Virginia as a whole, with the 

exception of the City of Richmond, which continues to lose population. The Virginia minority 

population appears to have grown faster than the population as a whole, leaving Virginia with a 

larger percentage of minority individuals. The larger counties in the table (Hanover, Henrico, 

and Spotsylvania-Fredericksburg City) also appear to have followed this pattern, with slightly 

higher percentages of minorities, while Richmond and the smaller counties (Caroline, King 

William, and Louisa Counties) have slightly lower percentages. Orange County has remained 

approximately constant over the period. Virginia has a slightly greater percentage of lowincome people in 2006 than it did in 2000. Richmond seems to have a lower percentage of lowincome people, while the remaining larger counties have a greater percentage of low-income 

populations. No data are available for the smaller counties. The new information discussed 

above is not at the census block group level and is not sufficiently detailed to identify new 

minority and low-income populations. However, it does not appear from the data in Table 2-17 

that the percentage of minority populations or low-income populations have significantly 

changed in the counties where data are available. Therefore, the staff determined the new data 

would not change any conclusions in Sections 4.7 and 5.7, and therefore are not significant. 
Environment 

NUREG-1917, SEIS 2-52 February 2010 

2.10.2 Scoping and Outreach 

As part of the analysis in the ESP EIS (NRC 2006a) the staff conducted socio-economic 

interviews (NRC 2006c) with local officials including directors of social services and other 

contacts in the three counties surrounding the NAPS site (see Figures 2-4 and 2-5), and asked 

(1) whether the contact knew of any other areas containing minority and low-income populations 

that were not reflected in the map and (2) whether the contact knew of anyone who was 

practicing subsistence fishing or subsistence agriculture. No additional minority and low-income 

populations were identified and no subsistence activities were identified in this process. 

Figure 2-4. North Anna Census 2000 Environmental Justice Minority Populations 

(crosshatched areas) Within an 80-km (50-mi) Radius of the NAPS ESP Site 

(Dominion Nuclear North Anna, LLC 2006a) 
Environment 

February 2010 2-53 NUREG-1917, SEIS 

Figure 2-5. North Anna Census 2000 Environmental Justice Low Income Populations 

(crosshatched areas) Within an 80-km (50 mi) Radius of the NAPS ESP 

Site (Dominion Nuclear North Anna, LLC 2006a) 

Accordingly, none were mentioned in the letter report. Moreover, no additional populations, 

resource dependencies, or activities such as subsistence fishing and agriculture and no 

populations of special interest such as migrant farm workers were identified in the scoping 

meetings, two rounds of public meetings, and opportunities for public comment. During its 

review of Dominion’s information and independent evaluation for the Unit 3 SEIS, the staff did 

not become aware of new and significant information concerning environmental justice matters. 

The staff assumed that the census block groups identified in Figures 2-4 and 2-5 of the ESP EIS 

and repeated in this SEIS marked the locations of the relevant minority and low-income 

populations. 
Environment 

NUREG-1917, SEIS 2-54 February 2010 

Comments received in scoping for the Unit 3 COL SEIS suggested that downstream counties 

along the North Anna River might be affected by the construction and operation of Unit 3. The 

analysis has been expanded to include downstream minority and low-income populations, 

particularly those who may be engaged in subsistence fishing in the North Anna and Pamunkey 

Rivers downstream from Lake Anna. In its telephone contacts with the public officials and 

downstream counties and in the scoping process, the staff did not locate any subsistence 

fishing or agricultural activity with the exception of the Pamunkey Indian Tribe, who have a 

hatchery and a self-described subsistence fishery for shad on the Pamunkey River on their 

reservation near the town of King William, Virginia (Niemeyer 2009). Potential impacts of Unit 3 

operations on the shad fishery are considered in Sections 4.7 and 5.7. 

2.10.3 Health Preconditions and Special Circumstances of the Minority and LowIncome Populations 

The staff’s outreach and scoping activity identified special socioeconomic and heath 

circumstances and potential pathways for disproportionate health and environmental impacts, 

which are analyzed in Sections 4.8, 4.9, 5.8, and 5.9. The staff gathered data on mortality 

statistics and selected disease and health outcomes statistics of the total and minority 

populations in 1999 and 2005 for the Commonwealth of Virginia and the jurisdictions most likely 

to be affected by the construction and operation of the proposed Unit 3, all within the 80-km 

(50-mi) radius of the NAPS site. Data are shown in Table 2-18. Local death rate and chronic 

condition data are not available by income level. 

Table 2-18 shows that the death rates in the individual jurisdictions are volatile and do not follow 

any systematic relationship to time, ethnicity, or location. In general, the crude death-rate data 

depend on very small numbers, especially for infant deaths. Also, age-adjusted, death-rate data 

should be reported rather than crude death-rate data; however, adjustments could be made with 

the data available for the different population age structures statewide and those of the 

individual jurisdictions or for differences among ethnic groups. 

2.10.4 Migrant Populations 

The USCB defines a migrant worker as an individual employed in the agricultural industry in a 

seasonal or temporary nature and who is required to be absent overnight from their permanent 

place of residence. From an environmental justice perspective, there is a potential for such 

groups in some circumstances to be disproportionately affected by emissions in the 

environment. However, seasonal farm workers are rare in the counties surrounding the NAPS 

site. In addition, nothing is known about both the race and ethnicity of this population group or 

about how this picture may have changed since the 2002 Census of Agriculture.
February 2010 2-55 NUREG-1917, SEIS

Environment

Table 2-18. Selected Health and Mortality Statistics for Minority and White Population in Selected Jurisdictions near North Anna, 

and the Commonwealth of Virginia, 1999 and 2006 

Resident Infant Mortality 

per 1000 Live Births 

Crude Death Rate 

per 100,000 Residents 

Heart Attack Crude Death Rate 

per 100,000 Residents 

Cancer Crude Death Rate 

per 100,000 Residents 

Black Infant 

Death Rate, 

Number of 

Deaths 

Hispanic Infant 

Death Rate, 

Number of 

Deaths 

White Infant 

Death Rate, 

Number of 

Deaths 

Black Death 

Rate, Number 

of Deaths 

White Death 

Rate, Number 

of Deaths 

Black Death 

Rate, Number 

of Deaths 

White Death 

Rate, Number of 

Deaths 

Black Death 

Rate, Number 

of Deaths 

White Death 

Rate, Number 

of Deaths 

2005 Caroline No Deaths No Deaths No Deaths 861.0, 68 895.2, 155 177.3, 14 283.0, 189 253.2, 20 207.9, 36 Hanover 19.6, 2 No Deaths 3.3, 3 909.1, 88 738.1, 637 196.3, 19 185.4, 160 237.6, 23 185.4,160 Henrico 20.4, 24 3.5, 1 7.2, 18 541.5, 423 1021.4, 1911 101.1, 79 240.0, 449 139.5, 109 216.5, 405 

King William No Deaths No Deaths No Deaths 1053.3, 32 692.3, 79 296.2, 9 149.0, 17 197.5, 6 184.0, 21 Louisa 18.9, 1 No Deaths 6.1, 2 1298.9, 77 745.8, 178 303.6, 18 196.9, 47 320.5, 19 180.2, 43 Orange No Deaths No Deaths 6.0, 2 861.9, 35 1117.1, 90 147.7, 6 300.5, 78 246.2, 10 339.0, 38 City of Richmond 17.2, 30 9.7, 3 7.5, 9 1202.6, 1327 996.4, 794 261.0, 288 249.7, 149 251.0, 277 210.8,168 Spotsylvania 26.5, 5 No Deaths 6.8, 9 517.1, 90 535.9, 516 120.7, 21 129.8, 125 132.1, 23 122.5, 118 Fredericksburg City 20.6, 2 No Deaths 4.3, 1 977.1, 43 939.6, 149 181.8, 8 201.8, 32 340.8, 15 208.1, 33 Virginia 14.4, 319 5.2, 68 5.9, 427 762.3, 11753 7997.7, 44940 178.5, 2752 199.0, 11993 177.5, 2736 192.4, 10,821

1999 Caroline 31.6, 3 No Deaths 5.5, 1 922.6, 86 860, 114 236.0, 22 NA(a) 257.5, 24 NA Hanover 11.9, 1 No Deaths 3.0, 3 723.6, 74 740, 518 156.5, 16 NA 146.7, 15 NA 

Henrico 21.3, 22 10.5, 1 5.1, 12 728.0, 413 1010, 1821 218.6, 124 NA 167.4, 95 NA 

King William No Deaths No Deaths 13.8, 2 696.8, 31 700, 62 134.9, 6 NA 247.2, 11 NA 

Louisa No Deaths No Deaths 3.9, 1 810.0, 60 980, 171 256.5, 19 NA 121.5, 9 NA Orange No Deaths No Deaths No Deaths 587.8, 26 1200, 252 158.3, 7 NA 180.9, 8 NA 

City of Richmond 16.5, 32 No Deaths 6.3, 6 1139.2, 1269 1370, 1034 271.1, 302 NA 255.8, 285 NA Spotsylvania No Deaths No Deaths 4.1, 4 630.5, 70 680, 452 180.1, 20 NA 135.1, 15 NA Fredericksburg City 21.5, 2 No Deaths 7.6, 2 952.6, 44 1150, 172 151.5, 7 NA 216.5, 10 NA 

Virginia 12.9, 284 6.7, 37 5.6, 379 846.9, 11,726 820, 42,401 221.7, 3070 NA 198.5, 2479 NA Note: Except for infant deaths, Hispanic death rates were not available for either year at the individual jurisdiction level. White rates were not available by cause at the jurisdictional level for 1999. Sources: VDH 2002; VDH 2007. (a) Not available 
Environment 

NUREG-1917, SEIS 2-56 February 2010 

2.10.5 Environmental Justice Summary 

In the ESP EIS (NRC 2006a), the NRC staff found minority and low-income populations that 

exceeded the percentage criteria established for environmental justice analyses. Consequently, 

the staff performed additional analyses before making a final environmental justice 

determination. These analyses can be found in Section 4.7 of the ESP EIS (NRC 2006a) for 

construction effects, and in Section 5.7 for operational effects, as expanded by the commission 

order (CLI-07-27) (NRC 2007). The staff determined that there is new information available 

since the ESP EIS was prepared and the information reveals some changes to the numbers of 

the minority and low-income populations; however, these changes are not substantial and are 

not in conflict with the ESP EIS and the commission order (CLI-07-27). 

2.11 Related Federal Projects and Consultations 

Related Federal projects and consultations are reviewed in Section 2.11 of the ESP EIS (NRC 

2006a). The staff reviewed the possibility that activities of other Federal agencies might impact 

the issuance of a COL for proposed Unit 3. Any such activities could result in cumulative 

environmental impacts and the possible need for another Federal agency to become a 

cooperating or coordinating agency for preparation of this SEIS (10 CFR 51.10(b)(2)). 

The NRC and USACE revised their interagency agreement regarding environmental reviews for 

proposed nuclear plants as well as significant actions at existing plants in September 2008. 

Thus, USACE is a coordinating agency for this SEIS. Under the terms of the agreement, NRC 

is the lead NEPA agency for preparing the SEIS for NAPS Unit 3 and coordinating with USACE 

to address Clean Water Act permitting requirements. USACE will complete an independent 

permit decision regarding protection of U.S. waters and wetlands. 

The NRC is required under Section 102(2)(C) of NEPA to consult with and obtain the comments 

of any other Federal agency that has jurisdiction by law or special expertise with respect to any 

environmental impact involved in the subject matter of the SEIS. During the course of preparing 

the SEIS, NRC consulted and contacted various agencies. A list of the organizations contacted 

is included in Appendix B. 

2.12 References 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection Against Radiation.” 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 
Environment 

February 2010 2-57 NUREG-1917, SEIS 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 

“Designation of Areas for Air Quality Planning Purposes.” 

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

“Environmental Radiation Protection Standards for Nuclear Power Operations.” 

69 FR 52040. “Policy Statement on the Treatment of Environmental Justice Matters in NRC 

Regulatory and Licensing Actions.” Vol. 69, No. 163. August 24, 2004. 

70 FR 76165. “Approval and Promulgation of Air Quality Implementation Plans; Virginia; 

Redesignation of the City of Fredericksburg, Spotsylvania County, and Stafford County Ozone 

Nonattainment Area to Attainment and Approval of the Area's Maintenance Plan.” Vol. 70, 

No. 246. December 23, 2005. 

Audubon Society. 2008. 108th Christmas Bird Count. Lake Anna Virginia, United States. 

Accessed September 3, 2006 at http://cbc.audobon.org/cbccurrent/current_table.html. 

Accession No. ML083181274.

Bureau of Economic Analysis (BEA). 2000. Local Area Personal Income, Table CA25 – Total 

full-time and part-time employment by SIC industry. Accessed June 7, 2008 at 

http://www.bea.gov/regional/reis. Accession No. ML083181277. 

Bureau of Economic Analysis (BEA). 2006. Table CA-25N, Total full-time and part-time 

employment by NAICS industry. Bureau of Economic Analysis, U.S. Department of Commerce, 

Washington, D.C. Accessed July 17, 2008 at 

http://www.bea.gov/regional/reis/default.cfm?catable=CA25. Accession No. ML083260020. 

Caroline County Comprehensive Plan 2006-2026. 2008. Caroline County, Virginia, 2006-2026 

Comprehensive Plan, Section 6: Public Facilities. Amended March 11, 2008. Accessed 

June 9, 2008 at http://www.co.caroline.va.us/20062026compplan.html. Accession 

No. ML083181273. 

Caroline County Public Schools. 2008. Caroline County Public Schools. Accessed 

October 23, 2008 at 

http://www2.caroline.k12.va.us/education/components/sectionlist/sectionlist.php?sectiondetailid

=5. Accession No. ML083260038. 

County of Caroline. 2006. Bowling Green/Milford Area Plan 2005-2025. Appendix H. County 

of Caroline, Virginia. 
Environment 

NUREG-1917, SEIS 2-58 February 2010 

City-Data.com. 2008. City-Data.com. Accessed July 24, 2008, at 

http://www.citydata.com/county/Caroline_County-VA.html. Accession No. ML083181276. 

Clean Water Act. 33 USC 1251, et seq. (also referred to as the Federal Water Pollution Control 

Act [FWPCA].) 

Coastal Zone Management Act (CZMA) of 2006. 16 USC 1451 et seq. 

Council on Environmental Quality (CEQ). 1997. The 1997 Annual Report of the Council on 

Environmental Quality. Accessed at http://ceq.hss.doe.gov/nepa/reports/1997/index.html. 

Accession No. ML083230835. 

Dominion Electric Environmental Services Environmental Biology. 2004. North Anna River Low 

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3.0 Site Layout and Plant Description 

The site for the proposed Unit 3 reactor is located in Louisa County in rural south-central 

Virginia, within the current North Anna Power Station (NAPS) boundary. The site is situated 

approximately 64 km (40 mi) north-northwest of Richmond, Virginia. This chapter describes the 

approach Dominion Virginia Power and Old Dominion Electric Cooperative, collectively known 

as Dominion, used to identify the key site characteristics that the U.S. Nuclear Regulatory 

Commission (NRC) staff used to assess the environmental impacts of the proposed action. The 

site layout and existing facilities are discussed in Section 3.1. The plant design and power 

transmission system are discussed in Sections 3.2 and 3.3, respectively, and the list of 

references cited are in Section 3.4. 

3.1 External Appearance and Site Layout 

The NAPS site consists of two operating pressurized water reactors (Units 1 and 2), a shared 

turbine building, a switchyard, water intake and discharge structures, and support buildings. 

The site is located on the shores of Lake Anna. A radioactive waste disposal system, a fuelhandling system, the auxiliary structures, and other onsite facilities required for a complete 

nuclear power station are located on the NAPS site. The existing NAPS site development is 

shown in Figure 2-1. The operating licenses for Units 1 and 2 were renewed, and the units 

currently are authorized to operate through 2038 (Unit 1) and 2040 (Unit 2). In October 2009, 

the NRC approved a power uprate request for North Anna Unit 1 from 965 to 980 megawatts 

electric MW(e) and Unit 2 from 965 to 973 MW(e). The generating capacity for Units 1 and 2 

will increase by 1.6 percent. The NRC determined the increase in power could occur safely with 

the use of more accurate measurement of feedwater flow by using ultrasonic flow measurement 

instrumentation. Implementation of the power increase is projected to be July 2010 (NRC 

2009). The proposed Unit 3 would be located in a predominantly disturbed area in a westsouthwest direction adjacent to the existing Unit 2 (see Figure 2-1). 

Unit 3 will be the new Economic Simplified Boiling Water Reactor (ESBWR) design from 

GE-Hitachi Nuclear Energy; the ESBWR design has been submitted to the NRC for certification, 

and is undergoing review (GEH 2009). The facility will consist of the reactor and fuel building, 

the control building, a hot machine shop, a radwaste building, an electrical building, and a 

service building (Dominion 2009a). The proposed reactor would have a rated thermal power 

level of 4500 megawatts thermal (MW(t)) (Dominion 2009a). The NRC staff considered the 

current version of the ESBWR design and anticipated that the Unit 3 combined license (COL) 

application will be amended to reflect the current version of the ESBWR design. For the 

cooling system, Dominion has proposed a closed-cycle, combination wet and dry cooling tower 

system, with make-up water supplied from Lake Anna. Cooling system discharges from the 
Site Layout and Plant Description 

NUREG-1917, SEIS 3-2 February 2010 

proposed cooling tower blowdown will be sent to the existing NAPS Waste Heat Treatment 

Facility (WHTF) via the existing discharge canal. 

3.2 Plant Description 

The 4500-MW(t) ESBWR will use slightly enriched uranium fuel (i.e., 5 percent maximum 

concentration of uranium-235) with a maximum fuel burn-up rate of 62,000 MWd/MTU 

(Dominion 2009a). The proposed Unit 3 would operate at an estimated gross electrical power 

output of approximately 1605 MW(e) and estimated net electrical power output between 

approximately 1425 MW(e) and 1510 MW(e) (Dominion 2009a). 

The reactor will use water for cooling, natural circulation for normal operations, and passive 

safety features. Natural circulation relies on the principle that hot water is less dense and will 

rise convectively through the reactor core while more dense cool water will flow to the bottom of 

the core, thus creating water circulation within the core (GEH 2007). The natural circulation 

process eliminates the need for recirculation pumps and associated piping. Passive safety 

features include the isolation condensers and the gravity-driven cooling system. The isolation 

condensers take steam from the vessel or the containment, condense the steam, transfer the 

heat to a water pool, and introduce the cooled water back into the vessel (Hinds and Maslak 

2006). The gravity-driven cooling system consists of water pools above the reactor vessel 

that will re-flood the vessel when a very low water level is detected in the reactor (Hinds and 

Maslak 2006). 

GE-Hitachi Nuclear Energy submitted an application to the NRC for final design approval and 

standard design certification for the ESBWR on August 24, 2005 (GEH 2005). By letter dated 

December 1, 2005 (NRC 2005), the application was accepted by the NRC for docketing. 

Docket number 52-010 has been assigned to the ESBWR, but the design has not yet been 

certified by the NRC. The amendment for the current version of the ESBWR design was 

submitted in August 2009; the current revision is Revision 6 (GEH 2009). 

3.2.1 Plant Water Use 

The impacts of plant water use assessed in the early site permit environmental impact 

statement (ESP EIS) (NRC 2006) were based on the values of design parameters provided by 

Dominion in the ESP Environmental Report (ER) (Dominion Nuclear North Anna, LLC 2006). 

At the ESP stage, the staff’s review of the design parameters was limited to an evaluation of 

whether the parameter values were reasonable. This section describes the consumptive and 

nonconsumptive water uses of proposed Unit 3 and its associated water-treatment systems, 

based on information provided by Dominion in its ER (Dominion 2009a). The factual plantspecific information was evaluated relative to the design parameters considered in the ESP 

review. 
Site Layout and Plant Description 

February 2010 3-3 NUREG-1917, SEIS 

3.2.1.1 Plant Water Consumption 

This section describes plant water-consumption demands, excluding those demands that are 

part of the normal and ultimate heat sink cooling system. In Section 3.3 of the COL ER 

(Dominion 2009a), Dominion states that the water consumption associated with the two cooling 

system operating modes (energy conservation and maximum water conservation) for the 

proposed Unit 3 is unchanged from that reported in the ESP ER (Dominion Nuclear North Anna, 

LLC 2006) and evaluated in the ESP EIS (NRC 2006) for a single unit. Consumptive water 

demands associated with the Unit 3 cooling system are discussed in Section 3.4 of the ESP ER 

(Dominion Nuclear North Anna, LLC 2006). Noncooling-system-related demands for potable 

water, demineralized water, and fire-protection water are relatively small compared to the 

consumptive cooling demands of the proposed Unit 3. The normal and maximum water 

demands for these systems are 41.3 L/s (655 gpm) and 211 L/s (3340 gpm), respectively 

(Dominion Nuclear North Anna, LLC 2006). Potable and other domestic water would be 

provided from groundwater wells, whereas the demineralized water and fire protection water 

would be supplied from Lake Anna. 

3.2.1.2 Plant Water Treatment 

This section describes the water treatment systems for the proposed Unit 3. Because a 

specific design had not been selected at the ESP stage, water treatment systems were not 

specified in the ESP ER (Dominion Nuclear North Anna, LLC 2006) or ESP EIS (NRC 2006). In 

Section 3.3.2 of the COL ER, Dominion (2009a) provides factual information on water-treatment 

systems and chemical additives for various water sources and uses. Raw makeup water for the 

proposed Unit 3 cooling system and ultimate heat sink will be treated for biofouling, scaling, 

and suspended matter. Treatment is accomplished by injection of biocides (e.g., sodium 

hypochlorite, sodium bromide), anti-scalants, and dispersants at doses dependent on the flow 

rate and at appropriate points in the system. 

Treatment of makeup water for ultra-pure water systems, such as the condensate and primary 

cooling systems, would employ technologies such as reverse osmosis and ultra-filtration. Water 

not used for cooling (e.g., fire protection, demineralized water makeup) is treated with clarifying 

agents (e.g., coagulants, settling agents) prior to filtration. The water quality of effluents from 

any water treatment would be regulated by a Virginia Pollutant Discharge Elimination System 

(VPDES) permit for the proposed Unit 3. 

3.2.2 Cooling System 

The proposed Unit 3 would use a closed-cycle, combination wet and dry cooling tower system. 

Makeup water to the Unit 3 circulating water system and service water cooling system would be 

obtained from Lake Anna. Blowdown water (i.e., recirculating water removed from the cooling 
Site Layout and Plant Description 

NUREG-1917, SEIS 3-4 February 2010 

system to reduce the buildup of contaminants, such as dissolved solids) from the cooling 

systems would be discharged to the existing plant WHTF discharge canal. 

Based on the detailed plant system design, Dominion provided revised values for water use 

parameters for two cooling system operating modes (Dominion 2009a). These values were 

within the plant parameter envelope (PPE) values described in the COL ER (Dominion 2009a) 

and provided in Appendix I of the ESP EIS (NRC 2006). The plant would primarily use wet 

towers to cool Unit 3 during periods of relative water surplus, which are defined as periods when 

the water surface elevation of Lake Anna is at or above elevation 76.2 m (250.0 ft) above mean 

sea level (MSL). This cooling mode for the proposed Unit 3 is termed the Energy Conservation 

(EC) mode, and in this mode, the estimated makeup water flow rate is 1404 L/s (22,260 gpm) 

(Dominion 2009a). For its assessment of impacts on water supply, Dominion assumed that 

Unit 3 would be cooled with a closed-cycle, combination wet and dry cooling tower system to 

limit consumptive water use when the elevation of Lake Anna is below 76.2 m (250.0 ft) MSL for 

a period of seven or more consecutive days. Dominion terms this cooling mode the Maximum 

Water Conservation (MWC) mode; the estimated makeup water flow rate is 970.1 L/s 

(15,376 gpm) in MWC mode (Dominion 2009a). The recent Instream Flow Incremental 

Methodology (IFIM) study evaluated a scenario in which the normal pool level of Lake Anna was 

increased to 76.3 m (250.25 ft) (Dominion 2009c). This scenario would increase the frequency 

that the proposed Unit 3 would be in EC mode, resulting in a slightly higher water consumption 

rate than that considered in the ESP EIS. Under the existing pool elevation of 76.2 m (250.0 ft) 

MSL, the annual average Unit 3 evaporation rate would be 566.4 L/s (8977 gpm); if the pool 

elevation increases to 76.3 m (250.25 ft) MSL, the annual average Unit 3 evaporation rate 

would be 611.7 L/s (9695 gpm), or an approximately 8 percent increase. The conditions under 

which the proposed Unit 3 would switch from EC to MWC mode would be established by 

Virginia Department of Environmental Quality at the time of permitting.

3.2.2.1 Description and Operational Modes 

The operating modes for the proposed Unit 3 under normal operating and emergency shutdown 

conditions are described in detail in Section 3.2.2.1 of the ESP EIS (NRC 2006). 

3.2.2.2 Component Descriptions 

The following sections describe the intake, discharge, and heat-dissipation systems for the 

proposed Unit 3. Pursuant to Sections 316(a) and 316(b) of the Clean Water Act, Dominion is 

required to obtain approval from the Commonwealth of Virginia by documenting the plant design 

and conducting site-specific analyses regarding the impacts of the thermal discharges and 

operation of the intake systems on the Lake Anna aquatic environment. 
Site Layout and Plant Description 

February 2010 3-5 NUREG-1917, SEIS 

Intake System 

For the proposed Unit 3 intake system, water will be withdrawn from Lake Anna to supply 

circulating water, makeup water, fire-protection water, and demineralized water. The proposed 

location of the intake structure for Unit 3 is shown in Figure 2-1, and would be in approximately 

the same location as the intakes planned for the two additional power reactor units proposed at 

the time that NAPS Units 1 and 2 were licensed. The dimensions of the proposed intake 

structure to support operation of the proposed Unit 3 is 22 m (72 ft) long and approximately 

20 m (60 ft) wide, which are different than the dimensions described in the ESP ER (Dominion 

Nuclear North Anna, LLC 2006). Figures 3-1 and 3-2 show the plan view and side view, 

respectively, of the proposed arrangement of intake pumps and debris exclusion screens. The 

intake structure is designed to accommodate three makeup-water pumps, two station pumps, 

two screen-wash pumps, and two fire-water pumps. The maximum flow velocity into the trash 

racks (bar screens in Figure 3-1) at the intake structure opening is designed to be less than 

0.15 m/s (0.5 ft/s). Three sets of dual-flow traveling screens are located upstream of the three 

makeup water pumps; each traveling screen has a 2.4 m (8 ft)-wide basket and 2-mm (0.08-in.) 

mesh (Dominion 2008). The screen-wash pumps, station pumps, and fire-water pumps are 

located between the traveling screens and the main makeup water pumps. Dominion expects 

no major modifications to the shoreline or the existing intake channel. 

Since the ESP EIS was prepared, Dominion refined the conceptual design for the intake 

channel entrance. Instead of removing the existing cofferdam, it would be modified by 

installation of five box culverts approximately 3.05 m × 3.66 m (10 ft × 12 ft) (Figure 3-2) 

(Dominion 2008). The box culverts and intake channel are designed to keep flow velocities low 

to minimize entrainment of debris, aquatic life, and sediment. The flow velocity through the 

culverts is designed to be similar to the current velocity in Lake Anna, about 0.03 m/s (0.1 ft/s). 

During the final engineering phase, Dominion also may consider incorporating a fish return 

system into the intake system (Dominion 2009a). 

Discharge System 

Based on the detailed plant system design, Dominion provided revised values for water 

discharge parameters. These values were within the PPE values described in the COL ER 

(Dominion 2009a) and provided in Appendix I of the ESP EIS (NRC 2006). Blowdown 

discharge from the wet towers associated with the proposed Unit 3 would enter the WHTF via 

the discharge canal currently used by the existing Units 1 and 2. The proposed discharge 

structure would be located on the bank of the discharge canal adjacent to the discharge 

structure for the existing units. The maximum blowdown discharge from the proposed Unit 3 

would be 351 L/s (12.4 cfs or 5558 gpm), which is the discharge rate that was evaluated in the 

ESP EIS (NRC 2006). The discharge canal and WHTF canal system were designed to convey 

a flow of approximately 230,000 L/s (8000 cfs or 3,590,000 gpm), and the maximum flow rate 
NUREG-1917, SEIS 

3-6 February 2010 Figure 3-1. Plan View of NAPS Unit 3 Makeup Water Pump (Dominion 2008)

1< 12ft 

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screen I , 

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PLAN 

N.T.S. 
Site Layout and Plant Description 

February 2010 3-7 NUREG-1917, SEIS Figure 3-2. Side View of NAPS Unit 3 Makeup Water Pump Intake (Dominion 2008) 
Site Layout and Plant Description 

NUREG-1917, SEIS 3-8 February 2010 

from the existing units is approximately 120,000 L/s (4300 cfs or 1,930,000 gpm). Therefore, 

the existing discharge canal and WHTF system can easily accommodate the additional water 

discharged by the proposed Unit 3. 

Heat Dissipation Systems 

The condenser cooling and service water cooling systems reject heat to the atmosphere and 

to the WHTF. The condenser cooling needs of the proposed Unit 3 would be provided by a 

closed-cycle combination wet and dry tower system. The percentage of excess heat dissipated 

by the dry towers would depend in part on the availability of water from Lake Anna and ambient 

environmental conditions. If excess water were available (when Lake Anna pool elevation 

exceeds 76.2 m [250.0 ft] MSL), Unit 3 would be cooled entirely using the wet towers. When 

the lake level is low for a specified time, a minimum of one-third of the waste heat could be 

dissipated by the dry tower system. The percentage of waste heat dissipated by the dry tower 

system would increase with decreasing dry bulb temperature. The service water system cooling 

needs of the proposed Unit 3 would be provided by a closed-cycle wet tower system. 

3.2.3 Radioactive Waste Management System 

Liquid, gaseous, and solid radioactive waste management systems will be used to collect and 

treat the radioactive materials produced as byproducts from the operation of the proposed 

Unit 3. These systems will process radioactive liquid, gaseous, and solid effluents to maintain 

releases within regulatory limits and to levels as low as reasonably achievable before being 

released to the environment. 

Summary descriptions of the liquid, gaseous, and solid radioactive waste management systems 

for the ESBWR are presented in the following section. A more detailed description of these 

systems can be found in Chapter 11 of the ESBWR Design Control Document (GEH 2009). 

3.2.3.1 Liquid Radioactive Waste-Management System 

The liquid radioactive waste management system will be located in the radwaste building and 

will consist of the following subsystems: equipment drain, floor drain, chemical drain, and 

detergent drain. Wastes collected in tanks within the radwaste building will be processed on a 

batch basis. All liquid releases to the environment will be monitored and diluted as needed. 

These liquid releases will be discharged into the discharge canal that flows into the WHTF. 

The equipment drain subsystem is composed of three collection tanks and a mobile reverse 

osmosis filtration system. The floor drain subsystem collects liquids from floor drain sumps in 

the reactor, turbine, and radwaste buildings. This subsystem is composed of two collection 

tanks, a mobile reverse osmosis filtration system, and an ion-exchange system. The chemical 

drain subsystem consists of one tank that collects laboratory wastes and decontamination 
Site Layout and Plant Description 

February 2010 3-9 NUREG-1917, SEIS 

solutions. The detergent drain subsystem collects waste water from the controlled laundry and 

personnel decontamination facilities. This subsystem is composed of two collection tanks and a 

mobile processing system. The liquid radwaste system will be designed to use tank-collection 

basins and pipe chases to limit unmonitored releases to the environment. 

Filter media and ion-exchange resins will be used to concentrate radioactive materials during 

liquid radwaste processing. Sludge from the filters and ion exchange resins will be sent to the 

solid waste management system for additional processing. 

The liquid radioactive effluent source term for North Anna Unit 3 is presented in Section 5.9.1, 

Table 5.2 of this SEIS. The liquid radioactive effluent source term for the proposed Unit 3 is 

within the ESP PPE liquid radioactive effluent source term for the two original ESP units 

originally proposed; however, the source term was greater than the ESP PPE liquid effluent 

source term for a single ESP unit for several radionuclides. Dose calculation results presented 

in Section 5.9.2 show that the projected dose to the maximally exposed individual (MEI) is within 

the design objectives in Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix I. 

3.2.3.2 Gaseous Radioactive Waste-Management System 

Gaseous radioactive effluents are released through the building ventilation systems and the 

off-gas system. The off-gas system contains activated charcoal absorber beds that delay the 

release of noble gases, thus allowing for decay of radioactive material during the holdup period. 

Releases from the off-gas system are monitored for radioactivity prior to release to the 

environment from the plant stack or vent. The ESBWR will have ventilation stacks in the 

reactor/fuel building, the turbine building, and the radwaste building. 

The gaseous radiological effluent release source term for the proposed Unit 3 is within the 

ESP PPE gaseous effluent source term for the two ESP units; however, the source term 

was greater than the ESP PPE gaseous effluent source term for one ESP unit for several 

radionuclides. The ESBWR gaseous radioactive effluent source term for Unit 3 is presented in 

Section 5.9.1, Table 5.3 of this SEIS. The results of calculations presented in Section 5.9.2 

show that all the projected dose to the MEI would be within the design objectives in 10 CFR 

Part 50, Appendix I. 

3.2.3.3 Solid Radioactive Waste-Management System 

The solid radwaste management system for the proposed Unit 3 will process, package, and 

temporarily store solid radwaste prior to shipment. This system is located in the radwaste 

building and is composed of the following subsystems: wet solid waste collection, mobile wet 

solid waste processing, mobile concentrate treatment, dry solid waste accumulation and 

conditioning, and container storage. 
Site Layout and Plant Description 

NUREG-1917, SEIS 3-10 February 2010 

The wet solid waste collection system processes filter backwash sludge and ion-exchange bed 

resins from the liquid radwaste management system. The mobile wet solid waste processing 

subsystem consists of a dewatering station for high- and low-activity spent resins. Dry solid 

waste consists of air filters, paper and rags from contamination areas, contaminated clothing, 

contaminated tools, contaminated equipment parts, and solid laboratory wastes. The mobile 

processing systems are designed to be replaced as more efficient units are available. The 

radwaste building has storage space for at least 10 years of packaged Class B and Class C 

waste and approximately three months of packaged Class-A waste (Dominion 2009b). 

The estimated solid radwaste volume for an ESBWR is within the ESP PPE solid radwaste 

volume for the two ESP units; however, the volume was greater than the value identified in the 

ESP PPE per unit. The ESP EIS (NRC 2006) specified a value of 256 m3/yr (9041 ft3/yr) 

for each unit, while Table 3.0-2 of the COL ER (Dominion 2009a) shows a value of 474.7 m3/yr 

(16,764 ft3/yr) for the proposed Unit 3. The reason for this large difference in estimated 

radwaste volumes is the ESP estimate assumed compaction of the waste while the ESBWR 

estimate did not. Dominion (2009a) notes the number of shipments based on the waste volume 

of 474.7 m3/yr (16,764 ft3/yr) remains well below the one-truck-shipment-per-day condition given 

in 10 CFR 51.52, Table S–4. 

The estimated Unit 3 solid radwaste activity in the COL ER (Dominion 2009a) was less than 

the value for one unit used in the ESP EIS (NRC 2006). The ESP EIS specified a value of 

≤ 63.6 TBq/yr (2700 Ci/yr) per ESP unit, while the COL ER (Dominion 2009a) specified a value 

of 100 TBq/yr (1718 Ci/yr) for Unit 3. 

3.2.4 Nonradioactive Waste Management Systems 

The following sections provide descriptions of the nonradioactive waste systems for the 

proposed Unit 3, including systems for waste streams involving chemicals, biocides, sanitary 

wastes, and other effluents. Dominion (2009a) provided information on estimated 

concentrations of chemical effluents based on the ESBWR design. A separate sanitary waste 

system was identified for the proposed Unit 3. This is new information because the ESP 

application (Dominion Nuclear North Anna, LLC 2006) assumed the ESP units would share the 

sanitary waste system from Units 1 and 2. 

3.2.4.1 Effluents Containing Chemical and Biocides 

Chemicals and biocides will be employed in water treatment for various water systems at the 

proposed Unit 3 to include treatment of circulating water, service water, station water, and 

demineralized water. Effluent streams will also include pollutants (e.g., oil and grease, total 

suspended solids, and iron) from corrosion and wear of plant piping and equipment. Waste 

effluents from these systems will be regulated by the Virginia Pollutant Discharge Elimination 
Site Layout and Plant Description 

February 2010 3-11 NUREG-1917, SEIS 

System (VPDES) permit and will flow into the cooling tower blowdown sump. These effluents 

then will flow into the discharge canal where they will mix with circulating water from Units 1 and 

2 and finally be discharged into the WHTF. 

Maximum expected concentrations of free available chlorine, copper, sulfate, and total dissolved 

solids in the proposed Unit 3 cooling tower blowdown flow from the blowdown sump to the 

WHTF would be less than the PPE values identified in the ESP EIS (NRC 2006). While the 

expected iron concentration is slightly higher than the PPE value (2.4 mg/L [2.4 ppm] compared 

to the PPE value of 1 mg/L [1 ppm]); the Virginia Department of Environmental Quality has no 

water-quality standard for iron. Once mixed with the minimum liquid effluent discharge from 

Units 1 and 2, iron concentrations will be less than the 1 mg/L (1 ppm) PPE value. 

Unit 3 effluent streams will contain low levels of chemicals and/or biocides used for water 

treatment. Since preparation of the ESP EIS, Dominion identified in Section 3.3.2 of the COL 

ER (Dominion 2009a) likely water-treatment chemicals, their concentrations, and the points at 

which they will be injected during operation of the proposed Unit 3. None of the chemicals 

and/or biocides used for water treatment in the proposed Unit 3 will contain any of the 

126 priority pollutants listed in 40 CFR Part 423, Appendix A. However, the effluent streams 

from the proposed Unit 3 will include some of these priority pollutants because they are already 

present in the waters of Lake Anna. Two effluent streams (i.e., the service water and circulating 

water cooling tower blowdown) will concentrate pollutants, resulting in copper and tributyltin 

(TBT) concentrations in the discharge canal greater than Virginia Surface Water Quality Criteria. 

The copper is from past mining operations, and TBT was used in paint for marine applications. 

The impact of the copper and TBT concentration is discussed in Section 5.3. 

3.2.4.2 Sanitary System Effluents 

Since preparation of the ESP EIS, Dominion (2009a) has stated that a new sanitary waste 

treatment system would be built onsite for sanitary wastes generated during the construction 

and operation of the proposed Unit 3. The effluents of this system will comply with industry 

design standards, the Clean Water Act, the VPDES permit, and 9 VAC 25-790 (Sewage 

Collection and Treatment Regulations, Commonwealth of Virginia, State Water Control Board). 

Effluents will be monitored for contaminants, including radioactive materials, to verify 

compliance with regulatory standards. 

Sanitary water and waste from the potable water and sanitary waste system will be transferred 

to the sewage treatment plant. This plant will process the sanitary water and waste to meet 

local and State regulations for effluent quality as specified in the VPDES permit (Dominion 

2009a). Treated water from the sewage treatment plant will be routed to the cooling tower 

blowdown sump, which flows into the discharge canal and finally the WHTF. Sludge from the 

plant will be transported to a licensed sanitary waste landfill for disposal (Dominion 2009a). 
Site Layout and Plant Description 

NUREG-1917, SEIS 3-12 February 2010 

Until the new sanitary waste treatment system is built, portable sanitary facilities will be 

employed during Unit 3 construction, including a centralized restroom and hand-wash trailers 

(Dominion 2009a). Waste from these portable facilities will be removed and disposed of by a 

licensed sanitary waste disposal contractor (Dominion 2009a). 

3.2.4.3 Other Effluents 

Nonradioactive gaseous wastes (e.g., exhaust from diesel-powered backup generators) and 

nonradioactive solid wastes (e.g., construction debris) would be handled in compliance with 

appropriate State and Federal regulations. 

3.3 Power Transmission System 

The North Anna ESP EIS (NRC 2006) indicated that no additional power transmission 

infrastructure would be required to support the addition of two additional units at NAPS, but that 

would be determined as the result of a detailed system load studies that would be performed 

once the in-service date for the new units was established. The study has since been 

performed in support of the COL application for the proposed Unit 3. The study results indicate 

that a new 500-kV transmission line would be required, along with other system upgrades, to 

maintain grid reliability with the interconnection of the proposed Unit 3 into the existing 

transmission system (Dominion 2009a). Information regarding the additional infrastructure is 

provided below. 

An overhead conductor circuit would be required to connect the proposed Unit 3 to the existing 

500-kV switchyard at NAPS. The existing switchyard would be extended to the north for 

construction of additional 230-kV electrical bays. These bays would connect with the existing 

transmission system through the existing switchyard. 

Interconnection of the proposed Unit 3 will require several system upgrades that were identified 

in the system load studies (Dominion 2009a). The upgrades include: 

• replacement of existing 500-kV circuit breakers and associated high-voltage equipment with 

breakers with higher current and/or short circuit rating 

• addition of a 500-kV bay to support the North Anna to Ladysmith transmission line 

• addition of a 230-kV bay parallel to the existing 230-kV bay on the north side of the 

switchyard to support the reserve auxiliary transformer feed to Unit 3. 

Other modifications would be made to the east side of the existing 500-kV substation, including 

relocation of workshops and auxiliary buildings to make room for a new 500/230 kV intermediate 

switchyard. This new switchyard would provide the ability to step down the normal preferred 

power source from 500 kV to 230 kV. 
Site Layout and Plant Description 

February 2010 3-13 NUREG-1917, SEIS 

A new or expanded control house for the switchyard would house new control and relay 

protection equipment. Some of the existing service systems would be expanded or modified, 

including grounding, raceway, lighting, AC/DC station service, and lighting protection. 

The new 500-kV transmission line would be constructed from the NAPS substation to the 

Ladysmith switching substation located east of the NAPS site. The line is required to maintain 

grid reliability associated with the interconnection of the proposed Unit 3. The new transmission 

line would be installed in the existing NAPS-to-Ladysmith Substation right-of-way on new 

transmission towers located in proximity to the existing towers. The NAPS-to-Ladysmith 

Substation right-of-way is 84 m (275 ft) wide and 24 km (15 mi) long (NRC 2006). 

Current National Electrical Safety Code (NESC) and transmission line standards will be followed 

in terms of tower separation, line installation, and clearance to ground. The same transmission 

line standards will be followed in terms of tower structural design parameters, number of 

conductors, height, materials, color, and finish. Marking for aircraft visibility will be consistent 

with the existing towers in the right-of-way. The new towers will be approximately 3.05 m (10 ft) 

taller than the existing towers in the right-of-way. The current NESC code requirements 

regarding electric-field-induced current at the ground level (NESC 2007) will be met. 

The noise levels resulting from the new transmission line operations will be consistent with the 

existing transmission lines and in accordance with industry standards (IEEE 1992). The actual 

decibel noise level will be minimized by proper sizing of conductors and use of corona-free 

hardware (Dominion 2009a). 

3.4 References 

9 VAC 25-790. 2004. “Sewage Collection & Treatment Regulations.” Virginia Administrative 

Code, Richmond, Virginia. 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

40 CFR Part 423. Code of Federal Regulations, Title 40, Protection of the Environment, 

Part 423, “Steam Electric Power Generating Point Source Category.” 

Clean Water Act. 33 USC 1251, et seq. (also referred to as the Federal Water Pollution Control 

Act.) 
Site Layout and Plant Description 

NUREG-1917, SEIS 3-14 February 2010 

Dominion Nuclear North Anna, LLC (Dominion). 2006. North Anna Early Site Permit 

Application, Revision 9. Accession No. ML062580096. 

Dominion Virginia Power (Dominion). 2008. Letter dated from Eugene S. Grecheck (Dominion 

Virginia Power, Vice President) to the U.S. Nuclear Regulatory Commission, “Dominion Virginia 

Power, North Anna Unit 3 Combined License Application, Response to Request for Additional 

Information Regarding the Environmental Review,” July 17, 2008. Accession 

No. ML082620236. 

Dominion Virginia Power (Dominion). 2009a. North Anna 3 Combined License Application, 

Part 3: Applicant’s Environmental Report – Combined License Stage, Revision 2, July 2009. 

Accession No. ML092160490. 

Dominion Virginia Power (Dominion). 2009b. North Anna 3 Combined License Application, 

Part 2: Final Safety Analysis Report. Revision 2, May 2009. Accession No. ML091540602. 

Dominion Virginia Power (Dominion). 2009c. Letter from Pamela F. Faggert (Dominion 

Resources Services, Vice President) to Michael P. Murphy, Director, Virginia Department of 

Environmental Quality, Division of Environmental Enhancement, “Final Report: In Stream Flow 

Incremental Methodology (IFIM) study North Anna Power Station – Unit 3.” October 29, 2009. 

Accession No. ML093210500. 

GE-Hitachi Nuclear Energy (GEH). 2005. Letter dated from Steven A. Hucik (General 

Manager, Nuclear Plant Projects) to the U.S. Nuclear Regulatory Commission, “General Electric 

Company Application for Final Design Approval and Design Certification of ESBWR Standard 

Plant Design,” August 24, 2005. Accession No. ML052450241. 

GE-Hitachi Nuclear Energy (GEH). 2007. Fact Sheet – Natural Circulation in ESBWR. 

GEA-14842A (11/07). Accessed July 26, 2008 at 

http://www.gepower.com/prod_serv/products/nuclear_energy/en/downloads/natural_circulation_

esbwr.pdf Accession No. ML083250358. 

 GE-Hitachi Nuclear Energy (GEH). 2009. ESBWR Standard Plant Design Certification 

Application Design Control Document, Revision 6, Tier 1 and Tier 2. August 31, 2009. 

Accession No. ML092680561. 

Hinds D. and C. Maslak. 2006. “Next-Generation Nuclear Energy: The ESBWR.” Nuclear 

News. 49(1):35-40. Accessed October 16, 2008, at 

http://www.ans.org/pubs/magazines/nn/docs/2006-1-3.pdf. Accession No. ML083250548. 
Site Layout and Plant Description 

February 2010 3-15 NUREG-1917, SEIS 

Institute of Electrical and Electronic Engineers (IEEE). 1992. IEEE Standard for the 

Measurement of Audible Noise from Overhead Transmission Lines. Std 656-1992. Accessed 

at ieeexplore.ieee.org/iel1/2867/5503/00211074.pdf.

National Electrical Safety Code (NESC). 2007. Section 21, Rule 232.C.1.c. Institute of 

Electrical and Electronics Engineers (IEEE), Piscataway, New Jersey. 

U.S. Nuclear Regulatory Commission (NRC). 2005. Letter dated to Steven A. Hucik (General 

Manager, Nuclear Plant Projects), “Acceptance of the General Electric Company Application for 

Final Design Approval and Standard Design Certification for the Economic Simplified Boiling 

Water Reactor (ESBWR) Design,” December 5, 2005. Accession No. ML053200309. 

U.S. Nuclear Regulatory Commission (NRC). 2006. Environmental Impact Statement for an 

Early Site Permit (ESP) at the North Anna ESP Site. Final Report, NUREG-1811, 

Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2009. Letter from V. Sreenivas (NRC) to David 

Heacock, Vice President and Chief Nuclear Officer, Virginia Electric and Power Company, 

“North Anna Power Station, Unit Nos. 1 and 2, Issuance of Amendments Regarding 

Measurement Uncertainty Recapture Power Uprate (TAC Nos. ME0965 and ME0966).” 

October 22, 2009. Accession No. ML092250616. 

February 2010 4-1 NUREG-1917, SEIS 

4.0 Environmental Impacts of Construction 

This chapter examines the environmental issues associated with site preparation and 

construction activities of the proposed Unit 3 at the North Anna Power Station (NAPS) as 

described in the application for a combined license (COL) submitted by Dominion Virginia 

Power (DVP) and the Old Dominion Electric Cooperative (ODEC), collectively known as 

Dominion. A COL encompasses a construction permit and an operating license. As part of its 

COL application, Dominion submitted an environmental report (ER) (Dominion 2009a). The 

COL ER provides information used as the basis for the environmental review. The application 

references the early site permit (ESP) that was issued by the U.S. Nuclear Regulatory 

Commission (NRC) in November 2007 (NRC 2007). That permit is for approval of two 

additional nuclear units to be constructed within the boundaries of the NAPS. The basis for 

issuing that ESP was an environmental impact statement (EIS) that was prepared by the NRC 

staff in 2006 (NRC 2006). 

In Sections 4.1 through 4.10 of this chapter, the NRC staff evaluates new and significant 

information regarding the potential impacts on land use; meteorology and air quality; water use 

and quality; terrestrial and aquatic ecosystems; socioeconomics; historic and cultural resources; 

environmental justice; nonradiological and radiological health effects; and applicable measures 

and controls that would limit the adverse impacts of construction of the proposed Unit 3. In 

accordance with Title 10 of the Code of Federal Regulations (CFR) Part 51, impacts have been 

previously analyzed as part of the ESP application (Dominion Nuclear North Anna, LLC 2006), 

and significance levels (i.e., SMALL, MODERATE, or LARGE) of potential adverse impacts 

were assigned to each analysis. In the socioeconomic area where the impacts of taxes are 

assessed, some of the impacts were considered beneficial and are stated as such. Possible 

mitigation of adverse impacts, where appropriate, is presented in Section 4.10. A summary of 

the construction impacts is presented in Section 4.11. Full citations for the references cited in 

this chapter are listed in Section 4.12. Cumulative impacts of construction and operation are 

discussed in Chapter 7. The technical analyses provided in this chapter support the results, 

conclusions, and recommendations presented in Chapter 10. 

In the course of its evaluation, the NRC staff (1) met with Dominion staff, its contractors, and 

State and local officials; (2) conducted an independent evaluation of subject areas not covered 

in the ESP EIS, unresolved issues, and new and significant information; and (3) reviewed 

Dominion’s implementation of its process for identifying new and significant information, which 

the staff determined was adequate. While developing this supplemental EIS (SEIS), the staff 

also reviewed public comments it received and contacted Federal, State, Tribal, regional, and 

local agencies to solicit comments. Documents related to the NAPS site were reviewed and are 

listed as references where appropriate. All of the information collected through these processes 

was used in developing this SEIS. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-2 February 2010 

The staff also relied on the mitigation measures and the required Federal, State, and local 

permits and authorizations presented in the ER in reaching its conclusion on the significance 

level of the adverse impacts. Because the NAPS site has an approved ESP, the significance 

levels of the potential adverse impacts for the various areas evaluated remain the same as 

documented in the ESP EIS (NRC 2006) unless new and significant information has been 

identified that would have the potential to affect the findings or conclusions reached in the 

ESP EIS. The definition of new and significant information is documented in a Federal Register

notice (72 FR 49352). The staff relied on the infrastructure upgrades planned by the counties, 

cities, and towns, such as road and school expansions, in determining its original findings and 

conclusions. Failure to implement such infrastructure upgrades may result in greater impacts. 

4.1 Land-Use Impacts 

This section provides information on land-use impacts associated with construction of the 

proposed Unit 3 at the NAPS site, in the vicinity of the site, and in any transmission line rightsof-way that might be affected. 

4.1.1 The Site and Vicinity 

The proposed Unit 3 will be located southwest of the existing Units 1 and 2 and entirely within 

the existing NAPS site. There are no zoning regulations currently applicable to the site. 

Section 4.1.1 of the ESP EIS (NRC 2006) stated that all construction activities for the proposed 

Units 3 and 4, including ground-disturbing activities, would occur within the existing NAPS site 

boundary. In the ESP EIS, the staff concluded that the land-use impacts of construction would 

be SMALL, and additional mitigation was not warranted. 

The ER that Dominion submitted as part of its COL application states that some offsite land-use 

impacts could occur (Dominion 2009a). These impacts could occur in conjunction with road 

improvements (e.g., repairs, widening, and/or filling in low areas) needed for transportation of 

large components from either West Point or Walkerton, Virginia (Dominion 2009a). Any such 

impacts are likely to benefit the roads. New information in Revision 2 of the ER states that 

Dominion would use an approximately 38.8 ha (96 ac) tract of land northwest of and contiguous 

with the NAPS site for certain construction-related activities such as laydown areas, spoils 

storage, a concrete batch plant, and access roads (Dominion 2009a). The tract of land is 

owned by Dominion. The addition of this small tract of land, which was disturbed prior to 

acquisition by Dominion, would have a relatively minor impact and does not affect the findings 

or conclusions of the staff. Other new information identified by the NRC staff relating to 

construction land-use impacts is that with this request, Dominion proposes to construct and 

operate one new nuclear unit (Unit 3) instead of the two units (Units 3 and 4) considered in the 

ESP EIS (NRC 2006), a change that would reduce land-use impacts. The staff determined that 
Environmental Impacts of Construction 

February 2010 4-3 NUREG-1917, SEIS 

the changes in the information related to land use are minor and have no potential to change 

the staff’s impact characterization in the ESP EIS. 

The staff did not identify information that was both new and significant related to the 

construction impacts on land use through its evaluation of the information provided by Dominion 

and the NRC staff’s own independent review. The staff concludes that the land-use impacts of 

construction would be SMALL, and additional mitigation is not warranted. 

4.1.2 Offsite Transmission Line Rights-of-Way 

Section 4.1.2 of the ESP EIS (NRC 2006) states that no additional transmission lines or rightsof-way would be needed to transmit the power generated by new generating units at the NAPS 

site. The only new information identified by the staff related to Section 4.1.2 is that Dominion’s 

COL ER (Dominion 2009a) states that a new 500-kV transmission line from the North Anna 

substation to the Ladysmith switching substation would be needed to provide grid stability with 

the interconnection of proposed Unit 3 (Dominion 2009a). The new transmission line would be 

installed on new towers in the existing NAPS to Ladysmith Substation right-of-way, which runs 

to the east from the NAPS site. The existing right-of-way is approximately 84 m (275 ft) wide 

and 24 km (15 mi) long. Because the new transmission line would be built entirely within the 

existing right-of-way, with no widening required, the staff concludes that the changes in the 

information related to land use are minor and have no potential to change the staff’s impact 

characterization in the ESP EIS. 

The staff did not identify information that was both new and significant related to the 

transmission line construction impacts on land use through its evaluation of the information 

provided by Dominion and the NRC staff’s own independent review. The staff concludes that 

the land-use impacts of construction in the offsite transmission line right-of-way would be 

SMALL, and additional mitigation is not warranted. 

4.2 Meteorological and Air-Quality Impacts 

In its ESP EIS (NRC 2006), NRC noted that during construction activities on the NAPS ESP 

site, some minor air-quality impacts would be expected. The likely sources of these air-quality 

impacts would be fugitive dust emissions from general construction activities and the potential 

for elevated ambient air-quality levels caused by transportation emissions from the vehicles and 

equipment used by the workforce during construction. 

In Appendix J of its ESP EIS (NRC 2006), the NRC notes that the 5000 workers needed to 

construct Units 3 and 4 would be divided into two 10-hour shifts. Using an assumption of 

1.8 workers per commuter vehicle, 2800 additional vehicles per day would travel to and from the 

NAPS site while construction activities are ongoing. It was noted previously that the overall 

impact on air quality levels was difficult to estimate because of the timing of construction 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-4 February 2010 

activities and actual location of the workers that would be employed during construction. The 

ESP EIS (NRC 2006) also says that Dominion would develop methods for enhancing the use of 

multi-passenger vans to reduce the number of vehicles on the road at any given time. This 

issue was discussed during the site audit in April 2008, and Dominion stated that it still 

anticipates developing a plan prior to the start of construction. 

Because the COL application is for a single unit instead of the two units addressed in the 

ESP EIS (NRC 2006), it is anticipated that fewer construction workers would be required at any 

one time. Thus, the potential air-quality impacts would be less than originally estimated for the 

ESP application. Given the continued commitment by Dominion to develop a traffic 

management plan and current air-quality conditions within the region, the initial conclusion 

reached in the ESP EIS (NRC 2006), SMALL, remain the same and additional mitigation 

beyond the currently planned actions is not warranted. 

4.3 Water-Related Impacts 

This section describes the potential water-related impacts associated with construction of the 

proposed Unit 3 at the NAPS site. An overview of two proposed new units (Units 3 and 4) and a 

detailed discussion of construction-related impacts on water use and water quality are provided 

in Section 4.3 of the ESP EIS (NRC 2006). Dominion’s COL application (Dominion 2008d) is for 

construction of only one unit (Unit 3), using the Economic Simplified Boiling-Water Reactor 

(ESBWR) design with a closed-loop hybrid cooling system that employs wet and dry cooling 

depending on operating conditions (see description in Chapter 3 of this SEIS). In the following 

sections, the NRC staff summarizes the impacts described in the ESP EIS (NRC 2006), 

evaluates new information available for review since preparation of the ESP EIS, and 

determines whether there are any changes to the impact levels determined at the ESP stage for 

an additional unit at the NAPS site. 

Before obtaining a COL from the NRC, Dominion must obtain a Clean Water Act Section 401 

Certification. This certification would be issued by the Commonwealth of Virginia and would 

ensure that the project does not conflict with water quality management programs in the 

Commonwealth. Upon receipt of the permit, Dominion would notify the NRC. 

4.3.1 Hydrological Alterations 

The information and associated impacts for this section are provided and resolved in 

Section 4.3.1 of the ESP EIS (NRC 2006). Based on the staff’s analysis, construction-related 

impacts of hydrological alterations were considered to be SMALL. Information available since 

preparation of the ESP EIS includes changes to onsite drainage, changes to the cofferdam and 

the design of the intake structure, and a proposed new transmission line. 
Environmental Impacts of Construction 

February 2010 4-5 NUREG-1917, SEIS 

Excavation, fill, and grading operations that will occur during construction of the proposed Unit 3 

would alter two of three ephemeral streams on the NAPS site, and possibly one or more 

wetlands. The COL ER (Dominion 2009a) provided new information on the specific locations of 

the plant buildings, including the sanitary treatment plant for Unit 3, within the NAPS ESP site 

and indicated that the expected impacts to two ephemeral streams will occur in slightly different 

locations than were evaluated in the ESP EIS (Streams B and C instead of Streams A and B, 

Figure 2.4-5 of ESP ER [Dominion Nuclear North Anna, LLC 2006]). As described in 

Section 2.7.1, Dominion acquired 38.8 ha (96 ac) of adjoining property along the southwest 

boundary of the NAPS site. This property would be used for temporary construction support 

such as access roads, laydown areas, spoils storage, and a concrete batch plant. There are 

approximately 1130 linear m (3700 linear ft) of intermittent or perennial streams on this property, 

a portion of which may be affected by construction activities. The COL ER (Dominion 2009a) 

also stated that a new transmission line would be installed in the existing NAPS to Ladysmith 

transmission line right-of-way, but on new towers located close to the existing towers (see 

Figure 2.2). The existing right-of-way crosses several wetlands. 

These impacts to onsite drainage and the transmission line right-of-way would be localized 

temporary construction impacts. Wetland delineations and jurisdictional determinations of the 

upland landscape and submerged lake areas that would be affected by construction would be 

required in order to submit an application for a Section 404 Permit application to the U.S. Army 

Corps of Engineers (USACE). This permit regulates discharge of dredge or fill material into 

waters of the United States. The USACE permitting process ensures that impacts of 

construction are limited by requiring the appropriate construction best management practices 

(BMP). The applicant proposes a combination of avoiding wetlands and shorelines where 

practicable, and employing BMPs (e.g., hand clearing trees and brush and limiting disturbance 

of soil within 30 m [100 ft] of stream or ditch, removing materials placed in streams for 

temporary crossings, controlling erosion). These measures limit hydrological alterations and the 

impacts of construction on streams and wetlands. Dominion currently has not obtained a 

Section 401 certification from the Commonwealth of Virginia for construction activities at the 

NAPS site. 

The COL ER states that new water supply wells will be installed on the adjoining property 

acquired by Dominion to support batch plant operations and construction cleanup (Dominion 

2009a). Pumping groundwater from these new wells will depress the water table in the vicinity 

of the wells. However, any drawdown in the water table would be limited by the proximity of 

Lake Anna and the discharge canal. Construction impacts from this additional groundwater 

pumping would be localized and temporary. 

The ESP EIS evaluated a 21-m (70-ft)-long and 21-m (70-ft)-wide intake structure to support the 

combination wet and dry cooling tower for Unit 3 (NRC 2006). In response to a NRC request 

following receipt of the COL application, Dominion provided information on refinements to the 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-6 February 2010 

design of the cooling system intake structure. The proposed new intake structure is slightly 

longer (i.e., 21.9 m [72 ft] long) and narrower (i.e., approximately 18 m [60 ft] wide) to 

accommodate three pumps with debris exclusion equipment (Dominion 2009a). The structure 

location remains the same as that proposed in the ESP, in a cove crossed by a cofferdam just 

west of the intake for the existing Units 1 and 2 (Figure 2-1). 

Dominion (2008a) has proposed to allow water access from Lake Anna to the Unit 3 intake 

channel by installing five 3 × 3.7 m (10 × 12 ft) box culverts through the existing cofferdam. 

Dominion expects no major modifications to the shoreline or the existing intake channel. The 

box culverts and bottom elevation of the channel of approximately 67 m (220 ft) relative to mean 

sea level are designed to keep flow velocities low to minimize entrainment of debris, aquatic life, 

and sediment (Dominion 2009a). The COL design intake flow velocities at the culverts, in the 

intake channel, and at the intake pumps are within the plant parameter envelope values 

evaluated during the ESP environmental review. Implementing BMPs for dredging would 

minimize the potential for sediment to enter the lake during modification of the cofferdam. Any 

impacts of dredging would be localized and temporary. Before initiation of any shoreline 

modification or dredging activities, Dominion would be required to obtain a Section 404 Permit 

from the USACE. 

The staff did not identify information that was both new and significant related to construction 

impacts resulting from hydrological alterations in its evaluation of new information provided by 

Dominion and the staff’s independent review. The staff concludes that impacts of hydrological 

alterations from construction of the proposed Unit 3 at the NAPS site would remain SMALL, and 

further mitigation beyond the actions stated is not warranted. 

4.3.2 Water-Use Impacts 

The information and associated impacts for this section are provided and resolved in 

Section 4.3.2 of the ESP EIS (NRC 2006). The staff did not identify information that was both 

new and significant related to water use during construction in its evaluation of new information 

provided by Dominion and the staff’s independent review. The staff concludes that impacts on 

water use from construction of the proposed Unit 3 at the NAPS site would remain SMALL, and 

further mitigation is not warranted. 

4.3.3 Water-Quality Impacts 

The information and associated impacts for this section are provided and resolved in 

Section 4.3.3 of the ESP EIS (NRC 2006). Based on the staff’s analysis, construction-related 

impacts on water quality were considered to be SMALL. New information available since 

preparation of the ESP EIS includes the construction of one new unit instead of two new units, 

and specific information on the location of the new unit. Water-quality impacts for the 

construction activities would be similar to those associated with other large industrial 
Environmental Impacts of Construction 

February 2010 4-7 NUREG-1917, SEIS 

construction projects: that is, the impacts would be generally localized and temporary in nature. 

The impacts of construction on water quality are anticipated to be similar to or less than those 

described in the ESP EIS. 

The NRC staff did not identify information that was both new and significant related to waterquality impacts of construction through its evaluation of information provided by Dominion and 

its independent review. The staff concludes that water quality impacts resulting from 

construction of the proposed Unit 3 at the NAPS site would remain SMALL, and further 

mitigation is not warranted. 

4.4 Ecological Impacts 

This section describes the potential impacts of construction of the proposed Unit 3 on the 

ecological resources at the NAPS COL site and discusses terrestrial and aquatic ecosystems 

impacts, and threatened and endangered species. 

4.4.1 Terrestrial Ecosystem Impacts 

The information and associated impacts for this section are provided and resolved in 

Section 4.4.1 of the ESP EIS (NRC 2006). Based on the staff’s analysis, construction-related 

impacts to terrestrial ecosystems were considered to be SMALL. Information available since 

preparation of the ESP EIS includes a detailed description of the site layout for the proposed 

Unit 3, and the proposed NAPS to Ladysmith switching substation transmission line. 

Much of the proposed construction site for the proposed Unit 3 consists of dirt roads, cleared 

areas, parking lots, buildings, and other areas recovering from prior disturbances. Because of 

past development or use, undisturbed habitats are absent in this area. The current site layout 

indicates that the approximately 49 ha (120 ac) will be permanently altered by the construction 

of permanent facilities, and approximately 36 ha (90 ac) will be disturbed for temporary 

construction facilities (Dominion 2008a). The areas not permanently disturbed would be 

available for other uses after construction is complete. 

In the ESP EIS (NRC 2006), the NRC reported that approximately 32 ha (80 ac) of forested 

habitat would be lost because of construction of the Units 3 and 4. The current plant design and 

layout for Unit 3 indicate that approximately 50.6 ha (125 ac) of forested habitat would be lost 

(Dominion 2008a). All of this habitat is relatively recent regrowth and contains no unique or 

sensitive plant species or communities. No important animal species are likely to occur within 

the area, and it represents a very small percentage of the similar habitat in the site vicinity. 

Although the total amount of forested habitat affected by construction is likely to be somewhat 

greater than reported in the ESP EIS, the NRC staff has determined that this information does 

not change the staff’s conclusion that impacts to forested habitats would be SMALL. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-8 February 2010 

Since the ESP EIS was issued, Dominion has acquired 38.8 ha (96 ac) of adjoining property 

that will be used for temporary construction support. As described in Section 2.7, nearly all of 

the timber on the additional property was harvested prior to acquisition by Dominion; thus, use 

of the property for construction support will not result in any additional loss of forest habitat. 

The ESP EIS also indicated that approximately 2.70 ha (6.68 ac) of wetlands, 1680 linear m 

(5500 linear ft) of streams covering an area of approximately 0.19 ha (0.46 ac), and 

approximately 1.0 ha (2.49 ac) of open water were within the proposed construction footprint 

(NRC 2006). According to the current site layout, the expected impact will be less (Dominion 

2008a). The layout will include 15 m (50 ft) buffers around many of the wetland areas, thus 

avoiding impacts. Permanent disturbance may be limited to less than 0.2 ha (0.5 ac) of nontidal 

wetland, and less than 240 linear m (800 linear ft) of stream within the COL site footprint 

(Dominion 2008a). Although not directly related to Unit 3 construction, the need to relocate 

several facilities associated with Units 1 and 2 may result in the additional loss of less than 

0.4 ha (1 ac) of wetlands (Dominion 2009a). An additional 1.3 ha (3.1 ac) of wetlands will be 

lost within the temporary construction support areas of the newly acquired 38.8 ha (96 ac) 

property. Small wetland areas along the proposed heavy haul route from the barge unloading 

site to NAPS may also be affected. 

Dominion has indicated that it would avoid watercourses and wetlands to the extent practicable 

during construction, and that it would be required to comply with any wetland protection or 

mitigation measures attached to any permits issued by USACE or the Virginia Department of 

Environmental Quality (VDEQ). Dominion has been considering, in conjunction with the Virginia 

Department of Game and Inland Fisheries (VDGIF) and the USACE, mitigation that may be 

appropriate for the impacts that do occur to wetlands and stream losses on the site. Mitigative 

actions have not been determined but might include the purchase of wetland or stream credits 

from an approved mitigation bank, supplemented by stream preservation through the 

establishment of conservation easements either onsite or on other Dominion-owned lands. 

Because the impacts are bounded by the impacts considered in the ESP EIS, and because 

Dominion will be working with State and Federal agencies to mitigate for the impacts that do 

occur, the staff’s conclusion that impacts to on-site wetlands are SMALL has not changed. 

The new transmission line will be constructed in the existing North Anna to Ladysmith right-ofway. No additional clearing of forested vegetation will be required for construction of this 

transmission line, and existing access roads would be used for inspection and maintenance 

activities in the right-of-way. Where possible, Dominion expects to place towers adjacent to 

existing towers, and will avoid placement of towers in wetlands or other sensitive habitats. 

Dominion expects that of the 72 potential tower locations, two may be within or adjacent to 

wetland areas (Dominion 2009a). Land clearing would be limited to that necessary to 

accommodate the new tower foundations, and Dominion would follow established procedures 

and BMPs to minimize impacts and to restore vegetative communities. Only hand-clearing 
Environmental Impacts of Construction 

February 2010 4-9 NUREG-1917, SEIS 

would be used within 30 m (100 ft) of streams or creeks and BMPS for erosion and 

sedimentation control would be followed. If Dominion follows the procedures that are described 

in its COL ER (Dominion 2009a), minimal construction impacts are anticipated. 

In the COL ER (Dominion 2009a), Dominion represented that it would implement construction 

mitigation measures. These measures would include instituting construction BMPs for erosion 

and dust control, noise abatement, and proper equipment maintenance; restricting the timing of 

activities to minimize impacts to resources such as breeding birds; and adhering to applicable 

permit conditions (see ESP EIS Appendix J). Dominion delineated the wetlands and streams on 

the proposed construction site for Unit 3, has designed the current layout to minimize impacts to 

wetlands and streams, and would adhere to any permit conditions or mitigation requirements 

developed by the USACE or the VDEQ. The staff reviewed the potential impacts of constructing 

the proposed Unit 3 on terrestrial ecological resources, including loss of habitat, loss of 

wetlands, noise, dust emissions, and avian collisions. The staff did not identify information that 

was both new and significant related to the construction impacts on terrestrial resources through 

its evaluation of information provided by Dominion and the NRC staff’s independent review. 

The staff concludes that the impact to terrestrial resources would be SMALL, and additional 

mitigation beyond that described above is not warranted. 

4.4.2 Aquatic Ecosystem Impacts 

The information and associated impacts for this section are provided and resolved in 

Section 4.4.2 of the ESP EIS (NRC 2006). Based on the staff’s analysis, construction related 

impacts to aquatic ecosystems were considered to be SMALL. New information related to 

potential construction impacts available since preparation of the ESP EIS provides a description 

of the design of the proposed Unit 3 intake, the proposed NAPS-Ladysmith transmission line, 

and additional information on the possible presence of polychlorinated biphenyls (PCB) in the 

vicinity of the intake. As described in Section 4.4.1, additional information is also available for 

the land adjoining the NAPS Unit 3 site that will be used to support construction activities. 

The intake design evaluated during the ESP environmental review process assumed the new 

structure would be 21 m (70 ft) long and 21 m (70 ft) wide, and would house trash racks, 

traveling screens, and intake pumps. Recent information provided by Dominion (Dominion 

2008a) confirms that the intake structure will be located at the end of a cove on the south shore 

of Lake Anna near Harris Creek and immediately west of the cove where the intake structure for 

Units 1 and 2 is located. This is the same location originally planned for the intake of the two 

additional units proposed during the early 1980s. The cove currently is isolated from the lake by 

a cofferdam. To supply water to the proposed Unit 3, Dominion currently proposes that five box 

culverts, each with a width of 3.7 m (12 ft) and a height of 3 m (10 ft), would be installed in the 

existing cofferdam to allow water from Lake Anna to flow toward Unit 3 through the existing 

approach channel in Lake Anna (Dominion 2009a). Because of the limited quantity of water 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-10 February 2010 

required for the proposed Unit 3, Dominion (2009a) states that no major modifications to the 

existing shoreline or dredging in the approach channel will be needed. 

As described in the ESP EIS (NRC 2006), a temporary loss of benthic habitat and the 

displacement or loss of benthic organisms is expected to occur as a result of construction 

activities associated with the new intake. As a result, fish and mobile benthic organisms 

inhabiting the intake channel and the lake near the intake channel may temporarily leave the 

area during construction. In addition, in-water activities may temporarily increase turbidity, 

leading to a localized reduction in primary productivity from a decrease in light penetration and 

potential smothering of periphyton and aquatic macrophytes in the intake channel. The staff 

believes these impacts would be temporary, and the aquatic environment would recover soon 

after construction is completed. In response to a request by the staff, Dominion has confirmed 

that it is committed to employing BMPs related to erosion and sediment control, including the 

use of turbidity curtains, sheet piling, or other approved methods of protection between the 

intake bay for Unit 3 and the Lake Anna Reservoir (Dominion 2008b). These controls also 

would reduce the impact of other construction-related activities, such as accidental fuel spills 

into the reservoir or siltation into streams or watercourses adjacent to the proposed Unit 3 

cooling tower. Prior to any in-water activities associated with the construction of the intake 

structure, Dominion would be required to obtain a Clean Water Act Section 404 Permit from the 

USACE, and work closely with the VDEQ to ensure that the water quality and aquatic resources 

of Lake Anna are protected during construction. 

As described in Section 4.4.1, no additional clearing of forested vegetation will be required for 

construction of the new NAPS to Ladysmith transmission line in the existing right-of-way, and 

existing access roads will be used. Only hand-clearing would be used within 30 m (100 ft) of 

streams or creeks, and BMPs for erosion and sedimentation control would be followed. To the 

extent possible, tower bases will avoid wetlands and stream crossings. As noted above, two of 

72 proposed new towers may be located in or adjacent to wetland areas. 

As described in Section 2.7.2, approximately 38.8 ha (96 ac) of property adjoining the Unit 3 site 

has been recently acquired by Dominion to support construction activities. Nearly all the timber 

on this property was harvested prior to acquisition by Dominion, thus altering the hydrology and 

ecology of the site. Recent environmental investigations at this site indicate that approximately 

1130 linear m (3700 linear ft) of intermittent or perennial streams may be directly affected by 

construction activities. Because no threatened or endangered species are expected to occur in 

this location (Dominion 2009a) and the existing aquatic communities present on the land are 

commonly found elsewhere on the site and in the vicinity, minimal construction-related impacts 

are expected. Dominion also has expressed a willingness to consider compensation for stream 

losses by preserving other onsite streams, or through other kinds of mitigation, such as the 

purchase of mitigation credits (Dominion 2009a). 
Environmental Impacts of Construction 

February 2010 4-11 NUREG-1917, SEIS 

During the staff’s review of information associated with construction impacts to aquatic 

resources, Dominion confirmed that a small quantity of transformer oil containing low levels 

of PCBs was spilled near the intake in 1981 as the result of a fire in a turbine building. 

Immediately after the spill, a containment boom was deployed, and the cleanup was 

coordinated with the Commonwealth of Virginia. Because of this event, it is possible that PCB 

compounds are present in the sediments near the intake, but the concentrations probably are 

small because the transformer oil spilled was classified as “non-PCB” material based on 1981 

U.S. Environmental Protection Agency (EPA) criteria (Dominion 2008c). In 1979, EPA 

considered transformer fluid with less than 50 ppm of PCBs to be “non-PCB” material, and this 

criterion continues to be used today to classify electrical equipment containing these 

compounds (40 CFR Part 761) (EPA 1979). In 2006, the VDEQ analyzed sediment samples 

collected in Lake Anna in the vicinity of NAPS and in the Waste Heat Treatment Facility, and did 

not detect any PCBs in those sediments (VDEQ 2007). Thus, because it is likely that the 

concentrations of PCBs in the sediment near the intake are very low, the staff believes that if 

appropriate BMPs are employed during construction of the Unit 3 intake, the risk of 

re-suspending PCB compounds is small and adverse environmental effects are unlikely during 

construction. In addition, recent information from Dominion (Dominion 2008a) indicates that no 

dredging would be required in the approach channel, further reducing the likelihood of sediment 

re-suspension. 

Based on an independent review of existing and new information, the staff identified no 

information that was both new and significant. The staff concludes that the impacts to most 

aquatic resources from the construction of the proposed Unit 3 cooling system and proposed 

transmission line are expected to be localized and temporary. Although approximately 

1130 linear m (3700 linear ft) of intermittent or perennial streams on 38.8 ha (96 ac) of land 

adjoining the NAPS Unit 3 site could be affected by construction activities, no threatened or 

endangered species are expected to occur on this property (Dominion 2009a), and the aquatic 

resources present are common and found elsewhere on the site and in the vicinity. Thus, the 

overall impact of construction on aquatic resources associated with this land is expected to be 

minimal. Dominion has also indicated that any structures constructed outside of the NAPS site 

are not expected to be permanent, and would be removed after construction is completed. 

Dominion also may consider mitigation measures to compensate for stream loss through 

preservation of other onsite streams, or by purchasing credits from an approved mitigation bank 

(Dominion 2009a). Additionally, no planned construction activities would be expected to impact 

the fishery or any of the biological communities of the North Anna River. Thus, the conclusion 

of SMALL impact reached by the staff in the ESP EIS (NRC 2006) is still valid, and further 

mitigation beyond the actions stated above is not warranted. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-12 February 2010 

4.4.3 Threatened and Endangered Species 

The information and associated impacts for this section are provided and resolved in 

Section 4.4.3 of the ESP EIS (NRC 2006). Based on the staff’s analysis, construction-related 

impacts to threatened or endangered species were considered SMALL. New information 

available since preparation of the ESP EIS includes the Federal delisting of the bald eagle 

(Haliaeetus leucocephalus); changes to the State-listed endangered or threatened species, as 

described in Section 2.7; and the acquisition of 38.8 ha (96 ac) of property adjoining the ESP 

site. 

Since preparation of the ESP EIS (NRC 2006), the bald eagle has been removed from the list of 

species protected under the Federal Endangered Species Act (72 FR 37346), but it is still listed 

as Threatened by the Commonwealth of Virginia and is afforded continued protection by the 

Federal Bald and Golden Eagle Protection Act. The U.S. Fish and Wildlife Service issued 

management guidelines that provide suggested buffers to avoid harassment of eagles (USFWS 

2008). Generally, most construction activities that occur beyond 201 m (660 ft) from a nest 

would not be considered harassment under these guidelines, and blasting or other very loud 

noises beyond about 0.8 km (0.5 mi) from a nest would not be considered harassment. 

Dominion has confirmed that the nearest bald eagle nest is in the Contrary Creek drainage, 

approximately 3.2 km (2 mi) west of the NAPS site (Dominion 2008b). 

Dominion performed a habitat assessment of rare, threatened, and endangered species on the 

38.8-ha (96-ac) land parcel adjoining the NAPS 3 site that was purchased to support 

construction activities. No suitable habitat for such species was identified (Dominion 2009a). 

Because the property was recently clearcut, it is unlikely that habitat that would support the rare, 

threatened, and endangered species listed in Table 2-1 would be present. 

Since issuance of the draft SEIS, the Virginia Department of Conservation and Recreation 

(VDCR) informed the NRC staff that the NAPS site may contain suitable habitat for the 

Federally threatened and State-endangered small whorled pogonia (Isotria medeoloides) 

(VDCR 2009). The NRC staff contacted Dominion, which indicated that it was not aware of the 

presence of the species on the site. However, Dominion agreed to work with VDCR and to 

perform a habitat assessment to determine if the species is present (Dominion 2009b). If the 

species is identified, the NRC staff would perform an assessment and consult with the USFWS 

and the Commonwealth of Virginia for protection of the species. As described in Section 2.7.1.3, 

no Federally or State-listed species are known to exist within or near the North Anna to 

Ladysmith transmission line right-of-way, but one rare plant species, Epling’s hedge-nettle 

(Stachys eplingii), has been identified in one wetland area within the transmission line right-ofway (VDCR 2009). The right-of-way will not be widened to accommodate the additional set of 

towers, and except for two potential locations, the towers will not be placed within wetlands or 

other sensitive habitats. Thus, habitat for threatened or endangered plant species will not be 
Environmental Impacts of Construction 

February 2010 4-13 NUREG-1917, SEIS 

disturbed. Therefore, impacts to threatened or endangered species are unlikely to occur due to 

the installation of additional towers and transmission lines within the existing right-of-way. 

As described in Section 5.4.3.2 of the ESP EIS (NRC 2006), Dominion has monitored fish 

populations in Lake Anna and the North Anna River for more than 25 years. No Federally listed 

fish species has been collected in any of these monitoring studies, nor has any listed species 

been observed in creel surveys or occasional special studies conducted by Dominion. No range 

of any Federally or State-listed fish species includes Lake Anna or the North Anna River, and 

none is believed to occur in counties adjacent to Lake Anna or the North Anna River (i.e., 

Caroline, Hanover, Louisa, Orange, and Spotsylvania Counties). As stated in the ESP EIS, 

according to the VDGIF and Virginia Department of Conservation and Recreation databases, 

one Federally listed mussel species (dwarf wedge mussel [Alasmidonta heterodon]), and one 

mussel species (fluted kidneyshell [Ptychobranchus subtentum]) that is a candidate for Federal 

listing, occur in counties that border Lake Anna or the North Anna River. Neither of these 

species, nor the State-listed Atlantic pigtoe (Fusconaia masoni) had been found in Lake Anna or 

the North Anna River, or its tributaries during the development of the ESP EIS (NRC 2006). 

The State-listed green floater (Lasmigona subviridis) and Virginia Piedmont water boatman 

(Sigara depressa) were reported to occur in the upper Pamunkey River watershed. Neither 

species were found in Lake Anna or the North Anna River during either pre-impoundment 

surveys or more recent routine monitoring surveys. In addition, no threatened or endangered 

species are expected to occur in the 38.8-ha (96-ac) land parcel adjoining the NAPS 3 site that 

was purchased to support construction activities (Dominion 2009a). 

Based on the staff review of information provided by Dominion in the COL ER (Dominion 

2009a), and meetings with Commonwealth of Virginia resource managers, the staff identified no 

information that was both new and significant, and concludes that the ESP assessment of 

impact associated with threatened and endangered species during the construction of the 

proposed Unit 3 are still valid. Based on this information, the staff concludes that the effect of 

construction on threatened and endangered species would remain SMALL, and mitigation is not 

warranted. 

4.5 Socioeconomic Impacts 

This section evaluates the social and economic impacts to the surrounding region as a result of 

constructing a new nuclear powered electricity generating unit (Unit 3) at the NAPS site. This 

evaluation assesses the impacts of construction and the demands on the surrounding region 

that could result from the smaller workforce needed to construct the proposed Unit 3 only, rather 

than the two units (Units 3 and 4) considered in the ESP EIS (NRC 2006). Construction 

activities involving one unit rather than two units are assumed to last up to 4 years and require 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-14 February 2010 

2500 to 3500 workers, compared to the 5 years and 5000 workers assumed for the ESP EIS 

(Dominion 2008a). The evaluation also assesses the visual impacts of constructing the new 

plant structures for the proposed Unit 3. 

Dominion expects the workforce of 2500 to 3500 to be maintained for most of the construction 

period. This construction workforce would be in addition to the 1000 personnel currently 

employed at the site and crews involved in intermittent outage activities. 

4.5.1 Physical Impacts 

Construction activities at the proposed Unit 3 site could cause temporary and localized physical 

impacts including, but not limited to noise, odor, vehicle exhaust emissions, and fugitive dust. 

Dominion does not expect significant vibration and shock impacts during construction because 

of the strict restriction or control of such activities onsite (Dominion Nuclear North Anna, 

LLC 2006). This section qualitatively addresses those potential impacts that may affect people, 

buildings, roads, and recreational facilities (such as Lake Anna). 

4.5.1.1 Workers and the Local Public 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.1.1 of the ESP EIS (NRC 2006). Based on NRC’s independent review and 

Dominion’s representation that it would undertake mitigation measures, the staff concludes 

that the overall physical impacts to workers and the local population of constructing Unit 3 are 

SMALL, and further mitigation beyond the mitigation actions stated in the ESP EIS is not 

warranted. 

The new information available since preparation of the ESP EIS does not suggest that 

construction activities will be any larger in scale, any noisier, or any more intrusive visually than 

previously documented. Therefore, the staff concludes that the impacts would remain SMALL. 

4.5.1.2 Buildings 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.1.2 of the ESP EIS (NRC 2006). Because the nearest offsite building is about 

910 m (3000 ft) from the proposed Unit 3 construction site, the staff concludes that the overall 

physical impacts to offsite buildings would be SMALL, and mitigation is not warranted. 

The new information available since the ESP EIS was published does not suggest that 

construction activities will be any larger in scale, any noisier, or any more intrusive visually or 

otherwise than previously suggested. Therefore, the staff concludes that the impacts would 

remain SMALL. 
Environmental Impacts of Construction 

February 2010 4-15 NUREG-1917, SEIS 

4.5.1.3 Roads 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.1.3 of the ESP EIS (NRC 2006). Based on Dominion’s representation that it would 

develop and implement a traffic management plan and the staff’s independent review, the staff 

concludes that the overall physical impacts to local roadways would be temporary and SMALL, 

and additional mitigation beyond the actions stated in the ESP EIS is not warranted. 

Dominion remains committed to developing and implementing a traffic management plan for 

Unit 3. Because the currently contemplated construction workforce for one unit is 2500 to 

3500 workers rather than the 5000 workers anticipated for construction of two units documented 

in the ESP EIS, the impact on roads from commuter traffic is expected to be less. The impact 

from heavy hauling also should be significantly less, because the proposed Unit 3 would require 

roughly half the materials and structures to be hauled during the construction period. The 

amount of equipment needed probably would be less but not half, because only one unit would 

be built but the original concept contemplated reuse of some equipment on the second unit as 

the first proceeded to completion. The staff believes that the impact would be less than that 

described in the ESP EIS and would remain SMALL and temporary. 

4.5.1.4 Aesthetics and Recreation 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.1.4 of the EIS ESP (NRC 2006). As part of its COL application (Dominion 2008d), 

Dominion performed a visual impact study to determine the visual impact of the proposed Unit 3 

when it becomes operational; however, Dominion also addressed the visual impacts of 

construction. The staff’s review of the visual impact study concludes that the added visual 

impacts of construction are temporary and that the aesthetic impact will continue to be SMALL. 

As discussed in Section 3.7 of the COL ER (Dominion 2009a), construction of Unit 3 would 

require a new 500-kV transmission line to be installed in the existing North Anna to Ladysmith 

right-of-way. As discussed in Section 2.4 of the COL ER (Dominion 2009a), part of this 

transmission line would cross Lake Anna and other waterways and wetlands. During installation 

of the new transmission line, access to Lake Anna and the other subject waterways would be 

temporarily restricted from recreational use. Based on the Dominion’s representation that the 

limitation will be temporary in nature, and full use of the recreational areas would be restored 

upon completion of the installation, the staff concludes that the overall physical impact resulting 

from installation of the transmission line would be SMALL, and mitigation is not warranted. 

The visual impacts of construction, such as water turbidity from localized dredging and fugitive 

dust, would be temporary and would be controlled pursuant to Commonwealth regulations. In 

addition, based on Dominion’s representation that it would develop and implement a dust 

control plan (see Section 4.2.1), and the points from which construction activities could be 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-16 February 2010 

observed from the lake would be limited, the staff concludes that the visual impacts of 

construction on Lake Anna and the surrounding area would be SMALL, and further mitigation is 

not warranted. 

4.5.2 Demography 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.2 of the ESP EIS (NRC 2006). Based on the ESP EIS representation that (1) most 

construction workers would be expected to come from within the region and (2) the number of 

construction workers who might relocate to the region would be a small percentage of the larger 

population base, as well as the smaller workforce contemplated for Unit 3 alone, the staff 

concludes that the impacts of construction-based increases in population within the region 

would be SMALL, and mitigation is not warranted. 

4.5.3 Community Characteristics 

This section evaluates the social and economic impacts to the surrounding region as a result of 

constructing Unit 3 at the NAPS ESP site. Dominion provided new information on the workforce 

and costs of the proposed Unit 3. The evaluation assesses impacts of this new information 

concerning construction and demands placed by the workforce on the surrounding region. 

Construction activities are assumed to last up to 4 years and employ 2500 to 3500 workers 

(Dominion 2008a). Dominion expects this size workforce to be maintained for most of the 

construction period (Dominion Nuclear North Anna, LLC 2006). This construction workforce 

would be in addition to the 1000 personnel currently employed at the site to support the 

operation of Units 1 and 2, any operations workers for Unit 3 who will be onsite during 

construction, and any outage workers needed for Units 1 and 2 while Unit 3 construction is 

underway. 

4.5.3.1 Economy 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.3.1 of the ESP EIS (NRC 2006). The staff reviewed the impacts of construction of 

the proposed Unit 3 on the economy of the region and concludes that the magnitude of the 

economic impacts would be diffused in the larger economic bases of Henrico and Spotsylvania 

Counties and the City of Richmond. The economic impacts would be more noticeable for the 

smaller economic bases of Orange and Louisa Counties. Based on the positive aspects of the 

proposed construction on the regional economies and the workforce availability, the staff 

concludes that the impacts on the economy are mostly positive. Overall, the staff concludes 

that the impact on the regional economy would continue to be SMALL BENEFICIAL in the 

50 miles surrounding the NAPS site and up to MODERATE BENEFICIAL for Louisa and Orange 

Counties. 
Environmental Impacts of Construction 

February 2010 4-17 NUREG-1917, SEIS 

4.5.3.2 Taxes 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.3.3 of the ESP EIS (NRC 2006). The staff reviewed the income taxes generated on 

wages and salaries of Unit 3 construction workers and Dominion corporate profits as well as 

sales and use taxes, most of which represent beneficial sources of income for the 

Commonwealth and some of which would benefit the counties in the region. Property tax paid 

by contractors and by Dominion would directly benefit Louisa County. The overall impacts from 

real and personal property taxes on the region would continue to be SMALL BENEFICIAL to 

MODERATE BENEFICIAL for Louisa County, and mitigation is not warranted. 

4.5.4 Infrastructure and Community Service Impacts 

Infrastructure and community services include transportation, recreation, housing, public 

services, and education. 

4.5.4.1 Transportation 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.3.2 of the ESP EIS (NRC 2006). Based on its independent review and Dominion’s 

representation that it would develop and implement a traffic management plan, the NRC staff 

concluded in the ESP EIS that if the planned upgrades and improvements to the road systems 

in the region are implemented, the temporary impacts of construction on transportation in the 

region would be SMALL to MODERATE, and further mitigation beyond the actions stated above 

would not be warranted. 

New information that has become available since preparation of the ESP EIS indicates that the 

transportation infrastructure situation has not changed significantly. There are no new traffic 

data that would better identify the change in the level of service on key road segments; and no 

new sources of funding have been identified to speed plans to improve the local road network. 

When completed, the Route 208 bypass would significantly reduce traffic congestion along both 

Route 208 and Route 606 in Spotsylvania County and would smooth construction traffic flow 

north of Lake Anna (but without affecting congestion on Route 652 nearer the plant gate). The 

first phase of the bypass has been completed in Spotsylvania County (VDOT 2009), but 

although it is still under consideration for “stimulus funding,” Phase II had not been funded under 

the American Recovery and Reinvestment Act as of October 23, 2009.(a) The only significant 

change is that the proposed Unit 3 would require a much smaller labor force than posited in the 

 

(a) October 23, 2009 e-mail from Michael J. Scott (Pacific Northwest National Laboratory) to Richard A. 

Spurlock (Virginia Department of Transportation). Subject: Route 208 Upgrade, Phase II. 

Accession No. ML100350897. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-18 February 2010 

ESP EIS, thus reducing the traffic congestion associated with construction. However, the staff 

believes that the impacts in the region would remain SMALL to MODERATE. 

4.5.4.2 Recreation 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.3.4 of the ESP EIS (NRC 2006). New information includes a smaller construction 

workforce, which would reduce the impacts on the road network and on recreation facilities, and 

the fact that that some temporary safety-related interruption in boat traffic will occur during the 

stringing of new transmission lines across Lake Anna. Dominion (2009b) has stated that a 

communications plan will be developed to notify local citizens of the impact of the transmission 

line construction activities using public notices and “day-of” postings. These notifications will 

include a description of the schedule and anticipated duration of the activities. Interruptions that 

will affect recreational activities on Lake Anna are expected to be of short duration. Citizen 

band radio will be used to notify marine vessels of planned activities. Based on the expectation 

that the mitigative measures discussed earlier (e.g., traffic management, road improvements, 

and best construction management practices to minimize water-quality impacts) are 

implemented, the staff concludes that the impacts of construction on the recreational use of 

Lake Anna would remain SMALL to MODERATE, and further mitigation is not warranted.

4.5.4.3 Housing 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.3.5 of the ESP EIS (NRC 2006). Because of the overall availability of housing in 

Henrico and Spotsylvania Counties and the City of Richmond and assuming that the housing 

pattern follows past experience, the staff concluded that the overall impacts of construction on 

housing, including housing prices, in these areas would be SMALL, and mitigation is not 

warranted. No impact assessment was performed for the Washington, D.C., metropolitan area 

because the scale of the NAPS Unit 3 project is not likely to be large enough, relative to other 

economic trends in the Washington, D.C., area to produce a noticeable impact. 

The staff further concluded that housing impacts to Orange and Louisa Counties could be 

MODERATE if significantly more workers than expected move to these counties where a 

shortage of rental housing currently exists. Increased housing construction to meet this 

potential need is not likely because of the short duration Unit 3 construction activities. 

New information that has become available since preparation of the ESP EIS indicate that the 

available housing stock has grown in the local jurisdictions and that the in-migrating labor force 

will be smaller than contemplated in the ESP EIS (NRC 2006). Therefore, it is likely that the 

regional impact of Unit 3 construction activities on housing should remain SMALL. However, it 

is still likely that housing impacts could still rise to MODERATE in Orange and Louisa Counties 

if significantly more workers than expected move to these counties. 
Environmental Impacts of Construction 

February 2010 4-19 NUREG-1917, SEIS 

4.5.4.4 Public Services 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.3.6 of the ESP EIS (NRC 2006). Based on the current availability of services 

and additional taxes that would affect the financial demand for additional services, the staff 

concluded that the impact on the demand for public and related services as a result of 

construction would be SMALL, and mitigation is not warranted. New information available 

since the ESP EIS was published indicates a smaller construction workforce and a smaller 

population increase than that contemplated in the ESP EIS. Therefore, the staff concluded that 

the demand for public services also is likely to be smaller and that the conclusion documented 

in the ESP EIS does not change. 

4.5.4.5 Education 

The information and associated impacts for this section are provided and resolved in 

Section 4.5.3.7 of the ESP EIS (NRC 2006). Based on the overall availability of educational 

facilities in Henrico, Spotsylvania, Orange, and Louisa Counties and the City of Richmond and 

assuming that the housing pattern follows past experience, the staff concluded that the impacts 

of construction on educational resources would be SMALL to MODERATE, and mitigation is not 

warranted. 

Information available on the area since preparation of the ESP EIS indicates a continuation 

of general population growth and increases in school enrollment in all jurisdictions except the 

City of Richmond. The workforce employed to construct the proposed Unit 3 may accelerate 

the demand for additional school space but will not fundamentally change the demand. New 

schools will be needed in any case. For example, the Louisa County public school system 

has been planning construction for a new elementary school in response to growth in the area 

for several years. There was an increase in Louisa County school enrollment from 

4219 students during the 2000 to 2001 period to 4738 during the 2008 to 2009 period (Virginia 

Department of Education 2009), an increase of 519 students or 12 percent. As of the summer 

of 2009, the new Moss-Nuckols elementary school was under construction (Louisa County 

Public Schools 2009) and is scheduled to open in August 2010,(a) and consideration was being 

given to renovation or replacement of the older Thomas Jefferson elementary school (Louisa 

County 2009). 

The staff performed a calculation of the potential increase in school enrollment based on 

employment multipliers contained in an assessment of the expansion of NAPS performed by 

the Virginia Economic Development Partnership (VEDP 2006) and population estimates for 

Louisa County by the Census Bureau (USCB 2008). The staff estimates are based on 

 

(a) September 22, 2009 e-mail from Daniel Mussatti (NRC, Senior Economist) to Alicia Williamson (NRC, 

Project Manager). Subject: Moss-Nuckols School Opening. Accession No ML093210594. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-20 February 2010 

Dominion‘s workforce estimates that 700 of the 2500 to 3500 construction workers would 

migrate into the region and reside within 80 km (50 mi) of the plant. Based on the residences of 

the current plant population, 28.9 percent of the 700 workers would live in Louisa County, a total 

of 202 employees. While the number of indirect employees in-migrating into Louisa County is 

not clear, the staff assumed that the number would be between zero (if all new indirect jobs 

went to current county residents) and 281 (if all new indirect jobs went to new in-migrants). The 

average household size in the Commonwealth of Virginia is 2.55 people. This means that in 

Louisa County, the construction-related population increase would be between 515 and 

1232 people. The ratio of school-age population to total population in Louisa County is 0.179. 

Multiplying 0.179 times the number of new residents yields a range of 92 to 221 new school-age 

residents in Louisa County. This is a potential enrollment increase of 1.9 to 4.7 percent based 

on 2008 to 2009 enrollment, and is smaller than the recent growth experienced in the district. 

Furthermore, in view of the fact that the number of construction workers for the proposed Unit 3 

is considerably smaller than the number contemplated in the ESP EIS, the impact on schools 

also is likely to be smaller. The sample calculation performed by the staff indicates that the 

impact on enrollment will not be large. The range of impacts is still likely to remain SMALL to 

MODERATE. 

4.5.5 Summary of Socioeconomic Impacts 

As described in the ESP EIS (NRC 2006), adverse socioeconomic impacts resulting from 

construction of the Unit 3 range from SMALL to MODERATE, and beneficial impacts range 

from SMALL to MODERATE. 

4.6 Historic and Cultural Resources 

The National Environmental Policy Act of 1969 (NEPA) as amended requires Federal agencies 

to take into account the potential effects of their undertakings on the cultural environment, which 

includes archaeological sites, historic buildings, and traditional places important to local 

populations. The National Historic Preservation Act of 1966 (NHPA), as amended, also requires 

Federal agencies to assess impacts to those resources if they are eligible for listing on the 

National Register of Historic Places (NRHP). Such resources are referred to as “Historic 

Properties” in the NHPA. As outlined in 36 CFR 800.8, “Coordination with the National 

Environmental Policy Act of 1969,” the NRC coordinated compliance with Section 106 of the 

NHPA in meeting the requirements of NEPA. 

Construction activities for a new unit can affect either known or undiscovered cultural resources. 

Therefore, in accordance with the provisions of NHPA and NEPA, the NRC is required to make 

a reasonable and good faith effort to identify historic properties in the area of potential effect 

and, if present, determine if any significant impacts are likely to occur. Identification is to occur 
Environmental Impacts of Construction 

February 2010 4-21 NUREG-1917, SEIS 

in consultation with the State Historic Preservation Officer (SHPO), American Indian Tribes, 

interested parties, and the public. If significant impacts are possible, efforts should be made to 

mitigate them. As part of the NEPA/NHPA integration, if no historic properties (i.e., places 

eligible for listing on the NRHP are present or affected, the NRC is required to notify the SHPO 

before proceeding. If it is determined that historic properties are present, the NRC is required to 

assess and resolve adverse effects of the undertaking. 

As explained in Section 2.9.2 of this supplemental environmental impact statement (SEIS), 

cultural resource identification efforts identified seven resources that were recommended 

eligible for the NRHP and require evaluation or avoidance (historic archaeological site 

44LS0226, historic archaeological site 44LS0233, historic archaeological site 44SP0618, 

historic cemeteries 44LS0221, 44LS0222, and 44LS0227, and architectural resource VDHR No. 

016-5042/Blanton’s Road Farm) (Dominion 2009a). 

Dominion has planned construction activities to avoid the three historic cemeteries and one 

historic site located in the proposed Unit 3 site area (Dominion 2008a). Two of these 

cemeteries (44LS0221 and 44LS0222) were identified in the ESP ER (Dominion Nuclear North 

Anna, LLC 2006). The third cemetery (44LS0227) and the historic site (44LS0226) were 

identified in a November 7, 2007 letter from the SHPO to Dominion (VDHR 2007). The SHPO 

indicated that given the scope of the project as presented to the Virginia Department of Historic 

Resources (Dominion 2007), the letter to Dominion dated November 7, 2007 (VDHR 2007), and 

Dominion’s plan of avoidance of all four sites (44LS0221, 44LS0222, 44LS0226, and 

44LS0227) during construction and operation of the new facilities, the project will not negatively 

affect cultural and historic resources. Additional historic properties (NRHP eligible sites) have 

been identified since then, but Dominion has committed to working with the SHPO and to follow 

NHPA Section 106 (Dominion 2008a). 

In the ESP EIS (NRC 2006), the staff determined the impacts from construction on historic and 

cultural resources would be SMALL. The newly identified cultural resources were determined to 

be new information. For new information to be “significant,” it must be material to the issue 

being considered that it must have the potential to affect the finding or conclusions of the NRC 

staff’s evaluation of the issue (72 FR 49352). A total of seven resources were determined to be 

potentially eligible for the National Register of Historic Places, thus making their discovery 

significant. 

Dominion has made commitments to address the following concerns (Dominion 2008c): 

1. A commitment or management plan for evaluating sites found during surveys for eligibility 

to National Register of Historic Places if avoidance is not the planned action. 

2. A written procedure for establishing protective barriers for all historic sites found that were 

eligible for the National Register of Historic Places if avoidance is the planned action. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-22 February 2010 

3. If avoidance of located (National Register Eligible) sites is planned, provide a written 

commitment to do so and schedule for fencing or other physical barrier as a double check. 

4. If avoidance is not the planned action, a commitment or management plan for mitigation of 

(National Register Eligible) sites to be destroyed during construction. 

5. Written commitment/management practices for addressing cultural resources for future 

ground disturbing work at the NAPS site. 

6. Written commitment or management plan for contacting the Virginia Department of 

Historic Resources in case of an inadvertent or “post review” discovery. 

7. Provide the commitment/management practices for the new cemetery (identified) on the 

NAPS site. 

Even with the discovery of new and significant information, it is the staff’s conclusion that the 

potential construction impacts on historic and cultural resources would remain SMALL based on 

these commitments.

Any revised project activities or a change in scope would need to consider the potential impacts 

of plant construction on both known and unknown historic and archaeological resources at 

NAPS. Lands not previously surveyed would require investigation by a professional 

archaeologist prior to any ground-disturbing activities in the future. Any changes to these 

procedures or project plans should be developed in consultation with the SHPO. Mitigation 

might be warranted in the event of an inadvertent discovery.

4.7 Environmental Justice 

The staff evaluated whether the health or welfare of minority and low-income populations at 

those census blocks identified in Section 2.10 of this COL EIS could be disproportionately 

affected by the potential impacts of constructing Unit 3 at the NAPS site. A detailed 

characterization of the Environmental Justice analysis is contained in the ESP EIS (NRC 2006). 

In the ESP EIS, only three areas – local traffic, housing, and education – were identified where 

adverse impacts during construction of Units 3 and 4 would be classified as greater than 

SMALL. The analysis documented in the ESP EIS considered impacts under any conditions for 

any offsite population (including minority and low-income populations) in the area affected by 

the proposed units. 

Traffic congestion in the immediate vicinity of the plant could increase, but this effect would not 

have a disproportionate and adverse impact on minority and low-income populations because 

these populations typically live at some distance from the plant site and not on the main 

commuting routes as shown in Figures 2-6 and 2-7 of the ESP EIS (NRC 2006). The cost of 

renting housing in Orange and Louisa Counties might escalate if construction workers crowded 
Environmental Impacts of Construction 

February 2010 4-23 NUREG-1917, SEIS 

into those counties, which is not expected. It is doubtful that the impact would 

disproportionately fall on the diffuse (i.e., unmapped) minority and low-income individuals in 

these counties; rather, if it happened at all, all population groups would be affected to some 

extent, and the distribution of impact would be uncertain. If large numbers of construction 

workers’ children crowded into the public schools of Orange and Louisa Counties, which is not 

expected, these schools could become more crowded, but the entire populations of these 

counties would be proportionately affected. After this detailed consideration, as briefly stated in 

Section 4.7 of the ESP EIS, the NRC staff concluded that there were no environmental 

pathways by which the identified minority or low-income persons were likely to suffer 

disproportionate and adverse environmental or health impacts as a result of construction. 

The analysis has been expanded to incorporate a wider geographic area based on the 

possibility that minority and low-income populations in counties downstream from Lake Anna 

might experience disproportionate and adverse impacts from construction of Unit 3. The 

aquatic, ecological, and atmospheric analyses for this SEIS shown in Sections 4.2, 4.3, 4.4, 

4.6, 4.8, and 4.9 did not identify any significant environmental impacts reaching the three 

downstream counties. Therefore, minority and low-income populations will not be adversely 

and disproportionately affected through these pathways. It is theoretically possible that the 

three downstream counties might experience escalation of housing prices, crowding on 

commuter routes, and increased school enrollments from in-migrating construction workers 

concentrated in those three counties. However, this is even less likely than in Orange, Louisa, 

and Spotsylvania Counties because of the commuting distances involved for construction 

workers and the lack of services in these counties relative to Fredericksburg, Richmond, and 

Charlottesville. 

Based on new information provided by Dominion in its COL ER (Dominion 2009a) concerning 

the lower construction employment and Dominion’s continued commitment to develop and 

implement mitigation plans, and NRC’s independent review, the staff concludes that offsite 

impacts of construction of the proposed Unit 3 at the NAPS site would not impose a 

disproportionate and adverse impact on minority or low-income populations. 

4.8 Nonradiological Health Impacts 

The following sections summarize the results of the NRC staff’s assessment of nonradiological 

health impacts for construction of the proposed Unit 3 at the NAPS site. Physical impacts of 

construction on public and occupational health, including dust, vehicle emissions, noise, and 

transportation of materials and personnel, are summarized. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-24 February 2010 

4.8.1 Public and Occupational Health 

As discussed in the ESP EIS (NRC 2006), Dominion will develop and implement a dust control 

program to minimize fugitive dust exposure to the public. Dominion will control exhaust 

emissions from construction equipment in accordance with Federal, State, and local emission 

requirements. 

In general, human health risks for construction workers and personnel working onsite would be 

expected to be dominated by occupational injuries (e.g., falls, electrical shock, asphyxiation, 

etc.) to workers engaged in activities such as construction, maintenance, and excavation. 

Historically, actual injury and fatality rates at nuclear reactor facilities have been lower than the 

average U.S. industrial rates. In the COL ER (Dominion 2009a), Dominion reports that the 

average construction workforce for the proposed Unit 3 will be about 2500 to 3500 workers. 

The staff did not identify information that was both new and significant related to public and 

occupational health during construction activities for the proposed Unit 3. This was based on 

the staff’s review of information in ESP EIS (NRC 2006), the ESP ER (Dominion Nuclear North 

Anna, LLC 2006), the COL ER (Dominion 2009a), and associated documentation provided by 

and discussions with representatives of Dominion during an April 2008 site audit. The staff 

concludes that the public and occupational health impacts during construction of the proposed 

Unit 3 would remain SMALL. 

4.8.2 Noise Impacts 

The staff did not identify information that was both new and significant in Dominion’s plans for 

construction of proposed Unit 3 related to noise during construction. During the April 2008 site 

audit, staff reviewed the results of a modeling study demonstrating that noise levels at the 

Exclusion Area Boundary (EAB) would be less than 65 dBA.(a) The staff relied on the guidance 

published by the Federal Highway Administration’s (FHWA) Office of Natural and Human 

Environment (FHWA 2006) to assess the study. The FHWA report addresses a variety of noise 

sources associated with construction. It notes that noise is an inevitable byproduct of 

construction, and that there is a variety of assessment techniques, some simple and others 

requiring highly specialized codes, that take a number of factors into account. Some of the 

additional factors, which are discussed in Section 6.2 of this SEIS, include: 

• multiple pieces of construction equipment working either independently or simultaneously 

• refined characterization of noise emission (e.g., impulsive or steady) 

• distance from each piece of equipment to each receptor 

 

(a) FHWA (2006) notes that the unit of “noise” relevant to this problem is the A-weighted decibel, or dBA, 

where A is a weighting factor that gives more weight to the frequencies to which the human ear is 

most sensitive, and dB is the standard decibel. 
Environmental Impacts of Construction 

February 2010 4-25 NUREG-1917, SEIS 

• influence of time-of-day (daytime, evening, or nighttime) 

• expected duration of the work 

• ground characteristics between the equipment and the receptors 

• attenuation caused by constructed or natural barriers 

• potential shielding or reflective effects of nearby buildings 

• meteorological effects on noise propagation. 

The Dominion ER (Dominion 2009a) indicates that noise from blasting associated with 

construction would be 94 dBA at 15 m (50 ft) from the source. For perspective regarding sound 

reduction, the FHWA estimates that sound levels measured from a point source decrease at 

a rate of 6 dBA per doubling of distance (FHWA 2006). Therefore, at the EAB (870.17 m 

[2854.9 ft]), per the plant parameter envelope considered in the ESP ER (Dominion Nuclear 

North Anna, LLC 2006), the noise level would be reduced by approximately six doublings 

resulting in a noise reduction of 36 dBA, or a noise level of 94-36 equals 58 dBA, which is 

comparable with or slightly less than the 65 dBA limit required for other construction activities at 

the EAB. 

Based on information provided by Dominion and the staff’s independent review, the staff 

concludes the impacts would remain SMALL, and mitigation beyond that currently planned is 

not warranted. 

4.8.3 Impacts of Transporting Construction Materials and Personnel to the 

Proposed Unit 3 Site 

Nonradiological health impacts of transporting construction materials and personnel to the 

proposed Unit 3 site were calculated using the general approach used to calculate 

nonradiological health impacts of transporting fuel and waste. This supplemental information 

was not in the ESP EIS (NRC 2006), but was included in the record as part of the hearing. 

Construction material requirements were based on information taken from the ESP ER 

(Dominion Nuclear North Anna, LLC 2006) and the COL ER (Dominion 2009a). A new 

1000-MW(e) unit requires up to 150,000 m3 (200,000 yd3) of concrete and 14,000 MT 

(15,000 tons) of structural steel (Dominion Nuclear North Anna, LLC 2006). In the COL ER, 

Dominion estimates 2 million linear m (6.5 million linear ft) of cable for a single 1300-MW(e) unit 

and up to 84,000 linear m (275,000 linear ft) of piping greater than 6.4 cm (greater than 2.5 in.) 

in diameter would be required (Dominion 2009a). Other assumptions included: 

• Shipment capacities were 10 m3 (~13 yd3) of concrete per shipment, 10 MT (11 tons) of 

structural steel, and 300 linear m (1000 linear ft) of piping and cable per shipment. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-26 February 2010 

• The number of construction workers was estimated at 3500. This value represents the peak 

workforce for construction (Dominion 2009a). At an average of 1.8 persons/vehicle, there 

would be about 1950 vehicles per day (NRC 2006). Each person was assumed to travel to 

and from the NAPS site 250 days per year. A four-year construction period for the proposed 

Unit 3 was assumed in the COL ER (Dominion 2009a). 

• Average shipping distances for construction materials were assumed to be 64 km (40 mi) 

one way. This assumption was based on the approximate one-way shipping distance from 

Richmond, Virginia, to the NAPS site. The average commute distance for construction 

workers was assumed to be 32 km (20 mi) one way. 

• Accident, injury, and fatality rates for construction materials were taken from Table 4 in the 

report entitled State-Level Accident Rates for Surface Freight Transportation: A 

Reexamination (Saricks and Tompkins 1999). Rates for the Commonwealth of Virginia were 

used for construction material shipments, typically transported in heavy-combination trucks. 

Impacts associated with commuter traffic (i.e., workers traveling to and from the proposed 

Unit 3 construction site) were derived from Virginia Traffic Facts (DOT 2008a). 

The estimated nonradiological impacts of transporting construction materials to the proposed 

Unit 3 site and of transporting construction workers to and from the site are shown in Table 4-1. 

Nonradiological impacts are dominated by transport of construction workers to and from the 

proposed Unit 3 site. The total annual construction fatalities represents less than a 2 percent 

increase above the 15 traffic fatalities that occurred in Louisa County in 2007 (DOT 2008b). 

Therefore, the staff concludes that the impacts of transporting construction materials and 

workers to the proposed Unit 3 site would be SMALL, and mitigation is not warranted. 

Table 4-1. Impacts of Transporting Workers and Construction Materials to/from the Proposed 

Unit 3 Site

Accidents per Year Injuries per Year Fatalities per Year

Workers 34 15 0.23 

Materials 

Concrete 0.66 0.30 0.0045 

Rebar 0.059 0.027 0.0004 

Cable 0.085 0.039 0.00059 

Piping 0.0036 0.0017 0.000025 

Total - Construction 35 16 0.24 

 

4.8.4 Summary of Nonradiological Health Impacts 

The NRC staff performed an evaluation of the estimated injuries and fatalities that might be 

incurred during transport of materials and workers to and from the proposed Unit 3 construction 
Environmental Impacts of Construction 

February 2010 4-27 NUREG-1917, SEIS 

site. Impacts were determined to be SMALL. No new and significant information was identified 

related to nonradiological health impacts during construction activities for the proposed Unit 3 

during the staff’s review. The staff’s evaluation consisted of a review of the information in the 

ESP EIS (NRC 2006), the ESP ER (Dominion Nuclear North Anna, LLC 2006), the COL ER 

(Dominion 2009a), and associated documentation and discussions with representatives of 

Dominion during an April 2008 site audit. 

4.9 Radiological Health Impacts 

The sources of radiation exposure to construction workers include exposures from direct 

radiation, gaseous radioactive effluents, and liquid radioactive waste discharges from routine 

operations at the existing NAPS Units 1 and 2 during the site preparation and construction 

phase of the proposed Unit 3. 

4.9.1 Direct Radiation Exposures 

In its ESP ER, Dominion identified two principal sources of direct radiation exposure from the 

existing NAPS Units 1 and 2: (1) the boron recovery tank, and (2) the low-level waste storage 

area (Dominion Nuclear North Anna, LLC 2006). The Independent Spent Fuel Storage 

Installation (ISFSI) was also noted to be an additional source of direct radiation exposure. The 

staff’s evaluation identified no additional sources of direct radiation. 

Dominion estimated direct radiation exposure to the construction workers from existing Units 1 

and 2 by assuming the construction worker was located at the west protected area fence (i.e., 

the location closest to the ESP site/the proposed Unit 3 construction site) (Dominion Nuclear 

North Anna, LLC 2006). Protected area thermoluminescent dosimeter (TLD) measurements at 

this location were used to estimate the construction worker dose. An average annual TLD 

reading of 0.56 mSv/yr (56 mrem/yr) was used as the basis for the estimated dose evaluation 

documented in the ESP ER (Dominion Nuclear North Anna, LLC 2006). This value was based 

on TLD readings from 1996 through 2002. When corrected for worker occupancy (2080 hr/yr), 

Dominion estimated 0.13 mSv/yr (13 mrem/yr) to the construction worker from the existing 

Units 1 and 2. The staff reviewed the area TLD data for the west protected area fence location 

from 2003 to 2007. The average annual TLD reading for these years was 0.76 mSv/yr 

(76 mrem/yr) (Dominion 2008b), which was a 35 percent increase over the average readings 

from 1996 to 2002. When adjusted for worker presence onsite, these exposures would result in 

an estimated annual construction worker dose from Units 1 and 2 of 0.18 mSv/yr (18 mrem/yr). 

The information on the recent area TLD data was new but not significant as discussed in 

Section 4.9.4 of this SEIS. 

Dominion estimated the direct radiation dose to the construction worker from the ISFSI to be 

9.8 × 10-2 mSv/yr (9.8 mrem/yr) based on a fully loaded facility (Dominion Nuclear North Anna, 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-28 February 2010 

LLC 2006). This dose was calculated at the center of the ESP site (490 m [1600 ft] from the 

ISFSI). This estimate remains valid for construction workers for the proposed Unit 3 as it also 

represents the approximate center of the Unit 3 site. 

The total direct radiation dose estimate to the construction worker is 0.28 mSv/yr (28 mrem/yr). 

This is more than the dose estimate of 0.23 mSv/yr (23 mrem/yr) from the ESP evaluation 

(NRC 2006). 

4.9.2 Radiation Exposures from Gaseous Effluents 

Dominion used the estimated total body dose, skin dose, and critical organ dose to the 

maximally exposed individual from gaseous effluents in the annual radioactive effluent release 

report for 2001 (VEPCo 2002) as a basis to estimate the construction worker dose from 

gaseous effluents (Dominion Nuclear North Anna, LLC 2006). In the ESP EIS, the NRC staff 

determined this approach to be acceptable (NRC 2006). The staff reviewed annual effluent 

release reports from recent years (VEPCo 2006, 2007, 2008) and found the 2001 dose to be 

typical. The estimated total effective dose equivalent (TEDE) from gaseous effluents 

documented in the ESP ER was 2.1 × 10-3 mSv/yr (0.21 mrem/yr) (Dominion Nuclear North 

Anna, LLC 2006). 

4.9.3 Radiation Exposures from Liquid Effluents 

Dominion used the estimated whole body dose and critical organ dose to the maximally 

exposed individual from liquid effluents in the annual radioactive effluent release report for 

2001 (VEPCo 2002) as a basis to estimate the construction worker dose from liquid effluents 

(Dominion Nuclear North Anna, LLC 2006). The staff determined this approach to be 

acceptable in ESP EIS (NRC 2006). The staff reviewed annual effluent release reports from 

recent years (VEPCo 2006, 2007, 2008) and found the 2001 dose to be typical. The estimated 

TEDE from liquid effluents documented in the ESP ER (Dominion 2006) was 9.8 × 10-3 mSv/yr 

(0.98 mrem/yr). 

4.9.4 Total Dose to the Construction Workers 

The total annual dose to the construction worker was estimated to be 0.29 mSv (29 mrem), 

which is the sum of the three pathways: (1) direct radiation, (2) gaseous effluents, and (3) liquid 

effluents. This dose was greater than the dose estimate of 0.24 mSv/yr (24 mrem/yr) from the 

ESP EIS (NRC 2006). The dose is primarily from the direct exposure pathway, with the doses 

from liquid and gaseous effluents being small. The revised estimate is new but not significant, 

as it is well within both the dose limits to individual members of the public found in 

10 CFR 20.1301 and occupational dose limits to workers found in 10 CFR 20.1201. The 

annual dose limit to an individual member of the public is 1 mSv (100 mrem) TEDE. The annual 

occupational dose limit to workers is 0.05 Sv (5 rem) TEDE. 
Environmental Impacts of Construction 

February 2010 4-29 NUREG-1917, SEIS 

To obtain the estimated annual collective dose to the construction workers, the annual 

estimated dose to one construction worker was multiplied times the maximum number of 

construction workers (i.e., 3500) documented in the COL ER (Dominion 2009a). The estimated 

maximum annual collective dose to construction workers was estimated to be of 1.02 person-Sv 

(102 person-rem). This is less than the approximately 10.5 person-Sv (1050 person-rem) dose 

that construction workers would receive from natural background radiation (i.e., 3500 workers 

times 300 mrem/yr [NCRP 1987, 2009]). 

4.9.5 Summary of Radiological Health Impacts 

Based on the Dominion estimate of dose to construction workers and the NRC’s independent 

review, the staff found the doses to be well within NRC exposure limits designed to protect the 

public health, even if workers exceed the 2080 hrs/yr occupancy factor. Therefore, the staff 

concludes that the impacts of radiological exposures to construction workers would remain 

SMALL, and mitigation is not warranted. 

4.10 Measures and Controls to Limit Adverse Impacts 

During Construction 

Measures and controls to limit adverse impacts during construction were addressed in 

Section 4.10 of the ESP EIS (NRC 2006). These measures and controls have been 

incorporated into the Environmental Protection Plan for the site that is included as Appendix 1A 

of the COL ER (Dominion 2009a). That plan also includes the following additional mitigation 

measures and controls, which were outlined in Section 4.6 of the COL ER: 

• The new transmission lines would be located in an existing transmission line right-of-way 

and constructed under current practices and procedures applicable to new transmission 

lines. 

• Land-clearing activities to accommodate construction of the new transmission tower 

foundations would be controlled by existing Dominion transmission line procedures, good 

construction practices, established BMPs, and applicable regulations. 

• Once construction of the transmission lines has been completed, Dominion would restore 

disturbed areas by the most appropriate means, including restoring all damaged property to 

its original condition to the satisfaction of the property owner. 

• As a safety precaution, during the construction of the transmission lines, access to the 

transmission line right-of-way will be restricted. 

• Clearing methods will be conducted in a manner to protect nature resources and control 

erosion and siltation of streams. Special procedures would be used for clearing trees and 

brush within 30 m (100 ft) of a stream or ditch with running water. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-30 February 2010 

• Potential impacts to streams and creeks would be mitigated by performing work related to 

stream crossings in accordance with standards and specifications by the Commonwealth of 

Virginia. Materials used for temporary crossings of streams and creeks would be removed 

and the landscape restored upon completion of the construction activities. 

• Soil disturbances would be avoided or reduced to the extent possible within 30 m (100 ft) of 

streams and ditches with running water. Erosion and sedimentation control measures would 

be implemented to reduce runoff and erosion. 

• To the extent practicable, construction would avoid alterations to shoreline and wetland 

areas. If wetland areas will be impacted, appropriate Commonwealth and Federal agencies 

will be contacted and necessary permits and approvals will be obtained prior to construction 

activities that would impact the wetland areas. 

• Dust suppression techniques would be utilized along with good equipment maintenance 

practices to reduce airborne emissions from construction-related activities. 

• The discovery of potential historic or cultural resources will result in a stop work and 

appropriate procedures will be followed to notify the Virginia Department of Historic 

Resources. 

4.11 Summary of Construction Impacts 

Impact level categories identified during the evaluation of the ESP application are documented 

in Table 4-1 of the ESP EIS (NRC 2006). In that table, the expected environmental impact 

levels for each category are designated as SMALL, MODERATE, or LARGE. The staff’s review 

of information available during the site audit and from other information sources did not identify 

information that would change its conclusion and, therefore, the designation for any of the 

categories in Table 4-1. Some impacts, such as the addition of tax revenue from Dominion for 

the local economies, are still likely to be beneficial impacts to the community even though one 

new nuclear unit would be constructed as a result of this action compared to two nuclear units 

evaluated for the ESP application (Dominion Nuclear North Anna, LLC 2006). 

4.12 References 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection against Radiation.” 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800, “Protection of Historic and Cultural Properties.” 
Environmental Impacts of Construction 

February 2010 4-31 NUREG-1917, SEIS 

40 CFR Part 761. Code of Federal Regulations, Title 40, Protection of Environment, Part 761, 

“Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and 

Use Prohibitions.” 

72 FR 37346. “Endangered and Threatened Wildlife and Plants; Removing the Bald Eagle in 

the Lower 48 States from the List of Endangered and Threatened Wildlife.” Vol. 72, No. 130. 

July 9, 2007. 

72 FR 49352. “Licenses, Certifications, and Approvals for Nuclear Power Plants; Final Rule.” 

Vol. 72, No. 166. August 28, 2007. 

Clean Water Act. 33 USC 1251, et seq. (also referred to as the Federal Water Pollution Control 

Act [FWPCA].) 

Dominion Nuclear North Anna LLC. 2006. North Anna Early Site Permit Application. 

Revision 9, Glen Allen, Virginia. Accession No. ML062580096. 

Dominion Virginia Power (Dominion). 2007. Letter from Tony Banks, (Dominion Virginia 

Power) Project Lead-Environmental, to Dr. Ethel Eaton, Virginia Department of Historic 

Resources, “Dominion Combined License Project North Anna Station Supplemental 

Archaeological Survey,” October 11, 2007. Accession No. ML082910714. 

Dominion Virginia Power (Dominion). 2008a. Letter from Eugene S. Grecheck (Dominion 

Virginia Power, Vice President) to the U.S. Nuclear Regulatory Commission, “Dominion Virginia 

Power, North Anna Unit 3 Combined License Application, Response to Request for Additional 

Information Regarding the Environmental Review,” Letter to the U.S. Nuclear Regulatory 

Commission, July 17, 2008. Accession No. ML082620236. 

Dominion Virginia Power (Dominion). 2008b. Email from Tony Banks (Dominion Virginia 

Power) to Alicia Williamson, Laura Quinn (U.S. Nuclear Regulatory Commission) and William F. 

Sandusky (Pacific Northwest National Laboratory), “Subject: “NAPS Unit 3 COL Application – 

NRC’s Environmental Review Supplemental Information Needs, #1, #2, #7, and #18 (regarding 

wildlife, sediment control, and radiation monitoring) – 06/27/08 E-mail 1 of 1.” June 27, 2008. 

Accession No. ML081960657. 

Dominion Virginia Power (Dominion). 2008c. Letter from Eugene S. Grecheck (Dominion 

Virginia Power, Vice President) to the U.S. Nuclear Regulatory Commission, “Dominion Virginia 

Power North Anna Unit 3 Combined License Application Response to Request for Supplemental 

Information.” August 1, 2008. Accession No. ML082190839. 

Dominion Virginia Power (Dominion). 2008d. North Anna 3 Combined License Application. 

Revision 1, December 2008. Accession No. ML090570781. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-32 February 2010 

Dominion Virginia Power (Dominion). 2009a. North Anna 3 Combined License Application, 

Part 3: Environmental Report – Combined License Stage. Revision 2, July 2009. Accession 

No. ML092160490. 

Dominion Virginia Power (Dominion). 2009b. Letter from Eugene S. Grecheck (Dominion 

Nuclear Development, Vice President) to the U.S. Nuclear Regulatory Commission, “Dominion 

Virginia Power North Anna Unit 3 Combined License Application Environmental Report 

Supplemental Information.” December 16, 2009. Accession No. ML100350733. 

Federal Highway Administration (FHWA). 2006. FHWA Highway Construction Noise 

Handbook. Accessed October 14, 2008, at 

http://www.fhwa.dot.gov/environMent/noise/handbook/index.htm. Accession No. ML083260828. 

Louisa County. 2009. “County of Louisa Minutes of the Board of Supervisors, May 18, 2009.” 

Accessed at www.louisacounty.com/LCbos/min051809.htm on September 22, 2009. 

Accession No. ML093210597. 

Louisa County Public Schools. 2009. “Moss-Nuckols Elementary School Updates.” Accessed 

at www.lcps.k12.va.us/education/components/scrapbook/default.php?sectiondetailid=10171 on 

October 26, 2009. Accession No. ML093210594. 

National Council on Radiation Protection and Measurements (NCRP). 1987. Ionizing Radiation 

Exposure of the Population of the United States. NCRP Report No. 93. National Council on 

Radiation Protection and Measurements, Bethesda, Maryland. 

National Council on Radiation Protection and Measurements (NCRP). 2009. Ionizing Radiation 

Exposure of the Population of the United States. NCRP Report No. 160. National Council on 

Radiation Protection and Measurements, Bethesda, Maryland. 

National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq. 

National Historic Preservation Act of 1966 (NHPA). 16 USC 470, et seq. 

Saricks, C.L. and M.M. Tompkins. 1999. State-Level Accident Rates for Surface Freight 

Transportation: A Reexamination. ANL/ESD/TM-150, Argonne National Laboratory, Argonne, 

Illinois. 

U.S. Census Bureau (USCB). 2008. “2008 Population Estimates, Louisa County Virginia, 

T6-2008, Sex By Age.” Accessed September 22, 2009 at 

factfinder.census.gov/...edoLog=false&-all_geo_types=N&-geo_id=05000US51109&-

search_results=01000US&-format=&-_lang=en. Accession No. ML093210598. 
Environmental Impacts of Construction 

February 2010 4-33 NUREG-1917, SEIS 

U.S. Department of Transportation (DOT). 2008a. Virginia, Toll of Motor Vehicle Crashes, 

2006. Accessed on April 10, 2008 at http://www-nrd.nhtsa.dot.gov/departments/nrd30/ncsa/STSI/USA%20WEB%20REPORT.HTM. Accession No. ML083250667. 

U.S. Department of Transportation (DOT). 2008b. Traffic Safety Facts, Louisa County, Virginia, 

2003 to 2007. Accessed on September 24, 2008 at http://wwwnrd.nhtsa.dot.gov/departments/nrd-30/ncsa/STSI/USA%20WEB%20REPORT.HTM. Accession 

No. ML08325076. 

U.S. Environmental Protection Agency (EPA). 1979. EPA Bans PCB Manufacture; Phases Out 

Uses. Accessed November 8, 2008 at http://www.epa.gov/history/topics/pcbs/01.htm. 

Accession No. ML083260462. 

U.S. Fish and Wildlife Service (USFWS). 2008. National Bald Eagle Management Guidelines. 

Accessed July 15, 2008 at 

http://www.fws.gov/migratorybirds/issues/BaldEagle/NationalBaldEagleManagementGuidelines.

pdf. Accession No. ML083260017. 

U.S. Nuclear Regulatory Commission (NRC). 2006. Environmental Impact Statement for an 

Early Site Permit (ESP) at the North Anna ESP Site – Final Report. NUREG-1811, Vol. 1, 

Washington, D.C. Accession Nos. ML063480261 and ML063480263. 

U.S. Nuclear Regulatory Commission (NRC). 2007. North Anna Early Site Permit 

No. ESP-003. Washington, D.C. Accession No. ML073180440. 

Virginia Department of Conservation and Recreation (VDCR). 2009. Letter from Ms. Rene 

Hypes to Michael Sackschewsky, Pacific Northwest National Laboratory. Subject: North Anna 

Power Station Unit 3 – North Anna 3 Project Site, Construction Staging Area, and North Anna to 

Ladysmith Transmission Corridor. September 29, 2009. Accession No. ML093160317. 

Virginia Department of Education. 2009. “Data & Reports: Virginia Education Statistics.” 

Richmond, Virginia. Accessed at www.doe.virginia.gov/VDOE/Publications/ on October 26, 

2009. Accession No. ML093210601. 

Virginia Department of Environmental Quality (VDEQ). 2007. Fish Tissue and Sediment 

Monitoring Program, DEQ 2006 Sediment PCBs Results. Accessed on October 2, 2008 at 

http://www.deq.state.va.us/fishtissue/. Accession No. ML083260501. 
Environmental Impacts of Construction 

NUREG-1917, SEIS 4-34 February 2010 

Virginia Department of Historic Resources (VDHR). 2007. Letter from Roger Kirchen, Office of 

Review and Compliance, Virginia Department of Historic Resources, to Tony Banks, Dominion 

Resource Services, Inc., “Supplemental Archeological Survey, Dominion Combined License 

Project, North Anna Power Station, Louis County, Virginia.” November 7, 2007. Accession 

No. ML082910712. 

Virginia Department of Transportation (VDOT). 2009. “Spotsylvania Courthouse Bypass, 

Phase II.” Accessed at 

www.vdot.virginia.gov/projects/fredericksburg/spotsylvania_ch_bypass.asp on October 20, 

2009. Accession No. ML093160828. 

Virginia Economic Development Partnership (VEDP). 2006. “The Estimated Impact of an 

Expansion of the North Anna Power Station on Virginia”. Summary prepared for the Virginia 

Economic Development Partnership, 11-14-2006, Richmond, Virginia. 

Accession No. ML093210604. 

Virginia Electric and Power Company (VEPCo). 2002. Annual Radioactive Effluent Report 

North Anna Power Station (January 1, 2001 to December 31, 2001). Richmond, Virginia. 

Accession No. ML021230068. 

Virginia Electric and Power Company (VEPCo). 2006. Annual Radioactive Effluent Report 

North Anna Power Station (January 1, 2005 to December 31, 2005). Richmond, Virginia. 

Accession No. ML061160297. 

Virginia Electric and Power Company (VEPCo). 2007. Annual Radioactive Effluent Report 

North Anna Power Station (January 1, 2006 to December 31, 2006). Richmond, Virginia. 

Accession No. ML071210179. 

Virginia Electric and Power Company (VEPCo). 2008. Annual Radioactive Effluent Report 

North Anna Power Station (January 1, 2007 to December 31, 2007). Accession 

No. ML081280632. 
February 2010 5-1 NUREG-1917, SEIS 

5.0 Environmental Impacts of Operation 

This chapter examines environmental issues associated with operation of the proposed Unit 3 

nuclear reactor at the North Anna Power Station (NAPS) site for an initial 40-year period as 

described by Dominion Virginia Power and the Old Dominion Electric Cooperative, collectively 

known as Dominion. As part of its application for a combined license (COL), which 

encompasses a construction permit and an operating license, Dominion submitted an 

Environmental Report (ER) that discussed the environmental impacts of station operation 

(Dominion 2009a). This chapter is divided into 13 sections. Sections 5.1 through 5.12 discuss 

the potential operational impacts on land use, meteorology and air quality; water, terrestrial and 

aquatic ecosystems; socioeconomics; historic and cultural resources; environmental justice; 

nonradiological and radiological health effects; postulated accidents; global warming, climate 

change, and greenhouse gas impacts; and applicable measures and controls that would limit 

the adverse impacts of station operation during the 40-year operating period. 

In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 51, impacts have 

been analyzed and a significance level of potential adverse impacts (i.e., SMALL, MODERATE, 

or LARGE) has been assigned to each analysis. In the area of socioeconomics related to taxes, 

the impacts may be considered beneficial and are stated as such. Because the NAPS site has 

an approved early site permit (ESP), the significance levels of the potential adverse impact for 

the various areas evaluated remain the same as documented in the ESP environmental impact 

statement (EIS) (NRC 2006) unless new and significant information has been identified that 

would have the potential to affect the findings or conclusions reached in the ESP EIS. The 

definition of new and significant information is documented in a Federal Register notice 

(72 FR 49352). 

In the course of its evaluation, the U.S. Nuclear Regulatory Commission (NRC) staff (1) met 

with Dominion staff, its contractors, and State and local officials; (2) conducted an independent 

evaluation of subject areas not covered in the ESP EIS, unresolved issues, and new and 

significant information; and (3) reviewed Dominion’s implementation of its process for identifying 

new and significant information, which the staff determined was adequate. While developing 

the SEIS, the staff also reviewed public comments it received and contacted Federal, State, 

Tribal, regional, and local agencies to solicit comments. Documents related to the NAPS site 

were reviewed and are listed as references where appropriate. All of the information collected 

through these processes was used in developing this SEIS. 

The NRC staff’s findings and conclusions are based on the assumption that the mitigation 

measures identified in the ER or activities planned by various Commonwealth and county 

governments, such as infrastructure upgrades, as discussed throughout this chapter, are 

implemented. Failure to implement these upgrades might result in greater impacts. Possible 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-2 February 2010 

mitigation of adverse impacts also is presented, where appropriate. A summary of these 

impacts is presented in Section 5.13. The references cited in this chapter are listed in 

Section 5.14. 

5.1 Land-Use Impacts 

Sections 5.1.1 and 5.1.2 contain information regarding land-use impacts associated with 

operation of proposed Unit 3 at the NAPS site. Section 5.1.1 discusses land-use impacts at 

the NAPS site and in the vicinity of the site. Section 5.1.2 discusses land-use impacts with 

respect to offsite transmission line rights-of-way. 

5.1.1 The Site and Vicinity 

Operational land-use impacts at the NAPS site and in the vicinity of the site are described 

in Section 5.1.1 of the ESP EIS (NRC 2006). New information identified by the staff related to 

Section 5.1.1 is that, with this request, one new nuclear unit is considered by Dominion for the 

NAPS site. This information reduces land-use impacts at the site and does not change the 

impact characterization in Section 5.1.1 of the ESP EIS. 

The staff did not identify information that was both new and significant related to operations 

impacts on land use through its evaluation of the information provided by Dominion and the 

NRC staff’s own independent review. The staff concludes that the land-use impacts of 

operations would remain SMALL, and additional mitigation is not warranted. 

5.1.2 Offsite Transmission Line Rights-of-Way 

Operational land-use impacts associated with offsite transmission line rights-of-way are 

discussed in Section 5.1.2 of the ESP EIS (NRC 2006). The only new information identified by 

the staff related to Section 5.1.2 is that Dominion’s COL ER (Dominion 2009a) states that a 

2007 study by PJM Interconnection, LLC (Dominion 2009a) concluded that a new 500-kV 

transmission line from NAPS to the Ladysmith Substation would be needed for grid stability with 

the interconnection of the proposed Unit 3. The new transmission line would be installed on 

new towers in the existing NAPS to Ladysmith right-of-way, which runs to the east from the 

NAPS site. The right-of-way is approximately 84 m (275 ft) wide and 24 km (15 mi) long. 

Because the new transmission line would be built entirely in the existing right-of-way, with no 

widening, the staff concludes that the changes in the information related to land-use are minor, 

and have no potential to change the staff’s impact characterization in the ESP EIS. 

The NRC staff did not identify information that was both new and significant related to the 

operations impacts on land use through its evaluation of the information provided by Dominion 
Environmental Impacts of Operation 

February 2010 5-3 NUREG-1917, SEIS 

and the staff’s own independent review. The staff concludes that the land use impacts of 

operating offsite transmission line rights-of-way would remain SMALL, and additional mitigation 

is not warranted. 

5.2 Meteorological and Air-Quality Impacts 

As noted in the ESP EIS (NRC 2006), the proposed cooling systems for NAPS include a closedcycle, combination wet and dry cooling system for the proposed Unit 3. The meteorological and 

air-quality impacts from operation of the proposed Unit 3 would be limited to those resulting from 

the cooling system and periodic pollutant emissions from auxiliary boilers and generators that 

support the proposed Unit 3. 

ESP EIS (NRC 2006) notes that significant chemical interaction of the cooling tower plume and 

pollutants emitted onsite or in the vicinity of the plant are not anticipated. Also, these values are 

bounded by values presented in the ESP EIS (NRC 2006). In general, the approach to 

minimizing the potential for contact with cooling tower drift is to limit parking or work activities in 

the vicinity of the cooling towers. Air-quality impacts from routine releases other than the 

cooling system would be limited to nonradiological pollutants emitted during the operation of 

auxiliary boilers and emergency generators, and emissions from onsite service vehicles. With 

regard to air-quality impacts for criteria pollutants, given the distance from the Prevention of 

Significant Deterioration Class I areas (see the Clean Air Act, Section 169A, and 40 CFR 

Part 51, Subpart P) and the short duration of emissions, the resulting impacts on local ambient 

air-quality levels or visibility in the Class I areas are estimated to be negligible. 

The impact of transmission lines on air quality was addressed in Section 5.2 of the ESP EIS 

(NRC 2006). Since preparation of the ESP EIS, Dominion has determined that additional 

transmission lines will be required to support the operation of the proposed Unit 3. This is 

considered new information, but the impact on air quality is not considered to be significant 

given the anticipated size of the additional lines, the length of the lines, and the results of a 

previous evaluation of transmission lines on air quality (NRC 1996). In addition, because only 

one unit is being constructed, the anticipated emission of pollutants from auxiliary boilers and 

emergency generators will be less than anticipated in the ESP EIS. The NRC staff did not 

identify information that was both new and significant related to the operational impacts on 

meteorology and air quality through its evaluation of the information provided by Dominion and 

the staff’s own independent review. The staff concludes that the meteorology and air-quality 

impacts of operation would remain SMALL, and additional mitigation is not warranted. 

5.3 Water-Related Impacts 

This section describes the potential water-related impacts associated with operation of the 

proposed Unit 3 at the NAPS site. An overview of two proposed units (Units 3 and 4) and a 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-4 February 2010 

detailed discussion of operations-related impacts on water use and water quality are provided in 

Section 5.3 of the ESP EIS, with supporting analysis in Appendix K of ESP EIS (NRC 2006). 

Dominion’s COL application (Dominion 2008a) is for construction of only one unit (Unit 3), using 

the Economic Simplified Boiling-Water Reactor (ESBWR) design with a closed-loop hybrid 

cooling system that employs wet and dry cooling depending on operating conditions (see 

description in Chapter 3 of this SEIS). In the following sections, the NRC staff summarizes the 

impacts described in the ESP EIS, evaluates new information available for review since 

preparation of the ESP EIS, and determines whether there are any changes to the impact levels 

determined at the ESP stage. 

5.3.1 Hydrological Alterations 

The information and associated impacts for this section are provided and resolved in 

Section 5.3.1 of the ESP EIS (NRC 2006). Based on the staff’s analysis, operations-related 

impacts of hydrological alterations were considered to be SMALL. New information available 

since preparation of the ESP EIS includes changes to onsite drainage, the cofferdam design, an 

increase in the affected land area associated with new land acquisition, and the recent Instream 

Flow Incremental Methodology (IFIM) study. The staff determined that standard best 

management practices for stormwater management would be adequate to mitigate any 

stormwater environmental impacts. The cofferdam design will not appreciably alter the flow 

regime in the vicinity of the intake. 

The NRC staff did not identify information that was both new and significant to operation-related 

impacts from hydrologic alterations in its evaluation of information provided by Dominion and the 

staff’s independent review. The staff concludes that impacts of hydrological alterations from 

operation of the proposed Unit 3 would remain SMALL, and further mitigation beyond the 

actions stated is not warranted. 

5.3.2 Water-Use Impacts 

The information and associated impacts for this section are provided and resolved in 

Section 5.3.2 of the ESP EIS (NRC 2006). The staff concluded that water-use impacts caused 

by operation of the proposed Unit 3 would be SMALL in normal years and MODERATE in 

drought years. New information available since preparation of the ESP EIS includes updated 

withdrawal rates, consumptive water use, and blowdown flow rates, as well as the results of the 

Instream Flow Incremental Methodology (IFIM) study (Dominion 2009b). 

Based on the bounding parameters provided in the ESP application (Dominion Nuclear North 

Anna, LLC 2006a), the NRC staff performed an independent assessment of the water budget of 

Lake Anna and the North Anna River downstream of the lake (NRC 2006). Based on moredetailed information from Dominion, the consumptive water use for the proposed Unit 3 is within 

the plant parameter envelope (PPE) range stated in the ESP application. 
Environmental Impacts of Operation 

February 2010 5-5 NUREG-1917, SEIS 

Based on the detailed plant system design, Dominion provided slightly revised values for water 

use parameters for two operating modes (Dominion 2009a). These values were within the PPE 

values described in the ESP ER (Dominion Nuclear North Anna, LLC 2006a) and provided in 

Appendix I of this SEIS. The plant would primarily use wet towers to cool Unit 3 during periods 

of relative water surplus, which are defined as periods when the water surface elevation of Lake 

Anna is at or above elevation 76.2 m (250.0 ft) above mean sea level (MSL). This cooling mode 

for the proposed Unit 3 is termed the Energy Conservation (EC) mode, and in this mode, the 

estimated makeup water flow rate is 1404 L/s (22,260 gpm) (Dominion 2009a). 

For its assessment of impacts on water supply, Dominion assumed that Unit 3 would be cooled 

with a closed-cycle, combination wet and dry cooling tower system to limit consumptive water 

use when the elevation of Lake Anna is below 76.2 m (250.0 ft) MSL for a period of 7 or more 

consecutive days. Dominion terms this cooling mode the Maximum Water Conservation (MWC) 

mode; the estimated makeup water flow rate is 970.1 L/s (15,376 gpm) in MWC mode 

(Dominion 2009a). The recent IFIM study evaluated a scenario in which the normal pool level of 

Lake Anna was increased to 76.3 m (250.25 ft). This scenario would increase the frequency 

that the proposed Unit 3 would be in EC mode, resulting in a slightly higher water consumption 

rate than that considered in the ESP EIS (NRC 2006). Under the existing pool elevation of 

250 ft MSL, the annual average Unit 3 evaporation rate would be 566.4 L/s (8977 gpm); if the 

pool elevation increases to 76.3 m (250.25 ft) MSL, the annual average Unit 3 evaporation rate 

would be 611.7 L/s (9695 gpm), or approximately 8 percent increase. The exact conditions 

under which the proposed Unit 3 would switch from EC to MWC mode would be established by 

Virginia Department of Environmental Quality (VDEQ) at the time of permitting.

The staff did not identify information that was both new and significant to operation-related 

impacts to water use in its evaluation of information provided by Dominion and the staff’s 

independent review. The staff concludes that water-use impacts caused by operation of the 

proposed Unit 3 would remain SMALL in normal years and MODERATE in drought years. 

5.3.3 Water-Quality Impacts 

The information and associated impacts for this section are provided in Section 5.3.3 of the 

ESP EIS (NRC 2006). In the ESP EIS, the staff concluded that water-quality impacts resulting 

from operation of the proposed Unit 3 were unresolved but were expected to be SMALL. The 

water-quality impacts were unresolved at the ESP stage because without a specific design, 

Dominion could not provide specific information on water treatment systems. However, 

adequate information was available at the ESP stage to evaluate the thermal impacts. 

Dominion considered the rise in lake temperatures caused by Unit 3 operations and found that 

the average temperature rise in Lake Anna would be less than 0.06oC (0.1oF). The staff 

independently reviewed the analyses and agreed with the assessment (NRC 2006). The NRC 

staff did not identify information that was both new and significant related to thermal discharges 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-6 February 2010 

to Lake Anna. Thus, the staff concluded that impacts of releases during proposed Unit 3 

operation on the thermal aspect of water quality remain SMALL.

New information available since preparation of the ESP EIS includes additional information on 

the ambient water quality in Lake Anna, a description of plant water treatment methods and 

chemical additives, blowdown flow rates, and expected chemical concentrations in the plant 

discharge. 

The COL ER (Dominion 2009a) describes the chemical additives in the water treatment system 

and expected concentrations of pollutants in effluent associated with Unit 3. In its COL ER, 

Dominion stated that the new onsite sanitary waste treatment system will comply with industry 

design standards and its effluent will be regulated and monitored under a Virginia Pollutant 

Discharge Elimination System (VPDES) permit (VDEQ 2001, 2007) and 9 VAC 25-790 (Sewage 

Collection and Treatment Regulations, Commonwealth of Virginia, State Water Control Board). 

Treated effluent from the proposed new sanitary plant would be combined with Unit 3 plant 

discharges in the blowdown sump before discharging to the Waste Heat Treatment Facility 

(WHTF) (Dominion 2009a). As discussed in Section 3.2.4.1 of this SEIS, Unit 3 plant effluent 

(service water and circulating water cooling tower blowdown) will contain low levels of chemicals 

and/or biocides that are used for water treatment. None of these chemicals will contain any of 

the 126 priority pollutants listed in 40 CFR 423, Appendix A. 

The effluent streams from the proposed Unit 3 will include some of these priority pollutants 

because they are already present in the ambient waters of Lake Anna. Evaporation of water 

during operation of Unit 3 is expected to concentrate pollutants four to nine times relative to 

ambient lake water (Dominion 2008a). Although the estimated effluent concentrations of most 

pollutants provided in the COL ER did not exceed state water-quality criteria, copper (from past 

mining operations) and tributyltin (used in paint for marine applications) in Lake Anna are 

already at or above water-quality criteria. Therefore, evaporation during operation of the 

proposed Unit 3 would likely concentrate these chemicals enough so that the effluent entering 

into the discharge canal would exceed water-quality criteria. However, once the proposed 

Unit 3 discharge is released, it will be rapidly diluted with the much larger volume of water 

discharged from Units 1 and 2. This dilution would occur in the discharge canal and before 

entering the WHTF. Additional dilution would occur in the WHTF and Lake Anna. 

Discharge water-quality parameters for the proposed Unit 3 are within (equal to or less than) the 

range of PPE values evaluated for the ESP. Based on the above assessment of the current 

operational parameters for the proposed Unit 3, the NRC staff concludes that the impacts of 

operating the proposed Unit 3 on water quality would remain SMALL. Pollutant discharges 

would be regulated under a VPDES permit issued by the Commonwealth of Virginia. 
Environmental Impacts of Operation 

February 2010 5-7 NUREG-1917, SEIS 

5.4 Ecological Impacts 

This section describes the potential impacts to ecological resources from the operation of the 

proposed Unit 3 and discusses impacts to terrestrial and aquatic ecosystems and to threatened 

and endangered species. 

5.4.1 Terrestrial Ecosystem 

The information and associated impacts for this section are provided and resolved in 

Section 5.4.1 of the ESP EIS (NRC 2006). Based on the staff’s analysis, operations-related 

impacts to terrestrial ecosystems were considered to be SMALL. Information available since 

preparation of the ESP EIS include updated analyses of the potential impacts of salt drift, vapor 

plumes, fogging and icing, and noise associated with operation of the cooling towers, as well as 

information about the operation and maintenance impacts associated with the new transmission 

line connecting the NAPS site to the Ladysmith Substation. After issuance of the draft SEIS, 

additional information concerning the results of the IFIM study and Dominion’s acquisition of 

38.8 ha (96 ac) of adjacent property were made available to the staff. The IFIM study results 

related to wetlands are considered in Section 5.4.1.4 below. The new property would be used for 

temporary construction support; the operation of Unit 3 is expected to have little to no impact to 

terrestrial resources on the new property and is not considered further in this section. 

5.4.1.1 Cooling Tower Impacts on Terrestrial Ecological Resources 

Salt Drift 

Dominion evaluated the potential effects of salt deposition, vapor plumes, fogging, and icing 

using the Seasonal and Annual Cooling Tower Impacts (SACTI) computer code, which is a 

system of computer programs initially written and assembled by the Argonne National 

Laboratory for the Electric Power Research Institute (ANL 1984). Salt deposition effects to 

surrounding vegetation were evaluated in the ESP EIS (NRC 2006). At that time, it was 

estimated that deposition would be less than 1 kg/ha/month, and the staff concluded that 

impacts resulting from this deposition would be minimal. During the site audit in April 2008, the 

staff reviewed the results from updated simulations of the salt deposition based on the currently 

proposed tower design, and found that deposition rates were still well below levels considered 

to be damaging to vegetation. In addition, the staff determined that there are no important 

species or habitats as defined by NRC (2000a) that would be affected by cooling tower drift at 

the NAPS site. Therefore, the staff found no new and significant information regarding salt drift, 

and concludes that salt drift effects on surrounding vegetation would remain SMALL, and 

mitigation is not warranted. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-8 February 2010 

Vapor Plumes and Icing 

The staff evaluated the environmental impact of fogging, icing, and vapor plumes in the 

ESP EIS (NRC 2006). In the ESP EIS, the staff determined that operation of the cooling tower 

would have a minimal effect on fogging, icing, and vapor plumes. Since the preparation of the 

ESP EIS, the staff reviewed the results from updated simulations based on the proposed design 

of the cooling tower, and determined that the ESP EIS analysis was bounding on the current 

potential impacts. Therefore, the staff’s conclusion that the potential impacts of fogging, icing, 

and vapor plumes will be SMALL remains unchanged, and mitigation is not warranted. 

5.4.1.2 Noise 

Maximum noise levels from the operation of the reactors and combination wet and dry cooling 

towers would be similar to current noise levels at the NAPS site to which local species are 

adapted. In the ESP EIS (NRC 2006), the staff determined that noise levels at the NAPS 

site are occasionally as high as 100 decibels (measured at the security fence during outages), 

but they are typically less than 80 to 85 dBA, which is the level at which birds and small 

mammals are startled or frightened (Golden et al. 1979). More likely, the noise level would be 

65 dBA or lower, and noise levels from operation of the cooling towers would be less than 

65 decibels at the exclusion area boundary. Since the preparation of the ESP EIS, Dominion 

reassessed the potential noise levels based on the proposed cooling tower design and the 

proposed service water towers, and found that the maximum noise level is still less that 65 dBA. 

The staff reviewed the reanalysis and found that the new information regarding noise levels 

does not change the staff’s conclusion that noise impacts to terrestrial ecological resources 

would remain SMALL, and mitigation is not warranted. 

5.4.1.3 Avian Collisions 

The heights of the proposed facilities presented in the COL ER (Dominion 2009a), including the 

reactor building and the cooling towers, are within the PPE evaluated in the ESP EIS (NRC 2006), 

and the staff found no new information regarding avian collisions at the NAPS site. Dominion 

continues to follow a migratory bird protection program, including protection of nests and reporting 

of bird (especially raptor) strikes and other events (Dominion 2001). Therefore, the staff found 

that new information regarding the height of the proposed facilities does not change the staff’s 

conclusions that impacts to bird populations from collisions with heat dissipation and other facility 

structures would remain SMALL, and mitigation is not warranted. 

5.4.1.4 Shoreline and Riparian Habitat 

The staff evaluated the potential impacts to the shoreline of Lake Anna and the North Anna 

River downstream from the NAPS site in the ESP EIS (NRC 2006). In that analysis, the staff 

determined that Lake Anna would, on occasion, experience extended periods of lowered lake 
Environmental Impacts of Operation 

February 2010 5-9 NUREG-1917, SEIS 

elevation and discharge to the North Anna River, but these events would not have long-lasting 

impacts to the shoreline and riparian plant and animal communities. Dominion evaluated the 

impacts of lake level changes on shoreline and wetland vegetation as part of its IFIM study 

(Dominion 2009b). The IFIM study included an evaluation of raising the normal pool level of 

Lake Anna to 76.3 m (250.25 ft) from the current 76.2 m (250.0 ft), and the effect of that change 

on wetland communities along the shoreline and along the lake tributaries. The study 

concluded that even if the pool level were increased by a nominal 8 cm (3 in), the actual 

increase during most of the growing season would be less than that amount and would be within 

the inundation tolerance of the existing vegetation and wetland communities. Without the 

increase in pool level, operation of Unit 3 would decrease the lake level below current conditions 

during the growing season, but the elevation change would be similar to that evaluated in the 

ESP EIS (NRC 2006). An increase in operating pool level would result in fewer and shorter 

periods of very low flow (20 cfs) downstream from North Anna Dam. Without the increase in 

operating pool level, the addition of Unit 3 with the proposed wet/dry cooling system would 

slightly increase the number and duration of low-flow events, but these would be within the 

range evaluated in the ESP EIS (NRC 2006). Therefore, the staff’s conclusion that impacts 

regarding shoreline and riparian habitat would be SMALL is unchanged, and mitigation is not 

warranted. 

5.4.1.5 Transmission Line Rights-of-Way 

The vegetation in the existing NAPS to Ladysmith transmission line right-of-way is managed 

primarily through a combination of selective cutting and herbicide treatments, with about 

10 percent of the right of way being mowed. Dominion has procedures in place to protect 

sensitive habitat areas such as wetlands and stream crossings, and it attempts to maintain 

vegetative buffers in these areas. Although no rare or sensitive plant species are known to 

occur within the NAPS to Ladysmith transmission line right-of-way, Dominion has procedures in 

place to ensure that such species are identified and avoided, and that modified treatment 

practices are used to avoid adverse impacts. These modified vegetation treatments are 

developed in cooperation with the Virginia Department of Conservation and Recreation (VDCR) 

Natural Heritage Program (NRC 2002). 

The right-of-way for the transmission line from NAPS to the Ladysmith Substation has been 

maintained as a transmission line right-of-way for a number of years, and the addition of another 

set of towers and conductors within the existing right-of-way is not likely to significantly alter the 

maintenance practices or impacts. Therefore, the staff concludes that the effect of maintenance 

of the transmission line right-of-way on terrestrial resources would be SMALL, and mitigation is 

not warranted. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-10 February 2010 

5.4.1.6 Summary of Terrestrial Ecosystems Impacts 

The staff considered potential impacts to terrestrial ecological resources of operating the 

proposed Unit 3, including salt drift; fogging; icing; noise; avian collisions; changes to shoreline, 

riparian, and wetland habitat; and transmission line rights-of-way. The staff did not identify 

information that was both new and significant related to the operation impacts on terrestrial 

resources through its evaluation of information provided by Dominion and the staff’s independent 

review. The staff concludes that the operational impacts on terrestrial ecological resources of 

Unit 3, and the maintenance of the NAPS to Ladysmith transmission right-of-way would be 

SMALL, and mitigation is not warranted. 

5.4.2 Aquatic Impacts 

The information and associated impacts for this section are provided and resolved in 

Section 5.4.2 of the ESP EIS (NRC 2006). Based on the staff’s analysis, the impacts 

associated with the operation of the proposed units would increase impingement and 

entrainment losses by up to 3 percent relative to the losses related to operation of the 

existing Units 1 and 2. Thermal impacts (cold shock, heat stress) and physical impacts to 

aquatic resources related to operation of the proposed Units 3 and 4 were expected to be 

negligible because of the negligible increase in water withdrawal and heat load attributable to 

Unit 3. In the ESP EIS, the staff also determined that although the operation of the proposed 

Units 3 and 4 would increase the percentage of time that the reservoir surface elevation would 

be at or below 75.6 m (248 ft) above mean sea level, the associated flow reductions over the 

North Anna Dam would not likely occur during critical spawning periods for downstream fish 

communities. The staff’s overall conclusion was that impacts on Lake Anna and downstream 

aquatic communities would be SMALL and mitigation would not be warranted (NRC 2006). The 

staff reviewed information made available since preparation of the ESP EIS as it relates to 

impacts of operation on aquatic resources to determine whether changes to the previously 

determined impact levels were warranted. 

5.4.2.1 Intake and Discharge Systems 

As described in Section 3.4, the intake design proposed by Dominion since preparation of the 

ESP EIS includes the installation of five box culverts in the existing cofferdam, each with a width 

of 3.7 m (12 ft) and a height of 3.1 m (10 ft). The proposed intake structure, as described by 

Dominion (2008a), will include three pump/screen bays, each equipped with a trash rack and a 

dual-flow traveling screen that includes a 2.4-m (8-ft)-wide basket with 2-mm (0.08-in.) mesh 

size. The maximum flow velocity into the trash racks at the intake structure opening is designed 

to be less than 0.15 m/sec (0.5 ft/sec). The flow velocity through the box culverts connecting 

Lake Anna with the intake approach channel is designed to be approximately 0.03 m/s (0.1 ft/s), 

similar to the velocity in Lake Anna. This is intended to minimize entrainment of debris, 

sediment, and aquatic life. The approach channel is designed to slow the flow to approximately 
Environmental Impacts of Operation 

February 2010 5-11 NUREG-1917, SEIS 

0.003 m/s (0.01 ft/s) before water reaches the pump screens. The design flow velocity at the 

pump screens is less than 0.15 m/s (0.5 ft/s). Based on this design, shoreline erosion and other 

physical impacts (scouring, increased turbidity) associated with operation of the proposed Unit 3 

intake are expected to be negligible. Similarly, the maximum blowdown rate for the proposed 

Unit 3 (350 L/s [12.4 cfs]) is essentially unchanged from the ESP estimates of the COL ER 

(Dominion 2009a). Therefore, the physical impacts associated with discharges from the 

proposed Unit 3 intake are still considered to be negligible. 

5.4.2.2 Impingement and Entrainment 

Based on the information in the COL ER (Dominion 2009a), the maximum makeup water flow 

rates for the proposed Unit 3 is expected to be 970.1 L/s (15,376 gpm) under Maximum Water 

Conservation mode, and 1404 L/s (22,260 gpm) under Energy Conservation mode. Recent 

information from Dominion (Dominion 2009a) confirms these estimates, and indicates the 

addition of the proposed Unit 3, as described in Dominion (2008a), will increase water 

withdrawal from Lake Anna by approximately 1 percent compared to the current withdrawals by 

Units 1 and 2. A similar conclusion was reached in the ESP EIS (NRC 2006). 

As described in Section 5.4.2 of the ESP EIS (NRC 2006), Dominion determined that the 

operation of Unit 3 at 100-percent pumping capacity would increase average yearly 

impingement losses from Lake Anna from 182,440 individuals due to operation of Units 1 and 2 

to 187,880 with the addition of the proposed Unit 3, or approximately 3 percent (NRC 2006). 

Similarly, overall yearly entrainment during spawning months would increase from about 

149 million larvae to about 153 million larvae, or approximately 2 percent (NRC 2006). Using 

this information, the staff concluded in the ESP EIS that the impacts of both impingement and 

entrainment of Unit 3 operations in addition to the losses from Units 1 and 2 would be negligible 

(NRC 2006). 

The NRC staff reviewed environmental monitoring data for Lake Anna and the North Anna River 

made available since preparation of the ESP EIS. These data were derived from reports that 

include a summary of existing conditions and an evaluation of trends over at least a 10-year 

period (Dominion Nuclear North Anna, LLC 2006b; Dominion 2008b). The results of the staff 

review are summarized in Section 2.7.2 and suggest that the fish populations of Lake Anna and 

the North Anna River have generally remained stable over the past decade. Because the 

makeup water requirements for the proposed Unit 3 are within the PPE values described in the 

ESP ER (Dominion Nuclear North Anna, LLC 2006a), and no new and significant information 

concerning the impacts of impingement and entrainment on aquatic resources was found, the 

staff concludes that the estimates of impingement and entrainment losses developed during the 

ESP process are still valid. Thus, impingement and entrainment impacts associated with the 

operation of the proposed Unit 3 would remain SMALL.
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-12 February 2010 

5.4.2.3 Aquatic Thermal Impacts 

In the COL ER (Dominion 2009a), Dominion provided revised data on the thermal releases 

associated with the operation of the proposed Unit 3 cooling system. These data indicated that 

the proposed Unit 3 blowdown water temperature is expected to be a maximum of 38°C 

(100°F). This blowdown temperature is identical to the PPE value described in the ESP ER 

(Dominion Nuclear North Anna, LLC 2006a). Dominion considered the rise in lake temperatures 

caused by Unit 3 operations and found that the average temperature rise in Lake Anna would 

be less than 0.06oC (0.1oF). The staff independently reviewed the analyses and agrees with the 

assessment (NRC 2006). Thus, the staff’s conclusion stated in the ESP EIS that the thermal 

impacts of the proposed Unit 3 are SMALL is still valid, and mitigation is not warranted. 

5.4.2.4 Downstream Impacts 

Existing biological communities in the North Anna River downstream of the dam vary widely 

during seasonal and even daily river flows. However, most resident species are able to tolerate 

the stressful conditions associated with periodic low-flow events. Further, based on the 

independent analyses of flow alterations conducted by the staff, changes in flow regimes 

associated with the operation of the proposed Unit 3 are not expected to affect spawning fish 

because spawning events generally occur during the spring and early summer when low-flow 

conditions are unlikely. For these reasons, the staff concluded in the ESP EIS (NRC 2006) that 

impacts associated with the operation of Unit 3 on aquatic resources downstream of the North 

Anna Dam would not be significant. 

Since preparation of the ESP EIS, the staff has reviewed the revised the water budget provided 

by Dominion, evaluated the North Anna River low-flow monitoring study results presented in 

Dominion (2004), and reviewed the North Anna IFIM final study plan (Dominion 2009b) that 

describes work performed by Dominion to evaluate the effects of flow on the aquatic resources 

of the North Anna River. Based on a review of the new water budget provided by Dominion 

since the ESP EIS (Dominion Nuclear North Anna, LLC 2006a) was prepared, the staff 

concludes that the expected flow reductions at the North Anna Dam developed during the ESP 

process are still valid. Thus, the staff estimates that the percentage of time the surface 

elevation of Lake Anna would be below 75.6 m (248 ft) above mean sea level would increase 

from approximately 6 percent when only Units 1 and 2 are operating (baseline conditions) to 

11 percent when Units 1, 2, and 3 are operating. This will increase the number of days that 

0.6 m3

/s (20 cfs) releases are required from approximately 22 to 40 days per year. Decreased 

flows are expected to occur primarily in the late summer and early fall, and will not coincide with 

fish spawning in downstream locations. In 2004, Dominion published the North Anna Low Flow 

Monitoring Report, which summarized the results of physio-chemical and biological monitoring 

conducted on the North Anna River in response to period of low flow from December 2001 to 

November 2002, which resulted from a regional drought (Dominion 2004). The study found that 
Environmental Impacts of Operation 

February 2010 5-13 NUREG-1917, SEIS 

fish and invertebrate assemblages observed during the drought were similar to those observed 

during surveys when more normal flow predominated, suggesting the system is tolerant of lowflow conditions, as described above. 

As described in Section 2.7.2, as required by the Commonwealth of Virginia and as a condition 

of the ESP, Dominion conducted an IFIM study of the North Anna River below the dam to 

determine how lake level elevation changes and water releases over the North Anna Dam 

associated with the operation of the proposed Unit 3 would affect downstream resources and 

recreational boating activities (Dominion 2009b). The study also evaluated how various Unit 3 

operational scenarios would affect wetland resources and use of boat ramps and docks in the 

reservoir. Based on the study design, hydrologic information was combined with observations 

of substrate and cover in a model that integrates these habitat characteristics with habitat 

requirements of key species or guilds, to estimate “weighted usable area” (WUA) of preferred 

habitat over a range of stream flows. The study did not include the collection of biota. Rather, it 

used an environmental modeling technique that related stream flow to habitat suitability 

parameters (e.g., water velocity, water depth, substrate, and cover) under three operational 

scenarios: baseline conditions (operation of Units 1 and 2 only), the addition of the proposed 

Unit 3 under normal operations and maximum water conservation mode, and flow alterations 

under three-unit operation with an increase in reservoir surface elevation from 76.2 m (250.0 ft) 

to 76.3 m (250.25 ft) above mean sea level. 

Following an initial assessment of WUA data, the IFIM study (Dominion 2009b) concluded that 

aquatic habitat availability assessments should focus on the following three species and 

habitats where potential effects might occur: 

• Habitat for adult and spawning Northern hogsucker (Hypentelium nigricans) 

• Habitat for freshwater mussels (Lampsilis radiata and Elliptio complanata) 

• Coastal plain habitat for spawning and juvenile American shad (Alosa sapidissima). 

Habitat quality comparisons between the existing condition (Unit 1 and 2 operation) and the 

proposed Unit 3 operating in EC and MWC mode with a lake level raised to 76.3 m (250.25 ft) 

showed both habitat losses or gains were possible and were dependent on species, life stage, 

and season. As stated in the final IFIM study report (Dominion 2009b), in no case were habitat 

losses in the North Anna River more that 10 percent on an annual basis. Habitat gains were 

generally in the same percentage range. For the Pamunkey River, slight habitat gains were 

predicted for most species. The models generally predicted greater habitat changes relative to 

the existing conditions in summer and fall months, and lesser changes during the winter and 

spring months. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-14 February 2010 

Because the IFIM study results rely on modeling rather than biological observations to reach 

conclusions, the staff believes the IFIM study results can be best used to assess the effects of 

various reservoir management strategies for Lake Anna. 

Based on an agreement between Dominion and the Commonwealth of (Dominion 2009b), if the 

proposed Unit 3 is constructed and operated, the level of Lake Anna will be raised 8 cm (3 in) to 

76.3 m (250.25 ft). The resulting increase in lake water capacity will reduce the frequency of 

low-flow events during the summer months, and lessen impacts to aquatic communities 

downstream of the North Anna Dam. Water release from the dam could be scheduled to protect 

and enhance the downstream fishery during critical spawning and non-spawning periods. The 

agreement also provides a plan to provide recreational flows to the North Anna River from the 

dam during June and July, and a proposal to provide funds to enhance aquatic habitats within 

the North Anna and Pamunkey River watersheds in accordance with a Memorandum of 

Agreement between Dominion and VDGIF– again subject to the construction and operation of 

Unit 3 (Dominion 2009b). 

Based on the previous results presented in the ESP EIS (NRC 2006), an evaluation of new 

information, including the low-flow monitoring report and the IFIM final report (Dominion 2009b) 

described above, the staff concludes that the impacts associated with operations at the NAPS 

site and the proposed Unit 3 on downstream aquatic communities would not be significant. This 

conclusion is consistent with the conclusion reached in the ESP EIS (NRC 2006). Thus, 

downstream impacts are expected to remain SMALL.

5.4.2.5 Summary of Aquatic Impacts 

The aquatic plants and animals present in Lake Anna represent a balanced aquatic community. 

Studies of the aquatic resources in the lake suggest that these populations have remained 

stable as the reservoir has matured. Because of the demand for public fishing, state resource 

agencies, in cooperation with Dominion, have stocked the lake with both predator and prey 

species, and will continue to manage and monitor the lake collaboratively. An example of this is 

Dominion’s commitment to perform a preliminary investigation of mussel populations in Lake 

Anna to determine if mussel species should be included in the lake monitoring plan (Dominion 

2008c). Similarly, the North Anna River below the dam supports a diverse assemblage of fish 

and invertebrates that are adapted to the flow regimes of the river and are tolerant of extreme 

conditions. Dominion continues to monitor these downstream resources, shares the information 

with Commonwealth resource agencies, and has agreed to add a new study component that will 

evaluate smallmouth bass populations below the dam (Dominion 2007). Dominion, through a 

collaborative process with the Commonwealth of Virginia, also completed a comprehensive IFIM 

study that may affect the reservoir management plan for Lake Anna if Dominion chooses to 

construct and operate the proposed Unit 3 on the NAPS site. As part of the Memorandum of 

Understanding between Dominion and VDGIF (Dominion 2009b), and contingent on the 
Environmental Impacts of Operation 

February 2010 5-15 NUREG-1917, SEIS 

construction and operation of Unit 3, Dominion will provide funds to enhance aquatic habitats 

within the North Anna and Pamunkey River watersheds 

The NRC staff conducted an assessment of the current operational parameters for the proposed 

Unit 3 cooling system described in the COL ER (Dominion 2009b) and a review of new 

information. Because the staff did not identify information that was both new and significant, the 

conclusions for shoreline erosion, scouring, increased turbidity, entrainment, impingement, and 

thermal impacts are unchanged from those presented in the ESP EIS (NRC 2006). Consistent 

with those findings, the staff concludes that the aquatic impacts to Lake Anna and the 

downstream communities from the operation of Unit 3 would remain SMALL and mitigation is 

not warranted. 

5.4.3 Threatened and Endangered Species 

The information and associated impacts for threatened and endangered species are provided 

and resolved in Section 5.4.3 of the EPS EIS (NRC 2006). 

5.4.3.1 Terrestrial Species 

The information and associated impacts for this section are provided and resolved in 

Section 5.4.3 of the ESP EIS (NRC 2006). Based on the staff’s analysis, operations-related 

impacts to threatened or endangered species were considered to be SMALL. Information made 

available since preparation of the ESP EIS includes the Federal delisting of the bald eagle 

(Haliaeetus leucocephalus), and changes to the State list of endangered or threatened species 

as described in Section 2.7. 

Since preparation of the ESP EIS (NRC 2006), the bald eagle has been removed from the list of 

species protected under the federal Endangered Species Act (72 FR 37346), but it is still listed 

as Threatened by the Commonwealth of Virginia, and is protected by the Federal Bald and 

Golden Eagle Protection Act. The U.S. Fish and Wildlife Service (USFWS) has issued 

management guidelines (USFWS 2008b) that provide suggested buffers to avoid harassment of 

eagles. In general, most construction activities that occur beyond 660 feet from a nest would 

not be considered harassment under these guidelines, and blasting or other very loud noises 

beyond about 0.8 km (0.5 mi) from a nest would not be considered harassment. Dominion 

stated previously (Dominion Nuclear North Anna, LLC 2006b) that it follows nest site protection 

guidelines provided by the USFWS and the Virginia Department of Game and Inland Fisheries 

(VDGIF) (USFWS and VDGIF 2000), in which the primary management zone is 229 m (750 ft). 

Dominion has confirmed (Dominion 2008a) that the nearest bald eagle nest is in the Contrary 

Creek drainage, approximately 3.2 km (2 mi) west of the NAPS site; this nest is not likely to be 

affected by the operation of the proposed Unit 3. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-16 February 2010 

Since issuance of the draft SEIS, the VDCR informed the NRC staff that the NAPS site may 

contain suitable habitat for the Federally threatened and State-endangered small whorled 

pogonia (Isotria medeoloides) (VDCR 2009). The staff considered potential operational impacts 

to this species, and determined that once construction is complete, it is unlikely that any suitable 

habitat for this species would be adversely affected. 

Three Federally listed threatened or endangered plant species have been identified as 

potentially occurring within the NAPS site transmission line rights-of-way. These species 

include the small whorled pogonia (Isotria medeoloides), swamp pink (Helonias bullata), and the 

sensitive joint-vetch (Aeschynomene virginica). The small whorled pogonia inhabits forested 

areas and is not likely to occur in the open transmission line right-of-way. Normal maintenance 

of the right-of-way would not affect any forest habitats that could potentially contain the small 

whorled pogonia. The swamp pink and sensitive joint-vetch require wetland habitats with 

specific soil types which are not found within the North Anna to Ladysmith transmission line 

right-of-way. The New Jersey rush (Juncus caesariensis) is a Virginia State-threatened species 

and Federal species of concern that inhabits acidic bogs and has been reported to occur in 

Caroline County, but not in the vicinity of the Ladysmith substation. Epling’s hedge-nettle 

(Stachys eplingii) is a wetland species that is the only rare plant that has been reported to occur 

in the North Anna to Ladysmith transmission line right of way (VDCR 2009). Dominion’s 

standard transmission line maintenance practices are designed to avoid impacts to wetlands 

and other sensitive habitat areas. In its assessment of the potential impacts of continued 

operation of the existing Units 1 and 2 at NAPS, the staff concluded that continued operation 

and maintenance of the transmission lines and rights-of-way would not adversely impact the 

Federally listed plant species (NRC 2002). Because no changes to the maintenance practices 

within the transmission line rights-of-way are anticipated to result because of the addition of 

another transmission line to support the proposed Unit 3, there would be no change to the 

potential impact of operation and maintenance of the transmission lines or rights-of-way on 

these or any other threatened or endangered plant species. 

The staff evaluated the potential impacts of operation of the proposed Unit 3, including 

operation of the plant, cooling system, and transmission system. The staff did not identify 

information that was both new and significant related to the operation impacts on terrestrial 

threatened or endangered species through its evaluation of information provided by Dominion 

and the staff’s own independent review. Based on this evaluation, the staff concludes that the 

impacts of operating the proposed NAPS Unit 3 on terrestrial threatened and endangered 

species would remain SMALL, and mitigation is not warranted. 

5.4.3.2 Aquatic Species 

During the review process for the COL application (Dominion 2008a), the staff reviewed the 

COL ER and other information provided by Dominion since preparation of the ESP EIS, met 
Environmental Impacts of Operation 

February 2010 5-17 NUREG-1917, SEIS 

with VDEQ personnel, reviewed scoping comments associated with the COL action, and 

searched relevant databases of threatened and endangered species. 

As described in Section 2.7.2.2, the staff determined that two additional species – the green 

floater mussel, Lasmigona subviridis, and the Virginia Piedmont water boatman Sigara 

depressa, which is an aquatic insect – could occur in the upper Pamunkey River watershed 

based on information available on the VDCR Natural Heritage website (VDCR 2008). Neither 

species occurs on USFWS species lists by county (USFWS 2008a). Based on the information 

provided to the staff by Dominion in support of the COL action, none of the species listed in 

Section 2.7.2.2, Table 2-4, have been observed or collected in Lake Anna or the North Anna 

River during pre-impoundment surveys or in more recent routine monitoring surveys. Therefore, 

there would be no impact on any of the listed mussel species due to operation of an additional 

unit at NAPS. In addition, no threatened or endangered aquatic species are expected to occur 

in the 38.8 ha (96-ac) land parcel adjoining the NAPS 3 site that was purchased to support 

construction activities (Dominion 2009a). 

The staff did not identify any new and significant information suggesting that the distribution of 

aquatic threatened and endangered species in the regions encompassing Lake Anna or the 

North Anna River has changed since preparation of the ESP EIS (NRC 2006), or that the list 

of identified or candidate species has changed. Therefore, the staff concludes that the 

determination of SMALL impact to aquatic threatened and endangered species is still valid. 

5.5 Socioeconomic Impacts 

This section describes the socioeconomic impacts from operating the proposed Unit 3 at the 

NAPS site, and from the activities and demands of the operating workforce on the surrounding 

region. Socioeconomic impacts include potential impacts on individual communities, the 

surrounding region, and minority and low-income populations. 

5.5.1 Physical Impacts 

This section assesses the potential physical impacts on the nearby communities that could 

result from the operation of the proposed Unit 3 at the NAPS site. Potential impacts discussed 

include noise, odors, exhausts, thermal emissions, and visual intrusions. Dominion plans to 

manage these physical impacts to comply with applicable Federal, Commonwealth, and local 

environmental regulations (Dominion Nuclear North Anna, LLC 2006a). Dominion does not 

expect operation of the proposed Unit 3 to significantly affect the NAPS site and its vicinity 

(Dominion Nuclear North Anna, LLC 2006a). The staff’s evaluation is discussed in the following 

subsections. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-18 February 2010 

5.5.1.1 Workers and the Local Public 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.1.1 (NRC 2006). The staff evaluated the information provided by 

Dominion and notes that most of the local public is located well away from the NAPS site and 

onsite impacts to site workers can be mitigated. Based on these considerations and its own 

independent review, the staff concluded in the ESP EIS that the overall physical impacts of 

station operation to workers and the local public were SMALL, and additional mitigation beyond 

the actions discussed in the ESP EIS was not warranted. New information available since the 

ESP EIS was prepared does not change this conclusion. 

5.5.1.2 Buildings 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.1.2 (NRC 2006). Because operational activities at the proposed Unit 3 

are not expected to impact any offsite buildings, most of which are located well away from the 

NAPS ESP site boundaries, the staff concludes that any offsite physical impacts from station 

operation to buildings would remain SMALL, and mitigation is not warranted. 

5.5.1.3 Roads 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.1.3 (NRC 2006). Based on the staff assumption that any needed 

upgrades to the regional road system would have been made in conjunction with, or as a result 

of, the construction of the proposed Unit 3, and that the number of operating personnel would 

be significantly fewer than the number of construction personnel, the staff concludes that the 

physical impacts of station operation on the road system would remain SMALL, and mitigation is 

not warranted. 

5.5.1.4 Aesthetics and Recreation 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.1.4 (NRC 2006). Because the proposed Unit 3 would be located in the 

existing NAPS boundary and the visual aspects of the site to offsite viewers would be limited by 

screening and topography, and based on information provided by Dominion (Dominion 2009a) 

and its independent review, the staff concludes that the aesthetic impacts from the operation of 

Unit 3 would remain SMALL. There would be an elevated steam plume from the operation of 

the Unit 3 cooling towers; the staff concluded that the visual impacts would be quite noticeable 

at times, especially during the winter (periodic MODERATE visual impact). On an annual basis, 

however, this impact would be limited to about 10 percent of the year and would have the least 

impact from mid-spring to early fall when outdoor recreation is most likely to occur. In addition, 

the staff identified that during severe drought conditions, the operation of the proposed Unit 3 
Environmental Impacts of Operation 

February 2010 5-19 NUREG-1917, SEIS 

would have an impact on the water levels by slightly adding to the duration and extent of 

shoreline mud flats that could be exposed; the staff concluded that these visual aesthetic 

impacts would temporarily be MODERATE. Because of the temporary and infrequent nature of 

the impacts, mitigation is not warranted. 

Since the ESP EIS was prepared, confirmatory noise and visual aesthetic studies were 

performed by Dominion (2008a). To satisfy the commitment made in the ESP EIS (NRC 2006), 

a confirmatory analysis of the noise levels associated with the cooling towers was performed, 

using the location of the towers, the topography of the area in the vicinity of the towers, and 

manufacturer’s data typical of the towers selected for the proposed Unit 3. The methodology 

used was the same as that used in the analysis reported in the ESP ER (Dominion Nuclear 

North Anna, LLC 2006a). The staff reviewed the confirmatory analysis and concluded that the 

noise level reported in the ESP ER associated with the cooling towers remained bounding. 

Therefore, the staff concludes that the impact level for noise remains SMALL. 

Regarding visual impacts, the principal visible Unit 3 structures that can be seen from the 

access road are the hybrid and dry cooling towers, which because of their low profile are mostly 

obscured behind a line of trees adjacent to the access road. From the Units 1 and 2 intake area 

(from the lake), the proposed Unit 3 facilities blend in with the existing Units 1 and 2 buildings, 

as shown in Figures 5.1, 5.2, and 5.3, reproduced from the ER (Dominion 2009a) The visual 

effect will be approximately the same from other directions where the existing Units 1 and 2 are 

visible. The proposed Unit 3 profile is of a similar shape and size as that of Units 1 and 2. The 

Unit 3 cooling towers are designed to abate the vapor plumes, and a confirmatory analysis was 

conducted by Dominion using manufacturer’s data representative of the proposed Unit 3 cooling 

tower design. As in the ESP EIS (NRC 2006), the method used to estimate the impact of 

operating the cooling towers was the SACTI system of computer programs (ANL 1984). The 

analysis confirmed that the previous visual aesthetic effect discussed in the ESP EIS (NRC 

2006) remained bounding; that is, the impact would be no larger than that contained in the ESP 

EIS. The ESP EIS previously concluded that for most of the year, the visual aesthetic impact 

would be SMALL, rising to MODERATE approximately 10 percent of the time. The visual 

impact to the public from the proposed Unit 3 buildings will be similar to the visual impact from 

the existing Units 1 and 2, and the impact from the vapor plume will be no larger than that 

reported in the ESP EIS. Thus, the aesthetic impact will continue to be SMALL, rising to 

MODERATE no more than 10 percent of the time. Significant mitigation has been undertaken 

to minimize the temporary and infrequently visible vapor plume. No additional mitigation 

measures or controls are warranted. 

As described in Section 2.7.2, as a condition of the ESP, Dominion agreed to conduct an IFIM 

study of the North Anna River below the dam to determine whether reductions in dam releases 

associated with the operation of Unit 3 would affect downstream resources. Based on the study 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-20 February 2010 

 

Figure 5-1. North Anna Site, Looking Northeast Along the Plant Access Road, with Outlines of 

Hybrid Cooling Tower (behind trees) (Source: Dominion 2009a) 

 

Figure 5-2. North Anna Site, Looking Northeast from Final Approach After Main Gate. Unit 3 is 

shown in the distance. (Source: Dominion 2009a) 
Environmental Impacts of Operation 

February 2010 5-21 NUREG-1917, SEIS 

 

Figure 5-3. North Anna Site with Unit 3 Looking Southwest from Unit 1 and Unit 2 Intake Area 

(Source: Dominion 2009a) 

design (Dominion 2009a), a portion of the study evaluated the potential impacts of changes in 

Lake Anna surface elevations on the functionality of existing docks and boat ramps. Limited 

interviews with owners and users of docks and boat ramps were conducted in order to consider 

the perceived impacts associated with historic events when lower than normal lake levels were 

experienced. In addition, the effect of North Anna River flow changes below Lake Anna on 

canoeing has been evaluated. Results are shown in Section 5.5.4.2. 

5.5.2 Demography 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.2 (NRC 2006). There are currently 1000 personnel employed at the 

NAPS site for the existing Units 1 and 2. Approximately 500 additional permanent workers 

would be required for the operation of the proposed Unit 3 (Dominion 2008b). This is less than 

the 720 new workers assumed in the analysis conducted for the ESP EIS, Section 5.5.2. As an 

upper-bound estimate, the staff continued to assume that these 500 workers would relocate into 

the area with their families (i.e., none of the new workers already lived in the area). The 

500 additional employees would translate into an increase in population of about 1900 to the 

region, assuming each new employee represents a family of four (Dominion Nuclear North 

Anna, LLC 2006a). 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-22 February 2010 

The staff evaluated the impacts of station operation on increases in population and determined 

that while the additional operating personnel are expected to come from outside the region, 

their small numbers, when considering the population base of each jurisdiction, would not 

significantly increase the base population within each jurisdiction. Most new jobs created 

through the multiplier effect are expected to go to workers who already reside in the region. 

Based on these considerations, the staff concludes that the any adverse impacts of station 

operation on increases in the regional population would remain SMALL, and that mitigation is 

not warranted. 

5.5.3 Community Characteristics 

This section evaluates the social and economic impacts to the surrounding region as a result 

of operation of the proposed Unit 3 at the NAPS site. The evaluation assesses impacts of 

operation and of those demands placed by the workforce on the surrounding region during a 

40-year operating period. Dominion expects to employ up to an additional 500 workers to 

operate the proposed Unit 3 (Dominion 2008b). This is in addition to the 1000 personnel 

currently employed at the site. 

5.5.3.1 Economy 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.3.1 (NRC 2006). The staff reviewed the generally positive impacts of 

station operation on the economy of the region and concludes that the impacts (including tax 

receipts; see Section 5.5.3.2) would be small everywhere except potentially in Louisa and 

Orange Counties, where the impacts could be moderate. The magnitude of the economic 

impacts would be diffused in the larger economic bases of Henrico and Spotsylvania Counties 

and the City of Richmond; whereas, within the smaller economic bases of Orange and Louisa 

Counties, the economic impacts would be more noticeable. Based on the effects of station 

operation on the regional economies, the staff concludes that the impacts would continue to be 

SMALL BENEFICIAL to MODERATE BENEFICIAL (Louisa and Orange Counties). 

5.5.3.2 Taxes 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.3.3 (NRC 2006). The staff independently evaluated the effect of taxes 

from income on wages and salaries of the proposed Unit 3 operational workers, and sales, use, 

and property taxes on these employees and on Dominion’s corporate profits, most of which 

represent beneficial sources of income for the Commonwealth and some of which would benefit 

the counties in the region. Property tax paid by Dominion would directly benefit Louisa County. 

At $3000 per installed kW(e), the proposed Unit 3 would increase the potential property tax 

base in Louisa County by $4 billion; at $4000 per installed kW(e), Unit 3 would increase the 

potential property tax base by $6 billion. This compares with an assessed valuation of $1.7 billion 
Environmental Impacts of Operation 

February 2010 5-23 NUREG-1917, SEIS 

for Dominion in Louisa County in the fiscal year ending June 30, 2007 (Louisa County 2007a). 

Dominion (2009a) estimated that annually during the operations period, Unit 3 directly or indirectly 

would generate approximately $14.8 million in state taxes, $3.5 million in local property taxes, and 

$24 million in local sales and use taxes. The Louisa County combined operations and capital 

improvements budget is about $91 million for fiscal years 2007 to 2008 (Louisa County 2007b). 

Based on its independent review of the overall impacts from income, sales and use, and property 

taxes, the staff concludes that the beneficial impact level would continue to range from SMALL 

BENEFICIAL on the region to LARGE BENEFICIAL for Louisa County. 

5.5.4 Infrastructure and Community Service Impacts 

Infrastructure and community services include transportation, recreation, housing, public 

services, and education. 

5.5.4.1 Transportation 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.3.2 (NRC 2006). Based on the staff’s assumption that transportation 

network improvements would be made during the construction phase to accommodate the 

much larger construction workforce and that Dominion would implement a traffic management 

plan, as needed, the staff concludes that the overall impacts of station operation on 

transportation would be SMALL, and further mitigation is not warranted. New information 

available since the ESP EIS was prepared indicates that although the overall population in the 

region of the NAPS site is growing more rapidly than estimated in the ESP EIS, the operations 

workforce for Unit 3 will be smaller than contemplated in the ESP EIS (500 workers rather than 

720). The NRC staff continues to believe that any modifications that would be found necessary 

to relieve congestion on the local roads would have been made at the construction stage 

because of the much larger workforce involved (2500 to 3500 workers). Thus, the staff 

concludes that transportation impacts during operations would continue to be SMALL. 

5.5.4.2 Recreation 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.3.4 (NRC 2006). Based on the individual aspects of recreational activities 

in the vicinity of the NAPS site, if the normal operating level of Lake Anna remains at 76.2 m 

(250 ft), the staff concludes that the recreational impacts resulting from operations at the 

proposed Unit 3 would be SMALL most of the time, but could be MODERATE during the 

infrequent periods of extreme droughts. 

One aspect of recreation discussed in the ESP EIS was the potential impact of low-water levels 

on housing values. Staff analysis conducted of housing loans using Federal Financial 

Institutions Examination Council (FFIEC) sales data on Census tracts near Lake Anna for the 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-24 February 2010 

ESP EIS found no adverse impacts on housing prices in the vicinity of Lake Anna as a result of 

the 2001 to 2002 drought. That analysis was repeated for this SEIS using FFIEC data for the 

2000 to 2008 period census tracts near Lake Anna and for Virginia as a whole (FFIEC 2009). 

While these data are not specific enough to determine the impacts on individual properties, no 

adverse impact was found for either sales volume or housing prices attributable to the low-water 

levels during the two recent drought periods (2000 to 2001 and 2007 to 2008). The number of 

loans peaked in 2005 in both the Lake Anna census tracts and in the Commonwealth of 

Virginia; the average amount financed turned slightly downward in Virginia in 2006 and then 

recovered, while at Lake Anna, price increases continued through 2007, and then declined. 

Neither the number of loans (proxy for sales) nor the loan amount (proxy for price) appeared to 

be correlated with water levels in the lake. 

The Lake Anna Civic Association (LACA) membership survey (LACA 2008) and the IFIM study 

(Dominion 2009b) published since the draft SEIS and discussed in Section 2.8.4 offer additional 

details concerning the impacts of drought on recreation as they interact with operations at North 

Anna Unit 3, as well as the effect of raising the elevation of the lake by three inches to 76.3 m 

(250.25 ft) and conducting water release to enhance downstream recreation. The table shows 

that water levels resulting from drought are only slightly affected by the operation of Unit 3. The 

proposed raising of the lake level further reduces these impacts. The changes in lake level from 

Unit 3 operations make little difference in overall water levels and are unlikely to significantly 

affect either the number or severity of navigation hazards; the adverse impacts on use of docks 

and facilities, recreation-related businesses and visual aesthetics; or the other adverse 

consequences of low water levels that otherwise result from drought. The LACA survey showed 

strong support (92 percent) among the LACA members who responded to the survey for raising 

the water level of the lake 8 cm (3 in) to reduce the frequency/severity of low water conditions. 

Only a few respondents (eight in total) were opposed. Those opposed were concerned about 

negative impacts on rip rap or bulkheads, but no respondents expressed concerns with 

operability of docks or boat houses. Table 5.1 shows the impacts of Unit 3 operations on water 

level, water depth at the end of surveyed public boat ramps, and height above water of 

surveyed publicly-accessible docks from the IFIM study. 

Although impacted for some individuals and businesses on a temporary basis during droughts 

(e.g., boating safety, usability of boathouses, and property values are concerns expressed by 

the public, based partly on experiences during droughts that occurred in 2001 to 2002 drought 

and in 2007 to 2008), Lake Anna recreation does continue during droughts. In response to 

public comments on the IFIM study, the IFIM study team discussed the overall impact of low 

water levels on recreation activity as follows: 

DGIF has reviewed several pieces of information regarding effects of water level 

on recreational usage of the lake. None of them have shown an effect of low 

water levels on usage. We examined boat accidents for Lake Anna and showed 
Environmental Impacts of Operation 

February 2010 5-25 NUREG-1917, SEIS 

no correlation with water level. We reviewed marina launch data and again 

showed no correlation between water level and launches. Finally we reviewed 

monthly Lake Anna park data and showed no correlation between water level 

and attendance at the park other than for the month of October. Low water 

levels may pose problems for waterfront property owners who are situated in 

shallow coves but for overall effects on total recreation we can detect no impacts. 

In fact some of the data points to increasing usage when the lake was low and 

the weather hot (Dominion 2009b). 

Table 5-1. Impact of North Anna Unit 3 and Normal Lake Elevation Increase of 8 cm (3 in) on 

the Probability of Lake Anna Elevation, Lake Depth at the End of Public Launch 

Ramps, and Height Above Water of Publicly Accessible Docks 

Variable and

Scenario 

Percent Chance of Elevations Less than Shown 

50 25 10 0 (Minimum Value) 

Lake Elevation (ft) 

Existing Conditions 250.10 249.66 248.78 245.06 

EC/MWC 250.0 ft 250.10 249.49 248.43 244.17 

EC/MWC 250.25 ft 250.35 249.71 248.64 244.39 

Corresponding Depth of Water at End of Boat Ramps at Various Locations (ft) 

Existing Conditions 2.29-6.48 1.85-6.04 0.97-5.16 Not shown 

EC/MWC 250.0 ft 2.29-6.48 1.68-5.87 0.62-4.81 Not shown 

EC/MWC 250.25 ft 2.54-6.73 1.90-6.09 0.83-5.02 Not shown 

Corresponding Dock Height Above Water at Various Locations (ft) 

Existing Conditions 0.90-2.19 1.34-2.63 2.22-3.51 Not Shown 

EC/MWC 250.0 ft 0.90-2.19 1.51-2.80 2.57-3.86 Not Shown 

EC/MWC 250.25 ft 0.65-1.94 1.29-2.58 2.36-3.65 Not Shown 

Source, NRC Staff calculations, based on Table 4-2, Table 4-10a and Table 4-10b in Dominion 2009b. 

The IFIM study found that no change in accessibility would occur under the Lake Anna at an 

elevation of 76.2 m (250.0 ft) with the Unit 3 scenario and that the small elevation differences 

associated with the Lake Anna at 76.3 m (250.25 ft) with the Unit 3 scenario are not expected to 

adversely affect functionality of boat ramps or safe access to boats from docks (Dominion 

2009b). As described in Section 5.3, addition of operations at the proposed Unit 3 would 

change the frequency or depth of low water levels created by droughts, but not by enough to 

change the overall conclusion reported in the ESP EIS that adverse impacts of Unit 3 operations 

on recreation would be infrequent, temporary and MODERATE. The NRC staff believes that the 

additional mitigation of Unit 3 impacts on recreation discussed in the IFIM study further reduces 

these impacts and that mitigation beyond this action is not warranted. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-26 February 2010 

Based on the LACA survey and the results shown in Table 5.1, if the normal operating level of 

Lake Anna is raised 8 cm (3 in) to 76.3 m (250.25 ft), modification of residential and marina boat 

ramps and docks is unlikely to be necessary; this action would result in a SMALL impact. 

The IFIM study (Dominion 2009b) also discussed flow releases from Lake Anna to provide flows 

necessary to maintain recreational uses of the North Anna River below Lake Anna. The study 

indicated that flows of 3 to 6 m3/s (100 to 200 cfs) at the North Anna Dam would benefit 

recreational use of the Piedmont and Fall Zone by novice to intermediate canoeists (providing 

0.5 m [1.5 ft] of depth, though not target flows preferred by intermediate canoeists), with minimal 

impact to water levels in Lake Anna. According to the IFIM team recreational releases during 

drought such as 2000 to 2001 and 2007 would rarely if ever occur because the lower threshold 

for recreational releases of 76.2 m (250.0 ft) would not be exceeded (Dominion 2009b). The 

VDCR requested as a condition of Unit 3 operations that Dominion release enough water for 

one day each weekend in June and/or July to achieve a 6 m3/s (200 cfs) flow for 12 hrs below 

the dam. A release of 5 m3/s (177 cfs) at the dam for 17 hours would provide approximately 

12 hrs of flows in excess of 6 m3/s (200 cfs) through the Fall Zone, and is expected to have less 

than a 0.5 cm (0.2-in.) impact on water level in Lake Anna per event (Dominion 2009b). LACA 

(2008) believes that this negates about one-third of the benefit of the proposed 8 cm (3 in.) 

increase in lake elevation at Lake Anna. The IFIM study concluded that under the Lake Anna at 

76.3 m (250.25 ft) with Unit 3 scenario, when water elevations in Lake Anna are greater than 

76.2 m (250.0 ft), it would be feasible to provide recreational releases for one day each 

weekend during June and July, as requested by VDCR (Dominion 2009b). Because of the 

relatively large changes in flow necessary to materially affect the quality of the downstream 

canoeing experience, the NRC staff believes that the impact of Unit 3 itself on downstream 

recreation is SMALL. 

Based on the results of the final IFIM study (Dominion 2009b), the staff believes that impacts of 

plant operations on recreation downstream of Lake Anna would be temporary and SMALL, at 

most, occurring mainly during drought periods and then only incrementally to the effects of the 

drought itself. This is a similar conclusion to that reached for Lake Anna recreation activities, 

except that during droughts, the impact on the Lake recreation would be temporary and up to 

MODERATE at some shallow locations. The final results are likely to show that mitigation 

actions so far discussed would have a SMALL and beneficial effect on recreation. 

5.5.4.3 Housing 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.3.5 (NRC 2006). Based on the existence of a sufficient supply of houses 

in all price ranges within Henrico and Spotsylvania Counties and the City of Richmond, the staff 

concludes that the impacts of station operation on housing would be SMALL in these areas, and 

mitigation is not warranted. Because of its proximity to the NAPS site, the housing market 

within Orange and Louisa Counties could experience a temporary shortage that would increase 
Environmental Impacts of Operation 

February 2010 5-27 NUREG-1917, SEIS 

housing prices that could create a moderate impact in the short term. However, eventually over 

the 40-year operating life of the proposed Unit 3, the supply of housing would increase to meet 

demand. Therefore, the staff concluded the long-term impacts of station operation in Orange 

and Louisa Counties would remain SMALL, and mitigation is not warranted. 

Information concerning the regional housing market that has become available since the 

ESP EIS was prepared suggests that although the regional population is increasing more 

rapidly than discussed in the ESP EIS, construction of new housing has more than kept pace. 

Based on estimates in Section 2.8, housing vacancies have actually increased since the 

2000 Census despite the increased rate of growth. The NRC staff continues to believe that the 

supply of housing would increase to meet demand as needed during operations and that the 

impact of operations at the proposed Unit 3 on housing would continue to be SMALL. 

5.5.4.4 Public Services 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.3.6 (NRC 2006). Based on the information provided by Dominion and the 

staff’s independent review of the local and regional water and wastewater treatment capacities; 

the police, fire, and medical facilities; and the demand for social and related services, the staff 

concludes that any increase in demand for these services by an increase in the operations 

workforce for the proposed Unit 3 would remain SMALL, and mitigation is not warranted. The 

increase in employment associated with station operation could have beneficial impacts, which 

could reduce the demand for some social services, while the increase in tax revenue could help 

with the infrastructure and resource requirements from potential increase in demand for other 

services (e.g., police and fire protection services). 

Information concerning the regional housing market that has become available since the 

ESP EIS was prepared suggests that although the regional population is increasing more 

rapidly than discussed in the ESP EIS, there has not been an adverse impact on the availability 

of public services. With respect to public water needs, only Hanover County draws water from 

the North Anna River (15 MLD [4 MGD]), although Caroline County is considering the 

downstream Pamunkey River as a potential source of water. Hanover County estimates that 

the incremental increase of 19 MLD (5 MGD) in 2010 from the City of Richmond, along with 

other water sources, should be sufficient for the county through the 2020 to 2025 time period 

(see Section 2.8.3). 

In comments on the IFIM draft report, Hanover County expressed concerns that a limited 

number of seasonal irrigation users downstream from Lake Anna could experience or contribute 

to water shortages as a result of Unit 3 operations. The list of downstream withdrawals appears 

in Table 2-1 of the IFIM final report (Dominion 2009b). In reply to these comments, however, 

the IFIM study team noted that low flows would occur 0.9 percent more frequently with the 

EC/MWC and a control lake level at 76.2 m (250.0 ft), and that based on 29 years of record, all 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-28 February 2010 

of that time period would occur in fall and winter months. The team concluded that “... the 

EC/MWC at 76.3 m (250.25 ft) scenario for Unit 3 does not change the availability of water at 

low river flows compared to existing conditions during the spring and summer growing season” 

(Dominion 2009b). 

The staff concludes that any increase in demand for water services by an increase in the 

operations workforce would remain SMALL, and mitigation is not warranted. 

5.5.4.5 Education 

The information and associated impacts for this section are provided and resolved in the 

ESP EIS, Section 5.5.3.7 (NRC 2006). Based on the information provided by Dominion and the 

staff’s independent review of the local and regional educational facilities, the staff concluded 

that the impact on education as a result of station operation would remain SMALL, and 

mitigation is not warranted. 

5.5.5 Summary of Socioeconomic Impacts 

As described in the ESP EIS (NRC 2006), adverse socioeconomic impacts range from SMALL 

to MODERATE, and beneficial impacts range from SMALL to LARGE. Information concerning 

the regional housing market that has become available since the ESP EIS was prepared 

suggests that although the regional population is increasing more rapidly than discussed in the 

ESP EIS, there has not been an adverse impact on the availability of public services. Based on 

its independent analysis of the information that has become available since the ESP EIS was 

prepared, the staff believes that there is no reason to change the impact levels reported in the 

ESP EIS for socioeconomic impacts during operations at the proposed Unit 3. The staff expects 

adverse socioeconomic impacts range to remain from SMALL to MODERATE, and beneficial 

impacts range from SMALL to LARGE. 

5.6 Historic and Cultural Resource Impacts 

The National Environmental Policy Act of 1969 (NEPA) as amended, requires Federal agencies 

to take into account the potential effects of their undertakings on the cultural environment, which 

includes archaeological sites, historic buildings, and traditional places important to local 

populations. The National Historic Preservation Act of 1966 (NHPA), as amended, also requires 

Federal agencies to assess impacts to those resources if they are eligible for listing on the 

National Register of Historic Places (such resources are referred to as “Historic Properties” in 

the NHPA). As outlined in 36 CFR 800.8, “Coordination with the National Environmental Policy 

Act of 1969,” the NRC coordinated compliance with Section 106 of the NHPA in meeting the 

requirements of NEPA. 
Environmental Impacts of Operation 

February 2010 5-29 NUREG-1917, SEIS 

Operational activities at a new unit can affect either known or undiscovered cultural resources. 

Therefore, in accordance with the provisions of NHPA and NEPA, the NRC is required to make 

a reasonable and good faith effort to identify historic properties in the areas of potential effect 

and, if present, determine if any significant impacts are likely to occur. Identification is to occur 

in consultation with the State Historic Preservation Officer (SHPO), American Indian tribes, 

interested parties, and the public. If significant impacts are possible, efforts should be made to 

mitigate them. As part of the NEPA/NHPA integration, if no historic properties (i.e., places 

eligible for listing on the National Register of Historic Places) are present or affected, the NRC is 

required to notify the SHPO before proceeding. If it is determined that historic properties are 

present, the NRC is required to assess and resolve adverse effects of the undertaking. 

As discussed in Section 2.9.2, cultural resource identification efforts identified seven resources 

that were recommended eligible for the National Register of Historic Places (NRHP) and require 

evaluation or avoidance (historic archaeological sites 44LS0226, 44LS0233, 44SP0618; historic 

cemeteries 44LS0221, 44LS0222, and 44LS0227; and architectural resource Virginia 

Department of Historic Resources [VDHR] No. 016-5042/Blanton’s Road Farm) (Dominion 

2009a,c,d). The staff determined in the ESP that the impacts from the operation of any new 

facilities on historic and cultural resources would be SMALL. Such activities would include 

ground and other routine maintenance, construction of auxiliary buildings, etc. The newly 

identified cultural resources were determined to be new information. For new information to be 

“significant” it must be material to the issue being considered; i.e., that it must have the potential 

to affect the finding or conclusions of the NRC staff’s evaluation of the issue (72 FR 49352). A 

total of seven resources were determined to be potentially eligible for the NRHP, thus making 

them significant. During the course of the environmental review, Dominion provided a list of 

commitments related to protection of historic and cultural resources. These commitments are 

listed in Section 4.6 of this SEIS. 

Even with the discovery of the new and significant information, based on the commitments from 

Dominion, the staff concludes that the potential impacts of operations at the proposed Unit 3 on 

historic and cultural resources would remain SMALL.

Any revised project activities or a change in scope would need to consider the potential impacts 

of plant construction and operation on both known and unknown historic and cultural resources 

at NAPS. Lands not previously surveyed would require investigation by a professional 

archaeologist prior to any ground-disturbing activities in the future. Any changes to these 

procedures or project plans should be developed in consultation with the SHPO. Mitigation 

might be warranted in the event of an unanticipated discovery.

5.7 Environmental Justice Impacts 

The staff evaluated whether the health or welfare of minority and low-income populations at 

those census blocks identified in Section 2.10 of this SEIS could be disproportionately affected 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-30 February 2010 

by the potential impacts of operations at the proposed Unit 3 at the NAPS site. An analysis of 

environmental justice is contained in the ESP EIS (NRC 2006), and expanded by the 

Commission Order (NRC 2007b). 

During plant operations, as shown in the ESP EIS, as expanded, Chapter 5, the only 

environmental effects during normal operations that might adversely affect any offsite population 

and that were greater than SMALL were water use, visual aesthetics, and recreation. The 

MODERATE water use impact (occurring only during severe drought) could adversely affect 

customers of the Hanover County water utility, but this impact would fall proportionately on all 

customers. Visual aesthetics could be adversely affected by the proposed additional unit, 

cooling, towers, and plumes, but most of the residents of affected viewshed are not in minority 

populations (based on ESP EIS Figure 2-6 plus the scoping process) or the low-income 

population (based on Lake Anna lakeside housing prices and ESP EIS Figure 2-7). Based on 

the staff’s interviews with the local officials and other contacts in the area, adverse impacts on 

recreation during severe droughts at Lake Anna and the North Anna River downstream of the 

dam would not fall disproportionately on any particular population group, and people recreating 

on Lake Anna are not known to be either disproportionately within minority or low-income 

populations. 

The analysis has been expanded to incorporate a wider geographic area based on the 

possibility that minority and low-income populations in counties downstream from Lake Anna 

might experience disproportionate and adverse impacts from operation and maintenance of 

Unit 3. These minority and low-income populations are located at distances beyond 16 km 

(10 mi) from Unit 3. The aquatic, ecological, and atmospheric analyses did not identify any 

environmental impacts reaching the three downstream counties as a result of operations at 

Unit 3. Section 5.2 shows there would only be small localized air impacts. These impacts 

would not affect minority or low-income populations because of their distance from the NAPS 

site. Section 5.3 concluded that water quality would not be adversely affected by Unit 3 

operations. Section 5.4 did not find adverse impacts on aquatic species in Lake Anna and or 

the North Anna River in the downstream counties. Section 5.8 found that Unit 3 operations 

would not produce health impacts to the public from thermophillic microorganisms, noise 

generated by operations, or acute and chronic impacts of electromagnetic fields from 

transmission lines. Section 5.9 found that the maximally exposed individual near the plant 

would not receive a radiological dose exceeding safety standards. Therefore, the staff 

determined that the minority and low-income populations located at distances beyond 16 km 

(10 mi) from Unit 3 would not be adversely and disproportionately affected through these 

pathways. Based on the staff’s assumed geographic distribution of operations workers, the 

three downstream counties also are unlikely to experience negative socioeconomic impacts 

such as escalation of housing prices, crowding on commuter routes, and increases in school 

enrollments. 
Environmental Impacts of Operation 

February 2010 5-31 NUREG-1917, SEIS 

Although some minority and low-income populations live along the Pamunkey River farther 

downstream, impacts on fisheries that far downstream would not be significant and therefore 

are not expected to adversely affect any subsistence activities of these populations (see 

Section 5.4.2.4). If a design-basis accident were to occur, if there were any offsite impact at all, 

it is likely that minority or low-income populations would not be disproportionately affected 

because of their relatively distant locations. Accordingly, the staff concludes, as stated in 

Section 5.7 of the ESP EIS, that there were no environmental pathways by which minority and 

low-income populations would be disproportionately and adversely affected during operations at 

the proposed Unit 3. 

Based on information provided by Dominion and its own independent review, the staff 

concludes that there would be no disproportionate and adverse offsite impacts of operations at 

the proposed Unit 3 to minority and low-income populations. 

5.8 Nonradiological Health Impacts 

This section addresses the nonradiological health impacts of operating the proposed Unit 3 at 

the NAPS site. Health impacts to the public from the cooling system, noise generated by unit 

operations, and electromagnetic fields are discussed. Nonradiological health impacts also are 

evaluated for workers at the proposed Unit 3. Health impacts from radiological sources during 

operations are discussed in Section 5.9. 

5.8.1 Public Health (effects of thermophilic organisms) 

The information and associated impacts to public health affected by thermophilic organisms 

were provided and resolved in Section 5.8.1 of the ESP EIS (NRC 2006). Based on the staff’s 

analysis, impacts to members of the public from the effects of thermophilic organisms were 

considered to be SMALL. However, there was a commitment by Dominion to continue exploring 

options with VDEQ and Virginia Department of Health (VDH) to “communicate information 

related to existing risks to local residents” from thermophilic microorganisms, particularly 

Naegleria fowleri (NRC 2006). Information available since preparation of the ESP EIS includes 

a study of the presence of N. fowleri in Lake Anna (LACA 2007; Jamerson et al. 2008), 

discussions with representatives of the Lake Anna Civic Association as well as with VDEQ and 

VDH personnel, and the staff review of Centers for Disease Control and Prevention (CDC) 

recent publications. 

In 2007, the Lake Anna Civic Association commissioned a study with Dr. Marciano-Cabral, 

Virginia Commonwealth University, to determine the presence of N. fowleri in the Lake Anna 

reservoir. N. fowleri causes the rare but nearly always fatal disease called primary amoebic 

meningoencephalitis (PAM). People become infected as a result of water containing N. fowleri

entering the nose, followed by migration of the amoebae to the brain via the olfactory nerve 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-32 February 2010 

(CDC 2008a). There have been cases of PAM reported in Virginia, but not in Lake Anna (CDC 

1998a, 2000, 2002a, 2004a, 2006a, 2008a,b). In 2007, the disease was brought to the attention 

of the public when a total of six fatal cases of PAM in the continental United States reported 

from Arizona, Florida, and Texas (CDC 2008a). The staff contacted CDC in October 2009 and 

confirmed that there have been no reported cases of PAM in Virginia during 2008.(a)

During the summer of 2007, Dr. Marciano-Cabral and her staff sampled 16 locations across 

Lake Anna. Of the 16 sample locations, 9 locations were found to be positive for N. fowleri

based on an analysis using nested polymerase chain reaction assays. However, total amoeba 

counts, inclusive of N. fowleri, never exceeded 12 per 50 mL (1.7 ounce) of lake water at any 

sample location. There was no correlation between water quality parameters (conductivity, 

dissolved oxygen, temperature, and pH of water) and the presence of N. fowleri. Although the 

organism is known to exist in the lake, no cases of PAM have been reported. The authors of 

the published report concluded that “... predation by other protozoa and invertebrates, 

disturbance of water surface from recreational boating activities, or the presence of bacterial or 

fungal toxins, maintain the number N. fowleri at a low level in Lake Anna” (Jamerson et al. 

2008). This study is consistent with other studies suggesting the presence of this organism 

throughout most water bodies found in the southern states (Ettinger et al. 2003; CDC 2008a). 

Representatives of Dominion and several State agencies have been discussing options for 

warning recreational users of Lake Anna of the risks associated with swimming in the warm 

waters of lake. As a result of these discussions, a process for monitoring water temperature at 

Lake Anna State Park was conducted during the summer months of 2008. According to 

Douglas Graham, Virginia Department of Conservation and Recreation (VDCNR), lifeguards at 

the Lake Anna State Park swimming beach were instructed to take water temperature readings 

twice each week. The samples were taken in 0.6 m (2 ft) of water and at a depth of 0.3 m (1 ft). 

If the temperature readings approached 35oC (95oF), then the lifeguards were to post a notice 

with facts about N. fowleri for park visitors to be aware of this issue. Because water 

temperatures in the swimming area did not reach 35oC (95oF), no notices were posted. 

The CDC and the Council of State and Territorial Epidemiologists (CSTE) have formed a 

workgroup to review future actions related to N. fowleri and to improve risk communication for 

health-care providers and the public. In a 2008 report, they considered the posting of warning 

signs. In general, the workgroup stated that because the “... location and number of amoebae 

in the water can vary over time, environmental sampling, testing, and posting of warning signs 

are unlikely to be effective in preventing infections.” They went on to state that “... warning 

signs posted on selected lakes might create a misconception that those bodies of water not 

posted with warnings are free from N. fowleri.” In conclusion, the workgroup felt that “... 

 

(a) October 20, 2009, telephone call to Dr. Govinda Visvesvara (CDC/CCID/NCZVED/DPD/PDB, 

Microbiologist) from Lara Aston (Pacific Northwest National Laboratory, Scientist), “Subject: Update 

on incidence of primary amoebic meningoencephalitis in the U.S.” Accession No. ML100341353. 
Environmental Impacts of Operation 

February 2010 5-33 NUREG-1917, SEIS 

recreational water users should always assume a low level of risk is associated with entering all 

warm freshwaters in southern tier states” (CDC 2008a). 

Other types of microorganisms that are associated with nuclear power plant cooling towers and 

thermal discharges can have deleterious impacts on the health of plant workers and the public, 

including enteric pathogens (such as Salmonella spp., Pseudomonas aeruginosa, etc.), other 

bacteria (such as Legionella spp.) and thermophilic fungi. Several studies have been conducted 

to understand the distribution and abundance of Legionella spp. and other single-celled 

pathogens that cause similar symptoms to legionellosis in the vicinity of the cooling tower 

systems (Tyndall 1982, 1983; Christensen et al. 1983; Tyndall et al. 1985; Berk et al. 2006). 

While these organisms were found in and around the cooling tower systems, the studies 

concluded that the incidence of infection to workers could be minimized with addition of biocides 

in the water and standard practices for protection of workers when cleaning cooling towers and 

condensers. Also, exposure to the public from aerosolized microorganisms would be unlikely 

because of the distance between the cooling towers and the site boundary. Outbreaks of 

legionellosis, samonellosis, or shigellosis that occurred in Virginia were within the range of 

national trends (CDC 1997, 1998b, 1999, 2001, 2002b, 2003, 2004b, 2005, 2006b, 2007, 

2008c) in terms of cases per 100,000 population or total cases per year, and the outbreaks 

were associated with pools, spas, or lakes, but not systems associated with power plants. 

Based on a review of the new information collected at Lake Anna, the actions of State agencies, 

and the insights offered by the CDC and CSTE working group regarding recreational activities 

concerning N. fowleri, the staff concludes that there is a extremely low level of risk associated 

with contracting PAM and that the impacts of operations at the proposed Unit 3 would not 

significantly affect water temperatures in the WHTF or Lake Anna. The incidence of infection 

from other thermophilic microorganisms is minimal to plant workers based on operating 

procedures that include biocides and respiratory protection, and the incidence of infection to the 

public also is minimal because of the distance between the cooling towers and the site’s 

boundary. The staff concludes that the public health impacts from etiological agents would 

remain SMALL. 

5.8.2 Occupational Health 

Occupational health impacts were resolved as SMALL in the ESP EIS (NRC 2006). The staff 

did not identify new and significant information in this area during its evaluation of proposed 

Unit 3. Occupational health impacts would be less than that considered in the ESP EIS based 

on fewer onsite workers during operations of the proposed Unit 3 compared to the work force 

anticipated for two ESP units (500 workers for Unit 3 compared to 720 workers for two ESP 

units). 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-34 February 2010 

In the ESP EIS (NRC 2006), the NRC noted that actual injury and fatality rates at nuclear 

reactor facilities have been lower than the average U.S. industrial rates. Review of safety 

trends since issuance of the ESP EIS verified that this trend has continued. 

5.8.3 Noise Impacts 

The ESP application from Dominion (Dominion Nuclear North Anna, LLC 2006a) reported 

results from the CADNA/A Program predicting peak noise levels of less than 65 dBA along the 

exclusion area boundary (EAB) that would be associated with the operation of the new cooling 

tower. In the ESP EIS (NRC 2006), the staff assessed the expected noise levels during the 

operation of the proposed reactors and concluded that the levels would be less than 65 dBA, 

which is the level at which little effect is expected, consistent with the criteria used in 

NUREG-1437 (NRC 1996). The staff relies upon the conclusions previously stated in the 

ESP EIS (NRC 2006) that the potential impacts of noise resulting from the operation of an 

additional cooling system would be SMALL, and the only mitigation that might be necessary 

would be the use of ear-protection devices for workers in the vicinity of the tower. 

5.8.4 Acute Effects of Electromagnetic Fields 

The staff considered potential impacts to public health from the acute effects of electromagnetic 

fields from transmissions for the proposed ESP units in Section 5.8.4 of the ESP EIS (NRC 

2006). In the COL ER (Dominion 2009a), Dominion determined that the transmission line for 

Unit 3 would be designed in accordance with the National Electrical Safety Code (NESC) 

requirements for preventing electrical shock from induced current. The World Health 

Organization (WHO) has reviewed the biological effects from electromagnetic fields (EMF) 

exposure to various parts of the electromagnetic spectrum and concluded that exposures below 

the limits recommended in the guidelines by the International Commission on Non-Ionizing 

Radiation Protection (ICNIRP) do not appear to have any known consequences on health, 

although it notes that there are still key areas in need of further research before a final 

assessment can be made (WHO 2002). Another study (Bailey 2002) reviewed the historical 

basis for EMF exposure limits and concludes there is no need for lower limits. Given that the 

transmission lines carrying the additional power of the proposed Unit 3 would not exceed the 

NESC criteria for electric shock, the staff relies upon the conclusions in the previous 

assessment that the effects of EMF would remain SMALL. 

5.8.5 Chronic Effects of Electromagnetic Fields 

This issue was not resolved in the ESP EIS (NRC 2006). The staff reviewed the available 

scientific literature on chronic effects to human health from electromagnetic fields (EMF) and 

transmission lines, which produce extremely low frequency (ELF) EMF. The National Institute 

of Environmental Health Sciences (NIEHS), National Institutes of Health, and the 

U.S. Department of Energy have been designated to direct and manage studies assessing the 
Environmental Impacts of Operation 

February 2010 5-35 NUREG-1917, SEIS 

potential for health risks from exposure to EMF, including ELF-EMF. After conducting more 

than 100 studies, the NIEHS concluded that the “... scientific evidence suggesting that 

ELF-EMF exposures pose any health risk is weak” (NIEHS 1999). Additional work under the 

auspices of the WHO supplemented and updated the assessments of a number of scientific 

groups reflecting the potential for transmission line EMF to cause adverse health impacts in 

humans. A monograph on health and ELF-EMF by the WHO (2007) reviewed the literature on 

EMF exposure and a number of diseases such as cancers in children and adults, depression, 

suicide, reproductive dysfunction, developmental disorders, immunological modifications, and 

neurological disease. The extent of scientific evidence linking these diseases to EMF exposure 

is not consistent. The scientific evidence regarding the chronic effects of EMF on human health 

does not conclusively link to adverse health impacts. 

5.8.6 Impacts of Transporting Operations Personnel to the Site 

Nonradiological health impacts of transporting personnel to the proposed Unit 3 were calculated 

using the same general approach as that used to calculate nonradiological health impacts of 

transporting fuel and waste. This supplemental information was not included in the ESP EIS 

(NRC 2006), but was developed as part of the hearing process. The assumptions used in 

calculating impacts are discussed below. 

• The number of workers needed to operate the proposed Unit 3 is estimated to be about 

500 personnel (Dominion 2008a). An additional 1000 temporary workers are estimated to 

be needed for refueling outages (Dominion 2008a). 

• The average commute distance for operations and outage workers is assumed to be 32 km 

(20 miles) one way. 

• An average of 1.8 persons/vehicle is assumed (NRC 2006). 

• Each operations worker is assumed to travel to and from the site 250 times/yr. Each outage 

worker is assumed to travel to and from the site 60 times/yr. 

• Impacts (i.e., accidents, injuries, and fatalities) associated with commuter traffic (i.e., 

workers traveling to and from the proposed Unit 3 site) are derived from Virginia Traffic 

Facts 2007 (DOT 2008a). 

The estimated nonradiological impacts of transporting operations and outage workers to and 

from the proposed Unit 3 are shown in Table 5-2. The total annual traffic fatalities during 

operations, including both operations and outage personnel, represents less than a 1 percent 

increase above the 15 traffic fatalities that occurred in Louisa County in 2007 (DOT 2008b). 

This represents a small increase relative to the current traffic fatality risks in the area in the 

vicinity of the proposed Unit 3. Therefore, the staff concludes that the impacts of transporting 

personnel to the proposed Unit 3 site would be SMALL, and mitigation is not warranted. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-36 February 2010 

Table 5-2. Nonradiological Impacts of Transporting Workers to/from the Proposed Unit 3 Site

Accidents per 

Year

Injuries per 

Year

Fatalities per 

Year

Permanent workers 4.8 2.2 0.033 

Outage workers 2.3 1.1 0.016 

Total 7.1 3.3 0.049 

 

5.8.7 Summary of Nonradiological Health Impacts 

The staff evaluated health impacts to the public and the workers from the cooling systems, 

noise generated by operations at a single unit, acute and chronic impacts of EMFs from 

transmission lines, and transporting operations and outage workers to/from the proposed Unit 3. 

Health risks to workers are expected to be dominated by occupational injuries at rates below the 

average U.S. industrial rates. Health impacts to the public and workers from thermophilic 

microorganisms, noise generated by operations at the proposed Unit 3, and acute and chronic 

impacts of EMFs would be minimal. Based on the information provided by Dominion and the 

staff’s independent review, the staff concludes that the potential impacts to the public and 

workers from nonradiological effects resulting from the operation of the proposed Unit 3 would 

remain SMALL, and mitigation is not warranted. 

5.9 Radiological Impacts of Normal Operations 

This section addresses the radiological impacts of normal operations of the proposed Unit 3 

including a discussion of the estimated radiation dose to a member of the public and to the biota 

present in the proximity of the proposed unit. Estimated doses to workers at the proposed 

Unit 3 also are discussed. New information in the COL ER (Dominion 2009a) regarding the 

location of the nearest receptors for the maximally exposed individual necessitated the reevaluation of doses to the public. 

5.9.1 Exposure Pathways 

During normal operation, small quantities of radiological materials are released to the 

environment through gaseous and liquid effluents. Dominion Nuclear North Anna, LLC (2006a) 

stated in its ESP ER that the contribution to direct radiation exposure from new reactor designs 

would be negligible. The exposure pathways to humans are described in Regulatory 

Guides 1.109, 1.111, and 1.113 (NRC 1977a,b,c). 

The annual liquid radiological effluent release source term for the proposed Unit 3 was taken 

from the COL ER (Dominion 2009a), and is presented in Table 5-3. The annual gaseous 
Environmental Impacts of Operation 

February 2010 5-37 NUREG-1917, SEIS 

radiological effluent release source term for the proposed Unit 3 was also taken from the COL 

ER (Dominion 2009a) and is presented in Table 5-4. The impacts from the liquid and gaseous 

releases and direct radiation were evaluated by considering the probable pathways to 

individuals, populations, and biota near the proposed Unit 3. The highest calculated doses from 

the major exposure pathways were evaluated for a given receptor. 

Table 5-3. Liquid Effluent Release Source Term from Proposed Unit 3(a)(b) 

Radionuclide 

Release 

(Ci/yr) Radionuclide 

Release 

(Ci/yr) Radionuclide 

Release 

(Ci/yr) 

H-3 1.4 × 101 

[1.4 × 101] 

Y-93 1.2 × 10-3

[1.0 × 10-3] 

La-142 3.0 × 10-5

[2.0 × 10-5] 

N-24 5.1 × 10-3

[4.2 × 10-3] 

Zr-95 2.0 × 10-5

[1.0 ×10-5] 

Ce-141 7.0 × 10-5

[6.0 × 10-5] 

P-32 4.2 × 10-4 

[3.5 × 10-4] 

Nb-95 2.0 × 10-5

[1.0 × 10-5] 

Ce-143 3.0 × 10-5

[3.0 × 10-5] 

Cr-51 1.3 × 10-2

[1.1 × 10-2] 

Mo-99 3.0 × 10-3

[2.5 × 10-3] 

Pr-143 9.0 × 10-5

[7.0 × 10-5] 

Mn-54 1.6 × 10-4

[1.3 × 10-4] 

Tc-99m 5.5 × 10-3

[4.6 × 10-3] 

W-187 2.4 × 10-4

[2.0 × 10-4] 

Mn-56 1.3 × 10-3

[1.0 × 10-3] 

Ru-103 4.0 × 10-5

[4.0 × 10-5] 

Np-239 1.1 × 10-2

[9.3 × 10-3] 

Fe-55 2.3 × 10-3

[1.9 × 10-3] 

Ru-105 1.7 × 10-4

[1.3 × 10-4] 

 

Fe-59 7.0 × 10-5

[6.0 × 10-5] 

Te-129m 9.0 × 10-5

[7.0 × 10-5] 

 

Co-58 4.4 × 10-4

[3.7 × 10-4] 

Te-131m 1.0 × 10-4

[8.0 × 10-5] 

 

Co-60 9.0 × 10-4

[7.5 × 10-4] 

Te-132 2.0 × 10-5

[1.0 × 10-5] 

 

Cu-64 1.3 × 10-3

[1.0 × 10-2] 

I-131 4.2 × 10-3

[6.2 × 10-3] 

 

Zn-65 4.5 × 10-4

[3.7 × 10-4] 

I-132 8.2 × 10-4

[9.3 × 10-4] 

 

Zn-69m 9.2 × 10-4

[7.5 × 10-4] 

I-133 2.1 × 10-2

[3.0 × 10-2] 

 

Br-83 9.0 × 10-5

[1.0 × 10-4] 

I-134 4.0 × 10-5

[4.0 × 10-5] 

 

Sr-89 2.2 × 10-4

[1.9 × 10-4] 

I-135 5.4 × 10-3

[7.1 × 10-3] 

 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-38 February 2010 

Table 5-3. (contd) 

Radionuclide 

Release 

(Ci/yr) Radionuclide 

Release 

(Ci/yr) Radionuclide 

Release 

(Ci/yr) 

Sr-90 2.0 × 10-5

[1.0 × 10-5] 

Cs-134 6.8 × 10-4

[5.7 × 10-4] 

 

Sr-91 1.2 × 10-3

[9.5 × 10-4] 

Cs-136 4.1 × 10-4

[3.5 × 10-4] 

 

Sr-92 2.9 × 10-4

[2.3 × 10-4] 

Cs-137 1.8 × 10-3

[1.5× 10-3] 

 

Y-91 1.4 × 10-4

[1.2 × 10-4] 

Ba-139 4.0 × 10-5

[3.0 × 10-5] 

 

Y-92 1.1 × 10-3

[8.7 × 10-4] 

Ba-140 8.2 × 10-4

[6.9 × 10-4] 

 

(a) Source: COL ER (Dominion 2009a). 

(b) The numbers in brackets [ ] are the release values from DCD Revision 6 (GEH 2009a) that the staff used in its 

evaluation. Dominion used release values from DCD Revision 5 (GEH 2008) in their evaluation. The Revision 6 

values were lower for most radionuclides. 

The proposed Unit 3 would release liquid effluents into the WHTF through the discharge canal 

used for the operating units. The liquid pathways considered were the same as those evaluated 

for the ESP ER (Dominion Nuclear North Anna, LLC 2006a) and included ingestion of aquatic 

food, ingestion of drinking water, exposure to shoreline sediment, and exposure to water 

through boating, swimming, and other activities. 

The gaseous pathways considered in the COL ER (Dominion 2009a) were external exposure 

to the airborne plume, external exposure to contaminated ground, inhalation of airborne activity, 

and ingestion of contaminated agricultural products. The ESBWR design has three gaseous 

effluent release points: (1) reactor/fuel building stack, (2) turbine building stack, and 

(3) radwaste building stack (GEH 2009a). The dose calculation estimates to the maximally 

exposed individual (MEI) from gaseous effluents was conservatively assumed to be a groundlevel release. The distances to the MEI were based on the distances from the plant facility 

boundary that encompassed the three stacks (see Figure 5-4). Dominion conservatively 

assumed that each receptor type (i.e., nearest resident, nearest meat animal, and nearest 

vegetable garden) was at 1.20 km (0.74 mi) in each compass direction from the proposed Unit 3 

(Dominion 2008d). Dominion’s evaluation, which is summarized in Section 5.9.2.2 of this SEIS, 

conservatively assumed the closest receptors to be located in the direction of the maximum 

atmospheric dispersion factors (or χ/Qs at 1.2 km [0.74 mi]) east-southeast of the proposed 

Unit 3), which will maximize the estimated dose to the MEI. The maximum D/Q value was 

located at the same distance in the north-northeast direction (Dominion 2009a). This D/Q value 

was used in dose evaluation. The staff judged these assumptions to be bounding. 
Environmental Impacts of Operation 

February 2010 5-39 NUREG-1917, SEIS 

Table 5-4. Gaseous Effluent Release Source Term from Proposed Unit 3(a)(b) 

Radionuclide 

Release 

(Ci/yr) Radionuclide 

Release 

(Ci/yr) Radionuclide 

Release 

(Ci/yr) 

H-3 7.6 × 101 Sr-92 1.2 × 10-4 Xe-133 1.1 × 103

C-14 1.4 × 101 Y-90 2.2 × 10-6 Xe-135m 5.9 × 102

Na-24 1.5 × 10-4 Y-91 4.6 × 10-5 Xe-135 7.6 × 102

P-32 3.5 × 10-5 Y-92 1.0 × 10-4 Xe-137 7.6 × 102

Ar-41 3.8 × 10-2 Y-93 1.9 × 10-4 Xe-138 6.2 × 102

Cr-51 4.9 × 10-3 Zr-95 1.2 × 10-3 Cs-134 4.9 × 10-3

Mn-54 4.1 × 10-3 Nb-95 6.5 × 10-3 Cs-136 4.1 × 10-4

Mn-56 3.0 × 10-4 Mo-99 4.6 × 10-2 Cs-137 7.3 × 10-3

Fe-55 1.3 × 10-3 Tc-99m 5.9 × 10-5 Cs-138 2.3 × 10-5

Fe-59 5.4 × 10-4 Ru-103 2.7 × 10-3 Ba-140 2.1 × 10-2

Co-58 1.1 × 10-3 Ru-106 3.8 × 10-6 La-140 3.5 × 10-4

Co-60 8.6 × 10-3 Rh-103m 9.5 × 10-8 Ce-141 7.0 × 10-3

Ni-63 1.3 × 10-6 Rh-106 1.2 × 10-10 Ce-144 3.5 × 10-6

Cu-64 1.9 × 10-4 Ag-110m 2.7 × 10-6 Pr-144 4.3 × 10-9

Zn-65 8.6 × 10-3 Sb-124 1.4 × 10-4 W-187 3.5 × 10-5

Kr-83m 2.3 × 10-3 Te-129m 4.3 × 10-5 Np-239 2.2 × 10-3

Kr-85m 1.8 × 101 Te-131m 1.5 × 10-5 

Kr-85 1.4 × 102

 Te-132 3.8 × 10-6

Kr-87 3.8 × 101

 I-131 2.3 × 10-1

[2.4 × 10-1] 

 

Kr-88 5.7 × 101

 I-132 1.6 × 100 

Kr-89 3.8 × 102

 I-133 1.1× 100

[1.2 × 100] 

 

Rb-89 5.4 × 10-6 I-134 3.0 × 100

 

Sr-89 4.1 × 10-3 I-135 1.6 × 100

Sr-90 2.7 × 10-5 Xe-131m 4.1 × 100

Sr-91 1.8 × 10-4 Xe-133m 5.1 × 10-3 

(a) Source: COL ER (Dominion 2009a). 

(b) The release values in [ ] are values from DCD Revision 6 (GEH 2009a) that were different from the DCD 

Revision 5 values. The staff used release values from DCD Revision 6 in its evaluation while Dominion used 

values from DCD Revision 5. 
NUREG-1917, SEIS 

5-40 February 2010 Figure 5-4. Source and Receptor Locations (Dominion 2008d) 

'

. 

WNW 

W 

WSW 

SW 

KW 

'

. 

- • ..J . 

I 

, 

\ 

i 

_

.-

\ 

/ 

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DIstance: 0.5S Mlr •• 

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. ",. / 

//,-

\ 

\ 

, 

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SSW 

I 

" 

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f · :; <S. 

'

. 

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I 

I 

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North 

Un

Source and 

Loca

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Environmental Impacts of Operation 

February 2010 5-41 NUREG-1917, SEIS 

In its ESP review (NRC 2006), the NRC staff identified another airborne release pathway, the 

release to the atmosphere of tritium incorporated in water vapor resulting from evaporation of 

cooling water from the proposed Unit 3 closed-cycle, combination wet and dry cooling system. 

Units 1 and 2 release tritium to the Lake Anna, which will be used as feedwater to the Unit 3 

cooling system. The proposed Unit 3 will release tritium to Lake Anna at lower levels than the 

existing Units 1 and 2 (i.e., 0.5 TBq/yr [14 Ci/yr]). Units 1 and 2 released 43.07 TBq (1164 Ci) of 

tritium to Lake Anna in 2007 (VEPCo 2008b). 

Subsequent to the ESP review and as outlined in the NRC Regulatory Issue Summary 2008-03 

(NRC 2008), this pathway no longer needs to be considered. This regulatory summary stated 

that water containing radioactive material returned from the environment can be used by the 

licensee and returned to the environment without being considered a new radioactive material 

effluent release. The basis for this determination is that the licensee has already accounted for 

this radioactive material when the effluent was originally released. The licensee must evaluate 

whether subsequent use, possession, or release introduces a new significant dose pathway to a 

member of the public. A significant dose pathway would be one that contributes 10 percent or 

more of the total effluent dose. In the ESP EIS (NRC 2006), the staff evaluated dose impacts 

for the ESP reactor design and estimated doses to be <10 percent of the total gaseous effluent 

dose. The estimated dose to the MEI at the nearest residence was estimated to be small, 

1.2 × 10-4 mSv/yr (1.2 × 10-2 mrem/yr), in the ESP EIS (NRC 2006). The estimated doses from 

operation of Units 1 and 2 and the proposed Unit 3 would be less because the ESBWR will 

release less tritium to Lake Anna via the liquid effluent pathway when compared to the project 

evaluated in the ESP EIS. The ESBWR proposed for Unit 3 is estimated to release 0.5 TBq/yr 

(14 Ci/yr) of tritium; the two units considered in the ESP EIS were estimated to release 

63 TBq/yr (1700 Ci/yr) of tritium. 

5.9.2 Radiation Doses to Members of the Public 

The estimated dose to the MEI was calculated from both the liquid and gaseous effluent release 

pathways (Dominion 2009a), and a collective whole body dose was calculated for the population 

within 80 km (50 mi) of the proposed Unit 3. 

5.9.2.1 Liquid Effluent Pathway 

The liquid effluent source term for the ESBWR (see Table 5-3) is bounded by the PPE liquid 

effluent source term for the two proposed ESP units. In the COL ER (Dominion 2009a), doses 

to the MEI were recalculated using the ESBWR liquid effluent source term. All other 

parameters, including the effluent discharge rate, the dilution factor for discharge, and the transit 

time, to the receptor were the same as those used in the ESP ER calculation (Dominion Nuclear 

North Anna, LLC 2006a). A description of these parameters can be found in Appendix H of the 

ESP EIS (NRC 2006). 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-42 February 2010 

Liquid pathway doses to the MEIs were calculated for Unit 3 liquid effluents by Dominion 

(2009a) and the staff using the LADTAP II computer program (Strenge et al. 1986). Results are 

presented in Table 5-5. Estimated doses were lower than those calculated for the MEI in the 

ESP ER (Dominion Nuclear North Anna, LLC 2006a) for one ESP unit; therefore, the ESP 

evaluation was bounding. The calculated maximum annual total body dose was 9.4 × 10-4 mSv 

(9.4 × 10-2 mrem) to the adult. The calculated maximum annual thyroid dose was 

1.8 × 10-3 mSv (0.18 mrem) to the infant. The calculated maximum annual bone dose was 

1.3 × 10-2 mSv (1.3 mrem) to the child. The staff performed an independent evaluation of liquid 

pathway doses and found similar results. The staff determined that all input parameters used in 

Dominion’s calculations were appropriate. Results of the staff’s independent evaluation are 

presented in Table 5-5. 

Table 5-5. Estimated Liquid Pathway Doses for MEIs at Lake Anna from Unit 3 Liquid 

Effluents 

Pathway 

Total Body Dose 

(mSv/yr)(a) 

Thyroid Dose 

(mSv/yr)(a) 

Bone Dose 

(mSv/yr)(a) 

Fish 7.8 × 10-4

[6.6 × 10-4]

(c) 

NA[b] 1.2 × 10-2

[1.0 × 10-2] 

Invertebrate 8.3 × 10-5

[7.0 × 10-5] 

NA[b] 6.5 × 10-4

[5.5 × 10-4] 

Drinking water 4.1 × 10-5

[4.0 × 10-5] 

1.8 × 10-3

[2.6 × 10-3] 

5.6 × 10-5

[4.6 × 10-5] 

Shoreline recreation 3.0 × 10-5

[2.5 × 10-5] 

3.0 × 10-5

[2.5 × 10-5] 

3.0 × 10-5

[2.5 × 10-5] 

Swimming 1.2 × 10-6

[1.2 × 10-6] 

1.2 × 10-6

[1.2 × 10-6] 

1.2 × 10-6

[1.2 × 10-6] 

Boating 1.5 × 10-6

[1.5 × 10-6] 

1.5 × 10-6

[1.5 × 10-6] 

1.5× 10-6

[1.5 × 10-6] 

Total 9.4 × 10-4

[8.0 × 10-4] 

1.8× 10-3

[2.6 × 10-3] 

1.3× 10-2

[1.1 × 10-2] 

Age group receiving 

maximum dose 

Adult Infant Child 

(a) Multiply mSv/yr times 100 to obtain mrem/yr. 

(b) Thyroid dose is not applicable because infants are assumed not to consume fish and invertebrates. 

(c) The staff’s estimates are shown in brackets [ ]. 

Source: Dominion 2009a. 
Environmental Impacts of Operation 

February 2010 5-43 NUREG-1917, SEIS 

5.9.2.2 Gaseous Effluent Pathway 

The gaseous effluent source term for the ESBWR (see Table 5-4) was taken from Dominion 

(2009a) and is bounded by the PPE gaseous effluent source term for the two proposed ESP 

units. Doses to the MEIs were recalculated using the ESBWR gaseous effluent source term. In 

addition, as discussed in Section 5.9.1, Dominion (2009a) conservatively assumed all three of 

MEI receptor locations (i.e., nearest residence, meat cow, and vegetable garden) to be at a 

single bounding location (1.2 km [0.74 mile] east-southeast from the facility boundary). Other 

parameters including meat and vegetable production rates and consumption factors did not 

change from those used in the ESP evaluations (Dominion Nuclear North Anna, LLC 2006a; 

NRC 2006). A description of these parameters can be found in Appendix H of the ESP EIS 

(NRC 2006). 

Gaseous pathway doses to the MEIs were calculated for the proposed Unit 3 by Dominion using 

the GASPAR II computer program (Strenge et al. 1987) at the nearest site boundary and the 

bounding receptor location. Doses from the milk pathway were not calculated as there were no 

milk cows or goats located within an 8 km (5 mi) radius of the ESP site (Dominion Nuclear North 

Anna, LLC 2006a). 

Gaseous pathway doses to the MEIs calculated by Dominion (2009a) for the proposed Unit 3 

are presented in Table 5-6. Doses were lower than those calculated for the MEIs in the ESP 

ER (Dominion Nuclear North Anna, LLC 2006a) for one ESP unit; therefore, the ESP evaluation 

was bounding. The staff performed an independent evaluation of gaseous pathway doses and 

found similar results. All input parameters used in Dominion’s calculations were judged by the 

staff to be appropriate. Because of the change in receptor locations, the annual gaseous 

effluent source term and the atmospheric dispersion factors also changed. Results of the staff’s 

independent evaluation also are presented in Table 5-6.

5.9.2.3 External Radiation Pathway 

The estimated external radiation doses to the public from the ESBWR for the proposed Unit 3 

would be negligible (Dominion 2009a). The primary source of external radiation would be 

nitrogen-16. The estimated annual dose at 800 m (2624 ft) from the plant was 5.93 × 10-6 mSv 

(5.93 × 10-4 mrem) (GEH 2009a). The nearest member of the public would be at the nearest 

residence (1200 m [3937 ft]), which is farther away and would have a smaller annual dose. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-44 February 2010 

Table 5-6. Estimated Gaseous Pathway Doses for MEIs from Unit 3 Gaseous Effluents 

Location Pathway 

Total Body Dose 

(mSv/yr)(a) 

Thyroid Dose 

(mSv/yr)(a) 

Skin Dose 

(mSv/yr)(a) 

Nearest Site Boundary (1.4 km [0.88 mi] ESE) 

 Plume(e) 1.6 × 10-2 

[1.6 × 10-2]

[d] 

1.6 × 10-2

[1.6 × 10-2] 

4.0 × 10-2

[4.0 × 10-2] 

 Inhalation (adult) 9.1 × 10-5

[9.1 × 10-5] 

6.8 × 10-3

[7.0 × 10-3] 

NA(f)

 Inhalation (teen) 9.7 × 10-5

[9.7 × 10-5] 

8.9 × 10-3

[9.1 × 10-3] 

NA 

 Inhalation (child) 9.1 × 10-5

[9.1 × 10-5] 

1.1 × 10-2

[1.1 × 10-2] 

NA 

 Inhalation (infant) 5.5 × 10-5

[5.6 × 10-5] 

9.8 × 10-3

[1.0 × 10-2] 

NA 

Nearest Garden (1.2 km [0.74 mi] ESE)(b)

Vegetable (adult) 3.7 × 10-3

[3.7 × 10-3] 

4.0 × 10-2

[4.1 × 10-2] 

NA 

 Vegetable (teen) 5.8 × 10-3

[5.9 × 10-3] 

5.5 × 10-2

[5.6 × 10-2] 

NA 

 Vegetable (child) 1.3 × 10-2

[1.4 × 10-2] 

1.1 × 10-1

[1.1 × 10-1] 

NA 

Nearest Residence (1.2 km [0.74 mi] ESE) 

 Plume(e) 3.2 × 10-3

[3.2 × 10-3]

3.2 × 10-3

[3.2 × 10-3] 

6.5 × 10-3

[6.5 × 10-3] 

 Inhalation (adult) 9.9 × 10-5

[9.9 × 10-5]

7.2 × 10-3

[7.4 × 10-3] 

NA 

 Inhalation (teen) 1.0 × 10-4

[1.0 × 10-4] 

9.3 × 10-3

[9.6 × 10-3] 

NA 

 Inhalation (child) 9.6 × 10-5

[9.6 × 10-5] 

1.1 × 10-2

[1.2 × 10-2] 

NA 

 Inhalation (infant) 5.8 × 10-5

[5.8 × 10-5] 

1.0 × 10-2

[1.1 × 10-2] 

NA 

Nearest Meat Cow (1.2 km [0.74 mi] ESE)(b)

 Meat (adult) 1.3 × 10-3

[1.3 × 10-3] 

2.6 × 10-3

[2.7 × 10-3] 

NA 

 Meat (teen) 1.1 × 10-3

[1.1 × 10-3] 

2.0 × 10-3

[2.1 × 10-3] 

NA 

 Meat (child) 2.0 × 10-3

[2.1 × 10-3] 

3.4 × 10-3

[3.5 × 10-3] 

NA 
Environmental Impacts of Operation 

February 2010 5-45 NUREG-1917, SEIS 

Table 5-6. (contd) 

Location Pathway 

Total Body Dose 

(mSv/yr)(a) 

Thyroid Dose 

(mSv/yr)(a) 

Skin Dose 

(mSv/yr)(a) 

Nearest Garden/Residence/Meat Cow (1.2 km [0.74 mi] ESE) 

 All pathways(c) 

 Adult 8.3 × 10-3

[8.3 × 10-3] 

5.3 × 10-2

[5.4 × 10-2] 

6.5 × 10-3

[6.5 × 10-3] 

 Teen 1.0 × 10-2

[1.0 × 10-2] 

7.0 × 10-2

[7.1 × 10-2] 

6.5 × 10-3

[6.5 × 10-3] 

 Child 1.9 × 10-2

[1.9 × 10-2] 

1.3 × 10-1

[1.3 × 10-1] 

6.5 × 10-3

[6.5 × 10-3] 

 Infant 3.3 × 10-3

[3.3 × 10-3] 

1.4 × 10-2

[1.3 × 10-2] 

6.5 × 10-3

[6.5 × 10-3] 

(a) Multiply mSv/yr times 100 to obtain mrem/yr. 

(b) No infant doses were calculated for the vegetable and meat pathways because the doses that infants receive 

from their diet would be bounded by the dose calculated for the child. 

(c) The “All” pathways dose is the sum of the dose for nearest garden, nearest residence, and nearest meat cow 

for each age group (adult, teen, child, and infant) plus the dose from the plume exposure pathway. 

(d) The staff’s estimates are shown in brackets [ ]. 

(e) Includes dose from plume and ground deposition pathways. 

(f) NA means not applicable. 

Source: Dominion 2009a. 

5.9.3 Impacts to Members of the Public 

This section describes the staff’s evaluation of the estimated impacts from radiological releases 

and direct radiation of the proposed Unit 3. The evaluation addresses doses from operations to 

the MEI located at the proposed Unit 3 site boundary and the population dose (collective dose 

to the population within 80 km [50 mi]) around the proposed Unit 3 site.

5.9.3.1 Maximally Exposed Individual 

In Section 5.4.2 of the COL ER (Dominion 2009a), Dominion stated that whole body and organ 

dose estimates to the MEI from liquid and gaseous effluents for the proposed Unit 3 were within 

the design objectives of 10 CFR Part 50, Appendix I, and were bounded by the dose estimates 

calculated for one ESP unit (Dominion Nuclear North Anna, LLC 2006a; NRC 2006). The 

design objectives of 10 CFR Part 50, Appendix I are applicable to each reactor unit. Doses to 

whole body and maximum organ at Lake Anna from liquid effluents were well within the 

0.03 mSv/yr (3 mrem/yr) and 0.1 mSv/yr (10 mrem/yr) Appendix I design objectives, 

respectively. Doses at the site boundary from gaseous effluents were well within the Appendix I 

design objectives of 0.1 mGy/yr (10 mrad/yr) gamma in air, 0.2 mGy/yr (20 mrad/yr) beta in air, 

0.05 mSv/yr (5 mrem/yr) dose to the whole body, and 0.15 mSv/yr (15 mrem/yr) dose to the 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-46 February 2010 

skin. In addition, the dose to the thyroid was within the 0.15 mSv/yr (15 mrem/yr) Appendix I 

design objectives. A comparison of dose estimates for the proposed Unit 3 to the Appendix I 

design objectives is presented in Table 5-7. The staff completed an independent evaluation of 

compliance with Appendix I design objectives and found similar results. The staff’s results also 

are shown in Table 5-7. 

Table 5-7. Comparison of MEI Dose Estimates from Liquid and Gaseous Effluents to 

10 CFR Part 50, Appendix I, Design Objectives 

Pathway/Type of Dose Dominion(a) 

Appendix I Design 

Objectives(b) 

Liquid effluents 

• Whole body dose 

• Maximum organ dose 

0.00094 mSv/yr [0.0008](d) 

00.013 mSv/yr [0.011] 

0.03 mSv/yr 

0.1 mSv/yr 

Gaseous effluents (noble gases only)(c)

• Gamma air dose 

• Beta air dose 

• Whole body dose 

• Skin dose 

0.022 mGy/yr [0.022] 

0.025 mGy/yr [0.025] 

0.016 mSv/yr [0.014] 

0.04 mSv/yr [0.039] 

0.1 mGy/yr 

0.2 mGy/yr 

0.05 mSv/yr 

0.15 mSv/yr 

Gaseous effluents (radioiodines and 

particulates) 

• Organ dose (thyroid) 0.11 mSv/yr [0.13] 0.15 mSv/yr 

(a) Multiply mSv/yr (or mGy/yr) times 100 to obtain mrem/yr (or mrad/yr). 

(b) Design objectives are for each light-water-cooled nuclear power reactor (10 CFR Part 50, Appendix I). 

(c) Dose at site boundary (0.88 mi ESE). 

(d) The staff’s estimates are shown in brackets [ ]. 

Source: Dominion 2009a. 

In Section 5.4.2 of the COL ER (Dominion 2009a), Dominion stated that estimated doses from 

liquid and gaseous effluents to the MEI at the site boundary from the existing Units 1 and 2 and 

the proposed Unit 3 combined were well within the regulatory standards of 40 CFR Part 190 and 

are bounded by the dose estimates calculated for the ESP units and the existing Units 1 and 2. 

The dose from the existing units included the gaseous and liquid effluent pathways as well as 

external dose from three fully loaded pads at the Independent Spent Fuel Storage Installation 

(ISFSI) and Units 1 and 2. The estimated annual dose at the nearest site boundary (0.76 km 

[0.47 mi] SSW of the ISFSI) was calculated to be 0.036 mSv/yr (3.6 mrem/yr) (Dominion

2009a). 

The nearest residence is located farther from the ISFSI (0.87 km [0.54 mi]) and would result in a 

lower estimated annual dose (Dominion 2009a). These data are summarized in Table 5-8. 

Dominion (2009a) conservatively assumed the annual external dose at the site boundary from 
Environmental Impacts of Operation 

February 2010 5-47 NUREG-1917, SEIS 

Units 1 and 2 to be 0.01 mSv/yr (1 mrem/yr). The staff performed an independent evaluation of 

cumulative dose and found similar results. The staff’s results also are shown in Table 5-8. 

Table 5-8. Comparison of MEI Dose Estimates from Liquid and Gaseous Effluents from 

Existing Units 1 and 2 and the Proposed Unit 3 to 40 CFR Part 190 Standards 

Type of 

Dose 

Unit 3 – 

Liquid 

(mSv/yr) 

Unit 3 – 

Gaseous 

(mSv/yr) 

Unit 3 

Total 

(mSv/yr) 

Existing 

Units 1 and 

2 (mSv/yr)(b) 

Site Total 

(mSv/yr)(c) 

40 CFR 190 

Standards 

(mSv/yr) 

Whole body 

dose 

equivalent 

0.00094 

[0.0008](f) 

0.019 

[0.019] 

0.02 

[0.02] 

0.05(e)

[0.046]

0.069 

[0.067] 

0.25 

Thyroid 

dose 

0.0018 

[0.0026] 

0.13 

[0.13] 

0.13 

[0.13] 

0.051(e)

[0.051]

0.18 [0.18] 0.75 

Dose to 

another 

organ (bone) 

0.013 

[0.011] 

0.08 

[0.079](d) 

0.092 

[0.092] 

0.051(e)

[0.051] 

0.14 [0.14] 0.25 

(a) Multiply mSv/yr (or mGy/yr) times 100 to obtain mrem/yr (or mrad/yr). 

(b) Includes dose from gaseous and liquid effluents and external dose from ISFSI. 

(c) Total dose from Units 1 and 2 and proposed Unit 3. 

(d) Equals sum of the bone dose for nearest garden, nearest residence, and nearest meat cow for each age 

group (adult, teen, child, and infant) plus the dose from the plume exposure pathway. 

(e) These estimates were derived from 2001 effluent release report as included in Dominion Nuclear North Anna, 

LLC 2006a). Estimates were typical of those from more recent effluent release reports. 

(f) The staff’s estimates are shown in brackets [ ]. 

Source: Dominion 2009a. 

5.9.3.2 Population Dose 

Dominion (2009a) estimated a collective whole body dose within 80 km (50 mi) of the proposed 

Unit 3 to be 0.087 person-Sv/yr (8.7 person-rem/yr) as shown in Table 5-9. This estimate was 

bounded by the population dose estimate from one ESP unit (Dominion Nuclear North Anna, 

LLC, 2006a) of 0.28 person-Sv/yr (28 person-rem/yr). The staff performed an independent 

evaluation of population doses and found similar results. The staff’s results also are shown in 

Table 5-9. The estimated 0.087 person-Sv/yr (8.7 person-rem/yr) from the proposed Unit 3 

compares to approximately 8400 person-Sv/yr (840,000 person-rem/yr) to same population from 

natural background radiation. The collective dose from natural background radiation was 

calculated by using the 80-km (50-mi) population data of 2.8 million and the annual estimated 

dose of approximately 3.0 mSv/person (300 mrem/person) from natural background radiation in 

the United States (NCRP 1987, 2009). Section 5.9.3.2 of the ESP EIS (NRC 2006) discussed 

the health impacts of the estimated small population dose from the two proposed ESP units, 

which would bound the impacts of the proposed Unit 3. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-48 February 2010 

Table 5-9. Collective Total Body (Population) Dose within 80 km (50 mi) of the Proposed Unit 3 

Pathway Dose (person-Sv/yr)(a) 

Liquid 0.01 [0.0085] (b)

Gaseous (noble gases) 0.015 [0.012]

Gaseous (iodines and particulates) 0.0088 [0.0098] 

Gaseous (H-3 and C-14) 0.053 [0.053]

Total 0.087 [0.083] 

(a) Multiply person-Sv/yr times 100 to obtain person-rem/yr. 

(b) Staff’s estimates are shown in brackets [ ]. 

Source: Dominion 2009a. 

5.9.3.3 Summary of Radiological Impacts to the Public 

The staff evaluated the health impacts from routine gaseous and liquid radiological effluent 

releases from the proposed Unit 3 at the NAPS site. Based on the information provided by 

Dominion and the staff’s independent evaluation, the staff concludes there would be no 

observable health impacts to the public from normal operation of the proposed Unit 3; therefore, 

the radiological health impacts would be SMALL, and additional mitigation beyond the ALARA 

program is not warranted.

5.9.4 Occupational Doses to Workers 

The estimated annual occupational dose from operations at the proposed Unit 3 is 

0.81 person-Sv (81 person-rem) (GEH 2009a). The occupational dose estimate from one ESP 

unit was 150 person-rem (Dominion Nuclear North Anna, LLC 2006a) and bounds the revised 

estimate for the ESBWR. 

The staff concludes that the health impacts from occupational radiation exposure would remain 

SMALL based on individual workers receiving less than the 10 CFR 20.1201 dose limit and the 

collective occupational dose being typical of that experienced in current light water reactors; 

therefore, mitigation beyond the ALARA program is not warranted.

5.9.5 Impacts to Biota Other than Members of the Public 

In its COL ER, Dominion (2009a) estimated doses to fish, invertebrates, algae, muskrat, 

raccoon, heron, and duck (referred to as surrogate species) from the proposed Unit 3. New 

information for the COL evaluation included the use of the ESBWR effluent release source term 

for biota dose estimates instead of the PPE source term used in the ESP evaluation.
Environmental Impacts of Operation 

February 2010 5-49 NUREG-1917, SEIS 

Table 5-9 presents the estimated doses to the surrogate species for the liquid and gaseous 

effluent pathways (Dominion 2009a). Dominion Nuclear North Anna, LLC used the same input 

parameters as provided in its ESP application (Dominion Nuclear North Anna, LLC 2006a) with 

the exception of the revised liquid and gaseous effluent source terms. A detailed listing of the 

parameters used in the biota dose calculation can be found in Appendix H of the ESP EIS (NRC 

2006). The nearest biota was assumed to located 0.40 km (0.25 mi) east-southeast of Unit 3. 

This is the same biota location that was evaluated for the ESP. Dose estimates for the 

proposed Unit 3 were lower than the dose estimates in the ESP ER (Dominion Nuclear North 

Anna, LLC 2006a) for one ESP unit. Therefore, the ESP evaluation was bounding. The staff 

performed its independent evaluation (see Table 5-10) and reached the same conclusion. 

The staff reviewed the available information relative to the radiological impact on biota from the 

routine operation of the proposed Unit 3 and concludes the impacts would remain SMALL, and 

mitigation is not warranted. 

Table 5-10. Estimated Biota Doses from Proposed Unit 3 

Biota 

Dose from Liquid Effluents 

(mGy/yr)(a,b)

Dose from Gaseous Effluents 

(mGy/yr)(a,b) 

Fish 3.3 × 10-2 [2.8 × 10-2]

(d) NA 

Invertebrates 1.2 × 10-1 [9.4 × 10-2] NA 

Algae 1.7 × 10-1 [1.5 × 10-1] NA 

Muskrat 2.1 × 10-1 [1.8 × 10-1] 2.0 × 10-1 [1.5 × 10-1]

Raccoon 6.2 × 10-3 [5.3 × 10-3 ] 2.0 × 10-1 [1.5 × 10-1] 

Heron 9.9 × 10-2 [8.4 × 10-2] 2.0 × 10-1 [1.5 × 10-1] 

Duck 2.1 × 10-1 [1.8 × 10-1] 2.0 × 10-1 [1.5 × 10-1] 

(a) Multiply mGy/yr times 100 to obtain mrad/yr. 

(b) Staff estimates are in brackets [ ]. The staff estimates are lower because the staff used the annual 

liquid effluent release values from DCD Revision 6 (GEH 2009a) while Dominion used the release 

values from DCD Revision 5 (GEH 2008). 

Source: Dominion 2009a. 

5.9.6 Radiological Monitoring 

The staff reviewed the radiological monitoring program (REMP) proposed for the ESP units in its 

ESP EIS (NRC 2006) and determined that the current monitoring program for Units 1 and 2 

would be adequate for the proposed ESP units. This evaluation is found in Section 5.9.6 of the 

ESP EIS. 

The staff’s new and significant information review identified new information regarding 

groundwater sampling. Dominion now performs additional groundwater sampling around 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-50 February 2010 

Units 1 and 2 and the ISFSI in support of the Nuclear Energy Institute (NEI) Ground Water 

Protection Initiative. These results are summarized in the annual effluent monitoring report and 

annual environmental operating report for 2006 and 2007 (VEPCo 2007a,b, 2008a,b). Samples 

were analyzed for tritium and a few locations for gamma emitters and strontium-89/90. VEPCo 

(2008a) reported that tritium results were indicative of lake-to-groundwater communication and 

not indicative of a leak from a radioactive system. Additional groundwater sampling will be 

performed around the proposed Unit 3 as part of the NEI Ground Water Protection Initiative. 

Dominion (2009d) has endorsed the NEI 07-09 Template entitled “Generic FSAR Template 

Guidance for Offsite Dose Calculation Manual (ODCM) Program Description.” This template 

presents the generic elements of the REMP to include the means to monitor and quantify 

radiation and radioactivity levels in the environs of a plant associated with gaseous and liquid 

effluent releases and contribution of direct external radiation from contained sources of 

radioactive materials in tanks, equipment, and buildings. The staff has concluded that 

applicants implementing the elements of the NEI 07-09 Template have an acceptable REMP. 

The staff did not identity information that was both new and significant related to radiological 

monitoring through its evaluation of the information provided by Dominion and the staff’s own 

independent evaluation. The staff concludes that the current radiological monitoring program 

for Units 1 and 2 would be adequate to establish the radiological impacts to the environment 

related to the operation of the proposed Unit 3 at the NAPS site. 

5.10 Environmental Impacts of Postulated Accidents 

The impacts of postulated accidents of new reactors at the NAPS ESP site were considered by 

the NRC staff in its review of Dominion’s application for an ESP. The impacts identified in that 

review were determined to be of SMALL significance (NRC 2006). The applicable accident 

source terms listed in Appendix B of ESP-003 (NRC 2007b) do not bound the accident source 

terms for the ESBWR. Consequently, the staff updated its review of potential impacts for 

postulated accidents, taking into account the changes in source terms. Consequence estimates 

are based on the ESBWR DCD currently under review pursuant to 10 CFR Part 52. 

The term “accident,” as used in this section, refers to any off-normal event not addressed in 

Section 5.9 that results in release of radioactive materials into the environment. The focus of 

this review is on events that could lead to releases substantially in excess of permissible limits 

for normal operations. Normal release limits are specified in 10 CFR Part 20, Appendix B, 

Table 2. 

Numerous features combine to reduce the risk associated with accidents at nuclear power 

plants. Safety features in the design, construction, and operation of the plants, which comprise 

the first line of defense, are intended to prevent the release of radioactive materials from the 
Environmental Impacts of Operation 

February 2010 5-51 NUREG-1917, SEIS 

plant. There are additional measures designed to mitigate the consequences of failures in the 

first line of defense. These include the NRC’s reactor site criteria in 10 CFR Part 100, which 

require the site to have certain characteristics that reduce the risk to the public and the potential 

impacts of an accident, and emergency preparedness plans and protective action measures for 

the site and environs, as set forth in 10 CFR 50.47, 10 CFR Part 50, Appendix E, and 

NUREG-0654/FEMA-REP-1 (NRC 1980). These safety features, measures, and plans 

contribute to the defense-in-depth philosophy to protect the health and safety of the public and 

the environment. 

This section discusses (1) the types of radioactive materials, (2) the paths to the environment, 

(3) the relationship between radiation dose and health effects, and (4) the environmental 

impacts of reactor accidents, both design basis accidents (DBAs) and severe accidents. The 

environmental impacts of accidents during transportation of spent fuel are discussed in 

Chapter 6. 

Radioactive material exists in a variety of physical and chemical forms. The majority of the 

material in the fuel is in the form of nonvolatile solids. However, there is a significant amount of 

material that is in the form of volatile solids or gases. The gaseous radioactive materials include 

the chemically inert noble gases (e.g., krypton and xenon), which have a high potential for 

release. Radioactive forms of iodine, which are created in substantial quantities in the fuel by 

fission, are volatile. Other radioactive materials formed during the operation of a nuclear power 

plant have lower volatilities and, therefore, have lower tendencies to escape from the fuel than 

the noble gases and iodines. 

Radiation exposure to individuals is determined by their proximity to radioactive material, the 

duration of their exposure, and the extent to which they are shielded from the radiation. 

Pathways that lead to radiation exposure include (1) external radiation from radioactive material 

in the air, on the ground, and in the water; (2) inhalation of radioactive material; and 

(3) ingestion of food or water containing material initially deposited on the ground and in water. 

Radiation protection experts conservatively assume that any amount of radiation exposure may 

pose some risk of causing cancer or a severe hereditary effect and that the risk is higher for 

higher radiation exposures. Therefore, a linear, no-threshold response model is used to 

describe the relationship between radiation dose and detriments such as cancer induction. 

The BEIR VII report recently published by the National Research Council (2006) supports the 

linear, no-threshold dose response theory. Simply stated, any increase in dose, no matter how 

small, results in an incremental increase in health risk. This theory is accepted by the NRC as a 

conservative model for estimating health risks from radiation exposure, recognizing that the 

model probably overestimates those risks. 

Physiological effects are clinically detectable should individuals receive radiation exposure 

resulting in a dose greater than about 0.25 Sv (25 rem) over a short period of time (hours). 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-52 February 2010 

Doses of about 2.5 to 5 Sv (250 to 500 rem) received over a relatively short period (hours to a 

few days) can be expected to cause some fatalities.

5.10.1 Design Basis Accidents

The review of DBAs is described in Section 5.10.1 of the ESP EIS (NRC 2006). The review of 

environmental impacts of postulated accidents in the ESP EIS assumed the location of two new 

nuclear units at the NAPS ESP site with the following reactor design options: ABWR, AP1000, 

and ESBWR. The DBA analyses of the ESP EIS (NRC 2006) were based on Revision 1 of the 

ESBWR DCD (General Electric 2006). The initial COL application submitted by Dominion 

(2008a) was for one new ESBWR based on Revision 4 of the ESBWR DCD (GEH 2007). Since 

Revision 0 of the COL application was prepared, the ESBWR applicant has submitted 

Revision 6 to the DCD (GEH 2009a) to the NRC for review. The NRC staff expects Dominion to

revise its COL ER to adopt the latest version of the ESBWR DCD prior to the completion of the

application review. Therefore, the evaluation of consequences of DBAs is based on the source 

terms from Revision 6 of the DCD. The calculation approach used by Dominion for its COL 

application is consistent with the approach described in the ESP EIS (NRC 2006) and is 

summarized below. 

Dominion evaluated the potential consequences of postulated accidents to demonstrate that an 

ESBWR could be constructed and operated at the NAPS site without undue risk to the health 

and safety of the public (Dominion 2009a). These evaluations used a set of surrogate DBAs 

that are representative for the reactor design being considered for the NAPS site and sitespecific meteorological data. The set of accidents covers events that range from relatively high 

probability of occurrence with relatively low consequences to relatively low probability with high 

consequences. Consideration is given to one additional accident type (Cleanup Water Line 

Break with Pre-Incident Iodine Spike) that was not included in Revision 1 of the ESBWR DCD 

(General Electric Company 2006). 

The analyses in the ESP EIS (NRC 2006) assumed the accident releases occurred from the 

location within the area surrounding the two proposed units that resulted in the greatest dose. 

The single unit proposed in the COL application is situated entirely within the two-unit area 

assumed in the ESP application, so the previous EAB and low-population zone (LPZ) distances 

remain valid for the COL application. Any land acquisition that would increase the distance to 

the EAB in a particular direction would further reduce calculated doses. Potential 

consequences of DBAs are evaluated following procedures outlined in regulatory guides and 

standard review plans. Potential consequences of accidental releases depend on specific 

radionuclides released, radionuclide release rates, and meteorological conditions. Methods for 

evaluating potential accidents are based on guidance in Regulatory Guide 1.183 (NRC 2000b). 

Meteorological conditions are represented in these consequence analyses by atmospheric 

dispersion factors, also referred to as χ/Qs. Acceptable methods of calculating χ/Qs for 
Environmental Impacts of Operation 

February 2010 5-53 NUREG-1917, SEIS 

DBAs from meteorological data are set forth in Regulatory Guide 1.145 (NRC 1983). For 

environmental reviews, consequences are evaluated assuming realistic meteorological 

conditions. The meteorological data set used for this review is the same set as used in the 

ESP EIS (NRC 2006). 

Table 5-11 lists χ/Qs used in the environmental review of DBAs for the NAPS site. The first 

column lists the time periods and boundaries for which χ/Q and dose estimates are considered. 

For the exclusion area boundary, the postulated DBA dose and its atmospheric dispersion factor 

are calculated for a short-term (i.e., 2 hours), and for the LPZ, they are calculated for the course 

of the accident (i.e., 30 days [720 hours]) composed of four time periods. 

Table 5-11. Atmospheric Dispersion Factors for NAPS COL Site DBA Calculations 

Time Period and Boundary χ/Q (s/m3

) 

0 to 2 hr, Exclusion area boundary 3.34 × 10−5

0 to 8 hr, Low population zone 2.17 × 10−6

8 to 24 hr, Low population zone 1.50 × 10−6

1 to 4 d, Low population zone 1.20 × 10−6

4 to 30 d, Low population zone 9.00 × 10−7

Source: Dominion 2009a. 

In Table 7.1-1 of the COL ER (Dominion 2009a), the second column lists the χ/Qs presented. 

The χ/Qs match those presented in Table 5-14 of the ESP EIS (NRC 2006) that were developed 

using the site meteorological information discussed in ESP ER Section 2.7 (Dominion Nuclear 

North Anna, LLC 2006a) and Section 2.3 of the ESP EIS (NRC 2006), and the EAB and LPZ 

distances. Even with the collection of additional meteorological information, the χ/Qs used for 

accident consequence calculations need not change unless the initial meteorological data set 

was not representative of the site. 

The staff confirmed the meteorological data used by Dominion and the method used to calculate 

the atmospheric dispersion factors matched those evaluated in the ESP EIS (NRC 2006). 

Based on the previous reviews, the staff concludes that the χ/Qs for the NAPS site remain 

acceptable for use in evaluating potential environmental consequences of postulated DBAs for 

the ESBWR design at the NAPS site. 

Table 5-12 lists the set of DBAs considered and presents estimates of the environmental 

consequences of each accident in terms of total effective dose equivalent (TEDE), which is the 

sum of the committed effective dose equivalent from inhalation and the deep dose equivalent 

from external exposure. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-54 February 2010 

Table 5-12. DBA Doses for an ESBWR Reactor

Accident

Standard Review 

Plan Section(b)

TEDE in Sv(a)

EAB LPZ

Safety Review 

Criterion

Main steam line break 15.6.4 

 Pre-incident iodine spike 4.3 × 10−4 2.3 × 10−5 2.5 × 10−1(c)

 Equilibrium iodine activity 3.3 × 10−5 1.1 × 10−5

 2.5 × 10−2(d)

Loss-of-coolant accident 15.6.5 3.7 × 10−3 6.2 × 10−3

 2.5 × 10−1(c)

Feedwater system pipe break 15.2.8 

 Pre-incident iodine spike 3.0 × 10−3 1.9 × 10−4

 2.5 × 10−1(c)

 Equilibrium Iodine activity 1.8 × 10−5 1.1 × 10−5

 2.5 × 10−2(d)

Failure of small lines carrying primary 

coolant outside containment 

15.6.2 

 Pre-incident iodine spike 5.7 × 10−5 3.0 × 10−5(e)

 2.5 × 10−1(c)

 Equilibrium iodine activity 1.7 × 10−5 3.0 × 10−5(e)

 2.5 × 10−2(d)

Fuel handling 15.7.4 6.8 × 10−4 4.6 × 10−5

 6.3 × 10−2(d)

Cleanup water line break NA(f)

 

 Pre-incident iodine spike 1.2 × 10−3 8.0 × 10−5

 2.5 × 10−1(c)

 Equilibrium iodine activity 6.7 × 10−5 1.1 × 10−5

 2.5 × 10−2(d)

(a) To convert Sv to rem, multiply Sv by 100. 

(b) NUREG-0800 (NRC 2007a). 

(c) 10 CFR 52.79(a)(2) and 10 CFR 100.21 criterion. 

(d) Standard Review Plan criterion. 

(e) Value reported here is different from value provided in ER Table 7.1-2 (Dominion 2009a). Staff used χ/Q ratio 

(Unit 3/DCD) of 3.00 × 10-2 from ER Table 7.1-1 for LPZ 96–720 hr Failure of Small Line Carrying Primary 

Coolant Outside Containment (Dominion 2009a) and dose estimate from DCD Table 15.4-19 (GEH 2009a), 

where the applicant appears to have used χ/Q ratio (Unit 3/DCD) of 1.14 × 10-2. 

(f) There is no applicable SRP section. 

The DBAs listed in Table 5-12 are the same as those being considered in the design 

certification; therefore, the staff concludes that the set of DBAs is appropriate. In addition, the 

staff independently evaluated the calculation of the consequences of the DBAs in Revision 6 of 

the ESBWR DCD. Table 5-12 reflects the DBA consequences, accounting for site-specific 

χ/Qs. 

There are no environmental criteria related to the potential consequences of DBAs. 

Consequently, the review criteria used in the staff’s safety review of DBA doses are included in 

Table 5-12 to illustrate the magnitude of the calculated environmental consequences (TEDE 

doses). The staff considered the new information related to a new accident type and changes in 

source terms to determine if it is significant. For new information to be “significant,” it must be 

material to the issue being considered; that is, it must have the potential to affect the finding or 

conclusions of the NRC staff’s evaluation of the issue (72 FR 49352). This new information is 
Environmental Impacts of Operation 

February 2010 5-55 NUREG-1917, SEIS 

significant because it has the potential to affect the staff conclusions related to design basis 

accidents. In all cases, the calculated TEDE values remain considerably smaller than the TEDE 

doses used as safety review criteria. 

Summary of DBA Impacts 

The NRC staff reviewed the DBA analysis in the COL ER (Dominion 2009a), which is based on 

analyses performed for design certification of the ESBWR design with adjustment for NAPS sitespecific characteristics. The results of the staff evaluation indicate that the estimated 

environmental consequences associated with DBAs, if an ESBWR were to be located at the 

NAPS site, would be a small fraction of the dose guideline values (safety review criteria). 

Accounting for the new and significant information, the staff concludes that the environmental 

consequences of DBAs for an ESBWR reactor at the North Anna ESP site would be SMALL. 

5.10.2 Severe Accidents 

Dominion performed analyses of the potential environmental impacts of severe accidents as 

part of its application for an ESP. These analyses included an assessment of the potential 

impacts of severe accidents for the Advanced Light-Water Reactor (ALWR) designs (ABWR, 

AP1000, and ESBWR). The NRC staff reviewed and evaluated the results of the Dominion 

analyses and, after its review, presented the results in its ESP EIS (NRC 2006). In the 

ESP EIS, the NRC staff concluded that the probability-weighted consequences of the severe 

accidents for an ALWR at the North Anna ESP site were of SMALL significance. 

The COL application submitted by Dominion (2008a) was for one new ESBWR unit based on 

Revision 4 of the ESBWR DCD (GEH 2007). As part of its assessment of new and significant 

information for the COL application, Dominion reviewed the severe accident consequence 

analysis in the ESP EIS. Although changes in the ESBWR design constitute new information, 

Dominion concluded that the information was not significant. During its site audit, the NRC staff 

reviewed the Dominion analysis. 

Dominion revised its COL ER to adopt Revision 5 of the ESBWR DCD (Dominion 2009a). 

However, as discussed in the previous section, since preparation of Revision 1 of the COL 

application, the ESBWR applicant has submitted Revision 6 (GEH 2009a) to the NRC for 

review. In addition, the ESBWR applicant has submitted a revision to the ESBWR probabilistic 

risk assessment (PRA) (GEH 2009b). For new information to be ‘‘significant,’’ it must be 

material to the issue being considered; that is, it must have the potential to affect the finding or 

conclusions of the NRC staff’s evaluation of the issue (72 FR 49352). This new information is 

significant because it has the potential to affect the staff conclusions related to severe 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-56 February 2010 

accidents. The staff has limited its severe accident review to evaluation of the effects of 

changes in source term and core damage frequency based on Revision 6 of the DCD and 

Revision 4 of the PRA. 

The staff compared the reactor core inventories, release fractions, and core damage 

frequencies, from ESBWR DCD Revision 6 with those considered in the ESP EIS and in the 

draft SEIS. The changes in inventories, release fractions, and core damage frequencies, tend 

to offset each other. In Section 5.10.2.1 of the ESP EIS, the staff analysis shows that the risks 

associated with the ESBWR were several orders of magnitude lower than the risks associated 

with the Commission’s safety goals (51 FR 30028). Based on the changes in the reactor design 

and revised PRA, the staff estimates that the probability-weighted consequences of severe 

accidents are generally no more than a factor of 5 greater than those reported in Table 5-20 of 

the ESP EIS (NRC 2006). The exception to this is the risk of early fatality, which has increased 

by an about an order of magnitude. 

The staff determined that the changes in the information related to the impact of severe 

accidents are minor when compared to the Commission’s safety goals; both the average 

individual risk and the population risk remain several orders of magnitude below the risk levels 

established based on the safety goals. Considering the new and significant information, the 

staff concludes that probability-weighted consequences of severe accidents for an ESBWR 

reactor at the North Anna ESP site would be SMALL. Mitigation is discussed in the following 

section. 

5.10.3 Severe Accident Mitigation Alternatives 

Severe accident mitigation alternatives (SAMAs) include design alternatives intended to reduce 

the likelihood or consequences of reactor accidents that are more severe than DBAs. They also 

include procedural and training alternatives to achieve the same objectives. The purpose of the 

evaluation of SAMAs is to determine whether there are severe accident mitigation design 

alternatives (SAMDAs), procedural modifications, or training activities that can be justified to 

further reduce the risks of severe accidents (NRC 2000b). 

Appendix M contains a detailed review of the GE-Hitachi Nuclear Energy and Dominion SAMA 

analyses and presents the staff conclusions related to the NAPS site-specific analysis after 

considering changes in the ESBWR design (GEH 2009a) and PRA (GEH 2009b) . After 

reviewing the Dominion analysis and performing its independent evaluation, the staff concludes 

that there are no ESBWR SAMDAs that would be cost beneficial at the NAPS site. The staff 

further concludes that detailed consideration of procedural SAMAs should be deferred until 

procedures and training programs are being developed. The staff has a reasonable expectation 

that risk mitigation measures will be considered when procedures and training programs are 

developed and that procedure development will be completed prior to loading fuel. 
Environmental Impacts of Operation 

February 2010 5-57 NUREG-1917, SEIS 

5.10.4 Summary of Postulated Accident Impacts 

The staff evaluated the environmental impacts from DBAs and severe accidents for an ESBWR 

at the NAPS site. Based on the information provided by Dominion and NRC’s independent 

review, the staff concludes that the potential environmental impacts (risks) from postulated 

accidents from the operation of the proposed ESBWR would be SMALL, and further mitigation 

is not warranted. 

5.11 Global Warming, Climate Change, and Greenhouse 

Gas Impacts 

This section provides information on contemporary issues related to global warming, climate 

change and greenhouse gas emissions associated with the operation of the proposed Unit 3. 

Air quality impacts from operations are addressed in Section 5.2 of the SEIS. 

The greenhouse effect is a naturally occurring process, whereby certain gases, such as water 

vapor, carbon dioxide, methane, and other trace gases in the atmosphere absorb and emit 

infrared radiation back to the earth’s surface. Without these so-called greenhouse gases, the 

earth’s atmosphere would be significantly colder and the planet would be uninhabitable. When 

discussing global warming, increases in carbon dioxide are generally of primary concern, because 

carbon dioxide has a long lifetime in the atmosphere and it is very effective at absorbing in an 

infrared band (12 pm to 16 pm) that would otherwise be transparent to this energy. 

Human activity over the past century has been increasing carbon dioxide concentrations in the 

atmosphere, and the concern is that the additional carbon dioxide is enhancing the greenhouse 

effect and causing the earth’s atmosphere to warm. Although water vapor also is an important 

greenhouse gas, the lifetime for water vapor in the atmosphere is just a few days. This rapid 

turnover means that even if human activity is directly adding to or removing water vapor from 

the atmosphere, there would be no slow buildup of water vapor in a similar manner as with 

carbon dioxide. Water vapor concentration in the atmosphere is mainly a function of 

temperature and any additional increase in concentration, for example, from a cooling tower, is 

rapidly lost. The amount of carbon dioxide in the atmosphere, however, is determined by a 

balance between sources (e.g., transportation or industrial activity) and sinks (e.g., vegetative 

photosynthesis) and any increase in concentration from human activity can take hundreds of 

years for levels to return to pre-industrial levels even if all future carbon emissions ceased. 

Increased carbon dioxide emissions to the environment are generally attributed to the 

consumption of fossil fuels, whether for industrial use, such as an energy-intensive 

manufacturing facility, or personal use, such as for the automobile. Nuclear power plants do not 

emit carbon dioxide in large quantities during the operation of the facility for the production of 

electricity. Emissions are principally from auxiliary boiler operation and standby diesel 

generator testing. However, fossil fuels are often used as part of the infrastructure needed to 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-58 February 2010 

operate a nuclear power facility, primarily for the manufacture of the fuel that is used in the 

facility. A high percentage of the energy used in the uranium fuel cycle is consumed in the 

enrichment stage of the fuel cycle. The estimate of future nuclear fuel needs, current feedstock 

supplies, and the quality of uranium ore will have a direct bearing on the mining stage through 

the enrichment stage of the fuel cycle. 

Accounting for the uranium fuel cycle, the NRC estimates that the energy needed for the fuel’s 

life cycle for one year of operation of a 1000 MW(e) light water reactor would be about 5 percent 

of the net output of the reactor (see 10 CFR 51.51, Table S–3, and Table 6-1 of ESP EIS [NRC 

2006]). The U.S. Department of Energy (DOE) estimated that the carbon emissions that would 

be displaced if nuclear power plants replaced coal-based electricity generation would be about 

2.1 million metric tons per year for every unit of approximately 1000 MW(e) (Hagen et al. 2001). 

Therefore, using the DOE estimate and the 5 percent factor, approximately 105,000 MT 

(115,747 tons) of carbon would be produced for every 1000 MW(e) assuming a nuclear power 

plant was operating for the entire year. If the equivalent electricity were generated by alternative 

or renewable energy sources, then this quantity could be reduced, and if a combination of 

conservation and alternative energy sources were considered, the amounts could be reduced even 

further. The staff has evaluated energy alternatives and their associated impacts in Chapter 9. 

With the increasing interest in the nuclear power program in the United States, advancements in 

power reactor technology and uranium enrichment technology, the total carbon emissions that 

may result from the fuel cycle may differ from those described above. Depending on the 

number of existing nuclear power units that are considered for license renewal and the number 

of new nuclear power plant units that are contemplated, the need for new fuel resources is likely 

to be an important variable in this assessment. 

The staff considered the potential impact of climate change on water supply. The staff 

considered both the United States Global Change Research Program National Assessment 

(USGCRP 2000) and the Intergovernmental Panel on Climate Change AR4 Synthesis Report 

(IPCC 2007). Both studies agree on predicted increases in temperature. However, precipitation 

estimates in the climate models suggest either an increase in precipitation or precipitation 

remaining about the same as present. While there is general agreement in the scientific 

community that some change in climate is occurring, considerable uncertainty remains in the 

magnitude and direction of some of the changes. In light of these uncertainties, balancing 

society’s need for electricity and water under an altered climate is not now feasible and would 

amount to speculation. 

The impacts of global warming and climate change from the operation of the proposed Unit 3 at 

the NAPS site are negligible at the global level. The need for power analysis is addressed in 

Chapter 8; the results of the need for base-load capacity analysis indicate that there is currently 

a need for additional base-load capacity within the Dominion Zone. Consequently, the 

environmental impacts associated with the effects of greenhouse gas emissions from the 
Environmental Impacts of Operation 

February 2010 5-59 NUREG-1917, SEIS 

operation of a base-load power plant are unique between a fossil fuel and nuclear plant. The 

carbon emissions that would be displaced if nuclear power plants replaced coal-based electricity 

generation would be about 2.1 million MT/yr (2.31 million tons/yr) for every unit of approximately 

1000 MW(e). Therefore, the impacts from the effects of greenhouse gas emissions from the 

proposed Unit 3 at the NAPS site are SMALL beneficial by comparison to the fossil fuel baseload alternative. 

5.12 Measures and Controls to Limit Adverse Impacts 

During Operation 

The general measures and controls on which the staff relied in its evaluation of environmental 

impacts during operation of a single new unit at the NAPS site include applicable permits and 

authorizations required at the Federal, State, and local levels as listed in Table 1.2.1 of the 

COL ER (Dominion 2009a) as well as the mitigation actions contained in Environmental 

Protection Plan (EPP) included in Chapter 1 of the COL ER (Dominion 2009a). The main focus 

of EPP includes: 

• Compliance with the applicable Federal, Virginia, and local laws, ordinances, and 

regulations that prevent or minimize adverse environmental impacts (e.g., solid waste 

management, erosion and sediment control, air emission control, noise control, storm water 

management, spill response and cleanup, hazardous material management) 

• Compliance with applicable requirements of permits and licenses required for operation 

(e.g., National Pollutant Discharge Elimination System and VPDES permits and operating 

license requirements) 

• Compliance with Dominion procedures applicable to environmental control and 

management. 

Dominion also evaluated the measures and controls listed in Section 5.10 of the COL ER 

(Dominion 2009a) and considered them feasible from both a technical and economic standpoint. 

Dominion expects these measures and controls to be adequate for avoiding or mitigating 

potential adverse impacts associated with operation of the proposed Unit 3. These measures 

and controls include: 

• Nonradioactive effluents, including sanitary waste and blowdown from the proposed Unit 3 

cooling towers, will be controlled by limits established in the VPDES permit. 

• The new and separate Unit 3 sanitary waste treatment systems will be governed by 

applicable regulations and permits. 

• Operation of a dechlorination system to neutralize chlorine in the circulating water and plant 

service water cooling tower blowdown before discharge to the WHTF and eventually to the 

North Anna Reservoir, 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-60 February 2010 

If these measures and controls are implemented, the staff concludes that impacts resulting 

from operational activities will be mitigated. 

5.13 Summary of Operational Impacts 

Expected impact level categories are denoted in Table 5-22 of the ESP EIS (NRC 2006). These 

levels are designated as SMALL, MODERATE, or LARGE as a measure of their expected 

adverse impacts, if any. There is one addition to the original estimates in Table 5-22. The 

impact from global warming that was not evaluated in the ESP EIS (NRC 2006), but was 

evaluated as part of the SEIS with information provided in Section 5.11. The estimated impact 

is SMALL beneficial and mitigation action is not warranted. 

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to Michael Sackschewsky, Pacific Northwest National Laboratory, “North Anna Power Station 

Unit 3 – North Anne Project Site, Construction Staging Area and North Anna to Ladysmith 

Transmission Line Corridor,” September 29, 2009. Accession No. ML 093160317. 

Virginia Department of Environmental Quality (VDEQ). 2001. Authorization to Discharge under 

the Virginia Pollutant Discharge Elimination System (VPDES) and the Virginia State Water 

Control Act. VPDES Permit No. VA0052451, effective January 11, 2001, Virginia Department of 

Environmental Quality, Richmond, Virginia. 

Virginia Department of Environmental Quality (VDEQ). 2007. Authorization to Discharge under 

the Virginia Pollutant Discharge Elimination System (VPDES) and the Virginia State Water 

Control Act. VPDES Permit No. VA0052451, effective October 25, 2007, Virginia Department of 

Environmental Quality, Richmond, Virginia. 
Environmental Impacts of Operation 

NUREG-1917, SEIS 5-70 February 2010 

Virginia Electric and Power Company (VEPCo). 2007a. 2006 North Anna Power Station, 

Annual Radiological Environmental Operating Report (January 1, 2006 to December 31, 2006). 

Accession No. ML071230069. 

Virginia Electric and Power Company (VEPCo). 2007b. Annual Radioactive Effluent Report 

North Anna Power Station (January 1, 2006 to December 31, 2006). Accession 

No. ML071230069. 

Virginia Electric and Power Company (VEPCo). 2008a. 2007 North Anna Power Station, 

Annual Radiological Environmental Operating Report (January 1, 2007 to December 31, 2007). 

Accession No. ML081280636. 

Virginia Electric and Power Company (VEPCo). 2008b. Annual Radioactive Effluent Report 

North Anna Power Station (January 1, 2007 to December 31, 2007). Accession 

No. ML081280632. 

World Health Organization (WHO). 2002. Assessment of the Health Effects of EMF 

Exposure – Radiological Science Bulletin Number 301. June 2002. 

World Health Organization (WHO). 2007. Extremely Low Frequency Fields. Environmental 

Health Criteria Monograph No. 238, Geneva, Switzerland. Accession No. ML082880728. 
February 2010 6-1 NUREG-1917, SEIS 

6.0 Fuel Cycle, Transportation, and Decommissioning 

This chapter addresses the environmental impacts from (1) the uranium fuel cycle and solid 

waste management, (2) transportation of radioactive material, and (3) decommissioning for the 

proposed Unit 3 at the North Anna Power Station (NAPS) site. As part of its application, for a 

combined license (COL), Dominion Virginia Power and Old Dominion Electric Cooperative, 

collectively known as Dominion, submitted an Environmental Report (ER) (Dominion 2009a) 

that discussed the environmental impacts of transporting radioactive materials (Section 3.8), of 

the uranium fuel cycle (Section 5.7), and of decommissioning (Section 5.9). In accordance with 

Title 10 of the Code of Federal Regulations (CFR) Part 51, impacts have been analyzed and a 

significance level of potential adverse impacts (i.e., SMALL, MODERATE, or LARGE) has been 

assigned to each analysis. Since the NAPS site has an approved early site permit (ESP), the 

significance levels of the potential adverse impacts for the various areas evaluated will remain 

the same as documented in the ESP environmental impact statement (EIS) (NRC 2006) for the 

NAPS site unless new and significant information has been identified that would modify the 

original significance level. The definition of new and significant information is documented in a 

Federal Register notice (72 FR 49352). The NRC staff’s determination of significance levels is 

based on the assumption that the mitigation measures identified in the ER or activities planned 

by various State and County governments, such as infrastructure upgrades, as discussed 

throughout this chapter, are implemented. Failure to implement these upgrades might result in 

a change in significance level. 

There were several unresolved issues identified in the ESP EIS related to this chapter (see 

Appendix J of the ESP EIS [NRC 2006]). Environmental impacts from uranium fuel cycle 

activities other than light water reactors (LWR) were not resolved; however, this is not 

applicable because the Economic Simplified Boiling-Water Reactor (ESBWR) design for the 

proposed Unit 3 is an LWR design. Environmental impacts from transportation of gas-cooled 

reactor fuels were not resolved, but again, this is not applicable because the ESBWR is an LWR 

design. Finally, decommissioning was identified as an unresolved issue in the ESP EIS. The 

environmental review on decommissioning was deferred to the COL stage per the ESP EIS, and 

is presented in Section 5.9 of the COL ER (Dominion 2009a) and Section 6.3 of this 

supplemental EIS (SEIS). 

6.1 Fuel Cycle Impacts and Solid Waste Management 

The NRC staff reviewed fuel cycle impacts in Section 6.1 of its ESP EIS (NRC 2006), and 

concluded that the environmental impacts of the uranium fuel cycle for advanced LWR reactors 

would be SMALL and mitigation is not warranted. 
Fuel Cycle, Transportation, and Decommissioning 

NUREG-1917, SEIS 6-2 February 2010 

The staff’s review for proposed Unit 3 did not identify any new and significant information 

regarding fuel cycle impacts and solid waste management. The uranium fuel cycle impacts are 

scaled to Table S–3 impacts found in 10 CFR 51.51(b) based on reactor power level. 

Table S–3 provides the environmental impacts from uranium fuel cycle operations for a model 

1000-MW(e) LWR operating at 80-percent capacity with a 12-month fuel-loading cycle and an 

average fuel burnup of 33,000 MWd/MTU. Per 10 CFR 51.51(b), the staff considers the 

impacts in Table S–3 to be acceptable for the 1000 MW(e) reference reactor and for adequately 

bounding fuel cycle impacts associated with the proposed Unit 3. 

For the ESP EIS plant parameter envelope, the reactor power level was 9000 MW(t). This 

power level corresponded to 3040 MW(e) (NRC 2006). The proposed Unit 3 would be a 

4500 MW(t) ESBWR (Dominion 2009a) with a corresponding net electrical rating of 

1520 MW(e). Therefore, the uranium fuel cycle impacts from the ESP EIS (NRC 2006) would 

bound the Unit 3 impacts. Unit 3 impacts would be one-half of the impacts presented in the 

ESP EIS (NRC 2006) or approximately 1.9 times the impacts presented in Table S–3. 

North Anna Units 1 and 2 can no longer dispose of Class B and C low-level waste (LLW) at the 

Energy Solutions site in Barnwell, South Carolina. Proposed Unit 3, if in operation, also would 

not be able to dispose of these wastes at the Energy Solutions site. However, Class A LLW can 

be shipped to the Energy Solutions site in Clive, Utah. Other disposal sites may be available by 

the time proposed Unit 3 would become operational. The industry is investigating alternate 

disposal pathways for Class B and C LLW to include (1) compaction and storage at offsite 

vendor locations until disposal is secured and (2) blending of waste types with subsequent 

disposal at available disposal sites. 

The staff anticipates that licensees will temporarily store Class B and C LLW onsite until offsite 

storage locations are available. Dominion (2009b) has proposed storing packaged Class B and 

Class C waste accumulated over at least 10 years from the proposed Unit 3 onsite in the 

radwaste building. Several operating nuclear power plants have successfully increased onsite 

storage capacity in the past in accordance with existing NRC regulations. This extended waste 

storage onsite resulted in no significant increase in dose to the public. Additionally, the NRC 

issued considerations for extended onsite interim storage of LLW in Regulatory Issue 

Summary 2008-12 (NRC 2008). Examples of considerations included storing waste in a 

manner that minimizes potential exposure to workers, which may require adding shielding and 

storing waste in packaging compatible with the waste composition (e.g., chemical and thermal 

properties). 

The staff concluded in the Generic Environmental Impact Statement for License Renewal of 

Nuclear Plants (NUREG-1437) (NRC 1996) that the radiological impacts from LLW storage 

would be small and fall within current regulatory requirements. Although NUREG-1437 is for 

license renewal activities, the staff believes the same evaluation can be applied to new reactor 

licensing. In NUREG-1437 (Section 6.4.4.2), the staff concluded that there should be no 
Fuel Cycle, Transportation, and Decommissioning 

February 2010 6-3 NUREG-1917, SEIS 

significant issues or environmental impacts associated with interim storage of LLW generated 

by nuclear power plants. Interim storage facilities would be used until these wastes could be 

safely shipped to licensed disposal facilities. Dominion’s resolution of LLW disposal issues for 

existing Units 1 and 2 could also be implemented for proposed Unit 3. No new and significant 

information was identified regarding LLW disposal. 

The staff did not identify any new information regarding uranium fuel cycle and solid waste 

management impacts through its evaluation of the information provided by Dominion and the 

staff’s independent review. Environmental impacts of storing additional Class B and C waste in 

the proposed Unit 3 radwaste building were determined to be small based on operating 

experience at current nuclear power plants and the interim LLW storage discussion in 

NUREG-1437. The staff concludes that the uranium fuel cycle and solid waste management 

impacts would remain SMALL, and mitigation is not warranted. 

6.2 Transportation of Radioactive Materials 

The ESP EIS (NRC 2006) provided a detailed analysis of the radiological impacts of 

transporting fuel and radioactive waste to and from the NAPS ESP site and alternative sites. 

The ESP EIS concluded that a detailed transportation impact analysis was required because the 

proposed reactor did not meet all of the conditions specified in 10 CFR 51.52(a). The NRC staff 

performed the detailed transportation impact analysis that is described in the ESP EIS using 

standard methods and data supplemented by site-specific and reactor-specific information. The 

impacts were normalized by the staff to the reference reactor year to make comparisons to 

10 CFR 51.52, Table S–4. The ESP EIS stated that, “Because of the conservative approaches 

and data used to calculate impacts, actual environmental effects are not likely to exceed those 

calculated in the EIS.” Based on this statement and the impacts calculated in the EIS, the staff 

concluded that, “ ... the environmental impacts of transportation of fuel, and radioactive wastes 

to and from the North Anna ESP site would be SMALL, and would be consistent with the 

environmental impacts associated with transportation of materials, personnel, fuel, and 

radioactive wastes from current-generation reactors presented in Table S–4 of 10 CFR 51.52.” 

This SEIS addresses an unresolved issue about fuel and waste transportation that was 

identified in the ESP EIS. This unresolved issue involves the effects of spent fuel assembly 

crud on spent fuel transportation accident impacts. An analysis of the nonradiological impacts 

of transporting fuel and waste to and from the NAPS site also is provided. 

6.2.1 Impacts of Crud on Spent Fuel Transportation Accident Impacts 

The ESP EIS identified one technical area related to transportation of radioactive materials that 

would require further confirmation at the COL stage. The impact of “crud” on spent fuel 

transportation accident risks was not considered in the ESP EIS. Therefore, an analysis was 
Fuel Cycle, Transportation, and Decommissioning 

NUREG-1917, SEIS 6-4 February 2010 

conducted by the NRC staff to determine if including crud could significantly affect the 

conclusion about the magnitude of the spent transportation accident impacts presented in this 

SEIS. 

Fuel assembly crud is radioactive material deposited on the external surfaces of fuel rods. 

At the time the ESP EIS was prepared, the quantities and characteristics of crud deposited 

on advanced LWR spent fuel assemblies was not known. However, since that time, Dominion 

has investigated and provided information in their COL ER (Dominion 2009a) that the estimated 

cobalt-60 inventory in ESBWR crud would be 568 Ci/MTU. The NRC staff also evaluated the 

cobalt-60 activity in crud and estimated 584 Ci/MTU. The NRC staff used a conservative 

estimate of 584 Ci of cobalt-60 per MTU of spent fuel in this SEIS. 

A RADTRAN 5.6 analysis was conducted by the NRC staff to evaluate the effect of the crud 

contribution to spent fuel transportation accident impacts. New RADTRAN 5.6 (Weiner et al. 

2008) calculations were performed by the NRC staff because the computer code that was used 

in the ESP EIS to calculate radiological impacts of transporting fuel and waste to and from the 

ESP site and alternative sites was updated. Two RADTRAN 5.6 runs were made for the COL 

SEIS to determine the contribution of crud to the radiological impacts of accidents during 

transport of spent fuel. One RADTRAN run was performed with no crud in the source term (i.e., 

the source term is the same as that used in the ESP EIS). The second RADTRAN run assumed 

only the crud source term and modeled it as having different release characteristics than 

activation products. Activation products are created by neutron activation of stable elements 

within structural elements of the fuel assembly. Because crud forms on the external surfaces of 

fuel rods, it is more easily released to the spent fuel shipping cask cavity than other radioactive 

materials in spent fuel. Release characteristics were tailored to the specific physical and 

thermal characteristics of fuel assembly crud. Crud release fractions, dispersible fractions, and 

respirable fractions were taken from NUREG/CR-6672 (Sprung et al. 2000) and are presented 

in Table 6-1. 

The results of the staff’s analysis are as follows: 

• spent fuel without crud: 4.6 × 10-7 person-Sv/reference-reactor year (4.6 × 10-5 personrem/reference-reactor year) 

• crud only: 2.5 × 10-6 person-Sv/reference-reactor year (2.5 × 10-4 person-rem/referencereactor year) 

• total (spent fuel plus crud): 2.9 × 10-6 person-Sv/reference-reactor year (2.9 × 10-4 personrem/reference-reactor year). 

Based on the above information, including the crud contribution causes the potential accident 

impacts to increase. Using the same health effects model that was used in the ESP EIS (i.e., 

730 fatal cancers, nonfatal cancers, and severe hereditary effects per 10,000 person-Sv 
Fuel Cycle, Transportation, and Decommissioning 

February 2010 6-5 NUREG-1917, SEIS 

[1,000,000 person-rem]), the total detriment associated with this population dose is about 

2 × 10-7 fatal cancers, nonfatal cancers, and severe hereditary effects per year. The NRC staff 

concludes that these impacts are SMALL compared to the fatal cancers, nonfatal cancers, and 

severe hereditary effects that would be expected to occur annually in the same population from 

natural sources of radiation. The inclusion of fuel assembly crud in the spent fuel transportation 

accident risk analysis did not change this conclusion. 

Table 6-1. Release Characteristic for Spent Fuel Assembly Crud (from NUREG/CR-6672)

Severity Category Severity Fraction(a) Release Fraction(b)

1 1.53 × 10-8 2.0 × 10-3

2 5.88 × 10-5 1.4 × 10-3

3 1.81 × 10-6 1.8 × 10-3

4 7.49 × 10-8 3.2 × 10-3

5 4.65 × 10-7 1.8 × 10-3

6 3.31 × 10-9 2.1 × 10-3

7 0(c) 3.1 × 10-3

8 1.13 × 10-8 2.0 × 10-2

9 8.03 × 10-11 2.2 × 10-3

10 0(c) 2.5 × 10-3

11 1.44 × 10-10 2.0 × 10-3

12 1.02 × 10-12 2.2 × 10-3

13 0(c) 2.5 × 10-3

14 7.49 × 10-11 6.4 × 10-3

15 0(c) 5.9 × 10-3

16 0(c) 3.3 × 10-3

17 0(c) 3.3 × 10-3

18 5.86 × 10-6 2.5 × 10-3

19 0.99993 0 

(a) Severity fractions are the conditional probabilities that, given the occurrence of an 

accident, the mechanical and thermal conditions experienced by a spent fuel shipping 

cask are within the conditions defined by the Severity Category. See NUREG/CR-6672 

(Sprung et al. 2000) for detailed information about the derivation of these data. Generic 

steel-depleted uranium-steel cask designs were assumed for the severity fractions. This 

is the same set of severity fractions that was used in the ESP FEIS. 

(b) RADTRAN 5.6 also models the fraction of the released particulate material that is small 

enough to be dispersible in prevailing wind conditions and the fraction that is respirable. 

For this analysis, these parameters were set to 1.0 (i.e., 100 percent dispersible and 

100 percent respirable), as was done in Sprung et el. (2000). 

(c) The “0” values for certain severity fractions indicate the conditional probability of an 

accident that results in the mechanical and thermal accident conditions defined by the 

severity category is 0.0. The severity categories with “0” values were retained in the 

table for consistency with the source document (Sprung et al. 2000). 
Fuel Cycle, Transportation, and Decommissioning 

NUREG-1917, SEIS 6-6 February 2010 

6.2.2 Nonradiological Impacts 

This section provides an analysis of the nonradiological impacts of transporting fuel and waste 

to and from the proposed reactor site. 

Nonradiological impacts are the human health impacts projected to result from traffic accidents 

involving shipments of fuel and waste to and from the NAPS site; they do not consider 

radiological or hazardous characteristics of the cargo. Nonradiological impacts include the 

projected number of traffic accidents, injuries, and fatalities that could result from shipments of 

unirradiated fuel to the site and return shipments of empty containers from the site, shipments of 

empty spent fuel and radioactive waste shipping containers to the site, and loaded shipping 

containers to offsite disposal facilities. 

Nonradiological impacts are calculated using accident, injury, and fatality rates from published 

sources. The rates (i.e., impacts per vehicle-km traveled) are then multiplied by estimated 

travel distances for workers and materials. The general formula for calculating nonradiological 

impacts is: 

Impacts = (unit rate) × (round-trip shipping distance) × (annual number of shipments) 

In this formula, impacts are presented in units of the number of accidents, number of injuries, 

and number of fatalities per year. Corresponding unit rates (i.e., impacts per vehicle-km 

traveled) are used in the calculations. 

Accident, injury, and fatality rates were taken from Table 4 in ANL/ESD/TM-150, State-Level 

Accident Rates for Surface Freight Transportation: A Reexamination (Saricks and Tompkins 

1999). Nationwide median rates were used for shipments of unirradiated fuel (3200 km oneway shipping distance) and radioactive wastes (800 km one way). State-specific accident, 

injury, and fatality rates were used for shipments of spent fuel. State-by-state shipping 

distances were obtained from TRAGIS outputs (Johnson and Michelhaugh 2003). The data are 

representative of traffic accident, injury, and fatality rates for heavy truck shipments similar to 

those to be used to transport radioactive material to/from the NAPS site. 

The nonradiological accident impacts for transporting fuel and waste to and from the NAPS site 

(and return shipments of empty shipping containers) are shown in Table 6-2. The 

nonradiological impacts associated with the WASH-1238 (USAEC 1972; NRC 1975) reference 

LWR also are shown for comparison purposes. Note that the nonradiological impacts for the 

proposed Unit 3 ESBWR are significantly smaller than for the reference LWR in WASH-1238. 

This difference is due entirely to the smaller number of shipments for the proposed Unit 3 

ESBWR. 
Fuel Cycle, Transportation, and Decommissioning 

February 2010 6-7 NUREG-1917, SEIS 

Table 6-2. Annual Nonradiological Impacts of Transporting Fuel and Waste to and From the 

NAPS Site, Normalized to the Reference LWR 

Reactor, Radioactive 

Material 

Average 

Annual 

Shipments 

One-Way 

Shipping 

Distance, 

km 

Annual Nonradiological Impacts 

(Normalized to reference LWR) 

Accidents 

per Year 

Injuries 

per Year 

Fatalities 

per Year 

Reference LWR (WASH-1238) 

Unirradiated fuel 6.3 3200 1.1 × 10-2 7.7 × 10-3 3.7 × 10-4

Spent fuel 60 4391 1.1 × 10-1

 9.6 × 10-2 5.6 × 10-3

Radioactive waste 46 800 2.1 × 10-2

 1.4 × 10-2 6.8 × 10-4

TOTAL 112.3 1.4 × 10-1

 1.2 × 10-1 6.7 × 10-3

North Anna ESBWR 

Unirradiated fuel 4.1 3200 7.3 × 10-3

 4.9 × 10-3 2.4 × 10-4

Spent fuel 41 4391 7.5 × 10-2

 6.5 × 10-2 3.9 × 10-3

Radioactive waste 26 800 1.2 × 10-2

 7.9 × 10-3 3.8 × 10-4

TOTAL 71.1 9.4 × 10-2

 7.8 × 10-2 4.5 × 10-3

 

6.2.3 Conclusions 

An independent confirmatory analysis was conducted in the ESP EIS (NRC 2006) of the 

impacts under normal operating and accident conditions of transporting fuel and wastes 

to/from an ESBWR proposed for the NAPS site. To make comparisons to Table S–4 of 

10 CFR 51.52, the environmental impacts are normalized to a reference reactor year. The 

reference reactor is an 1100-MW(e) reactor that has an 80-percent capacity factor, for a total 

electrical output of 880 MW(e) per year.(a)

 The environmental impacts can be adjusted to 

calculate impacts per site by multiplying the normalized impacts by the ratio of the total electric 

output for the proposed NAPS ESBWR to the electric output of the reference reactor.

This SEIS reflects information included in the ESP EIS and addresses an unresolved issue 

about fuel and waste transportation that was identified in the ESP EIS. The unresolved issue 

 

(a) The transportation impacts associated with the NAPS site were normalized for a reference 

1100-MW(e) LWR at an 80-percent capacity factor for comparisons to Table S–4. Note that the basis 

for Table S–4 is an 1100 MW(e) LWR at an 80-percent capacity factor (AEC 1972, NRC 1975). The 

basis for Table S–3 in 10 CFR 51.51(b) that was discussed in Section 6.1 of this SEIS is a 

1000-MW(e) LWR with an 80-percent capacity factor (NRC 1976). However, because fuel-cycle and 

transportation impacts are evaluated separately, this difference does not affect the results and 

conclusions in this SEIS. 
Fuel Cycle, Transportation, and Decommissioning 

NUREG-1917, SEIS 6-8 February 2010 

from the ESP EIS involves the effects of spent fuel assembly crud on spent fuel transportation 

accident impacts (NRC 2006). It was determined that including the impacts of potential 

releases of crud in a severe transportation accident would not affect the NRC staff conclusion in 

the ESP EIS that transportation impacts are SMALL and would be consistent with the 

environmental impacts associated with transportation of fuel and radioactive wastes to and from 

current-generation reactors presented in Table S–4 of 10 CFR 51.52. 

6.3 Decommissioning 

At the end of the operating life of a power reactor, NRC regulations require that the facility 

undergo decommissioning. Decommissioning is the safe removal of a facility from service 

and the reduction of residual radioactivity to a level that permits termination of the NRC license. 

The regulations governing decommissioning of power reactors are found in 10 CFR 50.75 and 

50.82. The issue of decommissioning was deferred from the evaluation undertaken for the 

ESP EIS (NRC 2006). 

An applicant for a COL is required to certify that sufficient funds will be available to ensure 

radiological decommissioning at the end of power operations. As part of its COL application for 

the proposed Unit 3 on the NAPS site, Dominion included a Decommissioning Funding 

Assurance Report (Dominion 2008). Dominion will establish an external sinking funds account 

to accumulate funds for decommissioning. The staff reviewed this report and determined that it 

complied with the requirements in 10 CFR 50.33(k) and 50.75(b).

Environmental impacts from the activities associated with the decommissioning of any reactor 

before or at the end of an initial or renewed license are evaluated in the Generic Environmental 

Impact Statement for Decommissioning of Nuclear Facilities: Supplement 1, Regarding the 

Decommissioning of Nuclear Power Reactors (GEIS-DECOM), NUREG-0586, Supplement 1 

(NRC 2002). Environmental impacts of the DECON, SAFSTOR, and ENTOMB 

decommissioning methods are evaluated in the GEIS-DECOM. A COL applicant is not required 

to identify a decommissioning method at the time of the COL application. The NRC staff’s 

evaluation of the environmental impacts of decommissioning presented in the GEIS-DECOM, 

identifies a range of impacts for each environmental issue for a range of different reactor 

designs. The staff has no reason to believe that the impacts discussed in GEIS-DECOM are 

not bounding for reactors deployed after 2002. 

Therefore, the staff relies upon the bases established in GEIS-DECOM and concludes the 

following: 

1. Doses to the public would be well below applicable regulatory standards regardless of 

which decommissioning method considered in GEIS-DECOM is used. 
Fuel Cycle, Transportation, and Decommissioning 

February 2010 6-9 NUREG-1917, SEIS 

2. Occupational doses would be well below applicable regulatory standards during the 

license term. 

3. The quantities of Class C or greater than Class C wastes generated would be comparable 

or less than the amounts of solid waste generated by reactors licensed before 2002. 

4. Air quality impacts of decommissioning are expected to be negligible at the end of the 

operating term. 

5. Measures are readily available to avoid potential significant water quality impacts from 

erosion or spills. The liquid radioactive waste system design includes features to limit 

release of radioactive material to the environment, such as pipe chases and tank collection 

basins. These features will minimize the amount of radioactive material in spills and 

leakage that would have to be addressed at decommissioning. 

6. Ecological impacts of decommissioning are expected to be negligible. 

7. Socioeconomic impacts would be short-term and could be offset by decreases in 

population and economic diversification. 

The staff determined that decommissioning activities would result in a SMALL impact. 

6.4 References 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

72 FR 49352. “Licenses, Certifications, and Approvals for Nuclear Power Plants.” Vol. 72, 

No. 166. August 28, 2007.

Dominion Virginia Power (Dominion). 2008. North Anna 3 Combined License Application. 

Revision 1, December 2008. Accession No. ML090570781.

Dominion Virginia Power (Dominion). 2009a. North Anna 3 Combined License Application, 

Part 3: Applicants’ Environmental Report – Combined License Stage. Revision 2, July 2009. 

Accession No. ML092160490. 

Dominion Virginia Power (Dominion). 2009b. North Anna 3 Combined License Application, 

Part 2: Final Safety Analysis Report. Revision 2, May 2009. Accession No. ML091540602. 
Fuel Cycle, Transportation, and Decommissioning 

NUREG-1917, SEIS 6-10 February 2010 

Johnson P.E. and R.D. Michelhaugh. 2003. Transportation Routing Analysis Geographic 

Information System (TRAGIS) User’s Manual. ORNL/NTRC-006, Rev. 0, Oak Ridge National 

Laboratory, Oak Ridge, Tennessee. 

Saricks C.L. and M.M. Tompkins. 1999. State-Level Accident Rates for Surface Freight 

Transportation: A Reexamination. ANL/ESD/TM-150, Argonne National Laboratory, Argonne, 

Illinois. 

Sprung J.L., D.J. Ammerman, N.L. Breivik, R.J. Dukart, F.L. Kanipe, J.A. Koski, G.S. Mills, 

K.S. Neuhauser, H.D. Radloff, R.F. Weiner, and H.R. Yoshimura. 2000. Reexamination of 

Spent Fuel Shipment Risk Estimates. NUREG/CR-6672, Washington, D.C. 

U.S. Atomic Energy Commission (USAEC). 1972. Environmental Survey of Transportation of 

Radioactive Materials to and from Nuclear Power Plants. WASH-1238, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 1975. Environmental Survey of Transportation of 

Radioactive Materials to and from Nuclear Power Plants, Supplement 1. WASH-1238, 

NUREG-75/038, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 1976. Environmental Survey of the Reprocessing

and Waste Management Portions of the LWR Fuel Cycle. NUREG-0116 (Supplement 1 to 2 

WASH-1248), Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

on Decommissioning of Nuclear Facilities Supplement 1 Regarding the Decommissioning of 

Nuclear Power Reactors. NUREG-0586, Vols. 1 and 2, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2006. Environmental Impact Statement for an 

Early Site Permit (ESP) at the North Anna ESP Site. NUREG-1811, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2008. NRC Regulatory Issue Summary 

2008-12 – Considerations for Extended Interim Storage of Low-Level Radioactive Waste by 

Fuel Cycle and Materials Licensees. May 9, 2008. Accession No. ML073330725. 

Weiner R.F., D.M. Osborn, D. Hinojosa, T.L. Heames, J. Penisten, and D.J. Orcutt. 2008. 

RadCat 2.3 User Guide. SAND2006-6315, Sandia National Laboratories, Albuquerque, 

New Mexico. 
February 2010 7-1 NUREG-1917, SEIS 

7.0 Cumulative Impacts 

Dominion Virginia Power and Old Dominion Electric Power, collectively known as Dominion, 

applied for a combined license (COL) to construct and operate an Economic Simplified BoilingWater Reactor (ESBWR) at the North Anna Power Station (NAPS). In the Environmental 

Report (Dominion 2009a) submitted as part of its COL application, Dominion provided 

information on the impacts of this action to the U.S. Nuclear Regulatory Commission (NRC). 

When evaluating the potential cumulative impacts of constructing and operating the proposed 

ESBWR, which has been designated Unit 3, the NRC staff considers past, present, and 

reasonably-foreseeable future actions. Past actions are those related to the existing NAPS 

operating units (i.e., Units 1 and 2). Present actions are those related to resources at the time 

of the COL application for the proposed Unit 3 until the start of construction. Future actions are 

those that are reasonably foreseeable through construction and operation of the proposed 

Unit 3, including decommissioning. The geographical area over which past, present and future 

actions could contribute to cumulative impacts depends on the type of action considered and is 

described below for each impact area. 

The impacts of the proposed action, as described in Chapters 4 and 5 of this supplemental 

environmental impact statement (SEIS), are combined with other past, present, and reasonably 

foreseeable future actions in the vicinity of NAPS site that would affect the same resources 

impacted by the proposed Unit 3, regardless of what agency (Federal or non-Federal) or person 

undertakes such actions. These combined impacts are defined as “cumulative” in Title 40 of the 

Code of Federal Regulations (CFR) Subpart 1508.7, and include impacts that individually are 

minor but collectively would be significant when considered over a period of time. An action that 

may have a SMALL impact when considered individually could be part of a combination of 

actions that have a MODERATE or LARGE impact when considered collectively. Likewise, for 

a resource that is regionally declining or imperiled, even a SMALL individual impact could be 

important if it contributes to or accelerates the overall resource decline. 

In the course of its evaluation of cumulative impacts, the NRC staff (1) met with Dominion staff, 

its contractors, and State and local officials; (2) conducted an independent evaluation of subject 

areas not covered in the early site permit (ESP) environmental impact statement (EIS), 

unresolved issues, and new and significant information; and (3) reviewed Dominion’s 

implementation of its process for identifying new and significant information, which the staff 

determined was adequate. While developing the SEIS, the staff also reviewed public comments 

it received and contacted Federal, State, Tribal, regional, and local agencies to solicit 

comments. A list of the organizations contacted is provided in Appendix B. Other documents 

related to the NAPS site were reviewed and are listed as references where appropriate. All of 

the types of information collected through these processes was used in developing this SEIS. 
Cumulative Impacts 

NUREG-1917, SEIS 7-2 February 2010 

7.1 Land Use 

Cumulative land-use impacts are discussed in Section 7.1 of the NAPS early site permit (ESP) 

EIS (NRC 2006). The staff did not identify information that was both new and significant 

through its evaluation of information provided by Dominion and its independent review related to 

cumulative land-use impacts. Accordingly, the staff concludes that cumulative land use-impacts 

would remain SMALL, and mitigation is not warranted. 

7.2 Air Quality 

The NAPS site is located in Louisa County, Virginia, which is not included among those counties 

designated by the U.S. Environmental Protection Agency (EPA) as being in Nonattainment for 

the 8-Hour Ozone National Ambient air Quality Standards (VDEQ 2007a). Orange County, 

which also abuts Lake Anna, also is not on the list of areas designated for nonattainment. While 

adjacent Spotsylvania County is designated as being in nonattainment, it currently is under a 

Deferment of Official Nonattainment Designation. In a letter from the Virginia Department of 

Environmental Quality to the U.S. Environmental Protection Agency (EPA) (VDEQ 2009), the 

Commonwealth of Virginia recommended that Spotsylvania County, Stafford County, the City of 

Fredericksburg, and parts of Caroline County be classified as the Fredericksburg Nonattainment 

Area as it relates to the EPA 8-hour ozone standard. Although neighboring Spotsylvania 

County would be a nonattainment area under this recommendation, no change to the existing 

status of “in attainment or unclassified” was proposed for Louisa County. Although the final 

status of all regions in Virginia will not be determined by EPA until 2010, the staff has 

determined that no changes to the description of the NAPS site regional air quality are needed 

at the present time. Cumulative air quality impacts are discussed in Section 7.2 of the ESP EIS 

(NRC 2006). The NRC staff did not identify information that was both new and significant 

through its evaluation of information provided by Dominion and its own independent review 

related to cumulative air quality impacts. Accordingly, the staff concludes that cumulative air 

quality impacts would remain SMALL, and mitigation is not warranted. 

7.3 Water Use and Quality 

Information and associated impacts for water use are provided in Sections 4.3, 5.3, and 7.3 of 

the ESP EIS (NRC 2006). The geographic area in which cumulative impacts on water use were 

evaluated includes Lake Anna, the Waste Heat Treatment Facility (WHTF), and the North Anna 

River downstream of the North Anna Dam. In the ESP EIS, NRC staff concluded that future 

development was unlikely to appreciably alter the hydrology of Lake Anna, and that cumulative 

water-use impacts would be SMALL except during drought periods when the impacts would be 

MODERATE. In its ESP review, the NRC staff conducted an independent water budget 

assessment based on the plant parameter envelope (PPE) values described in the ESP ER 

(Dominion Nuclear North Anna, LLC 2006) and provided in Appendix I of the ESP EIS. This 
Cumulative Impacts 

February 2010 7-3 NUREG-1917, SEIS 

independent water budget assessment considered the combined impacts of the existing Units 1 

and 2 and the proposed Unit 3 on Lake Anna and the North Anna River downstream of the dam. 

Since issuance of the ESP EIS, the NRC staff reviewed the specific Unit 3 plant design and 

operation parameters relating to water use provided by Dominion in the COL ER (Dominion 

2009a) and determined that the parameters for both the Energy Conservation (EC) and 

Maximum Water Conservation (MWC) operating modes are within the PPE range evaluated in 

the ESP application. The NRC staff did not identify information that was both new and 

significant related to the cumulative impacts to water use through either its evaluation of 

information provided by Dominion or the NRC staff’s independent review. The staff conducted a 

literature review, contacted experts in the field as well as State resource agencies, 

independently reviewed the applicant’s water budget model, and reviewed the Instream Flow 

Incremental Methodology (IFIM) study. 

The recent IFIM study evaluated a scenario in which the normal pool level of Lake Anna was 

increased to 76.3 ft (250.25 ft) (Dominion 2009b). This scenario would increase the frequency 

that the proposed Unit 3 would be in EC mode, resulting in a slightly higher water consumption 

rate than that considered in the ESP EIS. Under the existing pool elevation of 76.2 m (250.0 ft) 

MSL, the annual average Unit 3 evaporation rate would be 566.4 L/s (8977 gpm); if the pool 

elevation increases to 76.3 m (250.25 ft) MSL, the annual average Unit 3 evaporation rate 

would be 611.7 L/s (9695 gpm), an approximately 8 percent increase. The exact conditions 

under which the proposed Unit 3 would switch from EC to MWC mode would be established by 

Virginia Department of Environmental Quality at the time of permitting. 

The staff concludes that the cumulative impacts to water use associated with the construction 

and operation of the proposed Unit 3 would remain SMALL except during drought periods, when 

the impacts would be MODERATE. Resolution of any future conflicts over water use during 

drought periods would fall within the regulatory authority of the Commonwealth of Virginia. 

Basic approaches considered by the staff to mitigate water-use conflicts include alternative 

operation of the proposed Unit 3, and alternative operating procedures for the North Anna Dam. 

Another approach considered during the ESP evaluation was alternative cooling system 

designs, which were discussed and resolved in Section 8.2 of the ESP EIS (NRC 2006). 

Information and associated impacts for water quality are provided in Sections 4.3, 5.3, and 7.3 

of the ESP EIS (NRC 2006). In the ESP EIS, NRC staff concluded that cumulative water-quality 

impacts were unresolved but were anticipated to be SMALL (NRC 2006). Water-quality impacts 

were unresolved at the ESP stage, because without a specific design, Dominion could not 

provide specific information on water treatment systems. In the COL ER (Dominion 2009a), 

Dominion provided additional information regarding plant water treatment systems, lake water 

quality, and specific discharge flow rates. The proposed Unit 3 discharge water-quality 

parameters were within (equal to or less than) the range of PPE values evaluated for the ESP. 

The discharge rate from the proposed Unit 3 is small (<2 percent) relative to the existing units’ 
Cumulative Impacts 

NUREG-1917, SEIS 7-4 February 2010 

discharge; therefore, the relative contribution from Unit 3 discharge to thermal impacts on the 

WHTF, Lake Anna, and the North Anna River downstream of the dam also would be 

insignificant. 

Dominion provided data indicating that two priority pollutants, copper and tributyltin, exist in the 

ambient water of Lake Anna at concentrations near or above the State water-quality criteria 

values. These pollutants are not associated with the operation of Units 1 and 2, but would be 

concentrated by operation of the proposed Unit 3 because of evaporation. The proposed Unit 3 

would discharge effluents into the discharge canal that will likely exceed water-quality criteria for 

copper and tributyltin. However, the proposed Unit 3 would contribute a small portion of the 

discharge canal flow relative to the discharges from Units 1 and 2, and therefore, the 

concentration of the proposed Unit 3 effluent will be rapidly diluted. Further dilution would occur 

in the WHTF and Lake Anna. Based on this information, the NRC staff concluded that the 

cumulative water-quality impacts associated with the proposed Unit 3 would remain SMALL. 

Pollutant discharges would be regulated under a Virginia Pollutant Discharge Elimination 

System permit issued by the Commonwealth of Virginia (VDEQ 2007b). 

7.4 Terrestrial Ecosystem 

The information and associated impacts for this section are provided and resolved in 

Section 7.4 of the ESP EIS (NRC 2006). Based on the staff’s analysis, the cumulative impacts 

of the construction and operation of the proposed Unit 3 along with interactions with past, 

present, and reasonably-foreseeable future actions could contribute to adverse cumulative 

impacts to terrestrial resources. For the purposes of this analysis, the geographic area in which 

adverse cumulative effects on terrestrial resources, such as wildlife populations and habitat 

areas, includes the areas around Lake Anna, within the North Anna ESP site, and within the 

existing transmission line rights-of-way, including the proposed NAPS to Ladysmith 

transmission line. The staff concluded in the ESP EIS that construction and operation of the 

proposed Units 3 and 4 would have SMALL cumulative impacts on terrestrial resources (NRC 

2006). Except for the continued development of land in the vicinity of NAPS and Lake Anna that 

results in the loss of wildlife habitat, the staff is not aware of any other significant cumulative 

impacts to terrestrial resources. The forest resources on the adjoining property were harvested 

prior to acquisition by Dominion, but it appears that the harvest would have occurred even 

without the transfer of ownership. The proposed NAPS to Ladysmith transmission line would be 

in an existing right-of-way already subject to the vegetative maintenance program and would not 

result in a significant change to the cumulative impacts of transmission line operations. 

The staff did not identify information that was both new and significant related to the cumulative 

impacts to terrestrial resources through its evaluation of information provided by Dominion and 

the NRC staff’s own independent review. The staff conducted a literature review to update 

information on rare species, contacted State resource agencies, reviewed information about the 
Cumulative Impacts 

February 2010 7-5 NUREG-1917, SEIS 

newly acquired property located southwest of the Unit 3 site, and reviewed portions of the IFIM 

study. The staff concludes that the cumulative impacts associated with the construction and 

operation of the proposed Unit 3 would remain SMALL, and additional mitigation is not 

warranted. 

7.5 Aquatic Ecosystem 

The information and associated impacts for this section are provided and resolved in 

Section 7.5 of the ESP EIS (NRC 2006). Based on the staff’s analysis, the cumulative impacts 

of the construction and operation of the proposed Unit 3 along with interactions with past, 

present, and reasonably-foreseeable future actions could contribute to adverse cumulative 

impacts to aquatic resources. For the purposes of this analysis, the geographic area of interest 

includes Lake Anna, the WHTF and the North Anna River downstream of the North Anna Dam. 

The staff concluded in the ESP EIS that construction and operation of the proposed Units 3 and 

4 would have SMALL cumulative impacts on aquatic resources (NRC 2006). 

Potential cumulative impacts include development that results in habitat loss and nonpoint 

pollution, recreational activity in or near the lake and river, potential alterations to the fish 

communities of Lake Anna resulting from changes in Virginia Department of Game and Inland 

Fisheries management practices, increased fishing pressure, natural environmental stressors, 

and short- or long-term changes in precipitation and temperature. The proposed NAPS to 

Ladysmith transmission line is within an existing right-of-way that already is subject to the 

vegetative maintenance program; therefore, no significant change to the cumulative impacts of 

transmission line operations would occur. 

The staff did not identify information that was both new and significant related to the cumulative 

impacts to aquatic resources through its evaluation of information provided by Dominion and the 

NRC staff’s own independent review. The staff conducted a literature review, contacted experts 

in the field as well as State resource agencies, toured the newly acquired property located 

southwest of the Unit 3 site, and reviewed the IFIM study (Dominion 2009b). The staff 

concludes that the cumulative impacts associated with the construction and operation of the 

proposed Unit 3 would be SMALL, and additional mitigation is not warranted. 

7.6 Socioeconomics, Environmental Justice, Historic and 

Cultural Resources 

The information and associated impacts for this section are provided and resolved in 

Section 7.6 of the ESP EIS (NRC 2006). 

The staff reviewed the information in the ESP EIS (NRC 2006), Dominion’s COL ER (Dominion 

2009a), other information made available since the publication of the ESP EIS, and its 
Cumulative Impacts 

NUREG-1917, SEIS 7-6 February 2010 

conclusion remain the same that under some circumstances, constructions and operation of the 

proposed Unit 3 could make detectable adverse contribution to the cumulative effects 

associated with some socioeconomic issues, including aesthetics and recreation. The individual 

impacts range from MODERATE ADVERSE to LARGE BENEFICIAL as described in the ESP 

EIS. 

The staff did not identify information that was both new and significant related to the cumulative 

impacts to unusual resource dependencies or practices through which minority or low-income 

populations would be disproportionately affected. As a result, there would be no cumulative 

disproportionate and adverse impacts on minority and low-income populations. 

The staff did not identify information that was both new and significant related to the cumulative 

impacts to historic and cultural resources through its evaluation of information provided by 

Dominion and the NRC staff’s own independent review. Dominion has indicated it would 

implement the existing NAPS procedures to ensure that either known or newly discovered 

potential historic and cultural sites would not be inadvertently impacted during onsite activities 

that involve land disturbances (Dominion 2009a). The staff concludes that the cumulative 

historic and cultural resources impacts associated with the construction and operation of the 

proposed Unit 3 would remain SMALL, and mitigation is not warranted. 

7.7 Nonradiological Health 

In Section 5.8.1 of this SEIS, the health impacts of operating the existing Units 1 and 2 and the 

proposed Unit 3 at the NAPS site were evaluated regarding the ambient temperature of Lake 

Anna and the potential formation of thermophilic microorganisms. The evaluation shows that 

the addition of the proposed Unit 3 is not likely to increase populations of thermophilic 

microorganisms beyond the levels normally occurring. 

Health risks to workers can be expected to be dominated by occupational injuries at rates below 

the average U.S. industrial rates. Health impacts to the public and workers from noise, dust 

emissions, acute electromagnetic fields, and transportation also were evaluated and found to be 

SMALL, and mitigation is not warranted. 

The ESP EIS (NRC 2006) considered the health impacts from chronic exposure to electromagnetic fields from transmission lines not resolved because of a lack of conclusive health 

effects information. The NRC staff reviewed the available scientific literature available since the 

ESP EIS was published, and the evidence regarding chronic effects of electro-magnetic fields 

on human health remains inconclusive. 

The staff concludes that the cumulative impacts resulting from construction of the proposed 

Unit 3 and operation of Units 1, 2, and 3 at the NAPS site on nonradiological health would be 

SMALL, and mitigation is not warranted. 
Cumulative Impacts 

February 2010 7-7 NUREG-1917, SEIS 

7.8 Radiological Impacts of Normal Operation 

The information and associated impacts for radiological impacts of normal operation were 

resolved in Section 7.8 of the ESP EIS (NRC 2006). As described in Section 5.9 of this SEIS, 

the public and occupational doses predicted from the operation of the existing Units 1 and 2 and 

proposed Unit 3 on the NAPS site are well below regulatory limits and standards. 

In October 2009, the NRC approved a power uprate request for North Anna Units 1 and 2 from 

2893 megawatts thermal (MW(t)) to 2940 MW(t) (NRC 2009). Dominion plans to install 

ultrasonic flow measurement instrumentation to the main feedwater lines to increase flow and 

temperature measurement accuracy. The NRC found that the power uprate does not result in a 

significant hazard under the standards set forth in 10 CFR 50.92(c), and will not result in a 

significant change in the types or significant increase in the amounts of effluents that may be 

released offsite; in addition, it does not result in a significant increase to the individual or 

cumulative occupational radiation exposure. Based on these conclusions the staff has 

determined that the contribution of the power uprate to environmental impacts would not be 

significant and will not be evaluated further in this SEIS (NRC 2009). The staff did not identify 

information that was both new and significant related to the cumulative impacts to radiological 

impacts of operation of the proposed Unit 3 and existing Units 1 and 2. Therefore, the impact 

would remain SMALL, and mitigation is not warranted. 

7.9 Severe Accidents 

The environmental impacts of potential severe accidents for an ESBWR, the reactor type 

proposed by Dominion for the new Unit 3 at the NAPS site, are discussed in Sections 5.10.2, 

5.10.3, and Appendix M of this SEIS. 

The risk associated with an ESBWR, in addition to the risk associated with the existing Units 1 

and 2, is the sum of the risks for the three individual reactors. The population dose risk for 

Units 1 and 2 is reported to be about 2.5 × 10−1

 person-Sv/Ryr (25 person-rem/Ryr) (NRC 

2006). In Appendix M, the staff estimates the population dose risk for a single ESBWR to be 

about 7.2 × 10−5 person-Sv/Ryr (7.2 × 10−3 person-rem/Ryr) based on the current design 

revision and probabilistic risk assessment. The combined risk for the existing two units plus the 

proposed ESBWR unit remains at about 2.5 × 10−1

 person-Sv/Ryr (25 person-rem/Ryr); 

therefore, the addition of an ESBWR does not significantly increase risk. Similar conclusions 

are obtained when other risks, such as cost risk, early fatalities, and decontamination areas, are 

evaluated. As a result, the staff concludes that the cumulative severe accident impacts 

associated with constructing and operating an ESBWR at the NAPS site would be SMALL, and 

mitigation is not warranted. 
Cumulative Impacts 

NUREG-1917, SEIS 7-8 February 2010 

7.10 Fuel Cycle, Transportation, and Decommissioning 

Cumulative impacts of the uranium fuel cycle and solid waste management are discussed in 

Section 7.9 of the ESP EIS (NRC 2006). The staff did not identify information that was both 

new and significant through its evaluation of information provided by Dominion and its 

independent review; accordingly, the staff concludes that cumulative impacts for the uranium 

fuel cycle and solid waste management would remain SMALL, and mitigation is not warranted. 

Cumulative impacts of transportation of radioactive materials also are discussed in Section 7.9 

of the ESP EIS (NRC 2006). In Section 6.2 of this SEIS, the NRC staff evaluated two new 

issues (i.e., the impact of crud on the surface of spent fuel rods and the nonradiological impacts 

of transporting unirradiated fuel, spent fuel, and radioactive waste) but determined that these 

were not new and significant and would not change the conclusion of the ESP EIS. 

Accordingly, the staff concludes that cumulative transportation impacts would remain SMALL, 

and mitigation is not warranted. 

Cumulative impacts of decommissioning were not resolved in Section 7.9 of the ESP EIS 

because the evaluation of decommissioning was deferred to the COL stage. The environmental 

impacts of decommissioning the proposed Unit 3 are discussed in Section 6.3 of this SEIS. The 

staff reviewed the impacts in the Generic Environmental Impact Statement for Decommissioning 

of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power 

Reactors (GEIS-DECOM), NUREG-0586, Supplement 1 (NRC 2002) and determined they 

would bound the impacts for reactors deployed after 2002. Accordingly, the staff concludes that 

cumulative decommissioning impacts would be SMALL, and mitigation is not warranted. 

7.11 Staff Conclusions and Recommendations 

The NRC staff considered the potential cumulative impacts resulting from construction and 

operation of a single additional nuclear unit together with the past, present, and reasonablyforeseeable future actions in the NAPS site area. For the duration of the proposed action (i.e., 

the construction period plus 40 years of operation), the staff’s evaluation took into account the 

potential impacts from factors known or likely to affect the environment. This included 

considering conditions at the site and surrounding vicinity from past, present, and future human 

activities. 

For each impact area, except socioeconomics, the staff concludes the potential cumulative 

impacts resulting from construction and operation generally would remain SMALL, and 

additional mitigation is not warranted. For socioeconomics, the staff found individual impacts 

would remain in the ranges of MODERATE ADVERSE to LARGE BENEFICIAL. 
Cumulative Impacts 

February 2010 7-9 NUREG-1917, SEIS 

7.12 References 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 

40 CFR Subpart 1508. Code of Federal Regulations, Title 40, Protection of Environment, 

Part 1508, “Terminology and Index.”

Dominion Nuclear North Anna, LLC. 2006. North Anna Early Site Permit Application. 

Revision 9, Glen Ellen, Virginia. Accession No. ML062580096. 

Dominion Virginia Power (Dominion). 2009a. North Anna 3 Combined License Application, 

Part 3: Applicant’s Environmental Report – Combined License Stage. Revision 2, July 2009. 

Accession No. ML092160490. 

Dominion Virginia Power (Dominion). 2009b. Letter from Pamela F. Faggert (Dominion 

Resources Services, Vice President) to Michael P. Murphy, Director, Virginia Department of 

Environmental Quality, Division of Environmental Enhancement, “Final Report: In Stream Flow 

Incremental Methodology (IFIM) study North Anna Power Station – Unit 3.” October 29, 2009. 

Accession No. ML093210500. 

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

Nuclear Power Reactors (GEIS-DECOM). NUREG-0586, Supplement 1, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2006. Environmental Impact Statement for an 

Early Site Permit (ESP) at the North Anna ESP Site. NUREG-1811, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2009. Letter from V. Sreenivas (NRC) to David 

Heacock, Vice President and Chief Nuclear Officer, Virginia Electric and Power Company, 

“North Anna Power Station, Unit Nos. 1 and 2, Issuance of Amendments Regarding 

Measurement Uncertainty Recapture Power Uprate (TAC Nos. ME0965 and ME0966).” 

October 22, 2009. Accession No. ML092250616. 

Virginia Department of Environmental Quality (VDEQ). 2007a. Virginia Ambient Air Monitoring 

2006 Data Report. Accessed June 27, 2008, at 

http://www.deq.virginia.gov/export/sites/default/airmon/documents/AnnualReport06.pdf. 

Accession No. ML083220335. 
Cumulative Impacts 

NUREG-1917, SEIS 7-10 February 2010 

Virginia Department of Environmental Quality (VDEQ). 2007b. Authorization to Discharge 

under the Virginia Pollutant Discharge Elimination System (VPDES) and the Virginia State 

Water Control Act. VPDES Permit No. VA0052451, effective October 25, 2007, Virginia 

Department of Environmental Quality, Richmond, Virginia. 

Virginia Department of Environmental Quality (VDEQ). 2009. Letter from D.K. Paylor, VDEQ, 

to W.T. Wisniewski, EPA Region 3, Identifying Recommendations and Comments on 

Designations of Areas in Virginia under 2008 8-hour Ozone NAAQS, March 11, 2009. 

Accession No. ML093160798. 
February 2010 8-1 NUREG-1917, SEIS 

8.0 Need for Power 

In a combined license (COL) application, an applicant must address the need for power if it was 

not resolved as part of an early site permit (ESP) proceeding. Dominion Virginia Power (DVP) 

and Old Dominion Electric Cooperative (ODEC), collectively known as Dominion, have 

submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for a COL to 

construct and operate a new nuclear power reactor (Unit 3) at the North Anna Power Station 

(NAPS). Dominion elected to defer consideration of the need for power to the COL stage and 

therefore included a discussion of need for power in its COL application (Dominion 2008a). 

Sections 8.0 through 8.4 of NRC’s Standard Review Plans for Environmental Reviews for 

Nuclear Power Plants (NUREG-1555) (NRC 2000) guide the staff’s review of the need for power 

analysis. The guidance in NUREG-1555 is limited because of changes in the regulatory 

structure that were occurring as this guidance was being revised. Deregulation of the electricity 

markets has had a significant impact on the analysis of the need for power. Applicants may be 

power generators rather than traditional utilities; therefore, analysis of the need for power must 

be sufficiently flexible to accommodate various applicant types. Because of deregulation in the 

bulk sales markets for electricity, the advent of independent power producers, and the increased 

use of purchases and exchanges of electricity among utilities to meet demand, the demand for 

electricity by ultimate consumers and customers within a utility’s service area is increasingly not 

being met by the utility’s own generating resources. Trading of electricity is further facilitated by 

the Federal Energy Regulatory Commission’s final rule, promulgated in 61 FR 21540, requiring 

all public utilities that own, control, or operate facilities used for transmitting electricity in 

interstate commerce to file open-access, nondiscriminatory transmission tariffs that contain 

minimum terms and conditions on nondiscriminatory service. 

The term “relevant service area” is used here to indicate any region to be served by the 

proposed facility, whether or not it corresponds to a traditional utility service area. “Relevant 

service area” is a situation-specific concept and must be defined on a case-by-case basis. 

Affected states or regional reliability corporations may prepare a need for power evaluation and 

assessment of the regional power system for planning or regulatory purposes. A need for 

power analysis may also be prepared by a regulated utility and submitted to a regulatory 

authority, such as a state public utility commission. The NRC staff would review the evaluation 

and determine if it is (1) systematic, (2) comprehensive, (3) subject to confirmation, and 

(4) responsive to forecasting uncertainty (NRC 2000). As outlined in NUREG-1555, if the staff 

finds the independently produced need for power evaluation acceptable, no additional 

independent review by the NRC may be needed, and the staff may rely upon that evaluation’s 

findings when assessing the applicant’s need for power analysis. However, the data may be 

supplemented by information from other sources such as the Energy Information Agency, 

Federal Energy Regulatory Commission, and the North American Electric Reliability Council. In 
Need for Power 

NUREG-1917, SEIS 8-2 February 2010 

the case of the proposed Unit 3 at the NAPS site, Dominion has defined a relevant service area 

corresponding to PJM Interconnection LLC’s PJM South Region (also known as the Dominion 

Zone, which is further described in Section 8.1). This area comprises most of the 

Commonwealth of Virginia and the northeastern part of the State of North Carolina (see 

Figure 8.1). 

 

Figure 8-1. Map of PJM South (the Dominion Zone), Showing Major Transmission Lines into 

the Dominion Zone (Dominion 2008a) 

The NRC staff compared representative load projections for the Dominion Zone in the years 

2015, 2016, and 2017 in PJM’s 2009 Load Forecast Report (PJM 2009) against the 

PJM forecast used in Dominion’s need for power assessment. The staff determined that for all 

three years there was about a 2 percent decrease from the Dominion reported estimate to the 

PJM’s 2009 estimate for summer peak load in the Dominion Zone. This difference was 

equivalent to one year’s growth in peak load. Therefore the staff concluded there was no need 

to update the estimates reported to accommodate the impacts of the 2009 recession because 

such changes would have no impact on the conclusions of this analysis. 
Need for Power 

February 2010 8-3 NUREG-1917, SEIS 

8.1 Description of the Power System 

DVP and ODEC, collectively referred to as Dominion, are co-owners of NAPS Units 1 and 2 with 

undivided ownership interests of 88.4 percent and 11.6 percent, respectively. DVP is the 

licensed operator of the existing units and has authority to act as ODEC’s agent. The two 

companies will have the same relationship for Unit 3. 

Dominion is one of about 500 members of PJM Interconnection, LLC. PJM is a regional 

transmission organization (RTO) headquartered in Valley Forge, Pennsylvania, that coordinates 

the movement of wholesale electricity in all or parts of Delaware, Illinois, Indiana, Kentucky, 

Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, 

West Virginia, and the District of Columbia. PJM operates as a federally regulated RTO to 

manage the region’s wholesale electricity market and ensure supply for the regional highvoltage transmission system, in part by telling power producers how much energy should be 

generated and by adjusting import and export transactions (PJM 2008b). 

DVP joined PJM in May 2005 and transferred control (but not ownership or operations) of its 

transmission facilities to the RTO. Also, DVP separated its electric generation and traditional 

customer delivery businesses (referred to now as “load serving entity,” or “LSE”) into two distinct 

operations within PJM’s system. The Dominion Zone currently is co-terminus with the power 

system control area of DVP and includes the electric distribution service territories of DVP, 

ODEC, North Carolina Electric Cooperatives (NCEMCS), and other municipals. DVP operates 

as an LSE in the Dominion Zone (Dominion 2009). DVP serves approximately 90 percent of the 

electric load in the Dominion Zone, including both peak demand and total energy requirements. 

ODEC also serves a small percentage of the Dominion Zone load through its nine members that 

distribute electrical services in the Virginia mainland. ODEC’s service territories either abut or 

overlap Dominion’s territories (Dominion 2009). Dominion is a member of the Southeastern 

Reliability Council (SERC) VACAR sub-region, which has federal responsibility for assuring 

reliability of the electrical grid for the southeastern part of the United States (SERC 2009). 

The DVP service territory in Virginia accounts for over 80 percent of its total load and includes 

many of the fastest-growing counties in the State. DVP also serves the northeastern corner of 

North Carolina, excluding several municipalities, and has native-load obligations throughout its 

service territory in Virginia and North Carolina (Dominion 2009). 

8.2 Power Demand/Integrated Resource Planning 

Need for power is an intricate part of all integrated resource planning, and is a derivative of load 

demand forecasting. Integrated resource planning can be thought of as a process of planning 
Need for Power 

NUREG-1917, SEIS 8-4 February 2010 

to meet users’ needs for electricity services in a way that satisfies multiple objectives with 

limited resources. Broad objectives can include, but are not limited to, the following: 

• conforming to national, regional, State, and local development objectives 

• ensuring that all households and businesses have access to electricity services 

• maintaining reliability of supply 

• minimizing the short-term or long-term economic costs of delivering electricity services 

• minimizing the environmental impacts of electricity supply and use 

• enhancing energy security by minimizing the use of external resources 

• providing economic benefits. 

Integrated resource planning is built on principles of comprehensive analysis. Traditional 

methods of electric resource planning focused on “supply-side” projections only for such things 

as construction of generation, transmission, and distribution facilities. Integrated resource 

planning considers a full range of feasible supply-side and demand-side options, and assesses 

them against a common set of planning objectives. 

Integrated resource planning provides an opportunity for electric planners to address complex 

issues in a structured, inclusive, and transparent manner. At the same time, it provides a 

chance for interested parties both inside and outside the planning region to review, understand, 

and provide additional input. 

The steps in the integrated resource planning process generally are to: 

• establish objectives 

• survey historical energy use patterns and develop load-demand forecasts 

• investigate electricity supply options 

• investigate demand-side management measures 

• prepare and evaluate supply plans 

• prepare and evaluate demand-side management (DSM) plans 

• integrate supply-side and demand-side plans into candidate integrated resource plans 

• select the preferred plan. 
Need for Power 

February 2010 8-5 NUREG-1917, SEIS 

8.3 Power Demand/Integrated Resource Planning in the 

PJM Region 

PJM has primary responsibility for integrated resource planning in the prospective service area 

for the proposed Unit 3 at NAPS. It administers a long-term PJM Regional Transmission 

Expansion Planning Process (RTEPP) and the Reliability Pricing Model (RPM), which provide a 

long-term price signal for existing and new generating capacity resources to ensure reliability for 

the PJM control area (Dominion 2009). 

In determining the need for power, PJM considers the reserve margin needed to ensure reliable 

system operation and supply of power. The reserve margin helps ensure that there will be 

sufficient generating resources available to meet the load, while providing allowance for 

generating facilities that may be unavailable due to planned or forced outages (Dominion 2009). 

PJM’s Reliability Assurance Agreement (RAA) among LSEs in the PJM Region obligates 

Dominion Virginia Power to own or procure an amount of capacity to maintain overall system 

reliability. PJM performs a technical analysis on an annual basis that calculates the appropriate 

generating capacity, including the reserve margin required to meet the RAA-defined reliability 

criteria. This technical analysis is based on a loss-of-load expectation (LOLE) of one day in 

10 years. This standard is also the standard adopted by Dominion’s regional reliability 

organization—SERC—and by the Reliability First Corporation (RFC), which is the regional 

reliability organization that covers much of the PJM market. After review and receipt of 

comments from the Planning Committee, the RAA-Reliability Committee approved a 15-percent 

installed reserve margin (IRM) target for the PJM region. This region-wide IRM target is used 

for RPM and is the basis for allocating a capacity obligation to each LSE within PJM based on 

that LSE’s share of the PJM summer peak load (Dominion 2009). 

Each LSE is responsible for installing or purchasing capacity, on a daily basis, to meet its 

reliability obligation. The rationale for imposing capacity obligations on LSEs is that installation 

of generating capacity requires time, coordination of electric system resources, and financial 

backing and, therefore, must be planned for in advance of need (Dominion 2009). 

To balance the requirements of buyers and loads with offers of suppliers and, by so doing, 

manage the reliability of the system over the long term, PJM administers an RPM annual market 

for capacity. This capacity market is designed to provide a price signal to ensure that the longterm peak requirements of the PJM system can be met by available capacity resources, 

consistent with the RTEPP (Dominion 2009). 

The Dominion Zone is one of the 23 Locational Deliverability Areas (LDA) in PJM. These 

23 LDAs, are identified by PJM as “ ... constrained areas that have a limited ability to import 

capacity due to physical limitations of the transmission system, voltage limitations or stability 
Need for Power 

NUREG-1917, SEIS 8-6 February 2010 

limitations.” Capacity to serve LSEs in constrained areas, such as the Dominion Zone, must be 

located within the constrained area or the LSE must enter into a bilateral transaction for capacity 

into the constrained area with another entity through Capacity Transfer Rights (CTRs) 

(Dominion 2009). 

A defining characteristic of each LDA is its transfer capability with adjacent electric transmission 

networks. Through the RTEPP planning exercise, PJM identifies each LDA’s capacity 

emergency transfer limit (CETL) and capacity emergency transfer objective (CETO), where 

CETL is the actual emergency import capability, expressed in megawatts, of the sub-area, and 

CETO is the import capability required for the sub-area to meet the approved LOLE negligible 

level of one day in 25 years, which is a higher standard than the one-in-10-year requirement for 

generation. PJM specifies the CETL and CETO for the Dominion Zone to be approximately 

3100 MW(e) and 1155 MW(e), respectively. Even with the new Meadow Brook to Loudoun 

500-kV transmission line sponsored by Dominion and other baseline transmission upgrades 

included in the PJM RTEPP, PJM believes that additional transmission system expansion and 

new generating sources will still be required to meet expected peak load supply requirements in 

the Dominion Zone beyond 2012 (PJM 2007b; PJM 2008d). 

8.4 Assessment of Need for Power 

Dominion’s need for power analysis relied on base-load growth projections based on historical 

growth observed by DVP in the Dominion Zone. Demand forecasts specific to ODEC’s service 

territory were not available, but DVP assumed that ODEC has a similar electric demand profile 

to its own, given that DVP and ODEC operate in overlapping and contiguous service territories 

(Dominion 2008a). 

The Dominion Zone is subject to oversight from four separate entities with respect to reserve 

margin standards, system reliability, and planning, as described in this section. These four 

entities are the PJM independent RTO, which operates the regional wholesale electricity 

market; the Virginia State Corporation Commission (Virginia-SCC), which regulates electric 

rates and service within Virginia and issues certificates of public convenience and necessity 

(CPCN) for individual electricity generating facilities that are proposed to serve customers in 

Virginia; the North Carolina Utilities Commission (NCUC), which regulates electricity rates and 

service in North Carolina and issues CPCNs for individual electricity-generating facilities that are 

proposed to serve customers in North Carolina; and the SERC region of the North American 

Electric Reliability Corporation, which promotes, regulates, and enforces and resolves disputes 

concerning reliability and adequacy arrangements among the power-supply systems in its 

region (Dominion 2008a). 

The Virginia-SCC must consider and rule on the application for the CPCN that Dominion must 

file for the proposed Unit 3. Under Virginia Code § 56-580.D, a utility must demonstrate to the 
Need for Power 

February 2010 8-7 NUREG-1917, SEIS 

Virginia-SCC that a proposed facility (1) will have no material adverse effect upon reliability of 

electrical service provided by any regulated public utility, (2) is required by the public 

convenience and necessity, and (3) is not otherwise contrary to the public interest. In 2007, the 

Virginia General Assembly amended the Virginia Utility Electric Regulation Act, Code of Virginia 

(Virginia General Assembly 2007) to accommodate the new legislation designed to ensure 

reliable and adequate supply of electricity. Part of this legislation requires each electric utility, 

such as Dominion, to file periodically with the Virginia-SCC its 10-year plan for its projected 

generation and transmission requirements to serve its native load, including how the utility will 

obtain such resources, their capital requirements, and the anticipated sources of such funding 

(Virginia Code § 56-585.1.A.3). As prescribed by the Virginia General Assembly, the VirginiaSCC also has the responsibility to fix, for each Virginia public utility, just and reasonable rates 

that it may charge for its services to its customers. The Virginia-SCC also has authority over the 

manner in which the utility companies provide service to their customers and requires public 

utilities to provide reasonable and reliable service and to adopt safety rules and regulations for 

the protection of the public. 

The NCUC requires all public utilities to first obtain a certificate of public convenience and 

necessity from the NCUC before beginning the construction or operation of any utility plant or 

system in North Carolina or acquiring ownership or control thereof. In August 2007, the 

Governor of North Carolina signed into law Senate Bill 3 (North Carolina General Assembly 

2007, Session Law 2007-397). Under the law, for generation facilities constructed outside of 

North Carolina, a utility seeking rate recovery must file a petition with the NCUC, and if need is 

shown, the NCUC will approve an estimate of construction costs and construction schedule if 

the plant is intended to serve North Carolina customers. The new law also contains provisions 

regarding review of the development costs for nuclear generation. As a general rule, the NCUC 

has the responsibility under the law to fix, for each North Carolina public utility, the rates that it 

may charge for its services to its customers. These rates are required to be just and reasonable 

and fair both to the public utility and to its customers. In addition, the NCUC has authority over 

the manner in which the utility companies provide service to their customers and requires public 

utilities to provide reasonable and reliable service and to adopt safety rules and regulations for 

the protection of the public. 

Finally, the service territories of DVP and ODEC are located in the VACAR sub-region of the 

SERC region (Eastern Virginia and all of North Carolina). SERC is responsible for proposing 

and enforcing reliability standards within the SERC region based on authority delegated to it 

from the North American Electric Reliability Corporation. SERC also is responsible for 

promoting and improving the reliability, adequacy, and critical infrastructure of the bulk power 

supply systems in the SERC region. SERC promotes the development of reliability and 

adequacy arrangements among the power supply systems; administers a regional compliance 

and enforcement program to achieve the reliability benefits of coordinated planning and 

operations; and provides a mechanism to resolve disputes on reliability issues 

(Dominion 2008a). 
Need for Power 

NUREG-1917, SEIS 8-8 February 2010 

8.4.1 Programs Affecting Demand 

Electricity demand can be influenced by DSM programs that are essentially interventions in the 

market to promote the adoption of more efficient end-uses and to change consumer behavior. 

Because much of the focus of PJM and other planners is on meeting summer peak demand, 

most existing programs in the region target peak demand rather than base-load energy 

consumption. Because this analysis is for the proposed Unit 3 at NAPS, which would provide 

base-load power, the impact of this analysis is on the impact of DSM programs on energy 

requirements, rather than peak demand. Dominion discussed several existing and proposed 

DSM programs in its discussion of the need for power in the Dominion Zone. 

PJM’s Emergency Load Response Program is designed to encourage customers to reduce 

load during an emergency event in exchange for compensation from PJM. However, these 

programs focus on reducing peak demand, and Dominion believes that they will have virtually 

no impact on base-load requirements. Dominion itself offers several tariff-based DSM options 

for both residential and nonresidential customers and DSM education programs, which are 

designed to educate customers and promote energy efficiency and/or conservation. With the 

exception of the education programs, which are focused on capital improvements, the typical 

DSM programs are designed to reduce consumption during times of peak demand and focus on 

reliability (Dominion 2008a). 

In 2007, the Virginia General Assembly passed House Bill 3068 and Senate Bill 1416, which 

were signed into law by Virginia’s Governor. One of the goals for the year 2022 of “ ... reducing 

the consumption of electric energy by retail customers ... ” in Virginia by 10 percent of the 

electric energy consumed by retail customers in 2006. Furthermore, it directs the Virginia-SCC 

to conduct a proceeding to (1) determine whether the 10-percent electric energy consumption 

reduction goal can be achieved cost effectively through the operation of such programs and, if 

not, determine the appropriate goal for the year 2022 relative to base year 2006; (2) identify the 

mix of programs that should be implemented in the Commonwealth to cost-effectively achieve 

the defined electric energy consumption reduction goal by 2022, including but not limited to 

DSM, conservation, energy efficiency, real-time pricing, and consumer education; (3) develop a 

plan for the development and implementation of recommended programs, with incentives and 

alternative means of compliance to achieve such goals; (4) determine the entity or entities that 

could most efficiently deploy and administer various elements of the plan; and (5) estimate the 

cost of attaining the energy consumption reduction goal (Virginia Code Commission 2007). 

The legislation indicates that these programs may include activities by electric utilities, public or 

private organizations, or both electric utilities and public or private organizations. The VirginiaSCC submitted its findings and recommendations to the Governor and General Assembly on 

December 14, 2007. The staff study concluded that 10 percent reduction envisioned in the 

legislation was possible, but that the investments and impacts would likely be substantial 

(Virginia-SCC 2007). In response to this directive by the General Assembly, the Virginia-SCC 
Need for Power 

February 2010 8-9 NUREG-1917, SEIS 

staff and interested parties (including Dominion) are working to develop a long-term energy 

conservation plan for Virginia (which is separate from the Virginia Energy Plan discussed in this 

section). 

In July 2007, Dominion announced that it had formed a conservation group “ ... to encourage a 

renewed customer interest in energy efficiency ... ” (Dominion 2008b). The conservation group 

“ ... will explore new technologies and techniques for residential and business customers to 

reduce their impact on the environment and help them reduce their demand for electricity ... ” 

Dominion also has identified pilot programs, which are described below, to gauge customer 

interest in and response to certain conservation, energy efficiency, education, demand 

response, and load-management initiatives in Virginia (Dominion 2008a). 

Dominion’s current conservation and DSM programs focus on customer education and provide 

rate incentives for load reductions during peak periods, including a number of pilot programs, 

all of which are subject to approval by the Virginia-SCC. If approved and fully implemented, 

Dominion estimates that their distributed generation/load curtailment pilot will run through 

2014. Further, if approved as submitted in the pilot filing and depending on whether it is fully 

implemented and well-received, the program may have up to an estimated 100-MW impact 

on peak load during that time (Dominion 2008a). Dominion also is a partner in the 

U.S. Environmental Protection Agency/U.S. Department of Energy ENERGY STAR program, 

to promote the purchase and use of energy-efficient products and appliances and energyefficient building practices for new homes. 

As previously noted, the Virginia legislature set the goal to reduce electricity use in 2022 by 

10 percent of the 2006 retail consumption through a mix of conservation, energy efficiency, load 

management, and DSM programs. This same goal was considered by the 10-year 

comprehensive Virginia Energy Plan (VDMME 2007), which was issued by the Commonwealth 

of Virginia Department of Mines, Minerals, and Energy on September 12, 2007. The Virginia 

Energy Plan refers to calculations based on studies in other states that show that Virginia, with 

a concerted private, public, and nonprofit investment in energy-efficiency and conservation 

activities, has an achievable cost-effective electric energy reduction potential of 14 percent over 

the next 10 years, scaled back to a 10-percent goal. The Virginia Energy Plan acknowledges 

that Virginia has no established funding source for energy-efficiency and conservation programs 

and that most states with a successful history of efficiency programs provide significant funding 

resources. The plan also acknowledges “ ... that utilities and consumers together would have to 

invest an average of approximately $300 million per year over the 15-year life of the program 

($100 to $120 million by electric utilities, matched by $180 to $200 million by consumers)” 

(VDMME 2007). Although these targets and the means of reaching them are uncertain, 

Dominion believes that, even with complete success in achieving the 10-percent conservation 
Need for Power 

NUREG-1917, SEIS 8-10 February 2010 

goal, Unit 3 is still necessary to meet the growth in base-load demand. Dominion’s need for 

power analysis gives full credit for reduction in load growth embodied in Virginia’s goals and still 

finds that a need for power exists. 

8.4.2 Comparison of PJM/Dominion Studies with NRC Criteria 

According to NUREG-1555, an NRC independent evaluation of the need for power may not 

be needed if the NRC determines that the State/region-prepared evaluation is (1) systematic, 

(2) comprehensive, (3) subject to confirmation, and (4) responsive to forecasting uncertainty. 

Each of the NUREG-1555 criteria is addressed below with respect to the collective PJM reports. 

After evaluating the PJM studies and reports against the four criteria, NRC staff relied on the 

PJM studies and reports to help determine the reasonableness of Dominion’s need for power 

analysis. Dominion also relied on the PJM studies and reports. 

8.4.2.1 Systematic 

PJM has a systematic process for load forecasting. The forecast was developed using 

accepted techniques and employs a range of economic, calendar, weather, and weather 

variables (including solar). The PJM load forecasts are based on a multiple variable ordinary 

least squares regression using economic and calendar variables for each of the 23 LDAs in 

PJM Manual 19 (PJM 2008c). An overview discussion of PJM’s load forecasting process 

follows. The PJM Load Forecast Model (PJM 2007a) produces a 15-year monthly forecast of 

unrestricted peaks assuming “normal” weather (i.e., average weather) for each PJM zone and 

the RTO, as well as unrestricted energy forecasts for the same sub-areas. The models for peak 

demand and energy use the same explanatory variables. Forecasts are developed for each 

zone’s noncoincident peak and the zone’s share of the PJM coincident peak. Econometric 

models are supplemented with a Monte Carlo simulation to derive a distribution of forecasts 

over a wide range of weather conditions. Calendar effects are captured by specifying the days 

of the week, month of the year, holidays, hours of daylight, and Daylight Savings Time. Holiday 

seasonal lighting load is reflected using a trend variable. Weather is reflected in the models as 

temperature-humidity index and heating and cooling degree-days. As a final step in the 

forecasting process, the PJM Load Forecast is reviewed by the Load Analysis Subcommittee, 

and presented to the Planning Committee for endorsement. Final approval is received from the 

PJM Board of Managers. 

Because the PJM model did not provide a forecast of base-load demand, Dominion derived an 

estimate of base-load demand and growth rate that they considered to be fully consistent with 

the peak demand forecasted by PJM for the Dominion Zone. Dominion estimated the 2006 

base-load demand in the Dominion Zone by reviewing historical PJM integrated hourly loads for 

the zone, sorting the 8760 hourly loads (i.e., 24 hours × 365 days) in declining order to create 

the load duration curve and selecting the 65th percentile hour load equal to 9538 MW(e) as the 

proxy for the 2006 base-load demand. Dominion assumed that this base-load demand would 
Need for Power 

February 2010 8-11 NUREG-1917, SEIS 

continue to grow at a compound annual growth rate of 2.4 percent, equal to the compound 

annual growth rate observed in historical Dominion weather-normalized average hourly sales 

over the 5-year period from 2002 to 2006. Dominion’s review of its historical weathernormalized peak load over the same 5-year period from 2002 to 2006 revealed a compound 

annual growth rate of 1.9 percent, which is was the same as PJM’s forecasted peak load 

growth. 

The NRC staff examined the PJM methodology and assumptions and found that they are 

systematic and are well documented. Given the PJM peak load forecast, the NRC staff 

concludes that Dominion’s derivation of the base-load forecast is a reasonable approach and 

also is well documented. 

8.4.2.2 Comprehensive 

PJM evaluated a large set of model parameters and model specifications. Measures of 

macroeconomic and demographic activity are included in the forecast model, representing total 

national, state, or metropolitan areas, depending upon their predictive value. The consumer 

price of power is not currently used as an explanatory variable in the model. The economic 

model specification uses Gross Metropolitan Area Product for Metropolitan Statistical Areas as 

economic drivers for the individual PJM zone (Richmond, Virginia Beach, and Roanoke in the 

Dominion Zone model). 

The PJM noncoincident peak forecasting model specification consists of over 50 independent 

variables. In PJM’s forecasting approach, while the parameter estimates do not vary by month, 

they do vary across the 18 electric distribution company zones. A range of different model 

specifications were evaluated, and the preferred specification was selected based on its 

superior performance according to accepted statistical techniques. Specifically, the preferred 

model specification was chosen based on model back-casting performance after reviewing 

several alternative specifications. The PJM Load/Energy Forecasting Model White Paper 

(PJM 2007a) served as documentation of the implemented peak and energy forecast models 

as well as other methods and specifications that were tested, but not adopted. 

In PJM’s scenarios and assumptions, the NRC staff note that the assessments focus on peak 

capacity because of its importance to the transmission system. However, the purpose and need 

of Unit 3 is predicated on need for base-load power, which is not explicitly discussed in the 

PJM forecasts. As a result, Dominion was forced to make its own derivative assessment of the 

need for base-load power, given the PJM forecasts that the staff evaluated. In addition, it does 

not appear that the PJM assessment takes into account some of the potential factors that may 

affect base-load demand in the future. For example, the assessment does not take into account 

conservation programs that are not contracted DSM programs directed at energy conservation 

(which affects base-load demand) rather than demand response (which affects peak demand). 

The assessment also does not include factors such as long-term fuel availability and price; nor 
Need for Power 

NUREG-1917, SEIS 8-12 February 2010 

does it include global climate change and its probable influence on both electricity demand and 

the cost of generating electricity by various technologies. Finally, the PJM forecasts do not 

include the potential for new sources of demand such as electric vehicles, growing sources of 

demand such as home entertainment systems and standby power loads for a variety of 

residential and commercial equipment, and disruptive technological change. The NRC staff 

believes that most of the omitted factors listed above are likely to add to the demand for power. 

The staff determined that the Dominion estimate of need for base-load power addresses DSM 

and conservation appropriately by giving no credit for DSM in reducing the base-load demand 

but giving 100 percent credit to Virginia’s 10-percent conservation goal. Uncertainties about fuel 

availability and price are likely to take the form of (1) cost increases for natural gas because of 

increasingly limited availability and (2) price increases for coal-fired generation resulting either 

from substitution to coal from natural gas (if there is no national future climate policy) or impacts 

of carbon reductions (if there is a national climate policy). Climate change itself is likely to add 

to the demand for cooling residential and commercial buildings (which would increase the 

demand for electricity), as would electric vehicles and increased standby demands. 

The NRC staff examined the PJM methodology and Dominion’s forecast derived with the 

assistance of the PJM methodology and found that when taken together these forecasts were 

thorough. While the methodology did not include several factors discussed above, these factors 

are likely to increase the need for power. Given the likely affect of the omitted factors, the NRC 

staff concludes that the methodology is sufficiently comprehensive for the staff to rely on it. 

8.4.2.3 Subject to Confirmation 

The PJM load forecast and the forecast results are subject to confirmation by multiple parties. 

The load forecast is a critical element of the process used to establish the capacity obligations 

of each LSE, which represent significant financial obligations. Thus, the load forecast receives 

considerable scrutiny from PJM members to ensure that it represents a reliable estimate of 

future peak loads and bases upon which to evaluate future capacity requirements. The load 

forecast must meet the forecasting standards of the RAA and PJM Manual 19 (PJM 2008c). 

The Load Analysis Subcommittee (LAS) is a member oversight group that monitors each load 

forecast produced by PJM. 

Under PJM Manual 19, the PJM Load Forecast is reviewed by the LAS, and presented to the 

Planning Committee for endorsement. The LAS is composed of representatives from electrical 

distribution companies that are members of PJM. Final approval is given by the PJM Board of 

Managers. A member of the Planning Committee may submit an appeal detailing an issue and 

outlining a solution for a review of part of or the entire forecast, which will be forwarded by the 

Chair of the Planning Committee to PJM, upon a vote of the Committee. Thus, there are at 

least two levels of internal review in the planned process of each PJM forecast, including rights 

of internal appeal. 
Need for Power 

February 2010 8-13 NUREG-1917, SEIS 

The historical PJM load forecast also has been confirmed independently by the Brattle Group, 

which was hired by PJM to provide an independent assessment of the load forecast (The Brattle 

Group 2006). PJM was prompted to conduct this independent evaluation of the model because, 

among other issues, the 2006 peak load forecast understated the actual peak by 9.36 percent. 

Weather conditions for the summer 2006 peak were extreme, and when the PJM load forecast 

was re-simulated using those actual weather and economic conditions, the forecast error was 

only 0.7 percent. The Brattle Group concluded that “ ... the model is doing a good job of 

forecasting peak demand and the main source of error is weather [i.e., the difference between 

long-term average weather and actual weather]” (Dominion 2008a). The NRC staff note that the 

uncertainty of ±0.7 percent, if applied to Dominion’s forecast of base-load demand, is equivalent 

to 70 MW(e), which is far less than the output of Unit 3. 

Looking forward, in its 2008 Annual Energy Outlook, the Energy Information Administration 

(EIA) forecast that electricity consumption for the SERC region will grow at a compounded 

annual rate of 1.2 percent per year, which is significantly less than the 1.9 percent per year 

projected for the Dominion Zone by PJM. However, SERC has come to the following 

conclusions, which are more in line with the PJM forecast (SERC 2007): 

• Projected peak demand will increase at 2.08 percent annually through 2016. 

• Electricity demand will increase 1.7 percent annually through 2016. 

• Firm capacity margins will be 13 to 15 percent through 2016, which is a requirement 

imposed on SERC’s members to maintain system reliability. 

The 2007 Virginia Energy Plan (VDMME 2007) projects that growth rates of peak electricity 

demand in Virginia during the period from 2005 and 2016 to range from about 0.5 percent per 

year (in a scenario with aggressive conservation savings of 14 percent of 2006 consumption) to 

about 1.9 percent per year (in a scenario without conservation programs in place). The latter 

projection is the one most comparable with the PJM forecast and is very similar. Dominion 

accounts for conservation programs in determining the need for Unit 3, working from the 

PJM forecast and then subtracting the impact of the conservation programs. 

The NRC staff finds that the PJM load forecast has been subjected to confirmation and 

confirmed by other regional forecasts. 

8.4.2.4 Responsive to Forecasting Uncertainty 

The historical predictive capability of the PJM load forecast for the Dominion Zone is indicated 

by its adjusted R-Squared of 0.961, indicating that over 96 percent of the dependent variable’s 

(i.e., load) variance from the mean is explained by the regression’s independent variables and 

specified parameter estimates. The Brattle Group review of the peak-demand forecast 

methodology indicates that the primary source of forecast error and uncertainty are the 
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NUREG-1917, SEIS 8-14 February 2010 

differences between projected average weather conditions used in the forecast and actual 

weather conditions. PJM addressed the forecast uncertainty associated with weather through 

the use of a Monte Carlo simulation based on actual weather conditions. As such, the forecast 

methodology and forecast results adequately account for forecast uncertainty concerning 

weather and coincident/noncoincident peaks. The Monte Carlo simulation, however, currently 

does not include other potential sources of uncertainty, such as the rates of increase in 

population and economic activity, in the economic variables. Moreover, while the consumer 

price of electricity has not been included in the PJM models, future increases in the cost of 

generating electricity in the Dominion Zone arising from adding new generating facilities to the 

base rate have an unknown potential for dampening load growth and, therefore, delaying the 

need for base-load capacity. 

The NRC staff concludes that the methodology was not fully responsive to forecast uncertainty. 

Therefore, the staff conducted sensitivity testing of the growth rate in peak demand within the 

Dominion Zone and the impact of increases in the average cost of power (see Section 8.4.3.2). 

Based upon these additional analyses the staff determined the PJM forecasts were not 

adversely impacted by forecasting uncertainty; therefore, the staff chose to rely on the 

PJM forecasts to support the staff’s need for power determination. 

8.4.3 Need for NAPS Unit 3 

8.4.3.1 Need for Base-Load Capacity 

For the purpose of estimating the specific need for base-load capacity that would be provided by 

Unit 3, Dominion defined base-load capacity in its ER to include generating units with a capacity 

factor of 65 percent or greater, which they state is consistent with the base-load definitions assumed 

by the Edison Electric Institute (EEI) and California Senate Bill 1368. The current base-load 

demand in the Dominion Zone was estimated by reviewing 2006 historical PJM integrated hourly 

loads for the Dominion Zone, sorting the year’s 8760 hourly loads in declining order to create the 

load duration curve shown, and then selecting the 65th percentile hour load equal to 9538 MW(e) as 

the proxy for 2006 base-load demand. Over the years from 1997 to 2006, Dominion’s base-load 

requirement grew by over 2000 MW(e), based on analysis of Dominion weather-normalized annual 

energy sales. Over the same period, Dominion reported that there has been virtually no 

development of additional base-load resources in the Dominion Zone, because only combined 

cycles and combustion turbines have been added since 1997 (Dominion 2008a). 

To estimate the unit availability rates shown above for hydroelectric and nuclear sources, 

Dominion reviewed historical state-level generation and capacity data published by the EIA, 

which showed that historically, nuclear units in Virginia operated at a 93 percent average 

capacity factor in 2005, while hydroelectric units operated with a 25 percent average capacity 

factor. Because hydroelectric and nuclear units are typically dispatched before other technology 

types based on lower variable costs, these capacity factors were used as proxy values for 
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February 2010 8-15 NUREG-1917, SEIS 

hydroelectric and nuclear generation availability rates. Coal-fired and biomass units were both 

assumed to have a 90 percent availability rate. Availability rates for the typical intermediate and 

peaking technology types (i.e., gas/oil fired and pumped storage) were assumed to be equal to 

1 minus the 5-year average Equivalent Forced Outage Rate as published by PJM in its 

2001-2005 Generating Unit Statistical Brochure (PJM 2006a). Dominion considered this a 

conservative approach and believed that it likely overstates the amount of intermediate and 

peaking capacity available, as the approach does not account for planned maintenance outages 

for intermediate and peaking capacity (Dominion 2008a). 

Based on EIA data, the Commonwealth of Virginia imported approximately 38 percent of 

Virginia’s total state-wide electric consumption in 2006 (DOE/EIA 2007). The District of 

Columbia, Delaware, Maryland, and New Jersey also rely heavily on imported power and 

compete with Virginia for available power supplies from West Virginia, Pennsylvania, and 

Illinois. North Carolina is less reliant on imports, but does import approximately 12 percent of 

the annual electricity consumed (DOE/EIA 2007). 

8.4.3.2 Other Potential Sources of Capacity 

Dominion currently contracts for 2089 MW(e) of capacity through existing Power Purchase 

Agreements (PPAs). All of this capacity comes from generation located within the Dominion 

Zone: Half of this contracted capacity is from coal-fired, base-load plants, with 809 MW(e) 

scheduled to expire by end of 2015, 379 MW(e) of which is base-load power. Relying on the 

future availability of long-term PPAs from developers of new base-load resources in other 

regions outside Virginia introduces uncertainty as to capacity and energy supply for Dominion. 

Dominion has an obligation to meet the demands of its native-load customers, and the Virginia 

General Assembly has made the policy determination to promote the construction of base-load 

generation for this purpose. Other power project developers may not have energy and capacity 

available to provide to Dominion in the future. There also may be competition for the available 

long-term, base-load PPAs among the other load centers surrounding the Dominion Zone. 

In addition to concerns of long-term supply assurance, reliance on power imported from other 

states increases demand on west-to-east transmission capabilities, resulting in heightened 

vulnerability to transmission-related interruptions. The U.S. Department of Energy has identified 

the Atlantic coastal area from Metropolitan New York southward through northern Virginia as 

one of two Critical Congestion Areas within the United States (DOE 2006). Virginia’s reliance 

on imported power increases its vulnerability to transmission-related interruptions. PJM, in its 

2006 RTEPP, raises concerns over its aging transmission infrastructure; more than 50 percent 

of the 188 500/230-kV transformers in service in the PJM system are 30 years old or older. 

Over the last several years, the PJM system has experienced an increasing number of 

transformer failures and degradation of older transformers (PJM 2006b). 
Need for Power 

NUREG-1917, SEIS 8-16 February 2010 

As of May 23, 2008, there were no announced plans for generator deactivations in the Dominion 

Zone (PJM 2008a). However, there are extensive retirements of older-generation facilities in 

nearby, interconnected regions that call into question the availability of future electricity imports 

as current contracts expire. As of May 23, 2008, deactivations accounting for 1696 MW(e) of 

electric power are planned in PJM for the period 2010 through 2012. The facilities included in 

the deactivation plan are all 35 years or older and are located in Illinois, New Jersey, Delaware, 

and the District of Columbia (PJM 2008a). Approximately 31 percent of the coal-fired 

generating capacity currently installed in PJM is from units that will be 50 years or older in 2015, 

a percentage that is not significantly affected by the later on-line date for Unit 3 of 2017. This is 

equivalent to approximately 20,252 MW(e) of electric power (Dominion 2008a). However, to be 

conservative, Dominion’s estimate of the demand for Unit 3 generation does not count the 

additional power plants that would have to be constructed to replace retiring facilities. The 

impact of any potential base-load capacity retirements both in and out of the Dominion Zone is 

conservatively excluded from the need for base-load capacity analysis. 

As shown in Table 8-1, the results of the need for base-load capacity analysis indicate that there 

is currently a need for additional base-load capacity within the Dominion Zone. Unit 3 is not 

anticipated to be in service until 2017, by which time the base-load capacity deficiency is 

projected to be over 1900 MW(e), even after including capacity supplied by Dominion’s Virginia 

City facility, other planned base-load capacity projects in the Dominion Zone, and conservatively 

assuming that DSM targets established by the Commonwealth of Virginia and existing 

PJM programs will reduce base-load demand. This additional need for base-load capacity is 

greater than the potential capacity that would be available from the proposed Unit 3 and could 

be even greater if DSM savings are less than the above conservative base-load estimates or if 

not all planned base-load projects are built. Thus, even conservatively assuming that DSM 

measures are adopted and that they actually reduce Dominion’s base-load requirements (a 

highly unlikely event given that DSM programs most often reduce peak load), there is still a 

need for nearly 2400 MW(e) of base-load capacity by 2017 for Dominion to meet its service 

obligations to native-load customers. As a result of these projections, Dominion is seeking 

approvals for the Virginia City facility as well as Unit 3 to assure it can meet the reliability 

requirements of the Virginia-SCC and PJM. 

NRC staff has reviewed the PJM 2008 forecast (PJM 2008e) and note that the forecasted 

average rate of peak demand growth in the Dominion Zone has declined from 1.9 percent 

shown in the 2007 forecast to 1.8 percent, a decline of about 5.3 percent in the growth rate. If 

this adjustment also is made to Dominion’s base-load demand forecast, the growth rate in baseload demand would be 2.27 percent per year, and the demand for 1900 MW(e) would occur in 

2016, which is one year later than shown in Table 8-1. 
February 2010 8-17 NUREG-1917, SEIS

Need for Powe

r

Table 8-1. Dominion’s Estimated Need for Base-Load Capacity from NAPS Unit 3 

Values Shown in 

MW(e), Unless 

Otherwise Noted 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2022 

CAGR 

2007– 

2022 

Base-load demand 

Base-load demand – 65% percentile hour (a)

9763 9993 10,229 10,470 10,717 10,970 11,229 11,494 11,765 12,043 12,327 12,618 13,851 2.40% 

DSM% reduction from 2006 consumption(b)

0.00% 0.00% 0.00% 1.00% 1.21% 1.47% 1.78% 2.15% 2.61% 3.16% 3.83% 4.64% 10.00%

DSM base-load MW reduction - - - (95) (116) (140) (170) (205) (249) (302) (365) (443) (954)

Base-load demand – DSM adjusted base-load supply 

9763 9993 10,229 10,375 10,602 10,830 11,059 11,289 11,516 11,741 11,961 12,175 12,897

Base-load supply 

Base-load installed capacity - availability adjusted 

8621 8621 8621 8621 8621 8621 8621 8621 8621 8621 8621 8621 8621

Planned base-load additions - availability adjusted 

Coal 17 17 17 35 74 644 644 644 644 644 644 644 644

Nuclear -- -- -- 195 265 325 325 325 325 325 325 325 325

Subtotal-planned base-load additions 17 17 17 230 338 969 969 969 969 969 969 969 969

Total base-load capacity supply 8638 8638 8638 8851 8960 9590 9590 9590 9590 9590 9590 9590 9590Base-load capacity surplus/(deficiency) (1125) (1355) (1591) (1524) (1642) (1241) (1470) (1699) (1926) (2151) (2372) (2585) (3308)(a) Based on analysis of Dominion Zone 2006 historical actual hourly load data. Assumes base-load demand will increase at same compounded annual 

growth rate observed in Virginia Electric Power Company historical weather-normalized average sales for 2002 through 2006. 

(b) DSM% Savings in Year (T) = 3E-170e^(0.1919*T). Source: Dominion 2008a. 
Need for Power 

NUREG-1917, SEIS 8-18 February 2010 

The NRC staff expects that an increase in the average cost of power (and therefore, the 

consumer price of power) in the Dominion Zone resulting from the addition of NAPS Unit 3 

would be at most approximately 5 percent, given the potential for high overnight capital cost of 

$4000 per installed kW (see Section 10.6.2.1 of this SEIS). Given that the long-term own-price 

elasticity of electricity is likely to be less than 1.0 in absolute value (e.g., the absolute value of 

electricity own-price elasticities in the National Energy Modeling System of the Energy 

Information Administration are considerably below 1.0 [Lady 2007]), a 5 percent increase in the 

cost of electricity would result in much less than a 5 percent decrease in the demand for 

electricity, a value that would delay by less than one year the need for Unit 3 in the Dominion 

Zone base-load generating mix. 

8.4.3.3 Need for Reserve Margin 

Dominion also provided an analysis of installed reserve margins for the Dominion Zone. It 

assumed that all proposed projects in the Dominion Zone included in the PJM Generation 

Interconnection Queue would be built, with the exception of the proposed Unit 3 (for a net 

increase of 4919 MW(e)). This is an upper bound assumption because some units in the queue 

may not be built. Similar to the need for base-load capacity analysis presented above, the 

impact of any potential retirements both in and out of the Dominion Zone is excluded from the 

calculation of installed reserve margins. 

The reserve margin calculation (expressed as percentage) was defined in the Dominion 

analysis as follows: 

Reserve Margin = (Estimated Generated Capability + Import Capability – Estimated 

Peak-Load Responsibility) ÷ Estimated Peak-Load Responsibility 

As shown in Table 8-2, the projected installed reserve margin (IRM), excluding import capacity, 

would fall to 14.3 percent by 2017, which is below the 15 percent IRM planning standard 

currently approved by PJM (PJM 2007a). Thus, without the additional base-load generating 

capacity from Unit 3 in 2017, the Dominion Zone would be relying heavily on imported power for 

reliability. 

There is a current need for base-load capacity in the Dominion Zone, and base-load capacity 

requirements in the Dominion Zone are projected to increase by 2372 MW(e) by 2017 and by 

4000 MW(e) by 2022. To meet its base-load requirements, Dominion has received approval for 

two base-load generating units: (1) NAPS Unit 3 and (2) a 585-MW(e) coal facility known as the 

Virginia City facility because it will be located in Virginia City, Virginia. The Virginia City facility 

will allow the supplemental use of opportunity fuels, such as biomass and waste coal, for up to a 

total of 20 percent of the plant’s output (Dominion 2008a). The Virginia City facility will be 

located in PJM’s American Electric Power Zone, but is included in the need for power analysis 
February 2010 8-19 NUREG-1917, SEIS

Need for Powe

r

Table 8-2. Determination of Installed Reserve Margin 

Values Shown in MW(e), 

Unless Otherwise Noted 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2022 

CAGR 

2007-

2022 

Summer peak demand(a) 19,167 19,583 19,956 20,347 20,746 21,110 21,519 21,923 22,334 22,769 23,222 23,619 25,320 1.9% Installed summer capacity(b) 21,613 21,613 21,613 21,613 21,613 21,613 21,613 21,613 21,613 21,613 21,613 21,613 21,613 

Planned capacity additions(c) 148 738 1873 4023 4141 4839 4899 4919 4919 4919 4919 4919 4919 

Maximum import capability (CETL)(d)

3100 3100 3100 3100 3100 3100 3100 3100 3100 3100 3100 3100 3100 

Total capacity supply 24,861 25,451 26,586 28,736 28,854 29,552 29,612 29,632 29,632 29,632 29,632 29,632 29,632 Calculated % reserve margin (with imports) 

29.7% 30.0% 33.2% 41.2% 39.1% 40.0% 37.6% 35.2% 32.7% 30.1% 27.6% 25.5% 17.0% 

Calculated % reserve margin (without imports) 

13.5% 14.1% 17.7% 26.0% 24.1% 25.3% 23.2% 21.0% 18.8% 16.5% 14.3% 12.3% 4.8% 

(a) PJM Load Forecast 2007. (b) PJM-Dominion Zone Installed Capacity as of 1/1/2007; Source: PJM 2007 EIA-411 Data. (c) PJM Generation Interconnection Queue as of 9/13/2007. (d) Order on Rehearing and Clarification and Accepting Compliance Filing, Federal Energy Regulatory Commission, Docket No ER05-1410-002 June 25, 2007. Source: Dominion 2008a. 
Need for Power 

NUREG-1917, SEIS 8-20 February 2010 

in Section 8.4 for completeness because it is being developed by Dominion to provide baseload power to the Dominion Zone. Within the Dominion Zone itself, the proposed NAPS Unit 3 

is the only major base-load facility with a generating capacity greater than 1000 MW(e) currently 

under study in the PJM Generation Interconnection Queue. 

Dominion’s need for power analysis assumes that Dominion’s Virginia City facility and all 

proposed base-load capacity projects in the Dominion Zone currently included in the PJM 

Generation Interconnection Queue will be built, with the exception of the proposed NAPS Unit 3, 

which they exclude to see if there is need for the generating capacity provided by the proposed 

Unit 3. This is an upper-bound assumption because it assumes all the projects in the queue will 

be built. A developer can withdraw from the interconnection queue process at any time. The 

staff considered this a reasonable assumption and employed it into their analysis. 

The staff’s analysis is based on an assumption that over the 13 consecutive years, from 2010 to 

2022, the usage rate for DSM and EE programs will increase each year until they meet the 

targeted 10-percent reduction in electric energy consumption by 2022. These assumptions are 

made for both Dominion’s Virginia and North Carolina service territories in the Dominion Zone 

(Dominion 2008a). 

As shown in Table 8-1, the results of the need for base-load capacity analysis indicate that even 

without consideration of the reserve margin requirements, there is currently a need for additional 

base-load capacity within the Dominion Zone. Unit 3 is not anticipated to be in-service until 

2017, by which time the base-load capacity deficiency is projected to be over 2372 MW(e), even 

after including generating capacity supplied by Dominion’s Virginia City facility, other planned 

base-load capacity projects in the Dominion Zone, and conservatively assuming that DSM 

targets established by the Commonwealth of Virginia and existing PJM programs will reduce 

base-load demand. This additional need for base-load generating capacity is greater than the 

potential capacity that would be available from the proposed Unit 3 and could be even greater if 

DSM savings are less than the above conservative base-load estimates or if not all planned 

base-load projects are built. Thus, even assuming that DSM measures are adopted and that 

they actually reduce Dominion’s base-load requirements (a highly unlikely event given that DSM 

programs most often reduce peak load) there is still a need for nearly 2400 MW(e) of base-load 

capacity by 2017 for Dominion to meet its service obligations to native-load customers. As a 

result of these projections, Dominion is seeking approvals for the Virginia City facility and Unit 3 

to assure it can meet the reliability requirements of the Virginia-SCC and PJM. 

8.5 NRC Conclusions 

Dominion submitted a forecast and analysis of the need for power in the Dominion Zone of 

PJM Interconnection, LLC, in support of its COL application. Dominion relied on a 2007 

PJM forecast as the basis for its assessment of the need for base-load generating capacity to 
Need for Power 

February 2010 8-21 NUREG-1917, SEIS 

provide electricity in the Dominion Zone and for an assessment of the need for NAPS Unit 3, 

allowing for other potential sources of base-load generation. The NRC staff reviewed the PJM 

need for power analysis and determined it is (1) systematic, (2) comprehensive, and (3) subject 

to confirmation. While the NRC staff did not find that the need for power analysis was fully 

responsive to forecasting uncertainty, the staff conducted additional sensitivity analysis that 

indicated that neither any likely increases in the cost of power nor uncertainties in the base-load 

forecast would significantly change Dominion’s conclusion concerning the need for power. The 

NRC staff therefore accepts the evaluation of the need for power as reasonable. 

The NRC staff has considered the past, present, and planned power-producing capability and 

the predicted load demands from Dominion’s assessment, the Annual Energy Outlook 

(DOE/EIA 2008), and the SERC. The NRC staff has concluded that Dominion’s detailed 

prediction of its future load demand is a reasonable basis for planning for the period from 2007 

to 2022 and that Dominion cannot expect to satisfy a significant portion of that demand load by 

relying on aggressive conservation, deferral of the retirement of existing generating units, 

additional electric purchases from neighboring producers, and the addition of planned nonnuclear units, all of which are already included in Dominion’s forecast. 

Based on this analysis, the staff concludes that there is a justified need for power in the 

Dominion zone of the PJM region. 

8.6 References 

61 FR 21540. “Promoting Wholesale Competition through Open Access Non-Discriminatory 

Transmission Services by Public Utilities; Recovery of Stranded Costs by Public Utilities and 

Transmitting Utilities.” Vol. 61, No. 92. May 10, 1996. 

The Brattle Group. 2006. An Evaluation of PJM’s Peak Demand Forecasting Processes. 

Prepared for PJM Interconnection, LLC by The Brattle Group, San Francisco, California. 

Dominion Virginia Power (Dominion). 2008a. North Anna 3 Combined License Application. 

Revision 1, December 2008. Accession No. ML090570781. 

Dominion Virginia Power (Dominion). 2008b. Dominion Welcomes Virginia State Corporation 

Commission Approval of Virginia City Hybrid Energy Center. Accessed at 

http://www.dom.com/news/elec2008/pr0331.jsp on October 14, 2008. 

Accession No. ML083190858. 

Dominion Virginia Power (Dominion). 2009. North Anna 3 Combined License Application, 

Part 3: Applicant’s Environmental Report – Combined License Stage. Revision 2, July 2009. 

Accession No. ML092160490. 
Need for Power 

NUREG-1917, SEIS 8-22 February 2010 

Lady, G. 2007. “Working Memorandum: NEMS Price Elasticities of Demand for Residential 

and Commercial Energy Use.” Feb 25, 2007. Accessed at http://optimacom.com/NEM_Evaluation/Evaluation_Method.htm on October 20, 2009. 

Accession No. ML093210608. 

North Carolina General Assembly. 2007. “Session Law 2007-397, Senate Bill 3.” Accessed at 

http://www.ncleg.net/sessions/2007/bills/senate/pdf/s3v6.pdf. Accession No. ML083260727. 

PJM Interconnection, LLC (PJM). 2006a. 2001-2005 Generating Unit Statistical Brochure -- 

Units Reporting Events. Accessed at http://www.pjm.com/planning/resadequacy/downloads/2001-2005-brochure.pdf. Accession No. ML083260732. 

PJM Interconnection, LLC (PJM). 2006b. 2006 PJM Regional Transmission Expansion Plan. 

Accessed November 20, 2008 at http://www.pjm.com/planning/2006-reg-trans-exp-plan.html. 

Accession No. ML083260769. 

PJM Interconnection, LLC (PJM). 2007a. PJM Load/Energy Forecasting Model. White Paper. 

Accessed at http://www.pjm.com/planning/resadequacy/downloads/forecast-modelwhitepaper.pdf. Accession No. ML083260800. 

PJM Interconnection, LLC (PJM). 2007b. PJM Load Forecast Report — January 2007. 

Accessed at http://pjm.com/planning/res-adequacy/downloads/2007-load-report.pdf. Accession 

No. ML083260780. 

PJM Interconnection, LLC (PJM). 2008a. Future Deactivations (as of May 23, 2008). 

Accessed at http://www.pjm.com/planning/project-queues/gen-retirements/20080523-

deactivation-requests.xls. Accession No. ML083260787. 

PJM Interconnection, LLC (PJM). 2008b. Overview. Accessed October 14, 2008 at 

http://www.pjm.com/about/overview.html. Accession No. ML083260776. 

PJM Interconnection, LLC (PJM). 2008c. PJM Manual 19: Load Forecasting and Analysis, 

Revision: 13. Accessed at http://www.pjm.com/contributions/pjm-manuals/pdf/m19.pdf. 

Accession No. ML083260825. 

PJM Interconnection, LLC (PJM). 2008d. 2007 PJM Regional Transmission Expansion Plan. 

Accessed November 20, 2008 at http://www.pjm.com/planning/reg-trans-exp-plan.html. 

Accession No. ML083260808. 

PJM Interconnection, LLC (PJM). 2008e. PJM Load Forecast Report— January 2008 (Revised 

May 2008). Accessed at http://www.pjm.com/planning/res-adequacy/downloads/2008-loadreport.pdf. Accession No. ML083260809. 
Need for Power 

February 2010 8-23 NUREG-1917, SEIS 

PJM Interconnection, LCC (PJM). 2009. PJM Load Forecast Report — January 2009, 

prepared by PJM Capacity Adequacy Planning Department, January 22, 2009. Accessed at 

www.pjm.com/documents/reports.aspx on October 20, 2009. Accession No. ML100431129. 

SERC Reliability Corporation (SERC). 2007. Information Summary. SERC Reliability 

Corporation, Charlotte, North Carolina. 

SERC Reliability Corporation (SERC). 2009. “SERC Reliability Corporation Homepage.” 

Accessed at http://www.serc1.org/Application/HomePageView.aspx on October 20, 2009. 

Accession No. ML093280325. 

U.S. Department of Energy (DOE). 2006. National Electric Transmission Congestion Study. 

Accessed November 20, 2008 at http://nietc.anl.gov/documents/docs/Congestion_Study_2006-

9MB.pdf. Accession No. ML083260811. 

U.S. Department of Energy-Energy Information Administration (DOE/EIA). 2007. State 

Electricity Profiles 2006. Access at 

http://www.eia.doe.gov/cneaf/electricity/st_profiles/e_profiles_sum.html 

Accession No. ML083260821. 

U.S. Department of Energy-Energy Information Administration (DOE/EIA). 2008. 2008 Annual 

Energy Outlook. Accessed November 20, 2008 at http://www.eia.doe.gov/oiaf/aeo/index.html. 

Accession No. ML083260812. 

U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental 

Reviews for Nuclear Power Plants. NUREG-1555, Vol. 1, Washington, D.C. Includes 2007 

revisions. 

Virginia Code Commission. 2007. Digest of the Acts of the General Assembly of Virginia at the 

2007 Session. Virginia Code Commission, Richmond, Virginia. 

Virginia Department of Mines, Minerals and Energy (VDMME). 2007. The Virginia Energy Plan. 

Accessed at http://www.dmme.virginia.gov/DE/VAEnergyPlan/2007VEP-Full.pdf. Accession 

No. ML083260698. 

Virginia General Assembly. 2007. “Public Service Companies, Virginia Utility Electric 

Restructuring Act.” Code of Virginia, Title 56, Chapter 23. Accessed October 14, 2008 at 

http://leg1.state.va.us/cgi-bin/legp504.exe?000+cod+TOC56000000023000000000000. 

Accession No. ML083260814. 
Need for Power 

NUREG-1917, SEIS 8-24 February 2010 

Virginia State Corporation Commission (Virginia-SCC). 2007. Letter from Theodore V. 

Morrison, Jr. (Chairman), Mark C. Christie (Commissioner), and Judith Williams Jagdmann 

(Commissioner) of the Virginia State Corporation Commission, to The Honorable Timothy M. 

Kaine (Governor, Commonwealth of Virginia) and Members of the General Assembly of Virginia, 

“The State Corporation Commission’s transmission of the proceedings initiated as required by 

Enactment Clause 3 of Chapters 888 and 933 of the 2007 Acts of the General Assembly 

(Senate Bill 1416 and House Bill 3068) (Third Enactment Clause),” December 14, 2007. 

Accession No. ML083260818. 
February 2010 9-1 NUREG-1917, SEIS 

9.0 Alternatives to the Proposed Action 

The U.S. Nuclear Regulatory Commission (NRC) staff’s review of alternative sites was 

conducted as part of the early site permit application environmental impact statement (ESP EIS) 

for the North Anna Power Station (NAPS) (NRC 2006). That review determined that none of the 

proposed alternative sites were environmentally preferable to the proposed NAPS site. No 

additional discussion of this topic is required in a supplement to an ESP EIS that is prepared for 

a COL application as described in 10 CFR 51.92(e)(3). Therefore, evaluation of alternative sites 

is not required for submittal of a combined license (COL) for the NAPS site that does not exceed 

two additional nuclear units. Discussions of alternatives to the proposed action are provided in 

Chapters 8 and 9 of the ESP EIS. The alternatives discussed are the no-action alternative 

(Section 8.1), system design alternatives (Section 8.3), and alternative sites (Sections 8.3 

through 8.8). 

Because Dominion Virginia Power (DVP) and Old Dominion Electric Cooperative (ODEC), 

collectively known as Dominion, chose to defer providing information regarding energy 

alternatives in the ESP application, energy alternatives are evaluated as part of the COL 

environmental review and are reported in Section 9.2 of this supplemental environmental impact 

statement (SEIS). Section 9.3 provides information regarding alternatives to the system 

designs. 

9.1 No-Action Alternative 

For purposes of a COL application, the no-action alternative refers to a scenario in which the 

NRC would deny Dominion’s application for a COL. Upon such a denial, the construction and 

operation of a new nuclear generating unit at the NAPS ESP site in accordance with Title 10 

of the Code of Federal Regulations (CFR) Part 52 would not occur. There would be no 

environmental impacts at the NAPS site associated with not issuing the COL, except the 

impacts associated with activities not within the definition of construction at 10 CFR 50.10(a) 

and 51.4. At the same time, the benefits associated with the proposed action would not occur. 

If the COL application is denied, the power would still be needed as discussed in Chapter 8 

of this SEIS. Dominion would have a variety of options for meeting power needs including 

constructing a new nuclear power plant at another site, constructing a coal-fired or natural gasfired plant at the NAPS site or at another site, and pursuing one or more of the other energy 

alternatives discussed in Sections 9.2.1 and 9.2.3 of this SEIS. There would be environmental 

impacts associated with each of these options that would occur at the site of implementation. 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-2 February 2010 

9.2 Energy Alternatives 

Energy alternatives were not evaluated in the ESP EIS because Dominion chose to defer the 

analysis of energy alternatives to the COL stage. Therefore, the issue of energy alternatives 

was considered unresolved at the ESP stage, as noted in Appendix J of the ESP EIS 

(NRC 2006). 

The objective of Dominion in seeking a COL for the proposed Unit 3 at the NAPS site is to 

secure a site for new base-load electric power generation. The generated power would be used 

by Dominion to maintain a reliable, stable supply of electricity within its power system control 

area. As discussed in Section 8.1 of the SEIS, the Dominion Zone is currently co-terminus with 

the power system control area of DVP and includes the electric distribution service territories of 

DVP, ODEC, North Carolina Electric Cooperatives, and other municipal entities (Dominion 

2009a). 

This section examines the potential environmental impacts associated with alternatives to 

construction of a new base-load nuclear generating facility. Section 9.2.1 discusses energy 

alternatives not requiring new generating capacity. Section 9.2.2 discusses the alternatives for 

new base-load generation that are technically reasonable and commercially viable. Other 

alternatives are discussed in Section 9.2.3, and a combination of alternatives is discussed in 

Section 9.2.4. Section 9.2.5 compares the environmental impacts from new nuclear, coal-fired, 

and natural gas-fired generating units at the NAPS site and a combination of energy 

alternatives. 

For analysis of energy alternatives, Dominion assumed a target value of 1500 MW(e) electrical 

output (Dominion 2009a). The staff also used this level of output in analyzing energy 

alternatives. 

9.2.1 Alternatives Not Requiring New Generating Capacity 

Four alternatives to the proposed action that would not require Dominion to construct new 

generating capacity are to: 

• Purchase the needed electric power from other suppliers 

• Reactivate retired power plants 

• Extend the operating life of existing power plants 

• Implement conservation or demand-side management (DSM) programs. 

The option of purchasing electricity from neighboring utilities or resources outside of the 

Dominion Zone is limited by both transmission import capability as well as other demand 

centers competing for the same electricity (Dominion 2009a). Virginia currently relies on over 
Alternatives to the Proposed Action 

February 2010 9-3 NUREG-1917, SEIS 

3000 MW(e) of imports from neighboring regions, which is close to the transmission system’s 

3100 MW(e) maximum transfer limit into the Dominion Zone (Dominion 2009a). Significant 

incremental electricity imports on a firm base-load basis would require major transmission 

system upgrades or reliance on an already strained transmission system (Dominion 2009a). 

Even with the new Meadow Brook to Loudoun 500-kV transmission line sponsored by Dominion 

and other base-line transmission upgrades included in the PJM Interconnection regional 

transmission expansion planning process, PJM Interconnection believes that additional 

transmission system expansion and new generating sources will still be required to meet 

expected peak-load supply requirements in the Dominion Zone beyond 2011 (Dominion 2009a). 

In addition, any upgrades to enable a power import comparable to the generation of proposed 

Unit 3 would need to cross multiple utility service territories and may prove to be cost prohibitive 

(Dominion 2009a). 

If power to replace the capacity of Dominion’s proposed Unit 3 were to be purchased from 

sources within the United States or from a foreign country, the generating technology likely 

would be one of those described in NRC’s Generic Environmental Impact Statement for License 

Renewal of Nuclear Plants (GEIS) (NUREG-1437) (e.g., coal, natural gas, or nuclear) (NRC 

1996). The description of the environmental impacts of other electricity-generating technologies 

described in the GEIS is representative of the impacts associated with the construction and 

operation of a new generating unit at the NAPS site. Under the purchased-power alternative, 

the environmental impacts of power production would still occur but would be located elsewhere 

within the region or nation, or in another country. The environmental impacts of coal-fired and 

natural gas-fired generating plants are discussed in Section 9.2.2. 

If the purchased-power alternative were to be implemented, a major environmental unknown 

would be whether new transmission line rights-of-way would be required. The staff concludes 

that the local environmental impacts from purchased power would be SMALL when existing 

transmission line rights-of-way would be used and could range from SMALL to LARGE if new 

rights-of-way are required. The environmental impacts of power generation would depend on 

the generation technology and location of the generation site, and therefore are unknown. 

Based on the issues discussed above, the staff concludes that purchasing 1500 MW(e) of baseload power from other suppliers is not a reasonable alternative to the proposed action. 

Nuclear power facilities are initially licensed by the NRC for a period of 40 years. The operating 

license can be renewed for up to 20 years, and NRC regulations provide for the possibility of 

additional license renewal. Dominion currently operates four nuclear power units in Virginia. 

Two are located at the NAPS site and two are located at the Surry site. NRC has renewed the 

operating licenses for each of the four units for an additional 20 years. The environmental 

impacts of continued operation of a nuclear power plant are significantly less than construction 

of a new plant. However, continued operation of an existing nuclear plant does not provide 

additional generating capacity. 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-4 February 2010 

Dominion currently plans to retire six combustion turbine units during the period from 2012 

through 2017. The units, which burn light fuel oil, have a combined winter generating capacity 

of approximately 447 MW(e) (Dominion 2009b). None of the units are used to generate baseload power. Extending the operating life of these units would not be a substitute for constructing 

a new 1500-MW(e) generating unit. The staff concludes that extending the life of existing 

generating plants would not be a reasonable alternative to the proposed action. 

Retired generating plants, predominately coal-fired and natural gas-fired plants that potentially 

could be reactivated, would ordinarily require extensive refurbishment. Such plants would 

typically be old enough to have economic difficulty meeting current environmental requirements. 

The staff concludes that reactivation of retired power plants would not be a reasonable 

alternative to the proposed action. The environmental impacts of any refurbishment scenario 

are bounded by the impacts associated with coal-fired and natural gas-fired alternatives (see 

Section 9.2.2 of this SEIS). 

Improved energy efficiency can cost less than construction of new generating capacity and 

provide a hedge against market, fuel, and environmental risks. Dominion has a conservation 

group to encourage a renewed customer interest in energy efficiency (Dominion 2009a). 

Dominion offers several DSM options for both residential and commercial customers 

(Dominion 2009a). The programs focus on customer education and also provide rate incentives 

for load reductions during peak demand periods (Dominion 2009a). Dominion is also a partner 

in the U.S. Environmental Protection Agency (EPA)/U.S. Department of Energy (DOE) 

ENERGY STAR program to promote the purchase and use of energy-efficient products and 

appliances and energy-efficient building practices for new homes (Dominion 2009a). 

Dominion’s current and proposed DSM resources are discussed in its 2009 Integrated Resource 

Plan (Dominion 2009b). 

ODEC currently owns approximately 11.6 percent of Units 1 and 2 at NAPS and would also be a 

partial owner of the proposed Unit 3. ODEC is a wholesale power supplier to 12 locally owned 

and controlled electric distribution cooperatives in Virginia, Maryland, and Delaware. It does not 

offer energy-efficiency or DSM programs, but its member cooperatives do offer such programs. 

The following electric cooperatives are members of ODEC: A&N, BARC, Choptank, 

Community, Delaware, Mecklenburg, Northern Neck, Northern Virginia, Prince George, 

Rappahannock, Shenandoah Valley, and Southside (ODEC 2008). 

The need for power discussion in Chapter 8 of this SEIS accounts for conservation and DSM 

programs (see Section 8.4.1). The staff concluded in Section 8.5 that there is a justified need 

for power in Dominion’s region of interest, even with implementation of conservation and DSM 

programs. 

The staff believes it would be unreasonable for an applicant to request a COL if (1) the power 

could be purchased from other electricity suppliers at a reasonable cost, (2) the power could be 
Alternatives to the Proposed Action 

February 2010 9-5 NUREG-1917, SEIS 

obtained by reactivating one or more retired generating plants or by extending the life of one or 

more existing generating plants, or (3) conservation or DSM programs could make the 

additional power from the proposed new nuclear unit unnecessary. 

Based on the preceding discussion, the staff concludes that the options of purchasing electric 

power from other suppliers, reactivating retired power plants, extending the operating life of 

existing power plants, and conservation and DSM programs are not reasonable alternatives to 

the proposed action which would provide new base-load power generation capacity. 

9.2.2 Alternatives Requiring New Generating Capacity 

In keeping with the NRC’s evaluation of alternatives to operating license renewal for nuclear 

power plants, a reasonable set of energy alternatives to the construction and operation of a 

new nuclear generating unit at the NAPS site should be limited to analysis of discrete powergeneration sources, a combination of sources, and those power-generation technologies that 

are technically reasonable and commercially viable (NRC 1996). The current mix of base-load 

power generation options in Virginia is one indicator of the feasible choices for power generation 

technology within the Commonwealth. As of 2009, the generation capacity profile in Virginia 

was approximately as follows: coal (38 percent), nuclear (37 percent), natural gas (17 percent), 

petroleum (3 percent), hydroelectric (2 percent), and other renewables (4 percent) 

(DOE/EIA 2009). 

This section discusses the environmental impacts of energy alternatives to the proposed 

action that would require Dominion to construct new generating capacity. The discussion in 

Section 9.2.2 is limited to the individual alternatives to base-load nuclear power generation that 

appear to the staff to be viable: coal-fired and natural gas-fired generation. The impacts 

discussed in this section are estimates based on present technology. 

The staff assumed that (1) new generation capacity would be located at the NAPS site for the 

coal-fired and natural gas-fired alternatives; (2) the cooling system proposed by Dominion for 

the proposed Unit 3 (closed-cycle with a combination of wet and dry towers) would be used for 

plant cooling; and (3) the existing transmission line rights-of-way serving NAPS would be 

adequate to serve a new coal-fired or natural gas-fired generating plant, but a new transmission 

line within an existing right-of-way would be needed as discussed in Section 2.2.2 of this SEIS. 

Each year, the Energy Information Administration (EIA), a component of DOE, issues an annual 

energy outlook. In its Annual Energy Outlook 2008 (DOE/EIA 2008), the EIA reference case 

projects that coal-fired capacity would account for approximately 40 percent of total electricitygenerating capacity additions between 2007 and 2030. Coal-fired plants generally are used to 

meet base-load requirements. The EIA projects that between 2007 and 2030, natural gas-fired 

plants would account for approximately 36 percent of new capacity additions. It projects that 

renewable energy sources would account for approximately 6 percent of new capacity additions 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-6 February 2010 

during the period and that new nuclear plants would account for approximately 18 percent 

(DOE/EIA 2008). The EIA projections are based on the assumption that providers of new 

generating capacity would seek to minimize cost while meeting applicable environmental 

requirements. 

9.2.2.1 Coal-Fired Generation 

For the coal-fired generation alternative, the staff assumed construction of three supercritical 

pulverized coal-fired units, each with a net capacity of 507 MW(e). These assumptions are 

consistent with Dominion’s COL application. Supercritical pulverized coal-fired plants are 

similar to conventional pulverized coal-fired plants except they operate at slightly higher 

temperatures and higher pressures, which allows for greater thermal efficiency. Supercritical 

coal-fired plants are commercially proven and represent an increasing proportion of new coalfired power plants. The coal-fired plant is assumed to have an operating life of 40 years and a 

capacity factor of 85 percent. 

The staff also considered an integrated gasification combined-cycle (IGCC) coal-fired plant. 

IGCC is an emerging technology for generating electricity with coal that combines modern coal 

gasification technology with both gas turbine and steam turbine power generation. The 

technology is cleaner than conventional pulverized coal plants because major pollutants can be 

removed from the gas stream before combustion. The IGCC alternative also generates less 

solid waste than the pulverized coal-fired alternative. The largest solid waste stream produced 

by IGCC installations is slag, a black, glassy, sand-like material that is potentially a marketable 

byproduct. The other large-volume byproduct produced by IGCC plants is sulfur, which is 

extracted during the gasification process and can be marketed rather than placed in a landfill. 

IGCC units do not produce ash or scrubber wastes. In spite of the these advantages, the staff 

concludes that, at present, a new IGCC plant is not a reasonable alternative to a 1500-MW(e) 

nuclear power-generation facility for the following reasons: (1) IGCC plants are more expensive 

than comparable pulverized coal plants (NETL 2007), (2) existing IGCC plants have 

considerably smaller capacity that the proposed 1500-MW(e) nuclear plant, (3) system reliability 

of existing IGCC plants has been lower than that of pulverized-coal plants, (4) the existing IGCC 

plants have had an extended (though ultimately successful) shakedown period (NPCC 2005), 

and (5) a lack of overall plant performance warranties for IGCC plants has hindered commercial 

financing (NPCC 2005). For these reasons, IGCC plants are not considered further in this 

SEIS. 

It is assumed that eastern bituminous coal and lime (calcium oxide or calcium hydroxide) or 

limestone (calcium carbonate) for a supercritical pulverized coal-fired plant would be delivered 

to the plant by train. Dominion estimates that the plant would consume approximately 3 to 

3.8 million MT (3.3 to 4.2 million tons) per year of pulverized coal (Dominion 2008a). Lime or 

limestone, used in the scrubbing process for control of sulfur dioxide (SO2) emissions, is 

injected as a slurry into the hot effluent combustion gases to remove entrained SO2. The 
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February 2010 9-7 NUREG-1917, SEIS 

lime-based scrubbing solution reacts with SO2 to form calcium sulfite, which precipitates and 

is removed from the process as sludge. Dominion estimates that approximately 71,000 to 

508,000 MT (78,000 to 560,000 tons) per year of limestone would be used for flue gas 

desulfurization (Dominion 2009a). 

Air Quality 

The impacts on air quality from coal-fired generation would vary considerably from those of 

nuclear generation because of emissions of SO2, nitrogen oxides (NOx), carbon monoxide (CO), 

particulate matter (PM), and hazardous air pollutants such as mercury (Hg). In its COL 

application, Dominion assumed a coal-fired plant design that would minimize air emissions 

through a combination of boiler technology and post-combustion pollutant removal. Dominion 

estimates that the coal-fired alternative emissions for SO2, NOx, CO, PM, Hg, and volatile 

organic compounds (VOC) would be approximately as follows (Dominion 2009a): 

 SO2 – 3777 MT (4163 tons)/yr 

 NOx – 1888 MT (2081 tons)/yr 

 CO – 4248 MT (4683 tons)/yr 

 PM10 – 853 to 1932 MT (940 to 2130 tons)/yr 

 PM2.5 – 490 to 1125 MT (540 to 1240 tons)/yr 

 Hg – 0.34 to 0.85 MT (0.37 to 0.94 tons)/yr 

 VOC – 165 MT (182 tons)/yr. 

PM10 is particulate matter with a diameter equal to or less than 10 microns (40 CFR 50.6), and 

PM2.5 is particulate matter with a diameter equal to or less than 2.5 microns (40 CFR 50.7). 

A new coal-fired plant at the NAPS site would also have unregulated carbon dioxide (CO2) 

emissions of approximately 12.2 million MT (13.5 million tons) per year that could contribute to 

global warming (Dominion 2009a). 

The acid rain requirements of the Clean Air Act capped the nation’s SO2 emissions from power 

plants. Dominion would need to obtain sufficient pollution credits either from a set-aside pool or 

purchases on the open market to cover annual emissions from the plant. 

A new coal-fired generation plant at the NAPS site would likely need a prevention of significant 

deterioration permit and an operating permit from the Virginia Department of Environmental 

Quality (VDEQ). The plant would need to comply with the new source performance standards 

(NSPS) for such plants in 40 CFR 60, Subpart Da. The standards establish emission limits for 

PM and opacity (40 CFR 60.42Da), SO2 (40 CFR 60.43Da), NOx (40 CFR 60.44Da), and 

mercury (40 CFR 60.45Da). 
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NUREG-1917, SEIS 9-8 February 2010 

The EPA has various regulatory requirements for visibility protection in 40 CFR 51, Subpart P, 

including a specific requirement for review of any new major stationary source in an area 

designated as in-attainment or unclassified for criteria pollutants under the Clean Air Act 

(40 CFR 51.307(a)). Criteria pollutants under the Clean Air Act are lead, ozone, particulates, 

CO, NO2, and SO2. Ambient air-quality standards for criteria pollutants are in 40 CFR Part 50. 

The NAPS site is in an area designated as in-attainment or unclassified for all criteria pollutants 

(40 CFR 81.347). 

Section 169A of the Clean Air Act (42 USC 7401) establishes a national goal of preventing 

future and remedying existing impairment of visibility in mandatory Class I Federal areas when 

impairment occurs because of air pollution resulting from human activities. In addition, EPA 

regulations provide that for each mandatory Class I Federal area located within a State, the 

State must establish goals that provide for reasonable progress toward achieving natural 

visibility conditions. The reasonable progress goals must provide for an improvement in visibility 

for those days on which visibility is most impaired over the period of the implementation plan 

and ensure no degradation in visibility for the least visibility-impaired days over the same period 

(40 CFR 51.308(d)(1)). If a new coal-fired, power-generation station were located close to a 

mandatory Class I area, additional air-pollution control requirements could be imposed. The 

only mandatory Class I Federal area within 80 km (50 mi) of the NAPS is Shenandoah National 

Park, which is within approximately 68 km (42 mi) of NAPS (NRC 2006). 

The fugitive dust emissions from construction activities would be mitigated using best 

management practices; such emissions would be temporary. 

The GEIS (NRC 1996) did not quantify emissions from coal-fired power plants, but suggested 

that air impacts would be substantial. It also mentioned global warming from unregulated CO2

emissions and acid rain from SO2 and NOX emissions as a potential impact (NRC 1996). 

Adverse human health effects, such as cancer and emphysema, have been associated with the 

byproducts of coal combustion. Overall, the staff concludes that air quality impacts from new 

coal-fired generation at the NAPS would be MODERATE. The impacts would be clearly 

noticeable, but would not destabilize air quality. 

Waste Management 

The GEIS (NRC 1996) and the NRC’s experience from operating license renewal analyses 

indicate that coal combustion generates waste in the form of ash, and equipment for controlling 

air pollution generates additional ash, spent selective catalytic reduction (SCR) catalyst, and 

scrubber sludge. Dominion estimates that a coal-fired plant would generate approximately 

100,000 to 428,000 MT (110,000 to 472,000 tons) per year of ash (Dominion 2009a). Dominion 

would expect to recycle approximately 25 percent of the ash for such uses as construction fill 

material, mine reclamation, and raw material in manufacturing of cement products (Dominion 

2009a). The coal plant would also generate approximately 112,000 to 805,000 MT (123,000 to 
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February 2010 9-9 NUREG-1917, SEIS 

887,000 tons) per year of scrubber sludge with potential uses as synthetic gypsum in wall board 

and cement manufacturing (Dominion 2009a). Dominion estimates that landfill disposal of the 

ash and scrubber sludge over a 60-year plant life would require approximately 36 to 211 ha 

(90 to 521 ac) (Dominion 2009a). 

In May 2000, EPA issued a “Notice of Regulatory Determination on Wastes from the 

Combustion of Fossil Fuels” (65 FR 32214). EPA concluded that some form of national 

regulation was warranted to address coal combustion waste products because of health 

concerns. Accordingly, EPA announced its intention to issue regulations for disposal of coalcombustion waste under Subtitle D of the Resource Conservation and Recovery Act of 1976. 

As of November 2009, EPA is continuing to study the appropriate form of regulation for coal 

combustion waste products. 

Waste impacts on groundwater and surface water could extend beyond the operating life of the 

plant if leachate and runoff from the waste storage area occurs. Disposal of the waste could 

noticeably affect land use and groundwater quality, but with appropriate management and 

monitoring, it would not destabilize any resources. After closure of the waste site and 

re-vegetation, the land could be available for other uses. Construction-related debris would 

be generated during plant construction activities and would be disposed of in approved landfills. 

For the reasons stated above, the staff concludes that the impacts from waste generated at a 

coal-fired plant would be MODERATE. The impacts would be clearly noticeable but would not 

destabilize any important resource. 

Human Health 

Coal-fired power generation introduces worker risks from coal and limestone mining, worker and 

public risk from coal and lime/limestone transportation, worker and public risk from disposal of 

coal-combustion waste, and public risk from inhalation of stack emissions. In addition, the 

discharges of uranium and thorium from coal-fired plants can potentially produce radiological 

doses in excess of those arising from nuclear power plant operations (Gabbard 1993). 

Regulatory agencies, including the EPA and State agencies, base air emission standards and 

requirements on human health impacts. These agencies also impose site-specific emission 

limits as needed to protect human health. Given the regulatory oversight exercised by the EPA 

and State agencies, the staff concludes that the human health impacts from radiological doses 

and inhaled toxins and particulates generated from coal-fired generation would be SMALL. 

Other Impacts 

Approximately 121 ha (300 ac) would need to be converted to industrial use for the plant power 

block, and coal-storage area (Dominion 2009a). Offsite land-use changes also would occur in 

an undetermined coal mining area to supply coal for the plant and for landfill disposal of ash and 
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NUREG-1917, SEIS 9-10 February 2010 

scrubber sludge. In the GEIS, the staff estimated that approximately 8900 ha (22,000 ac) would 

be needed for coal mining and waste disposal to supply a 1000 MW(e) coal-fired power plant 

over its operating life (NRC 1996). Overall, the staff concludes that land-use impacts would be 

MODERATE. The impacts on water use and quality from constructing and operating a coalfired plant at the NAPS would be comparable to the impacts associated with a new nuclear plant 

as discussed in Sections 4.3 and 5.3 of the ESP EIS (NRC 2006). All discharges would be 

regulated by the VDEQ through a Virginia Pollutant Discharge Elimination System permit. 

Indirectly, water quality could be affected by acids and mercury from air emissions. In the GEIS, 

the staff determined that some erosion and sedimentation would likely occur during construction 

of new facilities (NRC 1996). Overall, the staff concludes that the water-use and water-quality 

impacts would be SMALL to MODERATE. 

The coal-fired generation alternative would introduce ecological impacts from construction and 

new incremental impacts from operations. The impacts could include wildlife habitat loss and 

fragmentation, reduced productivity, and a local reduction in biological diversity. The impacts 

could occur at the NAPS site and at the sites used for coal and limestone mining. Disposal of 

waste products could affect water quality and the aquatic environment. The impacts on 

threatened and endangered species would be similar to the impacts from a new nuclear facility 

located at the NAPS site. Overall, the staff concludes that the ecological impacts would be 

MODERATE. 

Socioeconomic impacts would result from the approximately 2000 workers needed to construct 

the plant and 200 workers to operate it, demands on housing and public services during 

construction, and the loss of jobs after construction (Dominion 2009a). Overall, the staff 

concludes that these impacts would be SMALL to MODERATE. Dominion would pay significant 

property taxes for the plant to local taxing districts. The staff concludes that the taxes would 

have a LARGE beneficial impact to the tax recipients. 

The three coal-fired, powerblock units would be as much as 60 m (200 ft) tall and would be 

visible offsite during daylight hours. The three exhaust stacks would be as much as 183 m 

(600 ft) high. The stacks and associated emissions would likely be visible in daylight hours for 

distances greater than 16 km (10 mi). The powerblock units and associated stacks would also 

be visible at night because of outside lighting. The Federal Aviation Administration (FAA) 

generally requires that all structures exceeding an overall height of 60 m (200 ft) above ground 

level have markings and/or lighting so as not to impair aviation safety (FAA 2007). A mitigating 

factor is that the NAPS currently is an industrial site located in a semi-rural area. The visual 

impacts of a new coal-fired plant could be further mitigated by landscaping and color selection 

for buildings that is consistent with the environment. Visual impacts at night could be mitigated 

by reduced use of lighting, provided the lighting meets FAA requirements, and appropriate use 

of shielding. Overall, the staff concludes that the aesthetic impacts associated with new coalfired power generation at the NAPS site would be MODERATE. 
Alternatives to the Proposed Action 

February 2010 9-11 NUREG-1917, SEIS 

Coal-fired power generation would introduce mechanical sources of noise that would likely be 

audible offsite. Sources contributing to the noise produced by plant operation are classified as 

continuous or intermittent. Continuous sources include the mechanical equipment associated 

with normal plant operations. Intermittent sources include the equipment related to coal 

handling, solid-waste disposal, transportation related to coal and limestone delivery, use of 

outside loudspeakers, and the commuting of plant employees. Noise impacts associated with 

rail delivery of coal and lime/limestone would be most significant for residents living in the 

vicinity of the facility and along the rail route. Although noise from passing trains significantly 

increases noise levels near the rail corridor, the short duration of the noise reduces the impacts. 

Nevertheless, given the frequency of train transport and the fact that many people are likely to 

be within hearing distance of the rail line, the staff concludes that the impacts of noise on 

residents in the vicinity of the facility and of the rail line would be MODERATE. Noise and light 

from the plant would be detectable offsite. 

Historic and cultural resource impacts for a new coal-fired plant located at the NAPS would be 

similar to the impacts for a new nuclear plant as discussed in Sections 4.1.3 and 5.1.3 of the 

ESP EIS (NRC 2006). A cultural resources inventory would likely be needed for any onsite 

property that has not been previously surveyed. Other lands, if any, acquired to support the 

plant would also likely need an inventory of field cultural resources, identification and recording 

of existing historic and cultural resources, and possible mitigation of the adverse effect from 

ground-disturbing actions. The studies would likely be needed for all areas of potential 

disturbance at the plant site; any offsite affected areas, such as mining and waste-disposal 

sites; and along associated corridors where new construction would occur, such as roads. 

The staff concludes that the historic and cultural resource impacts would likely be SMALL. 

As discussed in Section 2.10 of the ESP EIS (NRC 2006), there are minority and low-income 

persons in the population near the NAPS site. Environmental impacts on minority and lowincome populations associated with a new coal-fired plant located at the NAPS site and at the 

sites used for coal and limestone mining could be SMALL to MODERATE, depending on the 

distribution and intensity of adverse air quality impacts on the local population. 

Other construction and operation impacts are likely to be SMALL. In most cases, the impacts 

would be detectable, but they would not destabilize any important attribute of the resource 

involved. Because of the minor nature of these impacts, mitigation beyond that discussed 

would not be warranted. 

The construction and operation impacts of coal-fired power generation at the NAPS site are 

summarized in Table 9-1. 

9.2.2.2 Natural Gas-Fired Generation 

For the natural gas-fired alternative, the staff assumed construction and operation of a natural 

gas-fired plant located at the NAPS site. The staff assumed that the plant would use 
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NUREG-1917, SEIS 9-12 February 2010 

combined-cycle combustion turbines, which is consistent with Dominion’s COL ER. The staff 

used the assumption in the COL ER of three units with a net capacity of 500 MW(e) per unit 

(Dominion 2009a). 

Table 9-1. Summary of Environmental Impacts of Coal-Fired Power Generation

Impact Category Impact Comment

Land use MODERATE Uses approximately 121 ha (300 ac) for the powerblock and coal storage 

area. Offsite impacts for coal mining and waste disposal. 

Air quality MODERATE SO2 – 3,777 MT (4163 tons)/yr 

NOx – 1888 MT (2081 tons)/yr 

CO – 4,248 MT (4683 tons)/yr 

PM10 – 853 to 1932 MT (940 to 2130 tons)/yr 

PM2.5 – 490 to 1125 MT (540 to 1240 tons)/yr 

VOC – 165 MT (182 tons)/yr 

Hg – 0.34 to 0.85 MT (0.37 to 0.94 tons)/yr 

Water use and quality SMALL to 

MODERATE 

Impacts would be comparable to the impacts for new nuclear generating units 

located at the NAPS. 

Ecology MODERATE Impacts could include wildlife habitat loss and fragmentation, reduced 

productivity, and a local reduction in biological diversity. Impacts could occur 

at the NAPS site and at the sites used for coal and limestone mining. 

Disposal of fly ash could affect water quality and the aquatic environment. 

The impacts on threatened and endangered species would be similar to the 

impacts from new nuclear generating units at the NAPS site. 

Waste management MODERATE Total waste volume would be approximately 100,000 to 428,000 MT (110,000 

to 472,000 tons) per yr of ash and an additional 112,000 to 805,000 MT 

(123,000 to 887,000 tons) per yr of scrubber sludge. 

Socioeconomics LARGE 

Beneficial to 

MODERATE 

Adverse 

Construction-related impacts would be noticeable. Local property tax base 

would benefit mainly during operations. Depending on where the workforce 

lives, the construction-related impacts would be noticeable or minor. Impacts 

during operation likely would be smaller than during construction. The plant 

would have aesthetic impacts. Some offsite noise impacts would occur. 

Human health SMALL Regulatory controls and oversight are assumed to be protective of human 

health. 

Historic and cultural 

resources 

SMALL Any potential impacts could likely be effectively managed. Most of the facility 

and infrastructure would be built on previously disturbed ground. 

Environmental justice SMALL to 

MODERATE 

There are minority and low-income persons in the local population. Impacts 

to such persons would depend on the distribution and intensity of adverse airquality impacts. 

 

Air Quality 

Natural gas is a relatively clean-burning fuel. When compared with a coal-fired plant, a natural 

gas-fired plant would release similar types of emissions but in lower quantities. 
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February 2010 9-13 NUREG-1917, SEIS 

A new natural gas-fired power generation plant would likely need a prevention of significant 

deterioration permit and an operating permit from VDEQ. A new natural gas-fired combinedcycle plant would also be subject to the new source performance standards in 40 CFR 60, 

Subparts Da and GG. These regulations establish emission limits for particulates, opacity, SO2, 

and NOX. 

The EPA has various regulatory requirements for visibility protection in 40 CFR 51, Subpart P, 

including a specific requirement for review of any new major stationary source in areas 

designated as in-attainment or unclassified under the Clean Air Act. The NAPS site is in an 

area designated as in-attainment or unclassified for criteria pollutants (40 CFR 81.347). 

Section 169A of the Clean Air Act (42 USC 7401) establishes a national goal of preventing 

future impairment of visibility and remedying existing impairment in mandatory Class I Federal 

areas when impairment is from air pollution caused by human activities. In addition, EPA 

regulations provide that for each mandatory Class I Federal area located within a State, the 

State must establish goals that provide for reasonable progress toward achieving natural 

visibility conditions. The reasonable progress goals must provide for an improvement in visibility 

for the most impaired days over the period of the implementation plan and ensure no 

degradation in visibility for the least-impaired days over the same period (40 CFR 51.308(d)(1)). 

If a new natural gas-fired power plant were located close to a mandatory Class I area, additional 

air pollution control requirements could be imposed. The only mandatory Class I Federal area 

within 80 km (50 mi) of the NAPS is Shenandoah National Park which is within approximately 

68 km (42 mi) of NAPS (NRC 2006). 

Dominion estimates that a natural gas-fired plant equipped with pollution control technology to 

meet emission limits would have approximately the following emissions (Dominion 2009a): 

 SOx – 128 MT (141 tons)/yr 

 NOx – 376 MT (414 tons)/yr 

 CO – 225 MT (248 tons)/yr 

 PM10 – 413 MT (455 tons)/yr 

 VOC – 79 MT (87 tons)/yr. 

A natural gas-fired power plant would also have an estimated 6.1 million MT/yr 

(6.7 million tons/yr) of unregulated carbon dioxide emissions that could contribute to global 

warming (Dominion 2009a). 

The combustion turbine portion of the combined-cycle plant would be subject to EPA’s National 

Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines 

(40 CFR 63, Subpart 5100) if the site is a major source of hazardous air pollutants. Major 
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NUREG-1917, SEIS 9-14 February 2010 

sources have the potential to emit 9 MT/yr (10 tons/yr) or more of any single hazardous air 

pollutant or 22.7 MT/yr (25 tons/yr) or more of any combination of hazardous air pollutants 

(40 CFR 63.6085(b)). 

The fugitive dust emissions from construction activities would be mitigated using best 

management practices; such emissions would be temporary. 

The impacts of emissions from a natural gas-fired power generation plant would be clearly 

noticeable, but would not be sufficient to destabilize air resources. Overall, the staff concludes 

that air quality impacts resulting from construction and operation of new natural gas-fired power 

generation at the NAPS site would be SMALL to MODERATE. 

Waste Management 

In the GEIS, the staff concluded that waste generation from natural gas-fired technology would 

be minimal (NRC 1996). The only significant waste generated at a natural gas-fired power plant 

would be spent SCR catalyst, which is used to control NOx emissions. The spent catalyst would 

be regenerated or disposed of offsite. Other than spent SCR catalyst, waste generation at an 

operating natural gas-fired plant would be mostly limited to typical operations and maintenance 

waste. Construction-related debris would be generated during construction activities. Overall, 

the staff concludes that waste impacts from natural gas-fired power generation would be 

SMALL. 

Human Health 

In the GEIS, the staff identified cancer and emphysema as a potential health risk from natural 

gas-fired plants (NRC 1996). The risk may be attributable to NOx emissions that contribute to 

ozone formation, which in turn contribute to health risk. Air emissions from a natural gas-fired 

power generation plant located at the NAPS site would be regulated by the VDEQ. The human 

health effect is expected to be either undetectable or sufficiently minor. Overall, the staff 

concludes that the impacts to human health from natural gas-fired power generation would be 

SMALL. 

Other Impacts 

A natural gas-fired generating plant would require approximately 45 ha (110 ac) for the powerblock and support facilities (Dominion 2009a). Construction of a natural gas pipeline from the 

NAPS to the closest natural gas distribution line would require additional acreage as would land 

required for natural gas wells and collection stations. The nearest natural gas supply line is 

approximately 21 km (13 mi) east of the NAPS site (Dominion 2008a). In the GEIS, the staff 

estimated that approximately 1460 ha (3600 ac) would be needed for wells, collection stations, 
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February 2010 9-15 NUREG-1917, SEIS 

and pipelines to support a 1000-MW(e) plant (NRC 1996). Overall, the staff concludes that the 

land use impacts from new natural gas-fired power generation at the NAPS would be SMALL to 

MODERATE. 

The impacts on water use and quality from constructing and operating a natural gas-fired plant 

at the NAPS site would be comparable to the impacts associated with constructing and 

operating a new nuclear facility. The impacts on water quality from sedimentation during 

construction of a natural gas-fired plant were characterized in the GEIS as SMALL (NRC 1996). 

The NRC also noted in the GEIS that the impacts on water quality from operations would be 

similar to, or less than, the impacts from other generating technologies (NRC 1996). Overall, 

the staff concludes that impacts on water use and quality would be SMALL to MODERATE. 

Siting of the natural gas-fired plant would have ecological impacts that would be comparable to 

a new nuclear facility. Much of the impact would occur in areas that were previously disturbed 

during the construction of NAPS Units 1 and 2. Constructing a new underground gas pipeline to 

the site would cause temporary ecological impacts. Ecological impacts on the plant site and 

utility easements would not affect threatened and endangered species, although some wildlife 

habitat loss and fragmentation, reduced productivity, and a local reduction in biological diversity 

would be likely. Overall, the staff concludes that ecological impacts would be SMALL. 

Socioeconomic impacts would result from the workers needed to construct the plant and the 

approximately 50 workers needed to operate it, demands on housing and public services during 

construction, and the loss of jobs after construction (Dominion 2009a). Overall, the staff 

concludes that these impacts would be SMALL because of the mitigating influence of the site’s 

proximity to the surrounding population area and the relatively small number of workers needed 

to construct and operate the plant in comparison to the nuclear and coal-fired generation 

alternatives. Dominion would pay property taxes for the plant to local taxing districts. 

Considering the population and economic condition of the county, the staff concludes that the 

taxes would have a MODERATE beneficial impact on the county. 

The turbine buildings, three exhaust stacks (approximately 60 m [200 ft] tall) and associated 

emissions, and the gas pipeline compressors would be visible during daylight hours from offsite. 

Noise and light from the plant would be detectable offsite. A mitigating factor is that the NAPS 

site is currently an industrial site located in a rural, forested area. Overall, the staff concludes 

that the aesthetic impacts associated with new natural gas-fired power generation at the NAPS 

site would be SMALL to MODERATE. 

Historic and cultural resource impacts for a new natural gas-fired plant located at the North 

Anna site would be similar to the impacts for a new nuclear plant, as discussed in Sections 4.1.3 

and 5.1.3 of the ESP EIS (NRC 2006). A cultural resources inventory likely would be needed 

for any onsite property that has not been previously surveyed. Other land, if any, that is 

acquired to support the plant would also likely need an inventory of field cultural resources, 
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NUREG-1917, SEIS 9-16 February 2010 

identification, and recording of existing historic and cultural resources, and possible mitigation of 

the adverse effect from ground-disturbing actions. The studies would likely be needed for all 

areas of potential disturbance at the plant site, any offsite affected areas, such as mining and 

waste disposal sites, and along associated corridors where new construction would occur, such 

as roads. The staff concludes that the historic and cultural resource impacts would be SMALL. 

As described in Section 2.10 of the ESP EIS (NRC 2006), there are minority and low-income 

persons in the population around the NAPS. The impacts of a natural gas-fired plant at the 

NAPS site on minority or low-income populations would depend on the distribution and 

magnitude of adverse air quality impacts, but would likely be SMALL. 

Other construction and operation impacts would be SMALL. In most cases, the impacts would 

be detectable, but they would not noticeably alter any important attribute of the resource 

involved. Because of the minor nature of these impacts, mitigation beyond that discussed 

would not be warranted. The construction and operational impacts of natural gas-fired power 

generation at the NAPS site are summarized in Table 9-2. 

9.2.3 Other Alternatives 

This section discusses energy alternatives that Dominion determined are not reasonable, the 

NRC staff’s conclusions about the overall environmental impacts of each alternative, and the 

staff’s basis for the conclusions. A new nuclear unit at the NAPS site would be a base-load 

generation plant, so any feasible alternative to the new unit would need to generate base-load 

power. In performing its initial evaluation in its COL ER, Dominion relied on the GEIS for license 

renewal (NRC 1996; Dominion 2009a). The staff reviewed the information submitted by 

Dominion and also conducted an independent review, and found that Dominion’s conclusion 

that these generation options would not be reasonable alternatives to a new nuclear unit was 

acceptable. 

The staff has not assigned significance levels to the environmental impacts associated with the 

alternatives discussed in this section because, in general, the generation alternatives would 

have to be installed at a location other than the NAPS site. Any attempt to assign significance 

levels would require the staff to speculate about an unknown site. 

9.2.3.1 Oil-Fired Generation 

EIA’s reference case in its Annual Energy Outlook 2008 projects that oil-fired power plants will 

not account for any new electric power generation capacity in the United States through the 

year 2030 (DOE/EIA 2008). Oil-fired generation is more expensive than nuclear, natural gasfired, or coal-fired generation options. In addition, future increases in oil prices are expected to 

make oil-fired generation increasingly more expensive. The high cost of oil has resulted in a 

decline in its use for electricity generation. In Section 8.3.11 of the GEIS, the staff estimated 
Alternatives to the Proposed Action 

February 2010 9-17 NUREG-1917, SEIS 

that construction of a 1000-MW(e) oil-fired plant would require about 49 ha (120 ac) of land 

(NRC 1996). Operation of an oil-fired power plant would have environmental impacts that would 

be similar to those of a comparably sized coal-fired plant (NRC 1996). 

Table 9-2. Summary of Environmental Impacts of Natural Gas-Fired Power Generation 

Impact Category Impact Comment

Land use SMALL to 

MODERATE 

Approximately 1500 ha (3700 ac) would be needed for the powerblock and support systems, connection to a natural gas pipeline, 

natural gas wells, and collection stations. 

Air quality SMALL to 

MODERATE 

SOx – 128 MT (141 tons)/yr 

NOx – 376 MT (414 tons)/yr 

CO – 225 MT (248 tons)/yr 

PM10 – 413 MT (455 tons)/yr 

VOC – 79 MT (87 tons)/yr 

Water use and quality SMALL to 

MODERATE 

Impacts would be comparable to the impacts for new nuclear 

generating units located at the NAPS site. 

Ecology SMALL Many of the impacts would occur in areas that were previously 

disturbed during the construction of NAPS Units 1 and 2. Thus, 

potential habitat loss and fragmentation and reduced productivity 

and biological diversity would be small. 

Waste management SMALL The only significant waste would be from spent SCR catalyst used 

for control of NOx emissions. 

Socioeconomics MODERATE 

Beneficial to 

MODERATE 

Adverse 

Construction and operations workforces would be relatively small. 

Addition to property tax base, while smaller than for a nuclear or 

coal-fired plant, might still be quite noticeable. Construction-related 

impacts would be noticeable. Impacts during operation would be 

minor because of the small workforce involved. The plant would 

have aesthetic impacts. 

Human health SMALL Regulatory controls and oversight are assumed to be protective of 

human health. 

Historic and cultural 

resources 

SMALL Any potential impacts could likely be effectively managed. Most of 

the facility and infrastructure would be built on previously disturbed 

ground. 

Environmental justice SMALL There are minority and low-income persons in the local population. 

Impacts to such persons would depend on the distribution and 

intensity of adverse air-quality impacts. 

 

For the preceding economic reasons, the staff concludes that an oil-fired power plant at or in the 

vicinity of the NAPS site would not be a reasonable alternative to construction of a 1500-MW(e) 

nuclear power facility that would be operated as a base-load plant. 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-18 February 2010 

9.2.3.2 Wind Power 

Virginia has significant land-based and offshore wind energy resources (VDMME 2007). 

Estimates of the wind resource are expressed in wind power classes ranging from Class 1 to 

Class 7, with each class representing a range of mean wind power density or equivalent mean 

speed at specified heights above the ground. Areas designated Class 4 or greater are suitable 

with advanced wind turbine technology under development today (DOE 2005). In Virginia, the 

potential installed capacity of land-based wind power in Class 4 and higher resource areas 

within 32 km (20 mi) of existing transmission lines is approximately 600 MW (VDMME 2007). In 

April 2008, Dominion and BP Alternative Energy North America Inc. announced that they had 

entered into an agreement to jointly develop, own, and operate wind energy projects in Virginia 

(Dominion 2008b). 

Newer wind turbines typically operate at approximately a 36 percent capacity factor 

(DOE 2008a). In comparison, the average capacity factor for a nuclear generation plant in 2006 

in the United States was nearly 90 percent (NEI 2007). Wind turbines generally can serve as an 

intermittent base-load power supply (NPCC 2005). Wind power, in conjunction with energy 

storage mechanisms such as pumped-hydroelectric or compressed-air energy storage (CAES), 

or another readily dispatchable power source like hydropower, might serve as a means of 

providing base-load power. 

The EIA is not projecting any growth in pumped storage capacity (DOE/EIA 2008). In addition, 

the staff concludes in Section 9.2.3.4 that the potential for new hydroelectric development in 

Virginia is limited. 

A CAES plant consists of motor-driven air compressors that use low-cost, off-peak electricity to 

compress air into a storage medium, typically an underground cavern. During high electricity 

demand periods, the stored energy is recovered by releasing the compressed air through a 

combustion turbine to generate electricity (NPCC 2009). Only two CAES plants are currently in 

operation. A 290-MW plant near Bremen, Germany began operating in 1978, and a 110-MW 

facility located in McIntosh, Alabama has been operating since 1991 (Energy Storage and 

Power 2008). Both facilities use salt caverns (Succar and Williams 2008). A CAES plant 

requires suitable geology such as an underground cavern for energy storage. A 268-MW CAES 

plant coupled to a wind farm, the Iowa Stored Energy Park, has been proposed for construction 

near Des Moines, Iowa. The facility would use a porous rock storage reservoir for the 

compressed air (Succar and Williams 2008). However, the staff concludes that there is a limited 

near-term likelihood of siting an energy-storage facility for a 1500-MW(e) intermittent power 

plant in Virginia. 
Alternatives to the Proposed Action 

February 2010 9-19 NUREG-1917, SEIS 

Southern Company and the Georgia Institute of Technology (GIT) studied the viability of 

offshore wind turbines in the southeastern region of the United States (Southern and GIT 2007). 

Among the conclusions of the study authors were the following: 

• The available wind data indicates that a wind farm located offshore of Georgia would likely 

have an adequate wind speed to support a project, although offshore project costs run 

approximately 50 to 100 percent higher than land-based systems. 

• Based on today’s prices for wind turbines, the 20-year levelized cost of electricity produced 

from an offshore wind farm would be above the current production costs from existing power 

generation facilities. 

• The current commercially available offshore wind turbines are not built to withstand major 

hurricanes above a Category 3 or a 1-minute sustained wind speed of 200 km/h (124 mph). 

• The U.S. Department of Interior Minerals Management Service (MMS) has jurisdiction, as 

authorized in the Energy Policy Act of 2005, over alternative energy-related projects on the 

outer continental shelf, including wind power developments. 

MMS has been authorized to complete a rulemaking process outlining the permitting 

requirements for such projects. Until these regulations are finalized, only limited activities 

toward the development of an offshore wind farm in Federal waters can be conducted. The staff 

believes that the preceding conclusions would generally apply to a wind farm located offshore of 

Virginia. 

For the preceding reasons, the NRC staff concludes that a wind energy facility at or in the 

vicinity of the NAPS site would not currently be a reasonable alternative to construction of a 

1500-MW(e) nuclear power generation facility that would be operated as a base-load plant. 

9.2.3.3 Solar Power 

Solar technologies use energy and light from the sun to provide heating and cooling, light, hot 

water, and electricity for consumers. Solar energy can be converted to electricity using solar 

thermal technologies or photovoltaics. Solar thermal technologies employ concentrating 

devices to create temperatures suitable for power production. Concentrating thermal 

technologies are currently less costly than photovoltaics for bulk power production. They also 

can be provided with energy-storage capacity or auxiliary boilers to allow operation during 

periods when the sun is not shining (NPCC 2006). 

The largest operational solar thermal plant is the 64-MW(e) Nevada Solar One plant located 

near Las Vegas, Nevada (DOE/EIA 2007). 

Solar radiation has a low energy density relative to other common energy sources. 

Consequently, a large amount of land area is needed to gather an appreciable amount of 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-20 February 2010 

energy. Typical solar-to-electric power plants require 2 to 4 ha (5 to 10 ac) for every MW of 

generating capacity (TSECO 2008). Thus, approximately 3000 to 6000 ha (7500 to 15,000 ac) 

would be needed for a hypothetical 1500-MW(e) solar power plant. For a large solar plant to be 

practical, a means to store large quantities of energy for distribution when the plant is producing 

less that 1500 MW(e) would be needed. However, the storage possibilities are limited as 

discussed in Section 9.2.3.2. 

Solar energy in Virginia has the potential to support local electrical distribution systems during 

periods of peak demand, especially in summer months (VDMME 2007). 

The staff concludes that solar energy facilities at or in the vicinity of the NAPS site currently 

would not be a reasonable alternative to construction of a 1500-MW(e) nuclear powered 

electricity generating facility that would be operated as a base-load plant. 

9.2.3.4 Hydropower 

A 1997 study prepared for DOE identified approximately 617 MW of undeveloped hydropower 

resource in Virginia (INEEL 1997). Significant legal and regulatory impediments, such as land 

acquisition and environmental protection, would be part of any major hydropower project. 

Additionally, reservoirs are typically built and managed primarily as municipal water supply and 

flood control systems and secondarily for power production. 

EIA’s reference case in its Annual Energy Outlook 2008 projects that U.S. electricity production 

from hydropower plants will remain essentially stable through the year 2030 (DOE/EIA 2008). 

In the GEIS, the staff estimated that land requirements for hydropower are approximately 

0.4 million ha (1 million ac) per 1000 MW(e) (NRC 1996). 

Because of the relatively low amount of undeveloped hydropower resource in Virginia and the 

large land-use and related environmental and ecological resource impacts associated with siting 

hydroelectric facilities large enough to produce 1500 MW(e), the staff concludes that local 

hydropower is not a feasible alternative to construction of a new nuclear power-generation 

facility operated as a base-load plant at the NAPS site. 

9.2.3.5 Geothermal Energy 

Hydrothermal resources, such as reservoirs of steam or hot water, are available primarily in 

the western states, Alaska, and Hawaii. However, geothermal energy can be tapped almost 

anywhere with geothermal heat pumps and direct-use applications. Other geothermal 

resources (e.g., hot dry rock and magma) are awaiting further technology development 

(DOE 2006). 
Alternatives to the Proposed Action 

February 2010 9-21 NUREG-1917, SEIS 

Geothermal energy has an average capacity factor of 90 percent and can be used for base-load 

power where available. However, geothermal technology is not widely used as base-load 

power generation because of the limited geographical availability of the resource and immature 

status of the technology (NRC 1996). Geothermal systems have a relatively small footprint and 

minimal emissions (MIT 2006). A recent study led by the Massachusetts Institute of Technology 

concluded that a $300 to $400 million investment over 15 years would be needed to make earlygeneration enhanced geothermal system power plant installations competitive in the evolving 

U.S. electricity supply markets (MIT 2006). 

Virginia has no high-temperature geothermal reservoirs, but it does have two low-temperature 

reservoirs that can be tapped for direct heat or for geothermal heat pumps (VDMME 2007). 

For the reasons discussed in this section, the NRC staff concludes that a geothermal energy 

facility in Virginia currently would not be a reasonable alternative to construction of a 

1500-MW(e) nuclear power-generation facility operated as a base-load plant at the NAPS site. 

9.2.3.6 Wood Waste 

In the GEIS, the staff determined that a wood-burning facility can provide base-load power and 

operate with an average annual capacity factor of around 70 to 80 percent and with 20 to 

25 percent efficiency (NRC 1996). The fuels required are variable and site-specific. A 

significant impediment to the use of wood waste to generate electricity is the high cost of fuel 

delivery and high construction cost per megawatt of generating capacity. The larger woodwaste power plants only produce 40 to 50 MW(e) of power. Estimates in the GEIS suggest that 

the overall level of construction impacts per megawatt of installed capacity would be 

approximately the same as that for a coal-fired plant, although facilities using wood waste for 

fuel would be built at smaller scales (NRC 1996). Similar to coal-fired plants, wood-waste plants 

require large areas for fuel storage and processing, and involve the same type of combustion 

equipment. 

Because of uncertainties associated with obtaining sufficient wood and wood waste to fuel a 

base-load power plant, the ecological impacts of large-scale timber cutting (e.g., soil erosion 

and loss of wildlife habitat), and high inefficiency, the staff concludes that wood waste would not 

be a reasonable alternative to a 1500-MW(e) nuclear power-generation facility operated as a 

base-load plant at the NAPS site. 

9.2.3.7 Municipal Solid Waste 

Municipal solid-waste combustors incinerate the waste and use the resultant heat to produce 

steam, hot water, or electricity. The combustion process can reduce the volume of waste by 

up to 90 percent and the weight of the waste by up to 75 percent (EPA 2008). Municipal waste 

combustors use three basic types of technologies: (1) mass burn, (2) modular, and 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-22 February 2010 

(3) refuse-derived fuel (DOE/EIA 2001). Mass burning technologies are most commonly used in 

the United States. This group of technologies processes raw municipal solid waste “as is,” with 

little or no sizing, shredding, or separation before combustion. In the GEIS, the staff determined 

that the initial capital cost for municipal solid-waste plants is greater than for comparable steamturbine technology at wood-waste facilities because of the need for specialized wasteseparation and waste-handling equipment for municipal solid waste (NRC 1996). 

Municipal solid-waste combustors generate an ash residue that is buried in landfills. The ash 

residue is composed of bottom ash and fly ash. Bottom ash refers to that portion of the 

unburned waste that falls to the bottom of the grate or furnace. Fly ash represents the small 

particles that rise from the furnace during the combustion process. Fly ash is generally 

removed from flue gases using fabric filters and/or scrubbers (DOE/EIA 2001). 

Currently, approximately 89 waste-to-energy plants are operating in the United States. These 

plants generate approximately 2700 MW(e), or an average of approximately 30 MW(e) per plant 

(IWSA 2008). Given the small size of existing plants, the staff concludes that generating 

electricity from municipal solid waste would not be a reasonable alternative to a 1500-MW(e) 

nuclear power-generation facility operated as a base-load plant at the NAPS site. 

9.2.3.8 Other Biomass-Derived Fuels 

In addition to wood and municipal solid-waste fuel, several other biomass-derived fuels are 

available for fueling electric generators, including crop waste that can be burned, liquid fuels 

(such as ethanol) produced from crops, and gaseous fuels produced from crops or wastes 

(including wood waste). In the GEIS, the staff determined that none of these technologies has 

progressed to the point of being competitive on a large scale or of being reliable enough to 

replace a large base-load generating plant (NRC 1996). 

Co-firing biomass with coal is possible when low-cost biomass resources are available. 

Co-firing is the most economical option for realizing new biomass power generation in the near 

future. These projects require small capital investments per unit of power generation capacity. 

Co-firing systems range in size from 1 MW to 30 MW of biopower capacity (DOE 2008b). 

The staff concludes that biomass-derived fuels do not offer a reasonable alternative to a 

1500-MW(e) nuclear power-generation facility operated as a base-load plant at the NAPS site. 

9.2.3.9 Fuel Cells 

Fuel cells work without combustion and its associated environmental side effects. Power is 

produced electrochemically by passing a hydrogen-rich fuel over an anode, air over a cathode, 

and then separating the two by an electrolyte. The only byproducts are heat, water, and carbon 
Alternatives to the Proposed Action 

February 2010 9-23 NUREG-1917, SEIS 

dioxide. Hydrogen fuel can come from a variety of hydrocarbon resources by subjecting them to 

steam under pressure. Natural gas is typically used as the source of hydrogen. 

Phosphoric acid fuel cells are generally considered first-generation technology. Highertemperature, second-generation fuel cells achieve higher fuel-to-electricity and thermal 

efficiencies. The higher temperatures contribute to improved efficiencies and give the secondgeneration fuel cells the capability to generate steam for cogeneration and combined-cycle 

operations. 

During the past three decades, significant efforts have been made to develop more practical 

and affordable fuel cell designs for stationary power applications, but progress has been slow. 

The cost of fuel cell power systems must be reduced before they can be competitive with 

conventional technologies (DOE 2007). 

The staff concludes that, at the present time, fuel cells are not economically or technologically 

competitive with other alternatives for base-load electricity generation. Future gains in cost 

competitiveness for fuel cells compared to other fuels are speculative. 

For the preceding reasons, the staff concludes that a fuel cell energy facility located at or in the 

vicinity of the North Anna site would not currently be a reasonable alternative to construction of 

a 1500-MW(e) nuclear power-generation facility operated as a base-load plant. 

9.2.4 Combination of Alternatives 

Individual alternatives to the construction of a new nuclear unit at the NAPS site might not be 

sufficient on their own to generate Dominion’s target value of 1500 MW(e) because of the small 

size of the resource or lack of cost-effective opportunities. Nevertheless, it is conceivable that a 

combination of alternatives might be cost effective. There are many possible combinations of 

alternatives. 

Section 9.2.2.2 assumes the construction of three 500-MW(e) natural gas-fired, combined-cycle 

generating units at the NAPS site using the existing main cooling reservoir. For a combined 

alternatives option, the staff assessed the environmental impacts of an assumed combination of 

two 500-MW(e) natural gas-fired, combined-cycle generating units at the NAPS site, 150 MW of 

hydropower, 100 MW from biomass sources including municipal solid waste, 100 MW from 

conservation and DSM programs, and 150 MW from wind power. A summary of the 

environmental impacts associated with the construction and operation of this assumed 

combination of alternatives is shown in Table 9-3. 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-24 February 2010 

Table 9-3. Summary of Environmental Impacts of a Combination of Power Sources 

Impact Category Impact Comment

Land use MODERATE A natural gas-fired plant would have land-use impacts for the 

powerblock and connection to a natural gas pipeline. Wind, 

hydroelectric, and biomass facilities and associated transmission 

lines would have land-use impacts in addition to the land-use 

impact of the natural gas-fired plant. 

Air quality SMALL to 

MODERATE 

Emissions from the natural gas-fired plant would be 

approximately: 

- SOx – 85 MT (94 tons)/yr 

- NOx – 251 MT (277 tons)/yr 

- CO – 151 MT (166 tons)/yr 

- PM10 – 277 MT (305 tons)/yr 

- VOC – 53 MT (58 tons)/yr 

- Municipal solid waste and biomass facilities would also have 

 emissions. 

Water use and 

quality 

SMALL to 

MODERATE 

Impacts would be less than the impacts for new nuclear 

generating units located at the NAPS site. 

Ecology SMALL to 

MODERATE 

Many of the impacts for the natural gas-fired plant would occur in 

areas that were previously disturbed during the construction of 

NAPS Units 1 and 2. Thus, potential habitat loss and 

fragmentation and reduced productivity and biological diversity 

would likely be minimal. Wind energy facilities could result in 

some avian mortality. Hydropower facilities would impact 

terrestrial and aquatic habitat. 

Waste management SMALL to 

MODERATE 

The only significant waste would be from spent SCR catalyst used 

for control of NOx emissions and ash from biomass and municipal 

solid-waste sources. 

Socioeconomics MODERATE 

Beneficial to 

MODERATE 

Adverse 

Construction and operations workforces would be relatively small. 

Addition to property tax base, while smaller than for a nuclear or 

coal-fired plant, might still be quite noticeable. Constructionrelated impacts would be noticeable. Impacts during operation 

would be minor because of the small workforce involved. The 

plants would have aesthetic impacts. 

Human health SMALL Regulatory controls and oversight are assumed to be protective of 

human health. 

Historic and cultural 

resources 

 SMALL Any potential impacts could likely be effectively managed. Most of 

the facilities and infrastructure at the site would likely be built on 

previously disturbed ground. 

Environmental justice SMALL Some impacts on housing availability and prices during 

construction may occur, as might beneficial impacts from property 

tax revenues. 
Alternatives to the Proposed Action 

February 2010 9-25 NUREG-1917, SEIS 

9.2.5 Summary Comparison of Alternatives 

Table 9-4 contains a summary of the staff’s environmental impact characterizations for 

constructing and operating new nuclear, coal-fired, and natural gas-fired, combined-cycle 

generating units at the NAPS site. The combination of alternatives shown in Table 9-4 assumes 

siting of natural gas-fired, combined-cycle units at the NAPS site and siting of other generating 

units in the general vicinity (within 160 km [100 mi]) of the site. 

The staff reviewed the available information on the environmental impacts of power-generation 

alternatives compared to the construction of new nuclear units at the NAPS site. Based on this 

review, the staff concludes that from an environmental perspective, none of the viable energy 

alternatives are clearly preferable to construction of a new base-load nuclear power-generation 

plant at the NAPS site. 

Table 9-4. Summary of Environmental Impacts of Construction and Operation of New 

Nuclear, Coal-Fired, and Natural Gas-Fired Generating Units, and a Combination 

of Alternatives at the NAPS Site

Impact Category Nuclear Coal Natural Gas

Combination of 

Alternatives

Land use SMALL MODERATE SMALL to MODERATE MODERATE 

Air quality SMALL MODERATE SMALL to MODERATE SMALL to MODERATE 

Water use and 

quality 

SMALL to 

MODERATE 

SMALL to 

MODERATE 

SMALL to MODERATE SMALL to MODERATE 

Ecology SMALL MODERATE SMALL SMALL to MODERATE 

Waste management SMALL MODERATE SMALL SMALL to MODERATE 

Socioeconomics LARGE 

Beneficial to 

MODERATE 

Adverse 

LARGE 

Beneficial to 

MODERATE 

Adverse 

MODERATE Beneficial 

to MODERATE 

Adverse 

MODERATE Beneficial 

to MODERATE 

Adverse 

Human health SMALL SMALL SMALL SMALL 

Historic and cultural 

resources 

SMALL SMALL SMALL SMALL 

Environmental justice SMALL SMALL to 

MODERATE 

SMALL SMALL 

 

9.3 System Design Alternatives 

Alternatives to the combination closed-cycle, wet and dry (hybrid) cooling system proposed for 

Unit 3 were evaluated in Section 8.2 of the ESP EIS (NRC 2006), in which once-through, wet, 

and dry cooling are discussed as alternatives to the proposed combination of wet and dry 

cooling for the proposed Unit 3. Dominion’s COL ER provides further information that the 

proposed Unit 3 design characteristics for the combined-cycle, wet and dry cooling system are 
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NUREG-1917, SEIS 9-26 February 2010 

equal to or less than the ESP design parameters (Dominion 2009a). The staff did not identify 

any information that was both new and significant regarding alternative heat dissipation 

systems. Therefore, the conclusion from the ESP EIS (NRC 2006) that the proposed 

combination of wet and dry cooling for the proposed Unit 3 is preferable to the other three 

cooling alternatives is still valid. 

Alternatives to the water intake and discharge structure designs, water supply, and watertreatment systems for the proposed Unit 3 were not evaluated in the ESP EIS. Therefore, the 

remainder of this section provides a discussion of alternative intake and discharge structures, 

alternative water supplies, and alternative water-treatment systems that were evaluated for the 

COL. 

9.3.1 Alternative Intake Structure Designs 

9.3.1.1 Proposed Intake Structure 

The intake structure for the proposed Unit 3 is a partially submerged concrete inlet structure 

located on the shore of Lake Anna adjacent to the intake for the existing Units 1 and 2 (see 

Figure 2-1 of this SEIS). This location is the same that was planned for two additional units that 

were proposed at the time that existing NAPS Units 1 and 2 were licensed. A berm or 

cofferdam separating the main body of the lake from a settling lagoon is already in place; a set 

of box culverts through the cofferdam would allow water from the lake to enter the lagoon at a 

velocity of about 0.03 m/s (0.1 ft/s), meeting the ESP design parameter for the proposed Unit 3. 

Dominion’s current description of the intake pump arrangement and debris exclusion system 

states that the flow rate into the trash racks and traveling screens will be less than 0.15 m/s 

(0.5 ft/s), which also meets the design parameter evaluated in the ESP EIS (NRC 2006). 

9.3.1.2 Alternative Intake Structures 

At the time of the ESP application, Dominion stated that its proposed intake design had not 

matured enough to consider alternative pumping arrangements, defouling processes, or screen 

systems. However, Dominion did consider several alternative intake systems and locations: a 

submerged offshore structure, a shoreline intake structure at an alternative location, and an 

intake structure on the North Anna River downstream of the dam (Dominion Nuclear North 

Anna, LLC 2006). 

• The submerged offshore structure would be positioned just above the lake bottom in the 

vicinity of the intake structure for Units 1 and 2. Construction would involve dredging for 

placement of the structure and its pipeline, and placement of the pipeline between the intake 

and the shore. Operational losses of aquatic organisms resulting from to impingement and 

entrainment may be comparable to those of the proposed intake. 
Alternatives to the Proposed Action 

February 2010 9-27 NUREG-1917, SEIS 

• The shoreline intake structure would be at a location other than the proposed structure, 

several hundred feet from the existing unit’s intake structure. Construction would involve 

shoreline disturbance at a location other than the area already disturbed from previous 

construction. Dredging would likely be required to construct the intake and its associated 

piping. Operational losses due to impingement and entrainment would be comparable to 

those of the proposed intake. 

• The riverine intake structure would be located on the North Anna River downstream of the 

dam. The staff determined that an intake located on the North Anna River would be 

infeasible when the Lake Anna pool elevation is below 76.3 m (250.25 ft) because the water 

supply would be insufficient. 

All of the alternative intake structure designs would disturb at least as much land and shoreline 

area during construction as the proposed intake structure. Because construction impacts would 

be greater than, and operational impacts would be comparable or greater than those of the 

proposed intake, none of the alternative intakes are environmentally preferable to the proposed 

intake design. Therefore, no further economic evaluation of the alternatives relative to the 

proposed structure was conducted. 

9.3.2 Alternative Discharge Structure Designs 

9.3.2.1 Proposed Discharge Structure 

Dominion proposes to discharge blowdown water from the proposed Unit 3 into the existing 

discharge canal through a partially submerged concrete outfall structure adjacent to the existing 

Units 1 and 2 outfall. The proposed Unit 3 discharge will mix with discharge from the existing 

Units in the discharge canal before entering the Waste Heat Treatment Facility (WHTF). 

9.3.2.2 Alternative Discharge Structures 

At the time of the ESP, Dominion considered several alternative discharge systems and 

locations: a submerged offshore structure, a shoreline structure on the WHTF and a shoreline 

discharge on Lake Anna (Dominion Nuclear North Anna, LLC 2006). 

• The submerged offshore structure would be positioned just above the bottom of the WHTF. 

Construction would involve dredging for placement of the structure and its pipeline, and 

placement of the pipeline between the discharge and the shore. Because of the low 

discharge volume relative to the flow from the existing units in the WHTF, operational 

impacts would be comparable to those of the proposed discharge structure. 

• A discharge structure on the shoreline of the WHTF would involve shoreline disturbance at a 

location other than the area already disturbed from previous construction. Dredging would 

likely be required to construct the discharge and its associated piping. Again, because of 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-28 February 2010 

the low discharge volume relative to the flow from the existing units in the WHTF, 

operational impacts would be comparable to those of the proposed discharge structure. 

• A discharge structure on the shoreline of Lake Anna would also involve shoreline 

disturbance at a location other than an area already disturbed from previous construction. 

Dredging would likely be required to construct the discharge and its associated piping. 

Station discharge directly to Lake Anna would result in greater operational impacts to Lake 

Anna than the proposed discharge. 

All of the alternative discharge designs and locations would disturb more land and shoreline 

area during construction than the proposed discharge structure. Because construction impacts 

would be greater than, and operational impacts would be comparable or greater than those of 

the proposed discharge, none of the alternative discharges are environmentally preferable to 

the proposed intake design. Therefore, no further economic evaluation of the alternatives 

relative to the proposed discharge structure was conducted. 

9.3.3 Alternative Water Supplies 

9.3.3.1 Proposed Water Supply 

Dominion proposes to use Lake Anna for its primary supply of water (Dominion Nuclear North 

Anna, LLC 2006). Dominion determined that because of the certainty of the water supply (Lake 

Anna) for the proposed Unit 3 closed-cycle cooling system, consideration of alternative cooling 

water sources was not warranted. The staff also did not evaluate any alternative water supplies 

in the ESP EIS and so the alternative water sources are not resolved in the ESP proceeding. 

The staff’s evaluation of alternative water supplies follows. 

9.3.3.2 Alternative Water Supplies 

The staff assumed, as did Dominion, that Lake Anna would be the sole source of water during 

normal years. However, because the staff determined that water-use impacts would be 

MODERATE in drought periods, the staff did consider alternative water supplies that might 

mitigate these impacts in such years. The staff considered inter-basin transfers, such as 

withdrawing water from the James River, and the use of municipal wastewater. 

• Interbasin transfer of water from a nearby drainage such as the James River basin. 

Construction-related impacts associated with a new pipeline may be significant. Depending 

on the source of water, operational impacts could be small to large. The interbasin transfer 

of water would also involve regulatory concerns. 

• The use of municipal wastewater would also have construction-related impacts associated 

with a new pipeline. Operationally, the use of municipal wastewater for cooling could affect 
Alternatives to the Proposed Action 

February 2010 9-29 NUREG-1917, SEIS 

the water quality in Lake Anna. Sufficient municipal wastewater to support operation of 

Unit 3 currently is not available nearby because of the relatively sparse population in the 

area. 

The two alternatives would have significant construction impacts, because there is no existing 

canal or pipeline infrastructure available to transport the water to the NAPS site. Operational 

impacts of the alternative water supplies could be greater than those of the proposed water 

supply. The staff concluded that no water supply alternative was environmentally preferable to 

the proposed sole reliance on Lake Anna. Therefore, no further economic evaluation of the 

water supply alternatives relative to Lake Anna was conducted. 

9.3.4 Alternative Water-Treatment Systems 

At the time of the ESP application, Dominion considered several water-treatment systems: 

mechanical treatment, chemical treatment, and nonchemical treatment (Dominion Nuclear North 

Anna, LLC 2006). However, the staff did not evaluate these alternatives in the ESP EIS and so 

the alternatives are not resolved in the ESP proceeding. The staff’s evaluation of alternative 

water treatment follows. 

9.3.4.1 Proposed Water Treatment System 

Water for the circulating water system, which includes the condenser and combination wet and 

dry cooling tower system, is treated to remove solids and to prevent scale, biofilm, and 

corrosion of circulating water system piping and equipment. Dominion proposes to use 

chemical water treatment, which consists of injecting biocides, anti-scalants, dispersants, and 

other chemicals into the circulating water system as described in Section 3.2.1.2. 

9.3.4.2 Alternative Water Treatment Systems 

Two alternative water treatment methods were considered – mechanical treatment and 

nonchemical treatment. 

• Mechanical treatment utilizes slightly abrasive sponge balls to physically remove organic 

and inorganic material from the cooling condenser piping. There would be no construction 

impacts associated with mechanical treatment, and using abrasive balls inside the 

condenser tubing does not result in any chemical discharge during operation. Use of 

mechanical treatment is limited to cleaning the cooling condenser tubing, and is not effective 

in maintaining the combination wet-dry cooling tower system. 

• Nonchemical circulating water treatment uses ultraviolet (UV) light to kill the microorganisms 

responsible for fouling. There would be no construction-related impacts from installation of 

the UV light treatment system; there would be no chemical discharges during operation. 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-30 February 2010 

However, neither of these alternative technologies is suitable for wet cooling portions of the 

proposed hybrid cooling tower. Use of nonchemical treatment for the circulating water may 

reduce biofouling in the areas exposed to the UV light. Mechanical treatment would not reduce 

or eliminate biofouling in the wet portion of the cooling tower, and neither mechanical nor 

nonchemical treatment would prevent scale or corrosion throughout the circulating water 

system. The staff determined that chemical treatment is the only technology suitable for the 

proposed cooling system design, and that no water treatment alternative was feasible or 

environmentally preferable. Additionally, based on the requirements of 40 CFR Part 423, any 

impacts from these chemical additives would not justify mitigation. Therefore, no further 

economic evaluation of the water treatment alternatives was conducted. 

9.4 Region of Interest and Site-Selection Process 

Dominion’s region-of-interest and site-selection process are discussed in Section 8.3 of the 

ESP EIS (NRC 2006). No additional discussion of these topics is required in a supplement to 

an ESP EIS that is prepared for a COL application (10 CFR 51.92(e)(3)). 

9.5 Alternative Sites 

Alternatives sites are evaluated in Sections 8.3 and 8.8 of the ESP EIS (NRC 2006). No 

additional discussion of this topic is required in a supplement to an ESP EIS that is prepared 

for a COL application (10 CFR 51.92(e)(3)). 

9.6 References 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

Certifications, and Approvals for Nuclear Power Plants.” 

40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 

“National Primary and Secondary Ambient Air Quality Standards.” 

40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, 

“Requirements for Preparation, Adoption, and Submittal of Implementation Plans.” 

40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 

“Standards of Performance for New Stationary Sources.” 
Alternatives to the Proposed Action 

February 2010 9-31 NUREG-1917, SEIS 

40 CFR Part 63. Code of Federal Regulations, Title 40, Protection of Environment, Part 63, 

“National Emission Standards for Hazardous Air Pollutants for Source Categories.” 

40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 

“Designation of Areas for Air Quality Planning Purposes.” 

40 CFR Part 423. Code of Federal Regulations, Title 40, Protection of Environment, Part 423, 

“Steam Electric Power Generating Point Source Category.” 

65 FR 32214. “Notice of Regulatory Determination on Wastes from the Combustion of Fossil 

Fuels.” Vol. 65, No. 99. May 22, 2000. 

Clean Air Act. 42 USC 7401 et seq. 

Dominion Nuclear North Anna, LLC. 2006. North Anna Early Site Permit Application, Part 3 – 

Environmental Report, Revision 9. Accession No. ML062580096. 

Dominion Virginia Power (Dominion). 2008a. Letter from Eugene S. Grecheck (Dominion 

Virginia Power, Vice President) to the U.S. Nuclear Regulatory Commission, “Dominion Virginia 

Power, North Anna Unit 3 Combined License Application, Response to Request for Additional 

Information Regarding the Environmental Review,” July 17, 2008. Accession 

No. ML082620236. 

Dominion Virginia Power (Dominion). 2008b. Dominion & BP Announce Agreement to Jointly 

Develop Wind Farms in Virginia. Accessed October 14, 2008 at 

http://www.dom.com/news/elec2008/pr0421.jsp. Accession No. ML08326092. 

Dominion Virginia Power (Dominion). 2009a. North Anna 3 Combined License Application, 

Part 3: Environmental Report – Combined License Stage. Revision 2, July 2009. Accession 

No. ML092160490. 

Dominion Virginia Power (Dominion). 2009b. “Dominion Virginia Power’s and Dominion North 

Carolina Power’s Report of Its Integrated Resource Plan.” Accessed at 

http://dom.mediaroom.com/index.php?s=43&item=800 on September 29, 2009. 

Accession No. ML100350880. 

Energy Policy Act of 2005. Public Law 109–58. 

Energy Storage and Power LLC (ESP). 2008. Technology Overview – CAES. Accessed 

September 24, 2008 at http://www.energystorageandpower.com/caes_overview.html. 

Accession No. ML083260696. 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-32 February 2010 

Federal Aviation Administration (FAA). 2007. Obstruction Marking and Lighting. Advisory 

Circular AC 70/7460-1K. Accessed at 

https://oeaaa.faa.gov/oeaaa/external/content/AC70_7460_1K.pdf. Accession 

No. ML083260700. 

Gabbard A. 1993. “Coal Combustion: Nuclear Resource or Danger.” Oak Ridge National 

Laboratory Review. Summer/Fall 1993. Oak Ridge National Laboratory, Oak Ridge, 

Tennessee. Accessed October 14, 2008 at http://www.ornl.gov/ORNLReview/rev26-

34/text/colmain.html. Accession No. ML083260701. 

Idaho National Engineering and Environmental Laboratory (INEEL). 1997. U.S. Hydropower 

Resource Assessment for Virginia. DOE/ID-10430(VA). Accessed at 

http://hydropower.id.doe.gov/resourceassessment/pdfs/states/va.pdf. Accession 

No. ML083260706. 

Integrated Waste Services Association (IWSA). 2008. Energy. Accessed at 

http://www.wte.org/energy/. Accession No. ML083260713. 

Massachusetts Institute of Technology (MIT). 2006. The Future of Geothermal Energy: Impact 

of Enhanced Geothermal Systems (EGS) on the United States in the 21st Century. Accessed 

at http://geothermal.inel.gov/publications/future_of_geothermal_energy.pdf. 

Accession No. ML093210610. 

National Energy Technology Laboratory (NETL). 2007. Cost and Performance Baseline for 

Fossil Energy Plants. Volume 1: Bituminous Coal and Natural Gas to Electricity. DOE/NETL2007/1281. Accessed at http:// www.netl.doe.gov/energyanalyses/pubs/Bituminous%20Baseline_Final%20Report.pdf?bcsi_scan_A3171404B2C9D30E

=0&bcsi_scan_filename=Bituminous%20Baseline_Final%20Report.pdf. Accession 

No. ML083260721. 

Northwest Power and Conservation Council (NPCC). 2005. The Fifth Northwest Electric Power 

and Conservation Plan. Accessed at http://www.nwcouncil.org/energy/powerplan/5/Default.htm 

Accession No. ML083260725. 

Northwest Power and Conservation Council (NPCC). 2006. Biennial Assessment of the Fifth 

Power Plan: Assessment of Other Generating Technologies. Accessed at 

http://www.nwppc.org/energy/Biennial/BiennialOther%20gen.pdf. Accession 

No. ML083260735. 

Northwest Power and Conservation Council (NPCC). 2009. Draft Northwest 6th Power Plan. 

Accessed at http://www.nwppc.org/energy/powerplan/6/default.htm on October 27, 2009. 

Accession No. ML100361059. 
Alternatives to the Proposed Action 

February 2010 9-33 NUREG-1917, SEIS 

Nuclear Energy Institute (NEI). 2007. Resources & Stats: Reliable and Affordable Energy. 

Accessed at 

http://www.nei.org/resourcesandstats/documentlibrary/reliableandaffordableenergy/graphicsand

charts/usnuclearindustrycapacityfactors/ on November 21, 2008. Accession No. ML083260737. 

Old Dominion Electric Cooperative (ODEC). 2008. Our Members. Accessed at 

http://www.odec.com/members/index.htm on October 14, 2008. Accession No. ML083260743. 

Resource Conservation and Recovery Act of 1976. 42 USC 6901 et seq. 

Succar, S. and R. H. Williams. 2008. “Compressed Air Energy Storage: Theory, Resources, 

and Applications for Wind Power.” Princeton University Energy Systems Analysis Group. 

Accessed at http://www.princeton.edu/~ssuccar/caesReport.html on October 27, 2009. 

Accession No. ML100361047. 

Southern Co. and Georgia Institute of Technology (Southern and GIT). 2007. Southern Winds: 

A Study of Wind Power Generation Potential off the Georgia Coast. Accessed at 

http://www.energy.gatech.edu/research/Summary-Southern-Winds.pdf. Accession 

No. ML083260744. 

Texas State Energy Conservation Office (TSECO). 2008. Texas Solar Energy. Accessed 

October 14, 2008 at http://www.seco.cpa.state.tx.us/re_solar.htm. Accession 

No. ML083260621. 

U.S. Department of Energy (DOE). 2005. Wind Energy Resource Potential. Accessed 

November 21, 2008 at http://www1.eere.energy.gov/windandhydro/wind_potential.html. 

Accession No. ML083260634. 

U.S. Department of Energy (DOE). 2006. Geothermal FAQs. Accessed October 29, 2008 at 

http://www1.eere.energy.gov/geothermal/faqs.html. Accession No. ML083260645. 

U.S. Department of Energy (DOE). 2007. Fuel Cell Technology Challenges. Accessed at 

http://www1.eere.energy.gov/hydrogenandfuelcells/fuelcells/fc_challenges.html on October 14, 

2008. Accession No. ML083260659. 

U.S. Department of Energy (DOE). 2008a. 20% Wind Energy by 2030, Increasing Wind 

Energy’s Contribution to U.S. Electricity Supply. DOE/GO-102008-2567. Accessed at 

http://www1.eere.energy.gov/windandhydro/pdfs/41869.pdf. Accession No. ML083260676. 

U.S. Department of Energy (DOE). 2008b. State Energy Alternatives: Biomass Energy. 

Accessed at http://www.eere.energy.gov/states/alternatives/biomass.cfm on October 14, 2008. 

Accession No. ML083260679. 
Alternatives to the Proposed Action 

NUREG-1917, SEIS 9-34 February 2010 

U.S. Department of Energy-Energy Information Administration (DOE/EIA). 2001. Renewable 

Energy 2000: Issues and Trends. DOE/EIA-0628(2000), Washington, D.C. Accessed at 

http://tonto.eia.doe.gov/FTPROOT/renewables/06282000.pdf. Accession No. ML083260685. 

U.S. Department of Energy-Energy Information Administration (DOE/EIA). 2007. Solar 

Thermal and Photovoltaic Collector Manufacturing Activities 2006. Accessed at 

http://www.eia.doe.gov/cneaf/solar.renewables/page/solarreport/solar.html on July 18, 2008. 

Accession No. ML083260689. 

U.S. Department of Energy-Energy Information Administration (DOE/EIA). 2008. Annual 

Energy Outlook 2008 with Projections to 2030. DOE/EIA-0383(2008). Accessed at 

www.eia.doe.gov/oiaf/aeo/pdf/0383(2008).pdf. Accession No. ML083260693. 

U.S. Department of Energy-Energy Information Administration (DOE/EIA). 2009. “Virginia 

Quick Facts.” Accessed at http://tonto.eia.doe.gov/state/state_energy_profiles.cfm?sid=VA on 

October 27, 2009. Accession No. ML100560239. 

U.S. Environmental Protection Agency (EPA). 2008. Basic Information: Municipal Solid Waste. 

Accessed at http://www.epa.gov/msw/facts.htm on October 14, 2008. Accession 

No. ML083260694. 

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants. NUREG-1437 Vols. 1 and 2, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2006. Environmental Impact Statement for an 

Early Site Permit (ESP) at the North Anna ESP Site. NUREG-1811, Washington, D.C. 

Accession Nos. ML063480261 and ML083480263. 

Virginia Department of Mines, Minerals, and Energy (VDMME). 2007. The Virginia Energy 

Plan. Accessed at http://www.dmme.virginia.gov/DE/VAEnergyPlan/2007VEP-Full.pdf. 

Accession No. ML083260698. 
February 2010 10-1 NUREG-1917, SEIS 

10.0 Conclusions and Recommendations 

On November 27, 2007, the U.S. Nuclear Regulatory Commission (NRC) received an 

application from Dominion Virginia Power and Old Dominion Electric Cooperative, collectively 

known as Dominion, for a combined license (COL) for the North Anna Power Station (NAPS) 

site (Dominion 2008a). The NAPS site is located approximately 64 km (40 mi) north-northwest 

of Richmond, Virginia. A COL, which encompasses both a construction permit and an operating 

license, is a Commission approval to build and operate one or more nuclear power facilities. In 

its application, Dominion specified the Economic Simplified Boiling-Water Reactor (ESBWR) as 

the proposed design for the new reactor, designated Unit 3, to be constructed and operated at 

the NAPS site. 

Section 102 of the National Environmental Policy Act of 1969 (NEPA) (42 USC 4321 et seq.) 

directs that an environmental impact statement (EIS) is required for major Federal actions that 

significantly affect the quality of the human environment. Section 102(2)(C) of NEPA requires 

that an EIS include information on: 

• the environmental impact of the proposed action 

• any adverse environmental effects that cannot be avoided should the proposal be 

implemented 

• alternatives to the proposed action 

• the relationship between local short-term uses of the environment and the maintenance and 

enhancement of long-term productivity 

• any irreversible and irretrievable commitments of resources that would be involved if the 

proposed action is implemented. 

The NRC has implemented NEPA in Title 10 of the Code of Federal Regulations (CFR) Part 51. 

In 10 CFR 51.20, the NRC requires preparation of an EIS for issuance of licenses to construct 

and operate a nuclear power plant. Subpart C of 10 CFR Part 52 contains the NRC regulations 

related to COLs. 

The COL application (Dominion 2008a) references an early site permit (ESP) for the North Anna 

ESP site, which is located on the NAPS. In November 2007, NRC approved issuance of the 

ESP for two additional nuclear units at the NAPS ESP site. This approval was supported by 

information documented in the ESP final environmental impact statement (ESP EIS) (NRC 

2006). The ESP permit, ESP-003, was issued to Dominion by the NRC on November 27, 2007 

(NRC 2007a). For a COL application that references an ESP, the NRC staff, pursuant to 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-2 February 2010 

10 CFR 51.75(c), prepares a supplement to the ESP EIS in accordance with 10 CFR 51.92(e). 

Therefore the staff relies upon the analysis in that document as the basis in preparation of this 

supplemental EIS (SEIS). 

Upon acceptance of the proposed Unit 3 COL application, the NRC began the environmental 

review process described in 10 CFR Part 51 by publishing in the Federal Register a Notice of 

Intent to prepare an EIS and Conduct Scoping (73 FR 13589). The initial Notice of Intent was 

later corrected and a supplement was published in the Federal Register (73 FR 41132). The 

staff held a public scoping meeting in Mineral, Virginia, on April 16, 2008, and a site audit at 

NAPS during the period of April 14-18, 2008. Both during and following the site audit and the 

scoping meeting and in accordance with NEPA and 10 CFR Part 51, the staff determined and 

evaluated the new and significant information related to the potential environmental impacts of 

constructing and operating a new nuclear unit at the NAPS site. 

The draft SEIS was published in December 2008 (NRC 2008). A 75-day comment period 

began on January 2, 2009, when the U.S. Environmental Protection Agency (EPA) issued a 

Federal Register Notice (74 FR 106) of filing of the draft SEIS to allow members of the public to 

comment on the results of the NRC staff’s review. The comment period was later extended 

(74 FR 4476). The NRC held a public meeting in Mineral, Virginia, on February 3, 2009, to 

describe the preliminary results of the environmental review, to answer questions, and to 

provide members of the public with information to assist them in formulating comments on the 

draft SEIS. When the comment period ended on March 20, 2009, the staff considered and 

addressed all of the comments received. All comments received on the draft SEIS are included 

in Appendix E. 

Included in this SEIS are (1) the results of the NRC staff’s analyses, which consider and weigh 

the environmental effects of the proposed action and of constructing and operating a new 

nuclear unit at the NAPS site; (2) mitigation measures for reducing or avoiding adverse 

effects; (3) the environmental impacts of alternatives to the proposed action; and (4) the 

staff’s recommendation regarding the proposed action based on its environmental review. 

The COL application references an ESP, so where appropriate, this SEIS adopts results of the 

environmental review conducted in support of the ESP application and incorporates those 

results by reference. 

During the course of preparing this SEIS, the staff reviewed the Environmental Report (ER) 

submitted as part of the COL application (Dominion 2009); relied on the environmental review 

conducted for the ESP application (Dominion Nuclear North Anna, LLC 2006) and documented 

in the ESP EIS (NRC 2006); consulted with Federal, State, Tribal, and local agencies; and 

followed the guidance set forth in Regulatory Guide 4.2, Revision 2 (NRC 1976), and Standard 

Review Plans for Environmental Reviews for Nuclear Power Plants (NUREG-1555) (NRC 

2000). Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power 
Conclusions and Recommendations 

February 2010 10-3 NUREG-1917, SEIS 

Plants (NUREG-0800) (NRC 2007b) also was applicable. In addition, the NRC considered 

public comments related to the environmental review received during the public comment 

periods. These comments are provided in Appendixes D and E of this SEIS. 

To guide its assessment of environmental impacts of a proposed action or alternative actions, 

the NRC has established a standard of significance for impacts based on guidance developed 

by the Council on Environmental Quality (40 CFR 1508.27). The three significance levels 

established by the NRC – SMALL, MODERATE, or LARGE – are defined as follows: 

SMALL – Environmental effects are not detectable or are so minor that they will neither 

destabilize nor noticeably alter any important attribute of the resource. 

MODERATE – Environmental effects are sufficient to alter noticeably, but not to destabilize, 

important attributes of the resource. 

LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize 

important attributes of the resource. 

Mitigation measures were considered for each environmental issue and are discussed in the 

appropriate sections. During its environmental review, the staff considered planned activities 

and actions that Dominion indicates it and others would likely take should Dominion receive a 

COL. In addition, Dominion provided estimates of the environmental impacts resulting from the 

construction and operation of a new nuclear unit on the NAPS site.

10.1 Impacts of the Proposed Action 

Impacts associated with construction of the proposed Unit 3 are discussed in Chapter 4 of the 

ESP EIS and are summarized in Table 4-1 of that document (NRC 2006). Likewise, impacts 

associated with operation of the proposed reactor and its associated facilities are discussed in 

Chapter 5 of the ESP EIS and are summarized in Table 5-22, page 5-92 (NRC 2006). This 

information, as modified and supplemented by this SEIS, provide the basis for an informed 

decision concerning the environmental impacts of issuance of a COL by the NRC. 

In Chapter 7 of this SEIS, the staff considered the potential cumulative impacts resulting from 

construction and operation of the proposed Unit 3 with past, present, and reasonably 

foreseeable future actions at and in the vicinity of the NAPS site. For each impact area, the 

staff’s determination is that the potential cumulative impacts resulting from construction and 

operation would be SMALL and that mitigation is not warranted. Several issues have the 

potential for MODERATE impacts, most of which would occur under temporary circumstances 

or as the result of a larger-than-expected concentration of construction workers settling near the 

NAPS site. 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-4 February 2010 

10.2 Unavoidable Adverse Environmental Impacts 

Section 102(2)(C)(ii) of NEPA requires that an EIS include information on any adverse 

environmental effects that cannot be avoided should the proposed project be implemented. 

Unavoidable adverse environmental impacts are those potential impacts of construction and 

operation of new units that cannot be avoided and for which no practical means of mitigation are 

available. 

The unavoidable adverse environmental impacts associated with the granting of the COL for 

NAPS Unit 3 would include impacts of both construction and operation. Unavoidable adverse 

impacts will be mitigated using best available mitigation measures. 

Before it could obtain a COL from the NRC, Dominion must obtain a Clean Water Act 

Section 401 Certification. This certification would be issued by the Commonwealth of Virginia 

and would ensure that the project does not conflict with water quality management programs in 

the Commonwealth. Upon receipt of the permit, Dominion would notify NRC. 

10.2.1 Unavoidable Adverse Impacts During Construction

Chapter 4 discusses in detail the potential impacts from construction of the proposed new Unit 3 

at the NAPS site. The unavoidable adverse impacts related to construction are listed in 

Table 10-2 of the ESP EIS (NRC 2006). In Table 10-1 of its COL ER (Dominion 2009), 

Dominion listed newly identified construction-related, unavoidable adverse impacts that would 

occur beyond those evaluated during the ESP environmental review. The primary newly 

identified construction-related, unavoidable adverse environmental impacts are the result of 

construction of an additional 500-kV transmission line to support the operation of the proposed 

Unit 3. A majority of the newly identified construction-related activities for the proposed Unit 3, 

including ground-disturbing activities, would occur outside the existing NAPS site boundary. 

According to Dominion (2009), the onsite land area that would be affected on a long-term basis 

as a result of constructing and operating permanent facilities encompasses approximately 49 ha 

(120 ac), which is a slight decrease from the estimate of 52 ha (128 ac) that was estimated for 

the ESP EIS (NRC 2006). Additional onsite lands areas that would be disturbed on a short-term 

basis as a result of temporary construction activities and facilities included the laydown areas 

along with road and rail improvements to transport the reactor pressure vessel and other large 

components to the site (Dominion 2009). 

Dewatering systems employed during excavation within the powerblock area would depress the 

water table in the general vicinity; however, the impacts would be localized and temporary. The 

alteration of the land surface at NAPS Unit 3 site would cause a localized change in the 

recharge rate to the Water Table aquifer. 
Conclusions and Recommendations 

February 2010 10-5 NUREG-1917, SEIS 

Construction activities for the proposed new 500-kV transmission line along the existing 

transmission line right-of-way would create impacts both onsite and offsite. Specific information 

regarding this new transmission line is available in Section 3.7 of Dominion’s COL ER 

(Dominion 2009). The 24-km (15-mi) transmission line would be constructed in the existing 

NAPS to Ladysmith right-of-way that is 84 m (275 ft) wide and would be approximately 3 m 

(10 ft) taller than the existing transmission line in the right-of-way.

Construction of the new transmission line would not impact any threatened and endangered 

species. Construction activities would be conducted in accordance with all applicable laws, 

regulations, and permit requirements, and would use good engineering and construction 

practices (Dominion 2008a). 

Socioeconomic impacts of construction include an increase in traffic involving construction 

workers, and possible demand pressure on the local housing market if workers concentrate in 

Louisa County. Air-quality impacts include fugitive dust from construction activities and pollutant 

emissions from construction equipment. Those impacts would be mitigated by the dust-control 

and vehicle-maintenance plans. Radiological doses to construction workers from the adjacent 

units are expected to be well below regulatory limits. No unusual resource dependencies on 

minority and low-income populations in the region were identified. In addition, no environmental 

pathways related to construction activities were found that would lead to adverse and 

disproportionate impacts on minority and low-income populations. 

Newly identified unavoidable adverse impacts from construction of the proposed Unit 3 are 

summarized in Table 10-1. 

Table 10-1. Newly Identified Unavoidable Adverse Environmental Impacts from Construction

Impact 

Category 

Adverse 

Impacts Based 

on Dominion’s 

Application Actions to Mitigate Impacts

Newly Identified Unavoidable 

Adverse Impacts 

Land use 

(onsite) 

Yes Comply with requirements of 

applicable Federal, State, Tribal, and 

local permits 

49 ha (120 ac) disturbed on a longterm basis; additional land 

disturbed on a temporary basis 

Transmission 

line rights-ofway and land 

use (offsite) 

Yes Restore disturbed areas, remove and 

dispose of debris left or caused by 

construction, restore damaged 

property to its original condition and 

to the satisfaction of the property 

owner, and take appropriate action 

following the discovery of potential 

historical or archeological resources. 

Construction of an additional 

500-kV transmission line, and 

associated equipment, in existing 

transmission rights-of-way 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-6 February 2010 

Table 10-1. (contd)

Impact 

Category 

Adverse 

Impacts Based 

on Dominion’s 

Application Actions to Mitigate Impacts

Newly Identified Unavoidable 

Adverse Impacts 

Hydrological 

and water use 

Yes Implement erosion and sedimentation 

control measures. 

Construction of an additional 

500-kV transmission line, and 

associated equipment, in an 

existing transmission line right-ofway and crossing water bodies 

Ecological 

(terrestrial) 

Yes Control soil disturbances within 30 m 

(100 ft) of streams, creeks, and 

ditches with running water. Obtain all 

necessary permits, if applicable, prior 

to site-preparation activities. Dustsuppression techniques would be 

utilized and equipment maintenance 

employed to reduce airborne 

emissions. After construction 

completed, restore disturbed areas 

with most practical methods. 

Construction of a new 500-kV 

transmission line in an existing 

right-of-way would disturb existing 

terrestrial habitats 

Aquatic Yes Control soil disturbances within 30 m 

(100 ft) of streams, creeks, and 

ditches with running water 

Construction of new 500-kV 

transmission line in an existing 

right-of-way could impact existing 

aquatic habitats

Socioeconomic Yes Access to recreational areas 

impacted would be temporarily 

restricted 

Construction of new 500-kV 

transmission line in an existing 

right-of-way could impact public 

access to areas for recreational 

activities 

Water-use Yes Nonradioactive effluents, including 

sanitary waste and blowdown from 

the Unit 3 tower would be governed 

by limits of VPDES permit. Operate 

a dechlorination system to neutralize 

chlorine in circulating water system 

and cooling tower blowdown before 

discharge into WHTF. 

New cooling tower and separate 

sanitary waste system would be 

added for the proposed Unit 3, 

creating the potential for additional 

chemical effluents 

Nonradioactive 

waste system 

Yes Sanitary wastes will be managed 

onsite and disposed of at an offsite 

location in compliance with applicable 

laws, regulations, and conditions 

associated with required permits. 

A separate sanitary waste system 

would be added for the proposed 

Unit 3, creating a requirement for 

disposal of additional sanitary 

waste 

 
Conclusions and Recommendations 

February 2010 10-7 NUREG-1917, SEIS 

10.2.2 Unavoidable Adverse Impacts During Operation 

Chapter 5 provides a detailed discussion of the potential impacts from operation of the proposed 

NAPS Unit 3. The unavoidable adverse impacts related to operation are listed in Table 10-3 of 

the ESP EIS (NRC 2006). In Table 10-2 of its COL ER (Dominion 2009), Dominion identified 

additional unavoidable adverse impacts during operation that would occur beyond those 

evaluated during the ESP environmental review. These impacts are summarized in Table 10-2. 

Table 10-2. Newly Identified Unavoidable Adverse Environmental Impacts from Operation 

Impact Category 

Adverse Impacts 

Based on 

Dominion’s 

Application Actions to Mitigate Impacts 

Additional Unavoidable 

Adverse Impacts 

Hydrological and 

water use 

Yes Comply with limits established 

in VPDES permit. This will 

require operation of a 

dechlorination system. 

Additional chemical effluents 

from new combined wet and 

dry cooling tower and 

separate sanitary waste 

system. 

Hydrological and 

water use 

Yes Waste managed onsite and 

disposed of offsite in 

compliance with State and local 

regulations and permit 

conditions. 

New separate proposed 

Unit 3 sanitary waste system 

would be constructed and 

operated. 

 

10.3 Alternatives to the Proposed Action 

Alternatives to the proposed action discussed in this SEIS are the no-action alternative, energy 

alternatives, and system design alternatives that were not addressed in the ESP EIS 

(NRC 2006). 

The no-action alternative is discussed in Section 9.1 of this SEIS. Under the no-action 

alternative, the NRC would not issue the COL to Dominion. There would be no environmental 

impacts associated with not issuing the COL at the NAPS site, except for the impacts 

associated with site preparation activities that are not within the definition of construction at 

10 CFR 50.10(a) and 51.4. At the same time, the benefits associated with the proposed action 

would not occur. If the COL application is denied, the power would still be needed as discussed 

in Chapter 8 of the SEIS. Dominion would have a variety of options for meeting power needs, 

including constructing a new nuclear power plant at another site, constructing a coal- or natural 

gas-fired plant at the NAPS site or at another site and pursuing one or more of the energy 

alternatives discussed in Section 9.2 of this SEIS. There would be environmental impacts 

associated with any of these options that would occur at the location of the alternative energy 

source and its surrounding area. 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-8 February 2010 

Energy alternatives are discussed in Section 9.2 of this SEIS. The staff concluded that none of 

the energy alternatives are both (1) practical for meeting Dominion’s purpose of providing 

approximately 1500 MW(e) of base-load power, and (2) environmentally preferable to the 

proposed action. 

System design alternatives are discussed in Section 9.3 of this SEIS. Cooling system design 

alternatives were evaluated and resolved as part of the ESP process. Alternatives to the water 

intake and discharge structure designs, water supply, and water treatment systems were 

evaluated in this SEIS. The staff concludes that none of the proposed alternatives in these 

areas were considered environmentally preferable to the proposed action. 

10.4 Relationship Between Short-Term Uses and Long-Term 

Productivity of the Human Environment 

Section 102(2)(C)(iv) of NEPA requires that an EIS include information on the relationship 

between local short-term uses of the environment and the maintenance and enhancement of 

long-term productivity. The evaluation of the relationship between local short-term uses of the 

environment and the maintenance and enhancement of long-term productivity for the 

construction and operation of proposed COL units can be performed by discussing the benefits 

of operating the units. The principal benefit is the production of electricity. The analysis of the 

benefit-cost balance is presented in Section 10.6 of this SEIS. If a new nuclear power plant is 

constructed on the NAPS site, power production would continue until the operating license or 

COL expires or the licensee chooses to cease operation. Once the plant is shut down, it would 

be decommissioned according to NRC regulations. Once decommissioning is complete and the 

NRC license is terminated, the site would be available for other uses. 

10.5 Irreversible and Irretrievable Commitments of 

Resources 

Section 102(2)(C)(v) of NEPA requires that an EIS include information on any irreversible and 

irretrievable commitments of resources that would occur if the proposed action is implemented. 

Irretrievable commitments of resources during construction of the proposed new units generally 

would be similar to that of any major construction project. A study by the U.S. Department of 

Energy (DOE) (DOE 2004) on new reactor construction estimated the following quantities of 

materials would be required for a new reactor: 9357 m3

 (12,239 yd3) of concrete, 2819 MT 

(3107 tons) of rebar, 2,000,000 m (6,500,000 ft) of cable, and 83,820 m (275,000 ft) of piping 

would be needed for a single reactor building. Hazardous materials such as asbestos would not 

be used. 
Conclusions and Recommendations 

February 2010 10-9 NUREG-1917, SEIS 

The staff expects that the use of construction materials in the quantities associated with those 

expected for NAPS Unit 3, while irretrievable, would be of small consequence with respect to 

the availability of such resources. 

The main resource that would be irretrievably committed during operation of the new nuclear 

units would be uranium. The availability of uranium ore and existing stockpiles of highly 

enriched uranium in the United States and Russia that could be processed into fuel is sufficient, 

so that the irreversible and irretrievable commitment would be of small consequence. 

10.6 Benefit-Cost Balance 

NEPA (42 U.S.C. 4321 et seq.), as amended, implemented by Executive Orders 11514 and 

11991 and the Council on Environmental Quality’s (CEQ) Guidelines (40 CFR Part 1500), 

requires that all agencies of the Federal Government prepare detailed environmental 

statements on proposed major Federal actions that can significantly affect the quality of the 

human environment. The NRC’s framework for implementing NEPA is provided at 10 CFR 

Part 51. A principal objective of NEPA is to require each Federal agency to consider, in its 

decision-making process, the environmental impacts of each proposed major action and the 

available alternative actions, including alternative sites. In particular, as stated below, NEPA 

requires all Federal agencies to the fullest extent possible: 

(B) identify and develop methods and procedures, in consultation with the Council on 

Environmental Quality established by title II of this Act, which will insure that 

presently unquantified environmental amenities and values may be given appropriate 

consideration in decisionmaking along with economic and technical considerations. 

However, neither NEPA nor CEQ requires the benefits and costs of a proposed action be 

quantified in dollars or any other common metric. 

NUREG-1555 (NRC 2000) Section 10.4.2 recommends the staff “... express all internal costs, 

either provided by the applicant or estimated by the staff, in monetary terms.” The intent of this 

section is not to identify and quantify all of the potential societal benefits of the proposed 

activities and compare these to the potential costs of the proposed activities. Instead, this 

section will focus on only those benefits and costs of such magnitude or importance that their 

inclusion in this analysis can inform the decision-making process. This section compiles and 

compares the pertinent analytical conclusions reached in earlier chapters of this SEIS. It 

gathers the expected impacts from construction and operations of the proposed Unit 3 and 

aggregates them into two final categories: (1) the expected costs and (2) the expected benefits 

to be derived from approval of the proposed action. 

This section identifies the benefits and costs of constructing and operating the proposed Unit 3 

at the NAPS site. Although conceptually similar to a purely economic benefit-cost analysis, 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-10 February 2010 

which determines the net present dollar value of a given project, the intent of this section is to 

identify all potential societal benefits of the proposed activities and compare these to the 

potential internal (i.e., private) as well as external (i.e., societal) costs of the proposed activities. 

The purpose is to generally inform the COL process by gathering and reviewing information that 

demonstrates the likelihood that the benefits of the proposed activities outweigh the aggregate 

costs. 

General issues related to Dominion’s financial viability are outside NRC’s mission and authority 

and, thus, are not considered in this SEIS. Issues related to the financial qualifications of the 

applicant will be addressed in the staff’s safety evaluation report. It is not possible to quantify 

and assign a value to all benefits and costs associated with the proposed action. This analysis, 

however, attempts to identify, quantify, and provide monetary values for benefits and costs 

when reasonable estimates are available. 

Section 10.6.1 discusses the benefits associated with the proposed action. Section 10.6.2 

discusses the costs associated with the proposed action. A summary of benefits is shown in 

Table 10-3. In accordance with the staff’s guidance in NUREG-1555, internal costs of the 

proposed project are presented in monetary terms. Internal costs include all of the costs 

included in a total capital cost assessment: direct and indirect cost of construction plus the 

annual costs of operation and maintenance. Section 10.6.3 provides a summary of the impact 

assessments, bringing previous sections together to establish a general impression of the 

relative magnitude of the proposed project’s costs and benefits. 

Table 10-3. Monetary and Nonmonetary Benefits of the Proposed Unit 3 (Adapted from 

Dominion COL ER) (Dominion 2009) 

Category of Benefit Description of Benefit 

Monetized Value of Benefit 

Over License Period 

Net Electrical Generating Benefits 

Net generating capacity ~1500 MW(e) 

Electricity generated (operating at 

90 percent cap.) 

~12,000,000 MW(h) per year 

Taxes and Other Revenue During Plant Construction and Operation Period (transfer payments – 

not independent benefits)(a) 

Annual state taxes NAPS from 

construction 

Proposed Unit 3 would pay 

$4.8 million per year over the 

3-year construction period. 

$14.4 million over the 3-year 

construction period 

Annual property taxes from 

construction 

Proposed Unit 3 would pay 

$3.1 million per year over the 

3-year construction period. 

$9.3 million over the 3-year 

construction period 
Conclusions and Recommendations 

February 2010 10-11 NUREG-1917, SEIS 

Table 10-3. (contd) 

Category of Benefit Description of Benefit 

Monetized Value of Benefit 

Over License Period 

Annual sales taxes from 

construction 

Proposed Unit 3 would pay 

$0.4 million per year over the 

construction period.

$1.2 million over the 3-year 

construction period 

Annual state taxes from NAPS from 

operations 

Proposed Unit 3 would pay 

$14.8 million per year. 

$592 million 

Annual local property taxes from 

NAPS from operations 

Proposed Unit 3 would pay 

$24.2 million per year. 

$968 million 

Annual local sales taxes NAPS 

from operations 

Proposed Unit 3 would pay 

$3.5 million per year 

$140 million 

Local NAPS purchases $29.3 million per year $1172 million 

Virginia NAPS purchases outside 

ROI 

$40 million per year $1600 million 

U.S. NAPS purchases outside 

Virginia 

$34 million per year $1360 million 

Effects on Regional Productivity 

Construction workers Approximately 2500 to 

3500 workers create an 

incremental increase of 1545 to 

2163 indirect jobs within the 

region. 

Operational workers 500 workers create an incremental 

increase in 1035 indirect 

permanent jobs within the region 

for at least 40 operating years. 

Socioeconomics Increased tax revenue supports 

improvements to public 

infrastructure and social services. 

The increased revenue spurs 

future growth and development. 

Technical and other nonmonetary 

benefits 

Fuel diversity reduces exposure to 

supply and price risk associated 

with reliance on any single fuel 

source. 

Price volatility Dampens potential for fuel price 

volatility. 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-12 February 2010 

Table 10-3. (contd) 

Category of Benefit Description of Benefit 

Monetized Value of Benefit 

Over License Period 

Electrical reliability Enhances reliability of the 

electricity supply. 

(a) Local property and sales taxes include impacts on counties other than Louisa County. VEDP estimated that 

about 92 percent of the local tax impact would occur in Louisa County during construction, but only 46 percent 

during operations. State and local tax impacts are based on the VEDP estimates of construction and operations 

expenditures and employment, which are less than Dominion’s current estimates of plant construction and 

operations requirements. See text in Section 10.6.1.2. 

10.6.1 Benefits

The most apparent benefit from constructing and operating a power plant is that it would 

generate power and provide thousands of residential, commercial, and industrial consumers 

with electricity. Section 8.1 of this SEIS outlines the social and economic importance of 

maintaining an adequate supply of electricity in any given region, establishing that power as the 

foundation for economic stability, growth, and as being fundamental to maintaining the standard 

of living we have come to expect. In addition to nuclear power, however, there are a number of 

different power-generation technology options that could meet this need, including natural gasfired and coal-fired plants, and hydroelectric plants. Because the focus of this SEIS is on the 

proposed expansion of the generating capacity at the NAPS site, this section focuses primarily 

on the relative benefits of the proposed Unit 3 option rather than the broader, more generic 

benefits of electricity supply. 

10.6.1.1 Societal Benefits 

From a societal perspective, price stability and longevity and energy security and fuel diversity 

are the primary benefits associated with nuclear power generation relative to most other 

alternative generating approaches. These benefits are described in this subsection. 

Price Stability and Longevity 

Because of relatively low and nonvolatile fuel costs, approximately 0.5 cents per kWh, and 

projected availability rate of 85 to 93 percent (see Section 8.4.3.1), nuclear energy is a 

dependable provider of electricity that can be provided at relatively stable prices to the 

consumer over a long period of time. 

Nuclear power plants are generally not subject to fuel price volatility like natural gas and oil 

power plants. In addition, uranium fuel constitutes only 3 to 5 percent of the cost of a kilowatthour of nuclear-generated electricity. Doubling the price of uranium increases the cost of 
Conclusions and Recommendations 

February 2010 10-13 NUREG-1917, SEIS 

electricity by about 7 percent; while doubling the price of gas would add about 70 percent to the 

price of electricity, and doubling the cost of coal would add about 36 percent to the price of 

electricity (WNA 2008). 

Energy Security and Fuel Diversity 

Currently, more than 70 percent of the electricity generated in the United States is from fossilbased technologies; thus, nonfossil-based generation, such as nuclear generation, are essential 

to maintaining diversity in the aggregate power generation fuel mix (DOE/EIA 2007). Nuclear 

power contributes to the diverse U.S. energy mix, thereby hedging the risk of shortages and 

price fluctuations for any one generating system. 

Chapter 8 of the Dominion’s COL ER (Dominion 2009) discussed the PJM load forecast for 

2008 (PJM 2007), which revealed a need for approximately 1900 MW(e) of additional base-load 

generation within the Dominion Zone in the 2015/2016 time frame, even after accounting for 

conservation and load-management programs. The proposed Unit 3 would generate 

approximately 1500 MW(e) net, or about four-fifths of that anticipated surplus demand. 

Assuming a reasonably low capacity factor of 85 percent, the plant’s average annual electrical 

energy generation would be more than 11,169,000 MWh. A reasonably high-capacity factor of 

93 percent would result in slightly more than 11,826,000 MWh of electricity. 

10.6.1.2 Regional Benefits 

Tax Revenue Benefits 

Dominion’s 2007 tax payments to Louisa County for the NAPS site were about $9.7 million, 

which represented approximately 22 percent of the total county property tax revenues 

(Dominion 2008b). Additional State and local tax revenue would represent a transfer benefit, 

but one of considerable importance to local government bodies. In 2006, the Virginia Economic 

Development Partnership (VEDP 2006) used IMPLAN, a commercially available input/output 

modeling program, to estimate the economic impact of the jobs created by the addition of a new 

nuclear generating unit at NAPS (Dominion 2008c). According to that report, Louisa County 

would realize substantial tax benefits (see Sections 4.5.3.2 and 5.5.3.2 of this SEIS). During the 

plant construction period, the VEDP estimated that the jobs created during construction of a 

new unit at the NAPS site should annually generate $4.8 million in state tax revenue and 

$3.5 million in tax revenue for the local counties (for the latter, $3.1 million in property taxes and 

$400,000 in sales and use taxes). The VEDP estimated the total tax benefit would be 

$24.9 million in total tax revenues over the projected 3-year construction period, $14.4 million in 

total state taxes to the Commonwealth of Virginia, $9.3 million in total property tax, and 

$1.2 million in total sales and use tax revenues allocated to the local counties. If the taxes paid 

during the construction period scale linearly with the construction project workforce size and 

duration, then based on Dominion’s employment estimates, total construction period taxes 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-14 February 2010 

would be roughly $51.9 to $72.6 million. These estimated taxes would be allocated as follows: 

$30 million to $42 million to the Commonwealth of Virginia, $19.3 million to $27.2 million in local 

property taxes, and from $2.5 million to $3.5 million in local sales and use taxes. 

During the plant operation period, the VEDP estimated that the additional direct and indirect 

labor increases associated with the proposed Unit 3 should generate $14.8 million in state tax 

revenue and $27.7 million in tax revenue for the local counties each year. (Tax revenue for the 

local counties consisted of $24.2 million in property taxes and $3.5 million in sales and use 

taxes annually). In nominal terms, not taking into account inflation or discount rates, the 

additional direct and indirect jobs associated with operations at the proposed Unit 3 should 

result in $592 million in total state taxes to the Commonwealth of Virginia, $968 million in total 

property tax, and $140 million in total sales and use tax revenues to the local counties. All of 

the operations-related values would be 33 percent lower if they scaled with Dominion’s estimate 

of the operations-period employment; however, for at least property taxes, the cost of the plant 

as constructed is not likely to scale downward with operation employment because the taxable 

value of the proposed Unit 3 will be determined by its cost to construct. 

In 2006, Dominion spent about $58.6 million annually in operations and maintenance materials, 

supplies, and technical services from the three counties surrounding the plant, Louisa, Orange, 

and Spotsylvania Counties; and about $80 million more in Virginia outside this three-county 

area. Nationally, Dominion purchased products and services (including labor) outside Virginia 

totaling another $68 million in 2006 (NEI 2008). Assuming the proposed Unit 3 would induce a 

50-percent increase in all operations and maintenance spending, over the 40-year life of the 

operating license, the three-county area could expect an increase in local commerce of about 

$1.2 billion, Virginia could experience an increase of $3.2 billion, and the rest of the nation could 

experience an increase in purchases of another $2.7 billion (in nominal dollars). 

Regional Productivity and Community Impacts 

Construction of NAPS Unit 3 would require a workforce of about 2500 to 3500 people and would 

generate additional income for the Commonwealth of Virginia and local economies for a period 

of up to 5 years (Section 4.5.3 of this SEIS). The subsequent operation of Unit 3 would require 

an operational workforce of about 500 people (Section 5.5.3 of this SEIS) and would generate 

additional income and value for the Commonwealth of Virginia and local economies for a period 

of at least 40 years. 

Based on the VEDP estimates of a construction workforce of 2000 workers and a construction 

period of about 3 years (Dominion 2008c), the construction and operation of the proposed Unit 3 

would increase economic output in the Commonwealth of Virginia’s by $42.5 million annually. 

Given Dominion’s somewhat higher estimate of the number of workers needed and construction 

time period, the positive impact of construction would be 25 to 75 percent higher, and would 

extend up to about 40 percent longer than estimated by the VEDP. If the direct value of the 
Conclusions and Recommendations 

February 2010 10-15 NUREG-1917, SEIS 

proposed Unit 3 output is included, State and County output attributable to the operation of 

Unit 3 would be significantly higher. The VEDP estimates that besides the 2000 direct 

construction jobs on Unit 3, 1236 additional indirect jobs would be created as a result of the 

construction activities at NAPS (Dominion 2008c). Temporary construction workers and their 

families would increase rental and property demand, spending on goods and services, and 

sales taxes collected. 

In addition, the VEDP estimates that the operation of the proposed Unit 3 would create 

750 direct jobs for Louisa County plus 1553 additional indirect jobs over a 40-year time period 

(Dominion 2008d). Dominion’s estimate for the proposed Unit 3 direct employment is about 

500 workers, so the indirect employment would be about 50 percent less than the employment 

estimated by the VEDP. The VEDP estimated that the indirect jobs would be concentrated in 

Louisa, Orange, and Spotsylvania Counties. Louisa County, where Unit 3 would be located, 

would experience the greatest impact. The general growth of the economic opportunities in the 

region would be a positive economic development. 

A summary of benefits is shown in Table 10-3. 

10.6.2 Costs 

Internal costs to Dominion as well as external costs to the surrounding region and environment 

would be incurred during the construction and operation of the proposed Unit 3. Internal costs 

include the costs to physically construct the power plant (capital costs), as well as operating and 

maintenance costs, fuel costs, waste disposal costs, and decommissioning costs. External 

costs include all costs imposed on the environment and region surrounding the plant and may 

include such things as a loss of regional productivity, environmental degradation, or loss of 

wildlife habitat. 

10.6.2.1 Internal Costs 

The most substantial monetary cost associated with nuclear energy is the cost of capital. 

Nuclear power plants typically have relatively high capital costs for building the plant, but very 

low fuel costs relative to alternative power generation systems. Because of the large capital 

costs for nuclear power plants, and the relatively long construction period before revenue is 

returned, servicing the capital costs of a nuclear power plant is the most important factor 

determining the economic competitiveness of nuclear energy. Construction delays can add 

significantly to the cost of a plant, but in Virginia, the cost for servicing debt is mitigated 

somewhat by the fact that by law any utility that constructs a nuclear plant can recover costs for 

the partially completed plant during construction (projected construction work in progress and 

associated allowance for funds used during construction) through a rate adjustment clause, 

thereby shifting the risk to consumers (Code of Virginia § 56-585.1.A.6). 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-16 February 2010 

Construction Costs 

In evaluating monetary costs related to constructing Unit 3, Dominion reviewed recently 

published literature, vendor information, internally generated financial information, and internally 

generated, site-specific information. An ESBWR construction cost estimate is provided in 

Table 10-4. This estimate is based on a number of studies that have been conducted by 

government agencies, universities, and other entities, and includes a significant contingency to 

account for uncertainty. In its COL ER (Dominion 2009), Dominion expressed the construction 

cost estimate in terms of “overnight capital cost,” which is a commonly used approach in the 

construction industry. The following costs are included in the overnight capital costs: 

• the engineering, procurement, and construction costs for the ESBWR proposed for the 

NAPS site 

• the owner’s costs, including site work and preparation, cooling water intake structures and 

cooling towers, import duties on components, insurance, spare parts, transmission 

interconnection, development costs, project management costs, owner’s engineering, state 

and local permitting, legal fees, and staffing-related training 

• contingency costs 

Interest and cost escalation during the construction period is excluded from the overnight capital 

cost. 

Dominion began with the Massachusetts Institute of Technology (MIT) 2003 study entitled The 

Future of Nuclear Power (MIT 2003), which gave $2000/kW(e) (in 2002 dollars) as a base-case 

estimate for the overnight capital cost of new nuclear units. Construction costs of $1800 to 

$2000 per kW(e) reported for two completed Advanced Boiling Water Reactors (ABWRs) at the 

Kashiwazaki-Kariwa Nuclear (KKN) Power Station in Japan were the basis for the MIT estimate. 

The DOE’s Energy Information Agency (EIA) examined nuclear power plant costs published as 

part of Annual Energy Outlook 2004 (DOE/EIA 2004). The EIA based its estimate on two 

Generation III light-water reactors in operation and another four reactors under construction in 

Asia. It started with the $2083 per kW(e) realized cost (inclusive of all contingencies) for the two 

completed reactors, and then projected that the realized cost, inclusive of contingencies, for the 

sixth unit, when completed, would be $1928 per kW(e). Dominion also examined an analysis 

jointly published by Organization for Economic Cooperation and Development (OECD) and the 

International Energy Agency (IEA), which provided an update on Projected Costs of Generating 

Electricity, 2005 Update (OECD/IEA 2005). The OECD/IEA reported that out of a reference set 

of 13 plants, the overnight construction costs for 11 of the plants generally ranged between 

$1000 to $2000 per kW(e). The overnight costs of the other two plants were slightly higher, with 

one plant at $2100 per kW(e) and another at $2500 per kW(e). 
Conclusions and Recommendations 

February 2010 10-17 NUREG-1917, SEIS 

Table 10-4. Internal and External Costs of Proposed Unit 3 (Adapted from Dominion COL 

ER) (Dominion 2009) 

Category of Cost Description of Cost 

Internal Costs(a) 

Construction (overnight cost) $4.5 billion to $6.0 billion ($3000 to $4000 per installed kW(e)) 

Operation $82 million per year ($6.83 per MWh for operations and 

maintenance, based on 12 million MWh), $55.7 million per year 

($4.64 per MWh) for fuel 

Decommissioning (NRC minimum) $518 million (approximately $1-$2 per MWh) 

External Costs 

Land and land use SMALL. Unit 3 occupies approximately 52 ha (128 ac) of the 

approximately 422 ha (1043 ac) existing NAPS site. 

Hydrological and water use SMALL for most years; MODERATE during drought years. There are 

some costs associated with providing water for various needs during 

construction and operation. Cooling water is taken from Lake Anna. 

Relatively small levels of hazardous and/or radioactive effluents 

introduced into Lake Anna. Thermal plume resulting from cooling 

water blowdown discharged to Lake Anna. The effect of 

consumption of cooling water is relatively small. 

Terrestrial and aquatic species SMALL. Some cost to wildlife due to mortality during construction 

operations is anticipated. However, these costs do not affect longterm wildlife populations. Wildlife mortality, including aquatic biota, 

during operations is expected to be minimal. 

Radioactive effluents and emissions SMALL. Radioactive waste is generated. The plant produces 

radioactive air emissions. Relatively small levels of radioactive 

effluents are introduced into Lake Anna. 

Hazardous and radioactive waste SMALL. Storage, treatment, and disposal of high-level radioactive 

spent nuclear fuel. Commitment of underground geological 

resources for disposal of radioactive spent fuel. 

Air emissions SMALL. Air emissions from diesel generators, auxiliary boilers and 

equipment, and vehicles that have a small impact on workers and 

local residents. Cooling tower drift that deposits some salt on the 

surrounding vicinity, but the level is unlikely to result in any 

measurable impact on plants and vegetation. Cooling tower 

atmospheric plume discharge abated with design. 

Materials, energy, and uranium SMALL. Irreversible and irretrievable commitments of materials and 

energy, including depletion of uranium. 

Socioeconomics SMALL. Construction of Unit 3 may pose additional costs to public 

and social services in the area. However, these costs are believed to 

be more than offset by increased tax revenues generated directly and 

indirectly by plant construction and operation. Impacts on recreation 

adverse and up to MODERATE in size during low-water periods. 

(a) It is not clear whether these internal costs include all the State and local taxes paid by Dominion and its 

employees. It does not include taxes paid by businesses and individuals who are not part of the direct 

construction and operations activity. The additional cost for State and local taxes, whether external or internal to 

Dominion’s cost estimate, is at most the total of tax benefits shown in Table 10-3. 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-18 February 2010 

Finally, Dominion reviewed a report published by The Keystone Center entitled Nuclear Power 

Joint Fact-Finding (Keystone Center 2007), which concluded overnight construction costs range 

between $3600 and $4200 per kW(e), based upon alternative discount rates and construction 

times. For comparison, Dominion quoted an early 2007 presentation by the Chief Financial 

Officer of FPL Group (Dewhurst 2007), who estimated a total overnight cost of $2400 to 

$3500 per kW(e) to which they added inflation and interest during the construction period for 

final construction costs (including financing cost) of between $4000 to $5500 per kW(e). 

Dominion also provided data in another 2007 presentation that suggested a capital cost in the 

$3200 to $4000 range per kW(e) (2007 dollars) in light of an escalating plant cost index 

(Dominion 2009). A capital cost of $4000 per kW(e) is consistent with the findings of the 2009 

update to the 2003 MIT report (MIT 2009). 

Based on the results from the studies described above, Dominion chose an overnight 

construction cost of approximately $3000 per kW(e) (in 2007 dollars) for a new nuclear unit as a 

reasonable estimate for the purpose of demonstrating its financial qualifications, and added a 

conservative contingency factor of 30 percent, leading to an overnight cost of $3000 to 

$4000 per kW(e). This translates into a total capital expenditure value (including allowance for 

funds used during construction) of $5600 to $8600 per installed KW(e) (Dominion 2008d). 

Operation Costs 

Operation costs are frequently expressed as levelized cost of electricity, which is the price per 

kWh of producing electricity, including the cost needed to cover operating costs and annualized 

capital costs. Overnight capital costs account for a third of the levelized cost, and interest costs 

on the overnight costs account for another 25 percent (University of Chicago 2004). Levelized 

cost estimates range from $36 to $83 per MWh (3.6 to 8.3 cents per kWh). Dominion reviewed 

and adopted the conclusions of a DOE study in which the annual operating and maintenance 

costs of a 1340 MW(e) ESBWR plant were estimated to be $74,178,482 (i.e., $6.83 per MWh in 

their COL ER (DOE 2004). A number of factors can affect the range, such as the choice of 

discount rate, construction duration, plant life span, capacity factor, tax rates, and premium for 

uncertainty. Estimates include decommissioning, but because of the effect of discounting a cost 

that would occur as much as 40 years in the future, decommissioning costs have relatively little 

effect on the levelized cost. 

Fuel Costs 

Dominion calculated nuclear fuel cost and decommissioning cost separately using information 

from a study published jointly by the OECD and the IEA (OECD/IEA 2005). In the report, 

OECD/IEA estimated the average fuel cost for a nuclear generating plant to be $4.64 per MWh 

for a 5-percent discount rate. 
Conclusions and Recommendations 

February 2010 10-19 NUREG-1917, SEIS 

Decommissioning 

The NRC requires that licensees provide reasonable assurance that funds would be available 

for the decommissioning process, see 10 CFR 50.75. Because of the effect of discounting a 

cost that would occur as much as 40 years in the future, decommissioning costs have relatively 

little effect on the levelized cost of electricity generated by a nuclear power plant. 

Decommissioning costs are about 9 to 15 percent of the initial capital cost of a nuclear power 

plant. However, when discounted, decommissioning costs contribute only a few percent to the 

investment cost and even less to the generation cost. In the United States, they account for 

0.1 to 0.2 cents per kWh, which is no more than 5 percent of the cost of the electricity produced 

(WNA 2008). Dominion’s decommissioning cost estimate is $518 million. 

10.6.2.2 External Costs 

External costs are social and/or environmental effects caused by the proposed construction of 

and operation of a new reactor at the NAPS site. This SEIS includes the NRC staff’s analysis 

that considers and weighs the environmental impacts of constructing and operating a new 

nuclear unit at the NAPS site or at alternative sites, and mitigation measures available for 

reducing or avoiding these adverse impacts. It also includes the staff’s recommendation to the 

Commission regarding the proposed action. 

Environmental and Social Costs 

Although available information does not exist to assign monetary values to the impacts of 

construction and operation of NAPS Unit 3, these impacts have been identified and analyzed in 

Chapters 4 and 5, and a significance level of potential adverse impacts (i.e., SMALL, 

MODERATE, or LARGE) has been assigned. Chapter 6 similarly addresses the environmental 

impacts from (1) the uranium fuel cycle and solid waste management, (2) the transportation of 

radioactive material, and (3) the decommissioning of nuclear units at the NAPS site. A 

summary of project internal and external costs is shown in Table 10-4. 

10.6.3 Benefit-Cost Summary 

As described in Section 8.4, there is increasing base-load demand and decreasing base-load 

supply in the region of interest. Without additional base-load generating capacity, Dominion’s 

electricity network will fail to maintain an adequate power reserve margin and meet its public 

service obligations to provide adequate power, and will jeopardize Dominion’s commitment to 

provide power to other electric service providers within the region. The proposed Unit 3 will help 

meet the increasing base-load demand in the region by supplying an average annual electricalenergy generation of about 12,000,000 MWh. 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-20 February 2010 

As described in this section, the proposed Unit 3 would have important strategic implications in 

terms of lessening the dependence of the United States on foreign energy supplies, and the 

potential interruption of these supplies, as well as vulnerability to volatile price changes or 

hostile political whims. While the additional direct and indirect creation of jobs would place 

some temporary burdens on local services and infrastructure, the additional annual taxes and 

revenue generated by the new workers would contribute to the local economy and stimulate 

future growth. 

On balance, the benefits of Unit 3 would significantly outweigh the economic, environmental, 

and social costs of the project. 

10.7 Staff Conclusions and Recommendations 

The staff’s recommendation to the Commission related to the environmental aspects of the 

proposed action is that the COL be issued. The staff’s evaluation of the safety and emergency 

preparedness aspects of the proposed action will be addressed in the staff’s Safety Evaluation 

Report. 

This recommendation is based on (1) the application, including the Environmental Report (ER), 

submitted by Virginia Electric Power Company, doing business as Dominion Virginia Power and 

the Old Dominion Electric Cooperative, collectively referred to as Dominion; (2) the staff’s 

review conducted for the ESP application and documented in the ESP EIS; (3) consultation with 

Federal, State, Tribal, and local agencies; (4) the staff’s own independent review of potential 

new and significant information available since preparation and publication of the ESP EIS; 

(5) the staff’s consideration of comments related to the environmental review that were received 

during the review process; and (6) the assessments summarized in this SEIS, including the 

potential mitigation measures identified in the Dominion ER and in the SEIS. 

10.8 References 

10 CFR Part 50. Code of Federal Regulations, Title 10 Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

Certifications, and Approvals for Nuclear Power Plants.” 

40 CFR Part 1500. Code of Federal Regulations, Title 40, Protection of Environment, 

Part 1508, “CEQ – Regulations for Implementing NEPA.” 
Conclusions and Recommendations 

February 2010 10-21 NUREG-1917, SEIS 

73 FR 13589. “Dominion Nuclear Power, LLC; North Anna Power Station Combined License 

Application; Notice of Intent to Prepare an Environmental; Impact Statement and Conduct 

Scoping Process.” Vol. 73, No. 50. March 13, 2008. 

73 FR 41132. “Virginia Electric And Power Company, D/B/A Dominion Virginia Power, and Old 

Dominion Electric Cooperative North Anna Nuclear Station Unit 3 Combined License 

Application; Correction and Supplement to Notice of Intent to Prepare an Environmental Impact 

Statement and Conduct Scoping Process.” Vol. 73, No. 138. July 17, 2008. 

74 FR 106. “Environmental Impacts Statements: Notice of Availability, EIS No. 20080536 North 

Anna Power Station Unit 3 Combined License (COL) for Construction of a Base-Load Nuclear 

Power Plant.” Vol. 74, No. 1. January 2, 2009. 

74 FR 4476. “Virginia Electric and Power Company, D/B/A Dominion Virginia Power, and Old 

Dominion Electric Cooperative; Correction to Notice of Availability of the Draft Supplemental 

Environmental Impact Statement and Public Meeting for North Anna Power Station Unit 3 

Combined License Application.” Vol. 74, No. 15. January 26, 2009. 

Dewhurst, M. 2007. “Financial Perspectives on Nuclear Power in a Consolidating Electric 

Power Industry.” Presented February 8, 2007, at Platt’s Third Annual Nuclear Energy 

Conference: Opportunities for Growth and Investment in North America, Washington, D.C. 

Dominion Nuclear North Anna, LLC. 2006. North Anna Early Site Permit Application. 

Revision 9, Glen Allen, Virginia. Accession No. ML062580096. 

Dominion Virginia Power (Dominion). 2008a. North Anna 3 Combined License Application. 

Revision 1, December 2008. Accession No. ML090570781. 

Dominion Virginia Power (Dominion). 2008b. E-mail from Tony Banks (Dominion Virginia 

Power) to Alicia Williamson and Laura Quinn (U.S. Nuclear Regulatory Commission) and 

William F. Sandusky (Pacific Northwest National Laboratory). “NAPS Unit 3 COL Application – 

NRC’s Environmental Review Supplemental Information Request (Louisa County Real Estate 

Taxes for NAPS).” October 2, 2008. Accession No. ML082800274. 

Dominion Virginia Power (Dominion). 2008c. E-mail from Tony Banks (Dominion Virginia 

Power) to Alicia Williamson and Laura Quinn (U.S. Nuclear Regulatory Commission) and 

William F. Sandusky (Pacific Northwest National Laboratory). “Attached Image.” 

September 25, 2008. Accession No. ML08296084.
Conclusions and Recommendations 

NUREG-1917, SEIS 10-22 February 2010 

Dominion Virginia Power (Dominion). 2008d. Letter from Eugene S. Grecheck (Dominion 

Virginia Power, Vice President) to the U.S. Nuclear Regulatory Commission, “Dominion Virginia 

Power, North Anna Unit 3 Combined License Application, Response to Request for Additional 

Information Regarding the Environmental Review.” July 17, 2008. Accession 

No. ML082620236. 

Dominion Virginia Power (Dominion). 2009. North Anna 3 Combined License Application, 

Part 3: Applicants’ Environmental Report – Combined License Stage. Revision 2, July 2009. 

Accession No. ML092160490. 

Executive Order 11514. 1970. “Protection and Enhancement of Environmental Quality.” 

3 CFR, 1966-1970, Comp., p. 902, as amended. 

Executive Order 11991. 1977. Amends Executive Order 11514. Office of the President, 

Washington, D.C. 

Keystone Center. 2007. “Nuclear Power Joint Fact-Finding.” Keystone Center, Keystone, 

Colorado. June 2007. Accessed at www.keystone.org/about-us/publications on October 20, 

2009. Accession No. ML093160833. 

Massachusetts Institute of Technology (MIT). 2003. The Future of Nuclear Power: An 

Interdisciplinary MIT Study. ISBN 0-615-12420-8. Accessed at 

http://web.mit.edu/nuclearpower/. Accession No. ML083260816. 

Massachusetts Institute of Technology (MIT). 2009. “Update of the MIT 2003 Future of Nuclear 

Power.” Massachusetts Institute of Technology Cambridge, Massachusetts. 2009. Accessed 

at web.mit.edu/nuclearpower last accessed on October 20, 2009. Accession 

No. ML093210610. 

National Environmental Policy Act of 1969, as amended (NEPA). 42 USC 4321, et seq. 

Nuclear Energy Institute. 2008. “Economic Benefits of North Anna Power Station, An 

Economic Impact Study by the Nuclear Energy Institute In Cooperation With Dominion.” 

Accession No. ML082960083. 

Organization for Economic Co-Operation and Development and International Energy Agency 

(OECD/IEA). 2005. Projected Costs of Generating Electricity, 2005 Update. International 

Energy Agency (IEA), Paris, France. 

PJM Interconnection, LLC (PJM). 2007. PJM Load/Energy Forecasting Model. White Paper. 

Accessed at http://www.pjm.com/planning/res-adequacy/downloads/forecast-modelwhitepaper.pdf. Accession No. ML083260800. 
Conclusions and Recommendations 

February 2010 10-23 NUREG-1917, SEIS 

University of Chicago. 2004. “The Economic Future of Nuclear Power.” Accessed at 

http://www.ne.doe.gov/np2010/reports/NuclIndustryStudy-Summary.pdf. Accession 

No. ML093260817. 

U.S. Department of Energy (DOE). 2004. Study of Construction Technologies and Schedules, 

O&M Staffing and Cost, Decommissioning Costs and Funding Requirements for Advanced 

Reactor Designs. Vol. 2 - MPR-2610, Prepared by Dominion Energy, Inc., Bechtel Power 

Corporation, TLG, Inc., and MPR Associates Vol. 2 - MPR-2610 and MRP-2627, DOE, 

Washington, D.C. 

U.S. Department of Energy-Energy Information Administration (DOE/EIA). 2004. Annual 

Energy Outlook, With Projections to 2025. DOE/EIA-0383(2004). Washington, D.C. Accessed 

September 17, 2008 at http://www.eia.doe.gov/oiaf/archive/aeo04/pdf/0383(2004).pdf 

Accession No. ML083260819. 

U.S. Department of Energy-Energy Information Administration (DOE/EIA). 2007. Energy 

Power Annual. Accessed at http://www.eia.doe.gov/cneaf/electricity/epa/epa_sum.html. 

Accession No. ML083269820. 

U.S. Nuclear Regulatory Commission (NRC). 1976. Preparation of Environmental Reports for 

Nuclear Power Plant Station. Regulatory Guide 4.2, Revision 2, Washington, D.C. Accession 

No. ML003739519. 

U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental 

Reviews for Nuclear Power Plants. NUREG-1555, Vol. 1, Washington, D.C. Includes 2007 

revisions. 

U.S. Nuclear Regulatory Commission (NRC). 2006. Environmental Impact Statement for an 

Early Site Permit at the North Anna ESP Site. NUREG-1811, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2007a. Early Site Permit for Dominion Nuclear 

North Anna, LLC - North Anna ESP Site (ESP-003). Accession No. ML073180440. 

U.S. Nuclear Regulatory Commission (NRC). 2007b. Standard Review Plans for Review of 

Safety Analysis Reports for Nuclear Power Plants, LWR Edition. NUREG-0800, Washington, 

D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2008. Supplemental Environmental Impact 

Statement for the Combined License (COL) for North Anna Power Station Unit 3 – Draft Report 

for Comment. NUREG-1917, Washington, D.C. 
Conclusions and Recommendations 

NUREG-1917, SEIS 10-24 February 2010 

Virginia Economic Development Partnership (VEDP). 2006. “The Estimated Impact of an 

Expansion of the North Anna Power Station on Virginia”. Summary prepared for the Virginia 

Economic Development Partnership, 11-14-2006, Richmond, Virginia. 

Accession No. ML093210604. 

Code of Virginia. Title 56, “Public Service Companies;” Chapter 23, “Virginia Electric Utility 

Regulations Act;” Part 56-585.1, “Generation, distribution, and transmission rates after capped 

rates terminate or expire.” Accessed November 12, 2008, at http://leg1.state.va.us/cgibin/legp504.exe?000+cod+56-585.1. Accession No. ML083260830. 

World Nuclear Association (WNA). 2008. The Economics of Nuclear Power. August 2008. 

Accessed at http://www.world-nuclear.org/uploadedFiles/org/info/pdf/EconomicsNP.pdf. 

Accession No. ML083260829. 
Appendix A 

Contributors to the 

Supplemental Environmental Impact Statement 

February 2010 A-1 NUREG-1917, SEIS 

Appendix A 

Contributors to the 

Supplemental Environmental Impact Statement 

The overall responsibility for the preparation of this environmental impact statement was 

assigned to the Office of New Reactors, U.S. Nuclear Regulatory Commission (NRC). The 

statement was prepared by members of the Offices of New Reactors with assistance from other 

NRC organizations and Pacific Northwest National Laboratory. 

Name Affiliation Function or Expertise

NUCLEAR REGULATORY COMMISSION

Alicia Williamson Office of New Reactors Project Manager 

Laura Quinn Office of New Reactors Assistant Project Manager 

Tamsen Dozier 

Gregory Hatchett 

Office of New Reactors 

Office of New Reactors 

Assistant Project Manager 

Branch Chief 

Richard Raione Office of New Reactors Branch Chief 

Andrew Kugler Office of New Reactors Alternative Energy Sources and Systems 

Jay Lee Office of New Reactors Accidents 

Richard Emch Office of New Reactors Health Physics, Cultural Resources 

Norma Garcia-Santos Office of Nuclear Material Safety 

and Safeguards 

Transportation of Radioactive Materials 

Lucieann Vechioli Office of Nuclear Material Safety 

and Safeguards 

Transportation of Radioactive Materials 

John Cook Office of Nuclear Material Safety 

and Safeguards 

Transportation of Radioactive Materials 

Christopher Cook Office of New Reactors Water Use, Hydrology 

Mark McBride Office of New Reactors Water Use, Hydrology 

Kenneth See 

Daniel Mussatti 

Office of New Reactors 

Office of New Reactors 

Water Use, Hydrology 

Socioeconomics, Environmental Justice, Cost Benefit 

Michael Masnik Office of New Reactors Ecology 

Stan Echols Office of Nuclear Material Safety 

and Safeguards

Fuel Cycle 

R. Brad Harvey Office of New Reactors Meteorology, Air Quality 

Irene Yu Office of New Reactors Land Use, Alternative Energy, Need For Power 

Allen Fetter/James 

Shepherd 

Office of Federal and State 

Materials and Environmental 

Management Programs 

Decommissioning 

Rafael Rodriguez Office of Nuclear Material Safety 

and Safeguards 

Project Management Support, Meteorology 

Adrienne Redden Office of New Reactors Licensing Assistant and Administrative Support 

Michelle Moser Office of New Reactors Project Support 
Appendix A 

NUREG-1917, SEIS A-2 February 2010

Name Affiliation Function or Expertise

Jean-Claude Dehmel 

Charles Hinson 

Sara Kirkwood 

Office of New Reactors 

Office of New Reactors 

Office if General Counsel 

Radiation Protection 

Radiation Protection 

Attorney 

Renee Holmes Office of General Counsel Attorney 

Robert Weisman Office of General Counsel Attorney 

Anthony Wilson Office of General Counsel Attorney 

Marcia Carpentier Office of General Counsel Attorney 

Ed Fuller Office of New Reactors Severe Accidents 

PACIFIC NORTHWEST NATIONAL LABORATORY(a)

William Sandusky Task Leader 

Adam J. Davis Deputy Task Leader 

Amanda Stegen Deputy Task Leader 

Terri Miley 

Michael Sackschewsky 

Team Lead Support 

Terrestrial Ecology 

Amoret Bunn Thermophilic Organisms 

Carl Berkowitz Meteorology, Air Quality, EMF 

Michael Smith Design Basis and Severe Accidents 

Van Ramsdell Air Quality, Design Basis and Severe Accidents 

Michael Scott Socioeconomics, Environmental Justice, Cost 

Benefit, Need for Power 

Donna Hostick Socioeconomics, Environmental Justice, Cost Benefit 

Jeffery Ward Aquatic Ecology 

Nancy Kohn Aquatic Ecology 

Paul Hendrickson Land Use, Alternative Energy 

Greg Stoetzel Health Physics, Fuel Cycle, Decommissioning, 

Non-Radiological Health 

Phil Daling Transportation 

Steve Ross Transportation 

Doug McFarland Cultural Resources 

Darby Stapp Cultural Resources 

Ellen Kennedy 

Lance Vail 

 Cultural Resources 

Surface Water Use, Hydrology, Alternative Systems 

Philip Meyer Ground Water Use, Hydrology 

Cary Counts Technical Editor 

Beverly Miller 

Sandi McInturff 

Lila Andor 

 Document Production 

Document Production 

Document Production 

Kathy Neiderhiser Document Production 

Mike Parker Document Production 

(a) Pacific Northwest National Laboratory is operated for the U.S. Department of Energy by Battelle Memorial 

Institute. 
Appendix B 

Organizations Contacted 

February 2010 B-1 NUREG-1917, SEIS 

Appendix B 

Organizations Contacted 

During the course of the staff’s independent review of potential environmental impacts from 

constructing and operating the proposed Unit 3 at the North Anna Power Station site, various 

Federal, State, regional, Tribal, and local agencies and organizations were contacted. 

Additional and more extensive contacts were made as part of the early site permit (ESP) 

application process. An entire listing of those contacts is available in Appendix B of the ESP 

environmental impact statement document. A listing of those agencies contacted as part of the 

proposed Unit 3 combined license application is provided below: 

Lake Anna State Park, Spotsylvania, Virginia 

Virginia Department of Conservation and Recreation, Richmond, Virginia 

Virginia Department of Historic Resources, Richmond, Virginia 

Chickahominy Indian Tribe, Providence Forge, Virginia 

Chickahominy Indians – Eastern Division, Providence Forge, Virginia 

Mattaponi Indian Tribe, West Point, Virginia 

Monacan Indian Nation, Madison Heights, Virginia 

Nansemond Indian Tribe, Suffolk, Virginia 

Pamunkey Indian Tribe, King William, Virginia 

Rappahannock Tribe, Indian Neck, Virginia 

Upper Mattaponi Indian Tribe, Mechanicsville, Virginia 

Eastern Shawnee Tribe of Oklahoma, Seneca, Missouri 

Virginia Council on Indians, Richmond, Virginia 

Advisory Council on Historic Preservation, Washington, D.C. 
Appendix B 

NUREG-1917, SEIS B-2 February 2010 

Tuscarora Nation, Lewiston, New York 

Tuscarora Indian Tribe, Sanborn, New York 

Shawnee Tribe, Miami, Oklahoma 

Eastern Band of Cherokee Indians, Cherokee, North Carolina 

Catawba Indian Nation, Rock Hill, South Carolina 

Virginia Department of Health, Richmond, Virginia 

Virginia Commonwealth University (Dr. Francine Marciano-Cabral), Richmond, Virginia 

U.S. Fish and Wildlife Service Virginia Field Office, Gloucester, Virginia 

United Keetoowah Band of Cherokee Indians in Oklahoma, Tahlequa, Oklahoma 

U.S. Army Corps of Engineers, Potomac Virginia Field Office, Leonardtown, Maryland 

Virginia Department of Environmental Quality, Richmond, Virginia 

Virginia Department of Game and Inland Fisheries, Richmond, Virginia 

Marine Resources Commission, Newport News, Virginia 

U.S. Fish and Wildlife Service, Chesapeake Bay Field Office, Annapolis, Maryland 

Lake Anna Boating and Recreation Association, Louisa, Virginia 
Appendix C 

Chronology of NRC Staff Environmental Review 

Correspondence Related to the Dominion Virginia 

Power and Old Dominion Electric Cooperative’s 

Application for a Combined License for Unit 3 at the 

North Anna Power Station Site 

February 2010 C-1 NUREG-1917, SEIS 

Appendix C

Chronology of NRC Staff Environmental Review 

Correspondence Related to Dominion Virginia Power 

and Old Dominion Electric Cooperative’s Application 

for a Combined License for Unit 3 at the 

North Anna Power Station Site 

This appendix contains a chronological listing of correspondence between the U.S. Nuclear 

Regulatory Commission (NRC) and Dominion Virginia Power (Dominion) and other 

correspondence related to the NRC staff’s environmental review, under 10 CFR Part 52, 

of Dominion’s application for the construction and operation of one economic simplified boiling 

water reactor (ESBWR) at the North Anna Power Station (North Anna Unit 3). All documents, 

with the exception of those containing proprietary or sensitive information, have been placed 

in the Commission’s Public Document Room, at One White Flint North, 11555 Rockville Pike 

(first floor), Rockville, Maryland. Such documents are also available electronically from 

the Public Electronic Reading Room found on the Internet at the following Web address: 

<http://www.nrc.gov/reading-rm.html>. From this site, the public can gain access to the NRC’s 

Agencywide Documents Access and Management System (ADAMS), which provides text and 

image files of NRC’s public documents in the publicly available records component of ADAMS. 

The ADAMS accession number for each document is included below: 

October 11, 2007 Letter from Mr. Tony Banks, Dominion, to Dr. Ethel Eaton, Virginia 

Department of Historic Resources, regarding the Supplemental 

Archeological Survey for the Combined License Application at North Anna 

(Accession No. ML082910714) 

November 7, 2007 Letter from Mr. Roger Kirchen, Virginia Department of Historic Resources 

to Mr. Tony Banks, Dominion regarding the Supplemental Archaeological 

Survey (Accession No. ML082910712). 

November 26, 2007 Letter from Mr. David A. Christian, Dominion Virginia Power, to NRC 

submitting the application for the construction and operation for an 

ESBWR at the North Anna Power Station (Accession No. ML073320913). 
Appendix C 

NUREG-1917, SEIS C-2 February 2010 

November 27, 2007 Letter from NRC to David A. Christian, Dominion Virginia Power regarding 

the issuance of the Early Site Permit for the North Anna ESP site (ESP003) (Accession No. ML073180427). 

November 27, 2007 North Anna Early Site Permit (ESP-003) (Accession No. ML073180440). 

December 4, 2007 Notice of Issuance of Early Site Permit for Dominion Nuclear North Anna, 

LLC Located 40 Miles North-Northwest of the City of Richmond, Virginia 

(72 FR 68202). 

December 6, 2007 Letter from NRC to Mr. Eugene S. Grecheck, Dominion Virginia Power, 

acknowledging the receipt and accessibility of the combined license 

application for North Anna Unit 3 (Accession No. ML073390655). 

December 12, 2007 Federal Register Notice of the receipt and accessibility of the combined 

license application for North Anna Power Station, Unit 3 (72 FR 70619). 

January 17, 2008 Letter from Mr. Eugene S. Grecheck, Dominion Virginia Power, to NRC 

supplementing the North Anna Unit 3 combined license application, with 

the early site permit COL Action Item 13.6-1 (Accession 

No. ML080230503). 

January 28, 2008 Letter from NRC to Mr. Eugene S. Grecheck, Dominion Virginia Power, 

acknowledging the acceptance for docketing of the Dominion combined 

license application for North Anna Power Station, Unit 3 (Accession 

No. ML080240154). 

February 4, 2008 Federal Register Notice of the acceptance for docketing the combined 

license application for North Anna Power Station, Unit 3 (73 FR 6528). 

February 29, 2008 Federal Register Notice Regarding Opportunity to Petition to leave to 

Intervene for the North Anna, Unit 3, combine license application 

(Accession No. ML080390307). 

March 7, 2008 Letter from NRC to Mr. Eugene S Grecheck, Dominion Virginia Power 

regarding the Notice of Intent to prepare an environmental impact 

statement and conduct scoping related to the combined license 

application for the North Anna Power Station (Accession 

No. ML080580288). 

March 10, 2008 Federal Register Notice of hearing and opportunity to petition for leave to 

intervene on a combined license application for North Anna Power 

Station, Unit 3 (73 FR 12760). 
Appendix C 

February 2010 C-3 NUREG-1917, SEIS 

March 13, 2008 Federal Register Notice of intent to prepare an environmental impact 

statement and conduct a scoping process for a combined license 

application for North Anna Power Station, Unit 3 (73 FR 13589). 

April 2, 2008 Meeting Notice of Public Meeting to discuss the environmental scoping 

process for the North Anna Power Station, Unit 3 combined license 

application (Accession No. ML081290490). 

April 4, 2008 Letter from NRC to Robert W. Duncan, Virginia Department of Game and 

Inland Fisheries, requesting information, comments, or concerns 

considered appropriate under the provisions of the Fish and Wildlife 

Coordination Act (FWCA) of 1934, as amended (Accession 

No. ML080780357). 

April 4, 2008 Letter from NRC to Deanna Beacham, Virginia Council on Indians, 

regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML080720297). 

April 4, 2008 Letter from NRC to Chief Gene “PathFollower” Adkins, Eastern 

Chickahominy Tribe, regarding the North Anna Power Station Unit 3 

combined license application review and request for comments under the 

scoping process (Accession No. ML080730087). 

April 4, 2008 Letter from NRC to Mr. Don Klima, Advisory Council on Historic 

Preservation, regarding the North Anna Power Station Unit 3 combined 

license application review and request for comments under the scoping 

process (Accession No. ML080701146). 

April 4, 2008 Letter from NRC to Mr. Roger Kirchen, Virginia Department of Historic 

Resources, regarding the North Anna Power Station Unit 3 combined 

license application review and request for comments under the scoping 

process (Accession No. ML080710129). 

April 4, 2008 Letter from NRC to The Honorable Leo Henry, Chief, Tuscarora Nation, 

regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML080920298). 

April 4, 2008 Letter from NRC to Chief Kenneth Adams, Upper Mattaponi Tribe, 

regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML080730099). 
Appendix C 

NUREG-1917, SEIS C-4 February 2010 

April 4, 2008 Letter from NRC to The Honorable Arnold Hewitt, Chief, Tuscarora 

Nation, regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML080920275). 

April 4, 2008 Letter from NRC to Dan Murphy, Deputy Field Supervisor (Acting), 

U.S. Fish and Wildlife Service regarding the North Anna Power Station 

Unit 3 combined license application review, list of protected species, and 

request for comments under scoping (Accession No. ML080710278). 

April 8, 2008 Letter from NRC to Chief Barry W. Bass, Nansemond Tribe, regarding the 

North Anna Power Station Unit 3 combined license application review and 

request for comments under the scoping process (Accession 

No. ML080730151). 

April 8, 2008 Letter from NRC to Chief William P. Miles, Pamunkey Tribal Government, 

regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML080730135). 

April 8, 2008 Letter from NRC to Chief Stephen R. Adkins, Chickahominy Tribe, 

regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML080730095). 

April 8, 2008 Letter from NRC to Chief Kenneth Branham, Monacan Indian Nation, Inc., 

regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML080730159). 

April 8, 2008 Letter from NRC to Chief G. Anne Richardson, Rappahannock Tribe, 

regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML080730114). 

April 8, 2008 Letter from NRC to Assistant Chief Carl “Lone Eagle” Custalow Mattaponi 

Tribe, regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML080720568). 

April 8, 2008 Letter from NRC to Mr. Neil Patterson, Jr., Tuscarora Nation, regarding 

the North Anna Power Station Unit 3 combined license application review 

and request for comments under the scoping process (Accession 

No. ML080920265). 
Appendix C 

February 2010 C-5 NUREG-1917, SEIS 

April 9, 2008 Letter from NRC to Mr. Eugene S. Grecheck, Dominion Virginia Power, 

regarding the supplement to the Federal Register Notice of hearing and 

opportunity to petition for the North Anna Power Station, Unit 3 

(Accession No. ML081000188). 

April 12, 2008 Summary of public scoping meeting conducted related to the review of 

the North Anna Power Station, Unit 3 combined license application 

(Accession No. ML081220522). 

April 18, 2008 Federal Register Supplement to Notice of Hearing and Opportunity to 

Petition for Leave to Intervene on a Combined License for North Anna 

Unit 3: Procedures for Access to Sensitive Unclassified Non-Safeguards 

Information and Safeguards Information for Contention Preparation 

(73 FR 21162). 

May 1, 2008 Letter from Mr. Roger Kirchen, Virginia Department of Historic Resources, 

to NRC regarding scoping comments from Virginia Department of Historic 

Resources for the North Anna Unit 3 combined license application 

(Accession No. ML081290490). 

May 9, 2008 Email from Amy Ewing, Virginia Department of Game and Inland 

Fisheries regarding scoping comments on the North Anna, Unit 3 

combined license application (Accession No. ML081630141). 

May 25, 2008 Correction to the Federal Register Notice of Hearing and Opportunity to 

Petition for Leave to Intervene on a Combined License for North Anna 

Unit 3 (Accession No. ML081440317). 

June 2, 2008 Federal Register Notice to correct the Notice of Hearing and Opportunity 

to Petition for Leave to Intervene on a combined license application 

for North Anna Unit 3, which incorrectly identifies the applicants 

(73 FR 31516). 

June 16, 2008 Memo regarding the summary of telecommunications with Dominion 

Virginia Power to discuss items associated with the environmental site 

audit for the combined License for the North Anna Power Station Unit 3 

(Accession No. ML081630061). 

June 18, 2008 Letter from NRC to Mr. Eugene S. Grecheck, Dominion Virginia Power, 

requesting additional information regarding the environmental review of 

the combined license application for North Anna Power Station, Unit 3 

(Accession No. ML081630583). 
Appendix C 

NUREG-1917, SEIS C-6 February 2010 

July 14, 2008 Correction and supplement Federal Register Notice for Notice of Intent to 

prepare an environmental impact statement and conduct scoping process 

(Accession No. ML081920719). 

July 17, 2008 Federal Register Notice of Correction and supplement to the Notice of 

Intent to prepare an environmental impact statement and conduct scoping 

process (73 FR 41132). 

July 17, 2008 Letter from Mr. Eugene S. Grecheck, Dominion Virginia Power to NRC 

regarding Dominion responses to the environmental RAIs for the North 

Anna Power Station, Unit 3 combined license application (Accession 

No. ML082620236). 

July 22, 2008 Emails from Tony Banks, Dominion Virginia Power to NRC, regarding the 

environmental report supplemental information needs responses 

(Accession No. ML081960674). 

July 25, 2008 Letter from NRC to Ms. Glenna J. Wallace, Chief, Eastern Shawnee Tribe 

of Oklahoma, regarding the North Anna Power Station Unit 3 combined 

license application review and request for comments under the scoping 

process (Accession No. ML081890454). 

July 25, 2008 Letter from NRC to Mr. Ron Sparkman, Chairman, Shawnee Tribe, 

regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML081890449). 

July 25, 2008 Letter from NRC to Mr. George Wickliffe, Chief, United Keetoowah Band 

of Cherokee Indians in Oklahoma, regarding the North Anna Power 

Station Unit 3 combined license application review and request for 

comments under the scoping process (Accession No. ML081890444). 

July 25, 2008 Letter from NRC to Mr. James Bird, THPO, Eastern Band of Cherokee 

Indians, regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML081890433). 

July 25, 2008 Letter from NRC to Dr. Wenoah G. Haire, Jr., THPO, Catawba Indian 

Nation, regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML081890451). 
Appendix C 

February 2010 C-7 NUREG-1917, SEIS 

July 25, 2008 Letter from NRC to Ms. Karen Mayne, U.S. Fish and Wildlife Service, 

regarding the North Anna Power Station Unit 3 combined license 

application review and request for comments under the scoping process 

(Accession No. ML081900047). 

August 14, 2008 Email from Ellie Irons, Virginia Department of Environmental Quality, to 

NRC regarding consultation and scoping comments for the North Anna 

Power Station Unit 3 combined license application review (Accession 

No. ML082321103). 

September 4, 2008 Memorandum to Richard Raione, NRC, regarding the scoping summary 

report related to the environmental scoping process for the North Anna 

Power Station, Unit 3 combined license application (Accession 

No. ML082310340). 

September 4, 2008 Scoping summary report related to the environmental scoping process for 

the North Anna Power Station, Unit 3 combined license application 

(Accession No. ML082480357). 

September 19, 2008 Letter from Eugene S. Grecheck, Dominion Virginia Power to NRC, 

regarding the environmental report supplemental information (Accession 

No. ML082680222). 

September 25, 2008 Email from Tony Banks Dominion Virginia Power to Alicia Williamson, 

NRC regarding VEDP Study with attached image (Accession 

No. ML 082960804). 

October 2, 2008 Email from Tony Banks Dominion Virginia Power to Alicia Williamson, 

NRC regarding the NAPS Unit 3 COL Application - NRC’S Environmental 

Review Supplemental Information Request on Louisa County Real Estate 

Taxes for NAPS (Accession No. ML082800274). 

November 4, 2008 Letter from Mr. Eugene Grecheck, Dominion, to Ms. Kathleen Kilpatrick, 

Virginia Department of Historic Resources regarding the Dominion 

Combined License Project North Anna Power Station Project Updates 

and Archeological Survey 2008 (Accession No. ML083220171). 

November 26, 2008 Memorandum from Ms. Alicia Williamson, NRC to Mr. Gregory Hatchett, 

NRC, regarding the Summary of the Environmental Site Audit Related to 

the Review of the Combined License Application for North Anna Power 

Station, Unit 3 (Accession No. ML082970800). 

December 16, 2008 NUREG-1917, Supplemental Environmental Impact Statement for the 

Combined License (COL) for North Anna Power Station Unit 3, Draft for 

Comment (Accession No. ML083380360). 
Appendix C 

NUREG-1917, SEIS C-8 February 2010 

December 16, 2008 Letter from NRC to Mr. Eugene Grecheck, Dominion Virginia Power, 

regarding the Notice of Availability of the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

Combined License (Accession No. ML083240722). 

December 16, 2008 Letter from NRC to U.S. Environmental Protection Agency, Office of 

Federal Activities, NEPA Compliance Division, EIS Filing Section, 

regarding the Draft Supplemental Environmental Impact Statement for the 

North Anna Power Station Unit 3 Combined License (Accession 

No. ML083240753). 

December 24, 2008 Federal Register Notice of availability of the Draft Supplemental 

Environmental Impact Statement and public meeting for the North Anna 

Power Station Unit 3 (79 FR 79197). 

January 2, 2009 U.S. Environmental Protection Agency Federal Register Notice of 

availability of the North Anna Power Station Unit 3 Draft Supplemental 

Environmental Impact Statement (74 FR 106). 

January 15, 2009 Federal Register Notice correcting the comment period to the notice of 

availability of the Draft Supplemental Environmental Impact Statement 

and public meeting for North Anna Power Station Unit 3 combined license 

(Accession No. ML090120457). 

January 15, 2009 Notice of Public Meeting to Discuss the Draft Supplemental 

Environmental Impact Statement for the North Anna Power Station Unit 3 

Combined License Application (Accession No. ML090140652). 

January 23, 2009 U.S. Environmental Protection Agency Federal Register Notice amending 

the comment period for the North Anna Power Station Unit 3 Draft 

Supplemental Environmental Impact Statement (74 FR 4195). 

January 27, 2009 Letter from NRC to Ms. Karen Mayne, U.S. Fish and Wildlife Service, 

Virginia Field Office requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090130266). 

January 27, 2009 Letter from NRC to Mr. Don Klima, Advisory Council on Historic 

Preservation, requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090130279). 
Appendix C 

February 2010 C-9 NUREG-1917, SEIS 

January 27, 2009 Letter from NRC to Dr. Wenoah G. Haire, Jr, THPO, Catawba Indian 

Nation, notifying issuance and requesting comments on the Draft 

Supplemental Environmental Impact Statement for North Anna Power 

Station Unit 3 combined license (Accession No. ML090130337). 

January 27, 2009 Letter from NRC to Chief Stephen R. Adkins, Chickahominy Tribe, 

notifying issuance and requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090130362). 

January 27, 2009 Letter from NRC to, Mr. James Bird, THPO, Eastern Band of Cherokee 

Indians, notifying issuance and requesting comments on the Draft 

Supplemental Environmental Impact Statement for North Anna Power 

Station Unit 3 combined license (Accession No. ML090130373). 

January 27, 2009 Letter from NRC to Chief Gene “PathFollower” Adkins, Eastern 

Chickahominy Tribe, notifying issuance and requesting comments on the 

Draft Supplemental Environmental Impact Statement for North Anna 

Power Station Unit 3 combined license (Accession No. ML091030388). 

January 27, 2009 Letter from NRC to Chief Glenna J. Wallace, Eastern Shawnee Tribe of 

Oklahoma, notifying issuance and requesting comments on the Draft 

Supplemental Environmental Impact Statement for North Anna Power 

Station Unit 3 combined license (Accession No. ML090130393). 

January 27, 2009 Letter from NRC to Chief Carl “Lone Eagle” Custalow, Mattaponi Tribe, 

notifying issuance and requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090130413). 

January 27, 2009 Letter from NRC to The Honorable Kenneth Branham, Tribal Chief and 

Chairman, notifying issuance and requesting comments on the Draft 

Supplemental Environmental Impact Statement for North Anna Power 

Station Unit 3 combined license (Accession No. ML090130421). 

January 27, 2009 Letter from NRC to Chief Barry Bass, Nansemond Tribe, notifying 

issuance and requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090130428). 

January 27, 2009 Letter from NRC to Chief William P. Miles, Pamunkey Tribal Government, 

notifying issuance and requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090130435). 
Appendix C 

NUREG-1917, SEIS C-10 February 2010 

January 27, 2009 Letter from NRC to Chief G. Anne Richardson, RappahannockTribe, 

notifying issuance and requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090130456). 

January 27, 2009 Letter from NRC to Mr. Ron Sparkman, Chairman, Shawnee Tribe, 

notifying issuance and requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090130461). 

January 27, 2009 Letter from NRC to Chief Arnold Hewitt, Tuscarora Nation, notifying 

issuance and requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090140166). 

January 27, 2009 Letter from NRC to Chief George Wickliffe, United Keetoowah Band of 

Cherokee Indians in Oklahoma, notifying issuance and requesting 

comments on the Draft Supplemental Environmental Impact Statement 

for North Anna Power Station Unit 3 combined license 

(Accession No. ML090140217). 

January 27, 2009 Letter from NRC to Chief Kenneth Adams, Upper Mattaponi Tribe, 

notifying issuance and requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090140246.) 

January 27, 2009 Letter from NRC to Deanna Beacham, Virginia Council of Indians, 

notifying issuance and requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090140252). 

January 27, 2009 Letter from NRC to Chief Leo Henry, Tuscarora Nation, notifying issuance 

and requesting comments on the Draft Supplemental Environmental 

Impact Statement for North Anna Power Station Unit 3 combined license 

(Accession No. ML090260037). 

January 27, 2009 Letter from NRC to Roger Kirchen, Archaeologist, Virginia Department of 

Historic Resources, notifying issuance and requesting comments on the 

Draft Supplemental Environmental Impact Statement for North Anna 

Power Station Unit 3 combined license (Accession No. ML090140266). 

January 27, 2009 Letter from NRC to Mr. Leopoldo Miranda, U.S. Fish and Wildlife Service, 

Chesapeake Bay Field Office, requesting comments on the Draft 

Supplemental Environmental Impact Statement for North Anna Power 

Station Unit 3 combined license (Accession No. ML090150214). 
Appendix C 

February 2010 C-11 NUREG-1917, SEIS 

January 27, 2009 Letter from NRC to Mr. Robert Duncan, Virginia Department of Game and 

Inland Fisheries, requesting comments on the Draft Supplemental 

Environmental Impact Statement for North Anna Power Station Unit 3 

combined license (Accession No. ML090150231). 

January 29, 2009 Email to Chief Kevin Brown, Pamunkey Tribal Government regarding 

upcoming meeting on the Draft Supplemental Environmental Impact 

Statement for the North Anna Power Station Unit 3 combined license 

(Accession No. ML090370149.) 

January 30, 2009 Letter from NRC to Regena Bronson, U.S. Army Corps of Engineers, 

Potomac Virginia Field Office, requesting comments on the Draft 

Supplemental Environmental Impact Statement for the North Anna Power 

Station Unit 3 combined license (Accession No. ML090140270). 

February 3, 2009 Letter to NRC from Roger Kirchen, Virginia Department of Historic 

Resources, regarding the Draft Supplemental Environmental Impact 

Statement, North Anna Power Station Unit 3 COL, DHR File 

No. 2000-1210; DEQ #09-00IF (Accession No. ML0906504620). 

February 3, 2009 Letter to NRC from Chief Kevin Brown, Pamunkey Tribal Government, 

providing comments on the Draft Supplemental Environmental Impact 

Statement for the North Anna Power Station Unit 3 Combined License 

Application (Accession No. ML090540397). 

February 27, 2009 Memorandum from Ms. Alicia Williamson, NRC to Mr. Gregory Hatchett, 

NRC regarding the summary of the public meeting conducted for the Draft 

Supplemental Environmental Impact Statement for the North Anna Power 

Station Unit 3 Combined License Application (Accession No. 

ML0905100280). 

March 9, 2009 Letter to NRC from Regena Bronson, U.S. Army Corps of Engineers, 

Potomac Virginia Field Office, providing comments on the Draft 

Supplemental Environmental Impact Statement for the North Anna Power 

Station Unit 3 Combined License Application (Accession No. 

ML090890275). 

March 18, 2009 Letter to NRC from Ellie Irons, Virginia Department of Environmental 

Quality, providing comments on the Draft Supplemental Environmental 

Impact Statement for the North Anna Power Station Unit 3 Combined 

License Application (Accession No. ML090900548.) 
Appendix C 

NUREG-1917, SEIS C-12 February 2010 

March 19, 2009 Letter to NRC from Eugene S. Grecheck, Dominion, providing comments 

on the Draft Supplemental Environmental Impact Statement for the North 

Anna Power Station Unit 3 Combined License Application 

(Accession No ML090830502). 

March 20, 2009 Letter to NRC from Jeffery Lapp, U.S. Environmental Protection Agency, 

Region III, providing comments on the Draft Supplemental Environmental 

Impact Statement for the North Anna Power Station Unit 3 Combined 

License Application (Accession No. ML091100400). 

April 15, 2009 Letter from NRC to U.S. Army Corps of Engineers, Potomac Virginia Field 

Office, responding to comments provided on the Draft Supplemental 

Environmental Impact Statement for the North Anna Power Station Unit 3 

Combined License Application 

(Accession No. ML090780026.) 

June 3, 2009 Letter from NRC to Dominion regarding update to the North Anna Unit 3 

combined license environmental review schedule 

(Accession No. ML0909706800). 

December 16, 2009 Letter from Eugene S. Grecheck (Dominion Nuclear Development, Vice 

President) to the U.S. Nuclear Regulatory Commission, Dominion Virginia 

Power North Anna Unit 3 Combined License Application Environmental 

Report Supplemental Information 

(Accession No. ML100350733). 

January 10, 2010 Letter from NRC to Chief Kevin Brown, Pamunkey Tribal Government, 

Summary of Government to Government Meeting between the 

Pamunkey Tribal Government and the U.S. Nuclear Regulatory 

Commission regarding North Anna Power Station, Unit 3. 

(Accession No. ML093500380). 
Appendix D 

Scoping Comments and Responses 

February 2010 D-1 NUREG-1917, SEIS 

Appendix D 

Scoping Comments and Responses 

On March 13, 2008, in accordance with Title 10 of the Code of Federal Regulations (CFR) 

Part 51.26, the U.S. Nuclear Regulatory Commission (NRC) initiated the scoping process by 

publishing a Notice of Intent to Prepare an Environmental Impact Statement and Conduct 

Scoping Process in the Federal Register (73 FR 9604). The Notice of Intent notified the public 

of the staff’s intent to prepare a supplemental environmental impact statement (SEIS) and 

conduct scoping for the proposed North Anna Unit 3 combined license (COL) application. 

Through the notice, the NRC also invited the applicants; Federal, Tribal, State, and local 

government agencies; local organizations; and individuals to participate in the scoping process 

by providing oral comments at the public meetings and/or submitting written suggestions and 

comments no later than May 16, 2008. On July 17, 2008, a Correction and Supplement to the 

previously published Notice of Intent was published in the Federal Register (73 FR 41132). The 

scoping period was reopened for 30 days, allowing for comments to be received no later than 

August 15, 2008. 

NRC regulations related to the environmental review of COL applications are contained in 

10 CFR Part 51 and 10 CFR 52, Subpart C. Pursuant to NRC regulations in 

10 CFR 51.50(c)(1), a COL applicant referencing an early site permit (ESP) need not submit 

information or analyses regarding environmental issues that were resolved in the ESP final 

environmental impact statement (EIS), except to the extent the COL applicant has identified 

new and significant information regarding such issues. In addition, pursuant to 10 CFR 52.39, 

matters resolved in the ESP proceedings are considered to be resolved in any subsequent 

proceedings, absent identification of new and significant information. The NRC staff is 

preparing this supplemental EIS (SEIS) to NUREG-1811, the ESP EIS, in support of the COL 

application for the proposed Unit 3 at the North Anna Power Station.

A public scoping meeting was held at the Louisa County High School Auditorium in Mineral, 

Virginia, on April 16, 2008. In addition, the NRC held an informal open house one hour prior to 

the public meeting. Approximately 250 members of the public attended the meeting. This 

session began with NRC staff members providing a brief overview of the COL process and the 

environmental review process. Following the NRC’s prepared statements, the meeting was 

opened for public comments. Forty four scoping meeting attendees representing 46 individuals 

(one speaker provided comments for herself and two other people) provided oral comments that 

were recorded and transcribed by a certified court reporter. Fourteen individuals also submitted 

written statements at the meeting. The transcripts of the meeting can be found as 

an attachment to the meeting summary, which was issued on May 12, 2008. The meeting 
Appendix D 

NUREG-1917, SEIS D-2 February 2010 

summary and transcripts are available electronically for public inspection in the NRC Public 

Document Room or from the Publicly Available Records component of NRC’s document 

system, the Agencywide Documents Access and Management System (ADAMS) under 

accession numbers ML081220488 (meeting summary) and ML081220353 (meeting transcript). 

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the 

Public Electronic Reading Room) (note that the URL is case-sensitive). 

At the conclusion of the scoping period, the NRC staff and its contractor reviewed the transcript 

of the scoping meeting and the written material received to identify specific comments and 

issues. All comments and suggestions received orally or in writing during the scoping period 

were considered by the staff and reviewed in terms of new and significant information as 

required by 10 CFR 51.92(e). Preparation of the SEIS took into account the relevant issues 

raised during the scoping process. 

Each comment applicable to this environmental review is summarized in this appendix. This 

information, which was extracted from the North Anna Combined License Scoping Summary 

Report, is provided for convenience of those interested in the scoping comments applicable to 

this environmental review. The comments that are outside of the scope of the environmental 

review for the proposed Unit 3 site are not included here. More detail regarding the disposition 

of general or inapplicable comments can be found in the Scoping Summary Report. The 

ADAMS accession number for the Scoping Summary Report is ML082486357. To maintain 

consistency with the Scoping Summary Report, the comment source ID and comment number 

along with the name of the commenter used in that report is retained in this appendix. 

Comments were consolidated and categorized according to topic. Comments with similar 

specific objectives were combined to capture the common essential issues raised in the source 

comments. Once comments were grouped according to subject area, the staff determined the 

appropriate response for the comment. 

Table D-1 identifies the individuals who provided comments in alphabetical order, their 

affiliation, if given, the source of their comments, and the ADAMS accession number that can be 

used to locate the correspondence that contained the comment. Parenthetical numbers after 

each comment refer to the comment source ID and comment numbers along with the name of 

the commenter. In Table D-2, comment categories are listed alphabetically with the associated 

commenters, their affiliations, and the comment numbers. 
Appendix D 

February 2010 D-3 NUREG-1917, SEIS 

Table D-1. Individuals Providing Comments During the Scoping Period 

Commenter Affiliation (if stated) 

Comment Source and 

ADAMS Accession # 

Comment 

Sources ID 

and Comment 

Number 

Amidon, Eleanor Charlottesville Center for 

Peace and Justice 

Meeting Transcript 

(ML081220353) 

0034-97 

AuClair-Valdez, 

Miguel 

Peoples Alliance for Clean 

Energy 

Letter (ML081130725) 0026-1 through 

0026-15 

E-mail (ML081510225) 008-1 

Meeting Transcript 

(ML081220353) 

0034-156 

through 

0034-160 

Ball, Kenneth Virginia Tech E-mail (ML081510213) 

E-mail (ML081130725) 

(dup) 

E-mail (ML081510217) 

(dup) 

0020-1 through 

0020-6 

Meeting Transcript 

(ML081220353) 

0034-110 

through 

0034-115 

Beament, Peter Dominion (retired) Meeting Transcript 

(ML081220353) 

0034-108 

through 

0034-109 

Black, Betty Piedmont Group of the 

Sierra Club 

Letter (ML081130725) 0023-1 through 

0023-9 

Meeting Transcript 

(ML081220353) 

0034-147 

through 155 

Brown, Eugene F. Virginia Tech E-mail (ML081130725) 

E-mail (ML081510213) 

(dup) 

E-mail (ML081510217) 

(dup) 

0019-1 through 

0019-4 

Meeting Transcript 

(ML081220353) 

0034-116 

through 

0034-119 

Bryan, James Self Meeting Transcript 

(ML081220353) 

0034-69 

through 

0034-71 
Appendix D 

NUREG-1917, SEIS D-4 February 2010 

Table D-1. (contd)

Commenter Affiliation (if stated) 

Comment Source and 

ADAMS Accession # 

Comment 

Sources ID 

and Comment 

Number 

Burns, Mecca Self E-mail (ML081510229) 0009-1 through 

0009-2 

Cherry, Pratt Nuclear Advocacy 

Network 

Meeting Transcript 

(ML081220353) 

0034-213 

through 

0034-214 

Crawford, Barbara Self E-mail (ML081510232) 0031-1 through 

0031-14 

Meeting Transcript 

(ML081220353) 

0034-197 

through 

0034-207 

Day, Donal Meeting Transcript 

(ML081220353) 

0034-127 

through 

0034-135 

Day, Elena Peoples Alliance for Clean 

Energy (PACE) 

E-mail (ML081510218) 

E-mail (ML081130725) 

(dup) 

0017-1 through 

0017-13 

Meeting Transcript 

(ML081220353) 

0034-136 

through 

0034-146 

DuBois, Paul and 

Linda 

Self E-mail (ML081510220) 0006-1 through 

0006-2 

Ellis, Larry Dominion (Retired) Meeting Transcript 

(ML081220353) 

0034-65 

through 

0034-68 

Ewing, Amy VDGIF E-mail (ML081630141) 0032-1 through 

0032-2 

Farmer, John Virginia Power (retired) Meeting Transcript 

(ML081220353) 

0034-106 

through 

0034-107 

Fawls, Rebecca North American Young 

Generation in Nuclear 

Meeting Transcript 

(ML081220353) 

0034-78 

through 

0034-83 
Appendix D 

February 2010 D-5 NUREG-1917, SEIS 

Table D-1. (contd)

Commenter Affiliation (if stated) 

Comment Source and 

ADAMS Accession # 

Comment 

Sources ID 

and Comment 

Number 

Fisher, Allison Public Citizen Meeting Transcript 

(ML081220353) 

0034-91 

through 

0034-96 

Gibson, Bob Louisa County Meeting Transcript 

(ML081220353) 

0034-22 

through 

0034-25 

Goldsmith, Aviv Self E-mail (ML082261539) 0035-1 through 

0035-49 

Grecheck, Eugene Dominion Letter (ML081130725) 0013-1 through 

0013-7 

Gunter, Paul Nuclear Policy Research 

Institute 

Meeting Transcript 

(ML081220353) 

0034-43 

through 

0034-46 

Harper, Willy Louisa County Board of 

Supervisors 

Meeting Transcript 

(ML081220353) 

0034-9 

Harte, Vicky Women in Nuclear Global Meeting Transcript 

(ML081220353) 

0034-218 

through 

0034-220 

Hayo, Dennis Self E-mail (ML081510235) 0010-1 through 

0010-3 

Heino, George and 

Gerry 

Self Letter (ML081130725) 

Letter (ML081510240) 

(dup) 

0012-1 through 

0012-6 

Meeting Transcript 

(ML081220353) 

0034-190 

through 

0034-196 

Irons, Ellie Virginia Department of 

Environmental Quality 

Letter (ML082270674) 0037-1 through 

0037-3 

Jones, Dale Lake Anna Boating and 

Recreation Association 

Meeting Transcript 

(ML081220353) 

0034-173 

through 

0034-179 

Kirchen, Roger Virginia Department of 

Historic Resources 

Letter (ML0812904901) 

Letter (ML081510228) 

(dup) 

0001-1 through 

0001-2 
Appendix D 

NUREG-1917, SEIS D-6 February 2010 

Table D-1. (contd)

Commenter Affiliation (if stated) 

Comment Source and 

ADAMS Accession # 

Comment 

Sources ID 

and Comment 

Number 

Lintecum, Lee Louisa County Letter (ML081130725) 0015-1 through 

0015-8 

Meeting Transcript 

(ML081220353) 

0034-10 

through 

0034-14 

Manzari, Jack Louisa County Chamber of 

Commerce 

Meeting Transcript 

(ML081220353) 

0034-26 

through 

0034-30 

Marshall, Burton Dominion (retired) Meeting Transcript 

(ML081220353) 

0034-100 

through 

0034-105 

Montague, Joe Self Meeting Transcript 

(ML081220353) 

0034-221 

Moore, Kenneth Virginia Power (Retired, 

VP Fossil and Hydro 

Services) 

Meeting Transcript 

(ML081220353) 

0034-59 

through 

0034-64 

Murphey, Bill Louisa County, Lake Anna 

Civic Association 

Letter (ML081130725) 0014-1 through 

0014-11 

Meeting Transcript 

(ML081220353) 

0034-223 

Nguyen, Vanthi Peoples Alliance for Clean 

Energy 

Meeting Transcript 

(ML081220353) 

0034-98 

through 

0034-99 

O’Hanlon, Jim Dominion Meeting Transcript 

(ML081220353) 

0034-47 

through 

0034-53 

Pierson, Mark Virginia Tech E-mail (ML081510213) 

E-mail (ML081510217) 

(dup) 

E-mail (ML081510223) 

(dup) 

0021-1 through 

0021-7 

Meeting Transcript 

(ML081220353) 

0034-120 

through 

0034-126 
Appendix D 

February 2010 D-7 NUREG-1917, SEIS 

Table D-1. (contd)

Commenter Affiliation (if stated) 

Comment Source and 

ADAMS Accession # 

Comment 

Sources ID 

and Comment 

Number 

Remmers, Ken Waterside Property 

Owners Association, Lake 

Anna Civic Association 

Letter (ML081130725) 0016-1 through 

0016-6 

E-mail (ML081510210) 0018-1 

E-mail (ML082261540) 0036-1 through 

0036-4 

Meeting Transcript 

(ML081220353) 

0034-31 

through 

0034-38 

Richmond, Michelle Clean and Safe Energy 

Coalition 

Meeting Transcript 

(ML081220353) 

0034-215 

through 

0034-217 

Rigali, Tony Virginia State Building 

Construction Trades 

Council 

Meeting Transcript 

(ML081220353) 

0034-18 

through 

0034-21 

Romano, John Self E-mail (ML081510224) 0011-1 through 

0011-4 

Rosenthal, Jerry Concerned Citizens of 

Louisa County 

Meeting Transcript 

(ML081220353) 

0034-31 

through 

0034-42 

Ruth, Harry Friends of Lake Anna 

(FOLA) 

Letter (ML081440463) 0033-1 through 

0033-88 

Ruth, Harry Friends of Lake Anna 

(FOLA) 

E-mail (ML081580556) 0028-1 through 

0028-74 

Schaible, Dennis Self Meeting Transcript 

(ML081220353) 

0034-222 

Smith, Doug Lake Anna Civic 

Association 

Letter (ML081130725) 0027-1 through 

0027-7 

Meeting Transcript 

(ML081220353) 

0034-180 

through 

0034-189 

Stiles, Lisa International Youth 

Nuclear Congress 

Meeting Transcript 

(ML081220353) 

0034-161 

through 

0034-172 
Appendix D 

NUREG-1917, SEIS D-8 February 2010 

Table D-1. (contd)

Commenter Affiliation (if stated) 

Comment Source and 

ADAMS Accession # 

Comment 

Sources ID 

and Comment 

Number 

Stuart, Michael Letter (ML081130725) 0025-1 through 

0025-3 

Meeting Transcript 

(ML081220353) 

0034-84 

through 

0034-85 

Taylor, Kelly Self Meeting Transcript 

(ML081220353) 

0034-72 

through 

0034-77 

Tolbert, J.R. Environment America Meeting Transcript 

(ML081220353) 

0034-208 

through 

0034-212 

Tribble, Charles Virginia Power (retired) Meeting Transcript 

(ML081220353) 

0034-54 

through 

0034-58 

Watkins, John Virginia Legislature Meeting Transcript 

(ML081220353) 

0034-1 through 

0034-8 

Wright, Jack Louisa Co. Board of 

Supervisors 

Meeting Transcript 

(ML081220353) 

0034-15 

through 

0034-17 

Zeller, Lou Blue Ridge Environmental 

Defense League 

Letter (ML081500318) 0024-1 through 

0024-13 

Meeting Transcript 

(ML081220353) 

0034-86 

through 

0034-90 
Appendix D 

February 2010 D-9 NUREG-1917, SEIS 

Table D-2. Comment Categories Alphabetically with Associated Commenters and Comments 

Comment Category Commenter (Comment ID) 

Accidents-Design Basis AuClair-Valdez, Miguel (0026-4) 

Goldsmith, Aviv (0035-31) (0035-32) 

Accidents-Severe AuClair-Valdez, Miguel (0026-9) 

Bryan, James (0034-69) (0034-70) (0034-71) 

Goldsmith, Aviv (0035-34) (0035-35) (0035-36) (0035-39) 

Stiles, Lisa (0034-172) 

Alternatives-Energy AuClair-Valdez, Miguel (0026-1) 

Day, Donal (0034-134) (0034-135) 

Day, Elena (0017-2) (0017-2) 

Day, Elena (0034-146) 

Fisher, Allison (0034-94) (0034-95) 

Goldsmith, Aviv (0035-40) 

Nguyen, Vanthi (0034-99) 

Pierson, Mark (0021-2) (0021-2) (0021-2) (0021-3) (0021-3) (0021-3) 

Pierson, Mark (0034-121) (0034-122) 

Stiles, Lisa (0034-167) (0034-168) 

Tolbert, J.R. (0034-211) 

Zeller, Lou (0024-7) 

Alternatives-Sites Zeller, Lou (0024-2) (0024-4) (0024-5) 

Alternatives-System 

Design 

Goldsmith, Aviv (0035-15) (0035-16) (0035-41) 

Hayo, Dennis (0010-3) 

Heino, George and Gerry (0012-6) (0012-6) 

Heino, George and Gerry (0034-196) 

Jones, Dale (0034-178) 

Remmers, Ken (0016-2) (0016-3) 

Remmers, Ken (0034-32) (0034-35) 

Ruth, Harry (0028-2) (0028-4) (0028-13) (0028-27) (0028-35) 

Ruth, Harry (0033-17) (0033-28) (0033-29) (0033-31) (0033-32) (0033-33) 

(0033-86) 

Zeller, Lou (0024-12) 

Benefit-Cost Balance AuClair-Valdez, Miguel (0026-2) 

Fawls, Rebecca (0034-79) (0034-82) 

Fisher, Allison (0034-92) (0034-96) 

Goldsmith, Aviv (0035-4) 

Gunter, Paul (0034-43) 

Pierson, Mark (0021-5) (0021-5) (0021-5) 

Pierson, Mark (0034-124) 

Rosenthal, Jerry (0034-40) 

Stiles, Lisa (0034-171) 

Taylor, Kelly (0034-72) 

Tolbert, J.R. (0034-209) (0034-212) 
Appendix D 

NUREG-1917, SEIS D-10 February 2010 

Table D-2. (contd) 

Comment Category Commenter (Comment ID) 

Cumulative Impacts AuClair-Valdez, Miguel (0026-11) 

Remmers, Ken (0034-33) 

Decommissioning Goldsmith, Aviv (0035-38) 

Ecology-Aquatic Black, Betty (0023-6) 

Black, Betty (0034-152) 

Crawford, Barbara (0031-11) 

Ewing, Amy (0032-2) 

Goldsmith, Aviv (0035-27) (0035-28) 

Heino, George and Gerry (0034-194) 

Ruth, Harry (0028-8) (0028-16) (0028-21) (0028-22) (0028-40) (0028-50) 

(0028-61) 

Ruth, Harry (0033-6) (0033-24) (0033-25) (0033-26) (0033-48) (0033-59) 

(0033-70) 

Smith, Doug (0034-185) 

Ecology-Terrestrial Ewing, Amy (0032-1) 

Goldsmith, Aviv (0035-13) (0035-18) 

Environmental Justice Zeller, Lou (0024-9) (0024-10) 

Geology Zeller, Lou (0034-89) 

Health-Non-Radiological Black, Betty (0023-4) (0023-5) 

Black, Betty (0034-150) (0034-151) 

Ruth, Harry (0028-15) (0028-17) (0028-18) (0028-20) (0028-39) (0028-44) 

(0028-49) (0028-52) (0028-59) (0028-65) (0028-66) (0028-67) (0028-68) 

(0028-69) (0028-71) (0028-72) (0028-74) 

Ruth, Harry (0033-7) (0033-8) (0033-21) (0033-22) (0033-23) (0033-42) 

(0033-47) (0033-52) (0033-58) (0033-61) (0033-68) (0033-74) (0033-75) 

(0033-76) (0033-77) (0033-80) (0033-81) (0033-83) 

Health-Radiological AuClair-Valdez, Miguel (0026-8) 

Day, Elena (0017-8) 

Day, Elena (0034-141) 

Goldsmith, Aviv (0035-6) (0035-30) 

Ruth, Harry (0033-27) 

Zeller, Lou (0034-87) 

Historic and Cultural 

Resources 

Kirchen, Roger (0001-1) (0001-2) (0001-2) 

Hydrology-Groundwater Zeller, Lou (0034-88) 
Appendix D 

February 2010 D-11 NUREG-1917, SEIS 

Table D-2. (contd) 

Comment Category Commenter (Comment ID) 

Hydrology-Surface 

Water 

AuClair-Valdez, Miguel (0008-1) 

AuClair-Valdez, Miguel (0026-14) (0026-15) (0034-157) 

AuClair-Valdez, Miguel (0034-158) (0034-159) 

Black, Betty (0023-3) (0023-7) 

Black, Betty (0034-149) (0034-153) 

Burns, Mecca (0009-1) 

Crawford, Barbara (0031-3) (0031-4) (0031-5) (0031-9) 

Crawford, Barbara (0034-201) (0034-203) 

Day, Elena (0017-9) 

Day, Elena (0034-142) 

Goldsmith, Aviv (0035-1) (0035-2) (0035-17) (0035-21) (0035-22) (0035-

23) (0035-24) (0035-25) (0035-26) (0035-29) (0035-48) 

Heino, George and Gerry (0012-1) (0012-1) (0012-3) (0012-3) 

Heino, George and Gerry (0034-190) (0034-192) 

Jones, Dale (0034-174) (0034-176) (0034-177) 

Lintecum, Lee (0015-7) 

Marshall, Burton (0034-103) 

Murphey, Bill (0014-2) (0014-3) (0014-4) (0014-5) (0014-6) (0014-7) 

(0014-8) (0014-9) (0014-10) (0014-11) 

Murphey, Bill (0034-223) 

O’Hanlon, Jim (0034-51) 

Remmers, Ken (0016-1) (0016-4) (0016-5) (0016-6) 

Remmers, Ken (0018-1) 

Remmers, Ken (0034-31) (0034-34) (0034-36) (0034-37) (0034-38) 

Remmers, Ken (0036-1) (0036-2) (0036-3) (0036-4) (0028-5) (0028-6) 

(0028-9) 

Ruth, Harry (0028-11) (0028-14) (0028-23) (0028-24) (0028-26) (0028-42) 

(0028-45) (0028-54) (0028-55) (0028-60) (0028-62) (0028-63) (0028-64) 

(0028-70) (0028-73) 

Ruth, Harry (0033-2) (0033-3) (0033-9) (0033-11) (0033-12) (0033-13) 

(0033-14) (0033-15) (0033-16) (0033-19) (0033-20) (0033-34) (0033-43) 

(0033-50) (0033-54) (0033-63) (0033-64) (0033-69) (0033-71) (0033-72) 

(0033-73) (0033-78) (0033-79) (0033-82) (0033-84) (0033-85) 

Schaible, Dennis (0034-222) 

Smith, Doug (0027-2) (0027-3) (0027-4) (0027-5) (0027-6) (0027-7) 

Smith, Doug (0034-182) (0034-183) (0034-184) (0034-186) (0034-188) 

(0034-189) 

Stiles, Lisa (0034-166) 

Taylor, Kelly (0034-74) 

Watkins, John (0034-7) 

Zeller, Lou (0024-11) 

Meteorology and Air 

Quality 

Goldsmith, Aviv (0035-11) (0035-12) (0035-45) (0035-47) 

Ruth, Harry (0028-33) 

Ruth, Harry (0033-41) 
Appendix D 

NUREG-1917, SEIS D-12 February 2010 

Table D-2. (contd) 

Comment Category Commenter (Comment ID) 

Need for Power Beament, Peter (0034-109) 

Brown, Eugene F. (0019-1) 

Brown, Eugene F. (0034-116) 

Ellis, Larry (0034-66) 

Farmer, John (0034-106) 

Fawls, Rebecca (0034-80) 

Grecheck, Eugene (0013-1) (0013-2) 

Manzari, Jack (0034-27) 

Marshall, Burton (0034-101) 

Moore, Kenneth (0034-60) 

Pierson, Mark (0021-4) 

Pierson, Mark (0034-123) 

Stiles, Lisa (0034-163) 

Stuart, Michael (0025-1) (0025-2) 

Stuart, Michael (0034-84) 

Tribble, Charles (0034-56) 

Watkins, John (0034-2) (0034-5) 

Wright, Jack (0034-15) 

Opposition-Licensing 

Action 

AuClair-Valdez, Miguel (0034-160) 

Black, Betty (0023-1) (0023-9) 

Black, Betty (0034-147) (0034-155) 

Day, Donal (0034-127) 

Day, Elena (0017-10) 

Opposition-Licensing 

Process 

Day, Elena (0017-1) (0017-13) 

Opposition-Nuclear 

Power 

AuClair-Valdez, Miguel (0034-156) 

Day, Donal (0034-132) (0034-133) 

Nguyen, Vanthi (0034-98) 

Out of ScopeEmergency 

Preparedness 

AuClair-Valdez, Miguel (0026-12) (0026-13) 

Crawford, Barbara (0031-13) 

Crawford, Barbara (0034-199) (0034-200) (0034-207) 

Goldsmith, Aviv (0035-14) 

Gunter, Paul (0034-45) 

Rosenthal, Jerry (0034-42) 

Ruth, Harry (0033-39) 

Out of ScopeMiscellaneous Crawford, Barbara (0031-14) 

Day, Donal (0034-131) 

Goldsmith, Aviv (0035-43) 

Rosenthal, Jerry (0034-39) 

Ruth, Harry (0033-10) 

Tolbert, J.R. (0034-208) 
Appendix D 

February 2010 D-13 NUREG-1917, SEIS 

Table D-2. (contd) 

Comment Category Commenter (Comment ID) 

Out of ScopeMiscellaneous (contd) Rigali, Tony (0034-19) (0034-20) 

Ruth, Harry (0028-12) (0028-28) (0028-29) (0028-30) (0028-31) (0028-34) 

(0028-36) (0028-37) (0028-38) (0028-41) (0028-43) (0028-46) (0028-47) 

(0028-48) (0028-51) (0028-53) (0028-56) (0028-57) (0028-58) 

Ruth, Harry (0033-4) (0033-5) (0033-36) (0033-37) (0033-38) (0033-44) 

(0033-45) (0033-46) (0033-49) (0033-51) (0033-53) (0033-55) (0033-56) 

(0033-57) (0033-60) (0033-62) (0033-65) (0033-66) (0033-67) 

Smith, Doug (0034-181) 

Tribble, Charles (0034-55) 

Out of Scope-NRC 

Oversight 

Black, Betty (0023-8) (0034-154) 

Crawford, Barbara (0034-202) 

Day, Donal (0034-128) (0034-130) 

Rosenthal, Jerry (0034-41) 

Ruth, Harry (0033-87) 

Out of Scope-Safety Crawford, Barbara (0031-2) 

Watkins, John (0034-3) 

Wright, Jack (0034-16) 

Zeller, Lou (0034-86) 

Out of Scope-Security 

and terrorism 

AuClair-Valdez, Miguel (0026-10) 

Crawford, Barbara (0034-198) 

Day, Donal (0034-129) 

Day, Elena (0017-7) 

Day, Elena (0034-140) 

Goldsmith, Aviv (0035-7) (0035-33) 

Gunter, Paul (0034-46) 

Ruth, Harry (0033-30) 

Process-ESP-COL Ruth, Harry (0028-7) (0028-25) 

Ruth, Harry (0033-35) (0033-88) 

Zeller, Lou (0024-3) (0024-8) 

Process-NEPA Goldsmith, Aviv (0035-8) (0035-9) (0035-10) 

Irons, Ellie (0037-1) (0037-2) (0037-3) 

Ruth, Harry (0028-19) 

Ruth, Harry (0033-18) (0024-1) (0024-6) (0024-13) 

Zeller, Lou (0024-1) (0024-6) (0024-13) 

Zeller, Lou (0034-90) 

Site Layout and Design Goldsmith, Aviv (0035-42) 

Tolbert, J.R. (0034-210) 

Socioeconomics Crawford, Barbara (0031-6) (0031-7) (0031-8) (0031-10) (0031-12) 

Crawford, Barbara (0034-204) (0034-205) (0034-206) 

Fawls, Rebecca (0034-78) (0034-81) 
Appendix D 

NUREG-1917, SEIS D-14 February 2010 

Table D-2. (contd) 

Comment Category Commenter (Comment ID) 

Socioeconomics (contd) Gibson, Bob (0034-22) (0034-23) (0034-24) 

Goldsmith, Aviv (0035-3) (0035-5) (0035-19) (0035-20) (0035-44) 

(0035-44) (0035-46) (0035-49) 

Hayo, Dennis (0010-2) 

Heino, George and Gerry (0012-2) (0012-4) (0012-4) (0012-5) (0012-5) 

Heino, George and Gerry (0034-191) (0034-193) (0034-195) 

Jones, Dale (0034-173) (0034-175) (0034-179) 

Lintecum, Lee (0015-2) (0015-3) (0015-4) (0015-5) (0015-6) 

Lintecum, Lee (0034-11) (0034-12) (0034-13) 

Manzari, Jack (0034-29) 

Support-Licensing 

Action 

Ball, Kenneth (0020-5) (0020-5) 

Ball, Kenneth (0034-114) 

Beament, Peter (0034-108) 

Brown, Eugene F. (0019-4) 

Brown, Eugene F. (0034-119) 

Cherry, Pratt (0034-214) 

Ellis, Larry (0034-65) (0034-68) 

Farmer, John (0034-107) 

Gibson, Bob (0034-25) 

Harper, Willy (0034-9) 

Harte, Vicky (0034-218) 

Hayo, Dennis (0010-1) 

Lintecum, Lee (0015-1) (0015-8) 

Lintecum, Lee (0034-10) (0034-14) 

Manzari, Jack (0034-26) (0034-30) 

Marshall, Burton (0034-100) (0034-105) 

Montague, Joe (0034-221) 

Moore, Kenneth (0034-59) (0034-62) (0034-64) 

Murphey, Bill (0014-1) 

O’Hanlon, Jim (0034-47) (0034-50) (0034-53) 

Pierson, Mark (0021-1) (0021-7) 

Pierson, Mark (0034-120) (0034-126) 

Rigali, Tony (0034-18) (0034-21) 

Ruth, Harry (0028-1) (0028-3) 

Ruth, Harry (0033-1) 

Smith, Doug (0027-1) 

Smith, Doug (0034-180) (0034-187) 

Stiles, Lisa (0034-161) 

Stuart, Michael (0025-3) 

Stuart, Michael (0034-85) 

Taylor, Kelly (0034-75) 

Tribble, Charles (0034-54) 

Watkins, John (0034-8) 

Wright, Jack (0034-17) 
Appendix D 

February 2010 D-15 NUREG-1917, SEIS 

Table D-2. (contd) 

Comment Category Commenter (Comment ID) 

Support-Licensing 

Process 

DuBois, Paul and Linda (0006-2) 

Grecheck, Eugene (0013-5) (0013-6) (0013-7) 

Moore, Kenneth (0034-61) 

O’Hanlon, Jim (0034-52) 

Richmond, Michelle (0034-217) 

Stiles, Lisa (0034-162) (0034-164) 

Support-Nuclear Power Ball, Kenneth (0020-1) (0020-2) (0020-3) (0020-4) (0020-6) 

Ball, Kenneth (0034-110) (0034-111) (0034-112) (0034-113) (0034-115) 

Brown, Eugene F. (0019-2) (0019-3) 

Brown, Eugene F. (0034-117) (0034-118) 

Cherry, Pratt (0034-213) 

DuBois, Paul and Linda (0006-1) 

Ellis, Larry (0034-67) 

Fawls, Rebecca (0034-83) 

Grecheck, Eugene (0013-3) (0013-4) 

Harte, Vicky (0034-219) (0034-220) 

Moore, Kenneth (0034-63) 

O’Hanlon, Jim (0034-48) 

Pierson, Mark (0021-6) 

Pierson, Mark (0034-125) 

Richmond, Michelle (0034-215) 

Romano, John (0011-4) 

Stiles, Lisa (0034-165) (0034-169) (0034-170) 

Taylor, Kelly (0034-73) (0034-76) 

Tribble, Charles (0034-57) (0034-58) 

Watkins, John (0034-1) (0034-4) (0034-6) 

Support-Plant Manzari, Jack (0034-28) 

Marshall, Burton (0034-102) (0034-104) 

O’Hanlon, Jim (0034-49) 

Richmond, Michelle (0034-216) 

Romano, John (0011-1) (0011-2) (0011-3) 

Taylor, Kelly (0034-77) 

Transportation AuClair-Valdez, Miguel (0026-6) 

Day, Elena (0017-6) 

Day, Elena (0034-139) 

Uranium Fuel Cycle Amidon, Eleanor (0034-97) 

AuClair-Valdez, Miguel (0026-3) (0026-5) (0026-7) 

Black, Betty (0023-2) 

Black, Betty (0034-148) 

Burns, Mecca (0009-2) 

Crawford, Barbara (0031-1) 

Crawford, Barbara (0034-197) 
Appendix D 

NUREG-1917, SEIS D-16 February 2010 

Table D-2. (contd) 

Comment Category Commenter (Comment ID) 

Uranium Fuel Cycle 

(contd) 

Day, Elena (0017-4) (0017-5) (0017-11) (0017-12) (0017-13) 

Day, Elena (0034-136) (0034-137) (0034-138) (0034-143) (0034-144) 

(0034-145) 

Fisher, Allison (0034-91) (0034-93) 

Goldsmith, Aviv (0035-37) 

Gunter, Paul (0034-44) 

Ruth, Harry (0028-32) 

Ruth, Harry (0033-40) 
Appendix D 

February 2010 D-17 NUREG-1917, SEIS 

North Anna Combined License 

Public Scoping 

Comments and Responses

The comments and suggestions received as part of the scoping process are summarized and 

discussed below. Parenthetical numbers after each comment refer to the Comment 

Identification number (ID) number (document ID number-comment number) and the commenter 

name. Comments are grouped by category. 

1. Comments Concerning the ESP-COL Process

Comment: Although the ESP was approved by the Commission in November, its order 

contained the seed of poor judgment. The Commission may have perfected the record but it 

failed to perfect the permit when it sidestepped the issues raised by Judge Karlin in his dissent. 

In fact, the Commission admitted to the self same errors of judgment in its Memorandum and 

Order approving the ESP. (0024-3 (Zeller, Lou)) 

Response: This issue is related to the Atomic Safety and Licensing Board and NRC 

Commission approval of the North Anna ESP application for up to two additional units to be 

constructed at the North Anna Power Station site. The NRC staff addressed the issues raised 

by Judge Karlin in supplemental information that was presented to the Commission. The NRC 

issued Dominion the North Anna ESP (ESP-003) in November 2007. This comment provides 

no new and significant information and will not be evaluated further. 

Comment: Both VDEQ and DGIF, in conjunction with Dominion Resources are currently 

conducting an In-stream Flow Incremental Methodology (IFIM) study on Lake Anna and the 

North Anna River and Pamunkey Rivers downstream to determine the effects of the reduced 

water flow on recreation, wildlife, aquatic life and fish as part of the conditional certification for 

the 3rd reactor Early Site Permit (ESP). This IFIM study must also address all of the comments 

made by the VA Dept of Conservation and Recreation (DCR). This IFIM study should be 

completed before any Draft Environmental Impact Statement for the COL is issued by the NRC 

so all the results of the IFIM study can be reviewed and commented on by the public. 

Otherwise the results from this important study will cause much re-work later by the NRC, 

Virginia and the public and waste much time. Currently there is no public participation in the 

study plan or results. (0028-7 (Ruth, Harry)) 

Comment: We also request public participation in each step/review of the In-stream Flow 

Incremental Methodology (IFIM) study for Lake Anna and the North Anna River being conducted 

as part of Virginia and the U.S. North Anna Early Site Permit (ESP) approval process. (0033-88

(Ruth, Harry)) 

Response: Under conditions of the North Anna ESP permit (ESP-003), Dominion is required to 

conduct an In-stream Flow Incremental Methodology (IFIM) study that is designed and 
Appendix D 

NUREG-1917, SEIS D-18 February 2010 

monitored in cooperation and consultation with the Virginia Department of Game and Inland 

Fisheries (VDGIF) and the Virginia Department of Environmental Quality (VDEQ) to address 

potential impacts of the proposed units on the fishes and other aquatic resources of Lake Anna 

and downstream waters. This study must be completed prior to issuance of a combined 

operating license for any new units at NAPS. Dominion agreed to consult both with VDGIF and 

VDEQ regarding surface water management, release, and in-stream flow conditions prescribed 

by VDGIF and VDEQ as implemented through appropriate state or Federal permits or licenses. 

Public involvement in the study plan and review of the results is the responsibility of the VDGIF 

and VDEQ, not the NRC. NRC staff, however, will monitor the progress related to completion of 

the study and results obtained. Any information that is available regarding the IFIM study at the 

time the SEIS is prepared will be included in the SEIS as part of Chapter 2.7.

Comment: As part of the earlier ESP process, Dominion continued to make revisions to issues 

as they were identified and analyzed. Hence our review of the DEIS became a moving target, 

without the NRC extending the time for the public to respond. It is requested that each time that 

Dominion makes a change to a previously submitted document that impacts the DEIS, that the 

NRC automatically extends the public comment period and the COL schedule as well to give the 

public sufficient time to review the changes and make comments. Hardcopies of the original 

documents and changes should also be supplied to the persons who sign up to request them, 

as trying to keep up with thousands of pages and changes on a home computer and ink-jet 

printer is next to impossible. The home printing cost for thousands of pages is prohibitive for 

most of the public and prevents them from participating in the public process. Also without 

having a hard copy to find all the references that are made throughout the documents and 

requests for information (ROI’s) it also a very impossible task to participate in the public 

process. (0028-25, 0033-35 (Ruth, Harry)) 

Response: These comments express general opposition to the NRC licensing process and 

provide no specific information related to the environmental review. Up-to-date information 

regarding the North Anna Power Station, Unit 3 COL application can be found at www.nrc.gov. 

These comments also fall outside the scope of 10 CFR 51 and 52, which describe the NRC’s 

environmental review process for a COL. Therefore, the comments will not be evaluated 

further.

2. Comments Concerning Process - NEPA

Comment: I guess more important and also relevant in this matter is the Fifth Amendment to 

the Constitution of the United States, which says that no person shall be deprived of life, liberty, 

or property without due process of law. I would submit to you that an accident caused by a 

foreseeable event cannot be construed as due process. (0034-90 (Zeller, Lou)) 

Response: The evaluation of postulated accidents and their impact on the environment and the 

public will be evaluated with in Chapter 5.10 of the SEIS. 
Appendix D 

February 2010 D-19 NUREG-1917, SEIS 

Comment: Public meetings should be held at other locations and times around the region so 

that interested parties are given the opportunity to be educated and voice their input in a public 

forum. This would facilitate public participation (which is one of the goals of the NEPA process). 

(0035-9 (Goldsmith, Aviv)) 

Response: Although NEPA does require federal agencies to initiate a scoping process, the 

decision of how to implement scoping is left to the agencies’ discretion. It is the policy of the 

NRC to involve the public in the Commission’s decision-making process and therefore it elects 

to conduct open public scoping meetings in association with its environmental review process. 

Meetings are generally held in a location to reach the largest population that will experience the 

most direct environmental impact as a result of the proposed action. In the case of NAPS 

Unit 3, this population is located in the area of Louisa County, Virginia. The scoping period is 

open for 60 days and, during this time, the public and other agencies are welcome to also 

submit written comments. The NRC will hold additional public meetings after the draft SEIS is 

published. Separate meetings will be held by the NRC in association with the safety review 

process. 

Comment: It seems that the ESL [ESP] EIS, was not performed by an unbiased 

interdisciplinary team as is required by NEPA. For example, Page 1-6 states that “Dominion did 

not or was unable to provide information and analysis for certain issues sufficient to allow the 

NRC staff to complete its independent analysis.” Thus the issues “are not resolved.” The NRC 

should commission independent sources to develop the required data at this time. (0035-10 

(Goldsmith, Aviv)) 

Response: All identified issues not resolved during the ESP process will be evaluated as part 

of the evaluation of the COL application. Those specific issues that were not resolved are listed 

in Appendix J of the ESP final environmental impact statement (NUREG-1811, Vol. 1) that was 

issued by the NRC in December 2006. 

Comment: The following discussion pertains to the NRC’s decision to prepare a supplemental 

EIS in support of the COL instead of an EIS. Inasmuch as a COL is a major federal action, a 

supplemental EIS would not provide the rigorous environmental analysis necessary to guide 

decision makers on a COL application. The NRC has repeatedly stated that “to construct and 

operate a nuclear power plant, an ESP holder must obtain a CP and OL, or a COL, which are 

separate major federal actions which require their own environmental review in accordance with 

10 CFR Part 51” (references: ESP Final EIS, page 1-2, ESP Supplemental EIS, Executive 

Summary, page xviii, and ESP, DEIS, Executive Summary page xxi). The recent decision 

(published on July 17, 2008) to prepare a supplement to the Final ESP EIS to support the COL 

instead of another EIS for the COL is also inconsistent with the NRC’s earlier position as 

reflected in Mr. William D. Beckner’s July 6, 2005 letter responding to Mr. Adrian Heymer at the 

Nuclear Energy Institute. In that letter, Mr. Beckner stated “We believe that a portion of the 

underlying basis for industry’s view is not consistent with the NRC’s regulations and the 

applicable case law interpreting the National Environmental Policy Act of 1969, as amended 

(NEPA). In particular, inasmuch as an ESP and a COL are major federal actions, an 
Appendix D 

NUREG-1917, SEIS D-20 February 2010 

environmental assessment is not a sufficient environmental inquiry on which to base an action 

on an ESP or COL application. Accordingly, pursuant to 10 CFR 51.20, both actions require the 

preparation of an EIS.” 

While we understand that the NRC’s current rules implementing NEPA (10 CFR 51.92) allow 

the NRC to prepare a supplement to the ESP EIS to support the COL, over the past five years 

(since 2003 until March 13, 2008) the NRC has consistently maintained that an EIS would be 

prepared to support the COL. It was with this understanding that the Commonwealth reviewed 

and commented on the Draft EIS (March 3, 2005) and Supplemental EIS (September 8, 2006) 

for the ESP. During the ESP review process several environmental impact considerations were 

deferred to the COL stage of the licensing process. Following the 2006 amendments to the 

NRC rules, the Final ESP EIS which was published in December 2007 continued to assert that 

the ESP and COL are separate major federal actions requiring their own environmental review. 

Therefore, the Commonwealth had no reason to anticipate the NRC’s recent change in its 

position on the type of NEPA document which would be prepared for the COL process. (0037-1

(Irons, Ellie)) 

Response: As outlined in a Federal Register Notice of August 28, 2007 (72FRN 49429), the 

NRC agrees an early site permit and a combined license are major Federal actions significantly 

affecting the quality of the human environment and both actions would require the preparation of 

an EIS. However, 10 CFR part 52 does provide finality for previously resolved issues. Thus, 

the environmental review conducted by the NRC at the combined license stage is informed by 

the EIS prepared at the ESP stage and information can be incorporated by reference in a 

combined license supplemental EIS. This supplemental EIS will focus on any identified new 

and significant information, resolution of significant environmental issues not addressed in the 

early site permit proceedings, and that all environmental terms and conditions included in the 

early site permit will be satisfied by the date of issuance of the combined license. 

Comment: Environmental Review 

The following state and local Virginia agencies are likely to be included in the coordinated 

review of submitted environmental documents (note: starred (*) agencies administer one or 

more of the Enforceable Policies of the Virginia Coastal Resources Management Program. 

Department of Environmental Quality: 

Office of Environmental Impact Review 

Tidewater Regional Office* 

Water Division 

Air Division* 

Waste Division 

Department of Game and Inland Fisheries* 

Department of Conservation and Recreation: 

Division of Chesapeake Bay Local Assistance* 

Division of Soil and Water Conservation* 

Division of Planning and Recreation Resources 

Department of Health* 

Marine Resources Commission* 
Appendix D 

February 2010 D-21 NUREG-1917, SEIS 

Department of Historic Resources 

Virginia Institute of Marine Science 

Department of Mines, Minerals, and Energy 

Department of Agriculture and Consumer Services 

U.S. Nuclear Regulatory Commission 

Department of Forestry 

Department of Transportation 

Hampton Roads Planning District Commission 

Affected Locality(ies) 

In order to ensure an effective coordinated review of the EIS and the consistency certification, 

we will require about 24 copies of each document (6 hard copies and 18 CDs) when it is 

published. The document should include one or more U.S. Geological Survey topographic 

maps as part of its information. We recommend, as well, that project details be adequately 

described and analyzed. While this Office does not participate in scoping efforts beyond the 

advice given herein, other agencies may independently provide scoping comments to you 

concerning the preparation of the NEPA document for the proposed project. (0037-3

(Irons, Ellie)) 

Response: An ample number of draft supplemental EIS documents will be made available for 

review by the state agencies that have been identified. Any comments from these agencies will 

be considered if they are submitted during the open scoping period. 

Comment: Pursuant to the CZMA, federal licensing or permit activities affecting Virginia’s 

coastal resources or coastal uses must be consistent with the enforceable policies of the 

Virginia Coastal Resources Management Program (VCP) (also called the Virginia Coastal Zone 

Management Program) (see Federal Consistency Regulations, 15 CFR Part 930, sub-part D, 

Consistency for Activities Requiring a License or Permit). DEQ must be provided with a federal 

consistency certification which involves an analysis of the activities in light of the enforceable 

policies of the VCP (first enclosure), and a commitment to comply with the enforceable policies. 

In addition, we invite your attention to the advisory policies of the VCP (second enclosure). 

Sections 930.57 and 930.58 of the Federal Consistency Regulations and Virginia’s Federal 

Consistency Information Package available on DEQ’s web site at 

http://www.deq.virginia.gov/eir/federal.html, give content requirements for a consistency 

certification. We recommend that the submission of the federal consistency certification follows 

the completion of the NEPA review process to facilitate the resolution of issues before 

embarking on the consistency review. We believe that this approach will prevent unnecessary 

delays in the consistency review process which could result from changes made during the 

NEPA review. (0037-2 (Irons, Ellie)) 

Response: This issue will be addressed in Chapter 2.2.1 of the COL SEIS. Dominion is 

required to provide a Coastal Zone Management Act certification to the Commonwealth of 

Virginia for proposed Unit 3 at the North Anna Power Station. Dominion has documented the 

need for preparing the consistency determination in Chapter 1 of the Environmental Report that 
Appendix D 

NUREG-1917, SEIS D-22 February 2010 

was submitted with the application. The environmental report for the proposed Unit 3 is a 

publicly available record from the NRC Agencywide Documents Access and Management 

System (ADAMS). ADAMS is accessible at http://www.nrc.gov/reading-rm/adams.html. The 

ADAMS accession number for the North Anna Unit 3 ER is ML073321238. 

3. Comments Concerning Site Layout and Design

Comment: I know that someone has stood up here and said that there don’t have to be any 

changes to the transmission line, but listening to our introduction this evening, I heard that 

Dominion has said that we will have to change the transmission line. So that’s something that 

needs to be considered. (0034-210 (Tolbert, J.R.)) 

Response: The environmental impacts associated with transmission lines from the proposed 

Unit 3 are considered new and significant and will be addressed in Chapter 3 of the SEIS. 

4. Comments Concerning Meteorology and Air Quality

Comment: Impact of additional fog and icing from wet cooling towers on local roadways and 

surrounding residential homes and communities. (0028-33 (Ruth, Harry)) 

Comment: Impact of additional fog and icing from wet cooling towers on local roadways and 

surrounding residential homes and communities. (0033-41 (Ruth, Harry)) 

Response: Fog and icing from cooling towers was previously discussed in NUREG-1811, 

ESP EIS for the early site permit. The analysis for the North Anna Unit 3 SEIS will address only 

new and significant information to determine if the impact level has changed. 

Comment: The impacts to traffic from increased fog occurrence should be addressed. 

(0035-12 (Goldsmith, Aviv)) 

Response: Fog and icing from cooling towers was previously discussed in NUREG-1811, 

ESP EIS for the early site permit. The analysis for the North Anna Unit 3 SEIS will address only 

new and significant information to determine if the impact level has changed. 

Comment: The same limited three-year climatological data set that was used in the DEIS was 

used for the SDEIS (page 2-7 line 3). Is this the same data referred to in Page 5-14 line 22? 

This may be insufficient to accurately predict ground fog impacts from the project. Furthermore, 

this data sent is inconsistent with other reporting periods (see DEIS Section 5-58 line 38 e.g.) 

used elsewhere in the document. (0035-11 (Goldsmith, Aviv)) 

Response: This comment refers to information in the North Anna draft ESP EIS that was 

superseded by the North Anna final ESP EIS (NUREG-1811) published by NRC in 

December 2006. NUREG-1811 was revised to incorporate numerous public comments 

(see NUREG-1811, Appendix E). Dominion was issued an ESP permit (ESP-003) in 

November 2007 for two units at the North Anna Power Station site under the specifications 
Appendix D 

February 2010 D-23 NUREG-1917, SEIS 

contained in that permit. All environmental issues related to the ESP application from Dominion 

were identified, evaluated, and resolved or proposed mitigation actions were identified. The 

impacts related to ground fog impacts were discussed and resolved in Chapter 5 of 

NUREG-1811, ESP EIS. 

Comment: The cooling tower will shift much of the thermal load from Lake Anna to the 

atmosphere. Shouldn’t mitigation be required to minimize heat island and climate change 

impacts? Such mitigation could include tree planting and similar regional measures. (0035-47

(Goldsmith, Aviv)) 

Response: This comment refers to information in the North Anna draft ESP EIS that was 

superseded by the North Anna final ESP EIS (NUREG-1811) published by NRC in 

December 2006. NUREG-1811 was revised to incorporate numerous public comments 

(see NUREG-1811, Appendix E). Dominion was issued an ESP permit (ESP-003) in 

November 2007 for two units at the North Anna Power Station site under the specifications 

contained in that permit. All environmental issues related to the ESP application from Dominion 

were identified, evaluated, and resolved or proposed mitigation actions were identified. The 

information related to atmospheric moisture and cooling towers was discussed and resolved in 

Chapter 2 of NUREG-1811, ESP EIS. Staff will evaluate new and significant information 

relating to cooling towers in Chapter 5 of the SEIS to determine whether the impact level has 

changed. 

Comment: Overall, the mitigations listed in Section 10 are insufficient. Items such as 

“consider” plume abatement measures are just one example. Plume abatement should be 

implemented. (0035-45 (Goldsmith, Aviv)) 

Response: This comment refers to information in the North Anna draft ESP EIS that was 

superseded by the North Anna final ESP EIS (NUREG-1811) published by NRC in 

December 2006. NUREG-1811 was revised to incorporate numerous public comments 

(see NUREG-1811, Appendix E). Dominion was issued an ESP permit (ESP-003) in 

November 2007 for two units at the North Anna Power Station site under the specifications 

contained in that permit. All environmental issues related to the ESP application from Dominion 

were identified, evaluated, and resolved or proposed mitigation actions were identified. The 

impacts related to plume abatement were discussed and resolved in Chapter 10.2 of 

NUREG-1811, ESP EIS. 

5. Comments Concerning Geology

Comment: Regarding seismicity, vibratory ground motion, the variance requested says, Unit 3 

does not fall within the ESP and the site safety analysis report. The data show the top of 

competent rock under Unit 3, seismic category 1 structures is higher than assumed for the ESP. 

The Nuclear Regulatory Commission has responsibility in this matter under 10 CFR 51.105, 

also under appendix A to part 100, which describes the type of inquiry necessary for the Nuclear 

Regulatory Commission to determine site suitability with regard to geologic stability and 

seismicity. (0034-89 (Zeller, Lou)) 
Appendix D 

NUREG-1917, SEIS D-24 February 2010 

Response: Seismic hazards are outside the scope of the environmental review. As part of the 

NRC’s site safety review, the staff considers whether, taking into consideration the site criteria 

in 10 CFR Part 100 and information provided by the applicant, such a reactor or reactors can be 

constructed and operated without undue risk to the health and safety of the public. This 

comment provides no new and significant information and will not be evaluated further. 

6. Comments Concerning Hydrology - Surface Water

Comment: I am opposed to this partly because of concern for global warming and associated 

drought issues in the region. It has been shown that this site is not capable of sustaining any 

more reactors. (0009-1 (Burns, Mecca)) 

Comment: A major problem for improvement of the conservation and use of lake water is that 

there are so many independent entities that have power over any change. LACA is appealing to 

all these entities to modify their positions so all of us can benefit from improved conservation 

and water use. (0014-3 (Murphey, Bill)) 

Comment: We ask that Dominion Resources, Louisa County, Fluvanna County, and the James 

River Authority all cooperate to enlarge the James River-Zions Cross Road water pipe (to about 

60 MGD) and extend the pipe through the town of Louisa to the North Anna Power Plant to 

permit the use of James River waster for make-up water for the third unit. (0014-5 (Murphey, 

Bill)) 

Comment: We ask the NRC to actively work with the other entities to achieve improved water 

conservation and use. (0014-8 (Murphey, Bill)) 

Comment: We ask specifically for NRC support to obtain third unit make-up water from the 

James River. (0014-9 (Murphey, Bill)) 

Comment: The Lake Anna region has been designated a growth area in the County’s 

Comprehensive Plan. In view of the annual low water level in Lake Anna and potential needs 

for water sources in the immediate future, Louisa County has recently begun a study to identify 

potential water supplies for our citizens. Lake Anna and its tributaries have been identified as 

potential water resources for this ever-growing population center of our County. (0015-7

(Lintecum, Lee)) 

Comment: Lake Anna is the smallest body of water in the eastern United States that provides 

water for cooling a nuclear power plant. The two operating reactors are putting a tremendous 

strain on the water resources of central Virginia, particularly during times of draught. Additional 

reactors will threaten the water that Virginians use for drinking, agriculture, and recreation. 

They will put increasing pressure on the ecosystem of the York River Watershed. (0023-7, 

0034-153 (Black, Betty)) 
Appendix D 

February 2010 D-25 NUREG-1917, SEIS 

Comment: The addition of North Anna Unit 3 at North Anna will have a large negative impact 

on water supply during that timeframe and would, as such, be a major factor in the water control 

plan. In response to drought conditions in Virginia and in accordance with 9 VAC25-780, the 

Town of Louisa has entered into a long-term regional water planning process with a completion 

due date of November 2, 2011. 

Unit 3 is to utilize a closed-cycle dry and wet tower cooling system which is expected to have an 

evaporation rate of 8707 gallons per minute and a minimum make-up flow rate 6 of 15,376 gpm 

in Maximum Water Conservation mode. Therefore, Unit 3 alone would have an annual 

consumptive use of over 8 billion gallons in water conservation mode. Thermoelectric power 

plants require huge amounts of water and the Surry and North Anna nuclear stations are the 

two top water users in Virginia. Together, they accounted for 44% of statewide surface water 

withdrawals; in 2001 the North Anna Power Station alone used 56% more surface water than all 

of Virginia’s agricultural, commercial, manufacturing, mining and public water supply users 

combined. (0024-11 (Zeller, Lou)) 

Comment: The NRC needs to stop passing the buck to the state of Virginia and ignoring the 

water crisis. The previous EIS gave this issue short shrift, stating that it’s Virginia’s problem and 

that our DEQ (Dept of Environmental Quality) can simply order Dominion to shut down one or 

more reactors in the event of low water! Does it make sense to build yet another reactor? What 

are the chances that all 3 reactors will even be able to operate at the same time? (0031-4

(Crawford, Barbara)) 

Comment: The previous EIS stated that there were no new or anticipated residential, business, 

or commercial demands on the watershed near the plant. This is incorrect. It was known, or 

should have been known based on documentation submitted to you, that there are 3 significant 

residential developments in the works, including Cutalong which is building a golf course that 

will require significant water withdrawals from Contrary Creek, one of the feeder streams for the 

power plant. Note that the DEQ has recommended this permit be granted. In addition, there 

are at least 3 businesses, that I know of, near the plant that require significant water use: 

Argonaut, Martin Marietta, and a shopping center with supermarket at Cutalong, all of which 

require water in order to operate. Again, the new EIS needs to look closely at these competing 

demands for water in an area that has very little of it. The new EIS needs to reevaluate the 

availability of water for a 3rd reactor. (0031-9 (Crawford, Barbara)) 

Comment: Electric power generation accounts for only about three percent of freshwater 

consumption in the U.S. The largest portion, 80 percent, is used for irrigation. And the next 

largest consumption is for residential use, at seven percent. There is nothing unique to nuclear 

power plants about the possibility of reducing electricity production because of decreased water 

levels in a drought or a severe heat wave. Whether this happens depends on what is 

constrained in local, state, and federal permits and the assumption of flow rates, temperatures, 

and water levels used in the safety analyses. (0034-166 (Stiles, Lisa)) 

Comment: Central Virginia and especially Louisa County is notoriously drought-prone and 

water-poor. And Lake Anna is already struggling to sustain reactors 1 and 2 and protect those 
Appendix D 

NUREG-1917, SEIS D-26 February 2010 

who live, work, and recreate on and around the lake. Dominion based its location of the power 

plant on the assumption that there will be drought every 20 years or so. In fact, we have had 

three major droughts in the past nine years. We are currently experiencing a drought that 

began last May that is now 11 months old and shows no sign of abating. There are predictions 

from the weather experts that this drought will continue throughout the spring and summer. 

Lake Anna’s lake level has dropped in excess of two feet in five of the past years. This fact 

alone suggests that the environmental impact statement needs to be revisited. (0031-3,

0034-201 (Crawford, Barbara)) 

Comment: One of the problems has been the idea of the low level of the lake and the small 

input into the lake. One of the solutions lies in what Louisa County is already doing. That is 

getting water from the James River and bringing it over to Zion Crossroads. What we would like 

to do is recommend that NRC work with the many other entities that are involved in the water 

and have the makeup water for the third unit piped over from the James River. Pipes are going 

to go all the way to Zion Crossroads. Already have heard about one of the county 

commissioners bringing water up into the center of the county. What we are saying is for 

Dominion and Louisa County, Fluvanna County, and the James River Authority, along with 

NRC, work to have the water makeup brought in from the James River. (0034-223

(Murphey, Bill)) 

Response: The comments will be considered in the Staff’s review of new and significant 

information related to water use and water availability of the Lake Anna Reservoir. Water 

resource management incorporates the uncertainty of projections of the future supply and 

demand for water that results from natural climate variability (e.g., droughts) and man-made 

demands. The Commonwealth of Virginia (VDEQ), the U.S. Environmental Protection Agency 

(EPA), and the U.S. Army Corps of Engineers (ACE) have jurisdiction for regulating water use 

and water quality through Federal and State laws. 

Comment: Virginia has been in drought conditions. This has been true at Lake Anna where 

water levels have been down from 2 to 5 feet in 5 of the past 8 years (3.5 ft this year). (0012-1, 

0034-190 (Heino, George and Gerry)) 

Comment: Dominion is now proposing Unit 3 which per their documentation will double the 

drought cycle and increase its length from 21 to 40 days (of course this occurs when the lake is 

most used in the summer months), (up to 24 million gallons a day will be extracted from the 

Lake). (0012-3, 0034-192 (Heino, George and Gerry)) 

Comment: We ask that the NRC review the estimates of water inflow to the Lake in relation to 

the uses proposed for the third unit. This review is in light of what appears to be a climate 

change in the amount of rainfall. The change in rainfall is shown by the occurrence two 20 year 

droughts in the past 5 years and by the fact that the Lake release has had to be reduced to the 

20 cfs rate 5 times in the past 8 years. (0014-7 (Murphey, Bill)) 
Appendix D 

February 2010 D-27 NUREG-1917, SEIS 

Comment: The current proposed cooling is a combination dry and wet cooling tower which 

introduces significant evaporation of water in the Lake Anna reservoir (up to 16.6 MGD water in 

the Maximum Water Conservation Mode). (0016-1 (Remmers, Ken)) 

Comment: Report on the North Anna Early Site Permit Water Budget Model (Lake WBT) for 

Lake Anna by Cook et al. January 2005 is insufficient and significant new information can come 

from an updated water budget model. This study was performed before the change in cooling 

technique to wet-dry hybrid system and only looked at once pass through and totally wet 

cooling. This study should be redone and include a hybrid and totally dry cooling systems. 

Once again travel time for the water to circulate from the discharge back to the input of the plant 

was not available for this study. It should be collected at least in the WHTF so that accurate 

predictions can be made. (0016-4 (Remmers, Ken)) 

Comment: The study does not address temperature. In response to a question by the NRC, 

Dominion stated On a long term basis the average temperature of the cooling lake due to the 

reduced lake level from Unit 3 has been estimated to be less than 0.1 degrees F. The so called 

long term effect is not where the problem exists. The hot summer months needs to be 

evaluated for temperature change. No calculations were provided by Dominion. It was only 

estimated. The calculations for the summer time periods should be performed by Dominion and 

independent calculations done by NRC. Units 1 and 2 will heat the water faster and return time 

for recycling will be increased during the problematic hot summer months. This temperature 

needs to be investigated more carefully. (0016-5 (Remmers, Ken)) 

Comment: I am working on getting a knot meter to measure the currents on the hot side. I 

would expect that we would measure the flow pattern i.e. The two canals, dikes 1, 2, 3 and exit 

to the power plant. Question on the temperature increase due to the third reactor. What 

volume of water do you assume the 100F blowdown is influencing? Where would the 

temperature be 0.1F higher? Or is there a gradient from plant output (hot side) to plant intake 

(cold side)? If you use the entire volume of the lake in this calculation, this would be inaccurate. 

My LACA measurements indicate the temperature of the reservoir at dike three even at 

3 meters depth is cooler than that measured temperature at the dam up to 3 meters. Can you 

provide the calculations that back up this 0.1F increase? Can you assure me that this will be 

considered as significant new information in the North Anna COLA DEIS. (0018-1

(Remmers, Ken)) 

Comment: Drought conditions this past summer decreased lake levels as well as downstream 

flows. Another reactor would increase the amount of water needed to cool the reactors. More 

hot water released into the Lake would increase evaporation, and further decrease lake levels 

as well as downstream flows into the North Anna and Pamunkey Rivers. Our water resources 

need to be protected, not wasted on inefficient and consumptive new and old nuclear units. 

(0026-15 (AuClair-Valdez, Miguel)) 

Comment: Low water levels on Lake Anna expose safety hazards to the thousands of 

recreational users of the Lake, create increased erosion along the entire shoreline, and damage 

wetlands and other aquatic life. Every effort to mitigate these impacts should be carefully 
Appendix D 

NUREG-1917, SEIS D-28 February 2010 

considered. We would like the NRC to focus its attention in the COL Environmental Impact 

Statement on the impact of low water levels on the Lake, its users, and its ecosystems. 

(0027-4, 0034-183 (Smith, Doug)) 

Comment: The third unit will consume 16 million gallons per day even while running in water 

conservation mode, resulting in the loss of up to 1.4 inches of lake level per month. If the third 

unit were operating this past year the lake would now be 15 inches lower. Its low point last fall 

would have been an additional 9 inches—about 4 feet below normal. The existing 

environmental impact statement assumes one drought every 20 years. We have had two 

official droughts and reached drought conditions of 248 feet on the lake in 5 of the last 8 years. 

The ESP EIS estimates that wetlands impact is small because as much wetland is created as is 

destroyed, but is silent about the impact of what appears to be an almost annual reduction to 

the 248’ level. We ask the NRC to review the water level modeling done in the ESP EIS to 

incorporate actual data and do further analysis of deviations from averages. Annual averages 

do not give accurate indications of summer lake level impacts and 20 year averages have not 

been consistent with actual experience. Additionally, inflow assumptions have not been field 

verified and should be reviewed: In dry weather Conditions, the already small Lake Anna 

watershed is significantly reduced by the impoundments caused by Lake Louisa, Lake Orange, 

and the hundreds of farm ponds and small lakes that impede the transmittal of water to the 

Lake. Dominion has developed new data including actual surveys of a portion of the wetlands 

on the Lake. We ask the NRC to carefully review and use this new data to determine if it alters 

its earlier impact assessments. (0027-5 (Smith, Doug)) 

Comment: We are concerned about the impact of low water levels. We believe new 

information is available to better estimate low water level impacts and that there are steps that 

can be taken to mitigate those impacts. We urge the NRC to focus its new efforts particularly on 

the modeling and assumptions made in the estimates on water levels, further analysis of 

impacts on the lake, and potential mitigation efforts. (0027-7, 0034-189 (Smith, Doug)) 

Comment: The Lake Anna Lake Level Task Force consisting of members from the Friends of 

Lake Anna, Lake Anna Civic Association and the Lake Anna Boating and Recreation 

Association have identified the following impacts that will be caused as a result of declining lake 

water levels. Each of these issues should be reviewed during the DEIS of the COL for the 3rd 

reactor: 

• The creation of many boating hazards with previously submerged items (rocks, stumps, 

sandbars, etc.) are exposed creating major safety hazards for recreational users when 

their boats hit these submerged items; 

• The water will get hotter faster in the summer months to unsafe water temperatures 

causing negative health impacts to humans, fish, wildlife, aquatic life, clams and 

mussels; 

• There will be major fire safety hazards for lake homes/communities by making the dry 

fire hydrants unusable due to the lack of water at the lake intake caused by the 

decreasing lake water level. 
Appendix D 

February 2010 D-29 NUREG-1917, SEIS 

• There will be shoreline stabilization problems and 

• There will be negative impacts on many lake businesses as people go elsewhere to 

recreate and live. (0028-11 (Ruth, Harry)) 

Comment: The previous NRC Lake Model in the ESP EIS also provided no details on how the 

assessment was made when it concluded that the lake water temperature would not rise any 

more than 0.1F with decreased water levels, and the addition of the proposed reactor 3 wet/dry 

cooling method. It appears that the EIS lake model did not take into consideration that Lake 

Anna is unique for providing cooling water for nuclear power plants. Most nuclear power plants 

receive cooling water from robust fast flowing rivers or oceans with the heated water flowing 

downstream and is quickly cooled. Lake Anna is unique in that 99% of the water is recirculated 

between the power plant and the dam, while only 1% of the water flows over the dam and 

downstream. As a result, 99% of the recirculated water gets hotter and hotter over the summer 

months. The NRC lake model for the COL DEIS should be updated to reflect the continuous recirculation of Lake Anna water and the cumulative effects of Units 1, 2, & 3 operating at the 

same time, with results being published in the COL DEIS. The projected cumulative impacts of 

global warming should also be included in these lake water temperature calculations. (0028-14

(Ruth, Harry)) 

Comment: The DEIS should examine what is the actual water flow into Lake Anna from all 

feeder streams during times of drought. Apparently all lake level predictions are based on 

computer models only and no one has ever taken actual water measurements on water flow 

from all the feeder streams to Lake Anna during drought conditions. Since Lake Anna is in a 

very small watershed and outflow over the dam is based on the Lake water level (and the 

outflow fluctuates during a drought), it is extremely important to know how much water is coming 

in the lake. The lake has experienced drought conditions during 5 of the past 8 years, so the 

accurate measure should easily be achieved. It is widely acknowledged that the water sources 

for Lake Anna are not nearly as substantial or robust as was originally planned. (0028-23, 

0033-19 (Ruth, Harry)) 

Comment: Recreational boaters will find more hazards throughout the lake, with stumps, rocks, 

sandbars, etc. causing lower units to hit them which in turn could necessitate major repairs or 

replacement of propellers, other engine components and boat hulls. In addition, the safety of all 

aboard the boats is severely jeopardized when the boats run into these newly emergent and 

changing boating hazards when the lake level is below 250 MSL and continues to decrease 

during drought cycles. Note: Per Dominion and the NRC, these drought cycles will be doubled 

with the proposed type of 3rd reactor wet/dry cooling method. These increased droughts will 

result in many human safety risks increasing dramatically. (0028-42, 0033-50 (Ruth, Harry)) 

Comment: Any substantial change to the lake water level will cause further erosion, as current 

bulkheads and rip rap and are installed for protecting the shoreline at the 250 MSL lake level. 

These installed shoreline stabilization techniques coupled with the natural shoreline weeds and 

tree roots have created the current shoreline stabilization throughout the 13,000 acre lake. If 

the lake level decreases, then the wave action will cause erosion to occur at a different water 
Appendix D 

NUREG-1917, SEIS D-30 February 2010 

level. This increased erosion may create muddy water and the current shoreline stabilization 

techniques may need to be changed. (0028-45, 0033-54 (Ruth, Harry)) 

Comment: Dominion has acknowledged that the wet/dry cooling method for the 3rd reactor will 

use up to an additional 24 million gallons of Lake Anna water each day in the Energy 

Conservation Mode and up to 16.6 million gallons per day in the Maximum Water Conservation 

Mode. (0028-5 (Ruth, Harry)) 

Comment: When boating, the lake users will find more hazards throughout the lake, with 

stumps, rocks, sandbars, etc. causing lower units to hit them which in turn could necessitate 

major repairs or replacement of propellers, other engine components and boat hulls. In 

addition, the safety of all aboard the boats is severely jeopardized when the boats run into these 

newly emergent and changing boating hazards when the lake level is below 250 MSL and 

continues to decrease during drought cycles. Note: Dominion and the NRC state these drought 

cycles will be doubled with the proposed type of 3rd reactor wet/dry cooling method. The 

doubling of the drought cycle will increase the human safety risks dramatically. (0028-54, 0033-

63 (Ruth, Harry)) 

Comment: Any substantial change to the lake water level will cause further erosion, as current 

bulkheads and rip rap and are installed for protecting the shoreline at the 250 MSL lake level. 

These installed shoreline stabilization techniques coupled with the natural shoreline weeds and 

tree roots have created the current shoreline stabilization throughout the 13,000 acre lake. If 

the lake level decreases, then the wave action will cause erosion to occur at a different water 

level. This increased erosion may create muddy water and the current shoreline stabilization 

techniques may need to be changed, which will increase the cost to the homeowner to modify 

their existing stabilization technique. (0028-55, 0033-64 (Ruth, Harry)) 

Comment: The Virginia Dept of Environmental Quality (VDEQ) Dept of Water Resources and 

the Dept of Game & Inland Fisheries (DGIF) have previously indicated that the North Anna 

watershed is too small to allow large water withdrawals. These could adversely affect the 

beneficial users of the North Anna and Pamunkey River which eventually flows into the 

Chesapeake Bay and the Atlantic Ocean. The DGIF &VDEQ analyses and Dominion 

acknowledges that the 3rd reactor would increase the drought cycle and cause decreased water 

flows during March, April; May; June, July, August, and September (7 months) of each year. 

Dominion has stated that the drought cycle will double with the addition of the 3rd reactor 

wet/dry cooling method. The proposed cooling method will cause the average drought period to 

increase from 21 to over 40 days per year (most likely during the summer months). Note that 

lake levels have decreased below 248 MSL in five out of the last eight years. Dominion has 

stated that with the addition of reactor 3 that a drought would only occur each 10 years. Our 

current drought started in May 2007 when the lake level fell below 250 MSL. The DEIS should 

explore facts versus Dominion predictions with lake levels decreasing below 250 MSL and 

related impacts to the public, fish, clams/mussels, and wildlife. (0028-6 (Ruth, Harry)) 

Comment: We (Friends of Lake Anna) are very concerned that that the declining water levels 

caused by natural drought cycles, global warming and water release rates to downstream users 
Appendix D 

February 2010 D-31 NUREG-1917, SEIS 

will be exasperated by the addition of a 3rd nuclear reactor with wet/dry cooling towers that will 

cause an additional evaporation rate of up to 28 million gallons per day and doubling of the 

drought cycle that will cause the water to decline further and the water to get hotter faster. 

(0028-60, 0033-69 (Ruth, Harry)) 

Comment: Water level decrease—According to the Nuclear Regulatory Commission 

Environmental Report (See Page 5.12) says: Because the Unit 3 Cooling tower would consume 

water (up to 28 Million Gallons per day (see section 3.2), the volume of water in Lake Anna 

would be reduced (compared to operation of only Units 1 and 2 alone) when the lake level 

elevation is below 250 ft MSL. Assuming the heat rejection rate from operations of Units 1 and 

2 remains constant, the reduced volume of water in the lake caused by Unit 3 operation would 

result in a faster increase of lake water temperature (See Page 5.12). (0028-63 (Ruth, Harry)) 

Comment: The VA Dept of Water Resources estimated that with the 3rd unit operating, the 

lake would decline at an additional rate of approximately 1.1 inches per month and the current 

drought started in May 2007. When the lake was recently down about 30 inches, with the 

3rd reactor wet/dry cooling method operating it would have been down about another 12 inches 

for a total of about a 42 inch drop in water level. Dominion states that when the lake is down to 

242 ft, the reactors must be shut down. If the 3rd reactor as proposed with wet/dry cooling 

towers is operational, one wonders whether Lake Anna can sustain three reactors running 

simultaneously, with the possibility of an 8 foot drop in water levels. (0028-64, 0033-73

(Ruth, Harry)) 

Comment: The previous NRC Lake Model in the ESP EIS has compared the once through 

cooling method (used by Units 1 & 2) with total wet cooling only and also used 20 year averages 

to compute modeling results. This lake model should be updated to the current proposed unit 3 

wet/dry cooling method and use median results for the past 20 years, so all the highs & lows are 

defined, including the most recent and current drought levels. VDEQ’s Dept of Water 

Resources has estimated that the lake levels will decline approximately 1.1 inches per month 

during a drought. During the current that started in May 2007, this would translate into 

decreased water level of over 1 foot today. (0028-9 (Ruth, Harry)) 

Comment: The proposed 3rd reactor will contribute to further low levels at the lake, contrary to 

Dominion’s statements that the hybrid cooling system will not use additional water. According to 

Dominion’s own numbers, the proposed cooling system will cause up to 24 million gallons of 

water to evaporate every day. Again, given that Lake Anna is struggling to sustain 2 reactors 

and that the ongoing low water levels are causing a myriad of problems for the people who live 

and work at the lake as well as the many people of the county and beyond who use Lake Anna 

for boating, fishing, swimming, etc., does it really make sense to build another reactor there? 

(0031-5, 0034-203 (Crawford, Barbara)) 

Comment: The previous NRC Lake Model in the ESP EIS also provided no details on how the 

assessment was made when it concluded that the lake water temperature would not rise any 

more than 0.1F with decreased water levels, and the addition of the proposed reactor 3 wet/dry 

cooling method. It appears that the EIS lake model used averaging that may have masked 
Appendix D 

NUREG-1917, SEIS D-32 February 2010 

temperature maximums in the summer months and did not take into consideration that Lake 

Anna is unique for providing cooling water for nuclear power plants. Most nuclear power plants 

receive cooling water from robust fast flowing rivers or oceans with the heated water flowing 

downstream and is quickly cooled. Lake Anna is unique in that 99% of the water is recirculated 

between the power plant and the dam, while only 1% of the water flows over the dam and 

downstream. As a result, 99% of the re-circulated water gets hotter and hotter over the summer 

months. Note that with only Units I & 2 operating, water temperatures have previously been 

recorded at over 104F in the cooling lagoons and over 93F on the main reservoir. The hot 

water is where humans recreate and where fish, wildlife, clams/mussels, and aquatic life share 

the water in what appears to be unsafe conditions. We request an upper water temperature 

limit in Fahrenheit degrees on the discharge of the water. (0033-11 (Ruth, Harry)) 

Comment: The NRC’s lake model should also be updated to the current proposed Unit 3 

wet/dry cooling method and use accurate results for the past 20 years, so all the high’s & low’s 

are defined (not 20 year averages), including the most recent and current drought levels. It also 

does not include all relevant data for the current proposed wet/dry cooling method. The 

previous NRC Lake Model in the ESP EIS has compared the once through cooling method 

(used by Units 1 & 2) with total wet cooling only and also used 20 year averages to compute 

modeling results. The model apparently does not take into consideration the various times of 

the year, particularly the high water temperatures (over 104F) during the hot summer months 

when the environmental impact is the greatest for the public, fish and wildlife. The lake model 

should be updated to the current proposed Unit 3 wet/dry cooling method and use actual high 

temperatures in the summer and low temperatures in the winter for the past 20 years, so all the 

high’s & low’s are defined, including the most recent and current drought levels. VDEQ’s Dept. 

of Water Resources has estimated that the lake levels will decline approximately 1.1 inches per 

month during a drought, while others have estimated 1.4 inches. During the current drought 

that started in May 2007, this would translate into an additional decreased water level of 

between 13 to 17 inches by April 08. (0033-12 (Ruth, Harry)) 

Comment: The NRC’s Report on the North Anna Early Site Permit Water Budget Model (Lake 

WBT) for Lake Anna by Cook et al. January 2005 is insufficient and significant new information 

will come from an updated water budget model. This study was performed before the change in 

cooling technique for Unit 3 to a combination wet-dry hybrid system and only looked at once 

pass through and totally wet cooling. This study should be redone and include a hybrid and 

totally dry cooling systems. The old study indicated that travel time for the water to circulate 

from the discharge back to the input of the plant was not available. This is critical information 

and it should be collected at least in the WHTF (cooling lagoons) so that accurate predictions 

can be made. The study does not address water temperature. In response to a question by the 

NRC, Dominion stated On a long term basis the average temperature of the cooling lake due to 

the reduced lake level from Unit 3 has been estimated to be less than 0.1 degrees F. The so 

call long term effect is not where the problem exists. The hot summer months needs to be 

evaluated separately for temperature change. No calculations were provided by Dominion. It 

was only estimated. The calculations for the summer time periods should be performed by 

Dominion and the NRC should also perform its own independent calculations to verify the data. 

Units 1and 2 will heat the less water caused by Unit 3 evaporation much faster and the return 
Appendix D 

February 2010 D-33 NUREG-1917, SEIS 

time for recycling will be shortened during the problematic hot summer months. This heated 

water temperature needs to be investigated more carefully, as it is the root cause for many of 

the public, fish and wildlife concerns. Annual averages do not give accurate indications of 

summer lake level impacts and 20 year averages have not been consistent with actual 

experience. (0033-13 (Ruth, Harry)) 

Comment: Impacts of Declining Water Levels in Lake Anna. Dominion has acknowledged that 

the wet/dry cooling method for the 3rP reactor will use up to an additional 24 million gallons of 

Lake Anna water each day in the Energy Conservation Mode and up to 16.6 million gallons per 

day in the Maximum Water Conservation Mode. Both of these methods will cause Lake Anna to 

have declining water levels, particularly during the summer months. The accumulative 

environmental issues as defined in subparagraphs (a) through (o) below caused by the 

projected annual low water levels in Lake Anna as a result of the 3rd reactor cooling method is 

LARGE and therefore mitigation efforts for alternative cooling methods are required. (0033-2

(Ruth, Harry)) 

Comment: The NRC should look at the impact to the public, fish, clams/mussels and wildlife as 

a result of increased droughts caused by the proposed wet/dry cooling method proposed. The 

Virginia Dept of Environmental Quality (VDEQ) Dept. of Water Resources and the Dept. of 

Game & Inland Fisheries (DGIF) have previously indicated that the North Anna watershed is too 

small to allow large water withdrawals. These could adversely affect the beneficial users of the 

North Anna and Pamunkey River which eventually flows into the Chesapeake Bay and the 

Atlantic Ocean. The DGIF &VDEQ analyses and Dominion acknowledges that the 3rd reactor 

would increase the drought cycle and cause decreased water flows during March, April, May, 

June, July, August, and September (7 months) of each year. Dominion has stated that the 

drought cycle will double with the addition of the 3rd reactor wet/dry cooling method. The 

proposed cooling method will cause the average drought period to increase from 21 to over 

40 days per year (most likely during the summer months). Note that lake levels have decreased 

below 248 MSL in five out of the last eight years. Dominion has stated that with the addition of 

reactor 3 that a drought would only occur each 10 years. Our current drought started in May 

2007 when the lake level fell below 250 MSL and did not increase to 250 MSL for 1 year in April 

2008. The DEIS should explore facts versus Dominion predictions with lake levels decreasing 

below 250 MSL and related impacts to the public, fish, clams/mussels, and wildlife. (0033-20

(Ruth, Harry)) 

Comment: The Lake Anna Lake Level Task Force consisting of members from the Friends of 

Lake Anna, Lake Anna Civic Association and the Lake Anna Boating and Recreation 

Association have identified the following impacts that will be caused as a result of declining lake 

water levels. 

• The creation of many safe boating hazards when previously submerged items (rocks, 

stumps, sandbars, etc.) are exposed creating major safety hazards for recreational users 

when their boats hit these submerged items; 
Appendix D 

NUREG-1917, SEIS D-34 February 2010 

• The water will get hotter faster in the summer months to unsafe water temperatures causing 

negative health impact to humans, fish, wildlife, aquatic life, clams, and mussels. (0033-3

(Ruth, Harry)) 

Comment: The accumulative environmental impacts caused by the projected annual low water 

levels in Lake Anna as a result of the 3 reactor cooling method are LARGE and therefore 

mitigation efforts for alternative cooling methods are required. (0033-43 (Ruth, Harry)) 

Comment: We the undersigned persons who recreate on the 13,000 acre Lake Anna, Virginia 

and/or own property adjacent to the main reservoir and/or cooling lagoons of the lake or nearby 

areas and/or own-or manage businesses that are affected by Lake Anna are very concerned 

about the declining water levels, increased water temperatures during the summer months and 

associated impacts to all forms of recreation in/on Lake Anna. We are also concerned that 

these declining water levels will: 

(a) create many boating hazards with previously submerged items (rocks, sandbars, etc.), and 

create major safety hazards for recreational users when their boats hit these submerged 

Items; 

(b) cause the water to get hotter faster in the summer months to unsafe-water temperatures 

causing negative impacts to humans, fish, wildlife, aquatic life, clams and mussels; 

(c) create a major fire safety hazard for lake homes/communities by making the dry fire 

hydrants unusable; 

(d) increase shoreline stabilization problems and 

(e) negatively impact many lake businesses with loss of customers. (0033-84 (Ruth, Harry)) 

Comment: Dominion states the addition of the 3rd nuclear reactor, will cause up to an 

additional 24 million gallons per day to be evaporated from the lake causing a doubling of the 

drought cycle and further lake level declines. (0033-85 (Ruth, Harry)) 

Comment: The NRC lake model for the COL DEIS should be updated to reflect the continuous 

re-circulation of Lake Anna water and the cumulative effects of Units 1, 2, & 3 operating at the 

same time, with results being published in the COL DEIS. (0033-9 (Ruth, Harry)) 

Comment: And the drought conditions in the past summer decreased the level, the lake levels, 

as well as downstream flow. Another reactor would simply increase the need for cooling water. 

More hot water will be released in the lake, which will increase evaporation and further 

decrease lake levels as well as downstream flow into the North Anna and Pamunkey Rivers. 

(0034-159 (AuClair-Valdez, Miguel)) 

Comment: Lake Anna has hundreds of stumps and boulders that were not removed prior to the 

hurricane filling the lake. When the lake level starts to decline below the 250-foot level, many 

hazardous conditions are created. The reduced water level has already caused numerous 

boating accidents on the lake and from these submerged objects. (0034-174 (Jones, Dale)) 
Appendix D 

February 2010 D-35 NUREG-1917, SEIS 

Comment: According to Dominion Resources, a proposed wet/dry cooling system will remove 

up to million additional gallons of water from the lake per day except when they are in the water 

conservation mode. In the conservation mode, they will evaporate 16 million gallons of water a 

day. This would cause the lake water level to drop more than 12 inches of water annually. 

During the past ten years, we experienced several periods of drought that reduce the lake levels 

from the requisite 250 to below 245 feet level. During the drought in 2007, the lake level 

dropped and a half feet. Further adding to the problem is a requirement of dumping a minimum 

of 26 million gallons of water per day from the lake to supply the businesses located below in 

Hanover County. (0034-176 (Jones, Dale)) 

Comment: Presently there are over 40 million gallons of water being removed daily from the 

lake over the dam. And the lake is still below 250 feet. A comprehensive study should be 

completed to evaluate the amount of water that is flowing into the lake when drought conditions 

prevail. Obviously for the last years, there has been insufficient water flow to maintain the 

250-foot level during the critical summer months. (0034-177 (Jones, Dale)) 

Comment: The third unit will consume 16 million gallons a day in the water conservation mode, 

resulting in the loss of 1.4 inches of lake level per month. If the third unit were operating this 

last year, the lake would currently be 15 inches lower. Its low point last fall would have been an 

additional nine inches, making this more than four feet below normal. The existing 

environmental impact statement assumes one drought every 20 years. We have had 2 official 

droughts and reached the drought condition of 248-foot level on the lake in 5 of the last 8 years. 

Clearly the water level modeling is suspect. (0034-184 (Smith, Doug)) 

Comment: The ESP EIS claims that wetlands impact is small because as much wetland is 

created as is destroyed, but is silent about the impact of what appears to be an almost annual 

reduction to the 248-foot level. The NRC should review modeling done in the environmental 

impact statement to incorporate new actual data and do further analysis of deviations from the 

20-year averages. Additionally, inflow assumptions have not been field-verified and should be 

reviewed. Dominion has developed new data, including actual surveys of a portion of the 

wetlands on the lake. We ask that NRC carefully review and use this new data to determine if it 

alters its earlier impact assessment. Additional steps can and should be taken to mitigate low 

water level impact on safety, erosion, and ecosystems on the lake. (0034-186 (Smith, Doug)) 

Comment: NRC’s report on the North Anna early site permit water budget model, lake WHTS, 

for Lake Anna in January of 2005 is insufficient, and significant new information can come from 

an update water budget model. This study was performed before the change in the cooling 

technique to wet/dry cooling hybrid systems, and only looked at once passthrough and totally 

wet cooling. The study should be redone to include hybrid and totally dry cooling systems. 

Once again, this study indicated that the travel time for the water to circulate from the discharge, 

all the way back to the intake of the plant, was not available for this study. This critical 

information should be collected at least in the waste heat treatment facility, so that accurate 

predictions can be made on that study. (0034-36 (Remmers, Ken)) 
Appendix D 

NUREG-1917, SEIS D-36 February 2010 

Comment: The study does not address temperature. In response to a question by NRC, 

Dominion stated on a long-term basis the average temperature of the cooling lake, due to the 

reduced lake level from Unit 3, has been estimated to be less than one-tenth of a degree 

Fahrenheit. The so-called long-term effect is not where the problem exists. The hot summer 

months need to be evaluated for temperature change. No calculations were provided by 

Dominion. It was only estimated. The calculation for the summertime period should be 

performed by Dominion, and independent calculations done by NRC. Units 1 and 2 will heat the 

water, less amounts—less amounts of water faster, and return time for recycling will be 

shortened during the problematic hot summer months. This temperature needs to be 

investigated more carefully. (0034-37 (Remmers, Ken)) 

Comment: Water level changes will be heightened during the period July-September. Since 

this coincides with increased summer recreational use of the lake, even minor changes could 

have MODERATE or HIGH impacts. (0035-21 (Goldsmith, Aviv)) 

Response: NRC staff will evaluate new information relating to inputs to the water budget model 

and any resulting changes to impacts of plant operation on Lake Anna reservoir lake level and 

discharge to the North Anna River. Inputs to the water budget model include plant water use, 

plant discharges, meteorology (precipitation), and streamflow information. Lake level and 

thermal impacts were previously addressed in NUREG-1811, ESP EIS; therefore, the SEIS 

analysis will focus on new and significant information that might change the original impact 

level. Water-related impacts of plant operation will be addressed in Chapter 5.3 of the SEIS. 

The results of the lake level elevation and discharge evaluation will also be used to evaluate 

ecological, socioeconomic, and human health impacts of plant operation, which will be 

addressed in Chapter 5.4, 5.5, and 5.8, respectively, of the SEIS.

Comment: A problem with Lake water quality is caused by the discharge of sewage plant 

effluent into the Lake. We understand that as part of the third unit, Dominion is planning to build 

an additional sewage treatment plant. They plan to discharge more sewage effluent into the 

Lake. This is environmentally bad. There is so little inflow to the Lake and thus so little flowthrough. The small flow-through means that the sewage effluent accumulated over time to 

unacceptable levels. (0014-10 (Murphey, Bill)) 

Comment: We request that there be no discharge of sewage effluent into the Lake. We 

request that Dominion follow the example of the Cutalong Project and use the sewage effluent 

as irrigation water or holding pond water on their own site. We request that the NRC support 

this reduction in environmental impact of the third unit. (0014-11 (Murphey, Bill)) 

Comment: Dominion has proposed a new Waste Treatment Facility for Unit 3. This is new and 

significant information. The effluent would be discharged into the WHTF of Lake Anna. Their 

current waste treatment facility for Units 1 and 2 already discharges in the lake and we would 

oppose a new discharge. Why can’t the current treatment plant support the new Unit 3? Is it up 

to capacity? Is the size of the proposed plant larger than needed or would it replace the Unit 1 

and 2 treatment plant? (0016-6 (Remmers, Ken)) 
Appendix D 

February 2010 D-37 NUREG-1917, SEIS 

Comment: In order to support the operation of a new unit and the 750 workers hired to operate 

and maintain it, Dominion plans to build a second waste treatment plant to locally process 

human and other waste. The treated effluent of that plant, like the effluent from the existing 

waste treatment facility, would be dumped into Lake Anna at the discharge canal. Lake Anna is 

not a free flowing stream. The added nutrients from the effluent will remain in the lake and 

accumulate over years. The buildup of nitrates can produce algae blooms that produce fish kills 

and encourage plant growth such as hydrilla that can choke entire bays. (0027-2

(Smith, Doug)) 

Comment: An alternative [sanitary waste treatment] system that would store the effluent and 

use it to water grass or wooded areas is available. It is currently in place in the town of Louisa 

and is planned for the golf community called Cutalong on Lake Anna. The ESP EIS listed 

impact on water quality as unresolved, due to the lack of information about the impact of these 

other waste streams flowing into the WHTF (Sec. 5.3). We ask the NRC to review the 

cumulative impact of dumping sewage effluent into Lake Anna. We would like for Dominion to 

consider an alternative method and include the existing sewage treatment facility effluent so 

that no effluent is dumped into the lake at all. (0027-3 (Smith, Doug)) 

Comment: We [Lake Anna Civic Association] are concerned about the dumping of sewage 

effluent into the lake and the impact of low water conditions on safety, erosion, and aquatic life. 

We encourage the consideration of a new alternative to preclude the dumping of effluent. 

(0027-6 (Smith, Doug)) 

Comment: The DEIS should examine the effects of adding additional treated sewage effluent 

from the requested expansion of the Dominion sewage treatment plant as needed for the influx 

of new workers who will be hired to construct the new reactor at Lake Anna. This sewage 

effluent will then be dumped into Lake Anna water and re-circulated throughout the lake with the 

current re-circulation flow. Note that 99% of the lake water is currently re-circulated between 

the power plant and the dam and only 1% runs over the dam. This water is heated by the 

power plant, which increases the risk to humans who swim and recreate in the water to 

increased biological risks from the sewage effluent. See attachment 2 for potential health risks 

from hotter water in Lake Anna. (0028-24 (Ruth, Harry)) 

Comment: The NRC in its DEIS should examine the effects of the new and significant 

information of Dominion requesting to put additional treated sewage effluent from the requested 

expansion of the Dominion sewage treatment plant as needed for the influx of new workers who 

will be hired to construct and/or operate the new reactor at Lake Anna. The NRC must look at 

the accumulative affect of dumping sewage effluent into the lake. This treated sewage effluent 

will then be discharged into the cooling lagoons (WHTF) of Lake Anna water and heated up to 

104 degrees during the summer months. While effluent may meet standards set for sewage 

discharge, nitrates in the water can accumulate and cause runaway plant growth that clogs 

streams and impedes navigation. In addition, the sewage effluent being heated to high 

temperature (over 100 degrees F) offers the opportunity for an increased proliferation of 

bacteria in the water where people swim and recreate on a routine basis. This water is then 

re-circulated throughout the main reservoir backup to the power plant with the current 
Appendix D 

NUREG-1917, SEIS D-38 February 2010 

re-circulation flow where many other people recreate. Note that 99% of the lake water is 

currently re-circulated between the power plant and the dam and only 1% runs over the dam. 

See Attachment B for Potential Human Health Impacts. (0033-14 (Ruth, Harry)) 

Comment: We are opposed to any additional sewage effluent being discharged into Lake 

Anna. Why can’t the current treatment plant support the new Unit 3? Is the current plant up to 

capacity? Why can’t innovative techniques be used to preclude putting the effluent into the lake 

and not create potential serious health hazards and runaway aquatic plant growth? (0033-15

(Ruth, Harry)) 

Comment: Dominion plans to build a second waste treatment plant to locally process human 

and other wastes. The treated effluent of that plant, like the effluent from the existing waste 

treatment facility, would be dumped into Lake Anna at the discharge canal. Lake Anna is not a 

free-flowing stream. The added nutrients from the effluent will remain in the lake and 

accumulate over the years. The build-up of nitrates can produce algae blooms that produce fish 

kills and encourage plant growth, such as Hydrilla, that can choke entire bays. An alternative 

system that would store the effluent and use it to water grass or wooded areas is available. It is 

currently in place in the Town of Louisa and is planned for the golf community called Cutalong 

on Lake Anna. We ask the NRC to review the cumulative impact of dumping sewage effluent 

into Lake Anna. This is legitimate because it is an unresolved issue in supplement number 1. 

And, as far as I can tell, we have never looked at the accumulated effect of the dumping of the 

sewage effluent. We would like Dominion to consider an alternative method and include the 

existing sewage treatment facility effluent so that no effluent is dumped into the lake at all. 

(0034-182 (Smith, Doug)) 

Comment: We are concerned about the dumping of sewage effluent into the lake and the 

impact of low water conditions on safety, erosion, and aquatic life. We ask the NRC to review 

long-term impact, and we ask Dominion to consider a new alternative to include the dumping of 

effluent. (0034-188 (Smith, Doug)) 

Comment: Dominion has proposed a new waste heat treatment facility for Unit 3. This is new 

and significant information. The effluent would be discharged into the waste heat treatment 

facility of Lake Anna. The current waste treatment facility for Units 1 and 2 already discharge 

into the lake, and we would oppose a new discharge. Why can’t the current treatment plant 

support the new Unit 3? Is it up to capacity already? Is the size of the proposed new waste 

treatment plant larger than needed? Or would it replace the Units 1 and 2 treatment plant? 

Why can’t new techniques be used where the effluent is not dumped into the lake? (0034-38

(Remmers, Ken)) 

Comment: When you talk about opposing a new discharge effluent path into the lake, that you 

don’t want to put the water back in the lake, it seems to me contradictory if you’re going to say 

that and then talk about water balanced studies, and so on and so forth. If you’re not going to 

put the water back in the lake, what are you going to do for it? What are you going to do with it? 

You’re going to increase how much water you’re taking out of the lake. And if the water is clean 

enough and meets the government’s standards and the EPA standards and the state standards, 
Appendix D 

February 2010 D-39 NUREG-1917, SEIS 

in all the studies that are done, why wouldn’t you put the water back in the lake so that we can 

use it for the water table, so we can use it for the downstream effluence? Why would you just 

randomly say, no, don’t put this water back in the lake, and somebody else figure out what to do 

with it. (0034-74 (Taylor, Kelly)) 

Response: The North Anna Unit 3 COL application contains new information regarding a 

proposed sanitary treatment plant that will discharge effluent at the same location as other plant 

effluent discharges. This information will be evaluated by NRC staff to determine impacts to 

water quality, which will be addressed in Chapter 5.3 of the SEIS. The NRC does not have the 

authority to set water quality limits; plant effluent discharges will continue to be regulated by 

VDEQ. Related ecological and human health impacts will be addressed in Chapter 5.4 and 5.8, 

respectively, of the SEIS. 

Comment: We ask that the seasonally adjusted level of the Lake to be increased to 250 feet 

3 inches above MSL (mean seal level). This will conserve water for use during low water times. 

(0014-4 (Murphey, Bill)) 

Comment: We ask that the dam release requirement be reduced to 20 cfs at a Lake level of 

250 feet 3 inches. 

—The below dam inflow study will show that the contribution of the Lake is not essential to the 

downstream user needs. 

—This change will conserve water for dry time use. (0014-6 (Murphey, Bill)) 

Comment: For example, the lake levels should not be raised which could cause property 

damage to lake owners in order unduly to quarantine more water so that it can be released later 

to satisfy the downstream users at different times of the year. Likewise the consumptive use of 

water and increased needs for water caused by population growth by downstream users should 

not cause the lake levels to be dropped so more water flow could be released to downstream 

users and then create mud flats throughout the lake. (0028-26 (Ruth, Harry)) 

Comment: For example, the lake levels should not be raised greater than 3 inches, which 

could cause property damage to lake owners in order unduly to quarantine more water so that it 

can be released later to satisfy the downstream users at different times of the year. Likewise 

the consumptive use of water and increased needs for water caused by population growth by 

downstream users should not cause the lake levels to be dropped so more water flow could be 

released to downstream users and then create mud flats throughout the lake during droughts. 

(0033-34 (Ruth, Harry)) 

Comment: North Anna is supplied by one of the smallest bodies of water supporting a nuclear 

power plant. And if we add an additional more than 50 percent, unless Dominion has figured a 

way to suspend the laws of physics and chemistry, we are going to have hotter water, we are 

going to have less water, and we are going to have lower levels in the lake. Now, a lot of this 

can be mitigated by keeping the water levels higher, allowing less water to go out over the dam, 
Appendix D 

NUREG-1917, SEIS D-40 February 2010 

et cetera, and I would recommend that the NRC require Dominion to come up with proven 

solutions to the low water conditions before the permits are issued. (0034-222

(Schaible, Dennis)) 

Comment: It is our understanding that when the MWC mode is in effect, it will stay there until 

the water level of the reservoir goes above 250 ft msl. Why on page 2-134 of the FSAR does 

Dominion say While in the MWC mode, the dry tower fans may be turned off to provide 

additional electrical output during hours of peak demand? This is totally against the idea of 

conserving water and the MWC mode. (0036-2 [Remmers, Ken]) 

Response: NRC staff will evaluate new and significant information relating to impacts of plant 

operation on Lake Anna reservoir lake level and discharge to the North Anna River below the 

dam. Water-related impacts of plant operation will be addressed in Chapter 5.3 of the SEIS. 

However, adjustments to reservoir operations are under the authority of the Commonwealth of 

Virginia, not the NRC. 

Comment: In light of the NRC concern with the environmental impact of the third unit, these 

requests are to reduce the environmental impact of the construction and operation of the third 

unit. We want to improve the conservation of the quantity and quality of water in Lake Anna. 

(0014-2 (Murphey, Bill)) 

Comment: I want to emphasize again my outrage that Dominion continues to discharge water 

without an upper temperature limit into Lake Anna’s cooling lagoons. Dominion’s activities are 

not in compliance with the federal Clean Water Act which protects surface waters of the U.S. 

The ill effects of high water temperatures in Lake Anna have been well documented. (0017-9 

(Day, Elena)) 

Comment: Water temperatures have reached as high as 106 degrees F in the Lake Anna 

cooling lagoons and 93 degrees in the main lake. There are no limits on these water 

temperatures. (0023-3 (Black, Betty)) 

Comment: Last Oct. the VA Dept. of Environmental Quality reissued the 316A variance to 

Dominion which permits the utility to continue to dump water used to cool the nuclear generating 

units into Lake Anna without an upper temperature limit. (Last summer temperatures in the so 

called cooling lagoons reached 106 F). This is illegal according to the Clean Water Act since 

the waters of Lake Anna and the streams that feed into the lake are recognized as surface 

waters of the U.S. Currently People’s Alliance for Clean Energy and Blue Ridge Environmental 

Defense League as well as three Louisa County residents are appealing this decision of 

VADEQ. (0026-14 (AuClair-Valdez, Miguel)) 

Comment: The U.S. Clean Water Act appears to have more safeguards for fish, wildlife, 

aquatic life, clams and mussels then for the protection of humans and recreation. VDEQ 

assumes that if the fish are o.k. then everything else must be o.k. There are currently no water 

temperature limits in Fahrenheit imposed in the current Water Discharge permit and its 
Appendix D 

February 2010 D-41 NUREG-1917, SEIS 

316A Variance for the North Anna plant for the current 2 reactors that can be measured by the 

public. Dominion can currently heat the entire lake to any temperature it desires with no 

penalties. (0028-62 (Ruth, Harry)) 

Comment: Lake Anna has currently experienced water temperatures exceeding 104 degrees F 

in some areas in the cooling lagoons and over 93F on the main reservoir with just two nuclear 

reactors operating. The NRC says (1) With the addition of the proposed 3rd reactor cooling 

method (a combination air and water cooling system), that the lake water will evaporate at a rate 

of up to 24 million gallons per day and (2) the water temperature will get hotter faster as the 

water level declines. The VDEQ Water Resources Dept says the water level will decline at an 

additional rate of about 1.1 inches per month when the 3rd unit is operating and the water level 

is below 250 MSL. (0028-70, 0033-79 (Ruth, Harry)) 

Comment: Question?—Can we take the chance that one of our loved ones will get sick or die 

because the water temperatures in Lake Anna which are currently at high levels in the summer 

months and will be increased further because of the up to 24 million gallons a day additional 

evaporation from the 3rd reactor cooling method than what they currently are from the existing 

two reactors?? Why? Because the water level will decline and there will be less water to cool 

the heat from the two current reactors causing the water to get hotter starting earlier in the 

summer and increasing temperatures throughout the summer and extending further into the fall. 

A simple analogy for the heating of water faster can be made with the fact that heating a cup of 

coffee will occur much faster than for heating a whole cup of coffee. If Dominion changed its 

proposed 3rd reactor cooling method to dry cooling (which they proposed for Unit 4 and is 

currently used in many places throughout the world), then the 3rd reactor cooling method would 

not further impact the hot water temperatures during the summer months in Lake Anna. (0028-

73, 0033-82 (Ruth, Harry)) 

Comment: The NRC in its DEIS should evaluate the new significant information from other 

U.S. states and governing bodies regarding national trends to reduce the water temperatures 

and the use of water from power plants to protect humans, fish, and wildlife. West Virginia in 

2008 issued a draft permit for Mt. Storm in the future (which is similar to Lake Anna) that 

imposed different water temperature restrictions measured in Fahrenheit degrees depending on 

the time of year. (In winter 1 Dec -30 Apr—a maximum discharge water temperature of 

73 degrees F (with a 5 degree differential between input and output, while in the summer (1 May 

-30 Nov) a maximum discharge water temperature of 87 degrees F, with no more than a 

5 degree temperature differential between input and output. Likewise New York is permitting 

only dry cooling on any new power plants on the Hudson River to insure that no additional heat 

is introduced to the Hudson River. Arizona and California are also imposing very strict 

restrictions on the use of water and adding heat to the water. Since the 3rd unit at North Anna 

will be in existence for probably the next 40 to 50 years, now is the time for Dominion to make 

the necessary changes in its cooling methods to reduce water consumption to be in front of or in 

line with the national curve and negate any additional heat being placed in Lake Anna to protect 

the Lake Anna environment for future generations. (0033-16 (Ruth, Harry)) 
Appendix D 

NUREG-1917, SEIS D-42 February 2010 

Comment: The U.S. Clean Water Act appears to have more safeguards for fish, wildlife, 

aquatic life, clams and mussels then for the protection of humans and recreation. VDEQ 

assumes that if the fish are o.k.—then everything else must be o.k. There are currently no 

water temperature limits in Fahrenheit imposed in the current Water Discharge permit and its 

316A Variance for the North Anna plant for the current 2 reactors that can be measured by the 

public. Dominion can currently heat the entire lake to any temperature it desires with no 

penalties. (0033-71 (Ruth, Harry)) 

Comment: Water level decrease—According to the Nuclear Regulatory Commission 

Environmental Report (See Page 5.12) says: Because the Unit 3 Cooling tower would consume 

water (up to 28 Million Gallons per day -see Section 3.2), the volume of water in Lake Anna 

would be reduced (compared to operation of only Units I and 2 alone) when the lake level 

elevation is below 250 ft MSL. Assuming the heat rejection rate from operations of Units 1 and 

2 remains constant, the reduced volume of water in the lake caused by Unit 3 operations would 

result in a faster increase of lake water temperature (See Page 5.12). (0033-72 (Ruth, Harry)) 

Comment: In October 2007, the Virginia Department of Environmental Quality (VDEQ) has 

granted a water discharge permit to Dominion that has imposed no water temperature limits in 

Fahrenheit that can be measured by the public at the North Anna plant for the current two 

operating nuclear units. In addition, VDEQ has granted Dominion a 316A Variance from the 

U.S. Clean Water Act which allows them legally to heat the entire lake to any temperature that 

they desire without any penalties. 

8. Microcystis Algae Bloom Facts—Note that Algae Blooms occur in Lake Anna every summer 

when the lake water gets hot. (0033-78 (Ruth, Harry)) 

Comment: While I was Manager of Water Quality at Dominion, the 316(A) temperature study of 

Lake Anna was completed and approved by the regulatory agencies. The company has agreed 

to change their water cooling design to a closed loop, hybrid system, instead of an open 

system, to minimize thermal impacts on Lake Anna. (0034-103 (Marshall, Burton)) 

Comment: I am outraged that Dominion continues to discharge water without an upper 

temperature limit into Lake Anna’s cooling lagoons. Dominion’s activities are not in compliance 

with the federal Clean Water Act, which protects surface waters of the United States. And, 

indeed, the waters of Lake Anna are surface waters of the United States. The ill effects of high 

water temperatures in Lake Anna have been well-documented. It’s irresponsible again for 

Dominion and the NRC to continue with an application to site new nukes on an already 

environmentally and hydrologically stressed watershed. And soon you’re going to find us 

humans competing with the nuclear reactors for water, for our sustenance. (0034-142

(Day, Elena)) 

Comment: The North Anna Power Station already threatens the water resources of this region. 

One, water temperatures have reached as high as 106 degrees Fahrenheit in the Lake Anna 

cooling lagoons and 93 degrees in the main lake. There are no limits on these water 

temperatures. (0034-149 (Black, Betty)) 
Appendix D 

February 2010 D-43 NUREG-1917, SEIS 

Comment: Last October the Virginia Department of Environmental Quality reissued the 316(a) 

variance to Dominion, which permitted the utility to continue to dump water used to cool the 

nuclear generating units at Lake Anna, which have been discussed. There has been reference 

to the cooling lagoon, reaching temperatures of 106 degrees Fahrenheit. Now, as a retired 

administrative law judge, it would seem to me that if we go with the same standards that the 

applicants used when they first came in, we are missing the point. I can’t imagine that Dominion 

came in and say, You know, we’ve got this great cooling system. We’re going to have 106-

degree Fahrenheit water in our cooling lagoons. I can’t imagine they said that. So they have 

proven, in fact, that there are some real suspect operations in terms of what they are doing. So 

if the NRC again uses this neutral kind of standard with somebody who already has one strike 

against them, they’re missing the boat. They’ve go to say, Look, the applicant has not 

performed satisfactorily in the past. The stakes are so high we are actually going to have a 

presumption against them. And until they can come up with convincing evidence to the 

contrary, they’re not going to get a pass from us. (0034-157 (AuClair-Valdez, Miguel)) 

Comment: The other thing is that this temperature is in violation of the Clean Water Act since 

Lake Anna, as has been pointed out, is surface water of the U.S. (0034-158 (AuClair-Valdez, 

Miguel)) 

Comment: Now that the economically simplified boiling water reactor has been selected by 

Dominion, the issue of cooling the third reactor can now carefully be reviewed. The once 

passthrough cooling was rejected in the EIS ESP because of the water temperature. It heated 

the lake up too much. The current proposed cooling is a combination of wet/dry cooling tower, 

which introduces significant evaporation of the water in Lake Anna reservoir, up to 16.6 million 

gallons a day of water in the maximum water conservation mode. Several state agencies—

DGIF, VDEQ, Division of Water Resources, DCR, and many other public sources such as the 

Lake Level Task Force Committee, which is a group of organizations and associations around 

the lake—LACA, FOLA, LABERA, and many other businesses around the lake—have objected 

to this high evaporation rate. It takes away the water in the lake very significantly. (0034-31

(Remmers, Ken)) 

Comment: Plan 3 was considered in a stand-alone condition. No consideration was made for 

the alternative of installing additional water conservation measures to the existing power 

reactors of Units 1 and 2, to compensate or mitigate against the significant, adverse, 

incremental impacts caused by Unit 3. (0034-34 (Remmers, Ken)) 

Comment: The new reactor at North Anna will not increase the temperature of Lake Anna. 

After concerns were raised by—of the potential thermal impact of a new reactor, Dominion 

committed to change the design to include cooling towers. (0034-51 (O’Hanlon, Jim)) 

Comment: The adverse impact of the new unit on Lake Anna will be minimal. Dominion has 

already committed to install a $200 million cooling system to that new unit, so that the power 

station will not increase the temperature of the water it feeds into the lake. (0034-7

(Watkins, John)) 
Appendix D 

NUREG-1917, SEIS D-44 February 2010 

Comment: Chapter 3 mentions blowdown and other discharges. Will the applicant stipulate to 

a 100 degree thermal discharge limit as an operating permit condition as requested by the 

Waterside Property Owners Association? Will the applicant stipulate to a 104 degree limit at the 

end of the discharge canal as requested by Friends of Lake Anna? 0035-17 (Goldsmith, Aviv)) 

Comment: Wouldn’t the installation of new unit(s) be an opportunity to mitigate some of the 

existing problems with water temperature and lake level? 0035-25 (Goldsmith, Aviv)) 

Response: NRC staff will evaluate the Unit 3 plant water use, cooling system operation, and 

effluent discharge descriptions in the COL application relative to the plant parameter envelope 

committed to by Dominion and approved by NRC as part of the ESP. New and significant 

information will be reviewed to determine whether there are any changes to the impacts of plant 

operation on water use and water quality, including temperature. The environmental impacts of 

construction on water use and water quality will be addressed in Chapter 4.3 of the SEIS; 

impacts of plant operation will be addressed in Chapter 5.3 of the SEIS. Related ecological, 

socioeconomic, and human health impacts of plant operation will be addressed in Chapters 5.4, 

5.5, and 5.8, respectively, of the SEIS. The NRC does not have the authority to set water 

quality limits; plant effluent discharges will continue to be regulated by the Commonwealth of

Virginia-VDEQ. 

Comment: Wrt [with respect to] Section 316(b), DGIF recommended a 2 mm screen intake 

with intake velocity of 0.25 fps. What is the design of this intake screen currently by Dominion? 

Will they comply with the bmp recommended by DGIF? (0036-4 (Remmers, Ken)) 

Response: NRC staff will consider these comments in its review of new and significant 

information related to proposed plant cooling system design and water use, which will be 

addressed in Chapter 3 of the SEIS. 

Comment: It appears that there are major discrepancies in the water sections. In numerous 

places the SDEIS asserted that data was lacking or simplified methodologies were used. (See 

for example Page 1-6 which states inter alia insufficient information was available “to allow the 

NRC staff to complete its independent analysis” and “these issues are not resolved for the North 

Anna ESP site”). (0035-1 (Goldsmith, Aviv)) 

Comment: As evidenced from the recent public hearing, water use and impacts on lake level 

and downstream flow are major areas of concern. The SDEIS (see Table 10-3 e.g.) that the 

impacts of water use and quality are “unresolved” is not sufficient to make a determination of the 

project’s acceptability. Perhaps a solution is to commission a truly unbiased third party water 

study to provide better methodology and data for impact assessments. This study could be 

incorporated into a new DEIS. (0035-2 (Goldsmith, Aviv)) 

Comment: The SDEIS continues to be very troubling regarding water analysis. It states that 

the assessments “are based on a simplified representation of the conservation of mass for the 

lake.” This excludes water temperature stratifications and the flow contributions from a many of 
Appendix D 

February 2010 D-45 NUREG-1917, SEIS 

the tributaries. How then, can the impact forecasts of SMALL be reliable? How can “no 

mitigation” be a reasonable solution? (0035-22 (Goldsmith, Aviv)) 

Comment: SDEIS page 5-7 line 26 concluded that “relatively small errors in the pool elevation 

measurements using this model can result in significant errors in the precipitation, groundwater, 

and tributary inflow estimate.” How then, can the impact forecasts of SMALL be reliable? How 

can “no mitigation” be a reasonable solution? Perhaps an independent comprehensive water 

study would provide more robust impact assessments. (0035-23 (Goldsmith, Aviv)) 

Comment: The determination in Table 10-3 and elsewhere that the impacts on water use and 

quality is “likely to be SMALL” is unsubstantiated. As was clear from the last public hearing, the 

public’s perception is that the impacts are LARGE. (0035-48 [Goldsmith, Aviv]) 

Response: This comment refers to the North Anna draft ESP EIS that was superseded by the 

North Anna final ESP EIS (NUREG-1811) published by NRC in December 2006. NUREG-1811 

was revised to incorporate numerous public comments (see NUREG-1811, Appendix E) and an 

independent water budget analysis (NUREG-1811, Appendix K). Dominion was issued an ESP 

permit (ESP-003) in November 2007 for two units at the North Anna Power Station site under 

the specifications contained in that permit. All environmental issues related to the ESP 

application from Dominion were identified, evaluated, and resolved or proposed mitigation 

actions were identified. In Chapter 5.3 of the SEIS, NRC staff will evaluate any new and 

significant information pertaining to the water-related impacts of plant operation to determine 

whether the impact level has changed from NUREG-1811, ESP EIS. 

Comment: In the FEIS for the ESP, it is stated that The MWC mode would be used when Lake 

Anna is below 250 ft msl for seven consecutive days. DGIF requested a change in this 

schedule to less than seven days and even when the level is above 250 ft msl during certain 

critical periods. In the submitted Rev 0 of the COLA Final Safety Analysis, page 2-133, 

Dominion states if the reservoir water level falls below Elevation 76.2 m (250 ft) msl and is not 

restored within a reasonable period of time, the MWC mode is used. Why is the seven 

continuous days eliminated from discussion and why is the DGIF request ignored? (0036-1

(Remmers, Ken)) 

Comment: Why are the Cooling Tower discussions in the FSAR and not in the EIS? Cooling 

tower discussions were unresolved in the FEIS of the ESP. The IFIM results could impact the 

amount of water released over the dam as well as any studies of the reservoir levels in the lake 

itself wrt recreation and safety. NRC should require Dominion put all cooling tower issues in the 

EIS. This is new and significant information and the NRC should open and address this issue of 

cooling methods used by Dominion for Unit #3. There may be insufficient water in the reservoir 

depending on the final IFIM recommendations. Virginia Coastal may not find the project in 

compliance and may not issue a certification. (0036-3 (Remmers, Ken)) 

Response: NRC staff will evaluate the Unit 3 plant water use, cooling system operation, and 

effluent discharge descriptions in the COL application relative to the plant parameter envelope 

committed to by Dominion and approved by NRC as part of the ESP. Staff will evaluate new 
Appendix D 

NUREG-1917, SEIS D-46 February 2010 

and significant information relating to impacts of plant operation on Lake Anna reservoir lake 

level and discharge to the North Anna River below the dam, including any information available 

from the IFIM study. Water-related impacts of plant operation will be addressed in Chapter 5.3 

of the SEIS. However, adjustments to reservoir operations are under the authority of the 

Commonwealth of Virginia VDEQ, not the NRC. 

Comment: Shouldn’t the operator’s role in decisions to change the normal lake level 

(Page 5-11, line 28 et. seq.) be one of conditions of the COL? Just because “modifications to 

the water release regime from the Lake Anna Dam to mitigate impacts would be under the 

jurisdiction of VDEQ” Page 5-33 line 14), does not absolve the operator or the NRC from 

adopting reasonable mitigation measures which could be subject to VDEQ approval. (0035-24

(Goldsmith, Aviv)) 

Response: This comment refers to information in the North Anna draft ESP EIS that was 

superseded by the North Anna final ESP EIS (NUREG-1811) published by NRC in 

December 2006. NUREG-1811 was revised to incorporate numerous public comments 

(see NUREG-1811, Appendix E). Dominion was issued an ESP permit (ESP-003) in 

November 2007 for two units at the North Anna Power Station site under the specifications 

contained in that permit. In Chapter 5.3 of the SEIS, NRC staff will evaluate any new and 

significant information relating to impacts of plant operation on Lake Anna reservoir lake level to 

determine whether the impact level has changed from NUREG-1811, ESP EIS. Adjustments to 

reservoir operations affecting lake water level are under the authority of the Commonwealth of 

Virginia VDEQ, not the NRC. 

Comment: “Consumptive water losses may noticeably impact lake levels and downstream 

flows.” This is a major area of local concern and should be more thoroughly analyzed and 

documented. It is hard to understand how an impact assessment of SMALL is derived from the 

discussion. It seems like the impacts are at least MODERATE and potentially LARGE. 

(0035-29 (Goldsmith, Aviv)) 

Response: This comment refers to information in the North Anna draft ESP EIS that was 

superseded by the North Anna final ESP EIS (NUREG-1811) published by NRC in 

December 2006. NUREG-1811 was revised to incorporate numerous public comments 

(see NUREG-1811, Appendix E). Dominion was issued an ESP permit (ESP-003) in 

November 2007 for two units at the North Anna Power Station site under the specifications 

contained in that permit. Under conditions of the ESP permit, Dominion is required to conduct 

an Instream Flow Incremental Methodology (IFIM) study that is designed and monitored in 

cooperation and consultation with the Virginia Department of Game and Inland Fisheries 

(VDGIF) and the Virginia Department of Environmental Quality (VDEQ) to address potential 

impacts of the proposed units on the aquatic resources of Lake Anna and downstream waters. 

This study must be completed prior to issuance of a combined license for any new units at 

NAPS. In Chapter 5 of the SEIS, NRC staff will evaluate any new and significant information 

pertaining to the water-related and aquatic resource impacts of plant operation to determine 

whether the impact level has changed from NUREG-1811, ESP EIS. 
Appendix D 

February 2010 D-47 NUREG-1917, SEIS 

Comment: Shouldn’t the WHTF be subject to Clean Water Act and DEQ standards? It is fed 

by eight public streams and should be treated as public waters. (0035-26 (Goldsmith, Aviv)) 

Response: In the Commonwealth of Virginia, the U.S. Environmental Protection Agency has 

granted VDEQ authority for regulating water quality under the Clean Water Act. The 

Commonwealth has determined that the WHTF for the plant’s thermal discharge is subject to 

the “waste treatment system” exclusion in the 9 VAC 25-31-10 definition of “surface waters.” 

VDEQ does not have authority to regulate the treatment facility itself, but VDEQ does regulate 

discharges from the WHTF into Lake Anna. For Chapter 5 of the SEIS, staff will review new 

and significant information related to the water quality impacts of Unit 3 plant operation to 

determine whether there is any change to the impact levels determined in NUREG-1811, 

ESP EIS. 

7. Comments Concerning Hydrology – Groundwater

None of the comments in this area were considered in scope. 

8. Comments Concerning Ecology - Terrestrial

Comment: We [VDGIF] have reviewed the proposed corridor for the additional 500kV line 

required to carry the output of the existing Lake Anna units and the proposed third unit. We do 

not currently document any listed wildlife or resources under our jurisdiction from the project 

area. Therefore, impacts upon such species and resources are not likely to result from the 

construction of this line. In addition, as this new line will be co-located within an existing power 

line corridor, it does not appear that significant wildlife habitat alterations will occur. (0032-1

(Ewing, Amy)) 

Response: The comment concerns terrestrial ecology issues and state listed species, and 

provides information relevant to the description of existing resources that will be provided in 

Chapter 2 of the SEIS. Impacts of construction of the plant and transmission line will be 

considered in Chapter 4, and the impacts of operation of the plant and transmission line will be 

considered in Chapter 5 of the SEIS.

Comment: Does the feeding range of bald eagles or loggerhead strikes extend to the North 

Anna vicinity (Page 213 line 32)? (0035-13 (Goldsmith, Aviv)) 

Comment: Section 4.4.3 line 35 acknowledged that bald eagles nest as close as 2.5 miles to 

the site. What effect will the project have on fish that the eagles may use as a food source? 

(0035-18 (Goldsmith, Aviv)) 

Response: Both the bald eagle and the loggerhead shrike would be expected to feed in the 

vicinity of NAPS Unit 3. NUREG-1811, ESP EIS determined that construction and operation of 

the proposed ESP facilities would have a SMALL impact on species of concern, including the 

eagle and shrike. The staff will evaluate whether there is any new and significant information 

concerning impacts to these species and will describe any changes to NUREG-1811, ESP EIS 
Appendix D 

NUREG-1917, SEIS D-48 February 2010 

conclusions in Chapters 4.4 and 5.4 of the SEIS. Potential effects of plant operations on fish 

populations were considered in Chapter 5.4.2 of NUREG-1811, ESP EIS and new and 

significant information relevant to these impacts will be evaluated for Chapter 5.4 of the SEIS. 

9. Comments Concerning Ecology - Aquatic

Comment: We recommend that all land disturbing activities adhere to erosion and sediment 

controls. We recommend conducting any in-stream activities during low or no-flow conditions, 

using non-erodible cofferdams to isolate the construction area, blocking no more than 50% of 

the streamflow at any given time, stockpiling excavated material in a manner that prevents 

reentry into the stream, restoring original streambed and streambank contours, revegetating 

barren areas with native vegetation, and implementing strict erosion and sediment control 

measures. Due to future maintenance costs associated with culverts, and the loss of riparian 

and aquatic habitat, we prefer stream crossings to be constructed via clear-span bridges. 

(0032-2 (Ewing, Amy)) 

Response: These recommendations will be considered; construction impacts will be addressed 

in Chapter 4 of the SEIS.

Comment: Sterile Grass Carp were introduced to assist in controlling the hydrilla. The grass 

carp life span was projected to be 15 years and that is just a few years away. (0028-21, 

0033-24 (Ruth, Harry)) 

Response: The staff will review new information regarding the current and planned activities 

associated with stocking the reservoir and incorporate this information into the SEIS.

Comment: The DEIS should examine the impact of declining Lake Anna Water levels on the 

wetlands and feeder streams throughout both the main reservoir and cooling lagoons of the 

lake. What will happen to the fish and wildlife that currently depend on the wetlands for 

survival? The DEIS should look at how long it takes to reestablish life forms at new water levels 

and the impact of increasing the range of variation of levels on the wetland areas. The ESP EIS 

identified that a cursory check had been accomplished and concluded that changes in the lake 

level result in creation of as much wildlife as is inundated or destroyed, hence low impact. A 

more comprehensive survey must now be accomplished. (0028-22 (Ruth, Harry)) 

Comment: Fish, aquatic life, clams, mussels and wildlife may be adversely impacted with less 

lake water which is also hotter in the summer months. (0028-40, 0033-48 (Ruth, Harry)) 

Comment: Fish, aquatic life, clams, mussels, and wildlife may be adversely impacted with less 

water and therefore hotter water because Units 1 & 2 cooling will still generate the same heat as 

today, but will have less water to cool it and the result will be hotter water. (0028-50, 0033-59

(Ruth, Harry)) 
Appendix D 

February 2010 D-49 NUREG-1917, SEIS 

Comment: We are also concerned that these declining water levels will cause the water to get 

hotter faster in the summer months to unsafe water temperatures causing negative impacts to 

humans, recreation, fish, wildlife, aquatic life, clams and mussels. (0028-61, 0033-70

(Ruth, Harry)) 

Comment: The NRC in its DEIS should examine the impact of declining Lake Anna Water 

levels on the wetlands and feeder streams throughout both the main reservoir and cooling 

lagoons of the lake and the additional human health impact of mosquito’s breeding in the 

stagnant water in the wetlands. What will happen to the fish and wildlife that currently depend 

on the wetlands for survival? The DEIS should look at how long it takes to reestablish life forms 

at new water levels and the impact of increasing the range of variation of levels on the wetland 

areas. The ESP EIS previously identified that a cursory check had been accomplished and 

concluded that changes in the lake level result in creation of as much wildlife as is inundated or 

destroyed, hence low impact. It also appears that no one previously investigated the human 

health impact of mosquito’s breeding in the stagnant water caused by declining water levels. 

(0033-26 (Ruth, Harry)) 

Comment: The ESP EIS claims that wetlands impact is small because as much wetland is 

created as is destroyed, but is silent about the impact of what appears to be an almost annual 

reduction to the 248-foot level. The NRC should review modeling done in the environmental 

impact statement to incorporate new actual data and do further analysis of deviations from the 

20-year averages. Additionally, inflow assumptions have not been field-verified and should be 

reviewed. Dominion has developed new data, including actual surveys of a portion of the 

wetlands on the lake. We ask that NRC carefully review and use this new data to determine if it 

alters its earlier impact assessment. Additional steps can and should be taken to mitigate low 

water level impact on safety, erosion, and ecosystems on the lake. (0034-185 (Smith, Doug)) 

Comment: Other impacts are unsafe water conditions, which occur at low water levels; boating 

hazards; shoreline stabilization issues; impact to wetlands; and impacts to business and home 

values. (0034-194 (Heino, George and Gerry)) 

Response: The impacts of temperature and low water levels on Lake Anna wetlands and 

aquatic resources were previously resolved in NUREG-1811, ESP EIS. The staff will evaluate 

new information, including any revision to the water budget, to determine whether the impact 

levels previously stated should be changed. The impacts of plant operation on aquatic 

resources will be discussed in Chapter 5.4 of the North Anna Unit 3 SEIS. Related impacts on 

recreation and human health will be discussed in Chapter 5.5 and 5.8, respectively, of the SEIS.

Comment: A major clam die-off occurred last year, but no study has been conducted by a 

certified malacologist to determine the health of the mussels and clams in Lake Anna. (0023-6, 

0034-152 (Black, Betty)) 

Comment: The SDEIS should also include the results of a professionally conducted total 

Clam/Mussel Survey of the entire Lake Anna as was previously requested by Brian Watson, the 

DGIF Wildlife Diversity Biologist/Malacologist. Apparently this study has never been completed. 
Appendix D 

NUREG-1917, SEIS D-50 February 2010 

According to Brian Watson (Phone 434-525-7522) a clam/mussel survey should be conducted 

by a Virginia State certified malacologist and should be current within the last 2 year time 

period. Mr. Watson has identified that the Asian clam (Corbicula fluminea), Eastern elliptio 

(Elliptio complanata), Paper pondshell (Uterbackia imbecillis) and Easter Floater (Pyganodon 

cataracta) are resident in Lake Anna. In addition, he is concerned about the potential impacts 

of elevated water temperatures upon native freshwater mussels and that other freshwater rare 

species mussels (Yellow lampmussel lampsilis cariosa), (eastern lampmussel lampsilis radiata, 

Eastern pondmussel liguimia nasuta) and the (Tidewater mucket-leptodea ochraces) which are 

rare species may also be present. This study needs to be done and now is the time to do it 

before irreparable harm is done. (0028-16, 0033-25 (Ruth, Harry)) 

Response: The staff will evaluate new investigation and monitoring information relating to 

aquatic resources, to determine whether the impact levels previously analyzed in NUREG-1811, 

ESP EIS should be changed. The impacts of plant construction and operation on aquatic 

resources will be discussed in Chapter 4.4 and 5.4 of the SEIS.

Comment: Both VDEQ and DGIF, in conjunction with Dominion Resources are currently 

conducting an Instream Flow Incremental Methodology (IFIM) study on Lake Anna and the 

North Anna River and Pamunkey Rivers downstream to determine the effects of the reduced 

water flow on recreation, wildlife, aquatic life and fish as part of the conditional certification for 

the 3rd reactor Early Site Permit (ESP). This IFIM study must also address all of the comments 

made by the VA Dept of Conservation and Recreation (DCR). This IFIM study should be 

completed before any Draft Environmental Impact Statement for the COL is issued by the NRC 

so all the results of the IFIM study can be reviewed and commented on by the public. 

Otherwise the results from this important study will cause much re-work later by the NRC, 

Virginia and the public and waste much time. Currently there is no public participation in the 

study plan or results. (0028-8 (Ruth, Harry)) 

Comment: The IFIM Study will be completed in June and should be studied and analyzed as a 

part of the new EIS. Dominion has been directed to conduct a scientific study called the 

Instream Flow Incremental Methodology study. DEQ, DGIF, and DCR are providing input and 

supervision. This study looks at both Lake Anna and the downstream rivers (North Anna and 

Pamunkey) and will provide much guidance and valuable information which needs to be 

evaluated before a COLA can be granted. (0031-11 (Crawford, Barbara)) 

Comment: The referenced IFIM study should be completed in draft only before any Draft 

Environmental Impact Statement for the COL is issued by the NRC so all the results of the IFIM 

study can be reviewed and commented on by the public. Otherwise the results from this 

important study will cause much re-work later by the NRC, Virginia and the public which will 

waste much time. Currently there is no public participation in the study plan or results. DCR, 

VDEQ, and DGIF, in conjunction with Dominion Resources are currently conducting an 

In-stream Flow Incremental Methodology (IFIM) study on Lake Anna and the North Anna River 

and Pamunkey Rivers downstream to determine the effects of the reduced water flow on 

recreation, wildlife, aquatic life and fish as part of the conditional certification for the 3rd reactor 

Early Site Permit (ESP). This IFIM study must also address all of the comments made by the 
Appendix D 

February 2010 D-51 NUREG-1917, SEIS 

VA Dept. of Conservation and Recreation (DCR) as to the total lake and recreation on the lake, 

as well as public review of the study. (0033-6 (Ruth, Harry)) 

Response: Under conditions of the ESP permit (ESP-003), Dominion is required to conduct an 

Instream Flow Incremental Methodology (IFIM) study that is designed and monitored in 

cooperation and consultation with the Virginia Department of Game and Inland Fisheries 

(VDGIF) and the Virginia Department of Environmental Quality (VDEQ) to address potential 

impacts of the proposed units on the fishes and other aquatic resources of Lake Anna and 

downstream waters. This study must be completed prior to issuance of a combined license for 

any new units at NAPS. Dominion agreed to consult both with VDGIF and VDEQ regarding 

surface water management, release, and instream flow conditions prescribed by VDGIF and 

VDEQ as implemented through appropriate state or Federal permits or licenses. Public 

involvement in the study plan and review of the results is the responsibility of the VDGIF and 

VDEQ, not the NRC. NRC staff, however, will monitor the progress related to completion of the 

study and results obtained. Any information that is available regarding the IFIM study at the 

time the SEIS is prepared will be included as part of Chapter 2.7.

Comment: Page 5-24 states that “larval abundance is not known” and that a 1978 model was 

used for the estimation. How good is the estimation? Couldn’t representative sampling give an 

estimate of larval abundance? (0035-27 (Goldsmith, Aviv)) 

Comment: Page 5-27 discusses cold shock and says that it will be less of a problem with a 

multiple unit plant. This is only true if the entire station does not shut down. If the remaining 

unit or units shut down, the cold shock will be much more severe due to the loss of a huge 

thermal load. (0035-28 (Goldsmith, Aviv)) 

Response: These comments refer to information in the North Anna draft ESP EIS that was 

superseded by the North Anna final ESP EIS (NUREG-1811) published by NRC in 

December 2006. NUREG-1811 was revised to incorporate numerous public comments 

(see NUREG-1811, Appendix E). Dominion was issued an ESP permit (ESP-003) in 

November 2007 for two units at the North Anna Power Station site under the specifications 

contained in that permit. All environmental issues related to the ESP application from Dominion 

were identified, evaluated, and resolved or proposed mitigation actions were identified. The 

impacts to aquatic resources were discussed and resolved in Chapters 4.4, 5.4, and 7.5 of the 

ESP EIS (NUREG-1811). Staff will evaluate new investigation and monitoring information 

relating to aquatic resources, to determine whether the impact levels previously stated should 

be changed. The impacts of plant construction and operation on aquatic resources will be 

discussed in Chapter 4.4 and 5.4 of the North Anna Unit 3 COL SEIS. 

10. Comments Concerning Socioeconomics

Comment: The first item is the number of workers and residents using Route 652, Kentucky 

Springs Road. It is our understanding that North Anna Power Station employs approximately 

800 permanent workers and every 18 months brings in an additional 1,000 workers during its 

outages. If Unit 3 is approved, there would be a need for approximately 2,000 employees 
Appendix D 

NUREG-1917, SEIS D-52 February 2010 

during the construction phase. When Unit 3 is complete and operational, North Anna Power 

Station would employ approximately 1500 full time employees and still require additional 

workers every 18 months. There are dozens of multi-lot subdivisions along Route 652. The 

Waters Subdivision is a 400 lot development within a few miles of the plant. Cutalong is a 

mixed use development, that at full build out, will have over 1000 dwellings, a golf course and 

commercial retail space at the intersection of Route 652 and Route 208. There will be severe 

traffic congestion with that many people traveling a two-lane country road. While there will be 

long economic benefits to the County, those effects will not be felt until construction of Unit 3 

begins and well thereafter. Louisa County needs to know what Dominion Power is doing for the 

increase of vehicles on Route 652? (0015-2 (Lintecum, Lee)) 

Comment: Dominion has stated that it would be willing to work cooperatively with state and 

county governments to facilitate planning decision to minimize transportation impacts to avoid 

congestion and they would develop a construction management traffic plan prior to the start of 

construction. If widening Route 652 to handle the massive increase in traffic is required, 

planning needs to begin now. (0015-3 (Lintecum, Lee)) 

Comment: Secondly, there would be a major influx of new people into Louisa County resulting 

in the need for new schools. Louisa County is currently building a new elementary school that 

will house 700 students. Even with the addition of this school, our elementary system will still 

be at maximum capacity. Louisa County Public Schools is currently working on a school 

construction plan, but needs more information about the impact of Unit 3 for that plan. (0015-4

(Lintecum, Lee)) 

Comment: The County understands that because of the nature of the construction industry, 

with a variety of employee skill sets required, many employees will be transient but Louisa 

County has a tremendous wealth of attractants that many employees may make Louisa their 

permanent home. Since energy is a national priority, with a focus on nuclear energy, then 

possibly school construction grants can be provided by the Federal government to assist with 

new school construction. Again, if we are not prepared for the impact on our community’s 

infrastructure, the County will have to play catch up, which will cost more in the long run. (0015-

5 (Lintecum, Lee)) 

Comment: Why there is a discrepancy of the ESP defining of 5000-7000 new workers 

(construction, periodic maintenance, professional) employees for 5 years on local roads and 

schools and now Dominion is saying there will only be 2000 workers involved with the 

3rd reactor. In any case, the COL DEIS should evaluate these new worker impacts on the need 

for new expanded and improved roads before the project begins because of the heavy 

equipment, large number of workers and the three newly approved Louisa County subdivisions 

for about 1800 new homes in close proximity to the plant. (0028-29 (Ruth, Harry)) 

Comment: New schools and other county infrastructure (police, fire, rescue squads, etc.) will 

need to be planned and built prior to any new tax dollars coming from Dominion. Louisa is now 

the 73rd fastest growing county in the U.S. Louisa and Spotsylvania are centrally located 

between three major fast growing metropolitan areas (Washington D.C., Richmond, and 
Appendix D 

February 2010 D-53 NUREG-1917, SEIS 

Charlottesville, VA). Who is going to pay for all these new requirements? Is the Federal 

Government (NRC & other departments) going to give grants to Louisa and Spotsylvania 

Counties, similar to the 8 to 10 million dollar grant they gave to Dominion for processing the 

Early Site Permit? (0028-30, 0033-38 (Ruth, Harry)) 

Comment: Emergency evacuation on small 2 lane roads. Need for expanded road system to 

accommodate new workers, heavy construction equipment and subdivisions. (0028-31

(Ruth, Harry)) 

Comment: The previous EIS calls the impacts of building a new reactor on Louisa County’s 

infrastructure small. This is absurd and must be revisited as part of the new EIS. This is not a 

wealthy county. Our schools will be overwhelmed and unable to serve the children of the 

estimated 5000 workers who would be employed for a period of five years to build the 

3rd reactor, in addition to the 850 people who work there now and the special crews that come 

to North Anna for the intermittent outages. Our roads are narrow, winding, 2-lane and unable to 

handle the new traffic. The construction equipment and materials would be heavy and 

damaging. Dominion has been directed to conduct a Traffic Impact Analysis. Have they done 

this? The results should be made available to the public. The new EIS should evaluate the 

results and set forth exactly what improvements Dominion will be expected to make. (0031-12

(Crawford, Barbara)) 

Comment: One is the State Route 652 Kentucky Springs Road, which is a two-lane road. And 

with the construction that is going to happen, and with the—and then afterwards with the 

additional workers that we’re going to be able to enjoy, the question is, you know, is that road 

adequate enough to handle the traffic that’s coming? And we have more development coming 

in that area, as it is—Lake Anna is one of the growth areas in Louisa County, and we’re going to 

have to face these problems. Obviously, the state currently is not in a position to help us with 

roads, so we’re having to try to figure it out ourselves. (0034-11 (Lintecum, Lee)) 

Comment: The second issue has to do with our school population. We’re getting ready to 

build our fourth elementary school, and when it’s built it will already be full. So we’re wondering 

about this influx of new people, about how to play catch up in our school construction, and what 

may be available to help us on that. (0034-12 (Lintecum, Lee)) 

Response: Impacts of North Anna Unit 3 plant construction and operation on the utilization of 

existing local infrastructure or need for new infrastructure are within the scope of the 

socioeconomic impacts to be addressed in the SEIS. Impacts related to socioeconomics 

previously resolved in NUREG-1811, ESP EIS will be evaluated in terms of new and significant 

information to determine if impact levels should be changed.

Comment: The Lake Anna region has been designated a growth area in the County’s 

Comprehensive Plan. In view of the annual low water level in Lake Anna and potential needs 

for water sources in the immediate future, Louisa County has recently begun a study to identify 
Appendix D 

NUREG-1917, SEIS D-54 February 2010 

potential water supplies for our citizens. Lake Anna and its tributaries have been identified as 

potential water resources for this ever-growing population center of our County. (0015-6

(Lintecum, Lee)) 

Comment: The previous EIS stated that there were no new or anticipated residential, business 

or commercial demands on the watershed near the plant. This is incorrect. It was known, or 

should have been known based on documentation submitted to you, that there are 3 significant 

residential developments in the works, including Cutalong which is building a golf course that 

will require significant water withdrawals from Contrary Creek, one of the feeder streams for the 

power plant. Note that the DEQ has recommended this permit be granted. In addition, there 

are at least 3 businesses that I know of, near the plant that require significant water use: 

Argonaut, Martin Marietta, and a shopping center with supermarket at Cutalong, all of which 

require water in order to operate. Again, the new EIS needs to look closely at these competing 

demands for water in an area that has very little of it. The new EIS needs to reevaluate the 

availability of water for a 3rd reactor. (0031-10 (Crawford, Barbara)) 

Comment: The previous EIS looked at the 3 counties bordering the lake, plus Henrico County 

and the City of Richmond. Considering that the water that flows over the dam goes into 

Hanover County and that Hanover County is dependent on that water for sewage treatment 

plants, private businesses such as Big Bear Paper Co. and Kings’ Dominion, and the health and 

recreation uses of the North Anna and Pamunkey Rivers, I would argue that the new EIS should 

take a close and hard look at the impacts on that county. The LLCP or Lake Level Contingency 

Plan is a fragile and contentious balance between Louisa County and Hanover County and 

reflects the competing needs for water. (0031-6 (Crawford, Barbara)) 

Comment: The third concern we have is that, since it is a growth area, we’re going to have to 

someday figure out how to get the public water supply in that area, and what the availability of 

or the tributaries that make up Lake Anna or Lake Anna as a possible water source, we would 

like to discuss those with Dominion. (0034-13 (Lintecum, Lee)) 

Comment: Considering that the water that flows over the dam goes into Hanover County and 

that Hanover County is dependent on that water for sewage treatment plans, private 

businesses, such as Big Bear Paper Company and King’s Dominion, and the health and 

recreational uses of North Anna and Pamunkey Rivers, I would argue that the new EIS should 

take a close and hard look at the impacts on that county. (0034-204 (Crawford, Barbara)) 

Comment: It’s important to bear in mind that when Lake Anna was created, neither Dominion 

nor any governmental body, whether federal, state, or local, in any way discouraged the public 

from purchasing land and building homes around the lake. I would argue that there, therefore, 

exists a responsibility to those homeowners to protect them from the adverse impacts of the 

power station. Okay. There is misinformation in here. It is in my written statements. We have 

three housing developments going up there plus three businesses that are going to use a lot of 

water. You have the information in your hands, and you put down that there was nothing 

planned. I don’t understand how that can happen. (0034-206 (Crawford, Barbara)) 
Appendix D 

February 2010 D-55 NUREG-1917, SEIS 

Response: The effects of population and industry on water demand, in conjunction with North 

Anna Unit 3 plant construction and operations, are within the scope of the SEIS. Impacts 

related to socioeconomics previously resolved in NUREG-1811, ESP EIS will be evaluated in 

terms of new and significant information to determine if impact levels should be changed.

Comment: Why there is a discrepancy of the ESP defining of 5000-7000 new workers 

(construction, periodic maintenance, and professional) employees for 5 years on local roads 

and schools and now Dominion is saying there will only be 2000 workers involved with the 

3rd reactor. In any case, the COL DEIS should evaluate these new worker impacts on the need 

for new expanded and improved roads before the project begins because of the heavy 

equipment, large number of workers and impact on earlier analysis of the three newly approved 

Louisa County subdivisions for about 1800 new homes in close proximity to the plant. (0033-37

(Ruth, Harry)) 

Comment: The new unit will bring 750 new jobs to the local area, additional tax revenues, and 

reduce the dependence on foreign oil, providing enough electricity to provide 375,000 homes. 

(0034-181 (Smith, Doug)) 

Comment: And what I’m here tonight to speak on is this is going to support—once this project 

starts, it’s going to support young kids that want to get in a trade, to learn a trade, which it can 

support them the rest of their life for their families. (0034-19 (Rigali, Tony)) 

Comment: North Anna 3 could—is an economic engine for Louisa County and the 

Commonwealth as a whole. And Dominion—if Dominion were to build this new nuclear unit at 

North Anna, the company would expect a workforce for more than 3000 construction workers, 

and that’s pretty much what it took when I was over there, and would require permanent 

workers of 750 high-paying permanent workers that were created for the station’s operation. 

The power station currently provides employment for more than 900 people. Roughly one third 

of these employees live in Louisa County, while the rest live in Richmond, Fredericksburg, and 

Spotsylvania County. (0034-20 (Rigali, Tony)) 

Comment: In direct revenue, North Anna pays Louisa County each year approximately 

$11 million. And since its inception, it has paid Louisa County over $230 million of direct 

revenue. The third nuclear reactor will add millions more dollars to that, and if you really want to 

see the impact just look at our new schools and our fire trucks and police cars and the services 

that this revenue provides our county. (0034-22 (Gibson, Bob)) 

Comment: The second point I’d like to make is, like our previous speaker said, 300—

approximately 300 of the 900 workers live in Louisa County. The average salary of these 

workers is $60,500. That equates to an annual payroll of Louisa County citizens of over 

$18 million. The new reactor is going to employ 750 people. If the same ratio applies, that 

means 250 of these jobs will go to Louisa County citizens, and with the same average payroll 

that’s an additional $15 million annually of payroll in Louisa County for Louisa County citizens. 

Taken together, that is over $33 million of payroll within Louisa County, and keep in mind this 
Appendix D 

NUREG-1917, SEIS D-56 February 2010 

money changes hands several times before it leaves Louisa County, so which will mean several 

million dollars more of additional indirect revenue for the county. (0034-23 (Gibson, Bob)) 

Comment: I would like to again bring out the point that a previous speaker made of the 

3000 construction workers coming into Louisa County. You know, the word surge is kind of 

popular these days in the United States, but this is going to be an economic development surge 

for the county, because these workers are going to get paid and probably a pretty good salary, 

and they’re going to rent homes, they’re going to buy homes, they’re going to buy groceries, 

they’re going to buy automobiles and trucks and every other type of retail purchase in our 

county. So this is going to mean additional revenue for our county. (0034-24 (Gibson, Bob)) 

Comment: The North Anna power station has also been—had a positive impact on the county. 

I don’t think I could add anything to what Bob just said. However, the county has benefitted 

economically from the—through the increased tax base and increased numbers of employees. 

(0034-29 (Manzari, Jack)) 

Comment: As Dominion’s lowest cost source of baseload electricity, nuclear is important to the 

economic well being of Virginians and to the economy of the Commonwealth. North Anna 

power station, as has been stated, has paid over $230 million in taxes to Louisa County, and I 

am informed that the taxes would more than double after this third unit goes into operation. 

(0034-55 (Tribble, Charles)) 

Comment: I’d like to start off talking about a Nuclear Energy Institute study that looked at the 

economic impact of North Anna power station on the State of Virginia. North Anna generates 

more than $710 million in economic benefit to the state. This includes approximately $11 million 

in property tax for the surrounding counties, which enables the counties to provide excellent 

educational facilities and staff, and other public works for everyone in the county, not just 

Dominion employees’ families. (0034-78 (Fawls, Rebecca)) 

Comment: Building a new nuclear power plant will bring approximately 2000 jobs during 

construction and provide approximately 600 permanent high-paying jobs. The new nuclear 

power plant would also increase tax revenues to the surrounding counties and Virginia as a 

whole. An added benefit would be the ripple effect on the economy, such as housing, 

restaurants, and manufacturing for the state. (0034-81 (Fawls, Rebecca)) 

Response: The impacts of North Anna Unit 3 plant construction and operating workforce are 

within the scope of the socioeconomic impacts to be addressed in the SEIS. Impacts related to 

socioeconomics previously resolved in NUREG-1811, ESP EIS will be evaluated in terms of 

new and significant information to determine if impact levels should be changed.

Comment: I AM OPPOSED TO A PLANT THAT WILL LOWER THE LAKE WATER LEVEL. 

Lowering the Lake level will negatively impact property values and negatively impact recreation. 

(0010-2 (Hayo, Dennis)) 
Appendix D 

February 2010 D-57 NUREG-1917, SEIS 

Comment: When water levels are down 2 ft the lake becomes unusable for the majority of 

homeowners. (0012-2 (Heino, George and Gerry)) 

Comment: Dominion (Vepco) was allowed to build their reactors as long as the lakes provide 

recreation, their proposed design will limit that significantly. (0012-4 (Heino, George and Gerry)) 

Comment: Other impacts are unsafe water conditions which occur at low water levels, boating 

hazards, shoreline stabilization issues, impact to wetlands and impacts to business and home 

values. (0012-5 (Heino, George and Gerry)) 

Comment: Recreational boaters will find more hazards throughout the lake, with stumps, rocks, 

sandbars, etc. causing lower units to hit them which in turn could necessitate major repairs or 

replacement of propellers, other engine components and boat hulls. When the lake level is 

below 250 MSL and continues to decrease during drought cycles, these hazards will only 

increase. (0028-12 (Ruth, Harry)) 

Comment: It is important to remember that the lake was not just built for Dominion to use to 

cool its power plant. The enabling legislation set forth very clearly that Lake Anna was also 

created as a recreational lake for the public to enjoy. One use is no more important than the 

other. And one use, e.g., cooling the reactors, cannot be allowed to destroy the lake’s 

recreational use. (0031-7 (Crawford, Barbara)) 

Comment: It is important to bear in mind that when Lake Anna was created, neither Dominion 

nor any governmental body, whether federal, state or local, in any way discouraged the public 

from purchasing land and building homes around the lake. I would argue that there therefore 

exists a responsibility to those homeowners to protect them from adverse impacts of the power 

station. (0031-8 (Crawford, Barbara)) 

Comment: 

Business Real Estates Sales/Rentals (B3R) 

i. Advantage: None 

ii. Disadvantages 

1. Lower lake level discourages any potential buyers or renters -minimal sales 

2. Current depressed real estate market will further decline 

3. Real Values and Assessments will decrease 

4. Sales /rental commissions will decrease 

5. Taxes to local communities will decrease 

6. Insurance rates may increase due to lack of water at dry fire hydrants 

7. Shoreline instability problems may create many related impacts. 

8. Fewer sales will mean less need for loans from banks/mortgage lenders 

9. Fewer sales will means less need for future land development 

10. Fewer sales will mean less need for title agencies. (0033-44 (Ruth, Harry)) 
Appendix D 

NUREG-1917, SEIS D-58 February 2010 

Comment: 

Business Construction (BC) 

i. Advantages: None 

ii. Disadvantages 

1. With fewer real estate sales/rentals there will be less need for future construction 

2. This will directly reduce need for building designers, building contractors, building 

materials, cabinetry & countertops, clearing services, concrete, construction of decks, 

decorative concrete, docks and boathouses, drywall contractors, excavating, hauling, 

heating & air conditioning, home improvement, home staging, interior design, kitchen & 

bath, landscape design, landscape lighting, lumber, remodeling, soil consultants, 

surveyor, underground sprinkler systems and water treatments. (0033-45 (Ruth, Harry)) 

Comment: 

Business Lake Recreation (BL) 

i. Advantages: Boating major repairs will increase for the few boaters that use lake 

ii. Disadvantages 

1. With less water in the lake, fewer people will want to use the lake or visit the lake 

 (0033-46 (Ruth, Harry)) 

Comment: This will directly reduce the business for boat rentals, boat repairs for many boaters 

who would have previously used the lake, boat RV/PWC/storage, boat sales, campgrounds and 

marinas. (0033-49 (Ruth, Harry)) 

Comment: An example of one safety impact is: Recreational boaters will find more hazards 

throughout the lake, with stumps rocks, sandbars, etc. causing lower units of boats to hit them 

which can cause severe injury to passengers and necessitate major repairs or replacement of 

propellers, other engine components and boat hulls. When the lake level is below 250 MSL and 

continues to decrease during drought cycles, these hazards will only increase. The drought 

cycles will double if the wet/dry cooling method for Unit 3 is selected. Businesses will suffer and 

users of the lake will find other places to recreate which will decrease property values and 

reduce tax income to the local counties. Also note that when the lake level drops below 248 

MSL that over 50% of the homeowners cannot use their boats piers due to low water levels. 

(0033-5 (Ruth, Harry)) 

Comment: Boat slip rental business and lake waterfront owners will encounter major difficulties 

in getting boats off boat lifts, possibly having mud-flats in front of their property making the lake 

unusable for swimming or using their boats. (0033-51 (Ruth, Harry)) 
Appendix D 

February 2010 D-59 NUREG-1917, SEIS 

Comment: Marinas, Campgrounds and lake front owners may have to extend their boat ramps 

& docks so they can launch and retrieve their boats. (0033-53 (Ruth, Harry)) 

Comment: If fewer people come to the lake because of declining lake levels, then the need for 

other lake services will also decline. (0033-55 (Ruth, Harry)) 

Comment: Fewer real estate sales & rentals and less construction will mean fewer people will 

live on or visit the lake, thereby decreasing the business for accounting, advertising, automotive, 

attorneys, awards, bed and bath, blinds & shades, business services, catering services, 

cleaning services, computer services, county stores, physicians, dentists, dining, event location, 

fitness centers, investment securities, lawn care, newspapers, retailers, self storage, shipping 

services, skin care, beauty shops, television services, travel & leisure, wineries, etc. (0033-56

(Ruth, Harry)) 

Comment: 

1. Advantage: Potential for lower taxes due to decreasing value of property. 

2. Disadvantages: 

a. Lower lake level discourages any potential buyers or rentals 

b. Real estate values and assessments could decrease. (0033-57 (Ruth, Harry))

Comment: Waterfront owners will encounter major difficulties in getting boats off boat lifts, 

possibly having mud-flats in front of their property making the lake unusable for swimming & 

boating. (0033-60 (Ruth, Harry)) 

Comment: Some owners and/or Property Owner Associations may have to extend their boat 

ramps so they can launch and retrieve their boats. (0033-62 (Ruth, Harry)) 

Comment: Day User (DU) Does not own Lake Anna property and uses Lake Anna for 

recreation (e.g., campground, marina, state park, etc.) for day and then goes to home, motel or 

cabin. 

1. Advantage: None. 

2. Disadvantages: 

a. Less water will cause the existing water to get hotter faster and increase the human 

health risks for immersion in heated water, together with the potential for health risks 

of increased bacteria (microorganisms) or algae blooms. Hotter water makes the 

lake less desirable in summer time and day users may try to find other cooler waters 

to recreate in. 

b. Fish, aquatic life, clams, mussels and wildlife may be adversely impacted with less 

water and the water temperatures rising could cause lethal effects to various water 

related wildlife. 
Appendix D 

NUREG-1917, SEIS D-60 February 2010 

c. Lower and hotter water levels could encourage the hydrilla and other aquatic life to 

proliferate, thereby making it less desirable, as well as unhealthy to swim and 

recreate on the lake. Previous high levels of hydrilla caused major difficulties in 

launching boats, caused the weeds to become entangled in boat propellers and 

choke the engine. In addition, young children when swimming previously became 

entangled in the hydrilla creating a very serious safety issue. 

d When boating, the lake users will find more hazards throughout the lake, with 

stumps, rocks, sandbars, etc. causing lower units to hit them which in turn could 

necessitate major repairs or replacement of propellers, other engine components 

and boat hulls. In addition, the safety of allay board the boats is severely 

jeopardized when the boats run into these newly emergent and changing boating 

hazards when the lake level is below 250 MSL and continues to decrease during 

drought cycles. Note: Dominion and the NRC state these drought cycles will be 

doubled with the proposed type of 3rd reactor wet/dry cooling method. The doubling 

of the drought cycle will increase the human safety risks dramatically. 

e. If fewer people come to the lake because of declining lake levels, then it is quite 

possible that many of the current lake services (restaurants, retail, etc.) will be 

unable to grow or stay in business due to lack of customers and will be unavailable 

to the day user when they visit. (0033-66 (Ruth, Harry))

Comment: Lake Anna Boating and Recreation Association has concerns that the proposed 

cooling towers for the third nuclear reactor at Lake Anna will create an additional adverse 

impact when lowering the lake levels, lower lake levels when compared to the safety and 

welfare of the estimated 500,000 boating and recreation enthusiasts that live at and visit the 

lake. (0034-173 (Jones, Dale)) 

Comment: Unsafe low water conditions cause many of the people that previously boated here 

to look elsewhere for the boating recreation. This causes a negative impact on our local 

business community. Many Lake Anna businesses rely on the sales that are made in the 

spring, summer, and fall months. The low water condition affects real estate, construction, 

marinas, dock builders, restaurants, banks, fishing guides, boat sales, repair shops, et cetera. 

The business owners that we had personally spoken to—and we haven’t spoken to all of 

them—have all concurred that the low lake levels will adversely impact their businesses. 

(0034-175 (Jones, Dale)) 

Comment: Fewer people will visit the Lake Anna State Park because of the increased risks at 

the lake. (0028-58, 0033-67 (Ruth, Harry)) 

Comment: The Lake Anna Boating and Recreation Association recognizes and appreciates 

the many benefits that are derived from the Dominion Resources, including construction of the 

lake. Many of our members, friends, and neighbors enjoy employment, which we have seen 

here tonight, a lot of them. They have enjoyed home ownership and business due to their 

presence. In the past, we have considered them to be a good neighbor and would expect that 

in the process of planning for future business expansion, Dominion Resources would be 

considerate of the needs of the public and continue to help maintain a healthy lake condition, as 
Appendix D 

February 2010 D-61 NUREG-1917, SEIS 

promised, rather than purposely destroy them. The maintenance of the 250-foot water level will 

only help ensure the continued success as well as others in the community. (0034-179

(Jones, Dale)) 

Comment: The majority of docks at Lake Anna only have three feet of water. When water 

levels are down two feet, the lake becomes unusable for the majority of homeowners. 

(0034-191 (Heino, George and Gerry)) 

Comment: Dominion, VEPCO, was allowed to build their reactors as long as the lake provides 

recreation. Their proposed design will limit that significantly. (0034-193 (Heino, George and 

Gerry)) 

Comment: Other impacts are unsafe water conditions, which occur at low water levels; boating 

hazards; shoreline stabilization issues; impact to wetlands; and impacts to business and home 

values. (0034-195 (Heino, George and Gerry)) 

Comment: The LLCP, or lake level contingency plan, is a fragile and contentious balance 

between Louisa County and Hanover County and reflects the competing needs for water. It is 

important to remember that the lake was not just built for Dominion to use to cool its power 

plant. The enabling legislation set forth very clearly that Lake Anna was also created as a 

recreational lake for the public to enjoy. One use is no more important than the other. And one 

use; for example, cooling the reactors, cannot be allowed to destroy the lake’s other use: its 

recreational use. (0034-205 (Crawford, Barbara)) 

Response: Impacts of low water levels on Lake Anna recreation, businesses, and property 

values were previously resolved in NUREG-1811, ESP EIS. Impacts related to socioeconomics 

previously resolved in the ESP EIS will be evaluated in terms of new and significant information 

to determine if impact levels should be changed. 

Comment: 

Business Real Estates Sales/Rentals (BR) 

i. Advantages—None 

ii. Disadvantages— 

1. Lower lake level discourages any potential buyers or renters—minimal sales 

2. Current depressed real estate market will further decline 

3. Real Values and Assessments will decrease 

4. Sales/rental commissions will decrease 

5. Taxes to local communities will decrease 

6. Insurance rates may increase due to lack of water at dry fire hydrants 

7. Shoreline instability problems may create many related impacts. 

8. Fewer sales will mean less need for loans from banks/mortgage lenders 

9. Fewer sales will means less need for future land development 

10. Fewer sales will mean less need for title agencies (0028-36 (Ruth, Harry)) 
Appendix D 

NUREG-1917, SEIS D-62 February 2010 

Comment: 

Business Construction (BC) 

i. Advantages: None 

ii. Disadvantages 

1. With fewer real estate sales/rentals there will be less need for future construction 

2. This will directly reduce need for building designers, building contractors, building 

materials, cabinetry & countertops, clearing services, concrete, construction of 

decks, decorative concrete, docks and boathouses, drywall contractors, 

excavating, hauling, heating & air conditioning, home improvement, home 

staging, interior design, kitchen & bath, landscape design, landscape lighting, 

lumber, remodeling, soil consultants, surveyor, underground sprinkler systems 

and water treatments (0028-37 (Ruth, Harry)) 

Comment: 

Business Lake Recreation (BL) 

i. Advantages: Boating major repairs will increase for the few boaters that use lake 

ii. Disadvantages 

1. With less water in the lake, fewer people will want to use the lake or visit the lake (0028-

38 (Ruth, Harry)) 

Comment: This [fewer people using the lake because of declining lake levels] will directly 

reduce the business for boat rentals, boat repairs for many boaters who would have previously 

used the lake, boat RV/PWC/storage, boat sales, campgrounds and marinas. (0028-41

(Ruth, Harry)) 

Comment: Boat slip rental business and lake waterfront owners will encounter major difficulties 

in getting boats off boat lifts, possibly having mud-flats in front of their property making the lake 

unusable for swimming or using their boats. (0028-43 (Ruth, Harry)) 

Comment: If fewer people come to the lake because of declining lake levels, then the need for 

other lake services will also decline. (0028-46 (Ruth, Harry)) 

Comment: Fewer real estate sales & rentals and less construction will mean fewer people will 

live on or visit the lake, thereby decreasing the business for accounting, advertising, automotive, 

attorneys, awards, bed and bath, blinds & shades, business services, catering services, 

cleaning services, computer services, county stores, physicians, dentists, dining, event location, 

fitness centers, investment securities, lawn care, newspapers, retailers, self storage, shipping 

services, skin care, beauty shops, television services, travel & leisure, wineries, etc. (0028-47

(Ruth, Harry)) 
Appendix D 

February 2010 D-63 NUREG-1917, SEIS 

Comment: Homeowners (H) 

1. Advantage: Potential for lower taxes due to decreasing value of property. 

2. Disadvantages: 

a. Lower lake level discourages any potential buyers or rentals 

b. Real estate values and assessments could decrease (0028-48 (Ruth, Harry)) 

Comment: Waterfront owners will encounter major difficulties in getting boats off boat lifts, 

possibly having mud-flats in front of their property making the lake unusable for swimming & 

boating. (0028-51 (Ruth, Harry)) 

Comment: Some owners and/or Property Owner Associations may have to extend their boat 

ramps so they can launch and retrieve their boats. (0028-53 (Ruth, Harry)) 

Comment: Homeowner Insurance rates may increase due to lack of water at dry fire hydrants 

k. If fewer people come to the lake because of declining lake levels, then it is quite possible that 

many of the current lake services (restaurants, retail, etc.) will be unable to grow or stay in 

business due to lack of customers. (0028-56 (Ruth, Harry)) 

Comment: 

Day User (DU) Does not own Lake Anna property and uses Lake Anna for recreation 

(e.g., campground, marina, state park, etc.) for day and then goes to home, motel or 

cabin. 

1. Advantage: None. 

2. Disadvantages: 

a. Less water will cause the existing water to get hotter faster and increase the 

human health risks for immersion in heated water, together with the potential for 

health risks of increased bacteria (microorganisms) or algae blooms. Hotter 

water makes the lake less desirable in summer time and day users may try to 

find other cooler waters to recreate in. 

b. Fish, aquatic life, clams, mussels and wildlife may be adversely impacted with 

less water and the water temperatures rising could cause lethal effects to various 

water related wildlife. 

c. Lower and hotter water levels could encourage the hydrilla and other aquatic life 

to proliferate, thereby making it less desirable, as well as unhealthy to swim and 

recreate on the lake. Previous high levels of hydrilla caused major difficulties in 

launching boats, caused the weeds to become entangled in boat propellers and 

choke the engine. In addition, young children when swimming previously 

became entangled in the hydrilla creating a very serious safety issue. 

d. When boating, the lake users will find more hazards throughout the lake, with 

stumps, rocks, sandbars, etc. causing lower units to hit them which in turn could 
Appendix D 

NUREG-1917, SEIS D-64 February 2010 

necessitate major repairs or replacement of propellers, other engine components 

and boat hulls. In addition, the safety of all aboard the boats is severely 

jeopardized when the boats run into these newly emergent and changing boating 

hazards when the lake level is below 250 MSL and continues to decrease during 

drought cycles. Note: Dominion and the NRC state these drought cycles will be 

doubled with the proposed type of 3rd reactor wet/dry cooling method. The 

doubling of the drought cycle will increase the human safety risks dramatically. 

e. If fewer people come to the lake because of declining lake levels, then it is quite 

possible that many of the current lake services (restaurants, retail, etc.) will be 

unable to grow or stay in business due to lack of customers and will be 

unavailable to the day user when they visit. (0028-57 (Ruth, Harry)) 

Comment: There will be major fire safety hazards for lake homes/communities by making the 

dry fire hydrants unusable due to the lack of water at the lake intake caused by the decreasing 

lake water level. 

• There will be shoreline stabilization problems (the seawalls & rip rap are designed for a 

water level of 250 MSL) and 

• There will be negative impacts on many lake businesses as people go elsewhere to recreate 

and live. (0033-4 (Ruth, Harry)) 

Comment: Homeowner Insurance rates may increase due to lack of water at dry fire hydrants. 

If fewer people come to the lake because of declining lake levels, then it is quite possible that 

many of the current lake services (restaurants, retail, etc.) will be unable to grow or stay in 

business due to lack of customers. (0033-65 (Ruth, Harry)) 

Response: Impacts of low water levels on Lake Anna recreation, businesses, and property 

values were previously resolved in NUREG-1811, ESP EIS. Impacts related to socioeconomics 

previously resolved in the ESP EIS will be evaluated in terms of new and significant information 

to determine if impact levels should be changed. The impacts on fire safety will be considered 

as part of the SEIS and addressed in Chapter 5.

Comment: The height of dry and wet cooling towers and facility buildings should not exceed 

the tree line to protect the rural aesthetic landscape of the community as Dominion indicated in 

its Jan 2006 stakeholder meeting. (0028-28 (Ruth, Harry)) 

Comment: Noise concerns/decibel levels emitted from 180/230 foot buildings that will travel 

long distances without having tree barriers to break the sound from giant fans. (0028-34

(Ruth, Harry)) 

Comment: To ensure that the proposed construction of a 3 reactor will minimize the adverse 

effects on the quality of life for those who live and work on and around or use Lake Anna, we 

also ask that you further evaluate the following concerns prior to your making a final decision on 

the ESP (conditional certification requirements) and are included for evaluation in the COL DEIS. 
Appendix D 

February 2010 D-65 NUREG-1917, SEIS 

a. The height of dry and wet cooling towers and facility buildings should not exceed the tree 

line to protect the rural aesthetic landscape of the community as Dominion indicated in its 

January 2006 stakeholder meeting. (0033-36 (Ruth, Harry)) 

Response: Local noise impacts and visual aesthetics of the proposed Unit 3 are within the 

scope of the SEIS. Impacts related to noise and visual aesthetics previously resolved in 

NUREG-1811, ESP EIS will be evaluated in terms of new and significant information to 

determine if impact levels should be changed. 

Comment: The section on socioeconomics is lacking. For example, there is no data on the 

impact that the project will have on local house values. The impacts on the human environment 

must be fleshed out in an EIS and this should be addressed as part of Section 5.5.3.1 or 

5.5.3.5. The potential impacts to the DC area are not addressed at all in the document and 

should be included. (0035-3 (Goldsmith, Aviv)) 

Response: Impacts of the construction and operation of the proposed power plant on housing 

availability and housing values were previously discussed and resolved in NUREG-1811, 

ESP EIS. The Unit 3 SEIS will primarily discuss new and significant information available since 

NUREG-1811 to determine whether any previously stated conclusions would change as a result 

of the new information. With respect to the impacts to the DC metropolitan area, the number of 

activities that affect that metropolitan housing market are many and diffuse, and it is extremely 

unlikely that the impact of the construction and operation of North Anna Unit 3 could be 

separately identified in that market. 

Comment: The transportation section is totally deficient. There is currently insufficient 

infrastructure to support the construction workforce or handle an evacuation. Assuming that the 

roads will be there when required (Page 5-37, line 16) is not science, it is superstition. The 

SDEIS stated “No new transportation routes...are currently planned in the vicinity of NAPS.” 

(Page 2-4 line 37). There is little to no funding for road expansions in Virginia. The DEIS 

acknowledged that the I-95/606 interchange is congested at “LOS D or worse” and that SR208 

from Blockhouse Road to Lake Anna (about 12.5 miles) is a minor two-lane road. Increased 

construction usage will have major impacts on these roads. If an evacuation is required during 

the construction interval when additional personnel are on site, the impact would be staggering. 

(0035-5 (Goldsmith, Aviv)) 

Response: The transportation section will address new and significant information available 

since NUREG-1811, ESP EIS, to determine if any impacts estimated in the ESP EIS should be 

changed. 

Comment: Given that Louisa County had a population of about 25,000 in 2000 (Page 2-1 

line 42), the SDEIS conclusion that a construction work force of 5000 would have a SMALL 

impact (Section 4.5) is unsubstantiated and suspect. (0035-19 [Goldsmith, Aviv]) 

Response: In NUREG-1811, ESP EIS for the North Anna site, the impact of the constructionrelated population was based in part on where the construction workforce chose to live. The 
Appendix D 

NUREG-1917, SEIS D-66 February 2010 

basic assumption was that the construction workforce would largely come from outside of 

Louisa County and would commute to the North Anna site. The basis for that assumption was 

given in the NUREG-1811, ESP EIS. It also stated that if more workers than expected located 

in Louisa County, the impact was estimated to rise to MODERATE. The North Anna Unit 3 

construction workforce is significantly smaller than that assumed in the ESP EIS, but more is 

now known about the housing and public services that the workforce would actually face. The 

North Anna Unit 3 COL SEIS will consider whether new and significant information available 

since NUREG-1811, ESP EIS would change any impact levels previously discussed. 

Comment: At the ESL public hearing that I was able to attend, Lake Anna residents expressed 

concern about the aesthetics of the cooling towers. A visual simulation should be included as 

part of Section 4.5.1.4 to address this concern. (0035-20 (Goldsmith, Aviv)) 

Response: A visual simulation has been provided in the applicant’s ER and will be discussed 

in the North Anna Unit 3 COL SEIS. 

Comment: Table 10-1 acknowledges that increased traffic congestion is unavoidable. This is 

not congruous with the SMALL impact determination. Table 10-2 should include an assessment 

of traffic similar to Table 10-1. Presently, this would also conclude that increased traffic 

congestion is unavoidable. (0035-44 (Goldsmith, Aviv)) 

Response: The analysis of mitigation and unavoidable impacts will consider any new and 

significant information on traffic congestion and the impact of traffic management plans. 

Comment: [Overall, the mitigations (listed in Section 10) are insufficient]. Major contributions 

to construction of a reliable road network are required. Financial contributions to neighboring 

counties to alleviate the housing, school, and health care burdens of the project should be 

implemented. (0035-46 (Goldsmith, Aviv)) 

Response: Chapter 10 of NUREG-1811, ESP EIS, considered potential mitigation actions in 

the area of traffic congestion. Potential mitigative actions will again be considered for impacts 

identified in the Unit 3 SEIS. 

Comment: Shouldn’t Appendix F or L or the socioeconomic section of the text include mention 

of the resolution passed by Spotsylvania County against the project and the ESP? (0035-49

(Goldsmith, Aviv)) 

Response: The resolution will be considered in the North Anna Unit 3 SEIS to the extent that it 

provides new and significant information that affects the impact levels previously discussed in 

NUREG-1811, ESP FEIS, or impacts that were not previously discussed. 

11. Comments Concerning Historic and Cultural Resources

Comment: Many issues regarding potential impacts to historic properties, specifically 

archaeological resources, were resolved during the Early Site Permit (ESP) process. Given the 
Appendix D 

February 2010 D-67 NUREG-1917, SEIS 

limitations of the ESP process and changes to the scope of the project, additional studies are 

warranted to determine this undertaking’s effect to historic properties. We understand, that an 

additional 90+ acres have been added to the project. We recommend that this and any 

additional areas included in the project be subjected to Phase I archaeological survey by a 

qualified professional in accordance with our Survey Guidelines (rev. 2003). Furthermore, as 

new tower height is established, we recommend finalizing the viewshed analysis to determine 

potential impacts to the setting of nearby historic properties. Finally, we are concerned about 

the avoidance and continued management of the three known cemeteries (44LS0221, 0222, 

and 0227) and the historic site (44LS0226), which have been found to be potentially eligible for 

listing in the National Register of Historic Places. We request that the NRC provide for their 

protection. (0001-1 (Kirchen, Roger)) 

Response: Cultural resource management and measures associated with impacts to cultural 

resources will be discussed in Chapters 4 and 5 of the SEIS. 

Comment: Since consultation regarding the ESP, several Federally-recognized Indian tribes 

have informed our office of their possible interest in undertakings in Virginia. Find attached 

contact information for these tribes. We do not know of any specific tribe with interest in this 

project nor do we make any statement regarding the completeness of this list. This information 

is provided as a courtesy and is intended as technical assistance to NRC in meeting its tribal 

consultation requirements. (0001-2 (Kirchen, Roger)) 

Response: The NRC intends to make use of the list of tribes provided by the Virginia SHPO to 

meet its tribal consultation requirements.

12. Comments Concerning Environmental Justice

Comment: NRC Commissioner Jaczko took issue with his fellow commissioners in the 

November decision to approve the North Anna ESP. In dissent, he wrote: “I concur with my 

colleagues on most of this decision, but dissent, in part, on the environmental justice portion of 

the Memorandum and Order. Environmental justice is a critical component of the agency’s 

NEPA review. It seeks to ensure that environmental, social, economic and health issues are all 

appropriately considered in the context of minority and low-income populations where the 

impacts of actions may be remarkably different from the impacts on the majority. Although the 

staff obtained underlying data on minority and low-income populations and provided its 

conclusions on the potential environmental impacts on those populations in the Environmental 

Impact Statement (EIS), I do not believe that the Staff sufficiently explained how it reached its 

conclusions regarding environmental justice. Without such an explanation, I believe it is difficult 

for the Commission, or the public, to determine whether the Staff has examined environmental 

justice issues in greater detail—as we, in our Environmental Justice Policy Statement, directed 

the Staff to do. I fully support my colleagues’ efforts in this Memorandum and Order to ensure 

that future environmental justice reviews are supported by a level of detail that would 

transparently describe the basis for the Staff’s conclusions. I diverge from my colleagues on 

this issue in one respect: I would have also directed the Staff to prepare a Supplemental EIS 

that provides a supporting analysis for its conclusions prior to the issuance of this Early Site 
Appendix D 

NUREG-1917, SEIS D-68 February 2010 

Permit. I recognize that requiring additional work in the environmental justice area would then 

impact the finality of this Early Site Permit. I also recognize that this could cause the applicant 

to adjust its future plans, even though it is the agency’s, not the applicant’s, responsibility to 

consider environmental justice issues. But as I have previously stated, this agency exists to 

serve the public. I have consistently demanded that applicants present thorough and high 

quality applications to this agency and it would be inconsistent for me not to demand the same 

in the Staff’s review of those applications. Both are necessary for the NRC to be able to 

transparently demonstrate how we meet our mission. In this instance, I believe we could have 

provided a supplemental environmental justice analysis at the cost of a bit more time, but with 

the benefit of being certain that the agency had a thorough analysis supporting issuance of this 

Early Site Permit.” 

It is now incumbent on the NRC to rectify this error. The supplemental analysis outlined above 

would be a reasonable, practicable remedy. We hereby request that the NRC implement this 

process at the earliest possible date. (0024-10 (Zeller, Lou)) 

Comment: The Nuclear Regulatory Commission has not fulfilled the environmental justice 

requirements embodied in Executive Order 12898 which requires the agency to review its 

programs, policies and activities to address disproportionately high impacts on minority and lowincome populations. (0024-9 (Zeller, Lou)) 

Response: Environmental Justice is within the scope of the SEIS. Because this subject was 

analyzed for the EIS developed for the North Anna ESP (NUREG-1811), the analysis for the 

Unit 3 COL SEIS will consider new information to assess whether the impact level determine in 

the NUREG-1811, ESP EIS should be changed.

13. Comments Concerning Health - Non Radiological

Comment: The human brain eating Naegleria fowleri amoeba was found in both the main 

reservoir and the cooling lagoons. This same amoeba caused deaths in Florida, Texas, and 

Arizona last summer. It proliferates in water around 86 degrees and thrives especially well at 95 

degrees and above. (0023-4, 0034-150 (Black, Betty)) 

Comment: Previous water temps—LACA/VDEQ water teams in 2006 and 2007 have 

confirmed in various tests that the Water Temperatures have risen to 104.6F on the warm side 

of the lake and 93F on the cool side of the lake. Dominion’s data reported to VDEQ and NRC is 

very close to this. 

1. How water temps affect prolonged human immersion and changes in concentrations of 

micro-organisms. The Virginia State Health Commissioner in a Sept. 15, 2005 letter to 

the Virginia Department of Environmental Quality state when evaluating the potential 
Appendix D 

February 2010 D-69 NUREG-1917, SEIS 

health effects of any such new nuclear reactors from (1) Direct effects of heat from 

immersion in ambient waters by recreational bathers, and (2) the potential adverse 

effects of any changes in the concentrations of microorganisms in those waters said in 

part: 

a. Naegleria Fowleri (amoebas1 which have been found at various locations in Lake 

Anna) species organism begins to proliferate at temperatures around 86F and 

thrives especially well (compared to its competitors) at temperatures of 95 to 

113F. Primary Amoebic Meningoencephalatis (PAM) is a rare but nearly always 

fatal infection caused by Naegleria fowleri. 

b. Persons with heart disease, children, parents and guardians of young children, 

the elderly, pregnant women and persons with spinal cord or peripheral nerve 

disorders should be cautious of prolonged immersion in waters that are warmer 

than body temperature. Bodies of water that have a temperature exceeding 

104F should be considered unsafe for recreational activity for all persons due to 

the effects of heat alone. 

c. Common sense suggests that to reduce the risk of PAM, swimmers might wish to 

avoid swimming in freshwater venues when water temperatures are high, (e.g. 

when surface water temperatures are greater than or equal to 95F. (0028-65, 

0033-74 (Ruth, Harry)) 

Comment: Various newspapers articles during the summer of 2007 identified that 6 deaths 

occurred in 3 different states in the U.S. during the summer of 2007 due to PAM. This is a 

major increase from previous statistics where the Centers for Disease Control said there were 

only 24 deaths between 1989 and 2000. 

1. The Virginia Commonwealth University conducted tests for Lake Anna Civic Association 

(LACA) the summer of 2007 to identify the presence or absence of Naegleria Fowleri 

(NF) in Lake Anna. See report dated Dec 2007 that identified 16 locations were tested 

and that 9 of the 16 locations tested positive for NF. 5 on the warm side of the lake and 4 

on the cold side of the lake. Some of the locations on the cold side are in the upper part 

of the lake above the 208 bridge. (See the full report at www.LakeAnnaVirginia.org) 

a. On Page 4 of the VCU Related research about NF Amebae states.” In studies of 

fresh water lakes associated with power plants, N. fowleri was routinely isolated. 

The heated water is a breeding ground for pathogenic NF amebae. Thermal 

enrichment of water can cause proliferation of amebae especially at 

temperatures of 86F to 111F. 

b. On Page 5 Recommendations to reduce the risk of infection. The report says 

“Since it has been shown that N. fowleri is present in Lake Anna, the public 

should be warned to wear nose plugs while diving, swimming or engaging in 

water activities in which the head is submerged when temperatures of Lake Anna 

reach 84F or higher.” (0028-67, 0033-76 (Ruth, Harry)) 
Appendix D 

NUREG-1917, SEIS D-70 February 2010 

Comment: Both amoeba and ameba are acceptable spellings as well as the plurals -bas and -

bae and all are used throughout this document by various authorities. 

a. On Page 13—In Conclusion the report says Quote Lake Anna Civic Association studies 

indicate that Lake Anna is unique in that 99% of the water between the power plant and the 

dam is re-circulated by the North Anna Power Station cooling pumps. During the summer 

months water temperatures are in excess of 100 degrees F at some locations. Thus, 

recirculation of the water could account for sites being positive on one sampling date and 

negative at another sampling date. This study indicates that increased temperatures at 

sites on the lake are associated with the presence of Naegleria fowleri. These sites should 

be monitored during the summer months when there are increased water activities to 

determine the abundance of amebae, in order to prevent primary amebic 

meningoencephalitis. There is a large body of literatures that demonstrates that as water 

temperatures rise, the amebae proliferate. This increased proliferation is consistent with a 

possible increased risk of human infection. Unquote. 

b. On Page 13—In summary the report says that Identifying the risk of contracting Primary 

Amebic Meningoencephalitis infection when N. fowleri amebae are present in the water is a 

very complex issue and there are no U.S. Standards. When concentrations of amebae are 

high there is a greater chance of becoming infected, but we do not know what all of the risk 

factors are and what the actual risk of infection is. (0028-68, 0033-77 (Ruth, Harry)) 

Comment: The VA State Health Commissioner says that as water temperatures rise there is 

an increased risk to the public for immersion in the hot water and also that amoebae proliferates 

faster in water temperatures above 85F. LACA/VDEQ teams have recorded water 

temperatures of 104.6F on the warm side and 93F on the cold side. The VA State Health 

commissioner says that persons with heart disease, children, parents and guardians of young 

children, the elderly, pregnant women and persons with spinal cord or peripheral nerve 

disorders should be cautious of prolonged immersion in waters that are warmer than body 

temperature (98.6F). The U.S. Safety Commission says that it could be fatal if you go into a hot 

tub with temperatures greater than 104F. Various newspapers confirmed the deaths of 6 young 

people in 3 states due to PAM during the summer of 2007. (0028-71, 0033-80 (Ruth, Harry)) 

Comment: Virginia Commonwealth University (VCU) studies during the summer of 2007 

confirmed the presence of Naegleria Fowleri (NF) on both sides of Lake Anna. The VCU 

studies further states that as water temperatures increase above 86F and the NF proliferate the 

risk of getting PAM in Lake Anna increases. The study also says there is a large body of 

literatures that demonstrates that as water temperatures rise, the amebae proliferate. This 

increased proliferation is consistent with a possible increased human infection. VDEQ has 

granted water discharges permits for the current 2 units to Dominion to heat up the entirety of 

Lake Anna to any water temperature it desires without any penalties. We have previously had 

water temperatures over 104F in some parts of the lake and in the high 90s in many parts of the 

lake. We also know that 99% of the water re-circulates between the power plant and the dam 

and what amoebas are at one location today could be at another tomorrow. There is much 

scientific evidence that there is increased risk of an algae bloom (with heated water and an 

abundance of nutrients in the water) which in turn creates various health concerns with the type 
Appendix D 

February 2010 D-71 NUREG-1917, SEIS 

of water exposure (contact or ingestion). The health risks to human from algae blooms have 

found to contribute to eye, ear, and skin irritation. More serious health effects (e.g., muscle 

cramps twitching) can also occur. (0028-72, 0033-81 (Ruth, Harry)) 

Comment: The FOLA organization is concerned about the Virginia Commonwealth University 

(VCU) conducted tests in 2007 for the presence or absence of Naegleria Fowleri (NF) a human 

brain eating amebae in Lake Anna. They tested 16 locations and found that 9 of the 

16 locations tested positive for NF. VCU also indicated that heated water is a breeding ground 

for pathogenic NF amebae. Thermal enrichment of water can cause proliferation of amebae 

especially at temperatures of 86F to 111 F. Note that Lake Anna had previous confirmed water 

temperatures exceeding 104F degrees F. We believe that the NRC should require Dominion to 

have continued tests bi-annually throughout the cooling lagoons and main reservoir to monitor 

the NF amebae and the results should be reported to the public bi-annually. These new and 

significant actions by the Health Department and State Park which effect the local economy with 

less people visiting the lake, loss of real estate values, etc. should be fully evaluated by the 

NRC during the DEIS. (0033-8 (Ruth, Harry)) 

Response: The staff will evaluate any new and significant information relating to the presence 

of the microorganism Naegleria fowleri in the Lake Anna reservoir to determine if impact levels 

should be changed. The staff will also evaluate new and significant information that may 

change the impacts related to the original thermal impact level and thus the nonradiological 

health impact level previously resolved in NUREG-1811, ESP EIS.

Comment: Note that with only Units 1 and 2 operating, water temperatures have previously 

been recorded at over 104F in the cooling lagoons and over 93F on the main reservoir. The hot 

water is where humans recreate and where fish, wildlife, clams/mussels, and aquatic life share 

the water in what appears to be unsafe conditions. (0028-15 (Ruth, Harry)) 

Comment: The NRC in its DEIS should also examine the effects of increased undesirable 

aquatic growth from the declining water levels which allows sunlight to permeate to lower levels 

of the lake, that previously were darkened. Will this declining water level caused by unit 3 

create a reoccurrence of increased undesirable aquatic life throughout the lake and the 

associated human safety concerns defined below? The sun light penetration enhances the 

growth of aquatic weeds (hydrilla) and (skunk weed) and possibly others. The skunk weed has 

increased dramatically during the recent drought due to lower water levels causing unsafe 

swimming conditions for young children. Approximately 11 years ago, hydrilla growth created 

many safety risks for the public and created many boating hazards in Lake Anna. Humans 

could not swim in many parts of the lake due to 10’ long hydrilla patches throughout. Children 

would become entangled in the hydrilla creating serious safety concerns. Boats would come to 

an abrupt stop when there motors were choked out by hydrilla causing people to become 

thrown about in their boats. (0028-20, 0033-23 (Ruth, Harry)) 

Comment: Less water will cause the existing water to get hotter faster in the summer and 

increase the possibility of adverse impacts to humans through the increased health risks of 
Appendix D 

NUREG-1917, SEIS D-72 February 2010 

human immersion in heated water, together with the potential for dangerous growth of bacteria 

(microorganisms) or algae blooms. (0028-39, 0033-47 (Ruth, Harry)) 

Comment: Less water will cause the existing water to get hotter faster and increase the human 

health risks for immersion in heated water, together with the potential for adverse effects of 

increased bacteria (microorganisms) or algae blooms. (0028-49, 0033-58 (Ruth, Harry)) 

Comment: Lower and hotter water levels could encourage the hydrilla and other aquatic life to 

proliferate, thereby making it less desirable to swim and recreate on the lake. Previous high 

levels of hydrilla caused major difficulties in launching boats, caused the weeds to become 

entangled in boat propellers and choked off the engine. In addition, young children when 

swimming previously became entangled in the hydrilla creating a very serious safety issue. 

(0028-44, 0028-52, 0033-52, 0033-61 (Ruth, Harry)) 

Comment: What do we know that is identified in official government, university, or government 

sanctioned studies/documents about the potential health risks to humans from hot water in Lake 

Anna from the current 2 nuclear reactors? Will the Lake water temperatures get hotter from the 

proposed 3rd Unit cooling method and decreased water levels? What are the health risks to 

humans from hot water??? (0028-59, 0033-68 (Ruth, Harry)) 

Comment: How elevated water temps affects prolonged human immersion. The 

U.S. Consumer Safety Commission indicates that no one should go into a Hot Tub if the water 

temperature exceeds 104F because of possible fatal consequences. (0028-66, 0033-75

(Ruth, Harry)) 

Comment: In October 2007, the Virginia Department of Environmental Quality (VDEQ) has 

granted a water discharge permit to Dominion that has imposed no water temperature limits in 

Fahrenheit that can be measured by the public at the North Anna plant for the current two 

operating nuclear units. In addition, VDEQ has granted Dominion a 316A Variance from the 

U.S. Clean Water Act which allows them legally to heat the entire lake to any temperature that 

they desire without any penalties. 

1. Microcystis Algae Bloom Facts—Note that Algae Blooms occur in Lake Anna every summer 

when the lake water gets hot. Frequently Asked Questions Concerning Health Impacts of 

Algae Blooms (0028-69 (Ruth, Harry)) 

Comment: Question? —Can we take the chance that one of our loved ones will get sick or die 

because the water temperatures in Lake Anna which are currently at high levels in the summer 

months and will be increased further because of the up to 24 million gallons a day additional 

evaporation from the 3rd reactor cooling method than what they currently are from the existing 

two reactors?? Why? Because the water level will decline and there will be less water to cool 

the heat from the two current reactors causing the water to get hotter starting earlier in the 

summer and increasing temperatures throughout the summer and extending further into the fall. 

A simple analogy for the heating of water faster can be made with the fact that heating a cup of 

coffee will occur much faster than for heating a whole cup of coffee. If Dominion changed its 
Appendix D 

February 2010 D-73 NUREG-1917, SEIS 

proposed 3rd reactor cooling method to dry cooling (which they proposed for Unit 4 and is 

currently used in many places throughout the world), then the 3rd reactor cooling method would 

not further impact the hot water temperatures during the summer months in Lake Anna. (0028-

74, 0033-83 (Ruth, Harry)) 

Comment: The NRC in keeping with its charter to protect public health and safety should 

evaluate in the DEIS for the Unit 3 COL all the related public health impacts that could result 

from hotter water in Lake Anna as a result of further lake level declines caused by the 

evaporation of up to 24 million gallons per day. 

We understand that the Virginia Dept of Health is considering issuing a statement that if the 

Lake Anna water is over 104 degrees F that it is unsafe for humans because of the water 

temperature. The health dept is also considering issuing a statement indicating to avoid 

swimming, jumping or diving into bodies of water when water temperatures are high (above 

95 degrees F), especially when the water levels are low. We further understand that the 

Virginia State Park is planning to monitor Lake Anna water temperatures and recommend that 

no one swims at the state park if the Lake Anna water temperatures exceed 95 degrees F. 

(0033-7 (Ruth, Harry)) 

Response: The impacts of lake temperature and low water levels were resolved in the 

NUREG-1811, ESP EIS. The staff will evaluate new and significant information to determine 

whether the previously resolved impact levels related to health risks or recreational hazards 

from warmer water or low lake level should be changed.

Comment: Noise concerns/decibel levels emitted from 180/230 foot buildings that will travel 

long distances without having tree barriers to break the sound from giant fans. (0033-42

(Ruth, Harry)) 

Response: Local noise impacts and visual aesthetics of the proposed Unit 3 are within the 

scope of the SEIS. Impacts related to noise and visual aesthetics previously resolved in 

NUREG-1811, ESP EIS will be evaluated in terms of new and significant information to 

determine if impact levels should be changed. 

Comment: PCBs have been found in Lake Anna resulting in a fish consumption advisory by 

the State Health Commissioner. (0023-5, 0034-151 (Black, Betty)) 

Comment: The DEIS should examine the source of Lake Anna PCB contamination that has 

now caused the Virginia Dept. of Health to issue a fish consumption advisory on August 31, 

2007. The VDH advisory cautions: Do not eat any Lake Anna gizzard shad and do not eat 

more than two meals a month of carp, largemouth bass, striped bass, white perch, white catfish, 

channel catfish or blue gill sunfish. The health advisory applies to the total lake, both the main 

reservoir and cooling lagoons. (0028-17 (Ruth, Harry)) 

Comment: The NRC in its DEIS should examine the source of Lake Anna PCB contamination 

that has now caused the Virginia Dept of Health to issue a fish consumption advisory on 
Appendix D 

NUREG-1917, SEIS D-74 February 2010 

August 31, 2007. The VDH advisory cautions: Do not eat any Lake Anna gizzard shad and do 

not eat more than two meals a month of carp, largemouth bass, striped bass, white perch, white 

catfish, channel catfish or blue gill sunfish. The health advisory applies to the total lake, both 

the main reservoir and cooling lagoons. (0033-21 (Ruth, Harry)) 

Response: The staff will evaluate any new and significant information relating to the presence 

of PCBs in fish and sediments from the Lake Anna reservoir and the WHTF as they relate to 

assessing the human health impacts of Unit 3 construction and operation. This information will 

be evaluated in terms of new and significant to determine if impact levels should be changed.

Comment: The DEIS should further investigate the fire at the North Anna Power station in 

1981 and the significant spill of transformer oil associated with this event as it likely contained 

polychlorinated biphenyls (PCB’s). It was reported at the time that some unknown quantity of oil 

did reach the waters of Lake Anna. The complete remediation effort, including what happened 

to the contaminated material from the ground site and precisely how the PCB’s were extracted 

from Lake Anna should be identified in the DEIS. This survey should include what possible 

impact the ground excavation for the 3rd reactor (which is on the same site as the PCB spill) 

and its facility buildings will have on Lake Anna. (0028-18 (Ruth, Harry)) 

Comment: The DEIS should further investigate the spill and fire at the North Anna Power 

station of poly-chlorinated biphenyls (PCB) transformer oil in 1981. It was reported at the time 

that some unknown quantity of oil did reach the waters of Lake Anna. It has also been noted 

that Dominion has not released the results of PCB samples that it recently took in the 

WHTF/Cooling Lagoons 1 & 3. The complete Dominion disclosure of the remediation effort, 

including what happened to the contaminated material from the ground site and precisely how 

the PCB’s were extracted from Lake Anna should be identified in the DEIS. This disclosure 

should include what possible impact the ground excavation for the 3rd reactor (which is on the 

same site as the PCB spill) and its facility buildings will have on Lake Anna. Core samples of 

the existing ground should be taken to insure it is PCB free. (0033-22 (Ruth, Harry)) 

Response: The staff will evaluate any new and significant information relating to the presence 

of PCBs on or near the proposed construction site, including Lake Anna in the vicinity of the 

intake structure, to determine whether previously stated impact levels should be changed. 

Construction impacts will be discussed in Chapter 4 and operational impacts will be discussed 

in Chapter 5 of the SEIS.

14. Comments Concerning Health - Radiological

Comment: I hold in my hand here North Anna 3 combined license application part 7 departures 

report. Departures report is variances of plant-specific deviation from one or more of the site 

characteristics design parameters terms and conditions of the early site permit or from the site 

safety analysis report. I picked out a few of these. There’s a long list of them, including annual 

thyroid dose and liquid effluent releases and gaseous pathways. But regarding the radiological 

exposure, the variances requested by Dominion say, distances to the closest receptors had 

changed. People are living closer to the plant. (0034-87 (Zeller, Lou)) 
Appendix D 

February 2010 D-75 NUREG-1917, SEIS 

Response: The staff will evaluate the impacts of the revised liquid and gaseous effluent 

release source term from the proposed Unit 3 at North Anna in Chapter 5.9 of the SEIS. The 

impact of the revised receptor locations will also be evaluated.

Comment: We are learning more and more about the hazards of tritium exposure and we also 

know that it is routinely released into the Lake and into the atmosphere. How will Dominion and 

the NRC act to limit tritium releases? Both Dominion and the NRC must continue to study and 

make public the effects of tritium exposure on humans and flora and fauna who live on and in 

the Lake and downstream. (0017-8 (Day, Elena)) 

Comment: The EIS should fully address the impact on flora and fauna in Lake Anna and 

surrounding tributaries caused by North Anna-3’s planned release of radioactive waste into the 

Lake. (0026-8 (AuClair-Valdez, Miguel)) 

Comment: The NRC in its DEIS should evaluate the effect of tritium being released into Lake 

Anna together with its heated water from Units 1 and 2 and if the possibility exists that Unit 3 

proposed cooling method could also introduce additional tritium which has a radioactive half-life 

of 12.3 years. Our understanding is that the current two units routinely discharge not only 

tremendous amount of heat, because the reactors are only 33 percent thermally efficient. 

67 percent of the fission generated heat is dumped into the lake together with some 

radioactivity. According to NRC records, since 2000, the current reactors have released more 

than 5700 curies of radioactive tritium water into the lake. It is increasingly uncertain what 

constitutes a permissible radiation exposure. The NRC’s protective standard for radioactive 

tritium in drinking water is 1 million picocuries per liter. While the Environmental Protection 

Agency standard is 20,000 picocuries per liter, Colorado and California have set theirs at 

400 per liter. What will the impact of the 3rd unit have on additional radioactivity being released 

into the lake with the reduced water levels? (0033-27 (Ruth, Harry)) 

Comment: I’m also concerned about the hazards of tritium exposure. And we also note that 

this tritium is routinely released into the lake and into the atmosphere. How would Dominion 

and the NRC act to limit tritium releases? Both Dominion and the NRC must continue to study 

and make public the effects of tritium exposure on humans and flora and fauna who live in and 

around the lake and downstream. (0034-141 (Day, Elena)) 

Response: The staff will review the impact of tritium releases to Lake Anna and the 

atmosphere in Chapter 5.9 of the SEIS. Tritium releases from the proposed ESBWR reactor 

design for Unit 3 are significantly lower than those evaluated in NUREG-1811, ESP EIS.

Comment: A summary is required that clearly sets out expected radiation impacts in the study 

area. (0035-6 (Goldsmith, Aviv)) 

Comment: The section on emergencies and radiation impacts is not understandable by lay 

persons. A summary is required that clearly sets out (a) expected radiation impacts in the study 

area, and (b) the possible radiation impacts from an emergency. (0035-30 (Goldsmith, Aviv)) 
Appendix D 

NUREG-1917, SEIS D-76 February 2010 

Response: The final ESP EIS (NUREG-1811) published by the NRC in December 2006 

discussed radiological impacts of normal operations in Chapters 5.9 and 7.8. The 

environmental impacts of postulated accidents (emergencies) were discussed in Chapter 5.10 

of NUREG-1811, ESP EIS. Chapter 5.9 and Chapter 5.10 both contain summary information at 

the end of each section. All environmental issues associated with radiological impacts of 

normal operations and environmental impacts of postulated accidents were resolved in NUREG1811, ESP EIS. The analysis for the North Anna Unit 3 SEIS will address only new and 

significant information to determine whether the impact level has changed. Any new and 

significant information identified since the ESP will be evaluated in Chapter 5 (Chapters 5.9 and 

5.10) of the COL SEIS. 

15. Comments Concerning Accidents - Design Basis

Comment: The EIS should address potential consequences (on the Lake, on people, on flora 

and fauna in the region) of a serious accident in the irradiated fuel pool at North Anna-3, and in 

other potential high-level radioactive waste storage facilities. (0026-4 (AuClair-Valdez, Miguel)) 

Response: Design-basis and severe accidents of the proposed Unit 3 are within the scope of 

the SEIS. Impacts related to design-basis and severe accidents previously resolved in the 

NUREG-1811, ESP EIS will be evaluated in terms of new and significant information to 

determine if impact levels should be changed.

Comment: Section 5.10 [Impacts of Postulated Accidents] is hard to understand the possible 

radiation impacts from an emergency. Given that “radiation experts conservatively assume that 

any amount of radiation exposure may pose some risk of causing cancer or a severe hereditary 

effect,” a common language summary is required that clearly sets out expected radiation 

impacts in the study area. (0035-31 (Goldsmith, Aviv)) 

Comment: Please clarify the statements in page SDEIS 5-57 line 35 et. seq. Does the SDEIS 

say that the project would create “730 fatal cancers, nonfatal cancers, and severe hereditary 

effects per 10,000 persons?” (0035-32 (Goldsmith, Aviv)) 

Response: These comments refer to generic information in the North Anna ESP draft EIS and 

draft supplemental EIS that were superseded by the North Anna final ESP EIS (NUREG-1811) 

published by NRC in December 2006. NUREG-1811 was revised to incorporate numerous 

public comments (see NUREG-1811, Appendix E). Dominion was issued an ESP permit 

(ESP-003) in November 2007 for two units at the North Anna Power Station site under the 

specifications contained in that permit. The information presented in NUREG-1811 is resolved. 

The statement quoted above related to the number of fatal cancers, nonfatal cancers, and 

severe hereditary effects is incomplete. The full statement gives a correlation between 

population dose and health effects published by the International Commission on Radiation 

Protection. That correlation says that a population dose of 1 million person-rem can be 

expected to produce 730 fatal cancers, nonfatal cancers, and severe hereditary effects. This 

correlation applies to population doses due to the project. It is used to convert population doses 
Appendix D 

February 2010 D-77 NUREG-1917, SEIS 

to health effects; it is not a statement that the project would cause 730 fatal cancers, nonfatal 

cancers, and severe health effects. 

16. Comments Concerning Accidents - Severe

Comment: When I read about the risk assessment of severe accidents in the environment 

impact statement prepared here, and specifically in Table 518, which I think was renumbered, 

but it’s—it was reviewed somewhat in response to public comments on that section in Volume 2, 

Section 3.14.3, Severe Accidents. And here I quote, A severe accident without loss of 

containment for an advanced boiling water reactor is estimated to have a core damage 

frequency of 1.34 times 10-7. That is 1.34 of the severe accidents in 10 million years. Now, 

how in the world are you predicting 10 million years from here? It just—it’s—my algebra 

teacher, when I was in ninth grade—and this was quite a few years ago --said, You can’t 

extrapolate way beyond your data. And I found this true when I did my master’s degree. I 

found this true when I did my doctorate. You can’t extrapolate like this. What are you doing 

thinking about 10 million years from now, and there is a likelihood of 1.34 accidents, severe 

accidents, in the proposed plant. I object also to the using two decimal points. It gives an 

illusion of—that you know what you’re doing. And I have to say these two decimal points do not 

give any additional information. You don’t have any idea, even to—even to an order of 

magnitude, and to put in 1.34, this is—this is a problem we’ve got in this country. (0034-69

(Bryan, James)) 

Response: The commenter refers to NUREG-1811 ESP EIS, specifically Table 5-18, where 

results are reported per reactor year (Ryr-1). The term reactor year refers to an operating year 

for a given reactor. For these analyses, the probability of a given event occurring are an 

indication of the probability of occurrence per operational year, considering the anticipated 

operational lifetime of the reactor (i.e., 40 years). Although the analyses indicate a very low 

probability occurrence for some events and consequences, this is not equivalent to the 

probability of a given event or consequence if the reactor were operated for millions of years. 

The staff agrees the use of 3 significant figures in the previously-reported results overstates 

their relative degree of accuracy. This comment provides no new and significant information; 

therefore, it will not be evaluated further.

Comment: Now, looking a little further at the same data, there is another problem. And that’s 

that when they do their analysis they leave out Three Mile Island. And if you read the 

explanation for it. Three Mile Island Reactor Number 2 is left out of the data set, and this 

accident -- this absence, I thought it was an accident. But they answer—Three Mile Island, 

Unit 2 is not among the current generation reactors included in preparation of Table 522, 

because it is no longer in operation. Well, do you want to make your basis of thinking the 

elimination of your most significant accident? (0034-70 (Bryan, James)) 

Response: The commenter refers to NUREG-1811 ESP EIS, specifically Table 5-22, where 

results for core damage frequency and population dose risk are compared to 28 operating 

current-generation reactors. Because only operating reactors are included in the comparison, 

the commenter incorrectly infers that lessons learned from the 1978 Three Mile Island Unit 2 
Appendix D 

NUREG-1917, SEIS D-78 February 2010 

accident are not considered. To the contrary, the analyses are made using well-developed 

methods that have been updated based on investigation of the accident at Three Mile Island 

and considerable research following the accident. These methods explicitly consider both preaccident and post-accident human errors. The comparison of analysis results to operating 

current-generation reactors is appropriate because many of the specific errors that led to the 

accident at Three Mile Island have been eliminated or reduced through updated design and 

procedure. This comment provides no new and significant information; therefore, it will not be 

evaluated further.

Comment: The EIS should describe and address the potential consequences of a beyond 

design basis accident at North Anna-3 and should address potential additional risks of a Firstof-a-Kind reactor design. (0026-9 (AuClair-Valdez, Miguel)) 

Comment: He [Dr. James Bryan] mentioned that Three Mile Island is considered as a 

reference case in either the ESP or the COL, wherever he had his comment. And I wanted to 

tell him that Three Mile Island was a PWR, pressurized water reactor. The reactor we are 

proposing or that Dominion is proposing here is ESBWR, a boiling water reactor. What 

happened at Three Mile Island can’t happen at a boiling water reactor. (0034-172 (Stiles, Lisa)) 

Comment: My third concern about the safety issue is the human error problem. And within the 

reports, the NRC says that they are taking into consideration human error. Human error has 

been the problem at Chernobyl, it has been the problem at Three Mile Island, it has been the 

problem in Japanese reactors. And one of the main human reactors—one of the main human 

errors has been when they have neglected to do the safety checks, the analyses that they 

needed to do. Now, you may say, Oh, this is Russia. This is Japan. This is not the United 

States. Well, right this month we have got airlines not being inspected when they needed to be 

inspected. We all know about that. There may be some people in this room that have been 

grounded for it. Fortunately, no one has been damaged by it, as far as I know. But leaving out 

the safety inspections that are mandated has been a worldwide problem, and it has not been 

absent here in the States either. You’ve got to pay more attention to human error. It’s a human 

characteristic. It’s just as part of us as breathing, is that we make mistakes. We try to take 

shortcuts. We try to do things the easy way. When there are safeguards, we figure out ways to 

make it—to overlook them. And this has to be part of a solid safety analysis is human error. 

(0034-71 (Bryan, James)) 

Response: Design-basis and severe accidents of the proposed Unit 3 are within the scope of 

the SEIS. Impacts related to design-basis and severe accidents previously resolved in the 

NUREG-1811, ESP EIS will be evaluated in terms of new and significant information to 

determine if impact levels should be changed. In addition, the staff will evaluate the potential 

consequences of design-basis accidents and the probability and consequences of severe 

accidents for the ESBWR as part of its review of the application for certification of the reactor 

design. While a detailed description of the design certification review is beyond the scope of the 

SEIS, it is important to note that while the reactor design may be new, severe accidents are 

associated with multiple failures of components, such as valves, and that the likelihood of failure 

of components may be reasonably well understood, even if the reactor type is new. The 
Appendix D 

February 2010 D-79 NUREG-1917, SEIS 

analysis methods also explicitly consider both pre-accident and post-accident human errors, 

along with any applicable lessons learned following operational events or accidents at worldwide locations, including the 1978 accident at Three Mile Island Unit 2. These comments 

provide no new and significant information; therefore, it will not be evaluated further.

Comment: Section 5.10 [Impacts of Postulated Accidents] should include a worst case 

analysis for low-probability events. (0035-34 (Goldsmith, Aviv)) 

Comment: A common-language summary of section 5.10.2 [Severe Accidents] is required. 

(0035-35 (Goldsmith, Aviv)) 

Comment: The statement on page 5-69 line 40 that “alternatives to mitigate severe accidents 

are not resolved” is incongruous with the SMALL impact determination. Since the ESP is 

designed to address site-specific issues, these must be resolved now, not at the COL stage as 

is suggested by page 5-70 line 2. (0035-36 (Goldsmith, Aviv)) 

Comment: There should be a Section 7.8.B that discusses the cumulative radiologic impacts 

of emergency situations (accidents and terrorism). Casual discussion in 7.8 of normal 

operations is insufficient treatment for this potentially devastating situation. (0035-39

(Goldsmith, Aviv)) 

Response: These comments refer to information on severe accidents in the North Anna 

ESP EIS (NUREG-1811) published by NRC in December 2006. NUREG-1811 includes 

revisions based on numerous public comments (see NUREG-1811, Appendix E). Dominion 

was issued an ESP permit (ESP-003) in November 2007 for two units at the North Anna Power 

Station site under the specifications contained in that permit. Environmental issues related to 

severe accidents in the ESP application were identified, evaluated, and resolved in 

Chapter 5.10.2 of the ESP EIS (NUREG-1811). Staff will evaluate new information relating to 

severe accidents in Chapter 5 of the COL SEIS to determine whether the impact level has 

changed. The Commission has considered the type of analyses that are appropriate for 

evaluating consequences of severe accidents and has determined that the evaluation should be 

on the basis of mean estimates of risk (51 FR 30028). NUREG-1811 concludes that the risk of 

severe accidents is comparable to the risk of normal operation and that risks of early fatality 

from normal operation or a severe accident are small compared to risks of an early fatality from 

other human activities. NUREG-1811 considered the risks of severe accidents and concluded 

that based on the risk the environmental impacts of severe accidents were SMALL. This does 

not mean that staff determined that the risk of severe accident could not be reduced further. 

The applicant did not address, and was not required to address, severe accident mitigation 

design alternatives and other severe accident mitigation alternatives in the ESP application. 

Therefore, the staff did not address them in NUREG-1811. Severe accident mitigation design 

alternatives and other severe accident mitigation alternatives must be addressed by the 

applicant in the COL application and by the staff in its review of that application. The staff does 

not believe that it is appropriate to assess cumulative impacts of severe accidents, regardless of 

the cause. Should there be a severe accident with large release of radioactive material, the 
Appendix D 

NUREG-1917, SEIS D-80 February 2010 

impacts of that release will dominate the impacts of releases of radioactive material from normal 

operations. And, the likelihood of simultaneous severe accidents is too small to be considered 

reasonably foreseeable. 

17. Comments Concerning the Uranium Fuel Cycle

Comment: It will be used up by the waste that is produced by 2010. So Dominion continues to 

bet that this high-level waste is going to go somewhere else. So I feel that this is irresponsible 

for Dominion as well as the NRC to entertain construction of new nukes when the high-level 

radioactive waste—and now since Barnwell is also going to close in June 2008, the low-level 

radioactive waste issue remains unresolved. (0034-137 (Day, Elena)) 

Comment: The EIS particularly needs to include the fact that—and assume that there will be 

no available repository for the full operating lifetime of this reactor, this proposed reactor, and to 

consider the consequences of onsite storage in perpetuity there on Lake Anna. This would also 

apply to—again, to what Jerry pointed out, was that as of June 2008, South Carolina will be 

closing the Barnwell low-level radioactive waste facility to Virginia, and so the EIS consequently, 

since there are no other sites, I believe it’s the responsibility of the EIS to fully account for the 

consequences of onsite storage of low level—so-called low-level radioactive waste. (0034-44

(Gunter, Paul)) 

Comment: The reactors will create approximately 20 MT/year of nuclear waste. Detailed plans 

for safe waste management, transport, and disposal should be presented and analyzed in the 

COL SDEIS. (0035-37 (Goldsmith, Aviv)) 

Response: The staff will evaluate new and significant information concerning the impact of lowlevel waste storage and disposal in Chapter 6.1 of the SEIS. The safety and environmental 

effects of long-term storage of spent fuel on site has been evaluated by the NRC and, as set 

forth in the Waste Confidence Rule at 10 CFR 51.23 (available at http://www.nrc.gov/readingrm/doc-collections/cfr/part051/part051 0023.html), the NRC generically determined that “if 

necessary, spent fuel generated in any reactor can be stored safely and without significant 

environmental impacts for at least 30 years beyond the licensed life for operation (which may 

include the term of a revised or renewed license) of that reactor at its spent fuel storage basin or 

at either onsite or offsite independent spent fuel installations. Further, the Commission believes 

there is reasonable assurance that at least one mined geologic repository will be available 

within the first quarter of the twenty-first century and sufficient repository capacity will be 

available within 30 years beyond the licensed life for operation of any reactor to dispose of the 

commercial high-level waste and spent fuel originating in any such reactor and generated up to 

that time.” These comments provide no new and significant information; therefore, they will not 

be evaluated further. 

Comment: Finally, we are again facing the very real possibility of uranium mining and milling in 

VA. There are uranium deposits in Orange, Madison, Fauquier, and Pittsylvania Counties. The 

drive by Dominion and other utilities to build new reactors has made uranium mining attractive 
Appendix D 

February 2010 D-81 NUREG-1917, SEIS 

once again after a twenty-five year ban. Mining and milling of uranium has never been 

attempted in a wet climate like ours. (0017-11, 0034-143 (Day, Elena)) 

Comment: Furthermore, the history of mining and milling of uranium in our western states is 

one of high cancer rates. The radioactive tailings love to continue to disburse their radioactivity 

as the wind blows. So the uranium fuel cycle from start to finish leaves a huge carbon imprint, a 

footprint, or whatever. (0017-12, 0034-144 (Day, Elena)) 

Comment: And in Virginia, this is interesting the way it is playing out is the claim for energy 

independence currently is being lauded by those seeking to extract uranium from the enormous 

deposit that has been identified in Virginia, in Pittsylvania County. The basis of this claim is that 

we do currently import about 70 percent of the uranium we use for fuel, for fuel in our reactors 

from abroad, from countries like Canada and Australia and some of the former Soviet Union 

states. So, then, to mine it here in Virginia, I suppose it would help us reduce our dependency 

on foreign sources of energy. I would say that it probably does not reduce our addiction to oil, 

as it has been brought up here tonight. As far as I know, we are not using uranium in our tanks 

at this point. But certainly it would bring up uranium. It would bring it back into our economy in 

the form of both mining and milling. What is interesting is that Virginia is going to be the only 

state in the country that is witnessing firsthand the cause and effect of nuclear expansion. Here 

in Virginia we have both a proposal for a new reactor and a corporation challenging the state’s 

moratorium on uranium mining. (0034-91 (Fisher, Allison)) 

Comment: And these [effects of nuclear expansion as relates to speculation on uranium 

mining] should be present in the environmental impact statement. The NRC should fully review 

the impacts of mining and milling within the scope of the EIS. (0034-93 (Fisher, Allison)) 

Response: Chapter 6.1 of SEIS will address new and significant information related to the 

environmental impacts of the uranium fuel cycle and solid-waste management to include 

uranium mining and milling. The generic impacts of the fuel cycle are codified in 

10 CFR 51.51(b), Table S–3, “Table of Uranium Fuel Cycle Environmental Data.” Per the 

guidance in 10 CFR 51.51, the staff will rely on Table S–3 as a basis for the impact of uranium 

fuel-cycle impacts to include uranium mining and milling.

Comment: So Dominion continues to bet that this high level waste is going to go somewhere 

else. It is irresponsible for Dominion as well as for the NRC to entertain construction of new 

nukes when the high level radioactive waste issue (and now since Barnwell is to close in 

June 2008)—the low level radioactive waste issue as well) remains unresolved. How much low 

level waste does Dominion plan to store on Lake Anna’s shores? How many dry casks does 

Dominion plan to site on the shores of Lake Anna. And will it be expanding water storage 

capacity? Will construction of more pools physically disturb Lake shores? Will more waste 

increase possibility of accident in the irradiated fuel pools? (0017-5 (Day, Elena)) 

Comment: The EIS should address the possible effects of North Anna-3 on the existing dry 

cask irradiated fuel storage units at the North Anna site, including their potential degradation 
Appendix D 

NUREG-1917, SEIS D-82 February 2010 

over time as well as the potential impacts of a large expansion of the dry cask units to store 

high-level radioactive waste from North Anna-3. (0026-5 (AuClair-Valdez, Miguel)) 

Comment: How much low-level waste does Dominion plan to store on Lake Anna shores? 

These are my concerns. This should be addressed in the EIS. How many dry casks does 

Dominion plan to site on the shores of Lake Anna? How will it be expanding water storage 

capacity for spent fuel? Will construction of more pools physically disturb lake water? Will more 

waste increase the possibility of accident in the irradiated fuel pools? (0034-138 (Day, Elena)) 

Comment: The EIS should address how and where all of the low-level radioactive waste at 

North Anna-3 can be expected to generate during its lifetime will be stored. Virginia’s access to 

the Barnwell, South Carolina low-level radioactive waste facility will end in June 2008. There 

are no current plans to build a new facility to handle radioactive waste generated in Virginia. 

This the EIS should assume that all low-level radioactive waste generated by North Anna-3 will 

be stored on-site for its licensed lifetime. (0026-7 (AuClair-Valdez, Miguel)) 

Comment: We believe that the on-site storage of radioactive waste poses unreasonable 

environmental and security risks for the people of Virginia. Building new reactors will increase 

these risks and leave our children and grandchildren with a horrible burden. (0034-148

(Black, Betty)) 

Response: The staff will evaluate new and significant information related to the impacts of lowlevel waste storage and disposal and the potential of fuel handling accidents in the reactor’s 

spent fuel pool in Chapter 6.1 and 5.10.1 of the SEIS, respectively.

Comment: The uranium fuel cycle from start to finish leaves a huge carbon footprint--in fact it 

takes two coal plants just to run the facility that processes the uranium into fuel rods in 

Kentucky—regardless of industry claims that there building nukes to save us from greenhouse 

gas emissions and global warming. Dominion’s plans for new nukes will associate it with the 

despoliation of our pristine rural VA counties if mining is allowed in the Commonwealth. 

(0017-13 (Day, Elena)) 

Comment: In fact, it takes two coal plants at Paducah, Kentucky to run the facility that 

processes the uranium into fuel rods. So, regardless of the claims of the industry that building 

nukes to save us from greenhouse gas emissions and global warming, you know, it’s not true 

that uranium cycle from start to finish leaves a huge carbon footprint. (0034-145 (Day, Elena)) 

Response: Chapter 6.1 of the SEIS will address new and significant information related to the 

environmental impacts of the uranium fuel cycle and solid-waste management to include 

uranium enrichment activities. The generic impacts of the fuel cycle are codified in 

10 CFR 51.51(b), Table S–3, “Table of Uranium Fuel Cycle Environmental Data.” Per the 

guidance in 10 CFR 51.51, the staff will rely on Table S-3 as a basis for the impact of uranium 

fuel-cycle impacts to include uranium enrichment.
Appendix D 

February 2010 D-83 NUREG-1917, SEIS 

18. Comments Concerning Transportation

Comment: If and when a repository for high level waste is licensed, how will the waste be 

transported safely, along what routes and is an evacuation plan included to safeguard residents 

in Louisa and along transportation routes in VA. (0017-6, 0034-139 (Day, Elena)) 

Comment: The EIS should address possible effects of transportation of radioactive waste 

generated at North Anna, in the unlikely event a waste repository ever will be built. This should 

include road, rail and barge transportation. If barges are not used, then trucks or trains would 

be. The Baltimore train tunnel fire of 2001 could have killed thousands if high-level radioactive 

waste had been on board, and that route has been targeted by the Dept. of Energy in the past. 

(0026-6 (AuClair-Valdez, Miguel)) 

Response: A detailed analysis of the health and safety impacts of transporting fuel and waste 

by truck to and from the proposed North Anna Power Station site will be conducted and included 

in Chapter 6 of the SEIS. Emergency preparedness planning and preparations to respond to 

transportation accidents is described in detail in the “Final Environmental Impact Statement for a 

Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste 

at Yucca Mountain, Nye County, Nevada” (DOE/EIS-0250F) and will not be addressed in the 

SEIS.

19. Comments Concerning Decommissioning

Comment: Section 6.3 of the SDIES mentioned that decommissioning would eventually be 

required and “reduction of residual radioactivity to a level that permits termination of the NRC 

license.” Has this been successfully done anywhere in the US? What financial security does 

the operator post to assure successful decommissioning? (0035-38 (Goldsmith, Aviv)) 

Response: Several nuclear power plants have successfully undergone decommissioning; in 

addition, 14 plants are currently undergoing decommissioning (see http://www.nrc.gov/infofinder/decommissioning/power-reactor/). Federal regulations (10 CFR 50.33(k) and 

10 CFR 50.75(b)) require an applicant for a COL license to certify that sufficient funds will be 

available to assure radiological decommissioning at the end of power operations. Chapter 6.3 

of the SEIS will evaluate the applicant’s plan for assuring these funds are available. 

20. Comments Concerning Cumulative Impacts

Comment: The EIS should address the cumulative effects of routine radiation releases on 

nearby populations and on aquatic life in and around the lake. (0026-11

(AuClair-Valdez, Miguel)) 

Response: The cumulative impacts associated with the construction and operation of the 

proposed Unit 3 will be evaluated and the results of this analysis will be presented in Chapter 7 

of the SEIS.
Appendix D 

NUREG-1917, SEIS D-84 February 2010 

Comment: Plant 3 was considered in a stand-alone condition. No consideration was made for 

the alternative of installing additional water conservation measures to the existing power 

reactors of Units 1 and 2, to compensate or mitigate against the significant, adverse, 

incremental impacts caused by Unit 3. (0034-33 (Remmers, Ken)) 

Response: Portions of the alternative cooling systems (i.e., cooling towers) previously resolved 

in the NUREG-1811, ESP EIS will be evaluated in terms of new and significant information to 

determine if impact levels should be changed. Information not analyzed in NUREG-1811, ESP 

EIS regarding alternative cooling systems intake and discharges structures will be evaluated in 

Chapter 9 of the SEIS.

21. Comments Concerning the Need for Power

Comment: Our goal in applying for the COL is to continue to maintain the option to build a third 

nuclear unit to meet the skyrocketing demand for electricity projected for Virginia. Right now, 

Virginia is the second largest importer of electricity in the nation, behind California. The state 

imports 30 percent of its electricity from electrical generators located in other states. Virginia 

also is one of the fastest-growing states in the United States. (0013-1 (Grecheck, Eugene)) 

Comment: The PJM Interconnect, the regional transmission operator for the Mid-Atlantic 

region, projects that by 2017 there will be a large gap between the amount of electricity that will 

be required for our customers and the electrical generation facilities available in Virginia to meet 

this demand. We are talking about a gap of 4000 megawatts of generating capacity, of which 

2000 megawatts must be from the type that is available 24 hours a day, seven days a week. 

(0013-2 (Grecheck, Eugene)) 

Comment: As you can see, according to U.S. DOE projections, we will need to increase our 

production of electricity by nearly 50% in the coming years. This increase is necessary due to 

population expansion, a greater reliance on electronics, and soon a major shift towards plug-in 

hybrid electric vehicles. As you can see, even if North Anna Unit 3 is built, and by some miracle 

we are able to miraculously expand our renewable contribution to 15%, we still have a huge gap 

of needed electricity. What’s even more sobering is that means we have to keep every coal, oil, 

gas, and nuclear station that we currently operate today. (0025-2 (Stuart, Michael)) 

Comment: Virginia is facing a significant shortfall of electricity of about 4000 megawatts in 

2017. With today’s volatile energy markets, we can no longer afford to rely on imported power 

for Virginia’s needs. If built, Unit 3 would make us less dependent on electricity produced 

outside the state. And it will also provide nearly a third of that shortfall in 2017. (0034-101

(Marshall, Burton)) 

Comment: Nuclear energy is a key ingredient in the Virginia energy plan, which calls for a 

20 percent increase in the in-state production of electrical energy by 2017 and the simultaneous 

30 percent decrease in the level of greenhouse gas emissions by 2025. According to remarks 

made by Steven Walsh, Chair of Governor Kaine’s Energy Policy Advisory Council, 

conservation and renewable energy targets will only get us halfway to this target. Research in 
Appendix D 

February 2010 D-85 NUREG-1917, SEIS 

the use of clean-burning coal-fired power plants and nuclear energy is clearly needed to make 

up the difference. (0019-1, 0034-116 (Brown, Eugene F.)) 

Comment: One of the issues that—concerns I have, and I think everybody does, we have—

there will be a shortage of energy (0034-15 (Wright, Jack)) 

Comment: Clearly the need for 4000 megawatts of new generating capacity, with 2000 of that 

being base load, is well-documented and validated by the PJM Interconnection Corporation. 

Also, the evaluation of the alternatives available to meet future energy needs show that to best 

meet Virginia needs, nuclear must play a large part. (0034-163 (Stiles, Lisa)) 

Comment: There is a need for a substantial amount of new generation capacity here in this 

state. Recent estimates call for an additional 4000 megawatts within a decade in order to serve 

the needs of Virginia. The southeastern region is a well-balanced mix of energy resources that 

help maintain reliable service and act as a hedge against price volatility and supply 

interruptions. It is important that we expand generation capacity and that we maintain the 

diversity of these sources. (0034-2 (Watkins, John)) 

Comment: The United States, and Virginia in particular, has an ever increasing need for 

electric power. In order to maintain our economic prosperity, we must continue to develop new 

sources of energy—electricity—as well as conserve as much as possible. This new unit will 

help in meeting that increased need. (0034-27 (Manzari, Jack)) 

Comment: The Virginia Energy Plan, of which I was a part in drafting and getting passage of in 

the Virginia Legislature back in 2006, calls for the needs of nuclear energy here in Virginia as an 

important capacity. (0034-5 (Watkins, John)) 

Comment: Virginia is in a deficit as far as generating capacity is concerned. The generation 

gap is projected to be about 4000 megawatts by 2017, and that goes well beyond already 

significant ability to import power from other states. In order to keep Virginia’s growing energy 

needs and keep rates stable, we surely need to have a strong investment in baseload energy 

sources within the Commonwealth. (0034-60 (Moore, Kenneth)) 

Comment: It is projected that Dominion’s Virginia service territory will require an additional 

4000 megawatts in the next decade. The state currently is the second largest importer of 

electricity, second only to California. Because 30 percent of the electricity currently used in 

Virginia is imported, Virginians are more vulnerable to price volatility in the electricity market. In 

order to keep rates stable, there is a significant need for investment in a diverse mix of 

generation within the state. (0034-66 (Ellis, Larry)) 

Comment: Over the next 10 years, Virginia will need to add an additional 4000 megawatts of 

capacity in order to keep up with demand. This electricity can either be generated here in 

Virginia, bringing our state closer to energy independence, or it can be imported. Either way it 

will be needed. North Anna Unit 3 would generate an additional 1520 megawatts. 

(0034-80 (Fawls, Rebecca)) 
Appendix D 

NUREG-1917, SEIS D-86 February 2010 

Comment: I am here today to speak about the need for power. Let me start by making it clear 

that Virginia is the second largest importer of electricity in the United States. The only state that 

imports more electricity in the United States is California. (0034-84 (Stuart, Michael)) 

Response: Affected states or regions prepare a Need for Power evaluation and assessment of 

the regional power system for planning or regulatory purposes. A Need for Power analysis may 

also be prepared by a regulated utility and submitted to a regulatory authority, such as a State 

Public Utility Commission. However, the data may be supplemented by information from other 

sources. The determination for the need for power is not under NRC’s regulatory purview. 

When another agency has the regulatory authority over an issue, NRC defers to that agency’s 

decision. The NRC staff reviews the Need for Power and determines if it is (1) systematic, 

(2) comprehensive, (3) subject to confirmation, and (4) responsive to forecasting uncertainty. If 

the Need for Power evaluation is found to be acceptable, no additional independent review by 

the NRC is needed. The Need for Power review will be discussed in Chapter 9 of the SEIS.

Comment: While I laud renewable energy sources such as solar and wind and believe that we 

must continue to build more of these kinds of plants, the point I am making is that they just 

cannot keep up with the current growth in electrical demand compared to other electrical 

generation sources such as nuclear. (0021-4 (Pierson, Mark)) 

Comment: I am here today to speak to the issue of the Need for Power. Let me start by 

making it clear that Virginia is the second largest importer of electricity in the United States. 

The only state that imports more power than Virginia is California. (0025-1 (Stuart, Michael)) 

Comment: North Anna right now contributes 17 percent of the power generated and used by 

Dominion customers. Of course, the new unit will increase this. And this station is strategically 

located between two very high growth areas in the company. This is a source for base-loaded 

power, which can operate at a very low cost and will enable us to keep electric rates within a 

reasonable amount of charge at which probably inflation increases. (0034-106 (Farmer, John)) 

Comment: Base load means a lot of generation when it’s needed. And the alternatives are 

offered of conservation, solar, wind energy, and tidal energy. Now, the problem is that when the 

wind doesn’t blow and the sun doesn’t shine, then base load is needed for reliability of the 

system as a whole to provide our customers. And conservation has a limited application in 

favor of an increase in population and customer demand. (0034-109 (Beament, Peter)) 

Comment: Why I applaud renewable sources, such as solar and wind, and believe that we 

must continue to build more of these kinds of plants, the point I am making is that they just 

cannot keep up with the current growth in electrical demand compared to other electrical 

generation sources, such as nuclear. (0034-123 (Pierson, Mark)) 

Comment: Last fall, last summer, we reached almost 20,000 megawatt hours as a peak load, 

so we doubled from ‘84 to ‘07. The projections indicate that we will double again by 2030. 

That’s 40,000 megawatts. Now, we all talk about conservation and, you know, I’ve got some of 

those little light bulbs that burn less energy, and I tend to cut off lights when I leave rooms, like I 
Appendix D 

February 2010 D-87 NUREG-1917, SEIS 

was taught. But at the same time, we can’t get there with conservation. We can help, but we 

can’t get there. We’ve got to have additional energy. (0034-56 (Tribble, Charles)) 

Response: The NRC staff will review the Need for Power and determine if it is (1) systematic, 

(2) comprehensive, (3) subject to confirmation, and (4) responsive to forecasting uncertainty. If 

the Need for Power evaluation is found to be acceptable, no additional independent review by 

the NRC is needed. The Need for Power review will be discussed in Chapter 9 of the SEIS. 

Regional forecasts, conservation, imports, and generation alternatives will be addressed in the 

discussion.

22. Comments Concerning Alternatives - Energy

Comment: Numerous comments have been received questioning an agency’s obligation, 

under the National Environmental Policy Act, to evaluate alternatives to a proposed action 

developed by an applicant for a federal permit or license. (0024-7 (Zeller, Lou)) 

Comment: The alternative section of the needs to assess other alternatives beyond siting such 

as renewables, demand side management, repowering of Units #1 and #2, etc. (0035-40

(Goldsmith, Aviv)) 

Response: Alternatives to the proposed action including energy alternatives and the no-action 

alternative will be considered in the SEIS. 

Comment: If and how conservation and energy efficiency might offset the need to embark on 

construction of new nukes is not even mentioned (has Dominion even explored these options?). 

(0017-2 (Day, Elena)) 

Comment: The North Anna Power Station Unit Three reactor plant would provide about 

1500 MW of electricity. For comparison, this is equivalent to about 750 to 1000 wind turbines—

more than twice the size of the world’s largest wind farm. Additionally, wind turbines have an 

average output of about 30% of their maximum power capacity, only providing electricity when 

wind speeds are able to support it. Thus, to consistently provide the same electrical power 

generation as North Anna Unit Three, it would require about three times as many wind turbines 

or 2000 to 3000 turbines. I contend the environmental impact of one modern state-of-the-art 

nuclear reactor is much less than the impact of 3000 wind turbines covering 100 acres per 

turbine or over 300,000 acres total. Additionally, on a hot, steamy, windless day when power 

loads from air conditioning are at a peak, wind power is not available. However, North Anna 

Unit Three would be on line providing 1500 MW of electricity all day. (0021-2, 0034-121

(Pierson, Mark)) 

Comment: If we compare a nuclear reactor to solar generation, it would take at least 

12,000 acres of solar arrays to produce a maximum electrical power output equivalent. But 

once again, solar is not always available, especially at night, and the average output is only 

20 percent of the maximum capacity. Thus, over 60,000 acres, or just under 100 square miles, 

of solar arrays would be needed to consistently produce the same output as one nuclear 
Appendix D 

NUREG-1917, SEIS D-88 February 2010 

reactor. Of course, the largest solar farm currently planned to be built would only yield about 

80 MW of electricity at an estimated cost of about half a billion dollars. Note also that most 

solar facilities are being built in the western United States in the desert where there is no snow 

and ice. Thus, on an overcast snowy and icy day on the east coast during a peak heating load, 

solar power is not available. However, North Anna Unit Three would be on line providing 

1500 MW of electricity day and night. (0021-3, 0034-122 (Pierson, Mark)) 

Comment: The EIS should fully consider alternatives to North Anna-3, including but not limited 

to: 

* use of renewable energy to meet electricity demand 

* use of energy efficiency to reduce electricity demand, including various and aggressive energy 

efficiency program scenarios 

* use of a combination of renewable energy and energy efficiency to meet electricity demand 

* the no action alternative (0026-1 (AuClair-Valdez, Miguel)) 

Comment: More [solar] energy falls on the surface of the Earth in one hour than the entire 

humanity uses in a year. It’s time for us to get creative, and it’s time to think outside the box. 

(0034-134 (Day, Donal)) 

Comment: Let me also point out to all of these people who talk about the windmills only 

producing when the wind blows and solar only producing when the sun shines. Dominion 

operates one of the largest pump storage facilities in the world because not all of the time they 

run their nuclear power plant, people are using the energy. They pump water uphill and store it 

very effectively and run it downhill. There is no reason that that same technique can’t be used 

for wind or for solar. (0034-135 (Day, Donal)) 

Comment: And there are many things that recent claims and stories didn’t mention, such as 

though the last August heat wave is often mentioned, most stories fail to point out that during 

the hottest weeks, the nation’s nuclear power plants were running at 98 percent capacity factor. 

During California’s heat wave in 2006, in which 60 people died, San Onofree and Diablo 

Canyon nuclear power plants were running at full output. On the other hand, the capacity factor 

for the state’s wind farms was an abysmal four percent. This performance for wind turbines 

during a heat wave is not unusual. According to the Energy Information Administration, capacity 

factors for wind farms are always the lowest during the hottest months of the year. (0034-167

(Stiles, Lisa)) 

Comment: Hydroelectric and thermal solar use more water per megawatt hour produced than 

nuclear. The already low efficiency of solar photovoltaics drops even further at high 

temperatures. And we certainly don’t want to depend on being able to grow corn, sugar, or 

switch grass, or anything else during a prolonged drought. The single largest nuclear facility in 

North America is in the middle of the desert in Arizona. And it does not suffer from any droughtrelated setbacks simply because water conservation was built into the design. (0034-168

(Stiles, Lisa)) 
Appendix D 

February 2010 D-89 NUREG-1917, SEIS 

Comment: There are alternatives out there, though, that are not anywhere near as expensive 

as the nuclear energy is and have lower CO2 emissions than nuclear energy. If you look at wind 

power, which everybody has bashed wind power a lot tonight, there is a very interesting study 

from March 2007 from the Oxford Research Group that just compares the carbon emissions of 

nuclear power to the carbon emissions of wind power. And, at its best, nuclear power has 4 

grams per kilowatt hour more of carbon emissions than wind power and 44 more grams of 

carbon emissions per kilowatt hour at its worst. So that’s one thing to consider. What do we 

need to consider? We need to be considering ways to look at energy efficiency. Energy 

efficiency is a realistic reliable way to do it. And we can decrease our energy consumption by 

20 percent and be able to have no net cost to the economy as well as we need to shift to 

renewable energy. (0034-211 (Tolbert, J.R.)) 

Comment: The scope of the EIS also considers alternatives to the project. This includes a 

no-action option. And this goes back to the first statement I made. I mean, obviously the 

alternative question is paramount here in Virginia. It asks the following. If not this reactor, how 

will Virginia meet its energy needs or we can pose it another way. Do we even need to assume 

the risk associated with the new reactor and mining in order to keep the lights on? I appreciate 

the graph that was just up here a few minutes ago. And I saw what was trying to be projected. I 

think what that was speaking to was not potential for renewable energy here in Virginia. It was 

talking about the political will and the utility’s will to implement those kind of technologies. So, to 

address these questions, the EIS should consider that Virginia’s choices are not limited to new 

nuclear or coal. In fact, it is technically and economically feasible for a diverse mix of existing 

renewable energy and efficiency technologies to completely need Virginia’s electricity needs 

over the coming decades. (0034-94 (Fisher, Allison)) 

Comment: These renewable resources could be harnessed effectively and reliably and without 

producing carbon dioxide or carbon emissions, radioactive waste, or relying on mining a finite 

resource. According to the National Renewable Energy Laboratory data in a Virginia Center for 

Coal and Energy Research study, Virginia’s electricity needs can be fully met in the coming 

decades by wind, solar, advanced hydroelectric power, and geothermal heat pumps. Then the 

EIS should include a full examination of the following data from the NREL study. First, Virginia’s 

wind potential comes over 104 million megawatt hours. That is over 92 percent of Virginia’s 

total annual electricity consumption. Virginia’s PV solar potential is 25,000 megawatts by 2025, 

which would generate over 46 million megawatt hours annually. Right now that’s... And then, 

finally, geothermal heat pumps could also be used in Virginia to reduce the energy used for 

heating and cooling billings by 30 to 60 percent. So it’s not just turning off your lights, and it’s 

not just putting in those newfangled light bulbs. There’s some other stuff out there that could be 

implemented. (0034-95 (Fisher, Allison)) 

Comment: And you can turn your considerable talents and your healthy ambitions to lifeenhancing projects, utilizing solar, wind, and wave energy to creating real and not bogus safety 

and security and to safeguarding the intensity of our relationship with future generations and 

with the whole of the natural world. (0034-99 (Nguyen, Vanthi)) 
Appendix D 

NUREG-1917, SEIS D-90 February 2010 

Comment: It is time for Dominion to stop its quest for new nukes and, instead, commit to 

programs of conservation, efficiency in conjunction with renewables as they come on line. 

(0034-146 (Day, Elena))

Response: Alternative energy sources, including energy conservation and renewable energy 

sources, will be addressed in Chapter 9 of the SEIS.

23. Comments Concerning Alternatives - System Design

Comment: I am hoping that you could use some kind of cooling tower to do the job [avoid 

lowering lake level]. (0010-3 (Hayo, Dennis)) 

Comment: The solution is simple although it may cost more it will insure Lake Anna continues 

to be a major state attraction. Dominion has proposed dry cooling for a potential Unit 4. If this 

was used for Unit 3 also then these major issues go away. This type of cooling is used in other 

countries why not here. (0012-6 (Heino, George and Gerry)) 

Comment: A new-fresh look at cooling technologies needs to be performed. Specifically the 

hybrid-cooling proposed will only remove up to 1/3 of the heat of the entire system during the 

hot humid days. The other 2/3 will be done by the wet cooling with large evaporation 

(16.6 MGD). In contrast dry cooling technology would consume only about 5-10% of that 

amount. Despite this enormous water savings, most of the cooling for new power plants 

primarily uses wet cooling. This is because on hot days, dry cooling can lead to increased 

turbine back pressure that prevents a plant from generating at its full rated capacity. The 

problem is compounded because hot days are precisely when the electricity demand is the 

highest. This hot-day performance problem with dry-cooled units can be alleviated by using 

small water supplemental cooling as needed. One such method recommended PIER EnergyRelated Environmental Research http://www.energy.ca.gzov/reports/2004-03-09 50003-

109.PDF is to introduce a small amount of water spay into the cooling tower inlet air stream, 

where it evaporates and cools the air. Studies have shown that reducing inlet air temperature 

by even a few degrees can maintain much of the plant’s output during hot hours. This is one of 

many dry cooling examples which are currently being used in the USA and worldwide. This dry 

cooling needs to be studied more carefully. (0016-2 (Remmers, Ken)) 

Comment: Plant #3 was considered in a standalone condition and no consideration was made 

for the alternative of installing additional water conservation measures on the existing nuclear 

power reactors Units 1 and 2, to compensate or mitigate against the significant and adverse 

incremental impacts that will be caused by Unit 3. Judge Karlin (ALSBP) stated that some of 

the once-through cooling water from Units 1 and 2 could be diverted to the cooling tower used 

for Unit 3. While this diversion would be small, it would offset some of the impacts of Unit 3. He 

rejected the NRC staff’s position that such an offset is per se unreasonable under NEPA. He 

stated There is no dispute that the NEPA alternative analysis {is the heart of the environmental 

impact statement}. When a company operates an existing facility that emits pollution and/or has 

adverse environmental impacts, it is common for a regulator to at least consider, and sometimes 

impose, additional environmental controls on the existing units as trade-off for obtaining 
Appendix D 

February 2010 D-91 NUREG-1917, SEIS 

approval to construct additional units. Judge Karlin stated It seems to me that creative nuclear 

engineers and environmental scientist, if properly motivated, might very well propose realistic 

offsets or mitigation measures that could be applied to the pre-existing reactors on the same 

site. This is significant new information that needs to be addressed. (0016-3 (Remmers, Ken)) 

Comment: The NRC should now determine how to implement the modest recommendations of 

ASLB Judge Karlin who parted ways with the majority on water supply: “My [Judge Alex Karlin] 

dissent is also based on the fact that Section 8.2 of the FEIS, entitled “System Design 

Alternatives” and the NRC Staff, excluded, per se, even considering the alternative of asking or 

requiring Dominion’s affiliates to install additional water conservation measures on the existing 

nuclear power reactor Units 1 and 2, to compensate or mitigate against the significant and 

adverse incremental impacts that will be caused by proposed Units 3 and 4.” (0024-12

(Zeller, Lou)) 

Comment: The drought cycles will double if the wet/dry cooling method for Unit 3 is selected. 

(0028-13 (Ruth, Harry)) 

Comment: We have several concerns, primarily with the cooling method proposed for the 

3rd reactor which will use up to 24 million gallons a day of Lake Anna water. If the cooling 

method were changed to dry cooling which Dominion has proposed for the 4th reactor and 

which is used in other parts of the world, most of our concerns would go away. (0028-2, 0028-4

(Ruth, Harry)) 

Comment: One alternative discussed, but not proposed by Dominion for the 3rd reactor’s 

cooling method is to exclusively use Dry Air Cooling for the 3rd unit, which would then negate 

any further water withdrawals from our small watershed and would also hopefully reduce major 

safety problems in the event that the dam would break or be blown-up by a terrorist attack, 

causing sudden loss of water for cooling any of the reactors. The North Anna Nuclear Power 

Plant (which supplies over 20% of Virginia’s power) could be offline for 3 years while we wait for 

the lake to refill. Our power would be purchased from other sources and our bills would 

increase significantly. The dry-air cooling appears to be a feasible option, since this is the same 

technology that Dominion has proposed for Unit 4 and is used by many overseas countries that 

do not have a local water source. In addition, many of the recommendations by VDEQ analysis 

to the NRC, requests that the air cooling mode be used with Unit 3 for 7 months of the year to 

reduce lake water drawdown and reduce the risk of a complete Unit 3 shutdown. In its 

response to the ESP DEIS, VDEQ’s Division of Water Resources (DWR) expressed its 

preference that the once-through cooling process proposed for Unit 3 be changed to a dry 

cooling tower because the dry cooling tower would results in less consumptive use of water 

than the either the once-through cooling or the combination wet/dry cooling tower. Also in its 

comments on the DEIS, DWR stated that it would have no concerns about this project if both 

the third and fourth reactors at North Anna were air cooled. The COL DEIS should fully analyze 

this alternative dry cooling method. (0028-27 (Ruth, Harry)) 
Appendix D 

NUREG-1917, SEIS D-92 February 2010 

Comment: Dry Air cooling of the 3rd reactor will preserve this beautiful lake resource for future 

generations and will not create all the decreasing water levels and negative effects as defined 

above that will be caused by the proposed wet/dry cooling towers. (0028-35 (Ruth, Harry)) 

Comment: The NRC should evaluate including the system design alternative of imposing some 

form of water saving measures and temperature reductions on the two nuclear reactors that 

already exist on the site, as a form of offset to the impacts of the proposed new reactors. Since 

there are significant surface water impacts that will be caused by the proposed Unit 3 (cooling 

method using up to 24 million gallons per day), the system design alternatives should include 

the alternative of imposing some form of water saving measures and temperature reductions on 

the two nuclear reactors that already exist on the site, as a form of offset to the impacts of the 

proposed new reactor. These Unit 1 & 2 offsets are necessary under the National 

Environmental Policy Act (NEPA) where the applicant and its affiliates seek to add a nuclear 

reactor at the same location of existing nuclear operations. The Units I & 2 water conservation 

measures should mitigate against the significant -and adverse incremental impacts that will be 

caused by the proposed Unit 3 cooling method. (0033-17 (Ruth, Harry)) 

Comment: The COL DEIS should fully analyze alternative cooling methods for the 3rd reactor 

which do not create all the environmental impacts defined above. An alternative cooling method 

that does not cause declining water levels would mitigate the LARGE declining water level 

impacts from the proposed 3rd reactor wet/dry cooling method currently proposed. (0033-28

(Ruth, Harry)) 

Comment: One alternative discussed, but not proposed by Dominion for the 3rd reactor’s 

cooling method is to exclusively use Dry Air Cooling for the 3rd unit, which would then negate 

any further water withdrawals from our small watershed. (0033-29 (Ruth, Harry)) 

Comment: Dry-air cooling appears to be a feasible option, since this is the same technology 

that Dominion has proposed for Unit 4 and is used by many overseas countries that do not have 

a local water source. In addition, many of the recommendations made by VDEQ analysis from 

almost all Virginia regulation authorities to the NRC, requests that the air cooling mode be used 

with Unit 3 for 7 months of the year to reduce lake water drawdown and reduce the risk of a 

complete Unit 3 shutdown. In its response to the ESP DEIS, VDEQ’s Division of Water 

Resources (DWR) expressed its preference that the once-through cooling process proposed for 

Unit 3 be changed to a dry cooling tower because the dry cooling tower would results in less 

consumptive use of water than the either the once-through cooling or the combination wet/dry 

cooling tower. Also in its comments on the DEIS, DWR stated that it would have no concerns 

about this project if both the third and fourth reactors at North Anna were air cooled. (0033-31

(Ruth, Harry)) 

Comment: Another alternative cooling method to be considered is the small water 

supplemental cooling method recommended by PIER Energy-Related Environmental Research. 

With the current proposed wet/dry cooling this will only remove up to 1/3 of the heat of the entire 

system during the hot humid days. The other 2/3 will be done be by the wet cooling with large 

evaporation (16.6 MGD). In contrast dry cooling technology would consume only about 10% of 
Appendix D 

February 2010 D-93 NUREG-1917, SEIS 

that amount. Despite this enormous water savings, most of the cooling for the proposed power 

plant would still use primarily wet cooling. This is because on hot days, dry cooling can lead to 

increased turbine back pressure that prevents a plant from generating at its full rated capacity. 

The problem is compounded because hot days are precisely when the electricity demand is the 

highest. This hot-day performance problem with dry-cooled units can be alleviated by using 

small water supplemental cooling. This supplemental cooling would introduce a small amount 

of water spray into the cooling tower inlet air stream, where it evaporates and cools the air. 

Studies have shown that reducing inlet air temperature by even a few degrees can maintain 

much of the plant’s output during hot hours. This is one of many dry cooling examples which 

are currently used in the USA and worldwide. No such studies of dry cooling were performed in 

the EIS-ESP because the PPE did not define a specific reactor design. This supplemental dry 

cooling needs to be studied more carefully before a cooling method is selected. (0033-32

(Ruth, Harry)) 

Comment: Another alternative cooling method would be for Dominion to run water pipes from 

the James River to the North Anna site to provide cooling for the Pr reactor without impacting 

the Lake Anna water level and the related negative effects. This alternative would also provide 

additional water for the power plant in the event that a dam leak occurred causing the shutdown 

of Units 1 and 2. All eggs would not be in the same basket of using exclusively Lake Anna 

water and also gives the additional opportunity of cooling Unit 4 in the future. Louisa County is 

currently planning to pipe in water from the James River to the Zion Crossroads in the county; 

possibly Dominion could participate in a joint venture with the county to extend the water pipe to 

the power plant at Lake Anna. (0033-33 (Ruth, Harry)) 

Comment: Other alternative cooling methods (i.e., dry cooling that Dominion proposed for the 

4th reactor) would not impact the lake level. (0033-86 (Ruth, Harry)) 

Comment: The consumption of an additional million gallons of water a day only aggravates an 

already serious condition. If the proposed cooling towers are to be used, then consideration 

must be given to other options to conserve and/or send water back into the lake for 

environmental concerns and public safety as the lake was originally designed. This is required 

to help facilitate the needs of the nuclear power plant, control water for usage in Hanover 

County, provide safe boating conditions on the lake for recreation, and ultimately help restore 

and promote business for all of the communities. (0034-178 (Jones, Dale)) 

Comment: The solution is simple. Although it may cost more, it will ensure Lake Anna 

continues to be a major state attraction. Dominion has proposed dry cooling for potential Unit 4. 

If this were used for Unit 3 also, then these major issues would go away. This type of cooling is 

used in other countries. So we can use it here. (0034-196 (Heino, George and Gerry)) 

Comment: A new fresh look at cooling technologies needs to be performed, specifically the 

hybrid cooling process, will only remove up to one-third of the heat of the entire system during 

the hot humid days. The other two-thirds will be done by wet cooling with large evaporation—

the 16.6 million gallons a day. In contrast, dry cooling technology would consume only about 

5 to 10 percent of that amount. Despite this enormous water savings, most of the cooling for 
Appendix D 

NUREG-1917, SEIS D-94 February 2010 

new power plants primarily use wet cooling. This is because on hot days dry cooling can lead 

to increased turbine back pressure that prevents a plant from generating at its full rated 

capacity. This problem is compounded because the hot days are precisely when the electric 

demand is the highest. The hot day performance problem with a dry cooled unit can be 

alleviated by using a technique such as small water supplemental cooling as needed. One such 

method is recommended by PIER Energy-Related Environmental Research—to introduce a 

small amount of water spray in the cooling tower inlet stream where it evaporates and cools the 

air, and such studies have shown that reducing the inlet air temperature, even by a few 

degrees, can maintain much of the plant’s output during hot hours. This is just one of many dry 

cooling examples which are currently being used in the USA and worldwide. No such studies of 

dry cooling were performed in the ESP EIS, because the PPE did not define this specific reactor 

design. (0034-32 (Remmers, Ken)) 

Comment: Judge Karlin of the Atomic Licensing Safety Board Panel stated that some of the 

once through cooling water from Unit 1 and 2 could be diverted to the cooling tower used for 

Unit 3. While this diversion would be small, it would offset some of the impacts of Unit 3. He 

rejected NRC staff position that such an offset per se is unreasonable under NEPA. He stated 

there is no dispute that the NEPA alternative analysis is the heart of the environmental impact 

statement. When a company operates in an existing facility and emits pollution and/or has 

environmental impacts, it is common for regulators to at least consider, and sometimes impose, 

additional environmental controls on existing units as a tradeoff. Judge Karlin stated, It seems 

to me that creative nuclear engineers and environmental scientists, if properly motivated, might 

very well propose a realistic offset or mitigation measures that could be applied to the 

preexisting reactors at the same site. (0034-35 (Remmers, Ken)) 

Response: The issue of alternative cooling system designs at North Anna was partially 

resolved in NUREG-1811, ESP EIS and will be evaluated in terms of new and significant 

information to determine if impact levels should be changed. Information not analyzed in 

NUREG-1811, ESP EIS regarding alternative cooling systems intake and discharge structures 

will be evaluated in Chapter 9 of the SEIS. 

Comment: Section 3 introduced the hybrid cooling tower. Is there an operating nuclear plant in 

the U.S. that has demonstrated this hybrid cooling tower technology is appropriate and safe for 

such a large thermal load? If not, the technology risks should be assessed and discussed 

herein. (0035-15 (Goldsmith, Aviv)) 

Comment: Since water is a critical concern, among the major alternatives that should be 

considered in detail in Chapter 8 are the retrofitting of a cooling tower to Units #1 and/or #2, and 

the application of a dry cooler to Unit 3. Factors in the analysis such as capital and operating 

costs and operating efficiencies should be detailed. The conclusion on page 8-5 line 23 is not 

supported. (0035-41 (Goldsmith, Aviv)) 

Response: These comments refer to information in the North Anna draft ESP EIS that was 

superseded by the North Anna final ESP EIS (NUREG-1811) published by NRC in December 

2006. Dominion was issued an ESP permit (ESP-003) in November 2007 for two units at the 
Appendix D 

February 2010 D-95 NUREG-1917, SEIS 

North Anna Power Station site under the specifications contained in that permit. The issue of 

alternative cooling system designs for North Anna Units 3 and 4 was partially resolved in 

NUREG-1811, ESP EIS and will be evaluated in terms of new and significant information to 

determine if impact levels should be changed. Information not analyzed in NUREG-1811, ESP 

EIS regarding alternative cooling systems intake and discharges structures will be evaluated in 

Chapter 9 of the SEIS. 

Comment: Section 3.2.1.2 mentions water treatment effluent. Shouldn’t Chapter 8 include an 

assessment of a zero discharge option as is used in many other power plants? (0035-16

(Goldsmith, Aviv)) 

Response: This comment refers to plant water treatment systems for Unit 3, which were not 

specified at the time of NUREG-1811, ESP EIS, because a specific system design had not been 

selected. For the COL SEIS, NRC staff will evaluate the water treatment and effluent discharge 

systems proposed in the COL application. Impacts related to effluent water quality will be 

addressed in Chapter 5 of the SEIS. Effluent discharges would be regulated by VDEQ through 

the Virginia Pollutant Discharge Elimination System. 

24. Comments Concerning Alternatives - Sites

None of the comments in this area were considered in scope. 

25. Comments Concerning Benefit - Cost Balance

Comment: Let us look at electrical generation costs. Since the year 2000, nuclear power has 

surpassed coal as the cheapest method of electricity production. In 2006, the average cost to 

produce electricity from nuclear generation was 1.72 cents per kilowatt-hour. This is compared 

to 2.37 cents per kilowatt-hour for coal generation and 6.75 cents for natural gas generation. 

We do admit these costs are based on the current fleet of nuclear power plants which have long 

since paid off most of their capital investment costs. It is anticipated that the cost to produce 

electricity from a new nuclear power plant will be approximately 4 cents per kilowatt-hour. 

However, since global warming has become an issue, there will come a time soon in this 

country where we will have some sort of carbon emission cap and trade program in place. 

Under this scenario, the cost of generating electricity from new nuclear power plants will be 

much lower than the cost from other sources such as coal or natural gas which will have to buy 

carbon credits from utilities that own nuclear power plants or hydroelectric facilities. This is 

because nuclear power plants have zero emission of carbon dioxide during production of 

electricity. In fact, nuclear power provides the largest source of emission-free electricity making 

up over 73% of the total emission-free electrical generation in the United States. The other 

primary source of emission-free electricity at 24% is hydroelectric. However, hydroelectric 

capacity in this country is about tapped out. We will not be building very many new major dams 

any time soon given the present regulations protecting our streams and rivers. To put all of this 

in perspective, it is estimated that the new North Anna Power Station Unit Three would reduce 

greenhouse gas emissions by the equivalent of taking 1.5 million cars off the road compared to 

conventional power production sources. (0021-5 (Pierson, Mark)) 
Appendix D 

NUREG-1917, SEIS D-96 February 2010 

Comment: Let us look at electrical generation costs. Since the year 2000, nuclear power has 

surpassed coal as the cheapest method of electricity production. We do admit these costs are 

based on the current fleet of nuclear power plants, which have long since paid off most of their 

capital costs. However, since global warming has become an issue. There will come a time 

soon in this country where we will have some sort of a carbon emission cap and trade program 

in place. Under this scenario, the cost of generating electricity from new nuclear plants will be 

much slower than the cost from other sources, such as coal or natural gas. This is because 

nuclear power plants have zero emission of carbon dioxide during production of electricity. In 

fact, nuclear power provides the largest source of emission-free electricity, making up over 

73 percent of the total emission-free electrical general in the United States. The other primary 

source of emission-free electricity, at 24 percent, is hydroelectric. However, hydroelectric 

capacity in this country is about tapped out. To put all of this in perspective, it is estimated that 

the new North Anna Power Station unit 3 would reduce greenhouse gas emissions by the 

equivalent of taking 1.5 million cars off the road compared to conventional power production 

sources. (0034-124 (Pierson, Mark)) 

Comment: The EIS should examine the Cost/Benefits of North Anna-3 using a process that 

would account for differing construction cost estimates for the facility. Moody’s Investor 

Services predicts construction costs for new reactors to be $5,000-$6,000/kw. In filings with the 

Florida Public Service Commission, Florida Power & Light projects costs as high as $12 billion 

per reactor. Because of these uncertainties, the EIS should examine the cost/benefits at the 

various cost ranges. (0026-2 (AuClair-Valdez, Miguel)) 

Comment: I would say don’t just look at the cost of building the plant. Look at the true cost 

associated with it. Taxpayers are what fund nuclear energy. You fund it when the money 

comes out of your check every week from the federal government taxes. You fund it when you 

have to buy the power from the utility company. You are what’s funding nuclear power. And 

look at the true cost to people. So when you are doing this cost-benefit analysis, peel back 

more than just the look at what the cost is and the economic benefit for the local community and 

compare what would it be if we didn’t have the massive subsidies that are paying for the nuclear 

energy right now. (0034-212 (Tolbert, J.R.)) 

Comment: Let’s look at the economic review. When we talk about the cost of nuclear power, it 

is not just Dominion’s cost. Taxpayers—every time somebody in the nuclear industry opens 

their mouth, they want to put their hand in your pocket and take it out with your money. It’s 

taxpayer money. So let’s add it all up. Let’s find out where all these costs are. We’ve got the 

utility cost, we’ve got the fed cost, we’ve got waste, we’ve got high-level waste, we’ve got 

low-level waste. We’ve got insurance, we’ve got subsidies. Let’s add it up, so that we can have 

a true site. (0034-40 (Rosenthal, Jerry)) 

Comment: I think one of the primary purposes of the EIS is to provide a clear, reasoned, and 

transparent cost-benefit analysis. And so we believe that this EIS should include a full range of 

cost estimates for the projected construction of the ESBWR, rather than hold those costs as 

propriety information. So I think that it’s vital, and particularly in terms of providing public 

credibility to this whole process, that the EIS—first of all, take a look at the fact that since the 
Appendix D 

February 2010 D-97 NUREG-1917, SEIS 

early site permit process was completed, that the cost projections for nuclear power have gone 

up by about 300 to 400 percent. Right now, the latest estimate that we’ve seen was provided in 

discovery documents as a result of Florida Power and Light disclosures to the Florida Public 

Service Commission where now we’re looking at projected costs of anywhere from $5500 per 

kilowatt to more than $8000 per kilowatt hour for new nuclear construction. So if you convert 

that to about a 1500 megawatt reactor, that is anywhere from between $6 billion to $12 billion 

for a new reactor. Clearly, this should be taken into consideration in terms of the cost-benefit 

analysis. (0034-43 (Gunter, Paul)) 

Comment: I’d like to point out to—as the NRC knows, and to members of the audience, that 

when you talk about rising fuel costs, the rising cost of concrete, the rising cost of metal, and 

you talk about the skyrocketing expenses that are involved in building a potential North Anna 

Unit 3, those same skyrocketing costs would apply to any baseload energy that you want to put 

in. (0034-72 (Taylor, Kelly)) 

Comment: The study also shows that this nuclear facility’s electricity production cost was 

1.38 cents per kilowatt hour in 2006. This is considerably lower than the coal, natural gas, 

and renewables whose --when the renewables cost was $4.37 per kilowatt hour. (0034-79

(Fawls, Rebecca)) 

Response: The cost and benefits of construction and operation of Unit 3 will be evaluated in 

Chapter 10, Benefit Cost, of the SEIS. 

Comment: I am just suggesting that nuclear power is not the best way to decrease emissions. 

It’s important to recognize those emissions from cradle to grave. From the point where we 

begin to take action on mining the uranium, we are making an environmental imprint. Okay? 

So we have to take that into account when we’re considering nuclear energy. Furthermore, not 

just a process of the mining of the uranium, but you have to enrich the uranium, the construction 

of the reactor, the disposing of the waste, which has been pointed out over and over,—we don’t 

really have a way to dispose of that waste right now—as well as any changes to the 

transmission line that would occur. (0034-209 (Tolbert, J.R.)) 

Response: Life-cycle carbon impacts will be considered to the extent that they were not 

previously considered in NUREG-1811, ESP EIS. The carbon impacts will be considered in 

Chapters 4 and 5 (construction and operation) and Chapter 9 (alternatives). If new and 

significant information concerning carbon cycle is found, it will be considered in the benefit-cost 

analysis in Chapter 10.

Comment: We need to evaluate all energy technologies with the same set of objective criteria, 

whether they relate to lifetime emissions, economic issues,—I started making notes as the 

speakers were going on—waste streams, or environmental footprints. When we consider all of 

those criteria objectively, then we need to thoughtfully deploy all our energy technologies so we 

meet the needs of all members of society, especially those that are disadvantaged and minimize 

the impact to our environment. If we do that thoughtfully and carefully, we will find that we need 

all energy technologies, including nuclear. As one speaker put it, nuclear is not the cheapest or 
Appendix D 

NUREG-1917, SEIS D-98 February 2010 

the cleanest. In this country, that would be hydro. But, in addition to the limit imposed by the 

number of adequate sites for hydroelectric power, consider that per-kilowatt hour produced, as I 

said before, hydro consumes much more water than nuclear. And as far as safety, far more 

people have been hurt or killed by dam breaks in this country than by nuclear power plants. 

What I am saying is that there is no one energy technology that is safest, cleanest, and 

cheapest. We have to thoughtfully maximize the benefits and minimize the risks of each one to 

solve our energy and environmental problems. (0034-171 (Stiles, Lisa)) 

Comment: The GE-designed ESBWR has multiple backup safety systems with automatic 

safety features. It is a low carbon energy source with a small ecological footprint. To make the 

same amount of electricity from a wind farm as a nuclear power plant, it would take up to 

200 square miles. And a solar plant would take 75 square miles, where a nuclear power plant 

would take approximately one square mile. (0034-82 (Fawls, Rebecca)) 

Comment: And also due to this unique circumstance [proposed nuclear reactor vs. state 

moratorium on uranium mining], the environmental impact statement, whose main purpose is to 

establish a cost-benefit analysis of the project to determine if the environmental costs outweigh 

the stated benefits, should consider the effects of nuclear expansion and how it relates to the 

booming speculation on uranium. (0034-92 (Fisher, Allison)) 

Comment: So regarding these technologies and for the purposes of the EIS, an analysis 

should consider cost comparison, ratepayer savings, and certainly job creation, which is another 

issue that has been broached here by several of the presenters. And there are plenty of studies 

that are showing that these technologies are bringing just as many jobs and just as many 

opportunities into communities and without the risks associated with nuclear power or coal. 

Alleviating us from these technologies is not going to shut down the economy, I assure you. So, 

just again, you know, or the choices our utilities are making for us are critical. And we really 

cannot afford economically as well as environmentally to continue on this business as usual 

path. And I think that, when all things are considered, what we will see is nuclear power is not 

the cheapest. It’s not the safest. And it’s certainly not the cleanest. (0034-96 (Fisher, Allison)) 

Response: The cost and benefits of construction and operation of Unit 3 will be evaluated in 

Chapter 10, Benefit Cost, of the SEIS. 

26. General Comments in Support of the Licensing Action

None of the comments in this area were considered in scope. 

27. General Comments in Support of the Licensing Process

None of the comments in this area were considered in scope. 

28. General Comments of Support of Nuclear Power

None of the comments in this area were considered in scope. 
Appendix D 

February 2010 D-99 NUREG-1917, SEIS 

29. General Comments in Support of the Existing Plant

None of the comments in this area were considered in scope. 

30. General Comments in Opposition to the Licensing Action

None of the comments in this area were considered in scope. 

31. General Comments in Opposition to the Hearing Process

None of the comments in this area were considered in scope. 

32. General Comments in Opposition to Nuclear Power

None of the comments in this area were considered in scope. 

33. Comments Concerning Issues Out of Scope – Emergency Preparedness

None of the comments in this area were considered in scope. 

34. Comments Concerning Issues Out of Scope – Miscellaneous

None of the comments in this area were considered in scope. 

35. Comments Concerning Out of Scope – NRC Oversight

None of the comments in this area were considered in scope. 

36. Comments Concerning Issues Out of Scope – Safety

None of the comments in this area were considered in scope. 

37. Comments Concerning Issues Out of Scope – Security and Terrorism

None of the comments in this area were considered in scope. 

Appendix E 

Comments and Responses on the Draft Supplemental 

Environmental Impact Statement 

February 2010 E-1 NUREG-1917, SEIS 

Appendix E 

Comments and Responses on the Draft Supplemental 

Environmental Impact Statement 

As part of the U.S. Nuclear Regulatory Commission (NRC) review of Dominion’s application for 

a combined license (COL) for proposed Unit 3 at the North Anna Power Station (NAPS) site, the 

NRC solicited comments from the public on a draft of this supplemental environmental impact 

statement (SEIS). NRC regulations related to the environmental review of COL applications are 

contained in Title 10 of the Code of Federal Regulations (CFR) Part 51 and 10 CFR Part 52, 

Subpart C. Pursuant to NRC regulations in 10 CFR 51.50(c)(1), a COL applicant referencing an 

early site permit (ESP) need not submit information or analyses regarding environmental issues 

that were resolved in the ESP final environmental impact statement (EIS), except to the extent 

the COL applicant has identified new and significant information regarding such issues. In 

addition, pursuant to 10 CFR 52.39, matters resolved in the ESP proceedings are considered to 

be resolved in any subsequent proceedings, absent identification of new and significant 

information. The NRC staff is preparing this SEIS to the ESP EIS (NRC 2006), in support of the 

COL application for the proposed Unit 3 at NAPS. 

The draft SEIS was published in December 2008 (NRC 2008). A 75-day comment period 

began on January 2, 2009, when the U.S. Environmental Protection Agency (EPA) issued a 

Federal Register Notice (74 FR 106) of filing of the draft SEIS to allow members of the public to 

comment on the results of the NRC staff’s review. The comment period was later extended (74 

FR 4475). The NRC held a public meeting in Mineral, Virginia, on February 3, 2009, to describe 

the preliminary results of the environmental review, to answer questions, and to provide 

members of the public with information to assist them in formulating comments on the draft 

SEIS. 

As part of the process to solicit public comments on the draft SEIS, the staff: 

• placed a copy of the draft SEIS (NRC 2008) at the Jefferson-Madison Regional Library in 

Mineral, Virginia; the Hanover Branch Library in Hanover, Virginia; the Orange County 

Library in Orange, Virginia; the Salem Church Library in Fredericksburg, Virginia; and the 

C. Melvin Snow Memorial Branch Library in Spotsylvania, Virginia 

• made the draft SEIS available in the NRC’s Public Document Room in Rockville, Maryland 
Appendix E 

NUREG-1917, SEIS E-2 February 2010 

• placed a copy of the draft SEIS on the NRC website at www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1917/index.html 

• provided a copy of the draft SEIS to any member of the public that requested one 

• sent copies of the draft SEIS to certain Federal, State, and local agencies 

• published a notice of availability of the draft SEIS in the Federal Register on December 24, 

2008 (73 FR 79196), and a corrected notice of availability on January 26, 2009 

(74 FR 4475) 

• filed the draft SEIS with U.S. Environmental Protection Agency 

• announced and held a public meeting on February 3, 2009, at Louisa County High School in 

Mineral, Virginia to describe the results of the environmental review, answer any related 

questions, and take public comments 

• established an email address to receive public comments through the Internet on the 

environmental review for the North Anna Unit 3 COL. 

Approximately 120 people attended this meeting and 39 attendees provided oral comments. A 

certified court reporter recorded these oral comments and prepared written transcripts of the 

meeting. The transcripts of the public meetings are part of the public record for the proposed 

project and were used to establish correspondence between comments contained in this 

volume of the SEIS to oral comments received at the public meeting. In addition to the 

comments received at the public meeting, the NRC received 181 letters and e-mail messages 

with comments. The comment period closed on March 20, 2009. 

The comment letters, e-mail messages, and the transcript of the public meeting are available 

from the Publicly Available Records component of NRC’s Agencywide Documents Access and 

Management System (ADAMS). ADAMS is accessible at www.nrc.gov/reading-rm/adams.html, 

which provides access through the NRC's Public Electronic Reading Room link. Persons who 

do not have access to ADAMS or who encounter problems in accessing the documents located 

in ADAMS, should contact the NRC's Public Document Room reference staff at 1-800-397-4209 

or 301-415-4737, or by e-mail at pdr@nrc.gov. The NRC staff has reviewed all comments 

received including comments received at the public meeting. 

At the conclusion of the comment period, the NRC staff and its contractor reviewed the 

transcript of the public meeting and the written material received to identify specific comments 

and issues. All comments and suggestions received orally or in writing during the comment 
Appendix E 

February 2010 E-3 NUREG-1917, SEIS 

period were considered by the staff and reviewed in terms of new and significant information as 

required by 10 CFR 51.92(e). Preparation of the SEIS took into account the relevant issues 

raised during the comment period. 

This appendix contains all of the comments abstracted from the comment letters and e-mail 

messages provided to the staff during the draft SEIS comment period as well as the comments 

from the transcripts. Each set of comments was given a unique identifier (correspondence ID), 

allowing each set of comments to be traced back to the transcript, letter, or e-mail in which the 

comments were submitted. 

After the comment period, the staff considered and dispositioned all comments received. To 

identify each individual comment, the NRC staff reviewed the transcript of the public meeting 

and each letter and e-mail received related to the draft SEIS. As part of the review, the staff 

identified statements that they believed were related to the proposed action and recorded the 

statements as comments. Each comment was assigned to a specific subject area, and similar 

comments were grouped together. Finally, responses were prepared for each comment or 

group of comments. 

For each comment, the staff determined whether a comment: 

• Related to the NAPS COL and discussed a specific environmental impact 

• Related to an issue considered outside the scope of this environmental review 

• Opposed or supported nuclear power 

• Opposed or supported the NAPS COL 

• Discussed NRC’s COL process 

• Discussed the National Environmental Policy Act of 1969 (NEPA) requirements. 

This appendix presents the comments and the NRC responses to them grouped by general, 

similar issues such as those listed below: 

• Comments Related to the COL Process 

• General Comments in Support of NRC and its COL Process 

• General Comments in Opposition to NRC and its COL Process 

• General Comments in Support of the Applicant and its COL Application 
Appendix E 

NUREG-1917, SEIS E-4 February 2010 

• Comments Related to Environmental Impacts 

• Comments Related to the Need for Power and the Cost of Power 

• Comments Related to Alternatives and Alternative Sites 

• Comments Concerning Editorial Issues 

• Comments Concerning Out-of-Scope Issues: Safety, Safeguards and Security, and 

Emergency Preparedness 

• Comments Concerning NRC’s Administrative Process 

• Comments in Support of or Opposition to Nuclear Power. 

When the comments resulted in a change in the text of the draft SEIS, the corresponding 

response refers the reader to the appropriate section of the report where the change was made. 

Revisions to the text from the draft SEIS are indicated by vertical lines beside the text. Table 

E-1 provides a list of commenters identified by name, affiliation (if given), comment number, and 

the source of the comment. In Table E-2, comment categories are listed alphabetically with the 

associated commenters and the comment numbers. 

Table E-1. Individuals Providing Comments on the Draft SEIS

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Abbott, Diana Email (ML090620253) 0004 

Abbott, Diana Email (ML090620253) 0011

Abbott, William Email (ML090750134) 0011 

Adams, Rod Meeting Transcript 

(ML090510041) 

0083 

Ahlgrim, Larry Email (ML090760128) 0011 

Ahlgrim, Larry Email (ML090760128) 0061 

Alexander, Mary Email (ML090760124) 0011 

Alexander, Mary Email (ML090860669) 0011 

Alexander, Nancy Email (ML090760132) 0011 

Allen, Connie Email (ML090750129) 0011 
Appendix E 

February 2010 E-5 NUREG-1917, SEIS 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Antoniewicz, Susan Email (ML090750123) 0011 

Apple, Joe Email (ML090720768) 0011 

Appleby, Monica Email (ML090720780) 0011 

Arens, Jordan Email (ML090750131) 0011 

Artemis, Diana Email (ML090720741) 0011 

Artemis, Diana Email (ML090720741) 0028 

Au Clair Valdez, 

Miguel 

Charlottesville Center for Peace 

and Justice 

Meeting Transcript 

(ML090510041) 

0081 

Aylor, Joseph Letter (ML090650464) 0020 

Bailey, Gene Fredericksburg Regional 

Alliance 

Meeting Transcript 

(ML090510041) 

0075 

Bailey, Marcia Email (ML090750142) 0011 

Bailey, Marcia Email (ML090750142) 0041 

Baird, Heidi Email (ML090720745) 0011 

Bandita, Gypsy Email (ML090690778) 0011 

Beament, Pete Retired employee of Dominion 

Resources 

Meeting Transcript 

(ML090510041) 

0075 

Biggs, Amy Email (ML090820061) 0011 

Bishop, Wayman Meeting Transcript 

(ML090510041) 

0075 

Bockstiegel, 

Dorothy 

 Email (ML090750226) 0011 

Boissonnault, 

James 

 Email (ML090750228) 0011 

Bolduc, Joan Email (ML090750494) 0011 

Brackett, Carl Email (ML090750144) 0011 

Bradshaw, Claude Email (ML090780785) 0011 

Bronson, Regena U.S. Army Corps of Engineers Letter (ML090710426) 0009 

Brown, E Email (ML090720789) 0011 

Brown, Kevin Pamunkey Indian Tribe Letter (ML090540397) 0013 

Brown, Kevin Pamunkey Indian Tribe Meeting Transcript 

(ML090510041) 

0073 
Appendix E 

NUREG-1917, SEIS E-6 February 2010 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Brummer, Ann Email (ML090790021) 0011 

Burt, William Email (ML090720737) 0011 

Burt, William Email (ML090720737) 0026 

Burtner, Caryl Email (ML090720784) 0011 

Butcher, Ava Email (ML090750201) 0011 

Butcher, Ava Email (ML090750201) 0048 

Caristo, Vince Meeting Transcript 

(ML090510041) 

0081 

Carroll, John Meeting Transcript 

(ML090510041) 

0075 

Chezik, Michael T. U.S. Department of the Interior Letter (ML090580122) 0001 

Churray, Richard Email (ML090720787) 0011 

Clark, Diane Email (ML090770098) 0011 

Clark, Loralee Email (ML090760127) 0011 

Clark, Loralee Email (ML090840322) 0011 

Clark, Theda Email (ML090720790) 0011 

Clark, Theda Email (ML090720790) 0036 

Cleary, Thomas Email (ML090760125) 0011 

Collingwood, 

Claudia 

 Email (ML090720759) 0011 

Connor, Jennifer People's Alliance for Clean 

Energy 

Meeting Transcript 

(ML090510041) 

0079 

Cook, Joe Email (ML090750234) 0011 

Cook, Joe Email (ML090750234) 0056 

Cowles, Virginia Email (ML090720724) 0011 

Cowles, Virginia Email (ML090720724) 0025 

Crawford, Barbara Letter (ML090370609) 0003 

Cruickshank, John Virginia Chapter of the Sierra 

Club 

Email (ML090620258) 0005 

Cruickshank, John Virginia Chapter of the Sierra 

Club 

Meeting Transcript 

(ML090510041) 

0078 

Cummings, Russell Email (ML090771076) 0011 
Appendix E 

February 2010 E-7 NUREG-1917, SEIS 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Cummings, Russell Email (ML090771076) 0066 

Currie, Susan Email (ML090750261) 0011 

Currie, Susan Email (ML090750261) 0057 

D'Onofrio, Adam Email (ML090720807) 0011 

Dail, Michelle Email (ML090720786) 0011 

Daiss, Becky Email (ML090750160) 0011 

Davies, Beth Email (ML090760131) 0011 

Day, Donal Charlottesville Meeting Transcript 

(ML090510041) 

0075 

Day, Elena Email (ML090750299) 0010 

Day, Elena Email (ML090750299) 0011 

Day, Elena Peoples Alliance for Clean 

Energy (PACE) 

Meeting Transcript 

(ML090510041) 

0073, 0075

De Trinis, Bonita Email (ML090750135) 0011 

Deming, Jill Email (ML090750255) 0011 

Desimone, John 

and Shirley 

 Email (ML090750119) 0011 

Dickon, Elisa Email (ML090750285) 0011 

Dickon, Elisa Email (ML090750285) 0059 

DiMarco, Paul Email (ML090720752) 0011 

DiMarco, Paul Email (ML090720752) 0030 

Dukovich, John Email (ML090720754) 0011 

Dunbar, Mary Email (ML090750197) 0011 

Ebert, Paul Email (ML090750204) 0011 

Ebert, Paul Email (ML090750204) 0049 

Ewing, Amy Virginia Department of Game 

and Inland Fisheries (VDGIF) 

Email (ML090960407) 0070 

Faggert, Pam Chief Environmental Office for 

Dominion 

Meeting Transcript 

(ML090510041) 

0073 

Farmer, John Virginia Power (retired) Meeting Transcript 

(ML090510041) 

0075 

Farnham, Ross Email (ML090760563) 0011 
Appendix E 

NUREG-1917, SEIS E-8 February 2010 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Farnham, Ross Email (ML090760563) 0064 

Farris, Rebecca Meeting Transcript 

(ML090510041) 

0075 

Fasceski, Jeffrey Email (ML090720755) 0011 

Feury, Patricia Email (ML090750492) 0011 

Figg, Landon Email (ML090720777) 0011 

Figg, Landon Email (ML090720777) 0034 

Fiscella, Glenn Email (ML090760129) 0011 

Fiscella, Glenn Email (ML090760129) 0062 

Ford, Betty Email (ML090750287) 0011 

Frank, Sarah Email (ML090750136) 0011 

Franke, John Email (ML090780786) 0011 

Frantz, Norma Email (ML090750165) 0011 

Frantz, Norma Email (ML090750165) 0043 

Fritzler, Deb Email (ML090760566) 0011 

Gaige, Eve Email (ML090750232) 0011 

Gaige, Eve Email (ML090750232) 0054 

Galindo, Ted and 

Carolyn 

 Email (ML090750193) 0011 

Galindo, Ted and 

Carolyn 

 Email (ML090750193) 0046 

Gann, Sara Email (ML090720805) 0011 

Gibson, Bob Louisa County Meeting Transcript 

(ML090510041) 

0073 

Gignac, David Email (ML090750206) 0011 

Gignac, David Email (ML090750206) 0050 

Girvin, Larry Meeting Transcript 

(ML090510041) 

0075 

Girvin, Larry Meeting Transcript 

(ML090510041) 

0077 

Goldsmith, Aviv Email (ML090820056) 0023 

Grant, Mary Email (ML090720746) 0011 
Appendix E 

February 2010 E-9 NUREG-1917, SEIS 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Grechek, Eugene Dominion Energy, Inc. Letter (ML090830502) 0084 

Hall-Bodie, 

Adrienne 

 Email (ML090750280) 0011 

Ham, Elspeth Email (ML090750223) 0011 

Hamilton, Jim and 

Donna 

 Email (ML090750230) 0011 

Hanger, Jane Email (ML090720740) 0011 

Hanger, Jane Email (ML090720740) 0027 

Hanks, Lou Email (ML090750253) 0011 

Harper, Willie Meeting Transcript 

(ML090510041) 

0073 

Harpole, Thane Email (ML090750207) 0011 

Harpole, Thane Email (ML090750207) 0051 

Harte, Vicky Women in Nuclear Global Meeting Transcript 

(ML090510041) 

0082 

Hartwig, Kristina Email (ML090750274) 0011 

Hartwig, Kristina Email (ML090750274) 0058 

Heegaard, 

Flemming 

 Email (ML090720800) 0011 

Heflin, Kerby Email (ML090750508) 0011 

Heim, Anka Email (ML090750115) 0011 

Heim, Anka Email (ML090750115) 0038 

Hepburn, Chet Email (ML090750256) 0011 

Hess, David Email (ML090750118) 0011 

Hess, David Email (ML090750118) 0039 

Hinkle, Carol Email (ML090750137) 0011 

Hodge, Mary Email (ML090750169) 0011 

Hoehlein, Jill Email (ML090750163) 0011 

Hoehlein, Jill Email (ML090750163) 0042 

Hoffman, Lilli Email (ML090720781) 0011 

Holtzback, Kaite Email (ML090720758) 0011 
Appendix E 

NUREG-1917, SEIS E-10 February 2010 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Horwege, Richard Email (ML090720802) 0011 

Houston, Karin Email (ML090720783) 0011 

Hutchinson, Amber Email (ML090750259) 0011 

Irons, Ellie Virginia Dept. of Environmental 

Quality 

Letter (ML090900548) 0069 

Jaronczyk, Ellen Email (ML090720778) 0011 

Jewell, B Email (ML090720785) 0011 

Jewell, B Email (ML090720785) 0035 

Johns, Brian Email (ML090750282) 0011 

Jones, Dale Lake Anna Boating and 

Recreation Association 

Letter (ML090650463) 0021 

Josaitis, Marvin Email (ML090750227) 0011 

Kalukin, Andrew Email (ML090750289) 0011 

Keyser, Liz Email (ML090760567) 0011 

Kiehl, Allison Email (ML090750295) 0011 

Kirchen, Roger Virgnia Dept. of Historic 

Resources 

Letter (ML090650462) 0014 

Kirchen, Roger Virgnia Dept. of Historic 

Resources 

Letter (ML090650462) 0071 

Kosch, Sandra Email (ML090750254) 0011 

Kroupa, Brenda Email (ML090720769) 0011 

Kunkel, Christopher Email (ML090750171) 0011 

Kunkel, Christopher Email (ML090750171) 0045 

Lamboley, 

Genevieve 

 Meeting Transcript 

(ML090510041) 

0077 

Lapp, Jeffrey U.S. Environmental Protection 

Agency 

Letter (ML091100400) 0072 

Larsen, Anne Email (ML090750244) 0011 

Larsen, Janice Email (ML090750250) 0011 

Laverdiere, Dorothy Email (ML090820063) 0011 

LeClair, Carol Email (ML090770092) 0011 

Leon, Matea Email (ML090760560) 0011 
Appendix E 

February 2010 E-11 NUREG-1917, SEIS 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Light, John Email (ML090750140) 0011 

Liske, Patricia Email (ML090770101) 0011 

Liske, Patricia Email (ML090770101) 0065 

Lloveras, Lang Email (ML090750288) 0011 

Lloveras, Lang Email (ML090750288) 0060 

Lufkin, Heather Email (ML090720765) 0011 

Lufkin, Heather Email (ML090720765) 0031 

Maddox, Joshua Email (ML090750294) 0011 

Marroni, Edmond Email (ML090750281) 0011 

Mastilovic, Nick Meeting Transcript 

(ML090510041) 

0082 

McDonald, Kim Email (ML090760135) 0011 

McFarland, Mary 

Ann 

 Email (ML090750298) 0011 

McNeal, Ashby Email (ML090750155) 0011 

Meredith, Betty Email (ML090720751) 0011 

Meredith, Betty Email (ML090720751) 0029 

Meyer, Jennifer Email (ML090760133) 0011 

Miles, Linda Email (ML090750168) 0011 

Miller, Katelyn Email (ML090750284) 0011 

Miller, Lara Email (ML090720735 ) 0011 

Miller, Mary Email (ML090720766) 0011 

Mosser, Dave Meeting Transcript 

(ML090510041) 

0081 

Mullen, Dale Meeting Transcript 

(ML090510041) 

0073 

Mullinax, Franklin Email (ML090720770) 0011 

Murphy, Bill Meeting Transcript 

(ML090510041) 

0080 

Neale, Laura Email (ML090680188) 0006 

Neale, Laura Email (ML090680188) 0011 
Appendix E 

NUREG-1917, SEIS E-12 February 2010 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Nelson, Deborah Clean and Safe Energy Coalition Meeting Transcript 

(ML090510041) 

0077 

Newell, Vicky Email (ML090750273) 0011 

Nguyen, Vanthi Meeting Transcript 

(ML090510041) 

0078 

Oyok, Louis Meeting Transcript 

(ML090510041) 

0081 

Payne, Andrew Email (ML090720771) 0011 

Payne, Andrew Email (ML090720771) 0032 

Phillips, Donna Email (ML090750225) 0011 

Phillips, Donna Email (ML090750225) 0053 

Pickering, Andrew Meeting Transcript 

(ML090510041) 

0080 

Pintado, Isabel Email (ML090720803) 0011 

Plaskett, Micheline Email (ML090720801) 0011 

Plata, Errol Email (ML090720806) 0011 

Presgraves, 

Sandra 

 Email (ML090720753) 0011 

Presley, Diann Email (ML090750139) 0011 

Rasmussen, 

Angela 

 Email (ML090720772) 0011 

Reiner, Brian Email (ML090750491) 0011 

Remmers, Ken Waterside Property Owners 

Association, Lake Anna Civic 

Association 

Email (ML090350536) 0018 

Remmers, Ken Waterside Property Owners 

Association, Lake Anna Civic 

Association 

Letter (ML090790368) 0022 

Remmers, Ken Waterside Property Owners 

Association, Lake Anna Civic 

Association 

Meeting Transcript 

(ML090510041) 

0073 

Reynolds, Norm Meeting Transcript 

(ML090510041) 

0082 

Rigby, John Email (ML090750278) 0011 
Appendix E 

February 2010 E-13 NUREG-1917, SEIS 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Roadcap, Leah Email (ML090720736)

Email (ML090720742)

0011 

Robbins, Patricia Email (ML090750199) 0011 

Robbins, Patricia Email (ML090750199) 0047 

Rollins, Megan Email (ML090720774) 0011 

Rollins, Megan Email (ML090720774) 0033 

Rosenthal, Jerry Email (ML090770102 ) 0012 

Rosenthal, Jerry Meeting Transcript 

(ML090510041) 

0082 

Roth, David Email (ML090750205) 0011 

Ruth, Harry Friends of Lake Anna (FOLA) Letter (ML090350112) 0017 

Salidis, Stratton Meeting Transcript 

(ML090510041) 

0079 

Schmidt, Arthur Email (ML090720757) 0011 

Scott, Patricia Email (ML090750133) 0011 

Shamaiengar, Beth Email (ML090750233) 0011 

Shamaiengar, Beth Email (ML090750233) 0055 

Shelton, Charles Email (ML090720756) 0011 

Shields, Page Email (ML090750262) 0011 

Sklar, Scott The Stella Group, Ltd. Email (ML090750195) 0011 

Smith, Doug Lake Anna Civic Association Email (ML090370608) 0019 

Smith, Doug Lake Anna Civic Association Meeting Transcript 

(ML090510041) 

0073 

Smith, Jay Meeting Transcript 

(ML090510041) 

0078 

Smith, John Email (ML090750251) 0011 

Smith, Louise Email (ML090750231) 0011 

Squires, George Email (ML090720747) 0011 

Steegmayer, 

Andrea 

 Email (ML090750257) 0011 

Stiles, Lisa International Youth Nuclear 

Congress 

Meeting Transcript 

(ML090510041) 

0075 
Appendix E 

NUREG-1917, SEIS E-14 February 2010 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Stone, Eric Email (ML090750209) 0011 

Stone, Eric Email (ML090750209) 0052 

Sumrall, Kamar Email (ML090720762) 0011 

Suter, Emanuel Email (ML090820059) 0011 

Suter, Emanuel Email (ML090820059) 0067 

Tanner-Sutton, 

Linda 

 Email (ML090760134) 0011 

Tanner-Sutton, 

Linda 

 Email (ML090760134) 0063 

Tarr, Suzanne Email (ML090720750) 0011 

Taylor, Kelly Meeting Transcript 

(ML090510041) 

0079 

Teeler, Sharon Email (ML090750224) 0011 

Testerman, Michael Email (ML090750174) 0011 

Traub, Charles Email (ML090750170) 0011 

Traub, Charles Email (ML090750170) 0044 

Van Lingen, 

Gabriele 

 Email (ML090750297) 0011 

Wells, Cathy Email (ML090720788) 0011 

Werderman, Kim Email (ML090710419) 0011 

White, Eric Email (ML090750158) 0011 

White, Phyllis Email (ML090750166) 0011 

Whitfield, Doris Email (ML090750121) 0011 

Whitfield, Doris Email (ML090750121) 0040 

Williams, Martha Email (ML090760130) 0011 

Wilson, Brian Email (ML090720744)

Email (ML090720749)

0011 

Witting, Marjorie Email (ML090720799) 0011 

Witting, Marjorie Email (ML090720799) 0037 

Woitte, Roger Email (ML090820062) 0011 

Wright, Jack Louisa Co. Board of Supervisors Meeting Transcript 

(ML090510041) 

0073 
Appendix E 

February 2010 E-15 NUREG-1917, SEIS 

Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID Number

Young, Emerald Environmental Action Committee 

of the Unitarian Church 

Meeting Transcript 

(ML090510041) 

0080 

Zeller, Lou Blue Ridge Environmental 

Defense League 

Email (ML090820058 ) 0024 

Zeller, Lou Blue Ridge Environmental 

Defense League 

Meeting Transcript 

(ML090510041) 

0078 
Appendix E 

NUREG-1917, SEIS E-16 February 2010 

Table E-2. Comment Categories Alphabetically with Associated Commenters and Comments

Comment Category Commenter (Comment ID)

Accidents-Severe Au Clair Valdez, Miguel (0081-4) 

Goldsmith, Aviv (0023-37) (0023-38) (0023-40) (0023-41) (0023-42) 

Alternatives-Energy Adams, Rod (0083-1) 

Artemis, Diana (0028-1) 

Burt, William (0026-1) 

Butcher, Ava (0048-2) 

Cruickshank, John (0078-11) (0078-12) (0078-13) 

Cummings, Russell (0066-1) 

Day, Donal (0075-3) (0075-4) (0075-5) 

Dickon, Elisa (0059-3) 

Ebert, Paul (0049-1) 

Farnham, Ross (0064-1) 

Goldsmith, Aviv (0023-6) (0023-46) 

Grechek, Eugene (0084-30) (0084-31) (0084-32) (0084-33) 

Hanger, Jane (0027-1) 

Harpole, Thane (0051-1) (0051-4) 

Hartwig, Kristina (0058-1) 

Heim, Anka (0038-1) 

Hoehlein, Jill (0042-1) 

Liske, Patricia (0065-1) 

Lufkin, Heather (0031-1) 

Phillips, Donna (0053-1) 

Rosenthal, Jerry (0082-14) 

Shamaiengar, Beth (0055-1) 

Tanner-Sutton, Linda (0063-1) 

Alternatives-Sites Goldsmith, Aviv (0023-50) 

Nguyen, Vanthi (0078-17) 

Alternatives-System 

Design 

Goldsmith, Aviv (0023-21) (0023-22) 

Smith, Doug (0019-5) 

Benefit-Cost Balance Cowles, Virginia (0025-1) 

Farris, Rebecca (0075-14) 

Goldsmith, Aviv (0023-4) (0023-5) (0023-48) 

Grechek, Eugene (0084-34) 

Harpole, Thane (0051-2) 

Harte, Vicky (0082-22) 

Rosenthal, Jerry (0012-5) (0082-16) (0082-17) 
Appendix E 

February 2010 E-17 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Cumulative Impacts Remmers, Ken (0018-2) (0073-34) 

Ruth, Harry (0017-15) 

Decommissioning Goldsmith, Aviv (0023-44) 

Ecology-Aquatic Brown, Kevin (0073-14) 

Cruickshank, John (0078-6) 

Ewing, Amy (0070-1) (0070-3) 

Goldsmith, Aviv (0023-33) (0023-34) 

Grechek, Eugene (0084-7) (0084-8) (0084-9) (0084-10) (0084-11) 

(0084-12) (0084-13) (0084-14) (0084-15) (0084-27) 

Irons, Ellie (0069-11) (0069-22) (0069-23) 

Lapp, Jeffrey (0072-2) 

Ecology-Terrestrial Abbott, William (0011-3) 

Ahlgrim, Larry (0011-3) 

Alexander, Mary (0011-3) 

Alexander, Nancy (0011-3) 

Allen, Connie (0011-3) 

Antoniewicz, Susan (0011-3) 

Apple, Joe (0011-3) 

Appleby, Monica (0011-3) 

Arens, Jordan (0011-3) 

Artemis, Diana (0011-3) 

Bailey, Marcia (0011-3) 

Baird, Heidi (0011-3) 

Bandita, Gypsy (0011-3) 

Biggs, Amy (0011-3) 

Bockstiegel, Dorothy (0011-3) 

Boissonnault, James (0011-3) 

Bolduc, Joan (0011-3) 

Brackett, Carl (0011-3) 

Bradshaw, Claude (0011-3) 

Bronson, Regena (0009-3) 

Brown, E (0011-3) 

Brummer, Ann (0011-3) 

Burt, William (0011-3) 

Burtner, Caryl (0011-3) 

Butcher, Ava (0011-3) 

Churray, Richard (0011-3) 

Clark, Diane (0011-3) 
Appendix E 

NUREG-1917, SEIS E-18 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Clark, Loralee (0011-3) 

Clark, Theda (0011-3) 

Cleary, Thomas (0011-3) 

Collingwood, Claudia (0011-3) 

Cook, Joe (0011-3) 

Cowles, Virginia (0011-3) 

Cruickshank, John (0078-10) 

Cummings, Russell (0011-3) 

Currie, Susan (0011-3) 

D'Onofrio, Adam (0011-3) 

Dail, Michelle (0011-3) 

Daiss, Becky (0011-3) 

Davies, Beth (0011-3) 

Day, Elena (0011-3) 

De Trinis, Bonita (0011-3) 

Deming, Jill (0011-3) 

Desimone, John and Shirley (0011-3) 

Dickon, Elisa (0011-3) 

DiMarco, Paul (0011-3) 

Dukovich, John (0011-3) 

Dunbar, Mary (0011-3) 

Ebert, Paul (0011-3) 

Ewing, Amy (0070-4) 

Farnham, Ross (0011-3) 

Fasceski, Jeffrey (0011-3) 

Feury, Patricia (0011-3) 

Figg, Landon (0011-3) 

Fiscella, Glenn (0011-3) 

Ford, Betty (0011-3) 

Frank, Sarah (0011-3) 

Franke, John (0011-3) 

Frantz, Norma (0011-3) 

Fritzler, Deb (0011-3) 

Gaige, Eve (0011-3) 

Galindo, Ted and Carolyn (0011-3) 

Gann, Sara (0011-3) 

Gignac, David (0011-3) (0050-2) 

Goldsmith, Aviv (0023-19) (0023-24) 

Grant, Mary (0011-3) 

Grechek, Eugene (0084-25) (0084-35) 

Hall-Bodie, Adrienne (0011-3) 

Ham, Elspeth (0011-3) 

Hamilton, Jim and Donna (0011-3) 
Appendix E 

February 2010 E-19 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Hanger, Jane (0011-3) 

Hanks, Lou (0011-3) 

Harpole, Thane (0011-3) 

Hartwig, Kristina (0011-3) 

Heegaard, Flemming (0011-3) 

Heflin, Kerby (0011-3) 

Heim, Anka (0011-3) 

Hepburn, Chet (0011-3) 

Hess, David (0011-3) 

Hinkle, Carol (0011-3) 

Hodge, Mary (0011-3) 

Hoehlein, Jill (0011-3) 

Hoffman, Lilli (0011-3) 

Holtzback, Kaite (0011-3) 

Horwege, Richard (0011-3) 

Houston, Karin (0011-3) 

Hutchinson, Amber (0011-3) 

Irons, Ellie (0069-2) (0069-5) (0069-6) (0069-8) (0069-9) (0069-13) 

(0069-21) (0069-24) (0069-25) (0069-26) (0069-27) (0069-28) (0069-29) 

(0069-30) (0069-31) (0069-45) (0069-46) 

Jaronczyk, Ellen (0011-3) 

Jewell, B (0011-3) 

Johns, Brian (0011-3) 

Josaitis, Marvin (0011-3) 

Kalukin, Andrew (0011-3) 

Keyser, Liz (0011-3) 

Kiehl, Allison (0011-3) 

Kosch, Sandra (0011-3) 

Kroupa, Brenda (0011-3) 

Kunkel, Christopher (0011-3) 

Larsen, Anne (0011-3) 

Larsen, Janice (0011-3) 

Laverdiere, Dorothy (0011-3) 

LeClair, Carol (0011-3) 

Leon, Matea (0011-3) 

Light, John (0011-3) 

Liske, Patricia (0011-3) 

Lloveras, Lang (0011-3) 

Lufkin, Heather (0011-3) 

Maddox, Joshua (0011-3) 

Marroni, Edmond (0011-3) 

McDonald, Kim (0011-3) 

McFarland, Mary Ann (0011-3) 
Appendix E 

NUREG-1917, SEIS E-20 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

McNeal, Ashby (0011-3) 

Meredith, Betty (0011-3) 

Meyer, Jennifer (0011-3) 

Miles, Linda (0011-3) 

Miller, Katelyn (0011-3) 

Miller, Lara (0011-3) 

Miller, Mary (0011-3) 

Mullinax, Franklin (0011-3) 

Neale, Laura (0011-3) 

Newell, Vicky (0011-3) 

Payne, Andrew (0011-3) 

Phillips, Donna (0011-3) 

Pintado, Isabel (0011-3) 

Plaskett, Micheline (0011-3) 

Plata, Errol (0011-3) 

Presgraves, Sandra (0011-3) 

Presley, Diann (0011-3) 

Rasmussen, Angela (0011-3) 

Reiner, Brian (0011-3) 

Rigby, John (0011-3) 

Roadcap, Leah (0011-3) 

Robbins, Patricia (0011-3) 

Rollins, Megan (0011-3) 

Roth, David (0011-3) 

Schmidt, Arthur (0011-3) 

Scott, Patricia (0011-3) 

Shamaiengar, Beth (0011-3) 

Shelton, Charles (0011-3) 

Shields, Page (0011-3) 

Sklar, Scott (0011-3) 

Smith, John (0011-3) 

Smith, Louise (0011-3) 

Squires, George (0011-3) 

Steegmayer, Andrea (0011-3) 

Stone, Eric (0011-3) 

Sumrall, Kamar (0011-3) 

Suter, Emanuel (0011-3) 

Tanner-Sutton, Linda (0011-3) 

Tarr, Suzanne (0011-3) 

Teeler, Sharon (0011-3) 

Testerman, Michael (0011-3) 

Traub, Charles (0011-3) 

Van Lingen, Gabriele (0011-3) 
Appendix E 

February 2010 E-21 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Wells, Cathy (0011-3) 

Werderman, Kim (0011-3) 

White, Eric (0011-3) 

White, Phyllis (0011-3) 

Whitfield, Doris (0011-3) 

Williams, Martha (0011-3) 

Wilson, Brian (0011-3) 

Witting, Marjorie (0011-3) 

Woitte, Roger (0011-3) 

Editorial Comments Goldsmith, Aviv (0023-36) 

Grechek, Eugene (0084-1) (0084-2) (0084-3) (0084-29) 

Environmental Justice Grechek, Eugene (0084-17) 

Oyok, Louis (0081-2) 

Health-Nonradiological Grechek, Eugene (0084-23) 

Irons, Ellie (0069-42) (0069-43) (0069-44) 

Remmers, Ken (0018-4) (0073-38) 

Shamaiengar, Beth (0055-2) 

Health-Radiological Harte, Vicky (0082-25) 

Rosenthal, Jerry (0082-15) 

Young, Emerald (0080-1) (0080-5) 

Zeller, Lou (0024-7) (0024-8) (0024-9) 

Historic and Cultural 

Resources 

Bronson, Regena (0009-6) 

Brown, Kevin (0013-2) (0013-3) (0013-4) (0073-12) (0073-13) 

Grechek, Eugene (0084-16) (0084-24) 

Irons, Ellie (0069-48) 

Kirchen, Roger (0014-1) (0071-1) 

Hydrology-Groundwater Irons, Ellie (0069-47) 

Hydrology-Surface Water Abbott, Diana (0011-2) 

Abbott, William (0011-2) 

Ahlgrim, Larry (0011-2) (0061-2) 

Alexander, Mary (0011-2) 
Appendix E 

NUREG-1917, SEIS E-22 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Alexander, Nancy (0011-2) 

Allen, Connie (0011-2) 

Antoniewicz, Susan (0011-2) 

Apple, Joe (0011-2) 

Appleby, Monica (0011-2) 

Arens, Jordan (0011-2) 

Artemis, Diana (0011-2) 

Aylor, Joseph (0020-2) 

Bailey, Marcia (0011-2) (0041-1) 

Baird, Heidi (0011-2) 

Bandita, Gypsy (0011-2) 

Beament, Pete (0075-25) 

Biggs, Amy (0011-2) 

Bockstiegel, Dorothy (0011-2) 

Boissonnault, James (0011-2) 

Bolduc, Joan (0011-2) 

Brackett, Carl (0011-2) 

Bradshaw, Claude (0011-2) 

Bronson, Regena (0009-2) (0009-4) (0009-5) 

Brown, E (0011-2) 

Brummer, Ann (0011-2) 

Burt, William (0011-2) 

Burtner, Caryl (0011-2) 

Butcher, Ava (0011-2) 

Churray, Richard (0011-2) 

Clark, Diane (0011-2) 

Clark, Loralee (0011-2) 

Clark, Theda (0011-2) 

Cleary, Thomas (0011-2) 

Collingwood, Claudia (0011-2) 

Cook, Joe (0011-2) 

Cowles, Virginia (0011-2) 

Crawford, Barbara (0003-3) (0003-4) (0003-5) 

Cruickshank, John (0005-1) (0078-2) (0078-3) (0078-4) (0078-5) (0078-7) 

Cummings, Russell (0011-2) 

Currie, Susan (0011-2) 

D'Onofrio, Adam (0011-2) 

Dail, Michelle (0011-2) 

Daiss, Becky (0011-2) 

Davies, Beth (0011-2) 

Day, Elena (0010-1) (0011-2) (0073-57) (0073-58) (0073-59) 

De Trinis, Bonita (0011-2) 

Deming, Jill (0011-2) 
Appendix E 

February 2010 E-23 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Desimone, John and Shirley (0011-2) 

Dickon, Elisa (0011-2) 

DiMarco, Paul (0011-2) 

Dukovich, John (0011-2) 

Dunbar, Mary (0011-2) 

Ebert, Paul (0011-2) 

Ewing, Amy (0070-6) 

Farnham, Ross (0011-2) 

Fasceski, Jeffrey (0011-2) 

Feury, Patricia (0011-2) 

Figg, Landon (0011-2) 

Fiscella, Glenn (0011-2) 

Ford, Betty (0011-2) 

Frank, Sarah (0011-2) 

Franke, John (0011-2) 

Frantz, Norma (0011-2) 

Fritzler, Deb (0011-2) 

Gaige, Eve (0011-2) 

Galindo, Ted and Carolyn (0011-2) 

Gann, Sara (0011-2) 

Gignac, David (0011-2) 

Goldsmith, Aviv (0023-10) (0023-23) (0023-27) (0023-28) (0023-29) 

(0023-30) (0023-31) (0023-32) (0023-35) (0023-55) 

Grant, Mary (0011-2) 

Grechek, Eugene (0084-18) (0084-19) (0084-20) (0084-26) 

Hall-Bodie, Adrienne (0011-2) 

Ham, Elspeth (0011-2) 

Hamilton, Jim and Donna (0011-2) 

Hanger, Jane (0011-2) 

Hanks, Lou (0011-2) 

Harpole, Thane (0011-2) 

Hartwig, Kristina (0011-2) 

Heegaard, Flemming (0011-2) 

Heflin, Kerby (0011-2) 

Heim, Anka (0011-2) 

Hepburn, Chet (0011-2) 

Hess, David (0011-2) 

Hinkle, Carol (0011-2) 

Hodge, Mary (0011-2) 

Hoehlein, Jill (0011-2) 

Hoffman, Lilli (0011-2) 

Holtzback, Kaite (0011-2) 

Horwege, Richard (0011-2) 
Appendix E 

NUREG-1917, SEIS E-24 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Houston, Karin (0011-2) 

Hutchinson, Amber (0011-2) 

Irons, Ellie (0069-1) (0069-7) (0069-12) (0069-15) (0069-16) (0069-17) 

(0069-20) (0069-32) 

Jaronczyk, Ellen (0011-2) 

Jewell, B (0011-2) 

Johns, Brian (0011-2) 

Josaitis, Marvin (0011-2) 

Kalukin, Andrew (0011-2) 

Keyser, Liz (0011-2) 

Kiehl, Allison (0011-2) 

Kosch, Sandra (0011-2) 

Kroupa, Brenda (0011-2) 

Kunkel, Christopher (0011-2) 

Lapp, Jeffrey (0072-1) 

Larsen, Anne (0011-2) 

Larsen, Janice (0011-2) 

Laverdiere, Dorothy (0011-2) 

LeClair, Carol (0011-2) 

Leon, Matea (0011-2) 

Light, John (0011-2) 

Liske, Patricia (0011-2) 

Lloveras, Lang (0011-2) 

Lufkin, Heather (0011-2) 

Maddox, Joshua (0011-2) 

Marroni, Edmond (0011-2) 

McDonald, Kim (0011-2) 

McFarland, Mary Ann (0011-2) 

McNeal, Ashby (0011-2) 

Meredith, Betty (0011-2) 

Meyer, Jennifer (0011-2) 

Miles, Linda (0011-2) 

Miller, Katelyn (0011-2) 

Miller, Lara (0011-2) 

Miller, Mary (0011-2) 

Mullen, Dale (0073-18) (0073-19) 

Mullinax, Franklin (0011-2) 

Murphy, Bill (0080-6) (0080-7) (0080-8) 

Neale, Laura (0011-2) 

Newell, Vicky (0011-2) 

Payne, Andrew (0011-2) 

Phillips, Donna (0011-2) 

Pintado, Isabel (0011-2) 
Appendix E 

February 2010 E-25 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Plaskett, Micheline (0011-2) 

Plata, Errol (0011-2) 

Presgraves, Sandra (0011-2) 

Presley, Diann (0011-2) 

Rasmussen, Angela (0011-2) 

Reiner, Brian (0011-2) 

Remmers, Ken (0018-3) (0018-7) (0073-35) (0073-36) (0073-37) 

(0073-39) (0073-42) (0073-44) 

Rigby, John (0011-2) 

Roadcap, Leah (0011-2) 

Robbins, Patricia (0011-2) 

Rollins, Megan (0011-2) 

Rosenthal, Jerry (0012-2) (0082-13) 

Roth, David (0011-2) 

Ruth, Harry (0017-2) (0017-6) (0017-7) (0017-8) (0017-9) (0017-10) 

(0017-12) (0017-13) (0017-14) 

Schmidt, Arthur (0011-2) 

Scott, Patricia (0011-2) 

Shamaiengar, Beth (0011-2) 

Shelton, Charles (0011-2) 

Shields, Page (0011-2) 

Sklar, Scott (0011-2) 

Smith, Doug (0019-1) (0019-3) (0019-4) (0073-47) (0073-49) (0073-52) 

(0073-54) (0073-55) (0073-56) 

Smith, John (0011-2) 

Smith, Louise (0011-2) 

Squires, George (0011-2) 

Steegmayer, Andrea (0011-2) 

Stiles, Lisa (0075-42) (0075-43) (0075-44) 

Stone, Eric (0011-2) 

Sumrall, Kamar (0011-2) 

Suter, Emanuel (0011-2) (0067-2) 

Tanner-Sutton, Linda (0011-2) 

Tarr, Suzanne (0011-2) 

Teeler, Sharon (0011-2) 

Testerman, Michael (0011-2) 

Traub, Charles (0011-2) 

Van Lingen, Gabriele (0011-2) 

Wells, Cathy (0011-2) 

Werderman, Kim (0011-2) 

White, Eric (0011-2) 

White, Phyllis (0011-2) 

Whitfield, Doris (0011-2) 
Appendix E 

NUREG-1917, SEIS E-26 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Williams, Martha (0011-2) 

Wilson, Brian (0011-2) 

Witting, Marjorie (0011-2) 

Woitte, Roger (0011-2) 

Zeller, Lou (0024-5) (0024-6) 

Land Use-Site and 

Vicinity 

Ewing, Amy (0070-5) 

Grechek, Eugene (0084-5) 

Irons, Ellie (0069-14) (0069-33) 

Meteorology and Air 

Quality 

Bailey, Marcia (0041-2) 

Goldsmith, Aviv (0023-17) (0023-52) (0023-54) 

Grechek, Eugene (0084-6) 

Irons, Ellie (0069-34) (0069-35) (0069-36) (0069-37) (0069-38) (0069-39) 

Need for Power Aylor, Joseph (0020-4) 

Bailey, Gene (0075-16) 

Beament, Pete (0075-23) 

Carroll, John (0075-29) 

Faggert, Pam (0073-27) (0073-28) (0073-29) (0073-31) 

Farmer, John (0075-20) 

Fiscella, Glenn (0062-1) 

Girvin, Larry (0075-47) 

Grechek, Eugene (0084-28) 

Lamboley, Genevieve (0077-12) 

Nelson, Deborah (0077-7) (0077-9) 

Rosenthal, Jerry (0012-1) (0082-11) 

Wright, Jack (0073-2) (0073-3) 

Opposition-Licensing 

Action 

Abbott, William (0011-1) (0011-5) (0011-7) 

Ahlgrim, Larry (0011-1) (0011-5) 

Alexander, Mary (0011-1) (0011-5) (0011-7) 

Alexander, Nancy (0011-1) (0011-5) (0011-7) 

Allen, Connie (0011-1) (0011-5) (0011-7) 

Antoniewicz, Susan (0011-1) (0011-5) (0011-7) 

Apple, Joe (0011-1) (0011-5) (0011-7) 

Appleby, Monica (0011-1) (0011-5) (0011-7) 

Arens, Jordan (0011-1) (0011-5) (0011-7) 

Artemis, Diana (0011-1) (0011-5) 

Bailey, Marcia (0011-1) (0011-5) 
Appendix E 

February 2010 E-27 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Baird, Heidi (0011-1) (0011-5) (0011-7) 

Bandita, Gypsy (0011-1) 

Biggs, Amy (0011-1) (0011-5) (0011-7) 

Bockstiegel, Dorothy (0011-1) (0011-5) (0011-7) 

Boissonnault, James (0011-1) (0011-5) (0011-7) 

Bolduc, Joan (0011-1) (0011-5) (0011-7) 

Brackett, Carl (0011-1) (0011-5) (0011-7) 

Bradshaw, Claude (0011-1) (0011-5) (0011-7) 

Brown, E (0011-1) (0011-5) (0011-7) 

Brown, Kevin (0013-1) (0073-11) 

Brummer, Ann (0011-1) (0011-5) (0011-7) 

Burt, William (0011-1) (0011-5) 

Burtner, Caryl (0011-1) (0011-5) (0011-7) 

Butcher, Ava (0011-1) (0011-5) (0011-7) 

Churray, Richard (0011-1) (0011-5) (0011-7) 

Clark, Diane (0011-1) (0011-5) (0011-7) 

Clark, Loralee (0011-1) (0011-5) (0011-7) 

Clark, Theda (0011-1) (0011-5) (0011-7) 

Cleary, Thomas (0011-1) (0011-5) (0011-7) 

Collingwood, Claudia (0011-1) (0011-5) (0011-7) 

Cook, Joe (0011-1) (0011-5) (0011-7) 

Cowles, Virginia (0011-1) (0011-5) (0011-7) 

Cruickshank, John (0005-2) (0078-1) (0078-14) 

Cummings, Russell (0011-1) (0011-5) (0066-2) 

Currie, Susan (0011-1) (0011-5) (0011-7) 

D'Onofrio, Adam (0011-1) (0011-5) (0011-7) 

Dail, Michelle (0011-1) (0011-5) (0011-7) 

Daiss, Becky (0011-1) (0011-5) (0011-7) 

Davies, Beth (0011-1) (0011-5) (0011-7) 

Day, Elena (0073-64) 

De Trinis, Bonita (0011-1) (0011-5) (0011-7) 

Deming, Jill (0011-1) (0011-5) (0011-7) 

Desimone, John and Shirley (0011-1) (0011-5) (0011-7) 

Dickon, Elisa (0011-1) (0011-5) (0011-7) 

DiMarco, Paul (0011-1) (0011-5) 

Dukovich, John (0011-1) (0011-5) (0011-7) 

Dunbar, Mary (0011-1) (0011-5) (0011-7) 

Ebert, Paul (0011-1) (0011-5) 

Farnham, Ross (0011-1) (0011-5) 

Fasceski, Jeffrey (0011-1) (0011-5) (0011-7) 

Feury, Patricia (0011-1) (0011-5) (0011-7) 

Figg, Landon (0011-1) (0011-5) (0011-7) 

Fiscella, Glenn (0011-1) (0011-5) (0011-7) 
Appendix E 

NUREG-1917, SEIS E-28 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Ford, Betty (0011-1) (0011-5) (0011-7) 

Frank, Sarah (0011-1) (0011-5) (0011-7) 

Franke, John (0011-1) (0011-5) (0011-7) 

Frantz, Norma (0011-1) (0011-5) (0011-7) 

Fritzler, Deb (0011-1) (0011-5) (0011-7) 

Gaige, Eve (0011-1) (0011-5) (0011-7) 

Galindo, Ted and Carolyn (0011-1) (0011-5) (0011-7) (0046-1) 

Gann, Sara (0011-1) (0011-5) (0011-7) 

Gignac, David (0011-1) (0011-5) (0011-7) 

Grant, Mary (0011-1) (0011-5) (0011-7) 

Hall-Bodie, Adrienne (0011-1) (0011-5) (0011-7) 

Ham, Elspeth (0011-1) (0011-5) (0011-7) 

Hamilton, Jim and Donna (0011-1) (0011-5) (0011-7) 

Hanger, Jane (0011-1) (0011-5) (0011-7) 

Hanks, Lou (0011-1) (0011-5) (0011-7) 

Harpole, Thane (0011-1) (0011-5) (0011-7) (0051-5) 

Hartwig, Kristina (0011-1) (0011-5) 

Heegaard, Flemming (0011-1) (0011-5) (0011-7) 

Heflin, Kerby (0011-1) (0011-5) (0011-7) 

Heim, Anka (0011-1) (0011-5) (0011-7) 

Hepburn, Chet (0011-1) (0011-5) (0011-7) 

Hess, David (0011-1) (0011-5) (0011-7) 

Hinkle, Carol (0011-1) (0011-5) (0011-7) 

Hodge, Mary (0011-1) (0011-5) (0011-7) 

Hoehlein, Jill (0011-1) (0011-5) (0011-7) 

Hoffman, Lilli (0011-1) (0011-5) (0011-7) 

Holtzback, Kaite (0011-1) (0011-5) (0011-7) 

Horwege, Richard (0011-1) (0011-5) (0011-7) 

Houston, Karin (0011-1) (0011-5) (0011-7) 

Hutchinson, Amber (0011-1) (0011-5) (0011-7) 

Jaronczyk, Ellen (0011-1) (0011-5) (0011-7) 

Jewell, B (0011-1) (0011-5) 

Johns, Brian (0011-1) (0011-5) (0011-7) 

Josaitis, Marvin (0011-1) (0011-5) (0011-7) 

Kalukin, Andrew (0011-1) (0011-5) (0011-7) 

Keyser, Liz (0011-1) (0011-5) (0011-7) 

Kiehl, Allison (0011-1) (0011-5) (0011-7) 

Kosch, Sandra (0011-1) (0011-5) (0011-7) 

Kroupa, Brenda (0011-1) (0011-5) (0011-7) 

Kunkel, Christopher (0011-1) (0011-5) (0011-7) 

Larsen, Anne (0011-1) (0011-5) (0011-7) 

Larsen, Janice (0011-1) (0011-5) (0011-7) 

Laverdiere, Dorothy (0011-1) (0011-5) (0011-7) 
Appendix E 

February 2010 E-29 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

LeClair, Carol (0011-1) (0011-5) (0011-7) 

Leon, Matea (0011-1) (0011-5) (0011-7) 

Light, John (0011-1) (0011-5) (0011-7) 

Liske, Patricia (0011-1) (0011-5) 

Lloveras, Lang (0011-1) (0011-5) (0011-7) 

Lufkin, Heather (0011-1) (0011-5) (0011-7) 

Maddox, Joshua (0011-1) (0011-5) (0011-7) 

Marroni, Edmond (0011-1) (0011-5) (0011-7) 

McDonald, Kim (0011-1) (0011-5) (0011-7) 

McFarland, Mary Ann (0011-1) (0011-5) (0011-7) 

McNeal, Ashby (0011-1) (0011-5) (0011-7) 

Meredith, Betty (0011-1) (0011-5) (0029-1) 

Meyer, Jennifer (0011-1) (0011-5) (0011-7) 

Miles, Linda (0011-1) (0011-5) (0011-7) 

Miller, Katelyn (0011-1) (0011-5) (0011-7) 

Miller, Lara (0011-1) (0011-5) (0011-7) 

Miller, Mary (0011-1) (0011-5) (0011-7) 

Mullinax, Franklin (0011-1) (0011-5) (0011-7) 

Neale, Laura (0006-2) 

Newell, Vicky (0011-1) (0011-5) (0011-7) 

Oyok, Louis (0081-1) 

Payne, Andrew (0011-1) (0011-5) 

Phillips, Donna (0011-1) (0011-5) (0011-7) 

Pintado, Isabel (0011-1) (0011-5) (0011-7) 

Plaskett, Micheline (0011-1) (0011-5) (0011-7) 

Plata, Errol (0011-1) (0011-5) (0011-7) 

Presgraves, Sandra (0011-1) (0011-5) (0011-7) 

Presley, Diann (0011-1) (0011-5) (0011-7) 

Rasmussen, Angela (0011-1) (0011-5) (0011-7) 

Reiner, Brian (0011-1) (0011-5) (0011-7) 

Rigby, John (0011-1) (0011-5) (0011-7) 

Roadcap, Leah (0011-1) (0011-5) (0011-7) 

Robbins, Patricia (0011-1) (0011-5) 

Rollins, Megan (0011-1) (0011-5) (0011-7) 

Roth, David (0011-1) (0011-5) (0011-7) 

Schmidt, Arthur (0011-1) (0011-5) (0011-7) 

Scott, Patricia (0011-1) (0011-5) (0011-7) 

Shamaiengar, Beth (0011-1) (0011-5) (0055-3) 

Shelton, Charles (0011-1) (0011-5) (0011-7) 

Shields, Page (0011-1) (0011-5) (0011-7) 

Sklar, Scott (0011-1) (0011-5) (0011-7) 

Smith, John (0011-1) (0011-5) (0011-7) 

Smith, Louise (0011-1) (0011-5) (0011-7) 
Appendix E 

NUREG-1917, SEIS E-30 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Squires, George (0011-1) (0011-5) (0011-7) 

Steegmayer, Andrea (0011-1) (0011-5) (0011-7) 

Stone, Eric (0011-1) (0011-5) (0052-1) 

Sumrall, Kamar (0011-1) (0011-5) (0011-7) 

Suter, Emanuel (0011-1) (0011-5) (0067-1) 

Tanner-Sutton, Linda (0011-1) (0011-5) (0011-7) 

Tarr, Suzanne (0011-1) (0011-5) (0011-7) 

Teeler, Sharon (0011-1) (0011-5) (0011-7) 

Testerman, Michael (0011-1) (0011-5) (0011-7) 

Traub, Charles (0011-1) (0011-5) (0011-7) (0044-1) 

Van Lingen, Gabriele (0011-1) (0011-5) (0011-7) 

Wells, Cathy (0011-1) (0011-5) (0011-7) 

Werderman, Kim (0011-1) (0011-5) (0011-7) 

White, Eric (0011-1) (0011-5) (0011-7) 

White, Phyllis (0011-1) (0011-5) (0011-7) 

Whitfield, Doris (0011-1) (0011-5) (0040-3) 

Williams, Martha (0011-1) (0011-5) (0011-7) 

Wilson, Brian (0011-1) (0011-5) (0011-7) 

Witting, Marjorie (0011-1) (0011-5) (0011-7) 

Woitte, Roger (0011-1) (0011-5) (0011-7) 

Opposition-Nuclear Power Caristo, Vince (0081-10) (0081-11) 

Connor, Jennifer (0079-3) 

Currie, Susan (0057-1) 

Day, Elena (0073-66) (0075-2) 

Dickon, Elisa (0059-1) (0059-2) (0059-4) 

DiMarco, Paul (0030-1) 

Farris, Rebecca (0075-12) (0075-13) (0075-15) 

Figg, Landon (0034-1) 

Frantz, Norma (0043-1) 

Kunkel, Christopher (0045-1) 

Payne, Andrew (0032-1) 

Pickering, Andrew (0080-9) (0080-10) 

Robbins, Patricia (0047-1) 

Rollins, Megan (0033-1) 

Taylor, Kelly (0079-4) (0079-5) 

Young, Emerald (0080-2) 

Opposition-Plant Gaige, Eve (0054-1) 

Liske, Patricia (0065-2) 

Lloveras, Lang (0060-1) 
Appendix E 

February 2010 E-31 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Outside ScopeEmergency PreparednessIrons, Ellie (0069-4) (0069-52) 

Outside ScopeMiscellaneous Abbott, Diana (0004-1) 

Abbott, William (0011-6) 

Ahlgrim, Larry (0011-6) 

Alexander, Mary (0011-6) 

Alexander, Nancy (0011-6) 

Allen, Connie (0011-6) 

Antoniewicz, Susan (0011-6) 

Apple, Joe (0011-6) 

Appleby, Monica (0011-6) 

Arens, Jordan (0011-6) 

Artemis, Diana (0011-6) 

Bailey, Marcia (0011-6) 

Baird, Heidi (0011-6) 

Bandita, Gypsy (0011-6) 

Biggs, Amy (0011-6) 

Bockstiegel, Dorothy (0011-6) 

Boissonnault, James (0011-6) 

Bolduc, Joan (0011-6) 

Brackett, Carl (0011-6) 

Bradshaw, Claude (0011-6) 

Brown, E (0011-6) 

Brummer, Ann (0011-6) 

Burt, William (0011-6) 

Burtner, Caryl (0011-6) 

Butcher, Ava (0011-6) 

Carroll, John (0075-30) 

Chezik, Michael T. (0001-1) 

Churray, Richard (0011-6) 

Clark, Diane (0011-6) 

Clark, Loralee (0011-6) 

Clark, Theda (0011-6) 

Cleary, Thomas (0011-6) 

Collingwood, Claudia (0011-6) 

Cook, Joe (0011-6) 

Cowles, Virginia (0011-6) 

Crawford, Barbara (0003-2) (0003-6) 

Cummings, Russell (0011-6) 

Currie, Susan (0011-6) 

D'Onofrio, Adam (0011-6) 
Appendix E 

NUREG-1917, SEIS E-32 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Dail, Michelle (0011-6) 

Daiss, Becky (0011-6) 

Davies, Beth (0011-6) 

De Trinis, Bonita (0011-6) 

Deming, Jill (0011-6) 

Desimone, John and Shirley (0011-6) 

Dickon, Elisa (0011-6) 

DiMarco, Paul (0011-6) 

Dukovich, John (0011-6) 

Dunbar, Mary (0011-6) 

Ebert, Paul (0011-6) 

Farnham, Ross (0011-6) 

Fasceski, Jeffrey (0011-6) 

Feury, Patricia (0011-6) 

Figg, Landon (0011-6) 

Fiscella, Glenn (0011-6) 

Ford, Betty (0011-6) 

Frank, Sarah (0011-6) 

Franke, John (0011-6) 

Frantz, Norma (0011-6) 

Fritzler, Deb (0011-6) 

Gaige, Eve (0011-6) 

Galindo, Ted and Carolyn (0011-6) 

Gann, Sara (0011-6) 

Gignac, David (0011-6) 

Goldsmith, Aviv (0023-1) (0023-47) (0023-56) 

Grant, Mary (0011-6) 

Hall-Bodie, Adrienne (0011-6) 

Ham, Elspeth (0011-6) 

Hamilton, Jim and Donna (0011-6) 

Hanger, Jane (0011-6) 

Hanks, Lou (0011-6) 

Harpole, Thane (0011-6) 

Hartwig, Kristina (0011-6) 

Heegaard, Flemming (0011-6) 

Heflin, Kerby (0011-6) 

Heim, Anka (0011-6) 

Hepburn, Chet (0011-6) 

Hess, David (0011-6) 

Hinkle, Carol (0011-6) 

Hodge, Mary (0011-6) 

Hoehlein, Jill (0011-6) 

Hoffman, Lilli (0011-6) 
Appendix E 

February 2010 E-33 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Holtzback, Kaite (0011-6) 

Horwege, Richard (0011-6) 

Houston, Karin (0011-6) 

Hutchinson, Amber (0011-6) 

Irons, Ellie (0069-54) (0069-55) (0069-56) 

Jaronczyk, Ellen (0011-6) 

Jewell, B (0011-6) (0035-1) 

Johns, Brian (0011-6) 

Josaitis, Marvin (0011-6) 

Kalukin, Andrew (0011-6) 

Keyser, Liz (0011-6) 

Kiehl, Allison (0011-6) 

Kosch, Sandra (0011-6) 

Kroupa, Brenda (0011-6) 

Kunkel, Christopher (0011-6) 

Larsen, Anne (0011-6) 

Larsen, Janice (0011-6) 

Laverdiere, Dorothy (0011-6) 

LeClair, Carol (0011-6) 

Leon, Matea (0011-6) 

Light, John (0011-6) 

Liske, Patricia (0011-6) 

Lloveras, Lang (0011-6) 

Lufkin, Heather (0011-6) 

Maddox, Joshua (0011-6) 

Marroni, Edmond (0011-6) 

McDonald, Kim (0011-6) 

McFarland, Mary Ann (0011-6) 

McNeal, Ashby (0011-6) 

Meredith, Betty (0011-6) 

Meyer, Jennifer (0011-6) 

Miles, Linda (0011-6) 

Miller, Katelyn (0011-6) 

Miller, Lara (0011-6) 

Miller, Mary (0011-6) 

Mullinax, Franklin (0011-6) 

Neale, Laura (0006-3) 

Newell, Vicky (0011-6) 

Nguyen, Vanthi (0078-15) (0078-18) 

Payne, Andrew (0011-6) 

Phillips, Donna (0011-6) 

Pickering, Andrew (0080-11) 

Pintado, Isabel (0011-6) 
Appendix E 

NUREG-1917, SEIS E-34 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Plaskett, Micheline (0011-6) 

Plata, Errol (0011-6) 

Presgraves, Sandra (0011-6) 

Presley, Diann (0011-6) 

Rasmussen, Angela (0011-6) 

Reiner, Brian (0011-6) 

Remmers, Ken (0018-5) (0073-40) (0073-43) 

Rigby, John (0011-6) 

Roadcap, Leah (0011-6) 

Robbins, Patricia (0011-6) 

Rollins, Megan (0011-6) 

Rosenthal, Jerry (0012-3) (0012-4) 

Roth, David (0011-6) 

Ruth, Harry (0017-1) (0017-4) 

Schmidt, Arthur (0011-6) 

Scott, Patricia (0011-6) 

Shamaiengar, Beth (0011-6) 

Shelton, Charles (0011-6) 

Shields, Page (0011-6) 

Sklar, Scott (0011-6) 

Smith, John (0011-6) 

Smith, Louise (0011-6) 

Squires, George (0011-6) 

Steegmayer, Andrea (0011-6) 

Stone, Eric (0011-6) 

Sumrall, Kamar (0011-6) 

Suter, Emanuel (0011-6) 

Tanner-Sutton, Linda (0011-6) 

Tarr, Suzanne (0011-6) 

Taylor, Kelly (0079-2) 

Teeler, Sharon (0011-6) 

Testerman, Michael (0011-6) 

Traub, Charles (0011-6) 

Van Lingen, Gabriele (0011-6) 

Wells, Cathy (0011-6) 

Werderman, Kim (0011-6) 

White, Eric (0011-6) 

White, Phyllis (0011-6) 

Whitfield, Doris (0011-6) 

Williams, Martha (0011-6) 

Wilson, Brian (0011-6) 

Witting, Marjorie (0011-6) 
Appendix E 

February 2010 E-35 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Woitte, Roger (0011-6) 

Zeller, Lou (0078-16) 

Outside Scope-NRC 

Oversight 

Clark, Theda (0036-1) 

Mastilovic, Nick (0082-8) 

Reynolds, Norm (0082-4) 

Outside Scope-Safety Bishop, Wayman (0075-9) 

Crawford, Barbara (0003-7) (0003-8) 

Day, Elena (0073-65) (0075-1) 

Irons, Ellie (0069-53) 

Salidis, Stratton (0079-6) (0079-7) 

Zeller, Lou (0024-4) 

Outside Scope-Security 

and Terrorism 

Goldsmith, Aviv (0023-8) (0023-13) (0023-39) (0023-45) (0023-49) 

Process-COL Crawford, Barbara (0003-1) 

Day, Elena (0010-2) 

Girvin, Larry (0077-1) 

Goldsmith, Aviv (0023-2) (0023-9) (0023-14) (0023-15) (0023-16) 

(0023-59) 

Nguyen, Vanthi (0078-19) (0078-20) 

Remmers, Ken (0018-6) (0022-1) (0073-41) (0073-45) 

Rosenthal, Jerry (0082-10) 

Ruth, Harry (0017-3) (0017-5) (0017-11) 

Whitfield, Doris (0040-1) (0040-2) 

Zeller, Lou (0024-1) 

Site Layout and Design Bronson, Regena (0009-1) 

Grechek, Eugene (0084-36) 

Site Redress Irons, Ellie (0069-10) 

Socioeconomics Bailey, Gene (0075-17) 

Beament, Pete (0075-27) 

Bishop, Wayman (0075-6) (0075-7) (0075-11) 

Carroll, John (0075-31) 
Appendix E 

NUREG-1917, SEIS E-36 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Ewing, Amy (0070-2) 

Farmer, John (0075-21) 

Gibson, Bob (0073-22) (0073-23) (0073-24) (0073-25) 

Goldsmith, Aviv (0023-11) (0023-12) (0023-20) (0023-25) (0023-26) 

(0023-51) (0023-53) 

Grechek, Eugene (0084-4) (0084-21) (0084-22) 

Harte, Vicky (0082-20) (0082-23) 

Irons, Ellie (0069-3) (0069-18) (0069-19) (0069-49) (0069-50) (0069-51) 

Mullen, Dale (0073-16) (0073-17) (0073-20) 

Reynolds, Norm (0082-3) 

Rosenthal, Jerry (0082-12) 

Smith, Doug (0019-2) (0073-48) (0073-50) (0073-51) (0073-53) 

Stiles, Lisa (0075-45) 

Support-Licensing Action Aylor, Joseph (0020-1) 

Bailey, Gene (0075-18) 

Beament, Pete (0075-22) 

Bishop, Wayman (0075-8) (0075-10) 

Carroll, John (0075-34) 

Faggert, Pam (0073-30) (0073-32) 

Farmer, John (0075-19) 

Gibson, Bob (0073-26) 

Girvin, Larry (0075-46) (0075-48) (0077-3) 

Harper, Willie (0073-4) (0073-5) (0073-6) (0073-8) (0073-9) (0073-10) 

Mastilovic, Nick (0082-7) (0082-9) 

Mosser, Dave (0081-9) 

Mullen, Dale (0073-15) (0073-21) 

Nelson, Deborah (0077-5) 

Remmers, Ken (0018-1) (0073-33) 

Reynolds, Norm (0082-2) 

Smith, Doug (0073-46) 

Smith, Jay (0078-23) 

Stiles, Lisa (0075-39) (0075-40) 

Support-Licensing 

Process 

Beament, Pete (0075-26) 

Girvin, Larry (0077-4) 

Harte, Vicky (0082-19) 

Support-Nuclear Power Adams, Rod (0083-2) 

Ahlgrim, Larry (0061-1) 

Aylor, Joseph (0020-3) 
Appendix E 

February 2010 E-37 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Beament, Pete (0075-24) 

Gignac, David (0050-1) 

Girvin, Larry (0077-2) 

Harte, Vicky (0082-18) (0082-24) 

Lamboley, Genevieve (0077-11) (0077-13) (0077-14) 

Mastilovic, Nick (0082-5) 

Mosser, Dave (0081-7) (0081-8) 

Nelson, Deborah (0077-6) (0077-8) (0077-10) 

Reynolds, Norm (0082-1) 

Smith, Jay (0078-21) 

Stiles, Lisa (0075-35) (0075-38) 

Taylor, Kelly (0079-1) 

Support-Plant Carroll, John (0075-28) (0075-32) (0075-33) 

Mastilovic, Nick (0082-6) 

Smith, Doug (0019-6) 

Smith, Jay (0078-22) 

Stiles, Lisa (0075-36) (0075-37) (0075-41) 

Wright, Jack (0073-1) 

Transportation Goldsmith, Aviv (0023-18) 

Uranium Fuel Cycle Abbott, Diana (0004-2) (0004-3) 

Abbott, William (0011-4) 

Ahlgrim, Larry (0011-4) 

Alexander, Mary (0011-4) 

Alexander, Nancy (0011-4) 

Allen, Connie (0011-4) 

Antoniewicz, Susan (0011-4) 

Apple, Joe (0011-4) 

Appleby, Monica (0011-4) 

Arens, Jordan (0011-4) 

Artemis, Diana (0011-4) 

Au Clair Valdez, Miguel (0081-3) (0081-5) (0081-6) 

Bailey, Marcia (0011-4) 

Baird, Heidi (0011-4) 

Bandita, Gypsy (0011-4) 

Biggs, Amy (0011-4) 

Bockstiegel, Dorothy (0011-4) 

Boissonnault, James (0011-4) 
Appendix E 

NUREG-1917, SEIS E-38 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Bolduc, Joan (0011-4) 

Brackett, Carl (0011-4) 

Bradshaw, Claude (0011-4) 

Brown, E (0011-4) 

Brummer, Ann (0011-4) 

Burt, William (0011-4) 

Burtner, Caryl (0011-4) 

Butcher, Ava (0011-4) (0048-1) 

Churray, Richard (0011-4) 

Clark, Diane (0011-4) 

Clark, Loralee (0011-4) 

Clark, Theda (0011-4) 

Cleary, Thomas (0011-4) 

Collingwood, Claudia (0011-4) 

Cook, Joe (0011-4) (0056-1) 

Cowles, Virginia (0011-4) 

Cruickshank, John (0078-8) (0078-9) 

Cummings, Russell (0011-4) 

Currie, Susan (0011-4) 

D'Onofrio, Adam (0011-4) 

Dail, Michelle (0011-4) 

Daiss, Becky (0011-4) 

Davies, Beth (0011-4) 

Day, Elena (0011-4) (0073-60) (0073-61) (0073-62) (0073-63) 

De Trinis, Bonita (0011-4) 

Deming, Jill (0011-4) 

Desimone, John and Shirley (0011-4) 

Dickon, Elisa (0011-4) 

DiMarco, Paul (0011-4) 

Dukovich, John (0011-4) 

Dunbar, Mary (0011-4) 

Ebert, Paul (0011-4) 

Farnham, Ross (0011-4) 

Fasceski, Jeffrey (0011-4) 

Feury, Patricia (0011-4) 

Figg, Landon (0011-4) 

Fiscella, Glenn (0011-4) 

Ford, Betty (0011-4) 

Frank, Sarah (0011-4) 

Franke, John (0011-4) 

Frantz, Norma (0011-4) 

Fritzler, Deb (0011-4) 

Gaige, Eve (0011-4) 
Appendix E 

February 2010 E-39 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Galindo, Ted and Carolyn (0011-4) 

Gann, Sara (0011-4) 

Gignac, David (0011-4) 

Goldsmith, Aviv (0023-3) (0023-7) (0023-43) (0023-58) 

Grant, Mary (0011-4) 

Hall-Bodie, Adrienne (0011-4) 

Ham, Elspeth (0011-4) 

Hamilton, Jim and Donna (0011-4) 

Hanger, Jane (0011-4) 

Hanks, Lou (0011-4) 

Harper, Willie (0073-7) 

Harpole, Thane (0011-4) (0051-3) 

Harte, Vicky (0082-21) 

Hartwig, Kristina (0011-4) 

Heegaard, Flemming (0011-4) 

Heflin, Kerby (0011-4) 

Heim, Anka (0011-4) 

Hepburn, Chet (0011-4) 

Hess, David (0011-4) (0039-1) 

Hinkle, Carol (0011-4) 

Hodge, Mary (0011-4) 

Hoehlein, Jill (0011-4) 

Hoffman, Lilli (0011-4) 

Holtzback, Kaite (0011-4) 

Horwege, Richard (0011-4) 

Houston, Karin (0011-4) 

Hutchinson, Amber (0011-4) 

Irons, Ellie (0069-40) (0069-41) 

Jaronczyk, Ellen (0011-4) 

Jewell, B (0011-4) 

Johns, Brian (0011-4) 

Jones, Dale (0021-1) 

Josaitis, Marvin (0011-4) 

Kalukin, Andrew (0011-4) 

Keyser, Liz (0011-4) 

Kiehl, Allison (0011-4) 

Kosch, Sandra (0011-4) 

Kroupa, Brenda (0011-4) 

Kunkel, Christopher (0011-4) 

Larsen, Anne (0011-4) 

Larsen, Janice (0011-4) 

Laverdiere, Dorothy (0011-4) 

LeClair, Carol (0011-4) 
Appendix E 

NUREG-1917, SEIS E-40 February 2010 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Leon, Matea (0011-4) 

Light, John (0011-4) 

Liske, Patricia (0011-4) 

Lloveras, Lang (0011-4) 

Lufkin, Heather (0011-4) 

Maddox, Joshua (0011-4) 

Marroni, Edmond (0011-4) 

McDonald, Kim (0011-4) 

McFarland, Mary Ann (0011-4) 

McNeal, Ashby (0011-4) 

Meredith, Betty (0011-4) 

Meyer, Jennifer (0011-4) 

Miles, Linda (0011-4) 

Miller, Katelyn (0011-4) 

Miller, Lara (0011-4) 

Miller, Mary (0011-4) 

Mullinax, Franklin (0011-4) 

Neale, Laura (0006-1) (0006-4) (0006-5) 

Newell, Vicky (0011-4) 

Payne, Andrew (0011-4) 

Phillips, Donna (0011-4) 

Pintado, Isabel (0011-4) 

Plaskett, Micheline (0011-4) 

Plata, Errol (0011-4) 

Presgraves, Sandra (0011-4) 

Presley, Diann (0011-4) 

Rasmussen, Angela (0011-4) 

Reiner, Brian (0011-4) 

Rigby, John (0011-4) 

Roadcap, Leah (0011-4) 

Robbins, Patricia (0011-4) 

Rollins, Megan (0011-4) 

Roth, David (0011-4) 

Schmidt, Arthur (0011-4) 

Scott, Patricia (0011-4) 

Shamaiengar, Beth (0011-4) 

Shelton, Charles (0011-4) 

Shields, Page (0011-4) 

Sklar, Scott (0011-4) 

Smith, John (0011-4) 

Smith, Louise (0011-4) 

Squires, George (0011-4) 
Appendix E 

February 2010 E-41 NUREG-1917, SEIS 

Table E-2. (contd)

Comment Category Commenter (Comment ID)

Steegmayer, Andrea (0011-4) 

Stone, Eric (0011-4) 

Sumrall, Kamar (0011-4) 

Suter, Emanuel (0011-4) 

Tanner-Sutton, Linda (0011-4) 

Tarr, Suzanne (0011-4) 

Teeler, Sharon (0011-4) 

Testerman, Michael (0011-4) 

Traub, Charles (0011-4) 

Van Lingen, Gabriele (0011-4) 

Wells, Cathy (0011-4) 

Werderman, Kim (0011-4) 

White, Eric (0011-4) 

White, Phyllis (0011-4) 

Whitfield, Doris (0011-4) 

Williams, Martha (0011-4) 

Wilson, Brian (0011-4) 

Witting, Marjorie (0011-4) (0037-1) 

Woitte, Roger (0011-4) 

Young, Emerald (0080-3) (0080-4) 

Zeller, Lou (0024-2) (0024-3) 

Many comments addressed topics and issues that are not part of the environmental review for 

this proposed action. These comments included questions about the NRC’s safety review, 

general statements of support or opposition to nuclear power, observations regarding national 

nuclear waste management policies, comments on the NRC regulatory process in general, and 

comments on NRC regulations. These comments are included, but detailed responses to such 

comments are not provided because they addressed issues that do not directly relate to the 

environmental effects of this proposed action and are thus outside the scope of the NEPA 

review of this proposed action. 

Many comments specifically addressed the scope of the environmental review, analyses, and 

issues contained in the draft SEIS, including comments about potential impacts, proposed 

mitigation, the agency review process, and the public comment period. Detailed responses to 

each of these comments are provided in the following sections. 
Appendix E 

NUREG-1917, SEIS E-42 February 2010 

1. Comments Concerning the COL Process 

Comment: Public meetings should be held at other locations and times around the region so 

that interested parties are given the opportunity to be educated and voice their input in a public 

forum. This would facilitate public participation (which is one of the goals of the NEPA process). 

(0023-15 [Goldsmith, Aviv]) 

Comment: The public meeting for the DEIS was in the evening in Louisa in the winter. 

Slippery conditions limited the number of participants. Personally, I work in the evenings and 

it is very hard to attend a meeting in another town in the evening. I request that the public 

meetings be expanded so that a more representative population of effected citizens can 

participate in the EIS process. One meeting should be held in each of Charlottesville, 

Richmond, and Fredericksburg. At least one of these meetings should be during the day. 

(0023-2 [Goldsmith, Aviv]) 

Response: It is the policy of the NRC to involve the public in the Commission's decisionmaking process; therefore, it elects to conduct open public meetings to collect comments on 

the draft SEIS (NRC 2008) in association with its environmental review process. Meetings are 

generally held in a location accessible by the largest population that will experience the most 

direct environmental impact as a result of the proposed action. In the case of the proposed 

NAPS Unit 3, this population is located in the area of Louisa County, Virginia. The comment 

period on the draft SEIS was open for 75 days, and during that time, the public and other 

agencies were welcome to submit comments by mail, e-mail, or in person. These comments 

provide no new and significant information. Therefore, no changes were made to the SEIS. 

Comment: The Nuclear Regulatory Commission suffers from major flaws in carrying out its 

mission. Aside from the particular problems identified during specific power plants, the 

Commission itself is critically flawed as a regulatory body. The Combined Operating License 

process merged construction and operating permits. According to the NRC, the COL process 

improved regulatory efficiency and added predictability. However, the actual result appears to 

be exemplified in the following illustration [author added cartoon]. The public's perception is that 

the agency lacks true independence; that the NRC's review of and approval procedures are 

incomplete and perfunctory; that the procedural process lacks the essential element of ju stice 

and impartiality. Public hearings are held to satisfy the National Environmental Policy Act, 

comments are submitted, and the paper exercise seems to be the beginning and the end of the 

procedure. (0024-1 [Zeller, Lou]) 

Comment: Second, the Draft Supplemental EIS has compounded NRC's failure to rectify 

errors in the Early Site Permit process. As stated in our scoping comments of May 16th, 2008, 

NRC's alternative sites analysis, which was inconsistent with both the letter and the spirit of the 

National Environmental Policy Act. The NRC not only failed to correct this error, it changed the 

rules to allow the error to stand. Moreover, the rules were changed after the dissenting judge 

registered his opposition to the North Anna Early Site Permit. (0078-19 [Nguyen, Vanthi]) 
Appendix E 

February 2010 E-43 NUREG-1917, SEIS 

Response: These comments provide general information in opposition to the licensing process 

for a COL at a site that has received an ESP. These comments provide no new and significant 

information. Therefore, no changes were made to the SEIS. 

Comment: NRC and draft SEIS ignores May 2008 petitions and letters representing over 

6400 citizens. Although the NRC has a Mission Statement to protect the public health and 

safety, promote the common defense and security, and protect the environment, the NRC 

recommendation is for the approval of the Construction and Operating License, without doing a 

Recreation Impact Study of Lake Anna and downstream. In a few words the NRC basically 

ignored all of our 10 May 2008 comments, together with the petitions and letters submitted 

representing over 6,400 citizens and in some cases put the burden on Commonwealth of 

Virginia and/or the local localities to simply put restrictions in permits to protect the public. 

(0017-11 [Ruth, Harry]) 

Comment: The NRC has created a very complex process that discourages public participation 

and also does not require any impact studies to Lake Anna (main reservoir and cooling lagoons) 

and downstream shorelines, structures (docks, piers, bridges), safety to navigation, aquatics, 

social and economic factors, recreation, drought management and environmental study be 

completed prior to proceeding. How can the NRC proceed with such a project, without having 

any idea of the above impacts? (0017-3 [Ruth, Harry]) 

Response: The licensing process for COL applications is specified in 10 CFR Part 52. The 

environmental review process associated with new reactor licensing includes a detailed review 

of an applicant's COL application to determine the environmental effects of building and 

operating the nuclear power facility for up to 40 years. The detailed environmental review for 

the North Anna Unit 3 COL can be found in the ESP EIS (NRC 2006a). The COL SEIS 

evaluated issues that were unresolved at the time the ESP EIS was published and looked for 

new and significant information. NRC approval of an application for a COL is not a foregone 

conclusion. Safety, as well as environmental issues, will be evaluated before a decision on an 

application is reached. 

Under conditions of the ESP permit (NRC 2007), Dominion is required to conduct an Instream 

Flow Incremental Methodology (IFIM) Study that is designed and monitored in cooperation and 

consultation with the VDGIF and the Virginia Department of Environmental Quality (VDEQ) to 

address potential impacts of the proposed units on the aquatic resources of Lake Anna and 

downstream waters including recreational impacts. This study must be completed prior to 

issuance of a COL for any new units at NAPS. 

In October 2009, the final results of the IFIM study were published by Dominion with 

concurrence from VDEQ. This document is available in the NRC Agencywide Documents 

Access and Management System (ADAMS) database under Accession number Accession 

No. ML093210500. Various Sections of this SEIS have been updated as appropriate to include 

this information. 
Appendix E 

NUREG-1917, SEIS E-44 February 2010 

Comment: The vast majority of comments that I previously submitted on the DEIS scoping 

were acknowledged in the DEIS to be legitimate comments but there was no substantive 

analysis or response that occurred. This is contrary to the goals of the EIS process and results 

in citizens being disenfranchised and potentially demoralized. (0023-59 [Goldsmith, Aviv]) 

Response: All comments received during the scoping process were addressed at an 

appropriate level of detail in the draft SEIS (NRC 2008). This comment provides no new and 

significant information. Therefore, no changes were made to the SEIS. 

Comment: I have one further comment on the COL request at North Anna. It is my 

understanding that the ESP was granted for two additional units at North Anna and is good for 

20 years. Dominion has obligated that the forth unit will be "dry cooled" and will not use any 

water from Lake Anna. This is based on the fact that Dominion would use a next generation 

Reactor which may employ liquid metal in place of steam and the higher temperatures would 

make dry cooling very efficient. This plant is probably 20 years away if it can be done at all. With 

this in mind, I have the following question. If after 10 or 15 years Dominion comes back to the 

NRC and request to make unit 4 the same as unit 3 (maybe even tying the request to the decommissioning of plant 1 or 2 ) would the NRC require the applicant to start over the ESP and 

COL process or could the ESP be modified and only a COL required? If the applicant has to 

start over or modify it application, would the NRC only entertain "new and significant 

information" to be discussed for the ESP and COL. I realize that this question is somewhat 

"what if" but it is important for the public at Lake Anna to get a commitment from the NRC as to 

how it would proceed. (0022-1 [Remmers, Ken]) 

Response: The ESP remains in effect for a period of 20 years from the time of issuance. If 

Dominion submitted an application to construct and operate another reactor beyond Unit 3, it 

would have to repeat the COL process. If the application referenced the ESP permit, the 

conditions of the ESP would still apply, and that environmental review of the COL would 

consider all new and significant information since issuance of the ESP. This comment provides 

no new and significant information. Therefore, no changes were made to the SEIS. 

Comment: Public comments should be obtained, and a public meeting held, prior to the 

determination of the scope of this assessment, and prior to the finalization of the assessment. 

The assessment shall be considered by the Board in its determination of the conditions of the 

issues of any permit. (0073-45 [Remmers, Ken]) 

Response: Public comments regarding the issues related to the application were obtained 

during a public scoping meeting held in Mineral, Virginia on April 16, 2008. The public meeting 

that was held in Mineral, Virginia on February 3, 2009 was an opportunity for the public to 

provide comments regarding the contents of the draft SEIS. All comments received during 

scoping are included in the North Anna Unit 3 Scoping Summary Report (ADAMS Accession 

No. ML082480357). Comments considered in-scope were also included in Appendix D of the 

draft SEIS. All comments received on the draft SEIS are included in the final SEIS 

(Appendix E). As part of the contested and mandatory hearings, all public comments are 
Appendix E 

February 2010 E-45 NUREG-1917, SEIS 

available for consideration. This comment provides no new and significant information. 

Therefore, no changes were made to the SEIS. 

Comment: THE PROCESS IS FLAWED. One year ago, we met here for a Scoping Meeting at 

which time the NRC asked the public, governmental and tribal entities, and any interested 

parties and organizations to give testimony identifying "new and significant" information which 

should be the subject of the supplemental EIS. Many people participated, we were here until 

11:30 pm, and the comments were transcribed. Then, at great expense to all of us, the 

taxpayers, the transcription was divided into segments and all of the information was summarily 

dismissed as irrelevant, of little significance, or up to the state to mitigate. The NRC also stated 

that they were certain that Dominion would remedy many of the problems identified. There is no 

reason for any of us to believe that this evening will be any different. Will anything we say 

tonight be taken seriously or are all of gathered here tonight wasting our time? It is my opinion 

that the Draft Supplemental Environmental Impact Statement is a tragic waste of the trees that 

were cut down in order to publish it. (0003-1 [Crawford, Barbara]) 

Comment: I believe the NRC has many more studies and calculations to do before a COL 

decision is made. (0010-2 [Day, Elena]) 

Comment: Complex NRC Environmental process discourages public knowledge of exactly 

what is being planned. A review of the draft Supplemental document (Dec 2008) is very difficult 

(if not almost impossible), because it provides supplemental data only (Approximately 

400 pages) and if you do not know what was in the initial Environmental Impact Statement for 

the ESP (Approximately 800 pages) (Dec 2006), you cannot get a complete picture of what is 

being proposed or what has changed. A line by line comparison of both documents must be 

made to determine what the final proposal is. This is next to impossible on a home computer 

and impossible at the local library. (0017-5 [Ruth, Harry]) 

Comment: This also brings up an important point that effects the public participation of the 

COL process. The DSEIS is impossible to read and understand unless the reader is fully 

familiar with the entire process of the ESP. The DSEIS is riddled with references to the ESP. 

Since the ESP granted by the NRC for 20 years, would the NRC expect the public to be fully up 

to speed with all the work and revisions of the ESP if 10 or 15 years later a COL is requested by 

the applicant say for Unit 4? (0018-6 [Remmers, Ken]) 

Comment: Throughout the ESL process, the applicant and NRC stated that additional 

analyses and data would be presented in the COL process. The public is counting on this 

approach being adhered to. (0023-14 [Goldsmith, Aviv]) 

Comment: It seems that the ESL SDEIS, like the DEIS, was not performed by an unbiased 

interdisciplinary team as is required by NEPA. For example, Page 1-6 states that "Dominion did 

not or was unable to provide information and analysis for certain issues sufficient to allow the 

NRC staff to complete its independent analysis". Thus the issues "are not resolved". The NRC 

should commission independent sources to develop the required data at this time. 

(0023-16 [Goldsmith, Aviv]) 
Appendix E 

NUREG-1917, SEIS E-46 February 2010 

Comment: I am resubmitting comments in my prior scoping letter dated 8/11/2008 (attached). 

The DEIS asserts that many of these issues have been "resolved" but they have only been 

mentioned or deleted from consideration. Please "resolve" them now. 

(0023-9 [Goldsmith, Aviv]) 

Comment: It is extremely important to me, having grown up in the Fredericksburg region, 

watching it grow to one of the fastest expanding area in Virginia, that it is critical that decision 

are based on current information and addressed accordingly in order to protect our health and 

safely. (0040-1 [Whitfield, Doris]) 

Comment: Dominion Power must adhere to citizens’ expectations of those living near Lake 

Anna and be required to follow regulations requiring a new environmental assessment. 

Anything less is not acceptable. (0040-2 [Whitfield, Doris]) 

Comment: This also brings up an important point that affects the public's participation in this 

COL process. The DSEIS is impossible to read, and understand, unless the reader is fully 

familiar with the entire process of the ESP. The DSEIS is riddled with references to ESP, since 

the ESP was granted by the NRC for 20 years, would the NRC expect the public to be fully up to 

speed with all the work and revisions of the ESP if 10 or 15 years later a COL was requested, 

say, for unit 4? (0073-41 [Remmers, Ken]) 

Comment: Through the Early Site Permit process, the NRC determined that the new reactor 

can be safely sited, and operated with minimal environmental impact. In its Draft Supplemental 

Environmental Impact Statement for the Combined Operating License, the NRC stated that no 

new significant environmental issues had been raised since the issuance of the Early Site 

Permit. (0077-1 [Girvin, Larry]) 

Comment: In conclusion, environmental impacts unresolved in the Early Site Permit 

proceeding, must be evaluated and documented in a supplemental EIS. In addition, any new 

and significant information that would have the potential to affect the finding or conclusion 

reached in the ESP, must be evaluated. The public can have no confidence in a regulatory 

agency which sidesteps the rules, and covers its tracks. (0078-20 [Nguyen, Vanthi]) 

Comment: There are several things that are wrong in this EIS. Some of them do come from 

the ESP, that haven't been addressed. There was the issue of plagiarism that came from 

Dominion to the PNNL and then to the NRC. This issue has not been addressed, and needs to 

be brought back again. (0082-10 [Rosenthal, Jerry]) 

Response: These comments express general opposition to the NRC's COL referencing an 

ESP process and will not be evaluated further. The NRC will continue to carefully review the 

NAPS Unit 3 application against its regulations that are intended to protect public health and 

safety and the environment. 

As outlined in the Federal Register Notice of August 28, 2007 (72 FRN 49429), the NRC rules 

indicate that issuance of an ESP and a COL are major Federal actions significantly affecting the 
Appendix E 

February 2010 E-47 NUREG-1917, SEIS 

quality of the human environment and that each action would require the preparation of an 

environmental impact statement (EIS). However, 10 CFR Part 52 does provide finality for 

previously resolved issues. Thus, the environmental review conducted by NRC at the COL 

stage is informed by the EIS that was prepared at the ESP stage, and information can be 

incorporated by reference in the COL SEIS. The COL SEIS for the proposed NAPS Unit 3 

focuses on new and significant information identified after issuance of the final ESP EIS (NRC 

2006a), resolves significant environmental issues not addressed in the ESP proceedings, and 

ensures that all environmental terms and conditions included in the ESP relevant to the COL will 

be satisfied by the date of issuance of the COL SEIS. These comments provide no new and 

significant information. Therefore, no changes were made to the SEIS. 

2. Comments Concerning Site Layout and Design 

Comment: We [U.S. Army Corps of Engineers (USACE)] recommend you submit the following 

information so we may conduct a public interest review: A USGS topographic map depicting the 

location and boundaries of the project site for the proposed Units 3 and 4. 

(0009-1 [Bronson, Regena]) 

Response: NRC will supply a map for the proposed Unit 3 layout. Any additional maps would 

need to be submitted to the USACE by Dominion and not by the NRC. Because this comment 

did not provide specific new and significant information, no change was made to the SEIS. 

Comment: The system reinforcements required were revised in the COLA-ER Rev. 1, 

submitted in December 2008. The second bullet should be revised to state: "addition of a new 

500 kV bay to support the new transmission line." (0084-36 [Grechek, Eugene]) 

Response: The comment is noted. Section 3.3 of the SEIS has been revised to reflect the 

comment. 

3. Comments Concerning Land Use – Site and Vicinity 

Comment: The SEIS does not include a discussion of potential project impacts on state 

subaqueous lands. (0069-14 [Irons, Ellie]) 

Response: This comment asserts that the Virginia Marine Resources Commission's (VMRC) 

permit jurisdiction would extend to the portions of the proposed project that result in direct 

impacts and encroachment to the historic stream channel of the North Anna River. The need 

for a permit from the VMRC is addressed in Table L-1 of the ESP EIS (NUREG-1811). Potential 

impacts to the historic stream channel are addressed in Chapters 4 and 5 of the ESP EIS (NRC 

2006a) and the COL SEIS. The comment provides no new and significant information. 

Therefore, no change was made to the SEIS. 

Comment: According to DCR-DSWC, the property owner is responsible for submitting a 

project-specific erosion and sediment control (ESC) plan to Louisa County for review and 

approval pursuant to the local ESC requirements, if the project involves a land-disturbing activity 
Appendix E 

NUREG-1917, SEIS E-48 February 2010 

of equal to or greater than 10,000 square feet. Depending on local requirements the area of 

land disturbance requiring an ESC plan may be less. The ESC plan must be approved by the 

locality prior to any land-disturbing activity at the project site. All regulated land-disturbing 

activities associated with the project, including on and off site access roads, staging areas, 

borrow areas, stockpiles, and soil intentionally transported from the project must be covered by 

the project specific ESC plan. Local ESC program requirements must be requested through 

Louisa County. [Reference: Virginia Erosion and Sediment Control Law paragraph 10.1-563; 

Virginia Erosion and Sediment Control Regulations 4 VAC 50-30-30 and 4 VAC 50-30-40]. 

(0069-33 [Irons, Ellie]) 

Response: Table L-1 in the ESP EIS (NRC 2006a) covers Federal, State, and local 

authorizations and consultations. A revised version of Table L-1 is included in the COL SEIS. 

The revised table reflects the erosion and sediment control plan requirements. 

Comment: We recommend that all land disturbing activities adhere to erosion and sediment 

controls (0070-5 [Ewing, Amy]) 

Response: This comment provides a specific recommendation to Dominion by the VDGIF. As 

noted in Sections 4.3.1, 4.4.1, 4.4.2, and 4.10 of the draft SEIS (NRC 2006b), Dominion has 

stated it would use best management practices and compliance with applicable regulatory 

requirements to control erosion. This comment provides no new and significant information. 

Therefore, no changes were made to the SEIS. 

Comment: "ESP site boundaries" should be shown in the FSEIS and are not reflected properly 

in the current drawing [Figure 2-1]. In addition, the intake channel in the DSEIS drawing 

indicates a full removal of the outer berm which contradicts correct statements made in DSEIS 

Section 9.3.1. Dominion suggests that Figure 1.1-1 from the ER be substituted. 

(0084-5 [Grechek, Eugene]) 

Response: Figure 2-1 was replaced in the SEIS. 

4. Comments Concerning Meteorology and Air Quality 

Comment: The same limited three-year climatological data set that was used in the DEIS was 

used for the SDEIS (page 2-7 line 3). Is this the same data referred to in Page 5-14 line 22? 

This may be insufficient to accurately predict ground fog impacts from the project. Furthermore, 

this data sent is inconsistent with other reporting periods (see DEIS section 5-58 line 38 e.g.) 

used elsewhere in the document. (0023-17 [Goldsmith, Aviv]) 

Comment: Overall, the mitigations listed in Section 10 are insufficient. Items such as 

"consider" plume abatement measures are just one example. (0023-52 [Goldsmith, Aviv]) 

Response: These comments refer to the draft ESP EIS (NRC 2006b). Comments on the draft 

ESP EIS were considered in the final ESP EIS, which was published in December 2006 (NRC 

2006a). The three year meteorological data set described in Section 2.3 is representative of 
Appendix E 

February 2010 E-49 NUREG-1917, SEIS 

site conditions and was used to evaluate atmospheric moisture, fog and the impact of cooling 

towers on the atmosphere in Sections 2.3 and 5.2 of the ESP EIS and the impacts were found 

to be SMALL. No new information was identified to indicate that the meteorological data set 

that was used is not representative of this site. Therefore, no changes were made to SEIS. 

Comment: The cooling tower will shift much of the thermal load from Lake Anna to the 

atmosphere. Shouldn't mitigation be required to minimize heat island and climate change 

impacts? Such mitigation could include tree planting and similar regional measures. 

(0023-54 [Goldsmith, Aviv]) 

Comment: Also I believe there is evidence to support the idea that putting a cap on carbon 

pollution will result in the springing up of all kinds of new ways of generating clean energy. With 

that in mind, I'd prefer to see that happen than to have another nuclear reactor added to the 

ones we already have. Please move toward a carbon cap, and selling credits for what you don't 

use. I believe that will help us much more than another nuclear reactor. 

(0041-2 [Bailey, Marcia]) 

Response: The minute, localized climatic changes related to the operation of the cooling tower 

for the proposed Unit 3 would be undetectable, and mitigation is not warranted. Heat island 

effects generally are related to urban centers that have vast tracks of land developed into 

situations that absorb insolation, compared to the transpiring surfaces more common in rural 

areas. The NRC staff evaluated the impacts of global warming, climate change, and 

greenhouse gases in Section 5.11 of the SEIS. The NRC's responsibility is to regulate the 

nuclear industry to protect the public health and safety within existing policy. The NRC is not 

involved in establishing and administering energy policy. These comments provide no new and 

significant information. Therefore, no changes were made to the SEIS. 

Comment: Measures and controls to limit adverse air impacts during construction were 

addressed in Section 4.10 of the ESP EIS (NRC 2006a) and incorporated into the 

Environmental Protection Plan (EPP) for the site that is included as Appendix 1A of the COL ER 

(Dominion 2007a) (SEIS page 4-25, section 4.10). The document (page 5-2, section 5.2) 

indicates that the meteorological and air quality impacts from operation of the proposed closed 

cycle, combination wet and dry cooling system for Unit 3 would be limited to those resulting from 

the cooling system and periodic pollutant emissions from auxiliary boilers and generators that 

would support the unit. (0069-34 [Irons, Ellie]) 

Response: This comment provides no new and significant information. Therefore, no changes 

were made to the SEIS. 

Comment: The project site is located in a designated ozone attainment area. Precursors to 

ozone (03) pollution include volatile organic compounds (VOCs) and oxides of nitrogen (NOX). 

However, due to the proximity of the site to Spotsylvania and Hanover counties, which are 

designated as ozone maintenance areas, Dominion should take all reasonable precautions to 

limit emissions of VOCs and NOX, principally by controlling or limiting the burning of fossil fuels. 

(0069-35 [Irons, Ellie]) 
Appendix E 

NUREG-1917, SEIS E-50 February 2010 

Response: The NRC staff’s assessment regarding impacts to air quality is presented in 

Sections 2.3, 4.2, 5.2, 5.11, and 7.2. Mitigating actions to be taken by the applicant related to 

air quality are included in the Environmental Protection Plan submitted as Appendix 1A of the 

COL application environmental report (ER), Table 1 ("Mitigating Actions for Construction 

Activities") and Table 2 ("Mitigating Actions for Operation") (Dominion 2009a). This comment 

provides no new and significant information. Therefore, no changes were made to the SEIS. 

Comment: Fugitive dust must be kept to a minimum by using control methods outlined in 

9 VAC 550-60 et seq. of the Regulations for the Control and Abatement of Air Pollution. These 

precautions include, but are not limited to, the following: 

• Use, where possible, of water or chemicals for dust control 

• Installation and use of hoods, fans, and fabric filters to enclose and vent the handling of 

dusty materials 

• Covering of open equipment for conveying materials 

• Prompt removal of spilled or tracked dirt or other materials from paved streets and 

removal of dried sediments resulting from soil erosion. 

(0069-36 [Irons, Ellie]) 

Comment: If project activities include the burning of construction material, this activity must 

meet the requirements under 9 VAC 5-40-5600 et seq. of the Regulations for open burning, and 

it may require a permit. The Regulations provide for, but do not require, the local adoption of a 

model ordinance concerning open burning. Dominion should contact Louisa County officials to 

determine what local requirements, if any, exist. The model ordinance includes, but is not 

limited to, the following provisions: 

• All reasonable effort shall be made to minimize the amount of material burned, with the 

number and size of the debris piles; 

• The material to be burned shall consist of brush, stumps and similar debris waste and 

clean-burning demolition material. 

• The burning shall be at least 500 feet from any occupied building unless the occupants 

have given prior permission, other than a building located on the property on which the 

burning is conducted. 

• The burning shall be conducted at the greatest distance practicable from highways and 

air fields. 

• The burning shall be attended at all times and conducted to ensure the best possible 

combustion with a minimum of smoke being produced. 
Appendix E 

February 2010 E-51 NUREG-1917, SEIS 

• The burning shall not be allowed to smolder beyond the minimum period of time 

necessary for the destruction of the materials. 

• The burning shall be conducted only when the prevailing winds are away from any city, 

town or built-up area. 

(0069-37 [Irons, Ellie]) 

Comment: The installation of any fuel burning equipment (e.g. boilers and generators), may 

require permitting from DEQ prior to beginning construction of the facility (9 VAC 5-80, Article 6, 

Permits for New and Modified Sources). This would include cooling towers as there may be 

issues with VOC emissions resultant from additives to make-up water, or particulate emissions 

from the cooling towers that may require air permitting. The project proponent should contact 

DEQ-NRO for guidance on whether this provision applies. (0069-38 [Irons, Ellie]) 

Response: These comments are recommendations directed at the applicant by the VDEQ. 

The NRC staff’s assessment regarding impacts to air quality including dust is presented in 

Sections 2.3, 4.2, 5.2, 5.11 and 7.2. Mitigating actions to be taken by the applicant related to air 

quality are included in the Environmental Protection Plan submitted as Appendix 1A of the COL 

ER), Table 1 ("Mitigating Actions for Construction Activities") and Table 2 ("Mitigating Actions for 

Operation") (Dominion 2009a). These comments provide no new and significant information. 

 Therefore, no changes were made to the SEIS. 

Comment: According to DEQ-NRO, the SEIS does not thoroughly discuss air permit 

requirements. (0069-39 [Irons, Ellie]) 

Response: Air quality and air quality permits are addressed in Section 2.3 of the final ESP EIS 

(NRC 2006a) where it is noted that VDEQ would regulate airborne emissions at the North Anna 

ESP site during construction activities and routine nonradiological emissions during operation. 

This requirement will be incorporated into the SEIS by reference. A list of permits relating to air 

quality is included in SEIS Appendix L, Table L-1. 

Comment: [Comment on DSEIS Section 2.3] The COLA-ER [Table 2.7-1, Note 1] describes 

the closest receptor as 1.20 km (3930 feet) from the plant facility boundary (Unit 3). 

(0084-6 [Grechek, Eugene]) 

Response: The clarification identified in this comment was incorporated into Section 2.3 of the 

SEIS. 

5. Comments Concerning Hydrology – Surface Water 

Comment: With respect to water related impacts, in Section 5.3 of the DSEIS, the NRC has 

devoted a whopping one and a half pages to this most important issue. 

(0073-39 [Remmers, Ken]) 
Appendix E 

NUREG-1917, SEIS E-52 February 2010 

Comment: Related to comments provided by Dominion for the ESP DEIS on ER Section 5.3.1, 

5.3.2, 5.4.1.4 and Appendix K as provided in Dominion Letter dated Sept. 12, 2006 (Accession 

No. ML062990422) and as summarized below: 

The FEIS for the ESP used an acceptable, but less precise method of confirming the evaluation 

performed by Dominion in order to assess the impact of Unit 3. The [NRC] analysis used the 

long term average evaporation rate that Dominion stated in the ESP Application, which included 

a large portion of time when the lake was at or above 250 ft. msl and there was enough water to 

support the evaporative cooling process. When applied to the time periods when the lake is 

below 250 ft. msl, this method over estimates the evaporative loss caused by wet cooling and 

does not adequately credit the use of dry (i.e., no evaporation) cooling. The FEIS for the ESP 

concluded that the water use impact of Unit 3 was SMALL during normal periods and 

MODERATE during drought periods using the conservatively high value for evaporation, so 

further analysis using a more precise method was not required. Dominion's analysis used a 

more precise evaluation including daily evaporation estimates as a function of ambient 

environmental conditions and cooling system modes of operation (EC or MWC) depending on 

the projected lake level. 

The FEIS for the ESP reflects the NRC confirmatory analysis, and while the results do not 

exactly match those stated in the ESP-ER, the conclusion of SMALL IMPACT is unaffected. 

(0084-26 [Grechek, Eugene]) 

Response: The issue of water-related impacts was resolved in the ESP EIS (NRC 2006a), with 

the exception of water-quality impacts related to water treatment. Only unresolved issues or 

new and significant information related to resolved issues need to be addressed in the SEIS. 

Water-quality impacts related to the water treatment system are addressed in Section 5.3.3 of 

the SEIS. These comments provide no new and significant information. Therefore, no changes 

were made to the SEIS. 

Comment: A third reactor would also jeopardize the water resources of the area. 

(0067-2 [Suter, Emanuel]) 

Comment: Downstream water, something that hasn't been considered. The State Fair is 

moving on to the North Anna River. They are planning on using the water from the North Anna 

as part of the State Fair. And this is going to be right at the height of the drought, late August, 

September, not included in there. (0082-13 [Rosenthal, Jerry]) 

Response: Water use impacts were considered and resolved in the ESP EIS (NRC 2006a), 

which stated that “... potential conflict over [downstream] water use, which exists regardless of 

whether Unit 3 is constructed, falls within the regulatory authority of the Commonwealth of 

Virginia.” No new and significant information was identified during the COL review that changed 

the staff’s conclusions on the level of impact. The IFIM study (Dominion 2009b) that was 

conducted as a requirement by the Commonwealth of Virginia and as a condition of the ESP for 

the North Anna site addressed impacts on lake levels and downstream flows under different 

reservoir operating scenarios during proposed Unit 3 operations, compared to the existing 
Appendix E 

February 2010 E-53 NUREG-1917, SEIS 

(Unit 1 and 2) reservoir operating condition. The IFIM study evaluated an alternative to increase 

Lake Anna reservoir storage capacity by raising the normal pool elevation by 0.25 ft to 250.25 ft. 

The results of the IFIM study were not available at the time the draft SEIS was published; 

however, the final IFIM report was published in October 2009, and the results are included in 

Section 2.7.2.4 and Chapter 5 of the final SEIS. Reservoir management, water use, and 

downstream instream flow requirements remain within the authority of the Commonwealth of 

Virginia. 

Comment: It appears that there are major discrepancies in the water sections. In numerous 

places the SDEIS asserted that data was lacking or simplified methodologies were used. (See 

for example Page 1-6 which states inter alia insufficient information was available "to allow the 

NRC staff to complete its independent analysis" and "these issues are not resolved for the North 

Anna ESP site"). As evidenced from the recent public hearing, water use and impacts on lake 

level and downstream flow are major areas of concern. The SDEIS (see Table 10-3 e.g.) that 

the impacts of water use and quality are "unresolved" is not sufficient to make a determination 

of the project's acceptability. Perhaps a solution is to commission a truly unbiased third party 

water study to provide better methodology and data for impact assessments. This study could 

be incorporated into a new DEIS. (0023-10 [Goldsmith, Aviv]) 

Comment: The SDEIS continues to be very troubling regarding water analysis. It states that 

the assessments "are based on a simplified representation of the conservation of mass for the 

lake". This excludes water temperature stratifications and the flow contributions from a many of 

the tributaries. How then, can the impact forecasts of SMALL be reliable? How can "no 

mitigation" be a reasonable solution? (0023-28 [Goldsmith, Aviv]) 

Comment: Along the lines of the prior comment, SDEIS page 5-7 line 26 concluded that 

"relatively small errors in the pool elevation measurements using this model can result in 

significant errors in the precipitation, groundwater, and tributary inflow estimate". How then, can 

the impact forecasts of SMALL be reliable? How can "no mitigation" be a reasonable solution? 

Perhaps an independent comprehensive water study would provide more robust impact 

assessments. (0023-29 [Goldsmith, Aviv]) 

Comment: Shouldn't the operator's role in decisions to change the normal lake level 

(Page 511, line 28 et. seq.) be one of conditions of the COL? Just because "modifications to 

the water release regime from the Lake Anna Dam to mitigate impacts would be under the 

jurisdiction of VDEQ" (Page 5-33 line 14), does not absolve the operator or the NRC from 

adopting reasonable mitigation measures which could be subject to VDEQ approval. 

(0023-30 [Goldsmith, Aviv]) 

Comment: Wouldn't the installation of new unit(s) be an opportunity to mitigate some of the 

existing problems with water temperature and lake level? (0023-31 [Goldsmith, Aviv]) 

Comment: The determination in Table 10-3 and elsewhere that the impacts on water use and 

quality is "likely to be SMALL" is unsubstantiated. As was clear from the last public hearing, the 

public's perception is that the impacts are LARGE. (0023-55 [Goldsmith, Aviv]) 
Appendix E 

NUREG-1917, SEIS E-54 February 2010 

Response: These comments refer to the draft ESP EIS (NRC 2006b) that was superseded by 

the final ESP EIS (NRC 2006a)) published by NRC in December 2006. The ESP EIS was 

revised to incorporate numerous public comments and an independent water budget analysis 

(Appendix K). In November 2007, the NRC issued an ESP (ESP-003) to Dominion for two units 

at the NAPS site (NRC 2007). In its environmental review of the subsequent COL application 

for the proposed Unit 3, the NRC staff reviewed information that might be new and significant 

pertaining to the water-related impacts of construction and operation of the proposed Unit 3. 

Those impacts, as well as potential mitigation measures, are addressed in Chapters 4 and 5 of 

this SEIS. The NRC’s environmental review is limited to the proposed action, which is 

construction and operation of Unit 3. Therefore, mitigative measures related to the continued 

operation of Units 1 and 2 are outside the scope of this review. Limits on the station discharge 

as well as the imposition of other mitigative measures remain within the authority of the 

Commonwealth of Virginia. No change was made to the SEIS as a result of these comments. 

Comment: New Sewage Treatment Facility (sewage effluent and chemicals discharged into 

Lake Anna). How can the NRC support sewage effluent and chemical being discharged into 

Lake Anna where the public swims and recreates??? The draft SEIS for the COL in 5.3.3 

(Water Quality Impacts) says that treated effluent from the proposed new sanitary plant would 

be combined with Unit 3 plant discharges in the blowdown sump before discharging to the 

Waste Heat Treatment Facility (WHTF)-cooling lagoons. 

In 3.2.4.1 the draft SEIS also says Chemicals and biocides will be employed in water treatment 

for various water systems at the proposed Unit 3 to include treatment of circulating water, 

service water, station water, and de-mineralized water. Effluent streams will also include 

pollutants (e.g. oil and grease, total suspended solids and iron) from corrosion and wear of plant 

piping and equipment. Waste effluents from these systems will be regulated by the VPDES 

permit and will flow into the cooling tower blowdown sump. These effluents then will flow into 

the discharge canal where they will mix with the circulating water from Units 1 and 2 and finally 

be discharged into the WHTF cooling lagoons. 

In 7.3 Water Quality, the draft SEIS says the proposed Unit 3 would discharge effluents into the 

discharge canal that will likely exceed water-quality criteria for copper and tributyltin. 

Further dilution would occur in the warm side of the lake (WHTF) and eventually Lake Anna 

(main reservoir). Based on this information, the NRC concluded that the cumulative 

water-quality impacts associated with the proposed Unit 3 would remain SMALL. Pollutant 

discharges would be regulated under a Virginia Pollutant Discharge Elimination System permit. 

Note that 99% of the lake water is currently re-circulated between the power plant and the dam 

and only 1% runs over the dam. This water is heated by the power plant, which increases the 

risk to humans who swim and recreate in the water to increased biological risks from the new 

sewage effluent, additional chemicals and pollutants added to Lake Anna. 

(0017-14 [Ruth, Harry]) 

Comment: Plans for Disposal of Treated Sewage. In order to support the operation of a new 

unit and the 750 workers hired to operate and maintain it, Dominion plans to build a second 
Appendix E 

February 2010 E-55 NUREG-1917, SEIS 

waste treatment plant to locally process human and other waste. The treated effluent of that 

plant, like the effluent from the existing waste treatment facility, would be dumped into Lake 

Anna at the discharge canal. Of special concern is the discharge of untreated sewage into Lake 

Anna during periods when the waste treatment plant is not operational. This is a common 

problem with all sewage treatment plants as no plant can operate without ever experiencing 

failures of some type. Lake Anna is not a free flowing stream but is basically an impoundment 

as much more water flows into the lake than is ever discharged at the dam. The added 

nutrients from the effluent will remain in the lake and accumulate over years. The buildup of 

nitrates can produce algae blooms that produce fish kills and encourage plant growth such as 

hydrilla that can choke entire bays. (0019-4 [Smith, Doug]) 

Comment: We have another concern, and that is about the sewage treatment facility that will 

be a part of the third unit. We would like Dominion to implement a system similar to what a new 

development here, Cutalong, is implementing in which the effluent would not be put back into 

the lake. (0073-55 [Smith, Doug]) 

Comment: Now, the NRC has, in the Draft SEIS you have a whole section on long-term 

impacts, but you fail to look at the long-term impact of putting the effluent into the lake and the 

accumulation of nitrates in the water, over time. We ask that you take another look at that, and 

include something in the Final SEIS on that subject. (0073-56 [Smith, Doug]) 

Response: Dominion will be required to operate the proposed sanitary treatment plant, or any 

other form of sanitary treatment, in compliance with the Sewage Collection and Treatment 

Regulations of the State Water Control Board (9 VAC 25-790), and to discharge effluent under 

the conditions of a Virginia Pollutant Discharge Elimination System (VPDES) permit. Dominion 

estimated the maximum discharge rate from the sanitary plant into the station discharge canal 

to be 105 gallons per minute (gpm), or approximately 2 percent of the Unit 3 cooling water 

system blowdown during normal operation, and less than 0.3 percent of the total effluent 

discharge from Units 1, 2, and 3 combined. Such a small amount of treated sanitary waste 

would not result in degradation of Lake Anna water quality by nutrients that would increase the 

frequency of algal blooms or the presence of Hydrilla. No change was made to the SEIS as a 

result of these comments. 

Comment: EPA continues to have concerns regarding the thermal discharge from the 

proposed Unit 3 consistent with those expressed in our August 28, 2006 comments on the 

Supplemental Environmental Impact Statement for the Early Site Permit. 

(0072-1 [Lapp, Jeffrey]) 

Response: In the August 28, 2006 comments on the supplemental draft EIS for the ESP, EPA 

expressed concerns about the limited information available regarding the closed cycle combined 

wet and dry cooling system to mitigate the effects of thermal discharges. The additional 

information regarding the cooling system, including the location of the system, the design of the 

system, and the planned operation of the system is now provided in Section 3.2.2, “Cooling 

System.” The impact that may result from the operation of the cooling system is provided in 

Section 5.4.1 on terrestrial resources and in Sections 5.4.2 on aquatic resources. 
Appendix E 

NUREG-1917, SEIS E-56 February 2010 

Comment: Numerous requests have been made to the NRC, the Commonwealth of Virginia, 

the Department of Environmental Quality (DEQ), the Department of Game and Inland Fisheries 

(DGIF), the Department of Conservation and Recreation (DCR) and Dominion itself to study all 

of the impacts on Lake Anna that will be brought on by the third reactor. 

It is imperative that we know how the lake will be affected. The increasing drought cycles have 

aggravated the low water levels on the lake. Many thousands of people live on or near the lake 

and many more use it on a daily basis. The Lake Anna State Park is a treasured resource 

where families gather to recreate. 

The normal pool level is 250 feet, but the lake is rarely full, whether from drought, summer heat, 

Dominion's failure to monitor the flow over the dam, and, of course, from the operation of Units 1 

and 2. We need to know to what extent the addition of a 3rd reactor will aggravate what is 

already a serious situation. 

When the lake falls below the 250 feet normal pool level, which is most of the time, the following 

problems occur: 

1. Homeowners have mudflats in front of their homes instead of lakefront. 

2. Homeowners are therefore unable to put their boats in the water, thus depriving them of one 

of the main reasons for purchasing lakefront land. 

3. Boulders, stumps, and sandbars which were previously submerged, become exposed or just 

below the surface, causing serious hazards to boating on the lake. 

4. The shoreline becomes destabilized. 

5. The 35 dry fire hydrants on the Louisa County side of the lake become unusable, making it 

difficult for firefighters to put out fires. 

6. Water temperatures which are already seriously elevated rise to levels that pose health 

hazards to the public. 

7. The many businesses which depend on a healthy and thriving environment at the lake are 

threatened with economic disaster, as the public goes elsewhere to recreate. 

(0003-4 [Crawford, Barbara]) 

Comment: 

D. DROUGHT CYCLES ARE INCREASING IN CENTRAL VIRGINIA AND THROUGHOUT 

THE SOUTHEAST 

Whether from Climate Change or Global Warming, drought cycles are increasing rapidly in our 

area and throughout all of the Southeast. Dominion, when it selected this area for the 

construction of a nuclear power plant, estimated that there would be a drought approximately 

every 20 years. In reality, we have experienced serious droughts in 6 of the past 10 years. The 

water level in the lake has fallen below 248 feet in 5 of the past 8 years. 
Appendix E 

February 2010 E-57 NUREG-1917, SEIS 

In 2002, after a 3 year drought, the water level fell to 245 feet and Dominion was faced with 

having to close down both Units 1 and 2. After that, Dominion extended its intake pipes which 

solved its problems but did nothing for all of the people who lived on and around the lake or who 

traveled there to recreate. 

Faced with yet another reactor at the lake, the question must be asked: is there truly enough 

water to sustain 3 reactors without destroying the lake for all of the people who live there? 

E. DOMINION HAS ACKNOWLEDGED THAT THE PROPOSED 3RD REACTOR WILL 

DOUBLE THE DROUGHT CYCLES AT LAKE ANNA 

For all of the reasons listed above, this could be a disaster for Lake Anna. It is important to 

remember that Lake Anna is not Dominion's possession, to do with as it sees fit. When 

Dominion was given permission to build a nuclear power plant here in Louisa County and to 

construct a dam and create Lake Anna as a means to cool its nuclear reactors, it was made 

clear that the lake would have 2 purposes: 1. to cool the reactors and 2. to create a recreational 

lake for the citizens of Virginia and the many others who would travel here to enjoy it. Soon 

after, the Commonwealth of Virginia decided to build a State Park here. 

It would be tragic if one use for the lake were permitted to destroy the other. It is for this reason 

that a comprehensive study of the impacts of the proposed 3rd reactor on Lake Anna must be 

undertaken. Just as the NRC mandated that the IFIM study be accomplished by Dominion prior 

to the issuance of the Combined Operating License, it is now appropriate that the NRC require 

Dominion to conduct a comprehensive study of the impacts on the Lake itself. 

(0003-5 [Crawford, Barbara]) 

Comment: The petitions and supporting letters requested that the NRC examine the impact of 

declining water levels that will: 

• Create many boating hazards with previously submerged items (rocks, stumps, 

sandbars, etc.) are exposed and create major safety hazards for recreational users 

when their boats hit these submerged items. 

• Cause the water will get hotter faster in the summer months to unsafe water 

temperatures causing negative health impacts to humans, fish, wildlife, aquatic life, 

clams and mussels. 

• Create a major fire safety hazards for lake homes/communities by making the dry fire 

hydrants unusable due to the lack of water at the lake intake caused by the decreasing 

lake water level. 

• Increase shoreline stabilization problems and Create negative impacts on many lake 

businesses as people go elsewhere to recreate and live. 

(0017-12 [Ruth, Harry]) 
Appendix E 

NUREG-1917, SEIS E-58 February 2010 

Comment: The Virginia Dept of Environmental Quality (VDEQ) Dept of Water Resources and 

the Dept of Game & Inland Fisheries (DGIF) have previously indicated that the North Anna 

watershed is too small to allow large water withdrawals. These could adversely affect the 

beneficial users of the North Anna and Pamunkey Rivers which eventually flow into the 

Chesapeake Bay and the Atlantic Ocean. The DGIF & VDEQ analyses and Dominion 

acknowledges that the third reactor would increase the drought cycle and cause decreased 

water flows during March, April; May; June, July, August and September (7 months) of each 

year. Dominion has stated that the drought cycle will double with the addition of the third 

reactor wet/dry cooling method. The proposed cooling method will cause the average drought 

period to increase from 21 to over 40 days per year (most likely during the summer months). 

Note that lake levels have decreased below 248 MSL in five out of the last eight years. The 

DSEIS should explore facts versus Dominion predictions with lake levels decreasing below 

250 MSL and related impacts to the public, fish, clams/mussels, and wildlife. 

(0017-8 [Ruth, Harry]) 

Comment: Flows into the cooling lagoon, millpond, and the reservoir, at this time are not even 

gauged to know what the input flows are, such as the North Anna River, the Pamunkey Creek, 

Terry's Run, and Contrary Creek. (0073-36 [Remmers, Ken]) 

Comment: Flows over the dam, water level changes, any introduced wetlands, and FERC 

requirements for any increased normal pool level, need to be addressed by the NRC and the 

DSEIS for the COL. (0073-37 [Remmers, Ken]) 

Comment: Two, low lake levels create increased erosion along the shoreline, and damage 

wetlands and other aquatic life. How many acres of wetlands do you think will be affected by the 

water consumption of the third reactor? Answer, nobody knows. 

(0073-49 [Smith, Doug]) 

Comment: Water levels, reduced water levels cause erosion around existing bulkheads, and 

existing shoreline protection. How many bulkheads and other structures are affected by this 

increased water consumption? Answer, nobody knows. (0073-52 [Smith, Doug]) 

Comment: I feel that the issue of overheated water in Lake Anna, its impacts on the lake 

ecosystems, its impact on recreation on or near the lake, its impacts downstream in the North 

Anna, Pamunkey, and York River watershed has still not been addressed in the Environmental 

Impact Statement. (0073-57 [Day, Elena]) 

Comment: Another nuke constructed on the shores of Lake Anna will only increase water 

temperature, and decrease availability of water in the lake, and downstream, especially in times 

of drought. (0073-58 [Day, Elena]) 

Comment: We do not believe that Lake Anna's water supply can support cooling for an 

additional reactor without decreasing the amount of water released into the North Anna river. 

This will be particularly serious during periods of drought, or near drought. 

(0078-3 [Cruickshank, John]) 
Appendix E 

February 2010 E-59 NUREG-1917, SEIS 

Comment: We also have concerns about lake levels. Some other people have discussed this. 

Altering the intake structures for units 1 and 2, and lowering the allowable minimum lake level 

would permit incrementally greater effective storage at the expense of greater impacts on 

recreation and fish populations. (0078-7 [Cruickshank, John]) 

Comment: Chapter 3 mentions blowdown and other discharges. Will the applicant stipulate to 

a 100 degree thermal discharge limit as an operating permit condition as requested by the 

Waterside Property Owners Association? Will the applicant stipulate to a 104 degree limit at the 

end of the discharge canal as requested by Friends of Lake Anna? 

(0023-23 [Goldsmith, Aviv]) 

Response: These comments reiterate concerns about the impacts of the proposed Unit 3 on 

the temperature and water level of Lake Anna, downstream impacts, and possible worsening of 

drought conditions. Thermal impacts were resolved at ESP stage and no new and significant 

information was identified during the COL review; the increase in temperature in Lake Anna and 

downstream in the North Anna River related to proposed Unit 3 operation would be insignificant. 

 As a condition of the ESP for the North Anna site, Dominion was required to conduct an IFIM 

study to address impacts on lake levels and downstream flows under different reservoir 

operating scenarios during proposed Unit 3 operations, compared to the existing (Unit 1 and 2) 

reservoir operating condition. The IFIM study components included downstream habitat for fish 

and other organisms, recreation on the North Anna and Pamunkey Rivers, wetlands around the 

shore of Lake Anna, and Lake Anna boat ramps and docks. The IFIM study considered 

increasing the normal pool level of Lake Anna by 0.08 m (0.25 ft) to 76.3 m (250.25 ft). The 

results of the IFIM study were not available at the time the draft SEIS was published; however, 

the final IFIM report was published in October 2009, and the results are included in Section 

2.7.2.4 and Chapter 5 of the final SEIS. Reservoir management, water use, and downstream 

instream flow requirements remain within the authority of the Commonwealth of Virginia.

Comment: Why can't Dominion use the cooler (60 to 65 degree F) Lake Anna Water located in 

deep water depth's (close to the dam) to provide supplemental cooling for the Unit 3 Reactor 

during the summer months, as opposed to operating in the ECM Mode (Up to 24 million gallons 

a day) Cooling Method? This could simply be accomplished by running an intake pipe from the 

deeper depths (cooler water) caused by thermoclines at the dam to the intake of the cooling 

towers, thereby eliminating an up to additional 8 million gallons a day of water usage from the 

lake. Over the expected 60 year life of a nuclear reactor, this intake pipe at the dam running to 

the unit 3 cooling process would amortized many times and save much water. 

(0017-13 [Ruth, Harry]) 

Comment: Draft SEIS -does not mention anything at all about the evaporation rate which will 

cause the water usage. Draft SEIS -simply says (5.5.2) Socioeconomic Impacts -Based on the 

individual aspects of recreational activities in the vicinity of the NAPS site, if the normal 

operating level of Lake Anna remains at 250 ft, the staff concludes that the recreational impacts 

resulting from the proposed Unit 3 would be SMALL most of the time, but could be MODERATE 

during the infrequent periods of extreme droughts. Although significantly impacted on a 

temporary basis during droughts (e.g., boating safety, usability of boathouses and property 
Appendix E 

NUREG-1917, SEIS E-60 February 2010 

values are concerns expressed by the public, based partly on experiences during droughts that 

occurred in 2001 to 2002 drought and in 2005). Lake Anna recreation does continue during 

droughts, and most of the impacts result from the lowering of lake levels by the drought itself, 

not by NAPS operations. (0017-6 [Ruth, Harry]) 

Comment: Changes in the cooling system for unit number 3 to utilize a combination of wet and 

dry cooling towers, increases the maximum water consumption rate, even further, during the 

energy conservation mode. During the maximum water conservation mode, it will still consume 

more water than with the previous once-through cooling system. (0078-4 [Cruickshank, John]) 

Response: Water consumption by the proposed Unit 3, including evaporative losses, are 

addressed in Section 5.3.2 of the SEIS. Dominion proposed a hybrid wet-dry cooling system to 

essentially eliminate thermal impacts while limiting the consumptive water use during summer 

months. The typical energy conservation operating mode of the proposed Unit 3 draws an 

estimated 22,260 gpm, while the maximum water conservation mode employs wet-dry cooling 

that draws an estimated 15,376 gpm, reducing consumptive water use by almost 7000 gpm. In 

comparison to the original once-through cooling system design, the current hybrid wet-dry 

system does consume more water. The NRC staff evaluated alternative intake structure 

designs in Chapter 9 of the draft SEIS, and concluded that the proposed intake structure 

location and design was preferable to either an inlet at another location or a submerged offshore 

intake design, because those alternatives were likely to have greater environmental impacts 

associated with construction. Prolonged water withdrawals from the hypolimnion could 

destabilize the temperature stratification in the lake, resulting in additional environmental 

impacts. No changes were made to the SEIS as a result of these comments. 

Comment: Judge Spencer's ruling on the DEQ water permit proves that Dominion has not 

been in compliance with the U.S. Clean Water Act. (0005-1 [Cruickshank, John]) 

Comment: Please note the ruling about the illegality of the 316A Variance issued to Dominion 

by the State of Virginia in late February. The 316A Variance has allowed Dominion to dump 

water without an upper temperature limit into Lake Anna since it began operations. This is not 

allowed by the Clean Water Act. A third reactor cannot be licensed to be built without first 

bringing the two operating reactors into compliance and then studying what the effects of a third 

operating reactor would have on water temperatures, especially in times of drought. 

(0010-1 [Day, Elena]) 

Comment: The North Anna Power Station is not currently in full compliance with the federal 

Clean Water Act and a third reactor will add to the problems already occurring with warm lake 

temperatures and downstream flow. (0011-2 [Abbott, Diana] [Abbott, William] [Ahlgrim, Larry] 

[Alexander, Mary] [Alexander, Mary] [Alexander, Nancy] [Allen, Connie] [Antoniewicz, Susan] 

[Appleby, Monica] [Apple, Joe] [Arens, Jordan] [Artemis, Diana] [Bailey, Marcia] [Baird, Heidi] 

[Bandita, Gypsy] [Biggs, Amy] [Bockstiegel, Dorothy] [Boissonnault, James] [Bolduc, Joan] 

[Brackett, Carl] [Bradshaw, Claude] [Brown, E] [Brummer, Ann] [Burtner, Caryl] [Burt, William] 

[Butcher, Ava] [Churray, Richard] [Clark, Diane] [Clark, Loralee] [Clark, Loralee] [Clark, Theda] 

[Cleary, Thomas] [Collingwood, Claudia] [Cook, Joe] [Cowles, Virginia] [Cummings, Russell] 
Appendix E 

February 2010 E-61 NUREG-1917, SEIS 

[Currie, Susan] [Dail, Michelle] [Daiss, Becky] [Davies, Beth] [Day, Elena] [De Trinis, Bonita] 

[Deming, Jill] [Desimone, John and Shirley] [Dickon, Elisa] [DiMarco, Paul] [D'Onofrio, Adam] 

[Dukovich, John] [Dunbar, Mary] [Ebert, Paul] [Farnham, Ross] [Fasceski, Jeffrey] [Feury, 

Patricia] [Figg, Landon] [Fiscella, Glenn] [Ford, Betty] [Franke, John] [Frank, Sarah] [Frantz, 

Norma] [Fritzler, Deb] [Gaige, Eve] [Galindo, Ted and Carolyn] [Gann, Sara] [Gignac, David] 

[Grant, Mary] [Hall-Bodie, Adrienne] [Ham, Elspeth] [Hamilton, Jim and Donna] [Hanger, Jane] 

[Hanks, Lou] [Harpole, Thane] [Hartwig, Kristina] [Heegaard, Flemming] [Heflin, Kerby] [Heim, 

Anka] [Hepburn, Chet] [Hess, David] [Hinkle, Carol] [Hodge, Mary] [Hoehlein, Jill] [Hoffman, Lilli] 

[Holtzback, Kaite] [Horwege, Richard] [Houston, Karin] [Hutchinson, Amber] [Jaronczyk, Ellen] 

[Jewell, B] [Johns, Brian] [Josaitis, Marvin] [Kalukin, Andrew] [Keyser, Liz] [Kiehl, Allison] 

[Kosch, Sandra] [Kroupa, Brenda] [Kunkel, Christopher] [Larsen, Anne] [Larsen, Janice] 

[Laverdiere, Dorothy] [LeClair, Carol] [Leon, Matea] [Light, John] [Liske, Patricia] [Lloveras, 

Lang] [Lufkin, Heather] [Maddox, Joshua] [Marroni, Edmond] [McDonald, Kim] [McFarland, Mary 

Ann] [McNeal, Ashby] [Meredith, Betty] [Meyer, Jennifer] [Miles, Linda] [Miller, Katelyn] [Miller, 

Lara] [Miller, Mary] [Mullinax, Franklin] [Neale, Laura] [Newell, Vicky] [Payne, Andrew] [Phillips, 

Donna] [Pintado, Isabel] [Plaskett, Micheline] [Plata, Errol] [Presgraves, Sandra] [Presley, 

Diann] [Rasmussen, Angela] [Reiner, Brian] [Rigby, John] [Roadcap, Leah] [Roadcap, Leah] 

[Robbins, Patricia] [Rollins, Megan] [Roth, David] [Schmidt, Arthur] [Scott, Patricia] 

[Shamaiengar, Beth] [Shelton, Charles] [Shields, Page] [Sklar, Scott] [Smith, John] [Smith, 

Louise] [Squires, George] [Steegmayer, Andrea] [Stone, Eric] [Sumrall, Kamar] [Suter, Emanuel] 

[Tanner-Sutton, Linda] [Tarr, Suzanne] [Teeler, Sharon] [Testerman, Michael] [Traub, Charles] 

[Van Lingen, Gabriele] [Wells, Cathy] [Werderman, Kim] [White, Eric] [White, Phyllis] [Whitfield, 

Doris] [Williams, Martha] [Wilson, Brian] [Wilson, Brian] [Witting, Marjorie] [Woitte, Roger]) 

Comment: Several important issues have come up which involve significant changes since the 

Draft EIS. Circuit Court ruling on compliance with Clean Water Act. (0012-2 [Rosenthal, Jerry]) 

Comment: Shouldn't the WHTF be subject to Clean Water Act and DEQ standards? It is fed 

by eight public streams and should be treated as public waters. (0023-32 [Goldsmith, Aviv]) 

Comment: North Anna Unit 3 would not meet the requirements of the US Clean Water Act. 

The Virginia Department of Environmental Quality has continually granted variances to 

Dominion's North Anna plant under Section 316 of the CWA, which allow excessive amounts of 

thermal pollution to be discharged into waters of the United States (0024-5 [Zeller, Lou]) 

Comment: However, a recent court decision remanded NPDES water discharge permit for the 

North Anna plant (Units 1 and 2) to the State Water Control Board [Court Ruling of February 20, 

2009, Transcript, BREDL et al v. Commonwealthof Virginia ex rel, Circuit Court in the City of 

Richmond, Case No.CL070006083-00]. The judge stated: The federal definition excludes 

cooling ponds from that exemption...the Court will rule that the exemption does not apply here 

because Lake Anna's hot and cold side would be a cooling lake. 

The SEIS does not address this issue. Unit 3, if licensed, would become part of the North Anna 

Power Station. This modification of the plant appears to require environmental reporting under 

10CFR51.53. Relevant sections require Clean Water Act 316 (a) and 316 (b) determinations. 
Appendix E 

NUREG-1917, SEIS E-62 February 2010 

For example: (D) If the applicant's plant is located at an inland site and utilizes cooling ponds, 

an assessment of the impact of the proposed action on groundwater quality must be provided. 

Further, 40 CFR 125.94 requires the EPA to determine the best technology available for 

Phase II electric generating plants, allowing demonstrations of compliance to be done for safety 

requirements at nuclear facilities "based on consultation with the NRC." The draft SEIS does 

not address these issues. (0024-6 [Zeller, Lou]) 

Comment: I believe we all have a stake in safeguarding our waters. Lake Anna is recognized 

as surface waters of the United States. And it is, therefore, to be protected by the Clean Water 

Act. It has not been protected as Dominion regards portions of the lake to be its private waste 

heat treatment facility. And, of course, the State of Virginia to date remains in non-compliance 

with the Federal Clean Water Act, when it awards Dominion the 316 variance, which allows it to 

dump water without an upper temperature limit, into Lake Anna. (0073-59 [Day, Elena]) 

Comment: North Anna Power Station is not currently in full compliance with the Federal Clean 

Water Act. And a third reactor will add to the problems already occurring with lake temperatures, 

and downstream flow. (0078-2 [Cruickshank, John]) 

Response: The NRC staff is aware that on February 20, 2009, the Richmond Circuit Court 

remanded back to the Virginia State Water Control Board the decision to issue a NPDES permit 

for the Units 1 and 2 WHTF into Lake Anna. Units 1 and 2 employ a once-through cooling 

system that would normally require a 316(a) variance to allow continued discharge to surface 

waters. The proposed Unit 3 would employ a closed-cycle cooling system and therefore it 

would not require a 316(a) variance. The remanded NPDES permit is an issue related to the 

continued operation of Units 1 and 2. Appendix L of the SEIS lists the permits and 

authorizations that will be required before the proposed Unit 3 can operate. Prior to operation, 

the proposed Unit 3 would be required to have a NPDES permit from VDEQ that would include 

water quality parameter limits that are presumed to be protective of human health and the 

environment. 

Comment: We [USACE] recommend you submit the following information so we may conduct 

a public interest review: the complete proposed plan of development with a depiction of all work 

that is subject to regulation under Section 404 of the Clean Water Act (i.e., intake and outfalls 

structures within jurisdictional waters and/or wetlands). (0009-2 [Bronson, Regena]) 

Comment: We [USACE] recommend you submit the following information so we may conduct 

a public interest review: evidence that discharges of dredged or fill material into waters of the 

United States are avoided or minimized to the maximum extent practicable at the project site. 

(0009-4 [Bronson, Regena]) 

Comment: We [USACE] recommend you submit the following information so we may conduct 

a public interest review: a compensatory mitigation plan that addresses the loss of wetlands 

and streams impacts by the proposed project. (0009-5 [Bronson, Regena]) 
Appendix E 

February 2010 E-63 NUREG-1917, SEIS 

Response: These comments refer to information requested of the applicant by the USACE to 

facilitate their public interest review under Section 404 of the Clean Water Act. No changes 

were made to the SEIS as a result of these comments. 

Comment: We recommend conducting any in-stream activities during low or no-flow 

conditions, using non-erodible cofferdams to isolate the construction area, blocking no more 

than 50% of the stream flow at any given time, stockpiling excavated material in a manner that 

prevents reentry into the stream, restoring original streambed and stream bank contours, 

revegetating barren areas with native vegetation, and implementing strict erosion and sediment 

control measures. Due to future maintenance costs associated with culverts, and the loss of 

riparian and aquatic habitat, we prefer stream crossings to be constructed via clear-span 

bridges. (0070-6 [Ewing, Amy]) 

Response: This comment is a specific recommendation by the VDGIF. Mitigation measures 

relevant to the impacts of construction and operation of the proposed Unit 3 are addressed in 

Chapters 4, 5, and 10 of the final SEIS. Appendix L lists the relevant permits required by the 

Commonwealth of Virginia and USACE prior to any activities involving dredging, filling, or 

discharge of pollutants into any surface water.

Comment: DGIF. Upon review of the Early Site Permit and associated federal consistency 

certification for the proposed addition of a third reactor at North Anna Power Station, DGIF 

expressed concerns about the operation of the third reactor and the reservoir as they relate to 

maintenance of downstream flows in the North Anna and Pamunkey rivers. To address agency 

concerns, DGIF and other state resource agencies recommended that Dominion perform an 

Instream Flow Incremental Methodology study in the North Anna River below the Lake Anna 

dam and in downstream waters of the Pamunkey River. DGIF worked closely with Dominion 

and the permitting agencies on the design of the study and the analysis of the results. As stated 

in the SEIS, the primary goal of the IFIM is to determine whether possible changes in dam 

releases resulting from the operation of the third reactor are likely to adversely impact aquatic 

resources below the dam. 

The IFIM is complete and DGIF is currently working with Dominion, the permitting agencies, and 

other natural resource agencies to finalize the results and develop operating rules for the 

proposed third reactor (including reservoir management procedures) that reduce the frequency 

of dam releases below 40 cubic feet per second (cfs), thereby protecting downstream aquatic 

resources. (0069-16 [Irons, Ellie]) 

Comment: According to the DEQ Office of Surface and Ground Water Supply Planning 

(OSGSP), DEQ, DGIF, DCR and Dominion have been working on the IFIM study that was 

required as result of the state's conditional Coastal Zone Management Act (CZMA) certification 

for the Early Site Permit. Based on the study, Dominion proposed a set of rules for operating the 
Appendix E 

NUREG-1917, SEIS E-64 February 2010 

reservoir and the cooling system of Unit 3 that would mitigate the impact of the new unit on 

water resources. In summary, the proposal involves: 

• raising the normal level of the lake by three inches 

• releasing a minimum flow of 40 cubic feet per second (cfs) whenever the lake is above 

248 feet 

• releasing a minimum flow of 20 cfs whenever the lake is less than 248 feet 

• operating in maximum water conservation mode whenever the lake is below 250 feet 

• making a targeted recreation release of 177 cfs in June and July if the lake is above 

250 feet. 

(0069-17 [Irons, Ellie]) 

Comment: The North Anna River is a highly altered system with the minimum release of 

40 cfs becoming the typical flow for most of the summer and fall. The historic minimum flow of 

40 cfs and the lack of turbidity in the release produced a fairly good sports fishery in the river 

below the dam. The weighted useable area graphs produced by the instream flow study were 

very important in forming preliminary recommendations for operating the project. These curves 

show sharply falling habitat as flow declines below 100 cfs for several important species. The 

state agencies do not support an increased frequency or duration of flows below 40 cfs, if 

avoidable, because of the precipitous decline in habitat that occurs as flow falls below these 

levels. 

With the three inch rise, and the early activation of dry cooling, the additional occurrences of 

releases of below 40 cfs will be limited. Dominion presented information to the agencies on 

December 15, 2008 that estimated that the amount of time that flows would be less than 40 cfs 

would be 5.5% of the time, an increase from 5.2% of the time with the present two units. 

OSGSP believes that this is a small change. 

Dominion's preliminary proposal for minimum releases is nearly identical with the proposal 

analyzed by NRC in the ESP EIS (i.e. 40 or 20 CFS depending on whether the lake was above 

or below 248 feet). The NRC concludes, in the SEIS and in the previous EIS for the ESP, that 

Unit 3 would have small or moderate impacts on lake levels and downstream flows. 

3(b) Findings. The draft SEIS does not factor in the effect of a potential three inch rise in normal 

lake storage. This mitigating measure will further reduce the impacts of Unit 3 on lake levels 

and downstream flow. (0069-20 [Irons, Ellie]) 

Response: These comments are statements by VDGIF and VDEQ regarding Lake Anna. 

Chapter 5 of the SEIS was modified to include discussion of the IFIM study results. 
Appendix E 

February 2010 E-65 NUREG-1917, SEIS 

Comment: As part of the Early Site Permit, Dominion was required to conduct an Instream 

Flow Incremental Methodology (IFIM) study to determine the impacts of the proposed third 

reactor on the North Anna River below the Lake Anna Dam. Dominion has not yet finished that 

study and, by its own admission, the NRC will have to study the results of that study and 

analyze those impacts prior to releasing a final Supplemental Impact Study. It makes no sense 

that the NRC released this draft now rather than waiting for the IFIM study which is expected 

very soon. This Draft will have to be amended and a new public hearing scheduled. This 

compounds the waste of taxpayers' money. (0003-3 [Crawford, Barbara]) 

Comment: Both VDEQ and DGIF, in conjunction with Dominion Resources are currently 

conducting an In stream Flow Incremental Methodology (IFIM) study on Lake Anna and the 

North Anna River and Pamunkey Rivers downstream to determine the effects of the reduced 

water flow on recreation, wildlife, aquatic life and fish as part of the conditional certification for 

the 3 reactor Early Site Permit (ESP) (0017-9 [Ruth, Harry]) 

Comment: The NRC needs to weigh in on the results of the IFIM study and any modification of 

the VPDES permit before any COL is issued. Flows into the cooling lagoons (Elk Creek and Mill 

Pond) and reservoir are not gauged even at the four major inputs on the reservoir (North Anna 

River, Pamunkey Creek, Terrys Run, and Contrary Creek). Flows over the dam, water level 

changes, any introduced wetlands and FERC requirements for any increased normal pool level 

need to be addressed by the NRC in the SEIS for the COL. (0018-3 [Remmers, Ken]) 

Comment: 

1. State input to the NRC Process will be in the form of 13 listed permits required before 

Unit 3 can be constructed as outlined in Appendix L of the DSEIS. NRC has deferred to 

the State on these items. Except the NRC has included a Conditional Consistency 

determination in the Coastal Zone Management Act for the completion of an IFIM study 

to be performed and results implemented in State permitting before any COL is issued. 

To date the public has not seen the results of this study nor have they been involved in 

the process. VDEQ has promised such public participation and a Stakeholders meeting 

to discuss the IFIM study and its implementation on Lake Anna as well as the discharges 

for downstream users. We are putting VDEQ on notice that the LACA Water Quality 

committee strongly requestswith the full support of the Combined Lake Level Task Force 

that any VPDES and WPP include mitigation effects for Unit 3. These mitigations 

include: 

a. Seasonal increase in the normal pool level of the lake by 3 inches. 

b. Variation in the graduated discharge at the dam during severe droughts. 

c. Better flow management of dam releases to adhere to defined discharge rates 

including electronic lake gage height readings which are put on the web similar to the 

discharge canal temperature readings. 

d. An assessment repot of the recreational, aquatic, and baseline environmental data, 

and the impacts of any proposed change to the lake and downstream. Public 

comments shall be obtained and a public meeting held: (1) prior to the determination 
Appendix E 

NUREG-1917, SEIS E-66 February 2010 

of the scope of the assessment and (2) prior to the finalization of the assessment. 

The assessment shall be considered by the Board in its determination of conditions 

on the issue of any permit. 

(0018-7 [Remmers, Ken]) 

Comment: Reviewers indicated that the draft SEIS did not address the Instream Flow 

Incremental Methodology study conducted by Dominion in cooperation with state natural 

resource agencies, including a discussion of the proposed operating rules developed from the 

study, particularly with respect to the effect of the potential three inch rise in normal lake 

storage. (0069-1 [Irons, Ellie]) 

Comment: Next the IFIM and VPDES permit. The NRC needs to weigh in on the results of the 

IFIM study, and any modifications to the VPDES permit, such a discharge permit, before any 

COL is issued. (0073-35 [Remmers, Ken]) 

Comment: These actions [proposed changes Unit 3 operating rules] will increase the 

availability of water for everyone during times of low rainfall. The mitigation actions are: One, 

increase the standard level of the pool from 250 feet, to 250 feet three inches. That doesn't 

sound like much, but that means there will be an additional 140 million cubic feet of water 

available when there is low rainfall. 

Second, reduce the fall of the lake from 40 cubic feet per second, to 20 cubic feet per second, 

as soon as it falls below 250 feet. This will conserve the water in the lake, without seriously 

affecting downstream users. 

They have already experienced the lower level of outflow, and this way they will all have more 

water to use. (0080-8 [Murphy, Bill]) 

Response: The Commonwealth of Virginia required Dominion to conduct a comprehensive 

IFIM study as part of their Coastal Zone Management Act consistency determination. The NRC 

included in its ESP a requirement that the IFIM study be completed prior to issuance of a COL 

for the proposed Unit 3. The results of the IFIM study were not available at the time the draft 

SEIS was published; however, the final IFIM report was published in October 2009, and the 

results are included in Section 2.7.2.4 and Chapter 5 of the final SEIS. The IFIM study 

addressed impacts on lake levels and downstream flows under different reservoir operating 

scenarios during proposed Unit 3 operations, compared to the existing (Unit 1 and 2) reservoir 

operating condition. One of the scenarios included increasing the Lake Anna normal pool 

elevation by 0.08 m (0.25 ft) to 76.3 m (250.25 ft). Reservoir management, water use, and 

downstream instream flow requirements remain within the authority of the Commonwealth of 

Virginia. 

Comment: I have been told the hybrid cooling tower will include both wet and dry cooling 

features, designed to minimize impact on the level of the lake. Dominion, I know, plans to utilize 

one of two wet or dry modes to cool the stream used in the production of electricity from unit 3. 
Appendix E 

February 2010 E-67 NUREG-1917, SEIS 

The energy conservation mode will be implemented when the elevation of the lake is full, or that 

is about 250 feet above sea level. And this cooling mode would also be used up to seven days 

after the lake level declines below 250 feet. (0073-18 [Mullen, Dale]) 

Comment: Dominion responded to initial concerns expressed about lake effect on Lake Anna, 

and has pioneered plans to use a hybrid wet and dry cooling tower for the new reactor. It is my 

belief, based on my conversations with Dominion staff, that this will mitigate water level, and 

water temperature concerns. (0073-19 [Mullen, Dale]) 

Comment: Dominion has agreed to build a hybrid wet-dry cooling tower, instead of using the 

once-through cooling from Lake Anna. And this change will ensure no additional heat level will 

be placed on Lake Anna. (0075-25 [Beament, Pete]) 

Comment: The hybrid cooling tower is a state of the art design that allows it to operate 

differently depending on whether the greatest need is to conserve energy, or to conserve water. 

If the lake level is below 250 feet above sea level, for more than seven days, the unit would 

switch to maximum water conservation mode. During a normal hot Virginia summer that would 

mean lake level would drop maybe an inch every 21 days. During a typical drought, when lake 

level is below 240 feet, and unit 3 is operating, the lake would be expected to drop less than an 

additional six inches. And temperature-wise unit 3 will have such a small impact that we, as 

users of the lake, won't notice it. Under normal conditions the increase in temperature would be 

about one-tenth of one degree fahrenheit. And during extended droughts the impact would be a 

maximum of three-tenths of a degree. (0075-42 [Stiles, Lisa]) 

Comment: Normally Dominion is required, by law, to maintain a flow of 40 cubic feet per 

second. In times of prolonged drought, when the lake level drops below 248 feet, they must 

maintain 20 cubic feet per second. With the hybrid cooling system, if we were to experience 

prolonged dry weather, such as the rare 80 year drought, the third unit might cause the amount 

of time that flow would be reduced, to 20 cubic feet per second, to increase by about 2 percent. 

(0075-44 [Stiles, Lisa]) 

Response: These comments describe aspects of the proposed Unit 3 circulating water system 

that were designed to reduce environmental impacts. They do not include any new and 

significant information. Therefore, no changes were made to the SEIS. 

Comment: I have also heard concerns about downstream flow. Before Dominion built the dam 

to support four units, the North Anna River, as my colleague Mike Stewart once put it very well, 

was a nearly dry creek bed virtually devoid of life. Downstream flows were erratic. Either the 

area was flooded, or it was completely dry. Since nuclear came to Louisa County, downstream 

flow has vastly improved, and the average flow over the dam is about 270 cubic feet per 

second. (0075-43 [Stiles, Lisa]) 

Response: This comment expresses general support for the operation of Lake Anna. It 

provides no new and significant information. Therefore, no changes were made to the SEIS as 

a result of this comment. 
Appendix E 

NUREG-1917, SEIS E-68 February 2010 

Comment: As described in Section 5.3, addition of operations at the proposed Unit 3 would 

change the frequency of depth of low water levels created by droughts, but not by enough to 

change the overall conclusion reported in the ESP ESI that adverse impacts on recreation 

would be temporary and MODERATE. Therefore, mitigation is not warranted. 

(0017-7 [Ruth, Harry]) 

Comment: Water Use Impacts, of the SEIS concludes that the NRC staff did not identify 

information that was both new and significant to operation related impacts and concludes that 

water use impacts would remain SMALL in normal years and MODERATE in drought years. 

Hence no mitigation of low water impacts are required. LACA is extremely disappointed in this 

finding and disagrees with the recommendation. Low water levels on Lake Anna expose safety 

hazards to the thousands of recreational users of the Lake, create increased erosion along the 

entire shoreline, and damage wetlands and other aquatic life. Anything that causes significant 

lowering of water levels during the perennially dry summer months which are also peak 

recreation months is not a small thing. (0019-1 [Smith, Doug]) 

Comment: The report on the LACA survey was completed in December of 2008. The report 

and supporting data in summary form are submitted with this statement. LACA believes this is 

new and significant data that reveals real information about the impact of low water levels on 

Lake Anna. We ask that the NRC review the data and reconsider their finding that mitigation of 

impact of low water levels should not be required before placing the third reactor in operation. 

Mitigation efforts are readily available. Actions such as a seasonal increase in standard pool 

level of the lake and improved management of flows over the dam can fully mitigate the water 

level impact of the third reactor and should be implemented before placing the reactor into 

operation. (0019-3 [Smith, Doug]) 

Comment: These mitigation include: Seasonal increase in the normal pool level of the lake, 

which we have talked about for a long time; variation of the graduated discharge at the dam 

during severe draughts; better flow management of the dam releases to adhere with the fine 

discharges rates including an electronic lake gauge height readings, which would be put on the 

web, similar to the discharge canal temperature readings. An assessment, report of the 

recreational, aquatic, and baseline environmental data, and the impacts of any proposed 

changes to the lake and downstream. (0073-44 [Remmers, Ken]) 

Comment: First is the consumption, by evaporation, of millions of gallons of water per day, in 

the critical summer months. We know the third unit will drop levels 3, 6, 9 inches, depending on 

the weather in that year. Section 5.3.2 of the SEIS' water use impacts, concludes that water 

use impacts would remain small in normal years, and moderate in drought years, hence no 

mitigation of low water impacts is required. LACA is extremely disappointed in this finding. 

(0073-47 [Smith, Doug]) 

Comment: Actions such as seasonal increase in the standard pool of the lake, and improved 

management of water flows over the dam, could fully mitigate the impact of the third unit. We 

believe that the NRC's review of the environmental impact should have concluded that some 

mitigation is desirable, if not required. (0073-54) 
Appendix E 

February 2010 E-69 NUREG-1917, SEIS 

Comment: And yet in the absence of any data, at all, on the impact of lowered water levels, the 

NRC has concluded that impact is small, except in a drought, and then it is moderate. 

(0073-54 [Smith, Doug]) 

Comment: My concern is about the lake level, and my concern is that the impact statement 

doesn't include certain mitigation activities that could be taken which were, really, quite 

reasonable. (0080-6 [Murphy, Bill]) 

Comment: We believe, I believe that the water management actions should be implemented to 

conserve the amount of water flowing into the lake, for responsible use, and to conserve the 

lake as a water resource. (0080-7 [Murphy, Bill]) 

Response: While Section 5.3.2 of the draft SEIS does conclude that water-use impacts would 

remain SMALL in normal years and MODERATE in drought years, it does not conclude that 

mitigation is not required. The Commonwealth of Virginia required Dominion to conduct a 

comprehensive IFIM study as part of their Coastal Zone Management Act consistency 

determination. The NRC included in its ESP a requirement that the IFIM study be completed 

prior to issuance of a COL for the proposed Unit 3. The IFIM study components included 

downstream habitat for fish and other organisms, recreation on the North Anna and Pamunkey 

Rivers, wetlands around the shore of Lake Anna, and Lake Anna boat ramps and docks. 

The results of the IFIM study were not available at the time the draft SEIS was published; 

however, the final IFIM report was published in October 2009, and the results are included in 

Section 2.7.2.4 and Chapter 5 of the final SEIS. The IFIM study addressed impacts on lake 

levels and downstream flows under different reservoir operating scenarios during proposed 

Unit 3 operations, compared to the existing (Unit 1 and 2) reservoir operating condition. One of 

the scenarios included increasing the Lake Anna normal pool elevation by 0.08 m (0.25 ft) to 

76.3 m (250.25 ft). Reservoir management, water use, and downstream instream flow 

requirements remain within the authority of the Commonwealth of Virginia.

Comment: Section 5.3 mentions that water level changes will be heightened during the period 

July-September. Since this coincides with increased summer recreational use of the lake, even 

minor changes could have MODERATE or HIGH impacts. (0023-27 [Goldsmith, Aviv]) 

Comment: The SDEIS concluded on page 5-31, line 18 that "consumptive water losses may 

noticeably impact lake levels and downstream flows". This is a major area of local concern and 

should be more thoroughly analyzed and documented. It is hard to understand how an impact 

assessment of SMALL is derived from the discussion. It seems like the impacts are at least 

MODERATE and potentially LARGE. (0023-35 [Goldsmith, Aviv]) 

Response: These comments refer to draft ESP EIS (NRC 2006b) published in July 2006. 

Comments received on the draft ESP EIS were considered in the final ESP EIS (NRC 2006a), 

which was published in December 2006. In the ESP EIS, the NRC staff concluded that water 

use impacts would be SMALL in most years but could be MODERATE in drought years. The 

Commonwealth of Virginia required Dominion to conduct a comprehensive IFIM study as part of 
Appendix E 

NUREG-1917, SEIS E-70 February 2010 

their Coastal Zone Management Act consistency determination. The NRC included in its ESP a 

requirement that the IFIM study be completed prior to issuance of a COL for the proposed 

Unit 3. The IFIM study components included downstream habitat for fish and other organisms, 

recreation on the North Anna and Pamunkey Rivers, wetlands around the shore of Lake Anna, 

and Lake Anna boat ramps and docks. The results of the IFIM study were not available at the 

time the draft SEIS was published; however, the final IFIM report was published in October 

2009, and the results are included in Section 2.7.2.4 and Chapter 5 of the final SEIS. The IFIM 

study addressed impacts on lake levels and downstream flows under different reservoir 

operating scenarios during proposed Unit 3 operations, compared to the existing (Unit 1 and 2) 

reservoir operating condition. One of the scenarios included increasing the Lake Anna normal 

pool elevation by 0.08 m (0.25 ft) to 76.3 m (250.25 ft). Reservoir management, water use, and 

downstream instream flow requirements remain within the authority of the Commonwealth of 

Virginia. 

Comment: Coordinate with DEQ-NRO regarding the Virginia Pollutant Discharge Elimination 

System permit that will be required for the proposed discharges to Lake Anna. 

(0069-12 [Irons, Ellie]) 

Comment: 2(b) Agency Comments. VMRC did not respond to our request for comments on the 

SEIS. However, in previous responses to the ESP EIS (DEQ #06-125F) and federal 

consistency certification (DEQ #05-079F) VMRC asserted that the agency's permit jurisdiction 

would extend to the portions of the project which result in direct impacts and encroachment to 

the historic stream channel of the North Anna River (Ellis/Madden, 8/31/06). 

(0069-15 [Irons, Ellie]) 

Comment: Erosion and Sediment Control and Stormwater Management. According to the 

SEIS (page 4-25. 4.10), measures and controls to limit adverse impacts during construction, 

including erosion and sediment control, were addressed in Section 4.10 of the ESP EIS (NRC 

2006). These measures and controls have been incorporated into the Environmental Protection 

Plan (EPP) for the site that is included as Appendix 1A of the COL ER (Dominion 2007a). 

Similarly, stormwater management is incorporated in the EPP. (0069-32 [Irons, Ellie]) 

Comment: DEQ agrees with the technical discussions in the SEIS and has no technical or 

regulatory reasons to suggest that a modification could not proceed. (0069-7 [Irons, Ellie]) 

Response: These comments are declarative statements by the VDEQ and raise no new issues 

with the conclusions of the SEIS. No changes were made to the SEIS as a result of these 

comments. 

Comment: Lake Anna has been a benefit to the region for surface water storage, recreation, 

conservation and wildlife (0020-2 [Aylor, Joseph]) 

Response: This comment is a statement about the benefits of Lake Anna, but it raises no issue 

with the conclusions of the SEIS. No change was made to the SEIS as a result of this 

comment. 
Appendix E 

February 2010 E-71 NUREG-1917, SEIS 

Comment: I'm very concerned about clean drinking water, and I don't want anything built that 

might jeopardize water (0041-1 [Bailey, Marcia]) 

Comment: If a license or okay is granted, let's make sure water quality is not compromised. 

(0061-2 [Ahlgrim, Larry]) 

Comment: Water quality issues are also a concern. The revised cooling system for unit 3 

includes a wet cooling tower, from which blow-down would be discharged into Lake Anna. The 

SDEIS states that makeup water for that tower would be treated with biocides anti-scalons, and 

dispersions. (0078-5 [Cruickshank, John]) 

Response: Water quality impacts related to the operation of the proposed Unit 3, including 

plant discharges, are addressed in Section 5.3.3 of the SEIS. Pursuant to the Clean Water Act, 

the U.S. EPA is responsible for protecting the Nation’s water quality. In Virginia, the U.S. EPA 

has delegated this responsibility to the VDEQ. Prior to operation, the proposed Unit 3 would be 

required to have a VPDES permit from VDEQ that would include water quality parameter limits. 

Water quality limits are presumed to be protective of human health and the environment. No 

change was made to the SEIS as a result of these comments. 

Comment: This IFIM study and Reactor Type should be completed before any Draft 

Supplemental Environmental Impact Statement for the COL is issued by the NRC so all the 

results of the IFIM study and impacts of the reactor type can be reviewed and commented on by 

the public. Otherwise the results from this important study will cause much re-work later by the 

NRC, Virginia and the public and waste much time. Currently there is no public participation in 

the study plan or results. (0017-10 [Ruth, Harry]) 

Comment: NRC has deferred to the State on these items, except the NRC has included a 

conditional consistency determination in the Coastal Zone Management Act, for the completion 

of an IFIM study to be performed and the results implemented in the State permitting before a 

COL is issued. To date the public has not seen the results of the study, nor have they been 

involved in the process. DEQ has promised such public participation in a stakeholders meeting 

to discuss IFIM and its implementation on the lake, as well as the discharges for downstream 

users. (0073-42 [Remmers, Ken]) 

Response: This comment refers to several aspects of the NRC’s COL environmental review 

process. The COL application before the NRC is for one Economic Simplified Boiling Water 

Reactor (ESBWR) Unit at the NAPS site. The NRC staff acknowledges that there has been 

speculation that the reactor type may change. Unless notified by the applicant that there is a 

change in design, the staff will continue the environmental review using the ESBWR design. 

The results of the IFIM study were not available at the time the draft SEIS was published, but 

they are included in Chapters 2 and 5 of this SEIS. Several commentors expressed concerns 

regarding public participation in the IFIM study. In an April 9, 2009 e-mail from Mr. David 

Paylor, director of VDEQ, stakeholder concerns appear to have been acted upon by the parties 

involved in conducting the study, and a stakeholder meeting was not needed at that time 

(Accession No. ML091000099). 
Appendix E 

NUREG-1917, SEIS E-72 February 2010 

Comment: DSEIS [Sec 3.2.2] implies that MWC mode will be initiated when the lake level 

drops below 250 ft. msl for a period of seven or more days. The period of seven days was 

utilized for analysis, but no commitment to use this period as the basis for switching from EC to 

MWC mode has been made in the COLA-ER. The operating parameters for switching from EC 

to MWC mode will be established in coordination with State agencies at the time of permitting. 

(0084-18 [Grechek, Eugene]) 

Comment: The DSEIS [Sec 3.2.2.2] statement as written misstates the operation and 

capability of the dry towers. The first sentence suggests that the dry tower will always be in 

operation. The third sentence as stated is not entirely accurate because at design ambient 

conditions the dry towers have the capacity to remove one-third of the heat load. A "majority" of 

dry cooling wouldn't be reached until the dry bulb temperature (DBT) reaches a certain level. 

Dominion suggests that the statement be reworded to state, "Dry tower operation depends on 

the availability of water from Lake Anna. If lake level is at or above 250 ft. msl, Unit 3 would be 

cooled entirely using the wet towers. During a dry weather period when lake level is below 

250 ft. msl for a specified time, a minimum of one third of the Unit 3 waste heat would be 

dissipated by the dry towers, increasing with decreasing DBT." (0084-19 [Grechek, Eugene]) 

Comment: The DSEIS [Secs 3.2.2.2, 4.3.1, 4.4.2, and 5.4.2.1] implies that the intake design 

has been finalized, but Dominion's response to RAI ER 3.4-1 was intended to provide NRC staff 

a conceptual layout of the Unit 3 intake. The final dimensions of the intake as well as the box 

culverts are subject to change to accommodate actual equipment size as indicated in the 

response to RAI ER 3.4-1. An equivalent flow area would be maintained. 

(0084-20 Grechek, Eugene]) 

Response: The comments were noted; appropriate sections of the SEIS were revised to reflect 

these comments. 

Comment: We also want to ensure that the impacts of all environmental issues, primarily with 

the cooling method proposed for the third reactor that will use up to 24 million gallons a day of 

Lake Anna water; will cause the water to heat faster during summer times of peak electricity 

demand and double the drought cycle from an average of 21 to 40 days per year are fully 

mitigated. Also putting new sewage effluent and chemicals into the heated lake must be fully 

evaluated. All of the impacts of lower water levels, hotter water and new sewage effluent to 

Lake Anna and surrounding infrastructure must be successfully mitigated with public 

participation prior to the issuance of and finalization of the COL Environmental Impact 

Statement. (0017-2 [Ruth, Harry]) 

Response: Water consumption by the proposed Unit 3, including evaporative losses, are 

addressed in Section 5.3.2 of the SEIS. Dominion proposed a hybrid wet-dry cooling system to 

essentially eliminate thermal impacts while limiting the consumptive water use during summer 

months. Unit 3 discharges as well as sanitary treatment plant effluent will be regulated by 

VDEQ under the conditions of a VPDES permit. Reservoir management, water use, water 

quality, and downstream instream flow requirements fall within the regulatory authority of the 

Commonwealth of Virginia. 
Appendix E 

February 2010 E-73 NUREG-1917, SEIS 

6. Comments Concerning Hydrology – Groundwater 

Comment: VDH-ODW states that there are four groundwater wells within one mile of the 

project site. The North Anna Power Plant operates wells 4, 6, 7 and the Information Center 

well. Impact to these wells may occur as a result of construction. There are no surface water 

intakes within a five-mile radius of the site. 1 1(c) Recommendation. VDH-ODW recommends 

that the NAPS waterworks system operator be notified prior to any ground disturbance or 

changes in discharge patterns at the facility. Contact Barry Matthews, VDH at (804) 864-7515 

for additional information. (0069-47 [Irons, Ellie]) 

Response: This comment is a specific recommendation to the applicant by the Virginia 

Department of Health, Office of Drinking Water. No change was made to the SEIS as a result of 

this comment. 

7. Comments Concerning Ecology – Terrestrial 

Comment: Existing wetlands, streams, and woodlands on the site may be adversely affected 

by the construction and operation of a new reactor. (0011-3 [Abbott, Diana] [Abbott, William] 

[Ahlgrim, Larry] [Alexander, Mary] [Alexander, Mary] [Alexander, Nancy] [Allen, Connie] 

[Antoniewicz, Susan] [Appleby, Monica] [Apple, Joe] [Arens, Jordan] [Artemis, Diana] [Bailey, 

Marcia] [Baird, Heidi] [Bandita, Gypsy] [Biggs, Amy] [Bockstiegel, Dorothy] [Boissonnault, 

James] [Bolduc, Joan] [Brackett, Carl] [Bradshaw, Claude] [Brown, E] [Brummer, Ann] [Burtner, 

Caryl] [Burt, William] [Butcher, Ava] [Churray, Richard] [Clark, Diane] [Clark, Loralee] [Clark, 

Loralee] [Clark, Theda] [Cleary, Thomas] [Collingwood, Claudia] [Cook, Joe] [Cowles, Virginia] 

[Cummings, Russell] [Currie, Susan] [Dail, Michelle] [Daiss, Becky] [Davies, Beth] [Day, Elena] 

[De Trinis, Bonita] [Deming, Jill] [Desimone, John and Shirley] [Dickon, Elisa] [DiMarco, Paul] 

[D'Onofrio, Adam] [Dukovich, John] [Dunbar, Mary] [Ebert, Paul] [Farnham, Ross] [Fasceski, 

Jeffrey] [Feury, Patricia] [Figg, Landon] [Fiscella, Glenn] [Ford, Betty] [Franke, John] [Frank, 

Sarah] [Frantz, Norma] [Fritzler, Deb] [Gaige, Eve] [Galindo, Ted and Carolyn] [Gann, Sara] 

[Gignac, David] [Grant, Mary] [Hall-Bodie, Adrienne] [Ham, Elspeth] [Hamilton, Jim and Donna] 

[Hanger, Jane] [Hanks, Lou] [Harpole, Thane] [Hartwig, Kristina] [Heegaard, Flemming] [Heflin, 

Kerby] [Heim, Anka] [Hepburn, Chet] [Hess, David] [Hinkle, Carol] [Hodge, Mary] [Hoehlein, Jill] 

[Hoffman, Lilli] [Holtzback, Kaite] [Horwege, Richard] [Houston, Karin] [Hutchinson, Amber] 

[Jaronczyk, Ellen] [Jewell, B] [Johns, Brian] [Josaitis, Marvin] [Kalukin, Andrew] [Keyser, Liz] 

[Kiehl, Allison] [Kosch, Sandra] [Kroupa, Brenda] [Kunkel, Christopher] [Larsen, Anne] [Larsen, 

Janice] [Laverdiere, Dorothy] [LeClair, Carol] [Leon, Matea] [Light, John] [Liske, Patricia] 

[Lloveras, Lang] [Lufkin, Heather] [Maddox, Joshua] [Marroni, Edmond] [McDonald, Kim] 

[McFarland, Mary Ann] [McNeal, Ashby] [Meredith, Betty] [Meyer, Jennifer] [Miles, Linda] [Miller, 

Katelyn] [Miller, Lara] [Miller, Mary] [Mullinax, Franklin] [Neale, Laura] [Newell, Vicky] [Payne, 

Andrew] [Phillips, Donna] [Pintado, Isabel] [Plaskett, Micheline] [Plata, Errol] [Presgraves, 

Sandra] [Presley, Diann] [Rasmussen, Angela] [Reiner, Brian] [Rigby, John] [Roadcap, Leah] 

[Roadcap, Leah] [Robbins, Patricia] [Rollins, Megan] [Roth, David] [Schmidt, Arthur] [Scott, 

Patricia] [Shamaiengar, Beth] [Shelton, Charles] [Shields, Page] [Sklar, Scott] [Smith, John] 

[Smith, Louise] [Squires, George] [Steegmayer, Andrea] [Stone, Eric] [Sumrall, Kamar] [Suter, 

Emanuel] [Tanner-Sutton, Linda] [Tarr, Suzanne] [Teeler, Sharon] [Testerman, Michael] [Traub, 
Appendix E 

NUREG-1917, SEIS E-74 February 2010 

Charles] [Van Lingen, Gabriele] [Wells, Cathy] [Werderman, Kim] [White, Eric] [White, Phyllis] 

[Whitfield, Doris] [Williams, Martha] [Wilson, Brian] [Wilson, Brian] [Witting, Marjorie] [Woitte, 

Roger]) 

Comment: Wetlands are another area of concern. Existing wetlands, streams, and woodlands, 

on the North Anna Power Station site, may be adversely affected by construction activities for 

unit number 3, and possibly by potential increases in the maximum lake level, and decreases in 

the minimum lake level. (0078-10 [Cruickshank, John]) 

Response: Wetlands, streams, and woodlands on the NAPS site are described in Section 2.7 

of the SEIS. Construction impacts to these resources are discussed in Section 4.4.1 of the 

SEIS. Operational impacts to wetlands, including potential changes in the lake level are 

discussed in Section 5.4.1 of the SEIS. The comments provide no new and significant 

information. Therefore, no changes were made to the SEIS. 

Comment: Does the feeding range of bald eagles or loggerhead strikes extend to the North 

Anna vicinity (Page 2-13 line 32)? (0023-19 [Goldsmith, Aviv]) 

Response: The distribution of the bald eagle and loggerhead shrike in the vicinity of the NAPS 

site was addressed in Section 2.7.1 of the SEIS. The NAPS site is within the feeding range of 

these two species. This comment provides no new and significant information. Therefore, no 

changes were made to the SEIS. 

Comment: According to DGIF records, listed wildlife resources under DGIF's jurisdiction are 

not documented from the site proposed for placement of the third reactor. Therefore, impacts 

upon listed wildlife resources are not likely to result from site preparation or construction of the 

third reactor. (0069-24 [Irons, Ellie]) 

Comment: DGIF reviewed the proposed corridor for the additional 500kV line required to carry 

the output of the existing Lake Anna units and the proposed third unit. DGIF does not currently 

document any listed wildlife or resources under its jurisdiction from the project area. Therefore, 

impacts upon such species and resources are not likely to result from the construction of this 

line. In addition, as this new line will be co-located within an existing power line corridor, it does 

not appear that significant wildlife habitat alterations will occur. (0069-25 [Irons, Ellie]) 

Comment: DCR-DNH searched its Biotics Data System for occurrences of natural heritage 

resources from the project site. Biotics historically documents the presence of natural heritage 

resources in the project area. However, due to the scope of the activity and the distance to the 

resources, DCR-DNH does not anticipate that this project will adversely impact these natural 

heritage resources. (0069-28 [Irons, Ellie]) 

Comment: DCR files do not indicate the presence of any State Natural Area Preserves under 

the agency's jurisdiction in the project vicinity. (0069-30 [Irons, Ellie]) 
Appendix E 

February 2010 E-75 NUREG-1917, SEIS 

Comment: We have reviewed the proposed corridor for the additional 500kV line required to 

carry the output of the existing Lake Anna units and the proposed third unit. We do not currently 

document any listed wildlife or resources under our jurisdiction from the project area. Therefore, 

impacts upon such species and resources are not likely to result from the construction of this 

line. In addition, as this new line will be co-located within an existing power line corridor, it does 

not appear that significant wildlife habitat alterations will occur. 

(0070-4 [Ewing, Amy]) 

Response: These comments from the Commonwealth of Virginia provide natural resource 

information that supports the NRC staff's independent analysis. These comments provide no 

new and significant information. Therefore, no changes were made to the SEIS. 

Comment: In general, DEQ recommends that stream and wetland impacts be avoided to the 

maximum extent practicable. To minimize unavoidable impacts to wetlands and waterways, 

DEQ recommends the following practices: 

• Operate machinery and construction vehicles outside of stream-beds and wetlands; use 

synthetic mats when in-stream work is unavoidable. Preserve the top 12 inches of 

trench material removed from wetlands for use as wetland seed and root-stock in the 

excavated area. 

• Erosion and sedimentation controls should be designed in accordance with the most 

current edition of the Virginia Erosion and Sediment Control Handbook. These controls 

should be in place prior to clearing and grading, and maintained in good working order to 

minimize impacts to state waters. The controls should remain in place until the area is 

stabilized. Place heavy equipment, located in temporarily impacted wetland areas, on 

mats, geotextile fabric, or use other suitable measures to minimize soil disturbance, to 

the maximum extent practicable. 

• Restore all temporarily disturbed wetland areas to pre-construction conditions and plant 

or seed with appropriate wetlands vegetation in accordance with the cover type 

(emergent, scrub-shrub, or forested). The applicant should take all appropriate 

measures to promote revegetation of these areas. Stabilization and restoration efforts 

should occur immediately after the temporary disturbance of each wetland area instead 

of waiting until the entire project has been completed. 

• Place all materials which are temporarily stockpiled in wetlands, designated for use for 

the immediate stabilization of wetlands, on mats, geotextile fabric in order to prevent 

entry in State waters. These materials should be managed in a manner that prevents 

leachates from entering state waters and must be entirely removed within thirty days 

following completion of that construction activity. The disturbed areas should be 

returned to their original contours, stabilized within thirty days following removal of the 

stockpile, and restored to the original vegetated state. All non-impacted surface waters 

within the project or right-of-way limits that are within 50 feet of any clearing, grading, or 

filling activities should be clearly flagged or marked for the life of the construction activity 
Appendix E 

NUREG-1917, SEIS E-76 February 2010 

within that area. The project proponent should notify all contractors that these marked 

areas are surface waters where no activities are to occur. 

• Measures should be employed to prevent spills of fuels or lubricants into state waters. 

(0069-13 [Irons, Ellie]) 

Comment: DGIF offers the following recommendations for the protection of wildlife resources 

during project construction: 

• Adhere to erosion and sediment controls for all land-disturbing activities. 

• Conduct any in-stream activities during low or no-flow conditions. 

• Use non-erodible cofferdams to isolate the construction area. 

• Block no more than 50% of the streamflow at any given time. 

• Stockpile excavated material in a manner that prevents reentry into the stream. 

• Restore original streambed and streambank contours. 

• Revegetate barren areas with native vegetation. 

• Construct stream crossings via clear-span bridges when applicable due to future 

maintenance costs associated with culverts and the loss of riparian and aquatic habitat. 

(0069-26 [Irons, Ellie]) 

Response: These comments provide lists of recommended procedures, best management 

practices, and mitigation measures to limit adverse impacts of construction to wetlands, 

streams, and other ecological resources. At the discretion of the appropriate State agencies, 

these recommendations might be attached as conditions to permits issued by the 

Commonwealth of Virginia for the construction and operation of the new unit. These 

recommendations are similar to the list of measures and controls proposed by Dominion in its 

environmental report (ER) and summarized in Section 4.10 of the SEIS. These comments 

provide no new and significant information. Therefore, no changes were made to the SEIS. 

Comment: The SEIS does not include a discussion of natural heritage resources. However, 

the document (page 2-17, section 2.7.1.4) states that the NRC expects Dominion to work with 

the Commonwealth, including the Department of Conservation and Recreation's Natural 

Heritage Program, on development and implementation of any required monitoring programs. 

(0069-27 [Irons, Ellie]) 

Response: The NRC staff received a letter from the Virginia Department of Conservation and 

Recreation’s Natural Heritage Division that identified several species of rare plants that may be 
Appendix E 

February 2010 E-77 NUREG-1917, SEIS 

affected by construction and operation of Unit 3. The staff has modified the text in Sections 2.7, 

4.4, and 5.4 of this SEIS to reflect this information.

Comment: We [USACE] recommend you submit the following information so we may conduct 

a public interest review: A survey and/or report for the federally listed threatened species; 

swamp pink (Helonias bullata), small whorled pogonia (lsotria medeoloides), and sensitive joint 

vetch (Aeschynomene virginica). (0009-3 [Bronson, Regena]) 

Comment: Other omissions that should be adequately addressed in the final SEIS include a 

discussion of the small whorled pogonia as it occurs on upland sites (0069-2 [Irons, Ellie]) 

Comment: VDACS notes that the SEIS lists several federal-and state-listed endangered and 

threatened species within the scope of the project area. The small whorled pogonia is not 

generally found in wetland habitat at described in the SEIS (page 5-13, section 5.4.3.1). The 

species occurs on upland sites in mixed deciduous or mixed deciduous and coniferous forests 

that are generally in second-or third-growth successional stages (0069-29 [Irons, Ellie]) 

Comment: DCR-DNH and VDACS offer the following recommendations for this proposal: 

• Contact DCR-DNH, Rene Hypes at (804) 371-2708 for an update on natural heritage 

information if a significant amount of time passes before the project is initiated since new 

and updated information is continually added to Biotics. 

• The final SEIS should include a discussion of the small whorled pogonia as it occurs on 

upland sites. 

(0069-31 [Irons, Ellie]) 

Response: The NRC staff has contacted and received correspondence from the Virginia 

Department of Conservation and Recreation, Division of Natural Heritage. The discussion of 

the small whorled pogonia and other Federally listed plant species has been modified in 

Sections 2.7.1, 4.4.3, and 5.4.3 of the SEIS to reflect the likely habitat requirements for these 

species. 

Comment: The Department of Forestry finds that proposed clearing of 125 acres of timberland 

for the Unit 3 footprint, and the 80 acre proposed clearing due to construction will have a 

significant impact on the forest resources of the Commonwealth. (0069-45 [Irons, Ellie]) 

Comment: VDOF recommends that the proposed clearing due to construction be mitigated. 

Potential opportunities for mitigation include but are not limited to: 

• Plant open company lands within Virginia to create forested stands. 

• Work with VDOF to develop a cost share program to assist private landowners 

statewide, to reforest harvested timberlands or plant open lands with pine or hardwood 

seedlings. This mitigation program would be funded by Dominion. 
Appendix E 

NUREG-1917, SEIS E-78 February 2010 

• Work with VDOF, or other Virginia conservation agency or group, to create a forest land 

conservation fund to be used for the purchase of conservation easements or property 

acquisitions of forested lands. These purchases could be statewide and would ensure 

that the forested lands are managed and retained as working forest lands. 

• Mitigation should achieve a ratio in excess of 1 to 1, more than one acre of land 

reforested or protected to every one acre cleared, for power-line right-of-way. Therefore, 

Dominion would assist landowners in the conservation, reforestation or purchase of at 

least 200+ acres within the county area or statewide. 

(0069-46 [Irons, Ellie]) 

Response: Section 4.4.1 of the SEIS indicates that Dominion estimates that 50.6 ha (125 ac) 

of forested habitat will be cleared to construct Unit 3; this area is greater than the estimate of 

32.4 ha (80 ac) provided in the ESP EIS (NRC 2006a). All of this habitat is relatively recent 

regrowth and contains no unique or sensitive plant species or communities. Once construction 

was complete, a portion of the disturbed forest area would be available for reforestation or other 

use. No forest clearing will be required for construction of the new North Anna to Ladysmith 

transmission line. The commenter also recommended several potential mitigation measures to 

counteract the small impact of the construction related forest habitat loss. While Dominion is 

encouraged to work with the Commonwealth of Virginia to implement forest resource 

conservation measures as suggested by the commenter, the staff does not consider these 

mitigation measures to be necessary in light of the SMALL construction impact.

Comment: Please mitigate the damage you cause with wetlands preservation elsewhere. 

(0050-2 [Gignac, David]) 

Comment: DEQ-OSGSP offers the following recommendations: 

- Dominion should continue to coordinate with DEQ regarding the evaluation of potential impact 

the three-inch rise may have on wetlands. Should the size or scope of the project change, 

additional review by DEQ may be necessary. 

- Dominion should strictly adhere to erosion and sediment controls and stormwater 

management practices, and monitor construction activities to ensure that erosion and 

stormwater management practices are adequately preventing sediment and pollutant migration 

into surface waters, including wetlands. (0069-21 [Irons, Ellie]) 

Comment: The SEIS recognizes the need for permitting of potential impacts to wetlands 

resulting from the construction and/or operation of Unit 3. According to the DEQ Office of 

Wetlands and Water Protection (OWWP), the report states that Dominion Virginia Power has 

conducted a wetland delineation to determine the location, extent, and type of surface waters 

present, and that approximately 6.68 acres of wetland, 5,500 linear feet of stream and 

2.49 acres of open water have been identified within the proposed construction footprint. The 

report also states that permanent disturbance may be limited to less than 0.5 acre of non-tidal 
Appendix E 

February 2010 E-79 NUREG-1917, SEIS 

wetland and less than 800 linear feet of stream within the site footprint. State-and federal-listed 

threatened and endangered species were identified as potentially occurring on the site. 

(0069-5 [Irons, Ellie]) 

Comment: [Virginia WaterProtectionPermit] Based on a review of the location map provided 

with the SEIS, DEQ is unable to determine the exact quantity of wetland and stream impacts. 

However, because impacts are proposed to wetlands and streams, this project will likely require 

a Virginia Water Protection Permit. DEQ-NRO agrees with the technical and regulatory 

discussion in the SEIS and finds no reason to suggest a VWPP could not be obtained. The 

DEQ-NRO VWPP program will make the final permit decision regarding potential impacts to 

state waters. (0069-6 [Irons, Ellie]) 

Comment: The wetland delineation should be confirmed by the U.S. Army Corps of Engineers 

(Corps). In addition to contacting the Corps for the wetland confirmation, Dominion must 

contact the DEQ Virginia Water Protection Permit program to determine the necessity of the 

VWPP(s). Coordination of this project should be conducted with the Virginia Marine Resources 

Commission, the Corps and DEQ through the Joint Permit Application (JPA) process. The JPA 

must include documentation of all avoidance and minimization efforts and a conceptual plan for 

appropriate compensatory mitigation. Avoidance and minimization of wetland and stream 

impacts should occur to the maximum extent practicable. (0069-8 [Irons, Ellie]) 

Comment: 

 Coordinate closely with DEQ regarding mitigation options as they are considered and 

developed. 

 Examine onsite mitigation options to compensate for unavoidable permanent wetland 

impacts and conversions or purchase of credits at a mitigation bank within the watershed of the 

proposed impacts. 

 Consider mitigating impacts to forested or converted wetlands by establishing new forested 

wetlands within the impacted watershed. (0069-9 [Irons, Ellie]) 

Response: As described in Section 2.7.1 of the draft SEIS, Dominion has delineated the onsite 

wet-land areas, and the USACE has verified the Dominion’s delineation. Subsequent to 

publication of the draft SEIS (NRC 2008), Dominion also delineated wetlands within the 

transmission line right-of-way and the newly acquired adjoining property. USACE also verified 

those delineations. Dominion has committed to obtaining and complying with all applicable 

permits regarding wetlands, and has committed to working with the Commonwealth of Virginia 

and USACE to develop and implement appropriate mitigation actions to compensate for any 

wetland losses. Sections 2.7.1, 4.4.1, and 5.4.1 of the SEIS have been updated to include the 

transmission line right-of-way wetland delineation information. 
Appendix E 

NUREG-1917, SEIS E-80 February 2010 

Comment: Section 4.4.3 line 35 acknowledges that bald eagles nest as close as 2.5 miles to 

the site. What effect will the project have on fish that the eagles may use as a food source? 

(0023-24 [Goldsmith, Aviv]) 

Response: As described in Section 5.3.3, Unit 3 operations will not add any EPA priority 

pollutants to Lake Anna, but some priority pollutants, such as Copper and tributyltin that are 

already in the lake water will become more concentrated (4-9 times) in the Unit 3 plant effluent. 

Although the concentration of these contaminants may exceed water quality criteria at the Unit 3 

discharge structure, their concentrations would be quickly diluted upon mixing with the much 

larger discharges from Units 1 and 2 in the discharge canal. Chemical discharges associated 

with Unit 3 are not expected to detectably change Lake Anna water quality or add additional 

priority pollutants of concern for accumulation in the food web. Semiannually, Dominion 

samples fish from Lake Anna as part of its Radiological Environmental Monitoring Program for 

Units 1 and 2. They sample game fish and bottom-dwelling species. A review of Dominion's 

Annual Radiological Environmental Operating Reports for the 2005, 2006, and 2007 showed no 

impact from plant operations, that is, activity levels in fish from Lake Anna were similar to the 

control location. Unit 3 is not expected to significantly increase the concentration of 

radionuclides in Lake Anna. The staff has not modeled the potential dose to bald eagles, but 

did estimate the potential dose to a set of surrogate species, with the heron being most similar 

to the bald eagle in Section 5.9.5. In the ESP EIS (NRC 2006a), the staff found that the 

potential dose to the heron from two new units would be significantly less than the chronic dose 

rate values established by the International Atomic Energy Agency (IAEA) and the National 

Council on Radiation Protection and Measurements (NCRP). As described in Section 5.9.5 of 

the SEIS, the estimated doses to the heron from the proposed unit 3 are lower than those 

estimated in the ESP EIS (NRC 2006a). Therefore, radiological doses to the bald eagle are not 

likely to be significant. Physical, chemical, and thermal impacts to fish populations from 

operation of Unit 3 were found to be SMALL, therefore the base of available food is not likely to 

be affected by operation of Unit 3. Additionally, Lake Anna is a highly managed system with 

respect to fish, in that VDGIF stocks the lake with a variety of predator and prey species and 

can adjust its management strategy based on their monitoring results. No changes were made 

to the SEIS based on this comment. 

Comment: As part of the IFIM study, Dominion is evaluating the potential impacts to shoreline 

and wetland vegetation, not monitoring as part of a program. Dominion suggests the following 

wording, "Dominion is evaluating the potential impacts of lake level changes on shoreline and 

wetland vegetation as part of its Instream Flow Incremental Methodology (IFIM) study, and 

regulatory permitting activities." (0084-25 [Grechek, Eugene]) 

Response: The text in Section 5.4.1 was modified based on this comment. 

Comment: [DSEIS Sec 2.7.1.2, text re "wildlife surveys ....and wetlands have not been 

delineated....along the Ladysmith right-of-way"] A wetlands delineation had not been performed 

at the time of submittal of COLA-ER Rev. 0. A wetlands delineation along the NAPS-toLadysmith transmission corridor was performed in August 2008 and is described in the 
Appendix E 

February 2010 E-81 NUREG-1917, SEIS 

COLA-ER Rev. 1, Section 4.3.1.1, submitted in December 2008. A jurisdictional determination 

from the US Army Corps of Engineers was also received in September 2008. 

(0084-35 [Grechek, Eugene]) 

Response: The text in Section 2.7.1 was modified to include the information contained in 

Dominion's wetland delineation and the USACE wetland determination for the North Anna to 

Ladysmith transmission corridor. 

8. Comments Concerning Ecology – Aquatic 

Comment: Page 5-24 states that "larval abundance is not known" and that a 1978 model was 

used for the estimation. How good is the estimation? Couldn't representative sampling give an 

estimate of larval abundance? (0023-33 [Goldsmith, Aviv]) 

Response: The statement on larval abundance appears in the draft ESP EIS (NRC 2006b), not 

the COL SEIS. As stated in Section 5.4.2.3 of the ESP EIS (NRC 2006a), the fish populations 

in Lake Anna most susceptible to entrainment are members of a balanced community and have 

remained relatively stable, in part because of the fishery management actions employed by the 

Commonwealth of Virginia. Thus, the NRC staff believes the use of the entrainment model 

used to evaluate additional entrainment losses associated with the operation of Unit 3, and that 

further synoptic sampling of larval communities in the lake is not warranted. This comment 

provides no new and significant information. Therefore, no changes were made to the SEIS. 

Comment: Page 5-27 discusses cold shock and says that it will be less of a problem with a 

multiple unit plant. This is only true if the entire station does not shut down. If the remaining unit 

or units shut down, the cold shock will be much more severe due to the loss of a huge thermal 

load. (0023-34 [Goldsmith, Aviv]) 

Response: This statement on cold shock appears on Page 5-26 of the ESP EIS 

(NUREG-1811), not the COL SEIS. In its independent assessment, the NRC staff determined 

the impact to be SMALL. This comment provides no new and significant information. 

Therefore, no changes were made to the SEIS. 

Comment: Coordinate with the Virginia Department of Game and Inland Fisheries and/or the 

U.S. Fish and Wildlife Service regarding presence of endangered or threatened species and/or 

habitat, prior to seeking a permit from the Virginia Water Protection Permit Program. 

(0069-11 [Irons, Ellie]) 

Response: This comment is a specific recommendation to the applicant by the Virginia 

Department of Environmental Quality (DEQ) and is addressed in Appendix L of the SEIS. 

Section 2.7.2.2 of the SEIS states that no Federally or State-listed fish species have been 

observed in Lake Anna or the North Anna River, and none are believed to occur in counties 

adjacent to Lake Anna or the North Anna River (i.e., Caroline, Hanover, Louisa, Orange, and 

Spotsylvania Counties). Three listed species – the dwarf wedgemussel (Alasmidonta 

heterodon), the James spinymussel (Pleurobema collina), and the Atlantic pigtoe (Fusconaia 
Appendix E 

NUREG-1917, SEIS E-82 February 2010 

masoni) – could occur in counties adjacent to or downstream of the Lake Anna reservoir. Two 

additional aquatic species – the green floater (mussel) (Lasmigona subviridis) and the Virginia 

Piedmont waterboatman, an aquatic insect, Sigara depressa – were identified by the 

Commonwealth as occurring in the upper Pamunkey River watershed (Table 2-4 in 

Section 2.7.2.2). None of the species identified above have been observed or collected in Lake 

Anna or the North Anna Rive during pre-impoundment surveys or in more recent routine 

monitoring surveys. 

Comment: DGIF will continue to work with Dominion, the permitting agencies, and other 

natural resource agencies to develop operating rules that avoid adverse impacts upon 

downstream resources, including recreational uses, or to mitigate unavoidable impacts. 

Possible impacts upon protected species and the waters that support them will be considered in 

DGIF's final comments and recommendations resulting from review of the IFIM results. 

(0069-22 [Irons, Ellie]) 

Response: This comment is a statement of intent by the VDGIF regarding development of 

Lake Anna operational requirements for the proposed Unit 3. Chapter 5 of the SEIS was 

modified to include discussion of the IFIM study. 

Comment: According to DGIF data and those from the Department of Conservation and 

Recreation (DCR), downstream waters have been known to support: 

• dwarf wedgemussel (federally-listed endangered) 

• James spinymussel (federally-listed endangered) 

• Atlantic pigtoe (state-listed endangered) 

• green floater (state-listed threatened). 

(0069-23 [Irons, Ellie]) 

Response: These species are known or likely to occur in counties adjacent to or downstream 

of the Lake Anna reservoir, but have not been observed or collected in Lake Anna or the North 

Anna River during pre-impoundment surveys or in more recent routine monitoring surveys. 

Section 2.7.2.2 of the SEIS has been modified to include this information. 

Comment: Upon review of the Early Site Permit and associated Coastal Consistency for the 

proposed addition of a third reactor at North Anna Power Station (NAPS), we expressed 

concerns about the operation of the third reactor and the reservoir as they relate to maintenance 

of downstream flows in the North Anna and Pamunkey rivers. To address our concerns, we and 

other state resource agencies recommend that Dominion perform an Instream Flow Incremental 

Methodology (IFIM) study in the North Anna River below the Lake Anna dam and in 

downstream waters of the Pamunkey River. We worked closely with Dominion and the 

permitting agencies on the design of the study and the analysis of the results. As stated in the 
Appendix E 

February 2010 E-83 NUREG-1917, SEIS 

SEIS, the primary goal of the IFIM is to determine whether possible changes in dam releases 

resulting from the operation of the third reactor are likely to adversely impact aquatic resources 

below the dam. (0070-1 [Ewing, Amy]) 

Response: Section 5.4.2.4 of the SEIS was modified to include discussion of the IFIM study 

results related to downstream aquatic impacts. 

Comment: According to our records, we do not currently document listed wildlife resources 

under our jurisdiction from the site proposed for placement of the third reactor. Therefore, 

impacts upon such resources are not likely to result from site preparation or construction of the 

third reactor. According to our data and those from VDCR, downstream waters have been 

known to support federal Endangered dwarf wedgemussel, federal Endangered James 

spinymussel, state Endangered Atlantic pigtoe, and state Threatened green floater. Possible 

impacts upon these species and the waters that support them will be considered in our final 

comments and recommendations resulting from review of the IFIM results. 

(0070-3 [Ewing, Amy]) 

Response: As described in Section 2.7.2.2 and Table 2-4, species listed in this comment are 

known or likely to occur in counties adjacent to or downstream of the Lake Anna reservoir, but 

have not been observed or collected in Lake Anna or the North Anna River during preimpoundment surveys or in more recent routine monitoring surveys. The text of Sections 2.7.2 

and 5.4.2 of the SEIS was modified to include discussion of the IFIM study design and results. 

Comment: But we know, from eight years of hard work, on mitigation with Newport News, that 

it was a good thing we did, and we got Newport News to agree to a lot of commitments, some 

financial commitments, and resources that will ensure that the shad population of the Pamunkey 

river will survive. (0073-14 [Brown, Kevin]) 

Response: Downstream impacts to aquatic resources are discussed in Section 5.4.2.4 of the 

SEIS. Although the operation of the proposed Unit 3 will increase the number of days when 

20 cfs flows occur at the North Anna Dam, the decreased flow events are expected to occur 

primarily in the late summer and early fall, and will not coincide with fish spawning in 

downstream locations that include the Pamunkey River. Thus, the staff concluded that impacts 

to aquatic resources downstream of the North Anna Dam would be SMALL. 

Comment: The SDEIS does not appear to contain an adequate discussion of the treatment of 

the blow-down, or the potential effects of the blow-down on Lake Anna, and downstream 

ecological resources. (0078-6 [Cruickshank, John]) 

Response: This comment appears to be related to the ESP EIS (NRC 2006a), which stated 

that some water quality impacts associated with blowdown water discharges were unresolved 

because a specific water quality treatment design was unavailable. Since that time, Dominion 

has provided additional information on the ambient water quality of Lake Anna, a description of 

plant water treatment methods and chemical additives, blowdown flow rates, and expected 

chemical concentrations in the plant discharge. This information and an analysis of impact on 
Appendix E 

NUREG-1917, SEIS E-84 February 2010 

water quality are presented in Section 5.3.3 of the SEIS. The staff concluded that impacts of 

operating the proposed Unit 3 on water quality would remain SMALL.

Comment: Missing the qualifier "among". Redbreast sunfish (Lepomis auritus) have 

consistently been among the most abundant species in the North Anna River since 1981. 

Reference - Accession No. ML081960653, page 28, "Environmental Study of Lake Anna and 

the Lower North Anna River - Annual Report for 2007". (0084-10 [Grechek, Eugene]) 

Comment: [DSEIS Section 2.7.2.1] Should say four stations, not six. Reference - Accession 

No. ML081960653, page 35, "Environmental Study of Lake Anna and the Lower North Anna 

River - Annual Report for 2007". "The locations of the following four (4) electrofishing stations 

are shown in Figure 4.1-1: NAR-1 (Route 601 Louisa Bridge), NAR-2 (Route 658 Bridge), 

NAR-4 (Route 601 Hanover Bridge) and NAR-6 (U.S. Route 1 Bridge)." 

(0084-11 [Grechek, Eugene]) 

Comment: Editorial: [Sec 2.7.2.1, "Recent Dominion surveys......"] Revise "Dominion" to 

"VDGIF." (0084-12 [Grechek, Eugene]) 

Comment: Dominion suggests deleting the word "Reservoir" from the title of Table 2-4 to be 

consistent with other references to Lake Anna in the DSEIS. (0084-14 [Grechek, Eugene]) 

Comment: The VDGIF reference presented a fishing preference with largemouth bass ahead 

of striped bass [ref SDEIS Section 2.7.2.1]. (0084-7 [Grechek, Eugene]) 

Comment: Change "2008" to "2002." [in sentence about discharges increasing from 

December 19 to 22, 2008] (0084-8 [Grechek, Eugene]) 

Comment: The America eel (Anguilla rostrata), should also be included [in list of abundant fish 

species in Sec 2.7.2.1]. Reference - Accession No. ML081960653, page 28, "Environmental 

Study of Lake Anna and the Lower North Anna River - Annual Report for 2007". "The 

numerically dominant species collected in 2007 were, in descending order, American eel, 

redbreast sunfish, rosefin shiner, margined madtom and satinfin shiner, fallfish Semotilus 

corporalis, and tessellated darter Etheostoma olmstedi (Table 4.2-3)." 

(0084-9 [Grechek, Eugene]) 

Response: These comments were incorporated in the SEIS text. 

Comment: Dominion suggests the following: Add "The IFIM study focused on how changes in 

flow resulted in changes in aquatic habitat in the North Anna and Pamunkey Rivers." Modify 

"The IFIM study... to reach conclusions." Insert "Though the study did not address explicitly the 

well-documented effect of diluting acid mine drainage in the North Anna River,..." Continue with 

"...the staff believes...in the North Anna and Pamunkey Rivers." (0084-13 [Grechek, Eugene]) 

Response: The text in the SEIS referred to in this comment has been extensively modified. 

The IFIM study design and results are discussed in Section 2.7.2.4 and Chapter 5, respectively. 
Appendix E 

February 2010 E-85 NUREG-1917, SEIS 

Comment: [in DSEIS Section 2.7.2.3 Aquatic Ecology Monitoring] Dominion suggests that the 

reference to "mussels" be deleted. Mussels were not included as part of the approved river 

study. Reference - Accession No. ML081960659, "A Monitoring Plan for Lake Anna, the Waste 

Heat Treatment Facility and the North Anna River", February 2008 - "Biological monitoring shall 

include fish population surveys." (0084-15 [Grechek, Eugene]) 

Response: The staff clarified that the “mussel” reference above pertains to Lake Anna rather 

than the river. Section 2.7 of the SEIS was modified.

Comment: As you know, the existing Units 1 and 2 have a thermal variance under Virginia's 

Pollution Discharge Elimination System (VPDES) permit. While the VPDES permit is protective 

of water quality, thermal discharges may decrease the level of dissolved oxygen in the water 

adding stress to the aquatic community. EPA has ecological concerns with the cumulative 

impacts to the lake due to thermal discharge from the existing units, the proposed Unit 3 and the 

low dissolved oxygen levels from several lake tributaries. As a result, EPA believes that 

Dominion Nuclear North Anna LLC should consider additional mitigative measures to offset the 

potential thermal discharge impacts. (0072-2 [Lapp, Jeffrey]) 

Response: The comment is noted. Cumulative impacts are discussed in Chapter 7 of the 

SEIS; mitigation of operating impacts is discussed in Chapters 5 and 10. Plant effluent 

discharges will continue to be regulated by the Commonwealth of Virginia. Because of the use 

of closed cycle cooling, the thermal contribution to Lake Anna waters due to the operation of the 

proposed Unit 3 would have an insignificant impact on dissolved oxygen levels in the reservoir. 

No change was made to the SEIS as a result of this comment. 

Comment: [DSEIS Sec 5.4.2.4] NRC references 250.3 ft. msl correctly as stated in the original 

study plan. The actual study and draft final report, however, are aimed at a target lake elevation 

of 250.25 ft. msl. (0084-27 [Grechek, Eugene]) 

Response: Section 5.4.2.4 was modified as suggested to change the increased reservoir 

surface elevation to 76.3 m (250.25 ft). 

9. Comments Concerning Socioeconomics 

Comment: The impact of the third reactor to social, economic, safety, health, environmental 

(i.e. shorelines, wet areas, etc.) and drought conditions on property owners, businesses, and 

usability of the lake are essentially unknown despite 5 years of permit approval process by State 

and Federal Authorities. Therefore, this past Fall, LACA conducted a survey of its members to 

measure impact of some aspects of recreational use of the lake. We asked our members to 

estimate the number of lost recreation days they experienced in 2007 low water conditions (not 

a major drought). The 151 respondents, primarily homeowners around the lake, reported a 

staggering 4,239 lost days. If extrapolated lake-wide this is the equivalent to nearly 20,000 lost 

days. That does not include the day users and users of the State Park. Furthermore, new data 

from the survey reveals that facilities become unusable and days are lost even before the lake 

reaches two feet low. (0019-2 [Smith, Doug]) 
Appendix E 

NUREG-1917, SEIS E-86 February 2010 

Comment: Recreation - The recreation release would begin on Friday afternoon or evening 

and last for about 18 hours. This pulse of water is designed to be present in the most popular 

recreational boating reach during the daylight hours on Saturday. These mitigation measures 

were designed to protect lake levels, protect aquatic life and enhance river recreation if water 

storage was in good condition. An additional benefit of the pulse is that it would temporarily 

improve fish habitat and restore some of the natural variability to river's summer hydrologic 

regime. (0069-18 [Irons, Ellie]) 

Comment: Wetlands - Dominion also studied the impact of the three-inch rise in normal lake 

levels on docks and on fringe wetlands around the lake. Preliminary indications are the threeinch rise will have small impacts on docks and wetlands. (0069-19 [Irons, Ellie]) 

Comment: One area of environmental concern, to the Louisa County staff and the residents, 

who work and live near the North Anna Power Station, and those who use the lake for 

recreation, is that of lake level. I have been told that most of the time the lake level will be at full 

pond with a third reactor operating. And that residents will be able to enjoy the lake the same as 

they do now. (0073-17 [Mullen, Dale]) 

Comment: One, low water levels expose safety hazards to thousands of recreational users of 

the lake. How many new hazards are created by the water consumption of the third reactor? 

Answer, nobody knows. (0073-48 [Smith, Doug]) 

Comment: Three, low water levels discourage use of the lake. How many additional people will 

be denied use of the lake? Nobody knows. (0073-50 [Smith, Doug]) 

Comment: Reduced use of the lake affects businesses that depend on lake, and taxes that are 

collected. What is that impact? Nobody knows. (0073-51 [Smith, Doug]) 

Comment: Since no impact data really exists, LACA, this past fall, decided to conduct a survey 

and at least ask its members what they believe the impact was in the year 2007. Now, we had 

dry year in 2007 and we at least asked them what the impact was. The answer was very 

interesting. And if extrapolated to all of the owners around the lake, it would mean 20,000 lost 

days of recreation for folks who live around the lake. That is the smaller portion of the total users 

of the lake, if you look at the park, and the day users that come in on public ramps, you would 

get a number much larger than that. LACA believes this is new and significant data, it reveals 

real information about the impact of low water levels on Lake Anna, and we ask the NRC to 

review the data, and reconsider their finding that mitigation of impact of low water levels is not 

required. (0073-53 [Smith, Doug]) 

Comment: If you consider the owners and operators, and family members of our [Lake Anna 

Business Partnership] membership, a rough estimate is that we represent probably about 

500 people who have an interest in maintaining the pristine nature of the resources provided to 

us by Lake Anna. (0075-6 [Bishop, Wayman]) 
Appendix E 

February 2010 E-87 NUREG-1917, SEIS 

Comment: I have to say that my recreational experience is not represented in the report of the 

findings of the survey conducted by the Lake Anna Civic Association. Now, when I read those 

findings I asked myself, do I live on the same lake? Perhaps I'm very fortunate, but I have to tell 

you that none of my recreational activities, since 1983, which include fishing, swimming, 

boating, and skiing, have never been negatively impacted by the water level at Lake Anna. 

Some days I step into my boat, some days I jump down into my boat. But I'm still able to operate 

my boat. My personal view is that your inability to use your boat Lake Anna is more a feature of 

short-sighted design and placement of your boat lift, than it is the level of the water at Lake 

Anna. (0075-7 [Bishop, Wayman]) 

Response: NRC staff evaluated new information related to inputs to the water budget model 

and any resulting changes to impacts of plant operation on Lake Anna reservoir lake level and 

discharge to the North Anna River. Inputs to the water budget model include plant water use, 

plant discharges, meteorology (precipitation), and streamflow information. Lake level and 

thermal impacts were addressed in the ESP EIS (NUREG-1811); therefore, the COL SEIS 

analysis focuses on new and significant information that might change the original impact level. 

The results of the lake level elevation and discharge evaluation were also used to evaluate 

socioeconomic (including recreational) impacts, which are addressed in Section 5.8 of the 

SEIS. 

As a condition of the ESP for the North Anna site, Dominion was required to conduct an IFIM 

study to address impacts on lake levels and downstream flows under different reservoir 

operating scenarios during proposed Unit 3 operations, compared to the existing (Unit 1 and 2) 

reservoir operating condition. The IFIM study components included downstream habitat for fish 

and other organisms, recreation on the North Anna and Pamunkey Rivers, wetlands around the 

shore of Lake Anna, and Lake Anna boat ramps and docks. Mitigation of impacts includes a 

proposal to increase Lake Anna reservoir storage capacity by raising the normal pool elevation 

by 0.08 m (0.25 ft) to 76.3 m (250.25 ft) and use of a wet-dry cooling tower in Maximum Water 

Conservation mode during periods when lake level is below 76.2 m (250.0 ft). The 7.62-cm 

(3-in.) increase in average pool level discussed in the IFIM is not expected to adversely affect 

the usability boat launches or publically-accessible docks. Private docks and boathouses were 

not evaluated. Raising the lake level slightly and MWC operation togther reduce the impact of 

drought on low water levels in Lake Anna and would allow for additional water flows in the 

Pamunkey river downstream of the lake. Both of these features of the mitigation plan slightly 

improve prospects for recreation during severe drought, and offset part of the Unit 3's negative 

impact on recreation, which remains SMALL most of the time but possibly up to MODERATE 

during extreme drought. The results of the IFIM study were not available at the time the draft 

SEIS was published, but they are included in Chapter 5 of the final SEIS, along with other 

proposed measures to mitigate habitat and recreational impacts. Reservoir management, water 

use, water quality, and downstream instream flow requirements fall within the regulatory 

authority of the Commonwealth of Virginia. 

Comment: Because this project is of great economic importance to the county, and its 

residents, and because the environmentally responsible development of reactor 3 is also 

paramount, I and my staff have sought to learn the facts concerning the plans for reactor 3 as 
Appendix E 

NUREG-1917, SEIS E-88 February 2010 

part of our professional review of the development of this important industry in your county. 

(0073-16 [Mullen, Dale]) 

Comment: They employ, currently, 950 people. And approximately a third, or over 300 live in 

Louisa County. They are the county's largest employer. Their annual payroll is approximately 

70 million dollars, and the average salary is over 74,000 dollars. The third reactor will add an 

additional 750 new jobs. And if you use the same ratio, that is approximately 250 new jobs for 

Louisa citizens, with an average salary of 74,000 dollars. Now, this doesn't include the 

3,000 new jobs that will be created during construction. And with an unemployment rate of 

6.1 percent and growing... (0073-22 [Gibson, Bob]) 

Comment: Dominion North Anna is Louisa's largest single taxpayer. Since its inception it has 

paid over 236 million dollars to Louisa County. The new reactor will provide additional millions of 

new tax revenue for Louisa County. (0073-23 [Gibson, Bob]) 

Comment: But if you want a visual of what it means to Louisa County, just drive and look at our 

schools, and the quality of our schools, and the new school that is being built, and you will see 

really what this reactor means to the county. (0073-24 [Gibson, Bob]) 

Comment: But on a broader scale, economic scale, reliable and affordable electricity is a 

foundation for attracting and maintaining industry. Dominion North Anna produces Dominion's 

lowest cost source of baseload electricity in their system, and generates 17 percent of all the 

electricity used by their customers. (0073-25 [Gibson, Bob]) 

Comment: I might also say, from an economic perspective, it is our belief that the only real 

recovery, and when I say real I'm not talking about artificial recovery, economically, I'm talking 

about real recovery to our economy, the best hope for this region is in building and operating 

reactor number 3. Because this is a rural area our response to any efforts to stimulate the 

economy will lag in the national economy by 18 to 24 months. So we think that the best hope for 

real economic recovery, in this area, is in reactor number 3. Thank you very much. 

(0075-11 [Bishop, Wayman]) 

Comment: We further acknowledge and appreciate the fact that at a time when the national 

unemployment rate is rising rapidly, and potential future unemployment keeps people up at 

night, that 314 citizens in the greater Fredericksburg area receive a paycheck from Dominion 

Virginia Power's North Anna facility. The ripple effect, through the economy, of increased 

salaries and wages, puts food on the table, parks a newer vehicle in the garage, puts our 

children through school, helps pay for health and dental care, and helps support thousands of 

businesses in the region. (0075-17 [Bailey, Gene]) 

Comment: It is a win-win, for both Louisa, for the State, for Dominion customers. You get 

3,000 new construction jobs, you get a permanent employment of 750 people, it provides 

energy, increased taxes, and good payroll for the area. (0075-21 [Farmer, John]) 
Appendix E 

February 2010 E-89 NUREG-1917, SEIS 

Comment: But, as an addendum to all the technical aspects of this facility, the immediate 

impact will be on the economic picture in the state and local environs, at a time when we are 

facing a bleak outlook. Jobs will be created at a time when they are needed most, and the 

ripple effect will be incalculable. (0075-27 [Beament, Pete]) 

Comment: Times have become very hard recently, for myself, and a lot of people like my 

family. This third reactor would be a huge boost for myself, my family, and hundreds of other 

families in this area. (0075-31 [Carroll, John]) 

Comment: I was going to talk about economic financial impacts, but a couple of people already 

have, 750 permanent jobs. (0075-45 [Stiles, Lisa]) 

Comment: As far as jobs go, this county, we talk about the recession, and the economy of 

Louisa County. Yes, our jobless rate is low, in the 6 or 7 percent for Louisa County. However, I 

can tell you that my husband has been laid off here for a year and a half. And the jobs that are 

in this county are low paying jobs. So this type of employment that will bring to this county will 

be a great help. And an analysis that was done for Comanche Peak, which is another unit that is 

proposing to have a new nuclear facility built, they actually had their economic stimulus. And 

what they had determined was that just the construction alone, let's not take out the 

construction cost, is 22 billion dollars in economic development and 104.7000 person years of 

employment, just for the construction. Can you imagine what that can do to the economy of a 

depressed area like Virginia? And, in fact, if we are building these all over the country, how 

good that would be for the government. (0082-23 [Harte, Vicky]) 

Comment: This country needs all sources of domestic energy we can get. To offset -- and in 

addition, to offset the financial crisis we, as a nation, are experiencing. The best thing we can 

do is develop sources of domestic energy, and prevent the excess of 700 billion dollars that 

goes outside of our country every year, just to purchase energy. (0082-3 [Reynolds, Norm]) 

Response: These comments are statements of support for constructing NAPS Unit 3, based in 

part on creation of construction jobs, subsequent operations jobs, or other economic benefits 

and does not provide new or significant information that would lead to a different level of impact 

than the MODERATE to LARGE beneficial level calculated for the economy in Sections 4.4 and 

5.4 of the SEIS. Therefore, no changes were made to the SEIS. 

Comment: The transportation section is totally deficient. There is currently insufficient 

infrastructure to support the construction workforce or handle an evacuation. 

Assuming that the roads will be there when required (Page 5-37, line 16) is not science, it is 

superstition. The SDEIS stated "No new transportation routes... are currently planned in the 

vicinity of NAPS." (Page 2-4 line 37) There is little to no funding for road expansions in Virginia. 

The DEIS acknowledged that the I-95/606 interchange is congested at "LOS D or worse" and 

that SR208 from Blockhouse Road to Lake Anna (about 12.5 miles) is a minor two-lane road. 

Increased construction usage will have major impacts on these roads. If an evacuation is 
Appendix E 

NUREG-1917, SEIS E-90 February 2010 

required during the construction interval when additional personnel are on site, the impact would 

be staggering. (0023-12 [Goldsmith, Aviv]) 

Comment: 

Table 10-1 acknowledges that increased traffic congestion is unavoidable. This is not congruous 

with the SMALL impact determination. 

Table 10-2 should include an assessment of traffic similar to Table 10-1. Presently, this would 

also conclude that increased traffic congestion is unavoidable. 

(0023-51 [Goldsmith, Aviv]) 

Comment: Major contributions to construction of a reliable road network are required. Financial 

contributions to neighboring counties to alleviate the housing, school, and health care burdens 

of the project should be implemented. (0023-53 [Goldsmith, Aviv]) 

Comment: a discussion of the expected traffic distribution (for construction-related traffic and 

for operations) and the effects upon the state highways and intersections (0069-3 [Irons, Ellie]) 

Comment: HanoverCounty 

Despite the conclusion in the SEIS (page 5-19, section 5.5.4.1) that the transportation impacts 

may be small, it is not possible to determine the impact of the project on Hanover County until 

more detailed information on the distribution of traffic is provided. This development is in a rural 

area where the impacts on these low-volume roads may be relatively higher than in an urban 

area. Note that VDOT does not normally make temporary improvements for constructionrelated traffic as the SEIS (page 5-19, section 5.5.4.1) appears to suggest. 

(0069-49 [Irons, Ellie]) 

Comment: Spotsylvania County 

Based on the information provided, it was also difficult to determine transportation impacts in 

Spotsylvania County. Availability of the traffic management plan, and VDOT's role, referenced in 

the document would assist in further evaluation. VDOT anticipates that the road network should 

be able to handle the addition of 500 employees. However, overweight loads due to 

construction traffic, may cause excessive impacts to the surrounding road system and road 

improvements or road repair may be required. A funding source for this work has not been 

addressed in the SEIS. Note that some of the planned road improvements that would serve this 

site no longer have public funds allocated, delaying the proposed work. 

(0069-50 [Irons, Ellie]) 

Comment: VDOT recommends that the final SEIS should include a discussion and analysis of 

the following: 

• The expected traffic distribution (for construction-related traffic and for operations) and 

the effects upon the state highways and intersections. 
Appendix E 

February 2010 E-91 NUREG-1917, SEIS 

• Where construction workers and additional employees will be housed, routes traveled to 

work, and the number of work shifts. 

(0069-51 [Irons, Ellie]) 

Response: NRC staff have made several efforts to engage Virginia Department of 

Transportation (VDOT) regional and local transportation planners to provide better estimates of 

traffic impacts, but VDOT has taken the position that the applicant should take this responsibility 

and essentially no new information has become available since the ESP EIS (NRC 2006a) 

concerning the current level of traffic, road capacities of potential commuter routes, congestion 

ratings that might occur during construction of Unit 3, or impacts that did occur during the 

construction period for Units 1 and 2. Some plans remain to upgrade several of the roads in the 

area, but the plans remain unfunded. It is not clear to the NRC staff that traffic would follow any 

particular route to reach the plant site or that any data base exists that would yield a different 

estimate of impact than the level already discussed in Sections 4.5 and 5.5 of the SEIS. 

Comment: Today the importance of nuclear power is geopolitical as well as economic, 

reducing dependency on imported oil and gas. I do have an article that was just released 

yesterday, and I'm just going to read a couple of words for you. But it is from OPEC. And this is 

from the Leaders of OPEC. And this is what they reported. We are not happy with even 

50 dollars a barrel worth of oil. We don't want a repeat of the 1980s where we, this is OPEC 

countries, had to lay off highly skilled people and didn't invest. So their goal is to get oil back up 

to 60 to 80 dollars a barrel. This was at their meeting held on March 15th. So while the view 

from the oil producers is that current oil prices are low enough to stimulate the economy, the 

price from OPEC is going to go against us, and it is going to raise the oil back up to prices to 

make it drive our gas back up, away from the prices that we so enjoy now. 

(0082-20 [Harte, Vicky]) 

Response: The comment is generally a supporting statement for the nuclear power based on 

the view that it can displace power generated by combusting oil and gas. This comment 

provided no new and significant information. Therefore, no changes were made to the SEIS. 

Comment: The section on socioeconomics is lacking. For example, there is no data on the 

impact that the project will have on local house values. The impacts on the human environment 

must be fleshed out in an EIS and this should be addressed as part of Section 5.5.3.1 or 

5.5.3.5. The potential impacts to the DC area are not addressed at all in the document and 

should be included. The document does not address the life cycle costs of power and the 

amount of government subsidy involved. (0023-11 [Goldsmith, Aviv]) 

Response: At the ESP stage, using Federal Deposit Insurance Corporation sales data on the 

Census tracts nearest Lake Anna, the NRC staff conducted a study of sales prices of housing 

that occurred during the 2001 to 2002 drought and searched for the potential impacts of decline 

in Lake Anna water levels on housing prices. The study was repeated for the 2005 to 2007 

period for this COL SEIS. While these data are not specific enough to determine the impacts on 

individual properties, no adverse impact on either sales volume or housing prices attributable to 
Appendix E 

NUREG-1917, SEIS E-92 February 2010 

low water levels was detected during the two drought periods. These analyses were described 

in Section 5.5 of the ESP EIS (NRC 2006a) and in Section 5.5 of the SEIS. The ESP EIS and 

the COL SEIS both indicate in their sections 4.5 that there could be upward pressure on local 

housing prices if construction workers decide to move to the local area. No impact assessment 

was performed for the Washington D.C., metropolitan area housing prices because the scale of 

the North Anna project is not likely to be large enough relative to other economic trends in the 

Washington area to produce a noticeable impact. This comment provides no new and 

significant information. Therefore no changes were made to the SEIS. 

Comment: The lack of full-time hospitals and fire/rescue facilities in the immediate Lake Anna 

area creates a high potential for serious impacts from an accident at the project. 

(0023-20 [Goldsmith, Aviv]) 

Response: The impact of lack of full-time hospitals and fire/rescue facilities in the immediate 

Lake Anna area in the event of an accident at the NAPS site depends upon what arrangements 

the site operator has made with the medical and emergency system surrounding the plant, and 

it should be approximately the same as with the current two operating plants. The emergency 

plan was filed with Dominion's application for Unit 3. Dominion has established a certification 

letter with the Virginia Commonwealth University Medical Center (VCUMC) under which 

VCUMC will provide medical services for injured personnel from Unit 3. VCUMC has 

established a specialized area of the hospital for treatment with appropriate Health Physics 

functions, and implements a coded system to alert hospital team members. Radiation 

monitoring equipment, dosimeters, and protective clothing are available at VCUMC. VCUMC 

established and maintains the capability to evaluate the radiation exposure and/or uptake of 

accident victims and to handle contaminated victims. The approximate time to transport a 

patient to VCUMC is 75 minutes. The estimated time for local rescue squads to arrive at the 

station is 30 minutes. 

All offsite local jurisdictions have emergency response plans created in cooperation with 

Dominion to deal with off-normal events at the NAPS site. The emergency plan for Unit 3 notes 

that Dominion conducts emergency exercises in accordance with NRC and U.S. Department of 

Homeland Security (DHS) rules (e.g., 10 CFR 50.47(b)(14) and 44 CFR 350.9). These 

exercises are developed and implemented to periodically test and evaluate major portions of the 

affected emergency plans, procedures, and organizations. Unless otherwise specified, 

emergency exercises simulate an emergency that results in offsite radiological releases 

requiring response by offsite authorities. The emergency plan for Unit 3 specifically notes that 

Dominion will conduct a full participation exercise (which tests as much of the licensee, 

Commonwealth of Virginia, and risk jurisdiction emergency plans as is reasonably achievable 

without mandatory public participation) within two years before initiation of scheduled initial fuel 

loading. This exercise will include (consistent with existing DHS rules and guidance) 

participation by the Commonwealth of Virginia, State of Maryland and affected local 

governments within the plume exposure and ingestion exposure pathways emergency planning 

zones. If the full participation exercise is conducted more than one year prior to initial fuel 

loading, Dominion will conduct an exercise that tests the onsite emergency plans within one 

year before initiation of full power operations. 
Appendix E 

February 2010 E-93 NUREG-1917, SEIS 

The impact of Unit 3 on medical and emergency resources was discussed in Sections 4.5 and 

5.5 of the SEIS, and was found to be SMALL. This comment provides no new and significant 

information. Therefore no changes were made to the SEIS. 

Comment: Given that Louisa County had a population of about 25,000 in 2000 (Page 2-1 

line 42), the SDEIS conclusion that a construction work force of 5,000 would have a SMALL 

impact (Section 4.5) is unsubstantiated and suspect. (0023-25 [Goldsmith, Aviv]) 

Response: Section 4.5 of the SEIS evaluated the socioeconomic impacts of the additional 

construction workers at the proposed Unit 3 site on the surrounding community. This comment 

provides no new and significant information. Therefore, no changes were made to the SEIS 

Comment: At the ESL public hearing that I was able to attend, Lake Anna residents expressed 

concern about the aesthetics of the cooling towers. A visual simulation should be included as 

part of section 4.5.1.4 to address this concern. (0023-26 [Goldsmith, Aviv]) 

Comment: It is also my understanding that the hybrid cooling tower system is beneficial, more 

beneficial, than the previous plan, because it is a low profile cooling tower that will minimize the 

profile of the North Anna Power Station on the lake, when viewed from the lake, and also from 

the land. (0073-20 [Mullen, Dale]) 

Response: The impacts associated with aesthetics are described in Sections 4.5.1.4 and 

5.5.1.4 of the SEIS as SMALL for construction and SMALL with periodic MODERATE impacts 

during operation. The North Anna site is already an industrial site and the view of the site would 

be largely unchanged. The applicant provided visual simulation pictures of the site in Section 

5.8.2 of its ER (Dominion 2009a). Section 5.5.1.4 of the SEIS has been modified to include the 

artist's rendering of the proposed Unit 3. 

Comment: We will continue to work with Dominion, the permitting agencies, and other natural 

resource agencies to develop operating rules that avoid adverse impacts upon downstream 

resources, including recreational uses, or to mitigate unavoidable impacts. 

(0070-2 [Ewing, Amy]) 

Response: This comment is a statement of intent by the VDGIF, and does not recommend any 

analysis. Therefore, no changes were made to the SEIS. 

Comment: One thing else that we need to look at here, is the impacts on the school system 

during construction. During units 1 and 2, and 3 and 4 were canceled, we had a significant 

impact here in Louisa County in which the 25 percent increase in the school system. Our school 

board has already brought this issue up, and they are still calling this a small impact, 25 percent 

increase in students, without an increase in revenue. How are we going to pay for this? Our 

Board of Supervisors, unfortunately, has not been forward looking, and we are not prepared for 

what -- we can't even get the next school built. So we've got problems right here. 

(0082-12 [Rosenthal, Jerry]) 
Appendix E 

NUREG-1917, SEIS E-94 February 2010 

Response: This comment is a statement apparently disputing the impact level assigned to 

education. The commenter asserts that Louisa public schools had a 25 percent increase in 

enrollment during construction of Units 1 and 2 and expects this same increase to happen with 

the construction of Unit 3, which may or may not occur in part due to whether the construction 

workforce decides to commute to the worksite or move to the area. This statement has been 

examined and a determination was made that while the information is new, it does not increase 

the level of impact to LARGE, and therefore is not significant information in light of estimates 

previously made of the potential impact of construction of the proposed NAPS Unit 3 on 

education. The comment also referred to the situation in mid-2008. As of summer 2009, the 

new 700-student Moss-Nuckols Elementary School was under construction and consideration 

was being given to renovation or replacement of the older Thomas Jefferson Elementary 

School. 

Comment: [DSEIS Section] 4.5.4.5 Education: Editorial. Change "construction" to "construct". 

(0084-22 [Grechek, Eugene]) 

Response: Section 4.5.4.5 of the SEIS was modified as suggested. 

Comment: The correct nearest population center with more than 25,000 residents is 

Charlottesville (Fredericksburg's population is less than 25,000). The US Census Bureau 

website lists the population of the city of Fredericksburg, VA as 22,410 for 2007 (access date 

1/12/09). (0084-4 [Grechek, Eugene]) 

Response: Section 2.1 of the SEIS has been modified to reflect the change requested in the 

comment. 

Comment: DSEIS Sections 4.5.1.3 and 5.5.4.1 cite an estimated construction workforce of 

25003000. This is inconsistent with the COLA-ER new and significant evaluation as well as 

other sections of the DSEIS (Section 4.5 and 4.5.3), which cite an estimated construction 

workforce of 2500-3500. Dominion suggests the construction workforce be characterized as 

2500-3500. (0084-21 [Grechek, Eugene]) 

Response: Sections 4.5.1.3 and 5.5.4.1 of the SEIS were modified to reflect that the 

construction workforce will be 2500 to 3500 workers. 

10. Comments Concerning Historic and Cultural Resources 

Comment: In addition, our review of the Virginia Department of Historical Resources Data 

Sharing System (VDHR DSS) indicates that the proposed work may affect cultural resources. 

These resources may eligible for listing on the National Register of Historic Places (enclosed 

maps) and may be subject to compliance with Section 106 of the National Historic Preservation 

Act of 1966. 
Appendix E 

February 2010 E-95 NUREG-1917, SEIS 

According to 36 CFR 800.2(a) (2): 

"... lf more than one Federal agency is involved in an undertaking, some or all [oj] the agencies 

may designate a lead Federal agency, which shall identify the appropriate official to serve as the 

agency official who shall act on their behalf, fulfilling their collective responsibilities under 

section 106. Those Federal agencies that do not designate a lead Federal agency remain 

individually responsible for their compliance with this part." 

Pursuant to the above provision, the United States Nuclear Regulatory Commission (USNRC) is 

hereby designated as the lead federal agency to fulfill the collective Federal responsibilities 

under Section 106 for the. North Anna Power Station Unit 3, if the USNRC determines an 

adverse effect on historic resources: 

The Corps authorizes the USNRC to conduct Section 106 coordination on its behalf. If a 

Memorandum of Agreement is required by USNRC, under 36 CFR 800.6, the following clause 

should be included in the introductory text: 

"WHEREAS, pursuant to Section 404 of the Clean Water Act, a Department of the Army permit 

will likely be required from the Corps of Engineers for this project, and the Corps has designated 

USNRC as the lead federal agency to fulfill federal responsibilities under Section 106; and 

Any work in these areas may require authorization by state and local agencies. Thank you for 

providing us the opportunity to provide early comment on the project. 

(0009-6 [Bronson, Regena])

Response: As outlined in 36 CFR 800.8, Coordination with the NEPA, the NRC coordinated 

compliance with Section 106 of the National Historic Preservation Act of 1966 in meeting the 

requirements of NEPA for the proposed North Anna Unit 3. The impacts to historic and cultural 

resources are addressed in Sections 4.6, 5.6 and 7.6 of the SEIS. The comment provides no 

new and significant information. Therefore, no changes were made to the SEIS. 

Comment: We find that the DSEIS accurately reflects consultation to date and adequately 

addresses our concerns. We strongly support commitments made by Dominion Virginia Power 

in Section 4.6 of the DSEIS which will provide for the continued consideration and protection of 

historic properties. If the NRC and Dominion are unable or unwilling to abide by these 

commitments, additional consultation on the impacts of the COL on historic properties will be 

necessary. Provided the commitments are met, we find that a determination of no adverse 

effect to historic properties is appropriate. (0014-1 [Kirchen, Roger]) 

Comment: DHR finds that the SEIS accurately reflects consultation to date and adequately 

addresses agency concerns. DHR strongly supports Dominion's commitments in the SEIS 

(section 4.6) which will provide for the continued consideration and protection of historic 

properties. 
Appendix E 

NUREG-1917, SEIS E-96 February 2010 

13(c) Requirement. If the NRC and Dominion are unable or unwilling to abide by the 

commitments, additional consultation on the impacts of the COL on historic properties will be 

necessary pursuant to Section 106. 

13(d) Conclusion. Provided the commitments are met, DHR finds that a determination 

(0069-48 [Irons, Ellie]) 

Comment: We have received from the Nuclear Regulatory Commission (NRC) the draft 

Supplemental Environmental Impact Statement (DSEIS) referenced above. We find that the 

DSEIS accurately reflects consultation to date and adequately addresses our concerns. We 

strongly support the commitments made by Dominion Virginia Power in Section 4.6 of the 

DSEIS which will provide for the continued consideration and protection of historic properties. If 

the NRC and Dominion are unable or unwilling to abide by these commitments, additional 

consultation on the impacts of the COL on historic properties will be necessary. Provided the 

commitments are met. we find that a determination of no adverse effect to historic properties is 

appropriate. (0071-1 [Kirchen, Roger]) 

Response: These comments provide information that supports the NRC staff's independent 

analysis. These comments provide no new and significant information. Therefore, no changes 

were made to the SEIS. 

Comment: The Tuscarora Nation is listed twice in Section 2.9.3. The Tuscarora Nation is listed 

as consulted in association with the COL and is listed under "additional six groups added to this 

list." Appendix B (Organizations Contacted) lists the Tuscarora Nation and the Tuscarora Indian 

Tribe; however the Tuscarora Indian Tribe is not listed in Section 2.9.3. Dominion suggests the 

NRC clarify its listing between both the Nation and Tribe. 

(0084-16 [Grechek, Eugene]) 

Response: Section 2.9.3 of the SEIS was modified to reflect that the Tuscarora Nation was 

consulted. 

Comment: [In DSEIS Section 4.10 on discovery of potential historic or cultural resources] 

Dominion suggests changing the word "Natural" to "Historic" to revise the reference to the 

Virginia Department of Historic Resources. (0084-24 [Grechek, Eugene]) 

Response: Section 4.10 of the SEIS was modified as suggested. 

Comment: In briefly looking over the report, we disagree with the findings that no significant 

historical or archaeological resources will be impacted (0013-2 [Brown, Kevin]) 

Comment: Anything that effects those [North and South Anna] rivers has a direct impact on our 

lives and our culture. (0013-3 [Brown, Kevin]) 

Comment: An in-depth TCP mitigation is warranted, and we are asking to be a consultant party 

in that mitigation. (0013-4 [Brown, Kevin]) 
Appendix E 

February 2010 E-97 NUREG-1917, SEIS 

Comment: In briefly looking over the report, I would strongly disagree with the findings that no 

significant historical or archaeological resources will be impacted. (0073-12 [Brown, Kevin]) 

Comment: We the Pamunkey Indians have lived, fished and hunted on the shores of the 

Pamunkey River for thousands of years. The headwaters of our river are the North and South 

Anna. Anything that affects those rivers has a direct impact on our lives, and our culture. An 

in-depth traditional culture and property mitigation is warranted, and we are asking to be a 

consultant party in that mitigation. (0073-13 [Brown, Kevin]) 

Response: This and other related cultural resources issues were resolved through a 

government-to-government meeting between the NRC and the Pamunkey Tribal Government. 

The meeting summary is available in the NRC Agency-Wide Document Management System 

(ADAMS) under Accession Number ML093500380/ In addition, the SEIS was modified in 

Sections 2.9 and 5.4.2.4 to include information as a result of the meeting..

11. Comments Concerning Environmental Justice 

Comment: We need to design a truly permanent systems that efficiently replenish themselves, 

and build --sorry, it is -- it is kind of hard to talk about environmental justice with so much money 

in my pockets. So I'm just going to have to leave it at that, sorry. You guys deal with it 

yourselves. (0081-2 [Oyok, Louis]) 

Response: The comment is noted. Environmental Justice refers to a Federal policy under 

which each Federal agency identifies and addresses, as appropriate, disproportionately high 

and adverse human health or environmental effects of its programs, policies, and activities on 

minority and low-income populations. The SEIS discusses impacts on low-income or minority 

populations in Sections 4.6 and 5.6. The comment provides no new and significant information. 

Therefore, no changes were made to the SEIS. 

Comment: [DSEIS Sec 1.10, 4.7, 5.7] NRC added a different data parameter in the DSEIS for 

the COL (minority and low-income populations in counties). The FEIS and ER for the ESP 

presented data on minority and low-income populations in Census Bureau Census Year 2000 

block groups in accordance with NRC guidance (NUREG-1555 and LIC-203). The county-based 

data cannot be accurately called new data because it has no relevance to minority and lowincome populations as defined in the ESP SEIS; the county-level amalgamation would mask 

any change at a block-group level. The two data sets, the county-based and census blockbased, are not comparable because multiple block groups make up counties and not all block 

groups contain minority or low-income populations. Dominion suggests NRC consider indicating 

that the ESP outreach revealed no discrepancy between minority and low-income information at 

that time, 2006, and that information gathered since that time does not indicate a substantial 

change. (0084-17 [Grechek, Eugene]) 

Response: The county-level population estimates of minority populations are a useful general 

indicator of the growth in these populations and can accurately be called new data. It is not 
Appendix E 

NUREG-1917, SEIS E-98 February 2010 

significant because, as the commenter noted, the new data did reveal any substantive changes. 

Minor changes have been made to the wording of Sections 2.10, 4.7, and 5.7 of the SEIS. 

12. Comments Concerning Health – Nonradiological 

Comment: The health and safety of those who recreate on and near Lake Anna need to be 

addressed due to possible contaminates. Lake Anna has been shown to have Naegleria fowleri

traces on both the hot and cold side of the lake. This new finding has not been discussed in the 

DSEIS. The DSEIS discusses the Clean Air Act Section 169A and 40 CFR Part 51, Subpart P 

as effect on local air quality levels as negligible. This did not include “Legion Ella [sic.] bacteria” 

some of which are immune to biocides. The potential for airborne and waterborne contaminates 

needs to be sorted out by the NRC and VDEQ. (0018-4 [Remmers, Ken]) 

Comment: The health and safety of those who recreate on or near Lake Anna need to be 

addressed due to possible contaminants. Lake Anna has been shown to have NF [Naegleria 

fowleri] traces on both the hot and cold side of the lake. (0073-38 [Remmers, Ken]) 

Response: Public health associated with the use of Lake Anna and the potential for 

microorganisms to affect the health and safety of the public was evaluated in Section 5.8.1 of 

the SEIS. A recent study was in the process of being published at the same time the draft SEIS 

was published, but the authors of the study shared their findings with the NRC staff for inclusion 

in the draft SEIS (see the reference for Jamerson et al. 2008). The staff concluded that, based 

on the results of the Jamerson et al. study and other published literature and discussions with 

state health officials and experts in the field, there currently is an extremely low level of risk 

associated with contracting primary amoebic meningoencephalitis from exposure to N. fowleri, 

and that impacts related to operation of Unit 3 will not measurably change the risk to the public. 

While there are no specific Federal regulations addressing disease-causing organisms in 

cooling towers or thermal effluents, 40 CFR 141.70 regulates maximum contaminant levels of 

various microorganisms, including Legionella spp., in public drinking water systems (NRC 

2000). However, standard practices for operating cooling towers include adding biocides to the 

water to limit growth of microorganisms inside the towers and providing appropriate protective 

equipment for workers who enter the cooling towers for maintenance operations. Biocides in 

the water sources for the cooling towers would limit microbial growth at the source, and 

minimize the potential for any aerosol releases. The distance from the cooling towers to the site 

boundary provide an additional measure of safety to members of the public. The use of 

biocides in various water systems for Unit 3 is discussed in Section 3.2.4.1 of the SEIS. 

Additional information was added to Section 5.8.1 to address Legionella spp. 

Comment: We MUST put health first--the health of all of us living in Central Virginia now and in 

the future, the health of all the wildlife that would be affected by this decision, and the health of 

the natural world that we live in and want to preserve for future generations. It would be 

irresponsible to move forward with this third reactor. (0055-2 [Shamaiengar, Beth]) 
Appendix E 

February 2010 E-99 NUREG-1917, SEIS 

Response: Health impacts to the public and workers, as well as to the terrestrial and aquatic 

environments, associated with the construction and operation of the proposed Unit 3 was 

evaluated in the ESP EIS (NRC 2006a), and new and significant information was reviewed and 

evaluated in the draft COL SEIS. NRC staff found through the NEPA process that the 

procedures and plans for compliance with Federal and State regulations associated with 

protection of human health and the environment were disclosed and potential impacts would be 

SMALL as outlined in Sections 4.8, 4.9, 5.8, and 5.9 of the SEIS. This determination means 

that "... environmental effects are not detectable or are so minor that they will neither destabilize 

nor noticeably alter any important attribute of the resource". The comment provides no new and 

significant information. Therefore, no changes were made to the SEIS. 

Comment: Any structures being demolished, renovated, or removed, should be checked for 

asbestos-containing materials (ACM) and lead-based paint (LBP) prior to demolition. If ACM or 

LBP are found, in addition to the federal waste-related regulations mentioned above, state 

regulations 9VAC 20-80-640 for ACM and 9VAC 20-60-261 for LBP must be followed. 

(0069-42 [Irons, Ellie]) 

Response: There are no plans to demolish, renovate, or remove any existing structures to 

construct the proposed Unit 3. There are no plans to use hazardous materials such as 

asbestos in the construction of Unit 3 (see Section 10.5 of the SEIS). As stated in Section 1.5 

of the SEIS, prior to construction and operation of the new unit, Dominion will be required to 

hold certain Federal, State, and local environmental permits, as well as meet applicable 

statutory and regulatory requirements. This comment provides no new and significant 

information. Therefore, no changes were made to the SEIS. 

Comment: 

The DEQ Waste Division recommends the following: 

• Access the following website to locate additional information on hazardous waste and 

solid waste sites using their identification numbers: 

http://www.epa..ov/superfund/sites/cursites/index.htm or. 

• Implement pollution prevention principles, including the reduction, reuse, and recycling 

of all solid wastes generated. All generation of hazardous wastes should be minimized 

and handled appropriately. 

8(f) Requirement. If the construction of this project will include the use of portable fuel AST(s) 

with a capacity of greater than 660 gallons, the tank(s) must be registered with DEQ using AST 

RegistrationForm 7540-AST. 

(0069-43 [Irons, Ellie]) 

Response: This comment is a specific recommendation directed at the applicant by the VDEQ. 

Plans for the use of hazardous and solid waste associated with the proposed Unit 3 are 
Appendix E 

NUREG-1917, SEIS E-100 February 2010 

addressed in Section 3.2.4 of the SEIS. The applicant has indicated that specific plans for 

construction and operations associated with fuel and waste will comply with appropriate State 

and Federal regulations. The comment provides no new and significant information. Therefore, 

no changes were made to the SEIS. 

Comment: DEQ recommends that the use of herbicides or pesticides for construction or 

landscape maintenance should be in accordance with the principles of integrated pest 

management. The least toxic pesticides that are effective in controlling the target species 

should be used. Contact the Department of Agriculture and Consumer Services at 

(804) 786-3501 for more information. (0069-44 [Irons, Ellie]) 

Response: This comment is a specific recommendation to the applicant by the VDEQ. The 

applicant has indicated that specific plans for the use of herbicides or pesticides associated with 

construction and operation of the proposed Unit 3 will comply with appropriate State and 

Federal regulations. The comment provides no new and significant information. Therefore, no 

changes were made to the SEIS. 

Comment: [DSEIS Section] 4.8.2 Noise: Editorial: Change dBz to dBA. Note the 65 dBA limit 

applies to plant operation, not construction activities. (0084-23 [Grechek, Eugene]) 

Response: Section 4.8.2 of the SEIS was modified as suggested. 

13. Comments Concerning Health – Radiological 

Comment: The goal of the radionuclide emission standard is to limit the lifetime risk of induced 

fatal cancer to a maximally exposed individual. The implementing regulations translate this into 

a maximum individual exposure of 10 millirem/year for airborne emissions that result in 

exposure through any environmental pathway [10 CFR 50, App I]. A recent meta-analysis of 

leukemia found that the majority of these studies detected higher rates of cancer in children 

living around nuclear facilities [BAKER P.J. & HOEL D.G. (2007) European Journal of Cancer 

Care 16, 355–363, Meta-analysis of standardized incidence and mortality rates of childhood 

leukaemia in proximity to nuclear facilitie]. The analysis concluded: The meta-analysis 

combined and statistically analysed studies of childhood leukaemia and nuclear facilities. Focus 

was on studies that calculated standardized rates for individual facilities. Due to variability 

between study designs, eight separate analyses were performed stratified by age and zone. 

One hundred and thirty-six sites were used in at least one analysis. Unadjusted, fixed effects 

and random effects models were used. Metarates greater than one were found in all models at 

all stratification levels often achieving statistical significance. Caution must be used when 

interpreting these results. The meta-analysis was able to show an increase in childhood 

leukaemia near nuclear facilities, but does not support a hypothesis to explain the excess. Eac 

htype of model utilized has limitations. Fixed effects models give greater weight to larger 

studies; however, population density may be a risk factor. Random effects models give greater 

weight to smaller studies that may be more likely to be affected by publication bias. A limitation 

of the overall study design is that standardized rates must be available for individual sites which 

led to exclusion of studies that only calculated rates for multiple sites and those that presented 
Appendix E 

February 2010 E-101 NUREG-1917, SEIS 

other statistical methods. Further, dose-response studies do not support excess rates found 

near nuclear facilities. However, it cannot be ignored that the majority of studies have found 

elevated rates, although not usually statistically significant. (0024-7 [Zeller, Lou]) 

Response: 10 CFR Part 50, Appendix I provides design objectives for new reactor designs to 

meet the As Low As Is Reasonably Achievable philosophy for radioactive material in reactor 

effluents. The design objective for estimated annual air dose to an individual in an unrestricted 

area from gaseous effluents is 10 millirads for gamma radiation or 20 millirads for beta radiation. 

The design objective for estimated annual dose to an individual from liquid effluents is 3 mrem 

to the total body or 10 mrem to any organ. The dose limit for the public from operation of a 

reactor is 100 mrem (total effective dose equivalent) annually as specified in 10 CFR 20.1301. 

The licensee must also comply with EPA’s environmental radiation standards in 40 CFR 

Part 190 which are 25 mrem annually to the whole body, 75 mrem annually to the thyroid, and 

25 mrem annually to any other organ. 

The Baker and Hoel article (Baker and Hoel 2007 provided a summary of past childhood 

leukemia studies around nuclear facilities. The authors identified that past studies have found 

elevated rates of childhood leukemia around nuclear facilities but that most were not statistically 

significant. They also noted that “... there is a question as to whether the amount of exposure 

received by children living near nuclear sites is sufficient to increase risk.” The referenced study 

has been reviewed by the NRC staff and it does not provide conclusive evidence of increased 

incidences of cancer at low dose rates. That is, the study reports an increased rate of cancer 

near particular nuclear facilities, but cannot and does not demonstrate a causal relationship 

between nuclear facilities and elevated incidences of cancer. This comment provides no new 

and significant information. Therefore, no changes were made to the SEIS. 

Comment: My final comments will be based on Professor Chris Busbee at the University of 

Liverpool, commenting on the waste, the high levels of radioactivity dumped into the Irish sea 

from Sellafield, which is the largest nuclear reprocessing plant in the world. 

The tidal mudflats in Kirkibright Bay in Scotland, discovered Celsium isotopes in the soil that 

were twice the levels of expected radiation, and pointed to the presence of plutonium. 

Near Sellafield childhood cancer in North Wales was ten times in excess of childhood leukemia 

and non-hodgkin's lymphoma in children birth to four years living near the plant. 

These studies were confirmed by independent epidemiological analyses. Nevertheless the 

authorities continued to refuse to accept that there is a causality. (0080-5 [Young, Emerald]) 

Response: The Sellafield site in the United Kingdom has a long history. An October 1957 fire 

in a graphite-moderated, air-cooled reactor on the site released substantial radioactive material 

into the environment. This was one of the original reactor designs, and it had few of the safety 

features found in modern day light-water reactors. Section 3.2 of the SEIS provides a brief 

description of the ESBWR safety systems. Some of the radioactive material in the environment 

discussed in the above comment may have been as a result of the 1957 fire. The Sellafield site 
Appendix E 

NUREG-1917, SEIS E-102 February 2010 

also has been home to several fuel reprocessing facilities used to extract uranium and 

plutonium from spent fuel. Routine effluents from these facilities have also been released to the 

environment over the past approximate 50 years. 

Absent specific reference to a particular report, it is difficult to respond to concerns about 

leukemia and lymphoma rates near the Sellafield site and how it relates to this COL application 

for an ESBWR at the NAPS site. A review study of past childhood leukemia studies around 

nuclear facilities performed by Baker and Hoel (2007) did include several cancer and leukemia 

epidemiological studies from around the Sellafield site. The authors identified that past studies 

have found elevated rates of childhood leukemia around nuclear facilities but that most were not 

statistically significant. They also noted that “there is a question as to whether the amount of 

exposure received by children living near nuclear sites is sufficient to increase risk.” The 

referenced study has been reviewed by the NRC staff and it does not provide conclusive 

evidence of increased incidences of cancer at low dose rates. That is, the study reports an 

increased rate of cancer near particular nuclear facilities, but cannot and does not demonstrate 

a causal relationship between nuclear facilities and elevated incidences of cancer. This 

comment provides no new and significant information. Therefore, no changes were made to the 

SEIS. 

Comment: The BEIR VII Committee published morbidity and mortality data in 2006 which 

show that children have a significantly higher risk of developing cancer from radiation than 

adults do and women have a higher risk of radiation-induced cancer than men do. BEIR VII 

found that a lifetime dose of one million person-rem results in a cancer incidence rate of 900 for 

men and 1370 for women; mortality rates for the same dose are 480 and 660 for men and 

women, respectively. Ref: Richard R. Monson (Chair) et al. Health Risks from Exposure to Low 

Levels of Ionizing Radiation: BEIR VII Phase 2. Committee to Assess Health Risks from 

Exposure to Low Levels of Ionizing Radiation, Board on Radiation Effects Research, National 

Research Council of the National Academies. Washington, DC: National Academies Press, 

2006 (0024-8 [Zeller, Lou]) 

Response: The Biological Effects of Ionizing Radiation (BEIR) VII report (National Research 

Council 2005) estimated that a group of 100,000 men exposed to 10 rads would results in 

900 men developing solid cancers or leukemia during their lifetime with 480 fatalities. A group 

of 100,000 women exposed to 10 rads would result in 1370 women developing solid cancers or 

leukemia during their lifetime with 660 fatalities. The total lifetime collective dose for the 

100,000 men or women would be 1 million person-rem. This comment reflects a statement of 

fact, but does not provide new information about the proposed project and will not be evaluated 

further. Accordingly, no changes were made to the SEIS as a result of the comment.

Comment: Based on these data, the operation of Unit 3at NAPS could place additional 

numbers of children at risk from airborne radiation exposure. The draft SEIS does not 

adequately assess airborne radionuclide impacts around the North Anna Power Station. 

(0024-9 [Zeller, Lou]) 
Appendix E 

February 2010 E-103 NUREG-1917, SEIS 

Response: The SEIS for the North Anna COL does address airborne radionuclide impacts 

from the proposed Unit 3 in Sections 5.9.2.2 and 5.9.3.2. Table 5-5 provides dose estimates to 

the maximally-exposed individual including the child and infant at the following locations: 

nearest site boundary, nearest garden, nearest residences, and nearest meat cow. The doses 

to the maximally exposed individual were less than the 10 CFR Part 50 Appendix I design 

objectives. Population doses were discussed in Section 5.9.3.2 and include dose contribution 

from children within an 80-km (50-mi) radius of the plant. The population dose from the 

proposed Unit 3 was bounded by the estimated population dose for the proposed ESP units. 

These comments provide no new and significant information. Therefore, no changes were 

made to the SEIS. 

Comment: Illinois has more nuclear reactors than any other state, it has 11 active. And there 

were a panel of experts who commented on emissions. I will read some of the comments. This 

is from Paul Gunther, who is the Director, or was the Director at that time, of Reactor Watchdog, 

a project of Nuclear Information Resource Services. Radioactive releases into the air and water 

routinely occur with nuclear power station operations. They occur as continuous emissions, and 

batch releases. A large portion of these radioactive releases are radioactive for intervals of 

seconds, minutes, days. Other radioactive isotopes can deliver harmful exposures for months, 

years, or even millions of years. As released radioactive gases decay, some form particulate 

matter, and join other persistent radioactive isotopes as fallout deposited on land and water. 

These long-lived isotopes persist and accumulate in the environment, and then biomagnify up 

the food chain. With no known safe threshold for radiation exposure, the prohibition of radiation 

releases is not unreasonable to demand, particularly considering that the developing fetus and 

children are the most vulnerable to radiation exposures. 

(0080-1 [Young, Emerald]) 

Response: As discussed in Sections 2.5 and 5.9.6 of the SEIS, Dominion has an established 

Radiological Environmental Monitoring Program (REMP) for Units 1 and 2. The NRC staff 

determined that this program would be adequate to establish the radiological impacts to the 

environment related to the construction and operation of the proposed Unit 3 at the NAPS site. 

As part of the REMP, Dominion will sample, measure, analyze, and monitor the radiological 

impact of reactor operations on the following pathways: direct radiation, atmospheric, aquatic, 

and terrestrial. Results of the REMP are summarized each year in an Annual Environmental 

Radiological Operating Report. Effluent releases are summarized annually in an Annual 

Radioactive Effluent Release Report. In addition, as discussed in Section 2.5 of the SEIS, the 

Virginia Department of Health has a radiological environmental monitoring program in the 

vicinity of the NAPS site. The State program samples airborne particulates, fish, milk, shellfish, 

silt, surface water, and vegetation. The purpose of the environmental monitoring programs 

undertaken by Dominion and the Commonwealth of Virginia is to detect any gradual buildup of 

radioactive materials from plant operations. No changes were made to the SEIS as a result of 

this comment. 

Comment: Tritium has not been discussed. (0082-15 [Rosenthal, Jerry]) 
Appendix E 

NUREG-1917, SEIS E-104 February 2010 

Response: Tritium was discussed in detail in the ESP EIS (NRC 2006a). As discussed in 

Section 5.9.1 of the SEIS, the estimated annual gaseous and liquid effluent releases from the 

ESBWR design proposed for Unit 3 are expected to be significantly less than the tritium 

releases evaluated in the ESP EIS using the plant parameter envelope approach. The ESP 

evaluation for tritium bounded the COL evaluation. The staff calculated doses to the maximally 

exposed individual and the population dose with the revised liquid and gaseous tritium source 

term in Section 5.9.2 of the COL SEIS. Sections 2.5 and 5.9.6 of the COL SEIS discuss the 

additional tritium groundwater monitoring being performed around Units 1 and 2 and proposed 

groundwater monitoring for Unit 3 in response to the tritium groundwater protection initiative. 

This comment does not provide any new and significant information about the project. 

Therefore, no changes were made to the SEIS. 

Comment: Here at North Anna, my children grew up here, and I just wanted -- we have never, 

I have not known anybody that has ever achieved any cancer rate, or any other type that was 

outside the norm for a population of this size. I also am a medical technologist, so I know a lot 

about that type of demographics. And there really is no increase when you look at the overall 

between the population expansion and the diseases. (0082-25 [Harte, Vicky]) 

Response: This comment does not provide any new and significant information about the 

proposed project. Therefore, no changes were made to the SEIS. 

14. Comments Concerning Accidents – Severe 

Comment: Section 5.10 should include a worst case analysis for low-probability events. 

(0023-40 [Goldsmith, Aviv]) 

Response: Consistent with the general NEPA philosophy that environmental reviews 

contain realistic estimates of impacts, the Commission in its safety goals policy statement 

(51 FR 30028) has adopted the use of mean estimates rather than worst-case estimates 

of accident risks. The staff addressed the impacts of design basis and severe accidents in 

Chapter 5 of its SEIS. Design basis and severe accidents will also be addressed in the staff's 

SER for certification of the ESBWR reactor design and the construction and operation of an 

ESBWR at the NAPS site. No changes were made to the SEIS as a result of this comment. 

Comment: The statement on page 5-69 line 40 that "alternatives to mitigate severe accidents 

are not resolved" is incongruous with the SMALL impact determination. Since the ESP is 

designed to address site-specific issues, these must be resolved now, not at the COL stage as 

is suggested by page 5-70 line 2. (0023-42 [Goldsmith, Aviv]) 

Response: The submitted comment refers to the draft ESP EIS (NRC 2006b) and is a request 

that specific analyses be conducted during the ESP stage. The ESP stage is completed; 

however, the requested analyses for severe accident mitigation alternatives were completed for 

the COL stage and are described in Section 5.10.3 and Appendix M of the SEIS. This comment 

provides no new and significant information. Therefore, no changes were made to the SEIS. 
Appendix E 

February 2010 E-105 NUREG-1917, SEIS 

Comment: A common-language summary of section 5.10.2 is required. 

(0023-41 [Goldsmith, Aviv]) 

Response: The submitted comment refers to draft ESP EIS NRC 2006b). The ESP stage is 

completed; comments received on the draft ESP EIS were considered in the final ESP EIS 

(NRC 2006a), published in December 2006. For the present COL environmental review, the 

impacts of postulated accidents were evaluated in Section 5.10. This comment provides no 

new and significant information. Therefore, no changes were made to the SEIS. 

Comment: The concern is that that is going to exponentionally increase the risks of accidents. 

And we only have to look at the most recent disaster in Tennessee, regarding ash coal, to see 

that there are projects which simply aren't based on sound science. 

(0081-4 [Au Clair Valdez, Miguel]) 

Response: Section 5.10 and Appendix M of the SEIS discuss the postulated accidents that the 

NRC staff evaluated and the mitigation alternatives considered. The accident risks are reported 

on an annual basis assuming a 40-year reactor lifetime. Aging aspects of the reactor would be 

specifically addressed in the safety review of any license renewal application submitted for 

operation beyond the first 20 years and is outside the scope of the environmental review. The 

comment provided no new and significant information; therefore, no changes were made to the 

SEIS. 

Comment: Section 5.10 is hard to understand the possible radiation impacts from an 

emergency. Given that "radiation experts conservatively assume that any amount of radiation 

exposure may pose some risk of causing cancer or a severe hereditary effect", a common 

language summary is required that clearly sets out expected radiation impacts in the study area. 

(0023-37 [Goldsmith, Aviv]) 

Comment: Please clarify the statements in page SDEIS 5-57 line 35 et. seq. Does the SDEIS 

say that the project would create "730 fatal cancers, nonfatal cancers, and severe hereditary 

effects per 10,000 person"s? (0023-38 [Goldsmith, Aviv]) 

Response: The submitted comments refer to draft ESP EIS (NRC 2006b). Dominion was 

issued an ESP permit (ESP-003) in November 2007 for two units at the NAPS site under the 

specifications contained in that permit (NRC 2007). The information presented in the ESP EIS 

is resolved. These comments provide no new and significant information. Therefore, no 

changes were made to the SEIS. 

15. Comments Concerning the Uranium Fuel Cycle 

Comment: In 1984 the NRC had expressed "confidence" that the problem of high level waste 

disposal would be resolved in 30 years. This has not happened ---Yucca Mt. is unlikely to ever 

open. (0004-2 [Abbott, Diana]) (0006-4 [Neale, Laura]) 
Appendix E 

NUREG-1917, SEIS E-106 February 2010 

Comment: I remember when the Nuclear Power Plant was constructed at Lake Anna, and 

many of us had concerns about long term disposal of spent fuel cartridges. There is still no 

satisfactory long term solution to the this problem. Yucca Mountain is not going to work out. 

Sending fuel cartridges into Space is not going to work out. (0006-1 [Neale, Laura]) 

Comment: The semi-permanent storage of radioactive waste at the North Anna site presents 

health and safety threats to the thousands of people of central Virginia. 

(0011-4 [Abbott, Diana] [Abbott, William] [Ahlgrim, Larry] [Alexander, Mary] [Alexander, Mary] 

[Alexander, Nancy] [Allen, Connie] [Antoniewicz, Susan] [Appleby, Monica] [Apple, Joe] [Arens, 

Jordan] [Artemis, Diana] [Bailey, Marcia] [Baird, Heidi] [Bandita, Gypsy] [Biggs, Amy] 

[Bockstiegel, Dorothy] [Boissonnault, James] [Bolduc, Joan] [Brackett, Carl] [Bradshaw, Claude] 

[Brown, E] [Brummer, Ann] [Burtner, Caryl] [Burt, William] [Butcher, Ava] [Churray, Richard] 

[Clark, Diane] [Clark, Loralee] [Clark, Loralee] [Clark, Theda] [Cleary, Thomas] [Collingwood, 

Claudia] [Cook, Joe] [Cowles, Virginia] [Cummings, Russell] [Currie, Susan] [Dail, Michelle] 

[Daiss, Becky] [Davies, Beth] [Day, Elena] [De Trinis, Bonita] [Deming, Jill] [Desimone, John and 

Shirley] [Dickon, Elisa] [DiMarco, Paul] [D'Onofrio, Adam] [Dukovich, John] [Dunbar, Mary] 

[Ebert, Paul] [Farnham, Ross] [Fasceski, Jeffrey] [Feury, Patricia] [Figg, Landon] [Fiscella, 

Glenn] [Ford, Betty] [Franke, John] [Frank, Sarah] [Frantz, Norma] [Fritzler, Deb] [Gaige, Eve] 

[Galindo, Ted and Carolyn] [Gann, Sara] [Gignac, David] [Grant, Mary] [Hall-Bodie, Adrienne] 

[Ham, Elspeth] [Hamilton, Jim and Donna] [Hanger, Jane] [Hanks, Lou] [Harpole, Thane] 

[Hartwig, Kristina] [Heegaard, Flemming] [Heflin, Kerby] [Heim, Anka] [Hepburn, Chet] [Hess, 

David] [Hinkle, Carol] [Hodge, Mary] [Hoehlein, Jill] [Hoffman, Lilli] [Holtzback, Kaite] [Horwege, 

Richard] [Houston, Karin] [Hutchinson, Amber] [Jaronczyk, Ellen] [Jewell, B] [Johns, Brian] 

[Josaitis, Marvin] [Kalukin, Andrew] [Keyser, Liz] [Kiehl, Allison] [Kosch, Sandra] [Kroupa, 

Brenda] [Kunkel, Christopher] [Larsen, Anne] [Larsen, Janice] [Laverdiere, Dorothy] [LeClair, 

Carol] [Leon, Matea] [Light, John] [Liske, Patricia] [Lloveras, Lang] [Lufkin, Heather] [Maddox, 

Joshua] [Marroni, Edmond] [McDonald, Kim] [McFarland, Mary Ann] [McNeal, Ashby] [Meredith, 

Betty] [Meyer, Jennifer] [Miles, Linda] [Miller, Katelyn] [Miller, Lara] [Miller, Mary] [Mullinax, 

Franklin] [Neale, Laura] [Newell, Vicky] [Payne, Andrew] [Phillips, Donna] [Pintado, Isabel] 

[Plaskett, Micheline] [Plata, Errol] [Presgraves, Sandra] [Presley, Diann] [Rasmussen, Angela] 

[Reiner, Brian] [Rigby, John] [Roadcap, Leah] [Roadcap, Leah] [Robbins, Patricia] [Rollins, 

Megan] [Roth, David] [Schmidt, Arthur] [Scott, Patricia] [Shamaiengar, Beth] [Shelton, Charles] 

[Shields, Page] [Sklar, Scott] [Smith, John] [Smith, Louise] [Squires, George] [Steegmayer, 

Andrea] [Stone, Eric] [Sumrall, Kamar] [Suter, Emanuel] [Tanner-Sutton, Linda] [Tarr, Suzanne] 

[Teeler, Sharon] [Testerman, Michael] [Traub, Charles] [Van Lingen, Gabriele] [Wells, Cathy] 

[Werderman, Kim] [White, Eric] [White, Phyllis] [Whitfield, Doris] [Williams, Martha] [Wilson, 

Brian] [Wilson, Brian] [Witting, Marjorie] [Woitte, Roger]) 

Comment: This is to make a request and comment on the third nuclear reactor at the North 

Anna Power Station in Lousia [sic] County, Virginia. It is requested that the permit and license 

for the proposed Unit III reactor include making the existing and expanded site a declared and 

dedicated permanent site for spent nuclear fuel storage that is produced in Virginia. That the 

spent fuel from the existing two units at North Anna and other units in Virginia is being stored on 

site is an established fact. The fact of the spent fuel from the proposed third unit is to be stored 

on site has been stated. It is well known and accepted from the beginning of the nuclear power 
Appendix E 

February 2010 E-107 NUREG-1917, SEIS 

generation age that this magic power source was stated to be “so cheap that the only cost 

would be the cost of distribution and metering.” The Nuclear Regulatory Commission (NRC) and 

the nuclear electric power industry have continued to view the spent fuel as a no cost problem 

that the U.S. Congress will dispose of. It is suggested that the good people of Lousia [sic] 

County and Virginia are the immediate beneficiaries of this cheap nuclear power and it is only 

fair that these good people be provided with the employment from operating the permanent 

storage site for the hundreds of generations into the future. The inclusion of making the North 

Anna site a permanent storage site should be written into the permit. 

(0021-1 [Jones, Dale]) 

Comment: Given the current administration's statements that the Yucca Mountain waste 

repository will not be developed, it is imprudent to approve a COL or consider an EIS without a 

waste solution as part of the project to be reviewed. This is especially so given that there are 

limits to onsite waste storage and storage is not disposal. If this waste is going to stay on site 

then is should be dealt with in detail in the EIS. (0023-3 [Goldsmith, Aviv]) 

Comment: The EIS must fully address the potential consequences of permanent storage of 

highlevel radioactive waste onsite (and so close to the national's capitol). There is no currently 

no permanent storage facility for high-level radioactive waste. Even if the proposed Yucca 

Mountain site opens during the operating lifetime of the proposed facility, this reactor will, by 

law, not be eligible to have its high-level waste stored there. Thus, the EIS must assume that 

there will be no available high-level radioactive waste repository for the full operating lifetime 

(plus possible license extension) of this unit, and the EIS must fully address how and where all 

of the high-level radioactive waste generated will be stored on-site, and what measures will be 

taken to ensure that the radioactivity from this waste remains permanently isolated from the 

environment. (0023-7 [Goldsmith, Aviv]) 

Comment: The Nuclear Waste Policy Act of 1982, as amended, specifies that high-level 

nuclear waste "including irradiated fuel rods from nuclear reactors" will be disposed of in a deep 

geologic repository at Yucca Mountain, Nevada. However, the draft SEIS provides an 

inadequate analysis of the disposition of irradiated fuel from Dominion-Virginia Power's 

proposed North Anna Unit 3 during the operating life of the reactor. The Nuclear Regulatory 

Commission has ignored both its own rules and the intractable problem of storage of irradiated 

fuel rods either at nuclear plant sites or at a proposed waste dump at Yucca Mountain in 

Nevada. Recently, the Obama Administration's proposed 2010 budget zeroed out funding for 

development of the Yucca Mountain repository project. Also, North Anna's irradiated fuel 

storage pools are vulnerable to fires caused by accidents or intentional attacks. The NRC has 

not even attempted to comply with the basic requirements for its waste decisions, such as 

preparing an environmental assessment that addresses the purpose of and need for the 

proposed action and evaluates alternatives. With no solution to radioactive waste, no new 

reactors should be licensed. Further, the NRC's Proposed Waste Confidence Rule and the 

Proposed Temporary Storage Rule do not satisfy the requirements of NEPA for a generic 

licensing decision for new nuclear power plants. Under the National Environmental Policy Act, 

the NRC is required to apply generic decisions to individual licenses; otherwise the regulations 

become a hash of exceptions and half measures. In other words, environmental impacts must 
Appendix E 

NUREG-1917, SEIS E-108 February 2010 

be assessed consistently in both the general case and the specific proceeding. In the particular 

case of North Anna, unless and until the NRC remedies the deficiencies in the Waste 

Confidence Rule, Table S-3of 10 C.F.R. § 51.51, and the Proposed Spent Fuel Storage Rule, 

the agency has no basis for issuing an operating license for Unit 3. (0024-2 [Zeller, Lou]) 

Comment: Personally, I believe no more nuclear power plants should be built until a 

satisfactory method of disposing of the fuel rods is found (0037-1 [Witting, Marjorie]) 

Comment: Furthermore, there is no known safe disposal for spent nuclear fuel rods and other 

contaminated material generated by a nuclear plant. The spent fuel remains radioactive and 

dangerous for hundreds of thousands of years. (0056-1 [Cook, Joe]) 

Comment: The NRC expressed confidence, in 1984, that the problem of disposal of high level 

radioactive waste, generated by nukes, would be resolved in 30 years. Now, because Yucca 

Mountain is unlikely to ever, ever open, as a permanent nuke waste repository, the NRC is 

extending that confidence to 60 years. (0073-60 [Day, Elena]) 

Comment: I would be more confident if the NRC suspended generation of waste from any new 

sources. In other words, would suspend licensing new nukes, new mines, new processing 

facilities and, instead, searched for a means to dispose of the waste already generated as 

safely as technologically possible. (0073-63 [Day, Elena]) 

Comment: In view of the problems with the Yucca Mountain repository, there is no guarantee if 

or when another permanent repository will be available. Lake Anna will become a semipermanent, if not a permanent high level waste repository. (0078-9 [Cruickshank, John]) 

Comment: And then I will read the comments of Kevin Camp, who is an expert, he is also a 

staff member, or was in 2004, of NIRS. Looking at Nuclear Waste Storage: Irradiated fuel 

leaves reactors a million times more radioactive than when the fuel goes in, and can deliver 

lethal doses of radiation in just a few minutes, even after decades of decay in cooling. To date 

the accumulated nuclear waste from 62 years of experimentation and power generation 

remains. For example, the nuclear waste from the early university of Chicago experiments 

Enrico Fermi, is stored on campus. High level radiation or radioactive waste is placed almost 

entirely in so-called interim temporary facilities at the reactors where they are generated. 

(0080-3 [Young, Emerald]) 

Comment: The Charlottesville Center for Peace and Justice is very concerned with the NRC's 

revisiting the waste competence decision, extending it from 30 to 60 years is basically just 

opening it up forever. The fact is I look at most of us in this crowd, I wonder how many of us will 

be alive in 60 years? So it really is a totally open direction. 

(0081-3 [Au Clair Valdez, Miguel]) 
Appendix E 

February 2010 E-109 NUREG-1917, SEIS 

Comment: The CCPJ is urging nuclear waste realism. The NRC should suspend all generation 

of atomic waste, from new sources, unless and until a truly permanent program that is 

scientifically sound, and rooted in a just and equitable siting decision process, is instituted. 

(0081-5 [Au Clair Valdez, Miguel]) 

Comment: It ranges from several years ago, in fact, quite a few years ago we had the issue of 

spent fuel, if you will, being stored on-site, outside the spent fuel pool. (0073-7 [Harper, Willie]) 

Comment: A lot of the cask problems that you heard about, were primarily DOE type events, 

with different types of technology that have nothing to do with the way spent fuel is stored now 

at nuclear sites. (0082-21 [Harte, Vicky]) 

Response: The safety and environmental effects of long-term storage of spent fuel onsite have 

been assessed by the NRC, and, as set forth in its Waste Confidence Decision (codified as 

10 CFR 51.23), the Commission generically determined that such storage could be 

accomplished without significant environmental impact. In the Waste Confidence Decision, the 

Commission determined that spent fuel can be stored onsite for at least 30 years beyond the 

license operating life, which may include the term of a renewed license. At or before the end of 

that period, the fuel would be removed to a permanent repository. In its Statement of 

Consideration for the 1990 update of the Waste Confidence Decision (55 FR 38472), the 

Commission addressed the impacts of both license renewal and potential new reactors. 

Therefore, the current rule can be used in the staff's review of a COL application. In its 

December 6, 1999, review of the Waste Confidence Decision (64 FR 68005), the Commission 

reaffirmed the findings in the rule. In addition to the conclusion regarding safe onsite storage of 

spent fuel, the Commission states in the rule that there is reasonable assurance that at least 

one geologic repository will be available within the first quarter of the 21st century, and sufficient 

repository capacity for the spent fuel will be available within 30 years beyond the licensed life for 

operation of any reactor. The Commission issued a proposed revision of the Waste Confidence 

Decision in the Federal Register (73 FR 59551) for comment on October 9, 2008. This revision 

provided the basis for extending the time for sufficient repository capacity for spent fuel to be 

available from within 30 years beyond the licensed life for operation of any reactor to within 

50 to 60 years. The proposed revision also provides reasonable assurance that spent fuel can 

be stored without significant environmental impacts for at least 60 years beyond the licensed life 

for reactor operation assuming storage of spent fuel in either a spent fuel storage basin or 

onsite or offsite independent spent fuel storage installation. Revision 2 of Dominion's Final 

Safety Analysis Report dated May 2009 (Dominion 2009c) noted that the design of the 

Radwaste Building was modified to hold at least 10 years of packaged Class B and C waste. 

Section 6.1 of the SEIS was revised to include a discussion of the environmental impacts of 

storing this waste onsite for up to 10 years. 

Comment: The reactors will create approximately 20 MT/year of nuclear waste. Detailed plans 

for safe waste management, transport, and disposal should be presented and analyzed in the 

COL SDEIS. (0023-43 [Goldsmith, Aviv]) 
Appendix E 

NUREG-1917, SEIS E-110 February 2010 

Comment: It is my understanding that Dominion has also been disposing of low level waste at 

a repository in South Carolina that has closed. What are the plans for disposal of low level 

waste from the facility? (0023-58 [Goldsmith, Aviv]) 

Comment: With the closing of the low-level radioactive waste dump in Barnwell, South 

Carolina to out-of-compact waste, the North Anna Unit3 nuclear power reactor has no place to 

send Class B, C or Greater-Than-C radioactive waste. Since there is no offsite licensed disposal 

available, extended on site storage becomes de facto onsite disposal. This could significantly 

increase the safety and security risks of the North Anna site. Absent any known disposal 

means, the draft SEIS should at least analyze the impacts of all the possible alternatives for its 

waste disposal. (0024-3 [Zeller, Lou]) 

Comment: In the meantime they are moving ahead to license new reactors, without revisiting 

the impact of generation of more, and more high level and low level waste at every stage of the 

nuclear fuel cycle, mining, milling, enrichment, fuel fabrication, and new plant operations. 

(0073-61 [Day, Elena]) 

Comment: CCPJ also supports the National Environmental Policy Act analysis of issues 

associated with waste generated at every step of the fuel chain prior to any federal action, 

including issuing the permit requested here tonight. (0081-6 [Au Clair Valdez, Miguel]) 

Response: The staff discussed impacts from nuclear waste in Section 6.1 of the SEIS. This 

discussion noted that fuel cycle and waste management impacts for proposed Unit 3 would be 

bounded by those evaluated in Section 6.1 of the ESP EIS (NRC 2006a). New information 

noted in Section 6.1 of the SEIS was the inability to currently dispose of Class B and C low-level 

waste offsite. Revision 2 of Dominion's Final Safety Analysis Report dated May 2009 (Dominion 

2009c) noted that the design of the Radwaste Building was modified to hold at least 10 years of 

packaged Class B and C waste. Section 6.1 of the SEIS was modified to include information 

regarding the environmental impacts of storing this waste onsite for up to 10 years. 

Comment: No new plants should be licensed until the issue of waste disposal, both high level 

and low level, is resolved. (0004-3 [Abbott, Diana]) (0006-5 [Neale, Laura]) 

Comment: Nuclear is a technology of the past, and you still don't even know what to do with 

the waste! (0039-1 [Hess, David]) 

Comment: I believe we have come to the time where we need only sustainable energy 

sources. Nuclear energy is not sustainable because of the very dangerous waste produced 

during the process. (0048-1 [Butcher, Ava]) 

Comment: The unsolved problem of its toxic waste is a legacy I do not want to pass on to my 

children. (0051-3 [Harpole, Thane]) 
Appendix E 

February 2010 E-111 NUREG-1917, SEIS 

Response: The impacts of nuclear and other waste related to the proposed Unit 3 are 

discussed in Chapter 6 of the SEIS. These comments provided no new and significant 

information. Therefore, no changes were made to the SEIS. 

Comment: DEQ's Waste Division staff determined that both solid and hazardous waste issues 

were addressed in the report. A geographic information system (GIS) database search did not 

reveal any waste sites within a half mile radius that would impact or be impacted by construction 

activities at the project site. 

The Waste Division performed a cursory review of DEQ data files and determined that there are 

several hazardous waste and solid waste sites located in the same zip code. These are as 

follows. 

Hazardous Waste Site 

• North Anna Power Station (VAD065376279), a treatment, storage and disposal facility 

(TSDF) 

Solid Waste Sites 

• Louisa County Sanitary Landfill, solid waste permit (SWP) 134, a closed sanitary landfill 

• Louisa County Sanitary Landfill, SWP 194, a sanitary landfill 

• Louisa County Sanitary Landfill, SWP 567, a sanitary landfill 

(0069-40 [Irons, Ellie]) 

Response: This comment is a statement of fact, but it does not provide new and significant 

information about the proposed project. Therefore, no changes were made to the SEIS. 

Comment: They are ignoring that storage in pools and casks at nuclear facilities increases the 

possibility of leakage, contamination and, of course, heightened security risks. 

(0073-62 [Day, Elena]) 

Comment: Waste management is another concern. The SEIS fails to evaluate the 

environmental impacts and security threat of indefinitely storing the additional irradiated fuel that 

will be generated by the proposed reactor on-site. (0078-8 [Cruickshank, John]) 

Comment: There are problems with transportation of the waste, also storage in dry cask is 

problematic, because of defective welds, and defective valves. Despite promises to unload 

casks if problems develop the Palisades Plant in Michigan left irradiated fuel in a defective cask 

for ten years. 
Appendix E 

NUREG-1917, SEIS E-112 February 2010 

An explosion occurred inside a cask at Point Beach, Wisconsin, in 1966. In Surry, Virginia, the 

first place in the country to use dry casks, the inner seals failed. 

(0080-4 [Young, Emerald]) 

Response: The safety and environmental effects of long-term storage of spent fuel onsite 

have been assessed by the NRC, and, as set forth in its Waste Confidence Decision (codified 

as 10 CFR 51.23), the Commission generically determined that such storage could be 

accomplished without significant environmental impact. In the Waste Confidence Decision, 

the Commission determined that spent fuel can be stored onsite for at least 30 years beyond 

the license operating life, which may include the term of a renewed license. At or before the 

end of that period, the fuel would be removed to a permanent repository. In its Statement of 

Consideration for the 1990 update of the Waste Confidence Decision (55 FR 38472), the 

Commission addressed the impacts of both license renewal and potential new reactors. 

Therefore, the current rule can be used in the staff's review of a combined license application. 

In its December 6, 1999, review of the Waste Confidence Decision (64 FR 68005), the 

Commission reaffirmed the findings in the rule. In addition to the conclusion regarding safe 

onsite storage of spent fuel, the Commission states in the rule that there is reasonable 

assurance that at least one geologic repository will be available within the first quarter of the 

21st century, and sufficient repository capacity for the spent fuel will be available within 30 years 

beyond the licensed life for operation of any reactor. In its proposed revision to its Waste 

Confidence Decision (73 FR 59551), the Commission discussed issues related to leakage from 

spent fuel storage pools and independent spent fuel storage installations and security risks from 

those facilities. Finding 3 of the proposed revision to the Waste Confidence Decision states that 

the Commission finds reasonable assurance that high-level waste and spent fuel will be 

managed in a safe manner until sufficient repository capacity is available. The Commission 

cited its success in regulating spent fuel from six decommissioned reactors under the 10 CFR 

Part 72 regulations. Inspections on the independent spent fuel storage installations at these 

locations have identified few issues once a loaded storage cask is placed on the storage pad. 

 In addition, in accordance with 10 CFR 50.54 (bb), the licensee is required to include in its 

license information about how it will provide funding to manage its spent fuel between the time 

the reactor stops operating and time the spent fuel is disposed of in a repository. Finding 4 of 

the proposed revision to the Waste Confidence Decision states that the Commission finds 

reasonable assurance that spent fuel generated in any reactor can be stored safely and without 

significant environmental impacts for at least 60 years beyond the licensed life for operations. 

 This finding was based on review of the following issues: (1) long-term integrity of spent fuel 

under water pool storage conditions, (2) the structure and component safety for extended facility 

operation for storage of spent fuel in water pools, (3) safety of dry storage, and (4) the potential 

risks of accidents and acts of sabotage at independent spent fuel storage installations. No 

changes were made to the SEIS as a result of these comments. 

Comment: Any soil that is suspected of contamination or wastes that are generated during 

construction-related activities must be tested and disposed of in accordance with applicable 

federal, state, and local laws and regulations. 

(0069-41 [Irons, Ellie]) 
Appendix E 

February 2010 E-113 NUREG-1917, SEIS 

Response: Section 3.2.4.3 of the SEIS states that nonradioactive solid wastes (e.g., 

construction wastes) would be handled in compliance with appropriate State and Federal 

regulations. No changes were made to the SEIS as a result of this comment. 

16. Comments Concerning Transportation 

Comment: The impacts to traffic from increased fog occurrence (Page 5-14 line 23) should be 

addressed. (0023-18 [Goldsmith, Aviv]) 

Response: The commenter is referring to 70 additional hours of fogging conditions predicted to 

occur as a result of vapor plumes produced by the cooling systems from the ESP analysis for 

Units 3 and 4. The ER submitted by Dominion (2009b) stated that natural heavy fog conditions 

(visibility less than 0.40 km [0.25 mi]) are infrequent, occurring 27.2 days per year. The 70 

additional hours of fog formation was stated in the ER to be negligible (Section 2.3.2.3). Studies 

on the frequency and severity of traffic accidents that occur during foggy conditions are not 

conclusive. A review of the literature shows that most accidents occur during normal weather 

conditions. The relationship between weather conditions and traffic accident frequency and 

severity is complex, and often behaves unpredictably. For example, one would expect that 

reduced visibility caused by fog would cause traffic accident risks to increase. However, driver 

behavior is also influenced by fog, causing motorists to slow down, thus reducing the likelihood 

and consequences of traffic accidents. In addition, motorists in areas affected by frequent 

fogging incidents may choose alternate routes that are less affected by fog. As a result, there is 

no definitive means of predicting the impacts to traffic from increased fogging. 

Because the increase in fogging due to operation of the proposed new unit is negligible, the 

NRC staff concluded the increase in traffic impacts would also be negligible. No changes were 

made to the SEIS as a result of this comment. 

17. Comments Concerning Decommissioning 

Comment: Section 6.3 of the SDIES mentioned that decommissioning would eventually be 

required and "reduction of residual radioactivity to a level that permits termination of the NRC 

license". Has this been successfully done anywhere in the US? What financial security does the 

operator post to assure successful decommissioning? (0023-44 [Goldsmith, Aviv]) 

Response: Approximately 10 nuclear power plants in the United States have completed the 

decommissioning process, with the most recent being Rancho Seco in California. As discussed 

in Section 6.3 of the draft SEIS (NRC 2008), Dominion has committed to establishing an 

external sinking funds account to accumulate funds for decommissioning. As defined in 

10 CFR 50.75(e)(1)(ii), an external sinking fund is established and maintained by setting funds 

aside periodically in an account segregated from licensee assets and outside the administrative 

control of the licensee in which the total amount of funds would be sufficient to pay 

decommissioning costs at the time permanent termination of operations is expected. At least 

every two years, the licensee must report to the NRC on the status of decommissioning funding 

for each reactor it owns. Examples of information that must be in the report include (1) amount 
Appendix E 

NUREG-1917, SEIS E-114 February 2010 

of decommissioning funds estimated to be required, (2) amount accumulated to date, 

(3) schedule of the annual amounts remaining to be collected, (4) assumptions used regarding 

escalation in decommissioning costs, and (5) rates of earning on decommissioning funds. No 

changes were made to the SEIS as a result of this comment.

18. Comments Concerning Site Redress 

Comment: Restore temporary impact areas to their original contours and revegetate with the 

same or similar species. (0069-10 [Irons, Ellie]) 

Response: The ESP for the NAPS site (ESP-003) contains a site redress plan (Appendix E) 

that would be implemented if site preparation activities were performed but the ESP expired 

before a COL was granted. Redress activities also apply to those areas not fully developed for 

the intended purpose of new nuclear power generation. Those areas would be returned to an 

environmentally stable and aesthetically acceptable condition that is consistent with local zoning 

laws. No changes were made to the SEIS as a result of this comment. 

19. Comments Concerning Cumulative Impacts 

Comment: Unit 1 and 2 Offsetting Measures. Since there are significant incremental surface 

water impacts that will be caused by the proposed Unit 3 (cooling method using up to 24 million 

gallons per day), the system design alternatives should include the alternative of imposing some 

form of water saving/water cooling measures on the two nuclear reactors that already exist on 

the site, as a form of offset to the impacts of the proposed new reactors. These unit 1 & 2 

offsets are necessary under the National Environmental Policy Act (NEPA) where the applicant 

and its affiliates seek to add a nuclear reactor at the same location of existing nuclear 

operations. The unit 1 & 2 water conservation measures should mitigate against the significant 

and adverse incremental impacts that will be caused by the proposed Unit 3 cooling method. 

(0017-15 [Ruth, Harry]) 

Comment: The NRC made no consideration for mitigation of Unit 1 and 2 for the operation of 

Unit 3 as requested. It is as if a box is drawn around Units 1and 2 and no consideration is made 

as to the total environmental impact of all three units. (0018-2 [Remmers, Ken]) 

Comment: Our first concern, the NRC in my previous comments, I requested the NRC to look 

at mitigation of plants 1 and 2 in way of unit 3. The NRC made no consideration for the 

mitigation of unit 1 and 2 as requested. It is as if a box was drawn around unit 1 and 2, and no 

consideration is made for the total environmental impact of all three units. 

(0073-34 [Remmers, Ken]) 

Response: Information regarding the cumulative impacts on water use from the operation of 

the proposed Unit 3 and the existing Units 1 and 2 is provided in Section 7.3 of the SEIS. 

Chapter 5 of the SEIS was revised to include the results of the IFIM study, which provides the 

basis for proposed changes to reservoir operation rules intended to mitigate the impacts of 

operating the proposed Unit 3. 
Appendix E 

February 2010 E-115 NUREG-1917, SEIS 

20. Comments Concerning the Need for Power 

Comment: Furthermore, in light of what we all now know about the condition of the Earth we 

can only expect that leaders in the energy field such as Va. Power should put a REAL effort into 

energy conservation first and foremost. With a true energy conservation program in place we 

would have no need at all for this proposed third nuclear plant. (0062-1 [Fiscella, Glenn]) 

Response: Decisions regarding which generation sources and alternatives to deploy are made 

by the applicant and regulatory bodies such as State energy planning agencies and public utility 

commissions, not the NRC. The NRC's review of "need for power" requires the alternatives to 

be technically viable, feasible, and competitive. Chapter 8 of the SEIS reviews the impacts of 

energy efficiency and demand-side management on the need for power and load forecasts, and 

the need for power exists, even allowing for success of ambitious energy conservation in the 

Dominion Zone service area. This comment does not provide any new and significant 

information. Therefore, no changes were made to the SEIS.

Comment: Several important issues have come up which involve significant changes since the 

Draft EIS...Economic recession: will significantly change economic assumptions including 

demand for electricity. (0012-1 [Rosenthal, Jerry]) 

Comment: Our need for electricity has increased due to population growth and additional 

electrically generated technologies. (0020-4 [Aylor, Joseph]) 

Comment: Money, expertise, personnel, and equipment can be imported from overseas, but 

I'm not aware of any way that they have ever found to import electricity from overseas. 

(0073-2 [Wright, Jack]) 

Comment: Virginia is one of the fastest growing states in the country. And we import 

approximately 30 percent of our electricity needs from electrical generators located in other 

states. (0073-27 [Faggert, Pam]) 

Comment: The PJM interconnect, which is the Regional Transmission Operator for the MidAtlantic Region, projects that by 2017 there will be a 4,000 megawatt gap between the amount 

of electricity needed for customers, and the electrical generation facilities available here in 

Virginia to meet the demand. Of that amount 2,000 megawatts must be baseload generation, or 

the kind of electricity that is generated 24 hours, 7 days a week, by facilities such as a nuclear 

reactor. (0073-28 [Faggert, Pam]) 

Comment: Dominion is working on several fronts to preempt such a gap in 2017, including 

promoting improvements in energy efficiency, increasing conservation efforts, and developing 

renewable energy facilities. (0073-29 [Faggert, Pam]) 

Comment: Everything I have read and heard during the past several years, has stressed the 

need for a safe continuing source of dependable and affordable power. Unit 3 will help meet this 

need. (0073-3 [Wright, Jack]) 
Appendix E 

NUREG-1917, SEIS E-116 February 2010 

Comment: We've heard a lot about deficits, recently. And Virginia has one. It is a major 

importer of electricity power. In fact it is the largest importer of electricity, other than California. 

And that is one of the needs of this plant. Nuclear energy provides an ideal mix, it is mixed with 

coal, gas, and hydro. (0075-20 [Farmer, John]) 

Comment: This project will help close a conservatively estimated 4,000 megawatt energy gap 

in Virginia, by 2017. 

It will provide 1,500 megawatts, or 37 percent of this need. And that is a key thought, maybe. If 

you are only going to provide 37 percent of what we are going to need by 2017. But it will do this 

with 24-7 reliability, and minimal impact on the environment. (0075-23 [Beament, Pete]) 

Comment: We want cheap electricity, delivered to our doorstep, but we don't want to see any 

generating facilities. (0075-29 [Carroll, John]) 

Comment: I believe the new unit is an essential addition to Virginia's electric energy portfolio. 

There is a significant need for investment in a diverse mix of generation within the state. 

Virginia faces, as we have heard tonight, considerable shortfall for electricity within the more 

than 4,000 megawatts over the next decade. The additional unit at North Anna will generate 

approximately, as we also have heard tonight, 1,500 megawatts. Enough energy to power the 

equivalent of 375,000 homes. (0075-47 [Girvin, Larry]) 

Comment: As you know our electricity demand will increase 25 percent by 2030. Here in 

Virginia nuclear power provides almost 35 percent of the state's energy needs. That is only 

expected to grow. Virginia has experienced growth of 2.8 percent per year over the past five 

years. To keep Virginia's economy growing the state will need new sources of power, power 

that is good for the environment, and good for the economy. (0077-12 [Lamboley, Genevieve]) 

Comment: We all know that our nation heavily relies on electricity. In fact, the Department of 

Energy estimates that our electricity demand will increase 25 percent by 2030. Technological 

advances have increased our reliance on the many gadgets that power our lives more 

efficiently, and that is only made the need for more clean sources of power even greater. 

(0077-7 [Nelson, Deborah]) 

Comment: The reality is that we will require more power from a variety of sources in the years 

ahead. (0077-9 [Nelson, Deborah]) 

Response: The determination for the need for power within a given area is not under 

the NRC's regulatory purview. When another agency has the regulatory authority over an 

issue, NRC defers to that agency's decision. The NRC staff reviews the need for power 

analysis to determine if it is (1) systematic, (2) comprehensive, (3) subject to confirmation, 

and (4) responsive to forecasting uncertainty. If the need for power evaluation is found to be 

acceptable, no additional independent review by the NRC is needed. States or regions may 

prepare a need for power evaluation and assessment of the regional power system for planning 

or regulatory purposes. A need for power analysis also may be prepared by a regulated utility 
Appendix E 

February 2010 E-117 NUREG-1917, SEIS 

and submitted to a regulatory authority such as a State public utility commission. The need for 

power analysis that Dominion provided in Chapter 8 of its environmental report for the COL was 

based largely on an electric power analysis by PJM, Inc., the Regional Transmission Operator 

for the multi-state region of which Virginia is a part. In its analysis of the need for power, 

Dominion specifically estimated the need for base-load generation and tested the 

consequences of alternative methods of satisfying base-load demand, including importing 

additional power and conservation and demand-side management. In Chapter 8 of the SEIS, 

the NRC staff reviewed the need-for-power analysis submitted by Dominion, including the 

findings of PJM and by Dominion based on the PJM analysis, tested some of the critical 

assumptions, and determined that the need for power analysis submitted was (1) systematic, 

(2) comprehensive, (3) subject to confirmation, and (4) responsive to forecasting uncertainty. 

Because the need for power evaluation was found to be acceptable, no additional independent 

review by the NRC was needed. No change was made to the SEIS as a result of these 

comments. 

Comment: The NRC denotes, in its Draft Supplemental EIS that Dominion's need for power 

analysis gives full credit for reduction in load growth embodied in Virginia's goals and still finds a 

need for power exists. (0073-31 [Faggert, Pam]) 

Response: The analysis of need for power discussed in Chapter 8 of the SEIS reflects the 

applicant's ongoing efforts to promote energy efficiency, conservation mandates, and updated 

demand forecasts by PJM, Inc., and tests the consequences of aggressive conservation 

programs. This comment provides no new and significant information. Therefore, no changes 

were made to the SEIS. 

Comment: Dominion has been consistently wrong, over time, on their projections of the energy 

that they were going to do. Unit 3 originally was canceled, and the ratepayers ended up paying 

600 million dollars back to Virginia Power in the early '80s. And this was due, at the time, to the 

same thing that they said, they had projected the energy wrong. Dominion and PJM, this needs 

to be looked at. With the recession that is coming on, we are going to see a significant 

difference in energy use. And that is crucial. (0082-11 [Rosenthal, Jerry]) 

Response: In Chapter 8 of the SEIS, the NRC staff examined the PJM forecast and the 

Dominion estimate of the need for base-load power in the Dominion Zone derived from the PJM 

forecast. The NRC staff also tested the forecast against the possibilities that demand for power 

would be significantly lower than projected because of conservation or because of lower overall 

growth of electricity demand in the Dominion Zone. The NRC staff determined that there was a 

plausible need for power in both cases. The staff notes that while demand for electric power 

may be reduced in the short term because of the current recession, there is nothing to suggest 

that demand will not recover by the time NAPS Unit 3 would be completed. No change was 

made to the SEIS as a result of this comment.

Comment: The current global business climate sharply reinforces the need for lower cost 

reliable energy, at a time when many businesses face reduced sales, lower profits, and 

increased pressure to pay bills, and make a payroll. Likewise, lower energy costs are a 
Appendix E 

NUREG-1917, SEIS E-118 February 2010 

significant advantage in trying to attract new businesses to our region, and grow the companies 

we already have. Given the current need for a major economic stimulus package, and the 

circumstances surrounding the present economy, this project will be appreciated now, more 

than any time since the economic challenges of the 1930s. It also represents a stable source of 

domestic energy, in an otherwise highly volatile and politically unstable global marketplace. 

(0075-16 [Bailey, Gene]) 

Response: This comment is largely a supporting statement for nuclear power on the basis of 

stable prices and specifically for NAPS Unit 3 as an economic stimulus for the region. This 

comment provides no new and significant information. Therefore, no changes were made to the 

SEIS. 

Comment: [SDEIS Sec. 8.4.3.3 Need for reserve margin]: Editorial. The statement should read 

"This is a conservative assumption because it does not account for the probability that they 

might not all be built." (0084-28 [Grechek, Eugene]) 

Response: The sentence in Section 8.4.3.3 of the SEIS has been reworded to clarify and to 

avoid a double negative statement. 

21. Comments Concerning Alternatives – Energy 

Comment: However, I am FOR a third reactor if it prevents the destruction of the 194 miles of 

destroyed mountain top ridges required for a wind mill farm. This is what it would take to provide 

the equivalant power of your 1 additional reactor. (0026-1 [Burt, William]) 

Response: The wind power alternative was discussed in Section 9.2.3.2 of the SEIS. This 

comment expresses support for the proposed Unit 3. This comment provided no new and 

significant information. Therefore, no changes were made to the SEIS. 

Comment: Say NO and Yes to a greener VA...by investing in wind power! 

(0027-1 Hanger, Jane]) 

Response: Wind power was evaluated in Section 9.2.3.2 of the SEIS. This comment provided 

no new and significant information. Therefore, no changes were made to the SEIS. 

Comment: The alternative section of the needs to assess other alternatives beyond siting such 

as renewables, demand side management, repowering of Units #1 and #2, etc. 

(0023-46 [Goldsmith, Aviv]) 

Comment: The Alternatives section is lacking in a detailed analysis of real alternatives to a 

large central station nuclear generator. (0023-6 [Goldsmith, Aviv]) 

Comment: There are far better alternatives: wind, solar & natural gas 

(0028-1 [Artemis, Diana]) 
Appendix E 

February 2010 E-119 NUREG-1917, SEIS 

Comment: We need to be working on alternative energy sources such as solar to meet our 

needs along with implementing incentives to reduce consumption. 

(0031-1 [Lufkin, Heather]) 

Comment: There is no reason why renewable energy like solar and wind power combined with 

energy saving methods could not be used instead of another new nuclear power plant. 

(0038-1 [Heim, Anka]) 

Comment: Lets spend the money on solar, wind and tidal generators. These three sources of 

energy are totally sustainable. (0048-2 [Butcher, Ava]) 

Comment: Energy conservation and solar, wind energy projects are the rational choice for 

Virginia and the United States energy needs. (0049-1 [Ebert, Paul]) 

Comment: The time is ripe now for massive investments in clean, safe renewable energy, such 

as solar and wind. (0051-1 [Harpole, Thane]) 

Comment: Dominion Power should be considering offshore wind power units instead. The 

strongest wind currents in the U.S. are along the New England coast down through Virginia. 

Wind power is SO MUCH SAFER THAN NUCLEAR POWER. WHy put residents at risk 

needlessly??? Please do what you know to be morally right and responsible. 

(0053-1 [Phillips, Donna]) 

Comment: Increasingly, the green movement is becoming a way of life (much overdue) and 

people around the country and around the world are seeing the damaging impact that human 

decisions have had and are having upon the Earth. It is absolutely time for bold thinking and 

unconventional approaches, time to re-examine our priorities. (0055-1 [Shamaiengar, Beth]) 

Comment: I have lived in Virginia all my life and wish to continue to, in good health. I sincerly 

hope there can be a better way to provide us with electricity, without more damage to the 

environment. (0058-1 [Hartwig, Kristina]) 

Comment: Get on the progressive bandwagon and use solar, geothermal, etc., etc. 

(0059-3 [Dickon, Elisa]) 

Comment: I believe that the development of efficient, affordable renewable energy technology 

is possible and is a much safer, smarter alternative. (0063-1 [Tanner-Sutton, Linda]) 

Comment: Indeed we need to explore alternative energy sources (0065-1 [Liske, Patricia]) 

Comment: Make a stand, and send a message, about protecting human life, as well as the 

environment. There ARE indeed alternatives. Though you may have to jump through more 

hoops, and it may be more costly, these alternatives ultimately better the situation for everyone 

and everything. (0066-1 [Cummings, Russell]) 
Appendix E 

NUREG-1917, SEIS E-120 February 2010 

Comment: Dominion Virginia Power has not been making any serious effort to pursue 

renewable energy alternatives, nor to promote effective measures to conserve electricity, or 

increase efficiency of use. I want to emphasize the word serious. They made no serious effort. 

(0078-12 [Cruickshank, John]) 

Comment: I took the time to come here to share a little bit about the alternatives to nuclear 

power. A lot of people talk about the fact that there lots of way to boil water and, sure, humans 

have been doing that for a long time. We figured out we could burn wood, we could burn natural 

gas, we can burn oil, we can burn coal. Many of the people that sell coal, oil, and natural gas, 

really don't like nuclear power very much, at all, because nuclear power takes market share 

from them. The young man who has left already, quoted E.F. Shumaker, a man who wrote 

Small is Beautiful. What he didn't know was that E.F. Shumaker, when he wrote that book, had 

been spending 20 years on the National Coal Board of Great Britain. His job was to sell and 

market coal. He liked Small is Beautiful because in Great Britain, before they moved the power 

plants outside the city, they burnt coal in the chimneys. How many people have seen Mary 

Poppins, and seen the chim chimney, chim chimney and the black smoke? If you ever traveled 

to Great Britain, at the time of E.F. Shumaker, when he was writing, people would burn coal 

inside their own houses, and whole towns were covered with soot. (0083-1 [Adams, Rod]) 

Response: Energy alternatives, including conservation and renewable energy sources such as 

solar and wind, as well as energy from other sources, were evaluated in Section 9.2 of the 

SEIS. Conservation is also discussed in Section 8.4.1 of the SEIS. Tidal power is an emerging 

technology that does not provide a reasonable alternative to a nuclear generating unit producing 

base-load power. These comments provided no new and significant information. Therefore, no 

changes were made to the SEIS. 

Comment: The existing problems need to be fixed, and then more environmentally sensitive 

power generation should be considered rather than storing unstable radioactive waste. 

(0064-1 [Farnham, Ross]) 

Response: Energy alternatives, including renewable energy sources such as solar and wind, 

were evaluated in Section 9.2 of the draft SEIS (NRC 2008). The NRC's Waste Confidence 

Decision (codified as 10 CFR 51.23) states that the Commission has made a generic 

determination that, if necessary, spent fuel generated in any reactor can be stored safely and 

without significant environmental impacts for at least 30 years beyond the licensed life for 

operation (which may include the term of a revised or renewed license) of that reactor at its 

spent fuel storage basin or at either onsite or offsite independent spent fuel storage installations. 

 Further, the Commission believes there is reasonable assurance that at least one mined 

geologic repository will be available within the first quarter of the 21st century, and sufficient 

repository capacity will be available within 30 years beyond the licensed life for operation of any 

reactor to dispose of the commercial high-level waste and spent fuel originating in such reactor 

and generated up to that time. The Commission issued a proposed update of the Waste 

Confidence Decision in the Federal Register (73 FR 59551) for comment on October 9, 2008. 

This revision provided the basis for extending the time for sufficient repository capacity for spent 

fuel to be available from within 30 years beyond the licensed life for operation of any reactor to 
Appendix E 

February 2010 E-121 NUREG-1917, SEIS 

within 50 to 60 years. The proposed revision also provides reasonable assurance that spent 

fuel can be stored without significant environmental impacts for at least 60 years beyond the 

licensed life for reactor operation, assuming storage of spent fuel in either a spent fuel storage 

basis or onsite or offsite independent spent fuel storage installation. No changes were made to 

the SEIS as a result of the comment. 

Comment: For the cost of building a new reactor at North Anna, we could make significant 

strides in advancing clean alternative energy implementation within Virginia. For instance, 

instead of nuclear, we could install solar arrays on every flat-roofed office building, school, 

warehouse, and factory in the state, supplying tons of energy directly where it's needed, with no 

additional infrastructure. We could also recoup through energy efficiency programs a huge 

percentage of the power that is currently just wasted. These are the steps we should be taking. 

(0051-4 [Harpole, Thane]) 

Comment: My comments today are actually linked not so much to the character of this power 

plant, it happens to be a nuclear power plant, but I'd be saying the same thing today if this were 

a coal powered, or a gas powered plant. And it has to do, I'm stimulated in my comments by 

some recent studies, one by the Electric Power Research Institute, it is a large industrysupported organization in Palo Alto, California. And they just released this new report, the 

Assessment of Achievable Potential Energy Efficiency and Demand Response Programs in the 

U.S. 2010-2030. The other report is by the American Physical Society, it is the largest 

organization of physicists in the United States, some 46,000 physicists, in universities, industry 

and government laboratories. 

And they just released this report last fall, and it is titled: How America Can Look Within to 

Achieve Energy Security and Reduce Global Warming. The third item, of course, is this recent 

cover from Time magazine, June 11th, 2009, which says why we need to see the light about 

energy efficiency. These two reports, the one by EPRI and the one by the American Physical 

Society, basically come to the same conclusion. The American Physical Society report deals 

globally with the entire energy program in the United States, including transportation, while the 

EPRI report deals only with electrical consumption and inefficiency. 

The EPRI report predicts that between 200 and 300 gigawatt electric peak demand can be 

offset by electrical energy efficiency and demand management in the United States. 

Now, if we just simply scale that number by population, Virginia's percentage of the United 

States population, that means between 4 and 6 gigawatts electricity peak demand, can bee 

eliminated in Virginia, through demand management and energy efficiency techniques. 

Meaning we don't have to build this plant, we don't have to build some other plant. This is a one 

gigawatt plant. (0075-3 [Day, Donal]) 

Comment: The APS study says, and they cover both the transportation sector, and the 

industrial sector as well, simply by looking at the replacement of incandescent light bulbs, by 

CFLs, would use one-fourth of the electricity. Over the United States one would save 

240 terrawatt hours of electricity annually. (0075-4 [Day, Donal]) 
Appendix E 

NUREG-1917, SEIS E-122 February 2010 

Comment: Again, if one just scales that by population to Virginia, that means that we would 

save five terrawatt hours in Virginia, every year, simply by switching our light bulbs. This plant, 

running 24 hours a day, seven days a week, 365 days a year, will produce about nine terrawatt 

hours in a year. So simply by swapping light bulbs we can eliminate half the production need 

that this plant can produce. So I asked my question earlier, of course, what studies were done 

by the NRC in looking at alternatives? Well, here are two reports that I would like to, at least, 

provide to the Staff. (0075-5 [Day, Donal]) 

Comment: The projected cost of a new reactor are much higher than alternative sources. In 

particular, energy efficiency resources have been estimated to be at less than three cents per 

kilowatt hour. This is the cheapest energy we can get, is through efficiency. And a report from 

the ACEEE has said that we could, in Virginia, we could be reducing our energy electric 

consumption by 19 percent through efficiency. (0078-13 [Cruickshank, John]) 

Response: In context, these comments appear to suggest that methods other than nuclear 

power are appropriate and preferable and less expensive for generating base load electricity (or 

in the case of conservation, using less of it). The NRC does not have authority to ensure that 

the proposed plant is the least costly alternative to provide energy services under any particular 

set of assumptions concerning future circumstances. This authority and responsibility is most 

often the role of State regulatory authorities such as public service commissions, or in the case 

of merchant plants, the competitive marketplace. 

Energy alternatives, including conservation and renewable energy sources such as solar, were 

addressed in Section 9.2 of the SEIS. Conservation was also discussed in Section 8.4.1 of the 

SEIS. These comments provide no new and significant information. Therefore, no changes 

were made to the SEIS. 

Comment: How about thinking outside the box - wind off shore, solar, conservation, improved 

efficiency. Let's work on trying to get the 2 we already have at higher efficiency and with a 

firmer approach to dealing with waste before we embark on another reactor. 

(0042-1 [Hoehlein, Jill]) 

Response: Energy alternatives, including conservation and renewable energy sources such as 

solar and wind, were evaluated in Section 9.2 of the draft SEIS. Conservation also was 

discussed in Section 8.4.1 of the draft SEIS. According to Nuclear Energy Institute 

publicationsissued in 2008 and 2009, the average annual capacity factor for North Anna Units 1 

and 2 was 90.8 percent between 2005 and 2007, and the average capacity factor for a nuclear 

power plant in the United States in 2008 was 91.5 percent. Thus, Units 1 and 2 are already 

operating efficiently, and there is little room for improvement. Any improvements in operating 

efficiency for Units 1 and 2 would not be sufficient to supply the need for power identified in 

Chapter 8 of the SEIS. 

The NRC's Waste Confidence Decision (codified as 10 CFR 51.23) states that the Commission 

has made a generic determination that, if necessary, spent fuel generated in any reactor can be 

stored safely and without significant environmental impacts for at least 30 years beyond the 
Appendix E 

February 2010 E-123 NUREG-1917, SEIS 

licensed life for operation (which may include the term of a revised or renewed license) of that 

reactor at its spent fuel storage basin or at either onsite or offsite independent spent fuel storage 

installations. Further, the Commission believes there is reasonable assurance that at least one 

mined geologic repository will be available within the first quarter of the 21st century, and 

sufficient repository capacity will be available within 30 years beyond the licensed life for 

operation of any reactor to dispose of the commercial high-level waste and spent fuel originating 

in such reactor and generated up to that time. The Commission issued a proposed update of 

the Waste Confidence Decision in the Federal Register (73 FR 59551) for comment on 

October 9, 2008. This revision provided the basis for extending the time for sufficient repository 

capacity for spent fuel to be available from within 30 years beyond the licensed life for operation 

of any reactor to within 50 to 60 years. The proposed revision also provides reasonable 

assurance that spent fuel can be stored without significant environmental impacts for at least 

60 years beyond the licensed life for reactor operation, assuming storage of spent fuel in either 

a spent fuel storage basis or onsite or offsite independent spent fuel storage installation. No 

changes were made to the SEIS as a result of the comment. 

Comment: Another defect of the SDEIS, is inadequate discussion of alternatives to the 

proposed project. Including the use of dry cooling for unit number 3, and energy efficiency 

programs. (0078-11 [Cruickshank, John]) 

Response: Alternative cooling systems for new nuclear units at the NAPS site, such as dry 

cooling, were evaluated in Section 8.2.3 of the ESP EIS (NRC 2006a) and discussed in 

Section 9.3 of the draft COL SEIS (NRC 2008). Energy alternatives, including conservation and 

renewable energy sources such as solar, were addressed in Section 9.2 of the SEIS. 

Conservation was also discussed in Section 8.4.1 of the SEIS. This comment provided no new 

and significant information. Therefore, no changes were made to the SEIS. 

Comment: When they say no alternatives are environmentally preferable to a nuclear plant, 

but they are not including the waste issue. It is incomprehensible. (0082-14 [Rosenthal, Jerry]) 

Response: The safety and environmental effects of long-term storage of spent fuel onsite have 

been assessed by the NRC, and as set forth in the Waste Confidence Decision (codified as 

10 CFR 51.23), the Commission generically determined that such storage could be 

accomplished without significant environmental impact. In its Waste Confidence Decision, the 

Commission determined that spent fuel can be stored onsite for at least 30 years beyond the 

license operating life, which may include the term of a renewed license. At or before the end of 

that period, the fuel would be removed to a permanent repository. In its Statement of 

Consideration for the 1990 update of the Waste Confidence Decision (55 FR 38472), the 

Commission addressed the impacts of both license renewal and potential new reactors. 

Therefore, the current rule can be used in the staff's review of a COL application. In its 

December 6, 1999, review of the Waste Confidence Decision (64 FR 68005), the Commission 

reaffirmed the findings in the rule. In addition to the conclusion regarding safe onsite storage of 

spent fuel, the Commission states in the rule that there is reasonable assurance that at least 

one geologic repository will be available within the first quarter of the twenty-first century, and 

sufficient repository capacity for the spent fuel will be available within 30 years beyond the 
Appendix E 

NUREG-1917, SEIS E-124 February 2010 

licensed life for operation of any reactor. The Commission issued a proposed update of the 

Waste Confidence Decision in the Federal Register (73 FR 59551) for comment on October 9, 

2008. This revision provided the basis for extending the time for sufficient repository capacity 

for spent fuel to be available from within 30 years beyond the licensed life for operation of any 

reactor to within 50 to 60 years. The proposed revision also provides reasonable assurance 

that spent fuel can be stored without significant environmental impacts for at least 60 years 

beyond the licensed life for reactor operation, assuming storage of spent fuel in either a spent 

fuel storage basis or onsite or offsite independent spent fuel storage installation. No changes 

were made to the SEIS as a result of the comment. 

Comment: NRC indicates that generation options in Virginia are an indicator of feasible 

technology choices then summarizes national projections from the EIA Annual Energy Outlook 

regarding new capacity additions. No description of the power generation mix within Virginia is 

provided. Dominion suggests that the statement regarding the current mix of base-load power 

generation options in Virginia be deleted from the text. (0084-32 [Grechek, Eugene]) 

Response: Section 9.2.2 of the SEIS has been modified to include the current electric power 

generation mix in Virginia. 

Comment: The statement in Section 9.2.2 of the DSEIS indicates that the analysis should be 

limited to discrete power generation sources. However, NRC evaluated a combination of 

alternatives in Section 9.2.4, and Dominion evaluated combinations of alternatives in 

Section 9.2.2.4 of the ER. Dominion suggests that the limitation to discrete power generation 

sources be eliminated from the text in Section 9.2.2. (0084-31 [Grechek, Eugene]) 

Response: Section 9.2.2 of the SEIS was modified to reflect that a combination of energy 

sources is also considered in the SEIS. 

Comment: [SDEIS Sec 9.2.1, statement "If the purchased-power alternative ......particularly if 

new transmission line rights-of-way were needed."] Text preceding this statement clearly 

indicates that new transmission lines would be required. Dominion suggests that the text should 

state: "If the purchased-power alternative were to be implemented, a major environmental 

unknown would be whether new transmission line rights-of-way would be required. ..." (0084-30

[Grechek, Eugene]) 

Response: Section 9.2.1 of the SEIS was modified to reflect this comment. 

Comment: [In DSEIS Section 9.2.2.1] NRC provided a single estimate for SO2, NOx, CO and 

VOC emissions (based on the 600 MW unit) and provided a range for PM10, PM2.5, and Hg 

emissions. Dominion suggests that all emissions estimates be presented as a range. 

(0084-33 [Grechek, Eugene]) 

Response: Section 9.2.3.1 of the ER (Dominion 2009a) states that Dominion assumed 

construction of three approximately 507 MW net output pulverized coal-fired units. The closest 

estimate of emissions in ER Table 9.2-4 was for a 600 MW unit. Consequently, the staff used 
Appendix E 

February 2010 E-125 NUREG-1917, SEIS 

the emission estimates for the 600 MW unit. The range of estimates for PM and Hg was 

derived from Dominion's July 17, 2008 request for additional information response. 

22. Comments Concerning Alternatives – System Design 

Comment: An alternative system that would store the effluent and use it to water grass or 

wooded areas is available. The EIS failed to adequately consider this long term impact. Despite 

including an entire section on long term impacts, the Supplement also does not consider this 

impact. We would like for Dominion to consider an alternative method and include the existing 

sewage treatment facility effluent so that no effluent is dumped into the lake at all. We ask that 

NRC address this cumulative impact in the supplement. (0019-5 [Smith, Doug]) 

Comment: Section 3.2.1.2 mentions water treatment effluent. Shouldn't Chapter 8 include an 

assessment of a zero discharge option as is used in many other power plants? 

(0023-22 [Goldsmith, Aviv]) 

Response: In the ESP EIS (NRC 2006a)), the staff determined that the impact of plant 

operation on water quality would be SMALL. In the COL review, the staff did not identify any 

new and significant information that would alter this finding. Water reuse is a potential 

alternative to discharge of effluents from the sewage treatment plant. Pursuant to the Clean 

Water Act, the EPA has responsibility for establishing water quality standards for effluent 

discharges. In Virginia, EPA delegates this responsibility to the VDEQ. The depth of 

consideration of alternative water treatment systems is determined by the impact level 

prescribed. In this case, the impact level was SMALL and the staff review was limited to 

alternatives that would be environmentally preferable. Given the relatively small volume of the 

sanitary effluent and the large assimilative capacity of the WHTF, the staff considered it 

unnecessary to evaluate alternatives that would increase costs with no detectable change in 

water quality. No changes were made to the SEIS as a result of these comments. 

Comment: Section 3 introduces the hybrid cooling tower. Is there an operating nuclear plant in 

the U. S. that has demonstrated this hybrid cooling tower technology is appropriate and safe for 

such a large thermal load? If not, the technology risks should be assessed and discussed 

herein. (0023-21 [Goldsmith, Aviv]) 

Response: There are no nuclear plants in the United States that use the proposed hybrid 

cooling tower design. The hybrid cooling system only provides cooling for normal operation. 

The hybrid cooling tower design is called the "normal heat sink." The safe operation and 

shutdown of the ESBWR is not determined by this normal heat sink but by the passive cooling 

design to ensure safe shutdown during design basis accidents and severe accidents (see 

Section 5.10 of SEIS). No changes were made to the SEIS as a result of this comment. 

23. Comments Concerning Alternatives – Sites 

Comment: ESP SDEIS Page 1-5 stated that an EIS must include an evaluation of alternative 

sites to determine whether there are any obvious superior alternatives. Although Chapter 9 
Appendix E 

NUREG-1917, SEIS E-126 February 2010 

determines that there are none, it also does not show that the Lake Anna site is clearly superior 

to many of the alternatives. Further discussion is required. (0023-50 [Goldsmith, Aviv]) 

Comment: And, two, the NRC has failed to correct the problems identified by us, and others, in 

the Draft EIS related to alternative site selection. (0078-17 [Nguyen, Vanthi]) 

Response: Alternative sites were evaluated in Chapter 8 of the ESP EIS (NRC 2006a). No 

additional discussion of this topic is required in a supplement to an ESP EIS that is prepared for 

a COL [10 CFR 51.92(e)(3)]. Hence, no discussion of alternatives sites is included in this SEIS. 

These comments provided no new and significant information. Therefore, no changes were 

made to the SEIS. 

24. Comments Concerning Benefit – Cost Balance 

Comment: I'd like, for a moment, just to address the 800 pound gorilla that is in this room, and 

that is money, and lots of it. My question is, when did we all decide that this is an either or 

proposition? That it is either nuclear or we all end up in dark caves rubbing sticks together, 

trying to make fire? (0075-14 [Farris, Rebecca]) 

Response: The benefit-cost balance for the proposed Unit 3 described in the SEIS relied on 

the best available estimate of project timing and duration, with uncertainties noted. 

Section 10.6 of the SEIS discusses the estimated overall costs and environmental impacts of 

the proposed project. The SEIS does discuss alternative energy sources and describes 

potential impacts from these sources in comparison with the proposed action in Chapter 9 of the 

SEIS. This comment provides no new and significant information. Therefore, no changes were 

made to the SEIS. 

Comment: Nuclear energy does not meet these requirements and is enormously costly to build 

and operate (0051-2 [Harpole, Thane]) 

Response: The comment, in context, generally relates to cost and environmental impacts of 

nuclear power versus other alternatives. It does not provide new and significant information 

concerning the proposed Unit 3. In Chapter 9 of the SEIS, the potential for alternative 

non-nuclear technologies to provide the electricity, and the environmental impacts of these 

alternatives, is discussed. Section 10.6 of the SEIS discusses the estimated overall costs and 

environmental impacts of the proposed project. This comment provides no new and significant 

information. Therefore, no changes were made to the SEIS. 

Comment: An EIS done properly, with full consideration of all factors and all alternatives, and 

with complete transparency of both conclusions and documentation of how those conclusions 

were reached, is a valuable document that can well serve the public. An EIS done without 

sufficient consideration of relevant factors, or without full transparency, instead undermines 

public trust in both the applicant and the regulatory agency. In such a case, the lack of public 

trust and confidence often can result in a final outcome counter to the applicant's desire even if 

a temporary victory, i.e. granting of an initial license, is gained. In this case, the EIS lacks 
Appendix E 

February 2010 E-127 NUREG-1917, SEIS 

credibility and appears more intended at deflecting and deterring public involvement in the EIS 

than contributing to careful and transparent analysis. Specifically, the lack of financial 

information, including basic estimates of construction cost, are to remain proprietary makes any 

discussion of cost/benefit analysis impossible, and thus irrelevant, and leaves the EIS unable to 

fulfill one of its most basic obligations. Absent fundamental information on the cost of this 

project, no cost/benefit analysis can be prepare or reviewed and the document presented is not 

an EIS prepared in compliance with NEPA. (0023-5 [Goldsmith, Aviv]) 

Response: Dominion is entitled by 10 CFR 2.390 to have trade secrets and commercial and 

financial information held by NRC as privileged or confidential, subject to certain procedural 

controls. The Commission also determines whether the right of the public to be fully apprised 

as to whether the bases for and effects of the proposed action outweighs the demonstrated 

concern for protection of a competitive position, and whether the information should be withheld 

from public disclosure. The NRC has determined that the requested financial information shall 

be held as confidential. The comparison of alternatives in Chapter 9 of the SEIS is an 

environmental comparison, not a financial one. This comment provides no new and significant 

information. Therefore, no changes were made to the SEIS. 

Comment: If the perceived benefits of a proposed project outweigh the potential damage and 

costs the project would reasonably be foreseen to cause, then the project is likely to obtain 

approval from regulatory authorities, and gain general public support as well. On the other hand, 

if the project's costs are perceived as greater than any foreseeable benefits, then the project 

likely will be rejected by both the public and regulatory agencies. To have credibility with the 

public and state and local governments and legislatures, this cost/benefit analysis must be as 

complete and transparent as possible. A primary purpose of an Environmental Impact 

Statement (EIS) is to provide this clear, reasoned, transparent cost/benefit analysis of a 

proposed project. (0023-4 [Goldsmith, Aviv]) 

Response: The purpose of the SEIS is to disclose potential environmental impacts of building 

and operating the proposed Unit 3 at the NAPS site. The disclosure of the costs of the 

proposed action relies on the best available estimate of financial costs with uncertainties noted. 

Associated costs that cannot be reliably quantified are discussed. Section 10.6 of the SEIS 

discusses the estimated overall internal and external benefits, costs, and associated 

environmental impacts of the proposed project. This comment provides no new and significant 

information. Therefore, no changes were made to the SEIS. 

Comment: Several important issues have come up which involve significant changes since the 

Draft EIS...Financial credit crisis will significantly affect availability of credit, costs, etc. 

(0012-5 [Rosenthal, Jerry]) 

Comment: Factors in the analysis such as capital and operating costs and operating 

efficiencies should be detailed. The conclusion on page 8-5 line 23 is not supported. 

(0023-48 [Goldsmith, Aviv]) 
Appendix E 

NUREG-1917, SEIS E-128 February 2010 

Comment: And deciding how Dominion balances their energy use. Dominion is going to spend 

more money just on applying to get this plant, than they are going to spend on all renewables, 

conservation, and energy efficiency. And that is not going to give us one kilowatt, we are just 

going to pay lawyers, lobbyists, and for paperwork. And get nothing. Where is the balance? 

(0082-16 [Rosenthal, Jerry]) 

Comment: Cost? Let's get realistic. Every analysis shows this is the highest cost that you can 

get. You don't have to go anywhere, MIT, Rocky Mountain Institute, IEER, everyone is going to 

show the exact same thing. This is the highest cost. And how is Dominion going to pay for it? 

Are they going to pay for it upfront? No. They want loan guarantees from the government. They 

want, and they use their lobbyists in power. They want the state of Virginia to bill you in 

advance, before we get any power. No other source do we do it that way. If it is safe why do 

they need subsidized insurance? If it is cheap, why stick their hands at every possible 

opportunity, into the taxpayer and the ratepayers' pocket? (0082-17 [Rosenthal, Jerry]) 

Response: The economic factors listed in these comments, and their significance, were 

examined in Section 10.6 of the SEIS. One commenter states that several outcomes of the 

current recession have called into question assumptions underlying the demand for power. 

Although the PJM market study for 2009 forecasts reduced demand for electricity in the overall 

PJM region compared with the 2008 study, the forecast for the Dominion Zone is virtually 

unchanged compared with the 2008 forecast. The financial credit crisis may have changed 

credit availability to some classes of borrowers, but the Federal Reserve response has generally 

reduced interest rates. The capital costs of the plant are expected to remain within the range of 

costs reported in the latest public studies. These newer cost estimates are reported in section 

10.6, but they are not significantly different from the range of costs reported in the draft and do 

not affect the conclusion. Unit 3 still is needed and the benefits still are believed to exceed the 

costs. 

Comment: Today the importance of nuclear power, the operation of -- this is operational cost, 

and this is from 2006, and this is nationwide, is 1.666 cents per kilowatt hour. Which is lower 

than coal, and much lower than gas. I don't know if you know it, but as of just two years ago, 

gas-fired electricity is costing you ten cents per kilowatt hour. And it has gone up from that point. 

(0082-22 [Harte, Vicky]) 

Response: This comment is largely a supporting statement for nuclear power on the basis of 

stable prices and specifically for NAPS Unit 3 as an economic stimulus for the region. This 

comment provides no new and significant information. Therefore, no changes were made to the 

SEIS. 

Comment: If environmental reasons do not convince you, please consider the cost. Think of 

the wind or solar farms that could built for the same amount. Also, there is the cost of 

transporting and storing dangerous radioactive waste somewhere. There is the liability of 

accidentally releasing radiation either from the plant or in the process of transportation and 
Appendix E 

February 2010 E-129 NUREG-1917, SEIS 

storage. Rate payers do not want to pay for this enormously expensive project. Why continue 

generating electricity by this dangerous and environmentally destructive method? 

(0025-1 [Cowles, Virginia]) 

Response: The costs and benefits of construction and operations of the proposed Unit 3 are 

addressed in Section 11.6 of the SEIS. The NRC does not have authority or responsibility by 

law or regulation to ensure that the proposed plant is the least costly alternative to provide 

energy services under any particular set of assumptions concerning future circumstances. This 

authority and responsibility is most often the role of State regulatory authorities such as public 

service commissions, or in the case of merchant plants, the competitive marketplace. The 

potential for alternative non-nuclear technologies to provide the electricity that could be 

generated by the proposed plant, and their environmental impacts, are considered in Chapter 9 

of the SEIS. This comment provides no new and significant information. Therefore, no changes 

were made to the SEIS. 

Comment: In Chapters 8 and 10 of its COLA-ER, Dominion notes that one benefit of the 

proposed action is the avoidance of air pollutants that would be emitted if the need for power 

was met by constructing and operating alternative coal- or gas-fired plants. This benefit is 

increasingly significant with regard to emissions of carbon dioxide, which is a greenhouse gas. 

The DSEIS acknowledges this in Chapter 9 but does not bring it forward to the benefit/cost 

discussion. Dominion suggests the NRC revise the DSEIS section 10.6.1 discussion of benefits 

by adding avoidance of emissions in general and greenhouse gas emissions in particular. 

(0084-34 [Grechek, Eugene]) 

Response: The benefit cited in this comment is actually an environmental cost of the 

alternative technology rather than a specific benefit of nuclear energy. NRC has chosen to keep 

these costs and benefits separate. No change was made to the SEIS as a result of this 

comment. 

25. General Comments in Support of the Licensing Action 

Comment: LACA's Water Quality Committee also supports the proposed third unit at Lake 

Anna with certain reservations. (0018-1 [Remmers, Ken]) 

Comment: I am very supportive of nuclear energy and for the NRC to issue a combined 

license for the North Anna Power Station, Unit 3, based upon the draft SEIS. This country made 

a decision to use nuclear power some 30 years ago and we have only seen positive upgrades 

to existing systems. Now we have an opportunity to finally invest in an additional reactor. 

(0020-1 [Aylor, Joseph]) 

Comment: And we think that, in fact we have great confidence in the fact that these examples 

of Dominion working with the community, and working with the county government, give us the 

confidence to, again, support the issuance of the license, and the construction of unit 3 

(0073-10 [Harper, Willie]) 
Appendix E 

NUREG-1917, SEIS E-130 February 2010 

Comment: The North Anna Power Station is a vital part of our local economy, and the 

economy of this region. Just for an example, in 2007, the taxes that North Anna Power Station 

generated for Louisa County, was about 20.76 percent, or 10,720,000 dollars of Louisa County 

local revenue for the general fund. (0073-15 [Mullen, Dale]) 

Comment: Reactor 3 brings important and unique economic, employment, and environmental 

opportunities for Louisa County. There are also environmental impacts that I'm eager to see 

examined, and explained. For these reasons I'm committed, on behalf of Louisa County, to 

continue our work with Dominion, and our continued support of our friends and neighbors at 

Dominion and the North Anna Power Station. (0073-21 [Mullen, Dale]) 

Comment: If Louisa and Virginia are to remain a competitive location we must have reliable, 

affordable source of energy. Unit 3, at Dominion North Anna, is a part of that solution, along with 

coal, wind, solar, and other sources. (0073-26 [Gibson, Bob]) 

Comment: While all types of generation must play a role in meeting Virginia's energy needs, 

Dominion believes clean, and safe nuclear energy must play a large role. 

(0073-30 [Faggert, Pam]) 

Comment: In closing, we are very encouraged by the NRC staff's preliminary recommendation 

that the COL be issued as proposed. (0073-32 [Faggert, Pam]) 

Comment: LACA Water Quality Committee also supports the proposed third unit at Lake Anna, 

with certain reservations. (0073-33 [Remmers, Ken]) 

Comment: But unit 3 can generate a significant amount of electricity without releasing any 

gases that are linked to the global climate change. (0073-4 [Harper, Willie]) 

Comment: In fact, the NRC has determined, early on, that unit 3 could be built without any 

significant impact to the environment at the North Anna site. And, at least to my knowledge, 

there has been no additional significant impacts identified. (0073-5 [Harper, Willie]) 

Comment: Louisa County has gone on record, in several instances, as endorsing this project, 

and we want to continue with that effort. We base that a lot on the track record that we have had 

with Dominion through the years. (0073-6 [Harper, Willie]) 

Comment: And we do this endorsement knowing full well that we have some citizens that do 

have concerns about the environmental impacts that may occur here with this project. 

(0073-8 [Harper, Willie]) 

Comment: But Dominion's decision to go with the wet-dry cooling system, cooling tower if you 

will, is an indication I believe, and the Board believes, of their willingness to work with people to 

resolve the differences. (0073-9 [Harper, Willie]) 

Comment: And so we are in support of the current plans by Dominion to construct and operate 

reactor number 3. (0075-10 [Bishop, Wayman]) 
Appendix E 

February 2010 E-131 NUREG-1917, SEIS 

Comment: In summary, the impact of job creation, and higher disposable incomes from this 

project, along with providing energy for a rapidly expanding population, will be a major economic 

stimulus to the region's economy, and be nothing short of a phenomenon, a stimulus package 

created by the private sector. (0075-18 [Bailey, Gene]) 

Comment: and urge that the Commission move forward with a timely review of this application. 

(0075-19 [Farmer, John]) 

Comment: I'd like to comment in support of the Combined Operating License for the new unit. 

Virginia, and for that matter the entire nation, badly needs a balanced energy strategy to meet 

our growing energy demands. The third unit at North Anna will be a key component in this 

program. (0075-22 [Beament, Pete]) 

Comment: And I think he is typical, they are the lifeblood of this community, of this county. 

Dominion and their employees have been a great neighbor. I sincerely hope that they are 

allowed to build reactor 3. (0075-34 [Carroll, John]) 

Comment: So I support Dominion's Combined License Application for North Anna unit 3, and 

conclusions contained in the NRC's Draft Supplemental Environmental Impact Statement. 

(0075-39 [Stiles, Lisa]) 

Comment: North Anna Unit 3 will benefit local communities, the Commonwealth, and the 

nation, by providing safe, reliable electricity, with technology that has a small overall 

environmental footprint, by providing good jobs that can't be outsourced, and providing large tax 

revenues. (0075-40 [Stiles, Lisa]) 

Comment: I'm here tonight to support the Draft Supplemental Environmental Impact Statement 

for the third reactor at North Anna. (0075-46 [Girvin, Larry]) 

Comment: Not only will a third reactor at North Anna provide affordable baseload power, but it 

will do so in a safe and environmentally conscious way. (0075-48 [Girvin, Larry]) 

Comment: And our informed opinion is that there is no compelling evidence, that has been 

made known to us, through these reports, and through our association with Dominion, that 

would suggest that the approval of the recommendations, findings, and conclusions of the Draft 

Supplemental Environmental Impact Statement should be dismissed. We concur with them, 

and would highly recommend that the Combined Operating License for reactor number 3 be 

issued. (0075-8 [Bishop, Wayman]) 

Comment: Virginia needs a balanced strategy moving forward to meet our increasing energy 

needs, while at the same time being mindful of the environment. The third nuclear unit at North 

Anna is a key component of this responsible and balanced energy strategy. 

(0077-3 [Girvin, Larry]) 
Appendix E 

NUREG-1917, SEIS E-132 February 2010 

Comment: I speak today on behalf of the Clean and Safe Energy Coalition, CASE Energy, and 

we support the construction of new reactors like the one proposed here at North Anna. 

(0077-5 [Nelson, Deborah]) 

Comment: I appreciate the work that the Commission has done. I appreciate the wide range of 

things that you have looked at. I was offended for you when someone tried to insinuate that 

money would influence your decisions. Keep up the good work and I hope that barring new 

information, that your final recommendation will be to continue to -- that the recommendation be 

to issue the COL. (0078-23 [Smith, Jay]) 

Comment: And I'm here tonight to support North Anna 3, and the nuclear industry in general. 

(0081-9 [Mosser, Dave]) 

Comment: I support this combined operating license. (0082-2 [Reynolds, Norm]) 

Comment: And it is very encouraging to see that we do have a process like this going forward. 

(0082-7 [Mastilovic, Nick]) 

Comment: The only disappointment that I really do have here is that this EIS is just for one 

reactor, and not more. And I do hope that Danville Utilities will one day consider Dan River 1, 2, 

and 3. (0082-9 [Mastilovic, Nick]) 

Response: These comments express general support of the proposed NAPS Unit 3 COL 

application (Dominion 2008). They provide no new and significant information. Therefore, no 

changes were made to the SEIS. 

Comment: LACA continues to support the proposed third unit, and we do have some lingering 

concerns that I would like to discuss this evening. (0073-46 [Smith, Doug]) 

Response: This comment expresses general support of the proposed NAPS Unit 3 COL 

application but with concerns. The nature of the concerns was not specifically provided; 

therefore, no change was made to the SEIS. 

26. General Comments in Support of the Licensing Process 

Comment: Furthermore they have also confirmed this new reactor can be safely sited, and 

operated, in a way that will have a minimal impact on the environment. 

(0075-26 [Beament, Pete]) 

Comment: I wish to thank you for giving me this opportunity to comment in support of the 

Combined Operating License tonight. (0077-4 [Girvin, Larry]) 

Comment: The NRC is not in love with Dominion, or any other utility. The Women in Nuclear is 

grateful for their regulatory oversight. And if you don't believe that, all you need to do is look on 
Appendix E 

February 2010 E-133 NUREG-1917, SEIS 

their website, and look at all the enforcement actions, and initiatives that they have taken 

against utilities for not being in compliance with something. (0082-19 [Harte, Vicky]) 

Response: These comments express general support of the NRC’s COL process. No new 

and significant information was provided. Therefore, no changes were made to the SEIS. 

27. General Comments of Support of Nuclear Power 

Comment: Also, businesses and residential properties will continue to improve and benefit the 

county and state for generations into the future (0020-3 [Aylor, Joseph]) 

Comment: I am a conservationist but am also a realist. Until we get alt enr online we need 

nuke energy. (0050-1 [Gignac, David]) 

Comment: I support nuclear power over coal, as long as it does not negatively impact the 

environment. (0061-1 [Ahlgrim, Larry]) 

Comment: The emphasis is on reliability. When you turn on the switch the power comes on 

immediately. You can't rely on all the alternative energy, or so-called green energy, to do this in 

a consistent manner. And this really closes a big gap, it provides an enormous baseload 

capability. (0075-24 [Beament, Pete]) 

Comment: Driving my participation in these groups is the knowledge that nuclear power is 

safe, clean, and reliable and an important part of a balanced energy mix. Balanced energy mix 

includes conservation and efficiency, nuclear and cleaner coal for baseload power, and a mix of 

natural gas and renewables, like wind, solar, and biomass. (0075-35 [Stiles, Lisa]) 

Comment: In a national energy portfolio that ensures our security and our economic growth, 

and that properly balances our need for reliable power, with our need to preserve the 

environment, nuclear must play a role. (0075-38 [Stiles, Lisa]) 

Comment: And wise energy policy recognizes the virtue of diversity. And in that diverse plan 

nuclear energy is a critical component. We all have a shared stake in America's energy future, 

and now is the time for our country to support nuclear energy as a means to generate electricity 

with a clean, safe, and dependable source of power. (0077-10 [Nelson, Deborah]) 

Comment: I speak today on behalf of the Clean and Safe Energy Coalition. We are a national 

grassroots organization of more than 1,800 individuals, and organizations, who come together 

to support nuclear power as a vital part of our country's energy portfolio. 

(0077-11 [Lamboley, Genevieve]) 

Comment: Nuclear energy is clean. The environmental impact at nuclear plants is far lower 

than at many other types of power generating plants. Nuclear energy is safe. In fact, the 

U.S. Bureau of Labor Statistics has shown that it is safer to work in a nuclear power plant than it 

is in the manufacturing sector, and even in the real estate and financial industries. 
Appendix E 

NUREG-1917, SEIS E-134 February 2010 

Subsequently a nuclear plant makes a good neighbor. It supports high paying jobs, directly at 

the plant, generates additional jobs in the community where it is located, and contributes by 

helping build good schools and roads. As our job report prints out, which you can access on our 

website, cleansafeenergy.org, if U.S. companies were to complete the more than 30 reactors 

now under construction, 12,000 to 21,000 new jobs would be added to the market. 

(0077-13 [Lamboley, Genevieve]) 

Comment: Already the nuclear energy industry has created 15,000 new jobs, and added four 

billion dollars to the economy, to prepare for building new state of the art reactors. In these 

economic times there is no stronger argument in support of expanding nuclear power. 

(0077-14 [Lamboley, Genevieve]) 

Comment: Nuclear power is safe, and effective, and it provides reliable energy. North Anna 

Power Station was built with safety in mind, and safe work practices are reinforced through 

training, and continuous improvement measures. (0077-2 [Girvin, Larry]) 

Comment: And we are actively engaged in generating a public dialogue to educate others 

about the economic and environmental benefits of new nuclear power. 

(0077-6 [Nelson, Deborah]) 

Comment: And nuclear energy is clean. It is the only large scale emissions-free source of 

electricity that we can readily expand to meet our growing energy demand. It already accounts 

for 70 percent of all clean energy produced in the U.S., and supplies 20 percent of all 

U.S. power. (0077-8 [Nelson, Deborah]) 

Comment: I support energy conservation, energy efficiency. And it is easy to say that that 

would solve our need for new energy. But those are just words. If we all drove hybrid cars, or 

electricity cars, we wouldn't need gas. But until then we don't stop building gas stations. Those 

seeking for guarantees in a project like this, or an energy source that has zero impact, need to 

know that there is no such thing. But what we can take comfort in is knowing that this is a highly 

regulated industry. This facility is highly regulated. In fact, they introduced two people who are 

there every day, making sure that it is abiding by the regulations. They are there to manage the 

risks, protect the environment and ensure the health of area residents. We need cleaner energy, 

and we need it now. Nuclear energy is a way to achieve that, and reduce our country's 

dependence on other energy, from other countries. (0078-21 [Smith, Jay]) 

Comment: There is no energy source that does not have an impact; an impact on the 

communities that it is in; an impact on the environment that it is placed within. I challenge 

anyone to venture forth a design for 1,500 megawatts electric baseload energy supply with a 

more benign environmental footprint than the one that is being evaluated by the NRC in this 

Environmental Impact Statement. Particularly one that can continue to produce power so 

reliably even during summer drought months. You would be hard-pressed to find 

1,500 megawatts that can produce 24 hours a day, seven days a week, even during a drought. 

(0079-1 [Taylor, Kelly]) 
Appendix E 

February 2010 E-135 NUREG-1917, SEIS 

Comment: And I can tell you, my first-hand experience, that no one in the industry puts so high 

a value on public safety and industrial safety, as nuclear power. In addition to that no other 

industry that I have worked in puts so high of a value on environmental stewardship. I have 

witnessed these things first-hand from the inside of these industries. So I can tell you that it is 

true, and it happens. (0081-7 [Mosser, Dave]) 

Comment: The second thing I would like to talk about tonight, and I hadn't initially thought 

about this, but in listening to a lot of folks tonight talk about conserving energy, and how that is 

going to save us into prosperity, I would like to say that is a little bit naive. And to illustrate that 

point, I would like you all to think about, if you were alive 30 years ago, I bet none of you had a 

personal computer. Twenty years ago none of you had a cell phone, ten years ago none of you 

had a wide screen TV, and five years ago none of you had a hybrid car. A lot of you have all of 

those things, or some of those things now. As an electrical engineer I can, I am positive, I am 

confident that electric-driven cars are our future. If you don't believe it, if you don't believe that 

there is a viable technology for electric cars, google Tesslen Motor Company, and look, there is 

a car that can go faster than a Ferrari, and can go 300 mile range, and it is available today. 

Now, the only drawback is that it is too expensive. But the technology is proven, it is coming, 

and it is going to be here. And I know that six months ago all of you were just like me, and were 

screaming at paying five dollars a gallon for gasoline. And it is going to happen again, because 

oil producing countries are going to take advantage when they can. Building safe and reliable 

energy, that is base loaded, that we can charge our electric cars at night is a good plan. 

(0081-8 [Mosser, Dave]) 

Comment: I strongly support nuclear energy. (0082-1 [Reynolds, Norm]) 

Comment: And I would like to say that I am a Member of Women in Nuclear, which is an 

organization that promotes the peaceful use of nuclear energy in all forms, business, medical, 

agricultural, and power wise. I've listened to a lot of what some of the people have said today, 

and from some -- one of the things, the nuclear industry in the past, if you go back, there has 

been a lot of talk of accidents that have happened in the past. And, overall, since the 1970s, 

the U.S. nuclear industry has dramatically improved its safety and operational performance. And 

now, by the start of this decade, we are among the world leaders with a capacity factor of over 

90 percent. (0082-18 [Harte, Vicky]) 

Comment: One thing that we do do, is we do do a lot of polling. And I just want to show you 

how public opinion has changed. In May 2005 70 percent favored the continued use of nuclear 

energy. In March 2006, 68 percent of people favored the use of nuclear energy. And in 2007 a 

survey of individuals living within 16 kilometers of nuclear power plants, but without any 

personal involvement, showed very strong support for new nuclear plants. Ninety percent 

thought that nuclear energy was important for the supply, 82 percent favored it now, and 

70 percent said they would accept a new plant. And this included plants that have on-site spent 

fuel storage. In August 2007 opposition started growing towards any type of thermal powered 

plant, in local communities, with 65 percent against nuclear, but 60 percent also against fossil. 

So if you are against fossil and nuclear your opportunities are slightly diminished. In April of 

2008 nuclear power support was back up to 82 percent, and in September 2008, 74 percent are 
Appendix E 

NUREG-1917, SEIS E-136 February 2010 

in favor of nuclear energy, with 69 percent favored definitely building new plants in the future, 

and 75 percent believing that having them built close to where they live is acceptable. 

(0082-24 [Harte, Vicky]) 

Comment: I spent quite a bit of time in Charlottesville, myself, at UVA. It is heartbreaking to 

see the nuclear program basically disappear there, see Observatory Hill disappear. 

(0082-5 [Mastilovic, Nick]) 

Comment: My experience with nuclear power is that I used to live within 200 feet of a reactor 

for three months at a time. I was sealed up inside a small vessel with 150 of my closest friends. 

We could breathe the air inside this vessel. It made all the water we needed, all the heat we 

needed, all the electricity we needed, and it pushed us around the ocean at a pretty fast clip at 

times. Now, that is a power plant operated for 14 years without new fuel. At the end of that 

operational time, the waste from that fuel would have fit in a podium just about twice the size of 

this one, okay? Imagine that, 9,000 ton ship with the waste inside a podium the size of this. 

Somebody quoted about the Asheville. We are talking about five million gallons of coal ash 

slurry from operating a power plant for 50 years. If you operated a nuclear power plant for 

50 years, you would fit the waste product inside the first couple of rows in this auditorium. That 

is all it would. Waste is the best news issue about nuclear power. Waste is so tiny, so compact, 

that my personal waste, if all of my energy came from nuclear power, it would fit inside a coke 

can. (0083-2 [Adams, Rod]) 

Response: These comments express general support for nuclear power. These comments 

provided no new and significant information. Therefore, no changes were made to the SEIS. 

28. General Comments in Support of the Existing Plant 

Comment: Dominion Power has an excellent safety record. I spent 43 years in a property and 

casualty business, and I understand the importance of safety. And I know, from experience, 

that it has to come from the top down. And I have found that Dominion has a strong commitment 

to safety, and I have been in their shop, I have seen some of their programs, when they have 

been recognized for their safety records, and I commend them for that. 

(0073-1 [Wright, Jack]) 

Comment: Dominion has many programs to try to save, to promote energy savings. 

(0075-28 [Carroll, John]) 

Comment: Dominion has been a great neighbor. Since 2004 we, as a community, have tried to 

raise money to put lights on the girl's ball field, right next door, here at the high school. It was 

very expensive, it was difficult. Two weeks ago Dominion shows up and installed those lights, at 

their own cost. Dominion has been a great neighbor. (0075-32 [Carroll, John]) 
Appendix E 

February 2010 E-137 NUREG-1917, SEIS 

Comment: I'm not sure of the exact time line, but when Harry Ruth and the Friends of Lake 

Anna pressed for a cooling tower, Dominion immediately stepped up and at a huge cost agreed 

to implement the tower in their design. Dominion has been a great neighbor. 

(0075-33 [Carroll, John]) 

Comment: Dominion is investing in all of these [renewables], including conservation and 

efficiency. (0075-36 [Stiles, Lisa]) 

Comment: Currently nuclear provides about one-fifth of our nation's electricity and about onethird of Virginia's. In Virginia the power output of the Surry and North Anna plants represent 

about seven million tons of carbon dioxide emissions avoided each year. (0075-37 [Stiles, Lisa]) 

Comment: I would be against anything that threatened my enjoyment of the lake. But 

Dominion has taken extensive steps to ensure minimal impact on it. (0075-41 [Stiles, Lisa]) 

Comment: We need to remember that the power plant gave us the lake, and it has been a 

good neighbor, and I believe that it will continue to be a good neighbor. (0078-22 [Smith, Jay]) 

Comment: And it is very heartening to see a company like Dominion take the lead, as they are 

right now, in bringing new technology to this state. It is embarrassing to see other countries 

taking the lead, and potentially getting ahead of us, in things like power generation, and so forth. 

(0082-6 [Mastilovic, Nick]) 

Response: These comments express support for the existing operating units at the NAPS site. 

No new and significant information was provided. Therefore, no changes were made to the 

SEIS. 

Comment: Summary The lake Anna Civic Association supports the third unit, but we are 

concerned that Lake use impacts have not been considered. (0019-6 [Smith, Doug]) 

Response: This comment expresses support of Unit 3 at the NAPS site, but is concerned that 

impacts to Lake Anna have not been considered. The nature of the impacts was not 

specifically provided. Therefore, no change was made to the SEIS. 

29. General Comments in Opposition of the Licensing Action 

Comment: As Chief of the Pamunkey Indian Tribe of Virginia, I am writing this letter to ask that 

a permit NOT be given to Dominion Power for construction of a new nuclear reactor at the North 

Anna site. (0013-1 [Brown, Kevin]) 

Response: This comment expresses opposition to the NAPS Unit 3 COL. No specific 

information relevant to the environmental review was provided. Therefore, no changes were 

made to the SEIS. 
Appendix E 

NUREG-1917, SEIS E-138 February 2010 

Comment: The NRC has no business approving a third reactor at North Anna. 

(0005-2 [Cruickshank, John]) 

Comment: I do not understand why the NRC would even consider construction of a 3rd 

reactor. I oppose construction of a new reactor at the North Anna Power Station. 

(0006-2 [Neale, Laura]) 

Comment: Please do not allow a third nuclear reactor at the North Anna site in Louisa County, 

VA, about 30 miles east of Charlottesville. (0011-1 [Abbott, William] [Ahlgrim, Larry] [Alexander, 

Mary] [Alexander, Mary] [Alexander, Nancy] [Allen, Connie] [Antoniewicz, Susan] [Appleby, 

Monica] [Apple, Joe] [Arens, Jordan] [Artemis, Diana] [Bailey, Marcia] [Baird, Heidi] [Bandita, 

Gypsy] [Biggs, Amy] [Bockstiegel, Dorothy] [Boissonnault, James] [Bolduc, Joan] [Brackett, 

Carl] [Bradshaw, Claude] [Brown, E] [Brummer, Ann] [Burtner, Caryl] [Burt, William] [Butcher, 

Ava] [Churray, Richard] [Clark, Diane] [Clark, Loralee] [Clark, Loralee] [Clark, Theda] [Cleary, 

Thomas] [Collingwood, Claudia] [Cook, Joe] [Cowles, Virginia] [Cummings, Russell] [Currie, 

Susan] [Dail, Michelle] [Daiss, Becky] [Davies, Beth] [De Trinis, Bonita] [Deming, Jill] 

[Desimone, John and Shirley] [Dickon, Elisa] [DiMarco, Paul] [D'Onofrio, Adam] [Dukovich, 

John] [Dunbar, Mary] [Ebert, Paul] [Farnham, Ross] [Fasceski, Jeffrey] [Feury, Patricia] [Figg, 

Landon] [Fiscella, Glenn] [Ford, Betty] [Franke, John] [Frank, Sarah] [Frantz, Norma] [Fritzler, 

Deb] [Gaige, Eve] [Galindo, Ted and Carolyn] [Gann, Sara] [Gignac, David] [Grant, Mary] [HallBodie, Adrienne] [Ham, Elspeth] [Hamilton, Jim and Donna] [Hanger, Jane] [Hanks, Lou] 

[Harpole, Thane] [Hartwig, Kristina] [Heegaard, Flemming] [Heflin, Kerby] [Heim, Anka] 

[Hepburn, Chet] [Hess, David] [Hinkle, Carol] [Hodge, Mary] [Hoehlein, Jill] [Hoffman, Lilli] 

[Holtzback, Kaite] [Horwege, Richard] [Houston, Karin] [Hutchinson, Amber] [Jaronczyk, Ellen] 

[Jewell, B] [Johns, Brian] [Josaitis, Marvin] [Kalukin, Andrew] [Keyser, Liz] [Kiehl, Allison] 

[Kosch, Sandra] [Kroupa, Brenda] [Kunkel, Christopher] [Larsen, Anne] [Larsen, Janice] 

[Laverdiere, Dorothy] [LeClair, Carol] [Leon, Matea] [Light, John] [Liske, Patricia] [Lloveras, 

Lang] [Lufkin, Heather] [Maddox, Joshua] [Marroni, Edmond] [McDonald, Kim] [McFarland, Mary 

Ann] [McNeal, Ashby] [Meredith, Betty] [Meyer, Jennifer] [Miles, Linda] [Miller, Katelyn] [Miller, 

Lara] [Miller, Mary] [Mullinax, Franklin] [Newell, Vicky] [Payne, Andrew] [Phillips, Donna] 

[Pintado, Isabel] [Plaskett, Micheline] [Plata, Errol] [Presgraves, Sandra] [Presley, Diann] 

[Rasmussen, Angela] [Reiner, Brian] [Rigby, John] [Roadcap, Leah] [Roadcap, Leah] [Robbins, 

Patricia] [Rollins, Megan] [Roth, David] [Schmidt, Arthur] [Scott, Patricia] [Shamaiengar, Beth] 

[Shelton, Charles] [Shields, Page] [Sklar, Scott] [Smith, John] [Smith, Louise] [Squires, George] 

[Steegmayer, Andrea] [Stone, Eric] [Sumrall, Kamar] [Suter, Emanuel] [Tanner-Sutton, Linda] 

[Tarr, Suzanne] [Teeler, Sharon] [Testerman, Michael] [Traub, Charles] [Van Lingen, Gabriele] 

[Wells, Cathy] [Werderman, Kim] [White, Eric] [White, Phyllis] [Whitfield, Doris] [Williams, 

Martha] [Wilson, Brian] [Wilson, Brian] [Witting, Marjorie] [Woitte, Roger]) 

Comment: A third reactor should not be built at North Anna. It will put unreasonable stress on 

water resources and jeopardize the health and safety of Virginia citizens 

(0011-5 [Abbott, William] [Ahlgrim, Larry] [Alexander, Mary] [Alexander, Mary] [Alexander, 

Nancy] [Allen, Connie] [Antoniewicz, Susan] [Appleby, Monica] [Apple, Joe] [Arens, Jordan] 

[Artemis, Diana] [Bailey, Marcia] [Baird, Heidi] [Biggs, Amy] [Bockstiegel, Dorothy] 

[Boissonnault, James] [Bolduc, Joan] [Brackett, Carl] [Bradshaw, Claude] [Brown, E] [Brummer, 
Appendix E 

February 2010 E-139 NUREG-1917, SEIS 

Ann] [Burtner, Caryl] [Burt, William] [Butcher, Ava] [Churray, Richard] [Clark, Diane] [Clark, 

Loralee] [Clark, Loralee] [Clark, Theda] [Cleary, Thomas] [Collingwood, Claudia] [Cook, Joe] 

[Cowles, Virginia] [Cummings, Russell] [Currie, Susan] [Dail, Michelle] [Daiss, Becky] [Davies, 

Beth] [De Trinis, Bonita] [Deming, Jill] [Desimone, John and Shirley] [Dickon, Elisa] [DiMarco, 

Paul] [D'Onofrio, Adam] [Dukovich, John] [Dunbar, Mary] [Ebert, Paul] [Farnham, Ross] 

[Fasceski, Jeffrey] [Feury, Patricia] [Figg, Landon] [Fiscella, Glenn] [Ford, Betty] [Franke, John] 

[Frank, Sarah] [Frantz, Norma] [Fritzler, Deb] [Gaige, Eve] [Galindo, Ted and Carolyn] [Gann, 

Sara] [Gignac, David] [Grant, Mary] [Hall-Bodie, Adrienne] [Ham, Elspeth] [Hamilton, Jim and 

Donna] [Hanger, Jane] [Hanks, Lou] [Harpole, Thane] [Hartwig, Kristina] [Heegaard, Flemming] 

[Heflin, Kerby] [Heim, Anka] [Hepburn, Chet] [Hess, David] [Hinkle, Carol] [Hodge, Mary] 

[Hoehlein, Jill] [Hoffman, Lilli] [Holtzback, Kaite] [Horwege, Richard] [Houston, Karin] 

[Hutchinson, Amber] [Jaronczyk, Ellen] [Jewell, B] [Johns, Brian] [Josaitis, Marvin] [Kalukin, 

Andrew] [Keyser, Liz] [Kiehl, Allison] [Kosch, Sandra] [Kroupa, Brenda] [Kunkel, Christopher] 

[Larsen, Anne] [Larsen, Janice] [Laverdiere, Dorothy] [LeClair, Carol] [Leon, Matea] [Light, John] 

[Liske, Patricia] [Lloveras, Lang] [Lufkin, Heather] [Maddox, Joshua] [Marroni, Edmond] 

[McDonald, Kim] [McFarland, Mary Ann] [McNeal, Ashby] [Meredith, Betty] [Meyer, Jennifer] 

[Miles, Linda] [Miller, Katelyn] [Miller, Lara] [Miller, Mary] [Mullinax, Franklin] [Newell, Vicky] 

[Payne, Andrew] [Phillips, Donna] [Pintado, Isabel] [Plaskett, Micheline] [Plata, Errol] 

[Presgraves, Sandra] [Presley, Diann] [Rasmussen, Angela] [Reiner, Brian] [Rigby, John] 

[Roadcap, Leah] [Roadcap, Leah] [Robbins, Patricia] [Rollins, Megan] [Roth, David] [Schmidt, 

Arthur] [Scott, Patricia] [Shamaiengar, Beth] [Shelton, Charles] [Shields, Page] [Sklar, Scott] 

[Smith, John] [Smith, Louise] [Squires, George] [Steegmayer, Andrea] [Stone, Eric] [Sumrall, 

Kamar] [Suter, Emanuel] [Tanner-Sutton, Linda] [Tarr, Suzanne] [Teeler, Sharon] [Testerman, 

Michael] [Traub, Charles] [Van Lingen, Gabriele] [Wells, Cathy] [Werderman, Kim] [White, Eric] 

[White, Phyllis] [Whitfield, Doris] [Williams, Martha] [Wilson, Brian] [Wilson, Brian] [Witting, 

Marjorie] [Woitte, Roger]) 

Comment: Say no to a new nuclear reactor at North Anna. (0011-7 [Abbott, William] 

[Alexander, Mary] [Alexander, Mary] [Alexander, Nancy] [Allen, Connie] [Antoniewicz, Susan] 

[Appleby, Monica] [Apple, Joe] [Arens, Jordan] [Baird, Heidi] [Biggs, Amy] [Bockstiegel, Dorothy] 

[Boissonnault, James] [Bolduc, Joan] [Brackett, Carl] [Bradshaw, Claude] [Brown, E] [Brummer, 

Ann] [Burtner, Caryl] [Butcher, Ava] [Churray, Richard] [Clark, Diane] [Clark, Loralee] [Clark, 

Loralee] [Clark, Theda] [Cleary, Thomas] [Collingwood, Claudia] [Cook, Joe] [Cowles, Virginia] 

[Currie, Susan] [Dail, Michelle] [Daiss, Becky] [Davies, Beth] [De Trinis, Bonita] [Deming, Jill] 

[Desimone, John and Shirley] [Dickon, Elisa] [D'Onofrio, Adam] [Dukovich, John] [Dunbar, Mary] 

[Fasceski, Jeffrey] [Feury, Patricia] [Figg, Landon] [Fiscella, Glenn] [Ford, Betty] [Franke, John] 

[Frank, Sarah] [Frantz, Norma] [Fritzler, Deb] [Gaige, Eve] [Galindo, Ted and Carolyn] [Gann, 

Sara] [Gignac, David] [Grant, Mary] [Hall-Bodie, Adrienne] [Ham, Elspeth] [Hamilton, Jim and 

Donna] [Hanger, Jane] [Hanks, Lou] [Harpole, Thane] [Heegaard, Flemming] [Heflin, Kerby] 

[Heim, Anka] [Hepburn, Chet] [Hess, David] [Hinkle, Carol] [Hodge, Mary] [Hoehlein, Jill] 

[Hoffman, Lilli] [Holtzback, Kaite] [Horwege, Richard] [Houston, Karin] [Hutchinson, Amber] 

[Jaronczyk, Ellen] [Johns, Brian] [Josaitis, Marvin] [Kalukin, Andrew] [Keyser, Liz] [Kiehl, Allison] 

[Kosch, Sandra] [Kroupa, Brenda] [Kunkel, Christopher] [Larsen, Anne] [Larsen, Janice] 

[Laverdiere, Dorothy] [LeClair, Carol] [Leon, Matea] [Light, John] [Lloveras, Lang] [Lufkin, 

Heather] [Maddox, Joshua] [Marroni, Edmond] [McDonald, Kim] [McFarland, Mary Ann] 
Appendix E 

NUREG-1917, SEIS E-140 February 2010 

[McNeal, Ashby] [Meyer, Jennifer] [Miles, Linda] [Miller, Katelyn] [Miller, Lara] [Miller, Mary] 

[Mullinax, Franklin] [Newell, Vicky] [Phillips, Donna] [Pintado, Isabel] [Plaskett, Micheline] [Plata, 

Errol] [Presgraves, Sandra] [Presley, Diann] [Rasmussen, Angela] [Reiner, Brian] [Rigby, John] 

[Roadcap, Leah] [Rollins, Megan] [Roth, David] [Schmidt, Arthur] [Scott, Patricia] [Shelton, 

Charles] [Shields, Page] [Sklar, Scott] [Smith, John] [Smith, Louise] [Squires, George] 

[Steegmayer, Andrea] [Sumrall, Kamar] [Tanner-Sutton, Linda] [Tarr, Suzanne] [Teeler, Sharon] 

[Testerman, Michael] [Traub, Charles] [Van Lingen, Gabriele] [Wells, Cathy] [Werderman, Kim] 

[White, Eric] [White, Phyllis] [Williams, Martha] [Wilson, Brian] [Wilson, Brian] [Witting, Marjorie] 

[Woitte, Roger]) 

Comment: Please say no to a new nuclear reactor at North Anna Power Station until the 

currents reactors comply with environmental considerations. These stations affect the health of 

all the waterways that run by. Just please, for the sake of our children and grandchildren, just 

please say no! (0029-1 [Meredith, Betty]) 

Comment: Thank you for saying no to a new nuclear reactor at North Anna as currently 

requested by Dominion (0040-3 [Whitfield, Doris]) 

Comment: I have seen no justification for a new reactor. The environmental and health hazard 

impacts of this proposal make it undesirable and objectionable. do not continue plans for an 

additional reactor at Lake Anna! (0044-1 [Traub, Charles]) 

Comment: There is a lot to be studied here and a third reactor should not be built at N. Anna. It 

will put unreasonable stress on water resources and jeopardize the health and safety of Virginia 

Citizens. We suggest a totally new environmental assessment be made before setting up a new 

reactor. (0046-1 [Galindo, Ted and Carolyn]) 

Comment: More reactors at North Anna is an expense, and a risk, that I'm not willing to accept. 

(0051-5 [Harpole, Thane]) 

Comment: It is the best interest of the Earth and your constituents that you oppose the building 

of the third nuclear reactor at North Anna. (0052-1 [Stone, Eric]) 

Comment: Please re-examine what is truly needed at North Anna and what the environmental 

impact could be, and develop a safer, smarter solution. (0055-3 [Shamaiengar, Beth]) 

Comment: Please disallow a third reactor, we are moving in a new direction in this country, 

and this issue is exactly what will be shunned if we continue down the nuclear path. 

(0066-2 [Cummings, Russell]) 

Comment: Dear Chief, Rules and Directives Branch: I urge you not allow a third nuclear 

reactor at the North Anna site in Louisa County, VA as it would potentially represent an 

environmental and safety threat to that area and to central Virdinia. (0067-1 [Suter, Emanuel]) 
Appendix E 

February 2010 E-141 NUREG-1917, SEIS 

Comment: As Chief of the Pamunkey Indian Tribe of Virginia, I'm writing this letter to ask that a 

permit not be given to Dominion Power for construction of a new nuclear reactor at the North 

Anna Site (0073-11 [Brown, Kevin]) 

Comment: Renewables and energy efficiency are on everyone's radar screen these days, 

except for our own electricity utility company. Dominion is seeking to build another nuke, and I 

think it is what, 1,500 megawatts? It is highly inefficient, and an incredibly expensive project. It is 

well known that every 1,000 megawatt nuke is really a 3,000 megawatt system, giving off 

2,000 megawatts in waste heat, to coolant waters and the surrounding air. 

(0073-64 [Day, Elena]) 

Comment: I am speaking as a representative of the Virginia Chapter of the Sierra Club, which 

has just about 17,000 members in the Old Dominion. The Sierra Club is opposed to the 

construction of the third reactor at the North Anna Power Station. We believe that this reactor 

will put an unreasonable strain on water resources, and jeopardize the health and safety of 

people living in Central Virginia. 

(0078-1 [Cruickshank, John]) 

Comment: The Sierra Club continues to oppose this project, and asks that the NRC reject 

Dominion's application for a Combined Operating License. The SDEIS does not adequately 

evaluate the impacts of this new reactor will have on water resources, on our natural habitats, 

and on the public health and safety. (0078-14 [Cruickshank, John]) 

Comment: As a young UVA students who will be facing the future consequences of our current 

exploitative mode of sustaining a society, I feel that if there is something, those who care about 

the permanence of not only you as communities, but communities around the world, me being 

hispanic, should do is focus our methods on community building that don't exploit mineral 

resources, harm fragile aquatic ecosystems, or sow fear of radioactive disaster into the minds of 

the public. (0081-1 [Oyok, Louis]) 

Response: These comments express opposition to NRC's COL process, the NAPS Unit 3 

COL, and the applicant. No new and significant information was provided. Therefore, no 

changes were made to the SEIS. 

30. General Comments in Opposition of Nuclear Power 

Comment: You don't know how to store, reprocess or neutralize the waste. This has been 

going on since the 1970's when you promised you would figure it out later. Lawsuits have been 

the result, unresolved and even more tax payer money wasted by the federal government. It is 

reprehensible that this some how doesn't get discussed. Nuclear power besides being 

extremely toxic and a terrorist target is the biggest waste of taxpayer money ever and the 

stupidest way mankind has ever come up with to boil water. Invest this money in solar thermal 

and get your act together. (0030-1 [DiMarco, Paul]) 
Appendix E 

NUREG-1917, SEIS E-142 February 2010 

Comment: Please remember the Three Mile Island disaster. The public deserves cleaner and 

much safer forms of renewable energy. Proponents of nuclear energy say it's clean energy, but 

nuclear waste is a very hazardous byproduct of its production. (0032-1 [Payne, Andrew]) 

Comment: There is still no viable solution to the problem of nuclear waste, and the opportunity 

is NOW for achieving green, safer new technologies. Investments should be made on these 

fronts instead of jeoparding people and the environment further. (0033-1 [Rollins, Megan]) 

Comment: It's not a safe or viable especially when there are so many people willing and able 

to reduce their consumption and use an alternative. People in this area are smart and involved 

in theire communities. Please do not further damage the area where we live, work and play. 

Thank you for your time. (0034-1 [Figg, Landon]) 

Comment: There is to much danger and risks and the problems it will cause far outweigh any 

benefits . We do not want it . (0043-1 [Frantz, Norma]) 

Comment: Please take reasonable steps to meet energy needs without the need for an 

additional nuclear reactor. Reduce coal use. Nuclear is simply a false choice 

(0045-1 [Kunkel, Christopher]) 

Comment: I realize all power options must be considered as part of a plan for ending out 

dependence on oil and reducing our carbon footprint. However, nuclear power carries many 

risks. These must be carefully assessed before any action is taken that could further degrade 

the environment. Virginia is a beautiful state with many options for outdoor recreation. It is 

important to preserve these options for our children. (0047-1 [Robbins, Patricia]) 

Comment: Please think of the future for our children and grandchildren. Do what is right and 

LEAD US IN A NEW DIRECTION. It is past time for our leaders to make decisions based on 

what is right for the long run! (0057-1 [Currie, Susan]) 

Comment: How can we be any more short-sighted than to think that more nuclear anything is a 

good thing? (0059-1 [Dickon, Elisa]) 

Comment: How can we do any more damage to our wetlands, and woodlands, to our water, to 

our air? (0059-2 [Dickon, Elisa]) 

Comment: What are you planning on leaving to your children and grandchildren? I know what 

I am leaving mine and that is knowing that I fought for them to have decent air to breath and 

water to drink and a safe place to live. Please think about this in some other way than monetary-

--think beyiond the imediate picture and look ahead at the consequences. Ask science what is 

the real danger. (0059-4 [Dickon, Elisa]) 

Comment: So it sickens me that Dominion and other utilities, highly invested in nukes, are 

lobbying so hard, right now today, for 50 billion in loan guarantees, to be invested in case they 

need this -- they do need this for their construction loans because, obviously, Wall Street won't 

lend it to them. But this is money that belongs to the taxpayer. This is what they are asking for in 
Appendix E 

February 2010 E-143 NUREG-1917, SEIS 

the stimulus bill that is now being reviewed in the Senate. And this is money that belongs to the 

taxpayer, it shouldn't be for nukes, because nukes are unsustainable, they are polluting, they 

are expensive, and rather than to demand our money for these, I think that this money should 

be earmarked for increases in energy efficiency in homes, in offices, and for investments in 

renewable technologies. (0073-66 [Day, Elena]) 

Comment: I'd like you to ask them just one question. Ask these scientists, these America's 

brightest and best, is it possible to boil water, to use the steam, to turn the turbines, to generate 

the electricity, without making us more of a terrorist target, without poisoning the air, and the 

soil, and the water; without radiation? (0075-12 [Farris, Rebecca]) 

Comment: If they tell you no, that is not possible, there is no other way to boil the water, to turn 

the turbines, to generate the electricity, than nuclear. Then I urge you not to trust their wisdom, 

and do not take their advice. (0075-13 [Farris, Rebecca]) 

Comment: It is my prayer, tonight, that each of us look into our hearts, and reconnect with our 

love of life, and turn away from this suicidal madness that is nuclear. 

(0075-15 [Farris, Rebecca]) 

Comment: So it sickens me that Dominion and other utilities, highly invested in nukes, are 

lobbying so hard, right now today, for 50 billion in loan guarantees, to be invested in case they 

need this -- they do need this for their construction loans because, obviously, Wall Street won't 

lend it to them. But this is money that belongs to the taxpayer. This is what they are asking for in 

the stimulus bill that is now being reviewed in the Senate. And this is money that belongs to the 

taxpayer, it shouldn't be for nukes, because nukes are unsustainable, they are polluting, they 

are expensive, and rather than to demand our money for these, I think that this money should 

be earmarked for increases in energy efficiency in homes, in offices, and for investments in 

renewable technologies. (0075-2 [Day, Elena]) 

Comment: And I'm not going to take up your time with too many words, I'm just going to 

provide a brief demonstration, an illustration of the functional observable relationship that I see 

between the NRC and Dominion Power. I need an audience volunteer. You. [Speaker and 

volunteer perform demonstration] (0079-3 [Connor, Jennifer]) 

Comment: Now, if we continue building these kinds of projects, then we may not have a 

chance for this kind of thing at all. So I invite all of you to join in with me, in appreciation of your 

neighbor, right now. So share some affection with the person sitting next to you, because if we 

continue to poison our environment, we are not going to have too much more time. [Speaker 

and volunteer perform demonstration] (0079-4 [Taylor, Kelly]) 

Comment: Yes, you are all falling sleep, you are all like zombified out there. And I hope that 

the NRC doesn't get like this, because that is how we get into our zombie future, where we just 

like walk like this into a nuclearized future. And it is, you know, we can't do that. We have to 

really consider this. So, yes, wake up all of us, take all this to your heart, that is all. 

(0079-5 [Taylor, Kelly]) 
Appendix E 

NUREG-1917, SEIS E-144 February 2010 

Comment: So I'm angry about that. Then I go to sadness, that we human beings can think that 

we are more important than anything else, the bees, the fish, the birds. Yes, I go to sadness. 

And I just ask what is the real cost of the economic security, or the safety that I've heard people 

talk about tonight, and jobs, and money, and future, and what is the real cost of that? 

(0080-10 [Pickering, Andrew]) 

Comment: It is more practical and economic to shut down reactors. (0080-2 [Young, Emerald]) 

Comment: So I wanted to speak on those who don't have a voice, and that would be my three 

children, my 60,000 bees, and I don't know how many fish are in Lake Anna, but several 

thousand. And I want to talk about how I feel about what I've heard tonight in the Supplemental 

EIS. I guess that I'm angry that the basic assumption is that human life, and human needs, is 

more important than anything else. (0080-9 [Pickering, Andrew]) 

Comment: This premise that as a society we have accept increased electrical consumption in 

the future, I'm not sure we need to accept that, or we should. Cell phones, laptops, cars, these 

things are choices that we can make. I'm not convinced that they've done much for personal 

happiness, or -- it is a decision that people have to make, and it is not already made for us. 

(0081-10 [Caristo, Vince]) 

Comment: After that I would like to read a poem by E.F. Shumaker from a book in 1972 called 

Small is Beautiful. 

No degree of prosperity could justify the accumulation of large amounts of highly toxic 

substances which nobody knows how to make safe, and which remain an incalculable danger to 

the whole of creation, for historical, or even geological ages. 

To do such a thing is a transgression against life itself. A transgression infinitely more serious 

than any crime perpetrated by man. The idea that a civilization could sustain itself, on such a 

transgression, is an ethical, spiritual, and metaphysical monstrosity. 

It means conducting the economic affairs of man as if people did not matter at all. 

(0081-11 [Caristo, Vince]) 

Response: These comments express general opposition to nuclear power. These comments 

provide no new and significant information. Therefore, no changes were made to the SEIS. 

31. General Comments in Opposition of the Existing Plant 

Comment: There is already an issue caused by the plant and another reactor will only 

exacerbate the problems. Please reconsider this plan. (0054-1 [Gaige, Eve]) 

Comment: The Commonwealth of Virginia has a bad enough record on environmental issues 

without pretending that there is no harm in permitting yet another reactor in the same area 
Appendix E 

February 2010 E-145 NUREG-1917, SEIS 

where the managing entities remain unable or unwilling to bring the existing site into compliance 

with existing regulations. Please do not sell us down the river yet again! 

(0060-1 [Lloveras, Lang]) 

Comment: however, we should solve the current problems with the North Anna Power station 

before expanding it's capacity, as well as it's current problems. (0065-2 [Liske, Patricia]) 

Response: These comments express opposition to the existing units at the NAPS site. No 

new and significant information was provided. Therefore, no changes were made to the SEIS. 

32. Comments Concerning Issues Outside Scope – Emergency 

Preparedness

Comment: and the discussion of an updated evacuation plan that addresses the area of 

impact in the event of an emergency (0069-4 [Irons, Ellie]) 

Comment: An updated evacuation plan that addresses the area of impact in the event of an 

emergency is desired based on the proposed improvements described in the SEIS. 

(0069-52 [Irons, Ellie]) 

Response: These comments on emergency preparedness are outside the scope of the 

environmental review of the COL, and were not addressed in the SEIS. An evaluation of 

emergency preparedness issues is part of the safety review, published in a safety evaluation 

report (see 10 CFR 52.18). No changes were made to the SEIS as a result of these comments. 

33. Comments Concerning Issues Outside Scope – Miscellaneous 

Comment: The U. S. Department of the Interior (Department) has no comment on the Draft 

Supplemental Environmental Impact Statement, NUREG-1917, for the Combined License for 

the North Anna Power Station Unit 3 in Louisa County, Virginia. (0001-1 [Chezik, Michael T.]) 

Response: This comment is a summary of comments from a reviewing Federal agency. No 

new and significant information was provided. Therefore, no changes were made to the SEIS. 

Comment: We are not opposed to the North Anna 3rd Unit Project. We also want to insure that 

Dominion identifies the type of Reactor that it will use and its potential impacts prior to 

proceeding (0017-1 [Ruth, Harry]) 

Response: Dominion has not withdrawn the present COL application for one ESBWR unit at 

the NAPS site, nor has Dominion submitted a revision of reactor type that could delay the 

environmental review. The NRC’s environmental review of one ESBWR unit at the NAPS site is 

contained in this SEIS. If a change does occur, the licensing process will consider the change. 

This comment provided no new and significant information. Therefore, no changes were made 

to the SEIS. 
Appendix E 

NUREG-1917, SEIS E-146 February 2010 

Comment: Dominion has announced that it cannot utilize the reactor that it had selected for the 

3rd reactor at NAPS (North Anna Nuclear Power Plant). Dominion has mounted a search for a 

different reactor. The problem is that the COL (Combined Operating License) application is 

predicated on the reactor originally selected. It will be necessary for the NRC to open the SEIS 

after Dominion has picked a new reactor. The NRC will need to reevaluate the Impact 

Statement based on this new information and then amend the Draft and hold yet another public 

meeting. This is a gross waste of taxpayers' money. The NRC should have waited to finalize 

this Draft until such time as the reactor is selected. (0003-2 [Crawford, Barbara]) 

Comment: Since Dominion Power is choosing a new reactor model, application for the COL 

should be put on hold. Once a new reactor model is chosen, then a new environmental 

assessment should be initiated. (0004-1 [Abbott, Diana]) (0006-3 [Neale, Laura]) 

Comment: At the very least, since Dominion Power is choosing a new reactor model, a totally 

new environmental assessment should be conducted. (0011-6 [Abbott, William] [Ahlgrim, Larry] 

[Alexander, Mary] [Alexander, Mary] [Alexander, Nancy] [Allen, Connie] [Antoniewicz, Susan] 

[Appleby, Monica] [Apple, Joe] [Arens, Jordan] [Artemis, Diana] [Bailey, Marcia] [Baird, Heidi] 

[Bandita, Gypsy] [Biggs, Amy] [Bockstiegel, Dorothy] [Boissonnault, James] [Bolduc, Joan] 

[Brackett, Carl] [Bradshaw, Claude] [Brown, E] [Brummer, Ann] [Burtner, Caryl] [Burt, William] 

[Butcher, Ava] [Churray, Richard] [Clark, Diane] [Clark, Loralee] [Clark, Loralee] [Clark, Theda] 

[Cleary, Thomas] [Collingwood, Claudia] [Cook, Joe] [Cowles, Virginia] [Cummings, Russell] 

[Currie, Susan] [Dail, Michelle] [Daiss, Becky] [Davies, Beth] [De Trinis, Bonita] [Deming, Jill] 

[Desimone, John and Shirley] [Dickon, Elisa] [DiMarco, Paul] [D'Onofrio, Adam] [Dukovich, 

John] [Dunbar, Mary] [Ebert, Paul] [Farnham, Ross] [Fasceski, Jeffrey] [Feury, Patricia] [Figg, 

Landon] [Fiscella, Glenn] [Ford, Betty] [Franke, John] [Frank, Sarah] [Frantz, Norma] [Fritzler, 

Deb] [Gaige, Eve] [Galindo, Ted and Carolyn] [Gann, Sara] [Gignac, David] [Grant, Mary] [HallBodie, Adrienne] [Ham, Elspeth] [Hamilton, Jim and Donna] [Hanger, Jane] [Hanks, Lou] 

[Harpole, Thane] [Hartwig, Kristina] [Heegaard, Flemming] [Heflin, Kerby] [Heim, Anka] 

[Hepburn, Chet] [Hess, David] [Hinkle, Carol] [Hodge, Mary] [Hoehlein, Jill] [Hoffman, Lilli] 

[Holtzback, Kaite] [Horwege, Richard] [Houston, Karin] [Hutchinson, Amber] [Jaronczyk, Ellen] 

[Jewell, B] [Johns, Brian] [Josaitis, Marvin] [Kalukin, Andrew] [Keyser, Liz] [Kiehl, Allison] 

[Kosch, Sandra] [Kroupa, Brenda] [Kunkel, Christopher] [Larsen, Anne] [Larsen, Janice] 

[Laverdiere, Dorothy] [LeClair, Carol] [Leon, Matea] [Light, John] [Liske, Patricia] [Lloveras, 

Lang] [Lufkin, Heather] [Maddox, Joshua] [Marroni, Edmond] [McDonald, Kim] [McFarland, Mary 

Ann] [McNeal, Ashby] [Meredith, Betty] [Meyer, Jennifer] [Miles, Linda] [Miller, Katelyn] [Miller, 

Lara] [Miller, Mary] [Mullinax, Franklin] [Newell, Vicky] [Payne, Andrew] [Phillips, Donna] 

[Pintado, Isabel] [Plaskett, Micheline] [Plata, Errol] [Presgraves, Sandra] [Presley, Diann] 

[Rasmussen, Angela] [Reiner, Brian] [Rigby, John] [Roadcap, Leah] [Roadcap, Leah] [Robbins, 

Patricia] [Rollins, Megan] [Roth, David] [Schmidt, Arthur] [Scott, Patricia] [Shamaiengar, Beth] 

[Shelton, Charles] [Shields, Page] [Sklar, Scott] [Smith, John] [Smith, Louise] [Squires, George] 

[Steegmayer, Andrea] [Stone, Eric] [Sumrall, Kamar] [Suter, Emanuel] [Tanner-Sutton, Linda] 

[Tarr, Suzanne] [Teeler, Sharon] [Testerman, Michael] [Traub, Charles] [Van Lingen, Gabriele] 

[Wells, Cathy] [Werderman, Kim] [White, Eric] [White, Phyllis] [Whitfield, Doris] [Williams, 

Martha] [Wilson, Brian] [Wilson, Brian] [Witting, Marjorie] [Woitte, Roger]) 
Appendix E 

February 2010 E-147 NUREG-1917, SEIS 

Comment: Several important issues have come up which involve significant changes since the 

Draft EIS...Dominion dropping GE/Hitachi as vendor and template for EIS. 

(0012-3 [Rosenthal, Jerry]) 

Comment: How can the NRC hold public draft environmental study meetings when neither the 

NRC or the public has any idea of what type of 3rd reactor will be installed at the North Anna 

plant or its impact to Lake Anna. It simply does not make any sense. On 12 Jan 2009, Dominion 

announced that it will no longer use the proposed GE Hitachi Economic Simplified Boiling Water 

Reactor. Other U.S. utility companies also announced they were abandoning this reactor 

because they could not get federal loan guarantees. The public still does not know what type of 

reactor will be installed at Lake Anna or its potential environmental impacts. 

(0017-4 [Ruth, Harry]) 

Comment: In section 5.3 of the DSEIS, the NRC has devoted a whopping one and a half page 

to this most important issue. Dominion's COL application is for construction of only one 

additional unit (Unit 3), using the Economic Simplified Boiling-water Reactor (ESBWR) designed 

by GE-Hitachi which now has been abandoned by Dominion. How can this decision not affect 

the NRC's staff preparation of the SEIS? Another reactor will have to be evaluated with respect 

to impact levels determined in the ESP and the Plant Parameter Envelope (PPE). 

(0018-5 [Remmers, Ken]) 

Comment: Since Dominion is no longer using the ESBWR design, it is imprudent to conduct a 

Environmental Impact Statement or consider a COL when the design of the facility, its costs, or 

schedule are not yet known. Without knowing the design it is not possible to determine its 

impact. It is not even clear whether a certified design will be used. Accordingly, it is requested 

that the DEIS process be put on hold until the design selection is finalized. 

(0023-1 [Goldsmith, Aviv]) 

Comment: Dominion's COL application is for the construction of only one unit, unit 3. In the 

report, using the ESBWR plant designed by GE Hitachi, which rumors have been running 

around that Dominion may be abandoning this plant. How can this decision not affect the 

NRC's staff preparation of the DSEIS, another reactor will have to be evaluated with respect to 

impact levels determined in the ESP and plant parameter envelope concerns. 

(0073-40 [Remmers, Ken]) 

Comment: One, the NRC's draft document is based on a false assumption, that is that 

Dominion Virginia Power will use the GE Hitachi nuclear energy reactor known as the economic 

simplified boiling water reactor, at North Anna. (0078-16 [Zeller, Lou]) 

Comment: First Dominion recently announced that it will solicit bids for an alternative nuclear 

technology and for a new contractor to build the reactor. The license application for North Anna 

unit 3 is based solely on the GE Hitachi reactor design. And the Supplemental EIS is based on 

this license application. Plainly Dominion has not made a final decision on its reactor design. 

Therefore the NRC cannot proceed with an environmental impact analysis it now knows to be 

incorrect. Dominion's request for bids is new and significant information under federal law. We 
Appendix E 

NUREG-1917, SEIS E-148 February 2010 

request that the NRC suspend the licensing of unit 3, and require a license revision. In fact, this 

is what NRC has done at Entergy's Grand Gulf Plant. NRC suspended its review at Grand Gulf's 

license pending reevaluation of alternative reactor technologies, which like North Anna, was 

based on the ESBWR, and an ESP. I will submit NRC's letter to Entergy. 

(0078-18 [Nguyen, Vanthi]) 

Comment: And for those who would criticize the NRC for continuing the evaluation of the 

studies that have been presented to them, and for doing the Environmental Impact Statement, 

and the studies that they have been charged to do, and that they have done so responsibly, 

they are not held responsible for evaluating rumors. They don't stop their job just because they 

heard a rumor that Dominion may be changing where they are getting their design from, since 

Dominion has not changed where they are getting their design from, the NRC doesn't just stop 

doing their job because they heard that there might be some other design that is chosen later 

on. (0079-2 [Taylor, Kelly]) 

Response: The comments express concern about a potential change in the reactor design for 

the proposed Unit 3 described in the SEIS. Dominion has not notified the NRC of any proposed 

change in the reactor design. The environmental licensing process will continue until Dominion 

notifies the NRC of any change. If a change does occur, the licensing process will consider that 

change, as appropriate. These comments provide no new and significant information. 

Therefore, no changes were made to the SEIS. 

Comment: We would be remiss if we did not take a moment to acknowledge that next month is 

the 30th Anniversary of the nuclear accident at Three Mile Island, the worst nuclear accident in 

U.S. history. We all hope and pray that no such event ever take place again, either here or 

anywhere in the world. But Three Mile Island did happen and we must not forget. 

(0003-6 [Crawford, Barbara]) 

Response: This comment provides general information regarding the nuclear industry. This 

comment provided no new and significant information. Therefore, no changes were made to the 

SEIS. 

Comment: Several important issues have come up which involve significant changes since the 

Draft EIS...Congressional action on efficiency and energy which will have significant impact on 

electrical demand. (0012-4 [Rosenthal, Jerry]) 

Response: This comment provides general information regarding potential Congressional 

action regarding energy efficiency. The NRC staff evaluated energy efficiencies such as 

demand-side management in Section 9.2.1. The comment did not provide specific new and 

significant information or reference specific legislative action. Therefore, no changes were 

made to the SEIS. 

Comment: Shouldn't Appendix F or L or the socioeconomic section of the text include mention 

of the resolution passed by Spotsylvania County against the project and the ESP? 

(0023-56 [Goldsmith, Aviv]) 
Appendix E 

February 2010 E-149 NUREG-1917, SEIS 

Response: Appendix F provides copies of letters from Federal or State agencies in response 

to a Federal Register notice by the NRC regarding the proposed licensing process, whereas 

Appendix L listed information regarding the status of required authorizations and consultations 

required by regulation. Information contained in the socioeconomics sections of the Draft SEIS 

deal with the affected environment regarding socioeconomic issues (Chapter 2); impacts 

resulting from construction and operation of the plant (Chapters 4 and 5), and resulting 

cumulative impacts (Chapter 7). The resolution passed by Spotsylvania County did not provide 

any specific information to be included in these chapters. These comments provide no new and 

significant information. Therefore, no changes were made to the SEIS. 

Comment: We would like to put DEQ on notice that LACA Water Quality Committee strongly 

requests, with the full support of the Combined Lake Level Taskforce, that any VPDES permit, 

and WPP permit, include mitigation for the effects for unit 3. (0073-43 [Remmers, Ken]) 

Comment: This deed language is typical of every waterfront parcel on Lake Anna, since the 

'60s. Anybody that owns waterfront land, the owner for himself, his successors, or assigns, for 

the above-considerations, does hereby grant, and convey to the company, being VEPCO at the 

time, the right to maintain and operate the electric generating facilities, dam, reservoir, dikes, 

cooling lagoons, electrical lines, and pipelines, including without limitation, the raising and 

lowering of the water of the aforesaid, and changing the condition of said waters. 

(0075-30 [Carroll, John]) 

Comment: First I'm going to read a poem by Nanau Sazaki, it is called North America. 

At Superstition Mountain, in the Sonoran Desert, a beer-bellied man is shooting at a 50 foot 

saguaro cactus with a rifle. A couple of minutes later the giant cactus falls to the ground and kills 

the man. April 1984. 

April 1986, in a ravine at Big Mountain in Hopi and Navajo land, a coyote is reading the Wall 

Street Journal. How many mice can I steal next year from the American economy? 

Off the coast of Northern California sea lions are listening to the long-term weather forecast on 

the radio. They want to freeze dry the redwood forest for the coming ice age. 

On a rocky ledge, somewhere in the center of nuclear power, a family of California condors is 

watching Wild Kingdom on TV. They ponder, how many more years homo sapiens, one of the 

most endangered species, can survive? (0078-15 [Nguyen, Vanthi]) 

Comment: I live on the Ravannah River in Charlottesville. And I see the river and water as a 

sacred element. And I just challenge anyone's assumption that water that is taken out of a body 

of water, heated up, and thrown back in, is not changed. I just think it is not true. 

(0080-11 [Pickering, Andrew]) 
Appendix E 

NUREG-1917, SEIS E-150 February 2010 

Response: These comments regarding various aspects of the process are considered to be 

outside the scope of the environmental review process. These comments provide no new and 

significant information. Therefore, no changes were made to the SEIS. 

Comment: The Thomas Jefferson Planning District Commission (TJPDC) reviewed the SEIS 

and has no comments. The George Washington Regional Commission and RappahannockRapidan Planning District Commission did not respond to DEQ's request for comments on the 

SEIS. Contact Rochelle Garwood, TJPDC at (434) 979-7310. 

(0069-54 [Irons, Ellie]) 

Comment: DEQ solicited comments on the SEIS from the Counties of Louisa, Orange, 

Spotsylvania and Hanover, and the Town of Mineral. However, no local comments on the 

proposal were received by DEQ. (0069-55 [Irons, Ellie]) 

Response: These comments provide the status of comments on the draft SEIS (NRC 2008) 

that were solicited from Louisa County, neighboring counties, the Town of Mineral, and several 

regional planning districts. These comments provide no new and significant information. 

Therefore, no changes were made to the SEIS.

Comment: We have several pollution prevention recommendations that may be helpful in the 

construction of this project and in the operation of the facility: 

• Consider development of an effective Environmental Management System (EMS). An 

effective EMS will ensure that the Dominion is committed to minimizing its environmental 

impacts, setting environmental goals, and achieving improvements in its environmental 

performance. DEQ offers EMS development assistance and it recognizes facilities with 

effective Environmental Management Systems through its Virginia Environmental 

Excellence Program. " Consider environmental attributes when purchasing materials. 

For example, the extent of recycled material content, toxicity level, and amount of 

packaging should be considered and can be specified in purchasing contracts. 

• Consider contractors' commitment to the environment (such as an EMS) when choosing 

contractors. Specifications regarding raw materials and construction practices can be 

included in contract documents and requests for proposals. 

• Choose sustainable materials and practices for infrastructure construction and design. 

These could include asphalt and concrete containing recycled materials, and integrated 

pest management in landscaping, among other things. 

• Integrate pollution prevention techniques into the airport maintenance and operation, to 

include the following: inventory control (record-keeping and centralized storage for 

hazardous materials), product substitution (use of nontoxic cleaners), and source 

reduction (fixing leaks, energy-efficient HVAC and equipment). Maintenance facilities 

should be designed with sufficient and suitable space to allow for effective inventory 

control and preventative maintenance. (0069-56 [Irons, Ellie]) 
Appendix E 

February 2010 E-151 NUREG-1917, SEIS 

Response: The issue on pollution prevention is outside the scope of the SEIS and is not 

addressed in the SEIS. Aspects of pollutant prevention are the subject of the overall 

environmental protection plan that Dominion will implement in the process of obtaining 

environmental-related authorizations, permits, and certifications. Those are listed in Appendix L 

of the SEIS. No changes were made to the SEIS as a result of this comment. 

Comment: Since water is a critical concern, among the major alternatives that should be 

considered in detail in Chapter 8 are the retrofitting of a cooling tower to Units #1 and/or #2, and 

the application of a dry cooler to Unit 3. (0023-47 [Goldsmith, Aviv]) 

Response: The concern regarding alternatives related to retrofitting the cooling technology for 

Units 1 and 2 is outside the scope of the environmental review of the Unit 3 COL and is not 

addressed in the SEIS. The SEIS only considers the application to construct and operate an 

additional unit at the NAPS site. Cooling system design alternatives for the proposed Unit 3 

were evaluated in Section 9.3 of the SEIS. No changes were made to the SEIS as a result of 

this comment. 

Comment: Dominion power needs to operate the current reactor in accord with the law and 

relevant rules and regulation. At that point a new environmental impact statement is necessary 

because we are becoming acutely aware of the encroachment on wetlands with every 

development application. And this is a huge development plan with serious consequences for 

the environment. (0035-1 [Jewell, B]) 

Response: This comment concerns operating the existing reactors, which is outside the scope 

of the SEIS. Resident NRC inspectors maintain a daily evaluation of the operation of the 

existing units. No changes were made to the SEIS as a result of this comment. 

34. Comments Concerning Issues Outside Scope – NRC Oversight 

Comment: At the very least call for the other two to be up to regulations, the environmental 

impact studies to be done by a third party AND FOLLOWED on all three. 

(0036-1 [Clark, Theda]) 

Comment: I would like to thank the NRC on their usual thorough work that they do in protecting 

people, and the environment, and for getting things right. I have personal experience in this, in 

that last year I noticed a very serious error in their website, I pointed it out to them, and they 

corrected it immediately. (0082-4 [Reynolds, Norm]) 

Comment: Also I just want to mention that I'm glad the NRC is here. You guys are definitely 

the gold standard. I've had a chance to work in industries, and every time I have worked in other 

industries I've always compared what was done when I was in the nuclear industry at the time, 

to what we were doing at the time then, and it was always a very high standard. And to add to 

that, if you look at the Simpsons, even Mr. Burns knows he can't bribe the NRC. So definitely 

kudos to you guys, and keep up the good work. (0082-8 [Mastilovic, Nick]) 
Appendix E 

NUREG-1917, SEIS E-152 February 2010 

Response: These comments provide general information regarding the NRC oversight 

process. These comments provide no new and significant information. Therefore, no changes 

were made to the SEIS. 

35. Comments Concerning Issues Outside Scope – Safety 

Comment: Dominion is at this moment engaged in a contest to see which power company will 

be first to get a new reactor on line. To the victor go many spoils, by way of a very large sum of 

money to be paid by the Federal Government. That's us, the taxpayers. A state of the art 

reactor run by state of the art computers still requires some 750 humans to operate and 

maintain it. That's a lot of potential human error. (0003-7 [Crawford, Barbara]) 

Comment: At another of these public meetings, several years ago, I met a gentleman as we 

exited this building. When he heard that I had grown up near Harrisburg, PA, he told me that he 

had spent the first 13 years of his career with the NRC "cleaning up the mess at Three Mile 

Island". The next time that someone tries to tell you that Three Mile Island was no big deal, 

remember that it took 13 years to clean up that very big deal. For years, the local papers 

reported, after the fact of course, when radioactive gases had been released into the air and 

when radioactive water had been released into the Susquehanna River. Every effort must be 

made to insure that this process here at NAPS be done correctly. Everyone involved must use 

caution and proceed slowly and with full knowledge of what we are getting into. Each step must 

be taken without shortcuts and without regard for the huge carrot being dangled at the end of 

that stick, to make sure that we are safe and that our environment is not destroyed in the 

process. To paraphrase President Obama: we will go forward with nuclear power if and when 

we are absolutely certain that it is safe. (0003-8 [Crawford, Barbara]) 

Comment: North Anna Unit 3, if constructed, would be the only nuclear plant in the nation 

licensed by the NRC and located on top of a geologic fault. In 1967, soon after DominionVirginia Power began work on the North Anna Power Station, evidence of seismic faults were 

found at the site. In February 1970 the excavation wall for Reactor Unit1 collapsed. One month 

later, independent geologists visited the site, identified a major fault zone, took pictures and 

reported their finding. Dominion admits that a fault underlies the site of Unit 3 but maintains that 

there is "no relevance with respect to the existence of [the] unnamed fault." Nevertheless, the 

fault is there. The draft SEIS does not determine the magnitude of the risk at the site. 

(0024-4 [Zeller, Lou]) 

Comment: DEQ recommends that NRC coordinate the development of the SER with DEM and 

DSP and provide them the opportunity to review and comment on the final document. 

(0069-53 [Irons, Ellie]) 

Comment: It is quite obvious that if nukes were really safe, they would be sited in Richmond 

City, or downtown DC, where this waste heat could be utilized. (0073-65 [Day, Elena]) 
Appendix E 

February 2010 E-153 NUREG-1917, SEIS 

Comment: And we are absolutely confident that in conjunction with the efforts of the Nuclear 

Regulatory Commission, and other federal, state, tribal, and local agencies, any risk to public 

health and public safety will be addressed and mitigated. (0075-9 [Bishop, Wayman]) 

Response: Security and terrorism are safety issues that are outside the scope of the 

environmental review. However, the NRC is devoting substantial time and attention to 

terrorism-related matters, including coordination with the U.S. Department of Homeland Security 

(DHS). As part of its mission to protect public health and safety and the common defense and 

security pursuant to the Atomic Energy Act of 1954, the NRC staff is conducting vulnerability 

assessments for the domestic use of radioactive material. In the time since September 11, 

2001, the NRC has identified the need for license holders to implement compensatory 

measures and has issued several orders to license holders imposing enhanced security 

requirements. Finally, the NRC has taken actions to ensure that applicants and license holders 

maintain vigilance and a high degree of security awareness. Consequently, the NRC will 

continue to consider measures to prevent and mitigate the consequences of acts of terrorism in 

fulfilling its safety mission. Additional information about the NRC staff’s actions regarding 

physical security since September 11, 2001, can be found on the NRC’s public web site 

(www.nrc.gov). No changes were made to the SEIS as a result of these comments. 

Comment: It is quite obvious that if nukes were really safe, they would be sited in Richmond 

City, or downtown DC, where this waste heat could be utilized (0075-1 [Day, Elena]) 

Comment: Okay, if you are operating a hair dryer, and it goes in your bathtub, you are dead 

meat, okay? And a nuclear reactor won't even fit inside a bathtub, so I don't know what she is 

talking about. And a lot of people think that nuclear power plants, they can cause some kind of 

nuclear explosion, or something, and that is really dangerous. Wrong, hippies. They can't cause 

nuclear explosions. Okay, maybe they can explode and melt down, and maybe 1,000 megawatt 

plant could render an area the size of Pennsylvania uninhabitable, but there are, last time I 

checked, 48 other perfectly -- other inhabitable states. I'm sorry, New Jersey. 

(0079-6 [Salidis, Stratton]) 

Comment: So, anyway, I just wanted to start operating this plant here, just to show you how 

much power it can make, and so safely. So, okay, here are the rods, yes, get them reacting. 

They are reacting. You see? Right now the lights are on, nothing bad is happening, it is perfectly 

safe and it is -- oh, my God, shield your groins, it is okay. No, that was just an accident, and now 

it is better. Okay, thank you very much. See how harmless that was? 

(0079-7 [Salidis, Stratton]) 

Response: The issue raised in these comments is outside the scope of the environmental 

review and is not addressed in the SEIS. The safety assessment for the proposed licensing 

action was provided as part of Dominion’s application. The NRC is in the process of developing 

a safety evaluation report that analyzes all aspects of reactor and operational safety. Examples 

of how the NRC addresses operational safety issues are discussed below. 
Appendix E 

NUREG-1917, SEIS E-154 February 2010 

The NRC maintains resident inspectors at each reactor site. These inspectors monitor the dayto-day operations of the plant and perform inspections to ensure compliance with NRC 

requirements. In addition, the NRC has an operational experience program that ensures that 

the safety issues found at one plant are properly addressed at the others, as appropriate. 

Finally, the design of any new reactors or storage facility will have benefitted already from 

lessons learned at existing reactors and will incorporate new safety features that would be 

impracticable to retrofit into existing plants. The NRC will issue a license or permit only if it can 

conclude with reasonable assurance that (1) the activities authorized by the license or permit 

can be conducted without endangering the health and safety of then public, and (2) such 

activities will be conducted in compliance with the rules and regulations of the NRC. No 

changes were made to the SEIS as a result of these comments.

36. Comments Concerning Issues Outside Scope – Security and 

Terrorism 

Comment: The section on emergencies and radiation impacts is not understandable by lay 

persons. A summary is required that clearly sets out (a) expected radiation impacts in the study 

area, and (b) the possible radiation impacts from an emergency. Emergency situations should 

include terrorist attacks. Shouldn't a worst case analysis be included for low-probability events? 

(0023-13 [Goldsmith, Aviv]) 

Comment: The continued lack of analysis and discussion of security against terrorist threats in 

Section 5.10 is a major omission. This subject is clearly part of today's "human environment". I 

would argue that terrorism is not an "accident". Terrorist attacks are deliberate and numerous. 

The proximity to DC could make North Anna an attractive target. Even FBI Director Mueller 

stated that a terrorist attack on a nuclear facility can be "postulated". 

(0023-39 [Goldsmith, Aviv]) 

Comment: There should be a Section 7.8.B that discusses the cumulative radiologic impacts of 

emergency situations (accidents and terrorism). Casual discussion in 7.8 of normal operations is 

insufficient treatment for this potentially devastating situation. 

(0023-45 [Goldsmith, Aviv]) 

Comment: Since Chapter 8 should address system design alternatives (page 1-10, line 38) the 

COL SDEIS should include consideration in section 8.2 for locating potentially vulnerable 

facilities (such as fuel and waste storage) underground to mitigate against terrorist attack or 

aviation accident. (0023-49 [Goldsmith, Aviv]) 

Comment: The EIS is noticeably weak in analysis and providing information on the key areas 

of public concern which include terrorism and safety. (0023-8 [Goldsmith, Aviv]) 

Response: Security and terrorism are safety issues that are outside the scope of the NRC 

staff’s environmental review. The NRC is devoting substantial time and attention to terrorismrelated matters, including coordination with the DHS. As part of its mission to protect public 

health and safety and the common defense and security pursuant to the Atomic Energy Act, the 
Appendix E 

February 2010 E-155 NUREG-1917, SEIS 

NRC staff is conducting vulnerability assessments for the domestic use of radioactive material. 

In the time since September 11, 2001, the NRC has identified the need for license holders to 

implement compensatory measures and has issued several orders to license holders imposing 

enhanced security requirements. Finally, the NRC has taken actions to ensure that applicants 

and license holders maintain vigilance and a high degree of security awareness. Consequently, 

the NRC will continue to consider measures to prevent and mitigate the consequences of acts 

of terrorism in fulfilling its safety mission. Additional information about the NRC staff’s actions 

regarding physical security since September 11, 2001, can be found on the NRC’s public web 

site (www.nrc.gov). No changes were made to the SEIS as a result of these comments. 

37. General Editorial Comments 

Comment: Section 5.9 is hard to understand by lay persons. A summary is required that 

clearly sets out expected radiation impacts in the study area. (0023-36 [Goldsmith, Aviv]) 

Response: Section 5.9 provides detailed information and supporting documentation regarding 

radiological impacts resulting from the various pathways during normal operation of the 

proposed Unit 3. A summary of the impacts from the operation of Unit 3 as well as from Units 1 

and 2 is provided in Section 7.8 of the SEIS. This comment provided no new and significant 

information. Therefore, no changes were made to the SEIS. 

Comment: Dominion suggests that the following text, paraphrased from Section 1.1 of its 

environmental report (ER) be substituted: The Dominion purpose and need for the proposed 

action is to provide additional base load power for customers in the region served by Dominion 

and ODEC, maintain fuel diversity in this region, reduce dependence on imported power, 

leverage Dominion's and ODEC's existing nuclear facilities, and to promote the regional 

economy, while not contributing to carbon dioxide emissions. (0084-1 [Grechek, Eugene]) 

Response: The suggestion in this comment applies to the Executive Summary of the SEIS. 

While the comment does provide more detail regarding the overall purpose and need for the 

plant, the staff thinks the information provided is sufficient. No changes were made to the SEIS. 

Comment: The DSEIS Appendix L list of authorizations and consultations is identical to the 

ESP EIS Appendix L. If NRC has determined that revision of the list is unnecessary, Dominion 

suggests the DSEIS Appendix L could be deleted and the section 1.5 language could be revised 

to read as follows: Appendix L of the ESP EIS lists authorization and consultation requirements 

that Dominion listed in connection with the Unit 3 construction and operation. NRC has identified 

no need to revise this list for the COL. Should NRC revise the DSEIS Appendix L list to include 

only those additional authorizations and consultations that Dominion identified in its COLA-ER, 

section 1.5 language could be revised as follows: Appendix L of the ESP EIS lists authorization 

and consultation requirements that Dominion listed in connection with the Unit 3 construction 

and operation. (0084-3 [Grechek, Eugene]) 

Response: Appendix L was included in the SEIS because it provides additional information 

that supports information in Appendix B, Organizations Contacted. While it might be considered 
Appendix E 

NUREG-1917, SEIS E-156 February 2010 

unnecessary to include that information, the NRC staff felt it was worthwhile to repeat it for 

completeness in evaluation of the application. For that reason, no changes were made to the 

SEIS. 

Comment: Dominion suggests that the following text, paraphrased from Section 1.1 of its 

environmental report (ER) be substituted: The Dominion purpose and need for the proposed 

action is to provide additional base load power for customers in the region served by Dominion 

and ODEC, maintain fuel diversity in this region, reduce dependence on imported power, 

leverage Dominion's and ODEC's existing nuclear facilities, and to promote the regional 

economy, while not contributing to carbon dioxide emissions. (0084-2 [Grechek, Eugene]) 

Response: The suggestion made in this comment applies to Section 1.3 of the SEIS. While 

the comment provides additional information regarding the need for the plant, the staff’s most 

compelling reason was the expectation for Dominion as reflected in Virginia Senate Bill 1416. 

For that reason, no change was made to the SEIS. 

Comment: [In SEIS Sec 9.2] Dominion suggests that NRC revise the text consistent with 

Dominion comments on the Executive Summary and other sections of Chapter 1. 

(0084-29 [Grechek, Eugene]) 

Response: The NRC staff did not think it was necessary to make changes to Chapter 1 of the 

SEIS; therefore, no changes were made to Section 9.2 of the SEIS.

38. References 

10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Rules of Practice for 

Domestic Licensing Proceedings and Issuance of Orders.” 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection Against Radiation.” 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses 

Certifications and Approvals for Nuclear Power Plants.” 

10 CFR Part 72 Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

Waste, and Reactor-Related Greater Than Class C Waste.” 
Appendix E 

February 2010 E-157 NUREG-1917, SEIS 

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800, “Protection of Historic and Cultural Properties.” 

40 CFR Part 141. Code of Federal Regulations, Title 40, Protection of the Environment, 

Part 141, “National Primary Drinking Water Regulations.” 

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of the Environment, 

Part 190, “Environmental Radiation Protection Standards for Nuclear Power Operations.” 

44 CFR Part 350. Code of Federal Regulations, Title 44, Emergency Management and 

Assistance, Part 350, “Review and Approval of State and Local Radiological Emergency Plans 

and Preparedness.” 

51 FR 30028. “Safety Goals for the Operation of Nuclear Power Plants.” Federal Register, 

Vol. 51, August 21, 1986. 

55 FR 38472. “Waste Confidence Decision Review.” Federal Register, Vol. 55, 

September 18, 1990. 

64 FR 68005. “Waste Confidence Decision Review: Status.” Federal Register, Vol. 64, 

No. 233, December 6, 1999. 

72 FR 49429. “Licenses, Certifications, and Approvals for Nuclear Power Plants.” Federal 

Register, Vol. 72, No. 166, August 28, 2007. 

73 FR 59551. “Waste Confidence Decision Update.” Federal Register, Vol. 73, No. 197, 

October 9, 2008. 

73 FR 79196. “Virginia Electric and Power Company, D/B/A Dominion Virginia Power, and Old 

Dominion Electric Cooperative; Notice of Availability of the Draft Supplemental Environmental 

Impact Statement and Public Meeting for North Anna Power Station Unit 3 Combined License 

Application. Federal Register, Vol. 73, No. 248, December 24, 2008. 

74 FR 106. “Environmental Impacts Statements: Notice of Availability, EIS No. 20080536 

North Anna Power Station Unit 3 Combined License (COL) for Construction of a Base-Load 

Nuclear Power Plant.” Vol. 74, No. 1. January 2, 2009. 

74 FR 4476. “Virginia Electric and Power Company, D/B/A Dominion Virginia Power, and Old 

Dominion Electric Cooperative; Correction to Notice of Availability of the Draft Supplemental 

Environmental Impact Statement and Public Meeting for North Anna Power Station Unit 3 

Combined License Application.” Vol. 74, No. 15. January 26, 2009. 

Atomic Energy Act of 1954. 42 USC 2011, et seq. 
Appendix E 

NUREG-1917, SEIS E-158 February 2010 

Baker, P.J. and D.G. Hoel. 2007. “Meta-analysis of Standardized Incidence and Mortality 

Rates of Childhood Leukemia in Proximity to Nuclear Facilities.” European Journal of Cancer 

Care 16(4):355-363. 

Clean Water Act. 33 USC 1251, et seq. (also referred to as the Federal Water Pollution Control 

Act.) 

Dominion Virginia Power (Dominion). 2008. North Anna 3 Combined License Application. 

Revision 1, December 2008. Richmond, Virginia. Accession No. ML090570781. 

Dominion Virginia Power (Dominion). 2009a. North Anna 3 Combined License Application 

Part 3: Environmental Report – Combined License Stage. Revision 2, July 2009. Accession 

No. ML092160490. 

Dominion Virginia Power (Dominion). 2009b. Letter from Pamela F. Faggert (Dominion 

Resources Services, Vice President) to Michael P, Murphy, Virginia Department of 

Environmental Quality, Director Division of Environmental Enhancement), “Final Report: 

Instream Flow Incremental Methodology (IFIM) Study North Anna Power Station – Unit 3.” 

October 29, 2009. Accession No. ML093210500. 

Dominion Virginia Power (Dominion). 2009c. North Anna 3 Combined License Application, 

Part 2: Final Safety Analysis Report. Revision 2, May 2009. Richmond, Virginia. Accession 

No. ML091540602. 

National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq. 

National Historic Preservation Act of 1966 (NHPA). 16 USC 470, et seq. 

National Research Council. 2005. Health Risks from Exposure to Low Levels of Ionizing 

Radiation: Biological Effects of Ionizing Radiation (BEIR) VII. Seventh Edition, National 

Academy of Sciences, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental 

Reviews for Nuclear Power Plants. NUREG-1555, Vol. 1, Washington, D.C. Includes 2007 

revisions.

U.S. Nuclear Regulatory Commission (NRC). 2006a. Environmental Impact Statement for an 

Early Site Permit (ESP) at the North Anna ESP Site – Final Report. NUREG-1811, Vols. 1 and 

2, Washington, D.C. 
Appendix E 

February 2010 E-159 NUREG-1917, SEIS 

U.S. Nuclear Regulatory Commission (NRC). 2006b. Environmental Impact Statement for an 

Early Site Permit (ESP) at the North Anna ESP Site – Draft Report for Comment. 

NUREG-1811, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2007. North Anna Early Site Permit 

No. ESP-003. Washington, D.C. Accession No. ML073180440. 

U.S. Nuclear Regulatory Commission (NRC). 2008. Supplemental Environmental Impact 

Statement for the Combined License (COL) for the North Anna Power Station Unit 3 – Draft 

Report for Comment. NUREG-1917, Washington, D.C. 

Appendix F 

Key Consultation Correspondence 

February 2010 F-1 NUREG-1917, SEIS 

Appendix F 

Key Consultation Correspondence 

Correspondence received during the evaluation process of the combined license (COL) 

application for Virginia Electric Power and Power Company and Old Dominion Electric 

Cooperative (collectively known as Dominion) for the proposed Unit 3 at the North Anna Power 

Station is identified in Table F-1. A full list of all correspondence during the preparation of this 

Supplemental Environmental Impact Statement is located in Appendix C. 

Table F-1. Correspondence Received Related to the North Anna Unit 3 COL Review 

Source Recipient Date of Letter/E-mail

Virginia Department of Historic 

Resources 

(Mr. Roger Kirchen) 

U.S. Nuclear Regulatory 

Commission 

(Pao-Tsin Kuo) 

November 07, 2008 

Virginia Department of Historic 

Resources 

(Mr. Roger Kirchen) 

U.S. Nuclear Regulatory 

Commission 

(Alicia Williamson) 

May 01, 2008 

Virginia Department of Game 

and Inland Fisheries 

(Ms. Amy Ewing) 

U.S. Nuclear Regulatory 

Commission 

(Alicia Williamson) 

May 09, 2008 

Virginia Department of 

Environmental Quality 

(Ms. Ellie Irons) 

U.S. Nuclear Regulatory 

Commission 

(Alicia Williamson) 

August 14, 2008 

Virginia Department of Historic 

Resources 

(Ms. Kathleen Kilpatrick) 

U.S. Nuclear Regulatory 

Commission 

(Alicia Williamson) 

November 4, 2008 

Virginia Department of Historic 

Resources 

(Mr. Roger Kirchen) 

U.S. Nuclear Regulatory 

Commission 

(Alicia Williamson) 

February 3, 2009 

Pamunkey Tribal Government 

(Chief Kevin Brown) 

U.S. Nuclear Regulatory 

Commission 

(Alicia Williamson) 

February 3, 2009 

U.S. Army Corps of Engineers 

(Ms. Regena Bronson) 

U.S. Nuclear Regulatory 

Commission 

(Alicia Williamson) 

March 9, 2009 
Appendix F 

NUREG-1917, SEIS F-2 February 2010 

Source Recipient Date of Letter/E-mail

Virginia Department of 

Environmental Quality (Ellie 

Irons) 

U.S. Nuclear Regulatory 

Commission 

(Alicia Williamson) 

March 18, 2009 

US Environmental Protection 

Agency (Jeffery Lapp) 

U.S. Nuclear Regulatory 

Commission 

(Alicia Williamson) 

March 20, 2009 
Appendix F 

February 2010 F-3 NUREG-1917, SEIS 

" .::.....~.>t~ '\,I,J ~~ P.24 

COMMONWEALTH of VIRGINIA L.Pt.< ... B.,...,.. ..... 

~ or N.tIJI'SIJlWlo\ft'C8 

November 7,2007 

Department of IJi$torie Resources 

2801 Kensington Avenue, Riclunond, Virginia 23221 

./ Mr. TOllyBanb 

DomInJonResoun:e ServicelI, Inc. 

Innsbrook Technical Cenrer 

SOOO Dt""lnIOli BI"<I. 

Glen All ..... VA '.3060 

1'<. (104) ldl·1121 

F ... (Mo)l61.2l9i 

TDD: (lIG4) )111·1316 

..".,.dh<.vIr,.....II". 

RB: SlIJIPlemental ~()logicD/ s..."e)'. Domlnfon Combined License Pro/eel. Nort1J bna Power 

SltIfItm, Louisa C'<!U'tI)'. nrglnla . 

OHlt Pile No. 2000-1210 

0_ Mr. Banks! 

We have received for CQnslderazion tha above-refemlCed document prllpanJd· by The Loul. Berger 

Group, Inc. for Dotninion ·lle.t..,W'CC Servi~s. Inc. We life pleased to inform YOIl tim the report meets the 

Seerdar)' of the Interior's St<tndard.J and G!tlaeliflU for the Docim,."tatirm of ArchaeologiCal Situ (43 

FR 4413~4'142) and our Dep8rtm~fs Survey G1ddelines (mrisod 2003). 

The survey Investigated six proposed work anas for the expansion of Domlnion'. North AMe facill!y. 

The survey dOQ\llllel\ted one previOUlily unr9COrded archaeological site (44LS0226), one known CCIIlleteJy 

(44LS0227 .and 054-5(35), and one lsol~ted find. The isolated find is, by defmition, not ~Iglble for 

listing In the Nallonal Register of Hisroric Pla_ and DO further work III th Is resoun;e is warranted. 

Sito!: 44LS0216 lJ the remains of 8 Iste 19" to early 20'" ~tuty domestic .Ite. Based on the integrity of 

the site and its potential to add .to our. undema.ocling of the AfrIcan-Amen.,.,. expedenoe during tlIa 

R.eeonstruetioQ and Growth era. tile consullallt recommends site 44LS0226 as eligible for IIstiog in the . 

National Register. Until a fotmal Pbue n evaluation of the site has been completed: we recommend this 

slle be tTI!.IIr.d IS petm/faTly ~llgtble for listing in the Nation.l Regiltat' and reoortmlend avoidance or 

Ilddltlonal Phase n investigation!. 

The idmtified cemetery, recorded as both archaeological .ile 44LS02l7 lI!1d an:bitectural resource 11054-

50lS, dates to the 19'" century, although the absence of iDscribed LtUlrnrs malces daring the burlab 

difficult. The cemetezy is currently fenced and do' ""ida" ••. is presented that 5Uggosts it extends beyoud 

tbis established boundary .. Tbls ~ite was not avaluated for Nationa! Register-eliglbility during this study: 

ho\'V""er, we.reoommend avcidQ1lce orthi' resource, If avoidance is not feasible, additioDal evalus.tion 

Allmioltlntt .. Solo .... to'Cour1hlNfC.Aveaur. . Pelmbarr .. VA 1310l 

T.l: (301)t6l-1 &:!~ 

Fn: CSOolo) '5l.tit96 

Ooplt<IIteJion 0111 .. nOl K!f'Idnl:tmJ;""IIe. 

I\l<b .... '" VA 23221 

Tel: t'''/ "1-23.23 , .. , (1104) 367·2391 

Tir:!tw1fef Ittgion 0I!u 

IJl41$ Old CourtAoUleW2)". 2" floor 

N...,.,..1"<wJ,VA2l6<>1 

Td, ".7/ &B.s.~e01 

F.x: (m! 886-2801 

It .... " a.s;c. Oftl .. J 03Q '_1M/' ~.,. S& Itoncb. VA 2-'40 13 

Tel! CS40}857-7"$ 

... : (540) 157.,,18 

Nonhcm RI:~oo omce llS'TMJltftSti.:ct 

PO e"" SI' S_ ... CilY. VA·nllS> Td: (540) 8S&.7DJ 1 

Fox, (5-<0) 1~'Dl2 . 

" .::.....~.>t~ '\,I,J ~~ P.24 

COMMONWEALTH of VIRGINIA L.Pt.< ... B.,...,.. ..... 

~ or N.tIJI'SIJlWlo\ft'C8 

November 7,2007 

Department of IJi$torie Resources 

2801 Kensington Avenue, Riclunond, Virginia 23221 

./ Mr. TOllyBanb 

DomInJonResoun:e ServicelI, Inc. 

Innsbrook Technical Cenrer 

SOOO Dt""lnIOli BI"<I. 

Glen All ..... VA '.3060 

1'<. (104) ldl·1121 

F ... (Mo)l61.2l9i 

TDD: (lIG4) )111·1316 

..".,.dh<.vIr,.....II". 

RB: SlIJIPlemental ~()logicD/ s..."e)'. Domlnfon Combined License Pro/eel. Nort1J bna Power 

SltIfItm, Louisa C'<!U'tI)'. nrglnla . 

OHlt Pile No. 2000-1210 

0_ Mr. Banks! 

We have received for CQnslderazion tha above-refemlCed document prllpanJd· by The Loul. Berger 

Group, Inc. for Dotninion ·lle.t..,W'CC Servi~s. Inc. We life pleased to inform YOIl tim the report meets the 

Seerdar)' of the Interior's St<tndard.J and G!tlaeliflU for the Docim,."tatirm of ArchaeologiCal Situ (43 

FR 4413~4'142) and our Dep8rtm~fs Survey G1ddelines (mrisod 2003). 

The survey Investigated six proposed work anas for the expansion of Domlnion'. North AMe facill!y. 

The survey dOQ\llllel\ted one previOUlily unr9COrded archaeological site (44LS0226), one known CCIIlleteJy 

(44LS0227 .and 054-5(35), and one lsol~ted find. The isolated find is, by defmition, not ~Iglble for 

listing In the Nallonal Register of Hisroric Pla_ and DO further work III th Is resoun;e is warranted. 

Sito!: 44LS0216 lJ the remains of 8 Iste 19" to early 20'" ~tuty domestic .Ite. Based on the integrity of 

the site and its potential to add .to our. undema.ocling of the AfrIcan-Amen.,.,. expedenoe during tlIa 

R.eeonstruetioQ and Growth era. tile consullallt recommends site 44LS0226 as eligible for IIstiog in the . 

National Register. Until a fotmal Pbue n evaluation of the site has been completed: we recommend this 

slle be tTI!.IIr.d IS petm/faTly ~llgtble for listing in the Nation.l Regiltat' and reoortmlend avoidance or 

Ilddltlonal Phase n investigation!. 

The idmtified cemetery, recorded as both archaeological .ile 44LS02l7 lI!1d an:bitectural resource 11054-

50lS, dates to the 19'" century, although the absence of iDscribed LtUlrnrs malces daring the burlab 

difficult. The cemetezy is currently fenced and do' ""ida" ••. is presented that 5Uggosts it extends beyoud 

tbis established boundary .. Tbls ~ite was not avaluated for Nationa! Register-eliglbility during this study: 

ho\'V""er, we.reoommend avcidQ1lce orthi' resource, If avoidance is not feasible, additioDal evalus.tion 

Allmioltlntt .. Solo .... to'Cour1hlNfC.Aveaur. . Pelmbarr .. VA 1310l 

T.l: (301)t6l-1 &:!~ 

Fn: CSOolo) '5l.tit96 

Ooplt<IIteJion 0111 .. nOl K!f'Idnl:tmJ;""IIe. 

I\l<b .... '" VA 23221 

Tel: t'''/ "1-23.23 , .. , (1104) 367·2391 

Tir:!tw1fef Ittgion 0I!u 

IJl41$ Old CourtAoUleW2)". 2" floor 

N...,.,..1"<wJ,VA2l6<>1 

Td, ".7/ &B.s.~e01 

F.x: (m! 886-2801 

It .... " a.s;c. Oftl .. J 03Q '_1M/' ~.,. S& Itoncb. VA 2-'40 13 

Tel! CS40}857-7"$ 

... : (540) 157.,,18 

Nonhcm RI:~oo omce llS'TMJltftSti.:ct 

PO e"" SI' S_ ... CilY. VA·nllS> Td: (540) 8S&.7DJ 1 

Fox, (5-<0) 1~'Dl2 . 
Appendix F 

NUREG-1917, SEIS F-4 February 2010 

Paae2 

November 7, 2Q07 

Mr. Tony Bania 

P.1il5 

vri1l be necellery to determine National !tegis)er.:eUgibility and a penni! must be obtaIned from our 

office ror 'II AnloVlli. 

Considering our carlier commt!lts !o the Nucl"r Regulat¢Ty Commlsaion dated October 20, 2006, the 

results of this study, and Domin!on's letter 10 our office dated October 11,2007, we concur with your 

concbl.!Jlon that thl! project will not negttlvaly imp •• t histone properties provided that the following 

t'ellourees are avoided and adequately pro~d during canatnlction and operation of the ficillty: 

44LS022I, 44LS0222. 44LSOl26. and 44LS0227IOS4-S03S. Iht any point, ""o!dllle. of thest sites is 

d~od 'impractical. please reinitiate consult8l!on with ou, office concerning Ibe ef£cet of !hIe 

undertaking on hiJlori. JIl'OPeJ1ie,. 

,we look f'orw.u'd to receiving Ibe Commission's fannal detenninalian ofeff'ect for this undertalcing and 

",orklng with 1111 pvlies throuahont this project. If you hovo any questions. plcase do nor lIesita:le to 

contact me at (804) 367·1323. ~'t. 153 or e-mail rgger.kirohen@dbr y~. 

Co, Mr. Eric Voigt, The Louis Berger Group, Inc. 

,/ U.SNiZ.(, f' ru- n 11/21 / 0 7 

VilE'&. 

TOTru. P.1il5 

Paae2 

November 7, 2Q07 

Mr. Tony Bania 

P.1il5 

vri1l be necellery to determine National !tegis)er.:eUgibility and a penni! must be obtaIned from our 

office ror 'II AnloVlli. 

Considering our carlier commt!lts !o the Nucl"r Regulat¢Ty Commlsaion dated October 20, 2006, the 

results of this study, and Domin!on's letter 10 our office dated October 11,2007, we concur with your 

concbl.!Jlon that thl! project will not negttlvaly imp •• t histone properties provided that the following 

t'ellourees are avoided and adequately pro~d during canatnlction and operation of the ficillty: 

44LS022I, 44LS0222. 44LSOl26. and 44LS0227IOS4-S03S. Iht any point, ""o!dllle. of thest sites is 

d~od 'impractical. please reinitiate consult8l!on with ou, office concerning Ibe ef£cet of !hIe 

undertaking on hiJlori. JIl'OPeJ1ie,. 

,we look f'orw.u'd to receiving Ibe Commission's fannal detenninalian ofeff'ect for this undertalcing and 

",orklng with 1111 pvlies throuahont this project. If you hovo any questions. plcase do nor lIesita:le to 

contact me at (804) 367·1323. ~'t. 153 or e-mail rgger.kirohen@dbr y~. 

Co, Mr. Eric Voigt, The Louis Berger Group, Inc. 

,/ U.SNiZ.(, f' ru- n 11/21 / 0 7 

VilE'&. 

TOTru. P.1il5 
Appendix F 

February 2010 F-5 NUREG-1917, SEIS 

L. Preston Bryant. Jr. 

Secretary of Natural Resources 

COMMONWEALTH of VIRGINIA 

Department of Historic Resou~ I' i-IVC D 

2801 Kensington Avenue, Richmond, Virgih~ 12322'1, ,. l_,. 

Kathleen S. Kilpatrick 

Director 

Tel, (&04) 367-2323 

Fax, (804) 367-2391 

TDD: (804) 367-2386 

www.dhr.virginia.gov 

May 1,2008 

Chief, Rules and Directives Branch 

Division of Administrative Services 

Mail Stop T-6D59 

U.S, Nuclear Regulatory Commission 

Washington, D.C. 20555-0001 

g/A8/0f( 

?,o?1Z !l35&y 

f!) 

RE: North Anna Power Station - Unit 3 Combined License (COL) Application Review 

DHR File No. 2000-1210; NRC Docket No. 52-017 

We have received from the Nuclear Regulatory Commission (NRC) notice of the action referenced above 

conducted on the behalf of Dominion ,Virginia"Power;:.--Thank,you for··initiating consultation on this 

undertaking pursuant.to Section 106' of th~ Natienal,Historic 'Preservation: Act·and,,'its implement.ing 

regulations codified 'at 36 CFR Part 800, On April 17,2008, .DHR staff met with·representatives:from· 

the NRC and Pacific Northwest National LabOratory. to discuss this:action and consultation'to date'on·the 

North Annaprojecv ,- "" ", :" ,," ',. .:",; ')i:' 

Many issues regarding pOtential impacts to histotic.·properties,specifically·archaeo!ogical resources, 

were resolved' during the Early Site Permit (ESP)'process;"(;iven theJimitations'of the .ESP proceSs and 

changes to the~scOpe of the project,: additional studies'rare warranted to determinethisundertaking',s 

~ffect' to historic properties, We understand. that an additional 90+ ae-res' have been added to the .project. 

We recommend that thi.s and any ,additional areas' included in ~theproject be' subjected to Phase. I 

archaeological survey by a qualified professional in accordance with .Our Survey GUidelines (rev. 2003). 

Furthermore, as new tower height: is established, we~nimimd: finalizing the viewshed analysis'to 

determine potential impacts to the setting of I!earby histotic properties;· Finally, we are· cOilcemeo',aoout 

the avoidan~cand' continued managemen,t'of the three:known cemeteries (44LS0221,.0222,:·anct;Q22·7) 

and the historic'$ite (44LS0226) which have 'been' found, to bepotentially-eligible'for listiilgO:iilthe 

National Register'ofHistoric Places. We request tharthe NRC provide:fonheir protection;'."; ':>,' 

Since consultation regarding the ESP, several Federally-recognized Indian tribes have informed our 

office of their possible'interest in undertakings in'Virginia. Find attached contact-information for'these 

tribes. We do not'know of any specific tribe with interest.,in this project n'or'do,1!ie'll'lakeany statement 

regarding' the completeness of this',~list.: This .information"is provided as a cOurtesy 'and is inteilde<t'!is 

technical assistance to NRC in meeting its tribal consultation requirements,:'" ; .... ,'" ,,',":-":.' ,,: ':"c ,-.; :".;. ' .... ,. "i '.'.", 

Administrative Services Capital Region Office 

10 Courthouse Avenue 280 1 Kensington Avc. 

Petersburg. VA 23803 Richmond,. VA 23221 

Tel, (804)863-1624 Tei:(804}367:2323 

Fax. '(804. )862-<;196 ~F":'(§04.lW_2391 

~c> fT~ -VSZ:: 13 el"/~ ;=- /):. 14 ~ 

-0/3 

TKlewater Region Office Roanoke Region Office Northern Region Office 

14415 Old Courthouse Way, 2"" Floor 1030 Penmar Ave.> SE 5357 Main Street 

N~t,l~ V~,2~60~ Roanok~ VA 240)3 PO Box 519 

TeI,(757)'886C2807' '" , Teq540) 857-7585 StephensCity, VA 22655 

. Eax:'(757),SS6--2808 , " ....... ,,:,F .. , f.54O) 857-7588 Tel: (540) 868-7031 

.,.e--~, /.l)h£ -to::3 '. Fax, (540) 868-7033) 

~=- ~·MM/a-..~(fJR-itJ1. 

L. Preston Bryant. Jr. 

Secretary of Natural Resources 

COMMONWEALTH of VIRGINIA 

Department of Historic Resou~ I' i-IVC D 

2801 Kensington Avenue, Richmond, Virgih~ 12322'1, ,. l_,. 

Kathleen S. Kilpatrick 

Director 

Tel, (&04) 367-2323 

Fax, (804) 367-2391 

TDD: (804) 367-2386 

www.dhr.virginia.gov 

May 1,2008 

Chief, Rules and Directives Branch 

Division of Administrative Services 

Mail Stop T-6D59 

U.S, Nuclear Regulatory Commission 

Washington, D.C. 20555-0001 

g/A8/0f( 

?,o?1Z !l35&y 

f!) 

RE: North Anna Power Station - Unit 3 Combined License (COL) Application Review 

DHR File No. 2000-1210; NRC Docket No. 52-017 

We have received from the Nuclear Regulatory Commission (NRC) notice of the action referenced above 

conducted on the behalf of Dominion ,Virginia"Power;:.--Thank,you for··initiating consultation on this 

undertaking pursuant.to Section 106' of th~ Natienal,Historic 'Preservation: Act·and,,'its implement.ing 

regulations codified 'at 36 CFR Part 800, On April 17,2008, .DHR staff met with·representatives:from· 

the NRC and Pacific Northwest National LabOratory. to discuss this:action and consultation'to date'on·the 

North Annaprojecv ,- "" ", :" ,," ',. .:",; ')i:' 

Many issues regarding pOtential impacts to histotic.·properties,specifically·archaeo!ogical resources, 

were resolved' during the Early Site Permit (ESP)'process;"(;iven theJimitations'of the .ESP proceSs and 

changes to the~scOpe of the project,: additional studies'rare warranted to determinethisundertaking',s 

~ffect' to historic properties, We understand. that an additional 90+ ae-res' have been added to the .project. 

We recommend that thi.s and any ,additional areas' included in ~theproject be' subjected to Phase. I 

archaeological survey by a qualified professional in accordance with .Our Survey GUidelines (rev. 2003). 

Furthermore, as new tower height: is established, we~nimimd: finalizing the viewshed analysis'to 

determine potential impacts to the setting of I!earby histotic properties;· Finally, we are· cOilcemeo',aoout 

the avoidan~cand' continued managemen,t'of the three:known cemeteries (44LS0221,.0222,:·anct;Q22·7) 

and the historic'$ite (44LS0226) which have 'been' found, to bepotentially-eligible'for listiilgO:iilthe 

National Register'ofHistoric Places. We request tharthe NRC provide:fonheir protection;'."; ':>,' 

Since consultation regarding the ESP, several Federally-recognized Indian tribes have informed our 

office of their possible'interest in undertakings in'Virginia. Find attached contact-information for'these 

tribes. We do not'know of any specific tribe with interest.,in this project n'or'do,1!ie'll'lakeany statement 

regarding' the completeness of this',~list.: This .information"is provided as a cOurtesy 'and is inteilde<t'!is 

technical assistance to NRC in meeting its tribal consultation requirements,:'" ; .... ,'" ,,',":-":.' ,,: ':"c ,-.; :".;. ' .... ,. "i '.'.", 

Administrative Services Capital Region Office 

10 Courthouse Avenue 280 1 Kensington Avc. 

Petersburg. VA 23803 Richmond,. VA 23221 

Tel, (804)863-1624 Tei:(804}367:2323 

Fax. '(804. )862-<;196 ~F":'(§04.lW_2391 

~c> fT~ -VSZ:: 13 el"/~ ;=- /):. 14 ~ 

-0/3 

TKlewater Region Office Roanoke Region Office Northern Region Office 

14415 Old Courthouse Way, 2"" Floor 1030 Penmar Ave.> SE 5357 Main Street 

N~t,l~ V~,2~60~ Roanok~ VA 240)3 PO Box 519 

TeI,(757)'886C2807' '" , Teq540) 857-7585 StephensCity, VA 22655 

. Eax:'(757),SS6--2808 , " ....... ,,:,F .. , f.54O) 857-7588 Tel: (540) 868-7031 

.,.e--~, /.l)h£ -to::3 '. Fax, (540) 868-7033) 

~=- ~·MM/a-..~(fJR-itJ1. 
Appendix F 

NUREG-1917, SEIS F-6 February 2010 

:.. ..... / ..... -:; 

Page 2 

North Arma Power Station COL 

DHR File No. 2000-1210; NRC Docket No. 52-017 

We look forward to working with the NRC and its consultants and applicant throughout this process. If 

you have any questions, please do not hesitate to contact me at (804) 367-2323, ext. 153 or e-mail 

roger.kirchen@dhr.virginia.gov. . 

:illffo.o,;. 

Office of Review and Compliance 

Cc (via email): Ms: Alicia R. Williamson, NRC 

:.. ..... / ..... -:; 

Page 2 

North Arma Power Station COL 

DHR File No. 2000-1210; NRC Docket No. 52-017 

We look forward to working with the NRC and its consultants and applicant throughout this process. If 

you have any questions, please do not hesitate to contact me at (804) 367-2323, ext. 153 or e-mail 

roger.kirchen@dhr.virginia.gov. . 

Office 

7~lo., of Review and Compliance 

Cc (via email): Ms: Alicia R. Williamson, NRC 
Appendix F 

February 2010 F-7 NUREG-1917, SEIS 

.!../ ."-.. 

Page 3 

North Anna Power Station COL 

OHR File !'io. 2000-1210; NRC Docket No. 52-017 

ATIACHMENT·. TRIBAL CONTACTS 

George Wickliffe, Chief 

Lisa C. Stopp, Acting THPO 

United Keetoowah Band of Cherokee Indians in 

Oklahoma 

POBox 746 

Tahlequa, OK 74465 

Phone: (918) 431-1818 

Fax: (918) 43 H873 

Istopp@unitedkeetoowahband.org 

Dr. Wenonah G. Haire Jr. 

Tribal Historic Preservation Officer 

Catawba Indian Nation 

Catawba Cultural Preservation Project 

61 I East Main Street 

Rock Hill, SC 29730 

(803) 328-2427 

wenonahh@ccppcrafts.com (also cc to 

jackier@ccppcrafts.com) 

Mr. James Bird 

Tribal Historic Preservation Officer 

Eastern Band of Cherokee Indians 

Cultural Resources Department Qualla 

Boundary 

P.O. Box 455 

Cherokee, NC 28719 

(828) 497-1594 

jamgbird@nc-cherokee.com 

Glenna J. Wallace. Chief 

Ms. Jo Ann Beckham, Administrative Assistant 

Eastern Shawnee Tribe of Oklahoma 

PO Box 350 

Seneca, MO 64865 

Phone: (918) 666-2435 

Fax:(9IS) 666-2186 

estochief@hotmail.com 

Ron Sparkman, Chairman 

Ms. Rebecca Hawkins 

Shawnee Tribe 

Historic Preservation Department 

P.O. Box 189 

Miami. OK 74355 

Phone: (918) 542-2441 

Fax: (918) 542-2922 

shawneethpo@neok.com 

Chief Leo Henry 

Tuscarora Nation 

2006 Mt. Hope Road 

Lewiston, New York 14092 

Phone: (716) 622-7061 

Fax: (716) 297-735 

.!../ ."-.. 

Page 3 

North Anna Power Station COL 

OHR File !'io. 2000-1210; NRC Docket No. 52-017 

ATIACHMENT·. TRIBAL CONTACTS 

George Wickliffe, Chief 

Lisa C. Stopp, Acting THPO 

United Keetoowah Band of Cherokee Indians in 

Oklahoma 

POBox 746 

Tahlequa, OK 74465 

Phone: (918) 431-1818 

Fax: (918) 43 H873 

Istopp@unitedkeetoowahband.org 

Dr. Wenonah G. Haire Jr. 

Tribal Historic Preservation Officer 

Catawba Indian Nation 

Catawba Cultural Preservation Project 

61 I East Main Street 

Rock Hill, SC 29730 

(803) 328-2427 

wenonahh@ccppcrafts.com (also cc to 

jackier@ccppcrafts.com) 

Mr. James Bird 

Tribal Historic Preservation Officer 

Eastern Band of Cherokee Indians 

Cultural Resources Department Qualla 

Boundary 

P.O. Box 455 

Cherokee, NC 28719 

(828) 497-1594 

jamgbird@nc-cherokee.com 

Glenna J. Wallace. Chief 

Ms. Jo Ann Beckham, Administrative Assistant 

Eastern Shawnee Tribe of Oklahoma 

PO Box 350 

Seneca, MO 64865 

Phone: (918) 666-2435 

Fax:(9IS) 666-2186 

estochief@hotmail.com 

Ron Sparkman, Chairman 

Ms. Rebecca Hawkins 

Shawnee Tribe 

Historic Preservation Department 

P.O. Box 189 

Miami. OK 74355 

Phone: (918) 542-2441 

Fax: (918) 542-2922 

shawneethpo@neok.com 

Chief Leo Henry 

Tuscarora Nation 

2006 Mt. Hope Road 

Lewiston, New York 14092 

Phone: (716) 622-7061 

Fax: (716) 297-735 
Appendix F 

NUREG-1917, SEIS F-8 February 2010 

NAPSEISComment Resource 

From: 

Sent: 

To: 

Ce: 

Subject: 

Ms. Williamson, 

Amy.Ewing@dgif.virginia.gov 

Friday, May 09, 2008 11:10 AM 

Alicia Williamson 

Brian.Watson@dgif.virginia.gov; John.Kauffman@dgif.virginia.gov 

RE: North Anna Power Station Combined License Application Review 

We have reviewed the proposed corridor for the additional 500kV line required to carry the output of the existing Lake 

Anna units and the proposed third unit. We do not currently document any listed wildlife or resources under our jurisdiction 

from the project area. Therefore, impacts upon such species and resources are not likely to result from the construction 

of this line. In addition, as this new line will be co-/ocated within an existing power line corridor, it does not appear that 

signifICant wildlife habitat alterations will occur. 

We recommend that all land disturbing activities adhere to erosion and sediment controls. We recommend conducting 

any in-stream activities during low or no-flow conditions, using non-erodible cofferdams to isolate the construction area, 

blocking no more than 50% of the streamflow at any given time, stockpiling excavated material in a manner that prevents 

reentry into the stream, restoring original streambed and streambank contours, revegetating barren areas with native 

vegetation, and implementing strict erosion and sediment control measures. Due to future maintenance costs associated 

with culverts, and the loss of riparian and aquatic habitat, we prefer stream crossings to be constructed via clear-span 

bridges. 

We have been very involved over many years and have provided a lot of input to Dominion, the permitting agencies and 

the NRC during the review process for the addition of Unit 3 to the North Anna Nuclear Power Plant. We are currently 

awaiting the resuHs of the Instream Flow Incremental Methodology (IFIM) study. Upon review of those results, we will 

make further recommendations regarding the protection of aquatic species under our jurisdiction as it relates to the 

addition of Unit 3 to the plant. If you are in need of any specific information or recommendations from us regarding this 

aspect of the COL at this time, please contact me. 

Thank you. 

AmyM. Ewing 

Environmental Services Biologist 

Virginia Dept. of Game and Inland Fisheries 

4010 West Broad Street 

Richmond, VA 23230 

804-367-2211 

amI'. ewing@dgif.virginia.gov 

From: Alida Williamson [mailto:A1icia.Williamson@nrc.gov] 

Sent: Wednesday, April 30, 2008 11:44 AM 

To: Ewing, Amy 

Cc: Femald, Ray; Watson, Brian; Kauffman, John 

Subject: RE: North Anna Power Station Combined Ucense Application Review 

AmySorry about any confusion our letter may have brought about, I hope our chat yesterday helped to clarify the 

information requests from NRC regarding the North Anna combined license environmental review. Attached is 

a map showing where the proposed new transmission lines will be placed. Dominion is planning to add the 

new lines to a pre-existing corridor, Line 575 (North Anna Station to Lady Smith Substation corridor) which is 

NAPSEISComment Resource 

From: 

Sent: 

To: 

Ce: 

Subject: 

Ms. Williamson, 

Amy.Ewing@dgif.virginia.gov 

Friday, May 09, 2008 11:10 AM 

Alicia Williamson 

Brian.Watson@dgif.virginia.gov; John.Kauffman@dgif.virginia.gov 

RE: North Anna Power Station Combined License Application Review 

We have reviewed the proposed corridor for the additional 500kV line required to carry the output of the existing Lake 

Anna units and the proposed third unit. We do not currently document any listed wildlife or resources under our jurisdiction 

from the project area. Therefore, impacts upon such species and resources are not likely to result from the construction 

of this line. In addition, as this new line will be co-/ocated within an existing power line corridor, it does not appear that 

signifICant wildlife habitat alterations will occur. 

We recommend that all land disturbing activities adhere to erosion and sediment controls. We recommend conducting 

any in-stream activities during low or no-flow conditions, using non-erodible cofferdams to isolate the construction area, 

blocking no more than 50% of the streamflow at any given time, stockpiling excavated material in a manner that prevents 

reentry into the stream, restoring original streambed and streambank contours, revegetating barren areas with native 

vegetation, and implementing strict erosion and sediment control measures. Due to future maintenance costs associated 

with culverts, and the loss of riparian and aquatic habitat, we prefer stream crossings to be constructed via clear-span 

bridges. 

We have been very involved over many years and have provided a lot of input to Dominion, the permitting agencies and 

the NRC during the review process for the addition of Unit 3 to the North Anna Nuclear Power Plant. We are currently 

awaiting the resuHs of the Instream Flow Incremental Methodology (IFIM) study. Upon review of those results, we will 

make further recommendations regarding the protection of aquatic species under our jurisdiction as it relates to the 

addition of Unit 3 to the plant. If you are in need of any specific information or recommendations from us regarding this 

aspect of the COL at this time, please contact me. 

Thank you. 

AmyM. Ewing 

Environmental Services Biologist 

Virginia Dept. of Game and Inland Fisheries 

4010 West Broad Street 

Richmond, VA 23230 

804-367-2211 

amI'. ewing@dgif.virginia.gov 

From: Alida Williamson [mailto:A1icia.Williamson@nrc.gov] 

Sent: Wednesday, April 30, 2008 11:44 AM 

To: Ewing, Amy 

Cc: Femald, Ray; Watson, Brian; Kauffman, John 

Subject: RE: North Anna Power Station Combined Ucense Application Review 

AmySorry about any confusion our letter may have brought about, I hope our chat yesterday helped to clarify the 

information requests from NRC regarding the North Anna combined license environmental review. Attached is 

a map showing where the proposed new transmission lines will be placed. Dominion is planning to add the 

new lines to a pre-existing corridor, Line 575 (North Anna Station to Lady Smith Substation corridor) which is 
Appendix F 

February 2010 F-9 NUREG-1917, SEIS 

highlighted. In addition, below is a link to the North Anna combined license home page should you need more 

detailed information. 

We look forward to receiving VDGIF's comments on the scope of the North Anna combined license 

environmental review. 

If you have any additional questions, please feel to contact me. 

Thanx 

Alicia 

hltP:/Iwww.nrc.gOV/reactors/new-licensing/colinorth-anna.html 

scroli down to Applicant Documents, Click part 3 - Environmental Report 

From: Amy.Ewing@dgif.virginia.gov [mailto:Amy.Ewing@dgif.virginia.gov] 

Sent: Tuesday, April 29,20083:31 PM 

To: AlIda Williamson 

Cc: Ray.Femald@dgif.virginja.gov; Brian.Walson@dgif,virginia.gov; John.Kauffman@dgif.virginia.gov 

Subject: North Anna Power Station Combined Ucense Application Review 

Ms. Wlmamson, 

We received a letter from your office dated April 1, 2008 that requests information, comments or concerns from us that 

we consider appropriate under the provisions of the FWCA. It appears you are asking for this information in preparation 

for writing the EIS on the combined license. As you know, our agency has been very involved in all aspects of this 

project, including the IFIM being performed in waters downstream of Lake Anna. We have not, as of yet, received 

any maps of the proposed transmission line and cannot provide comments related to impacts the construction of this 

line may have on wildlife without understanding what the proposed corridor is. 

I am writing to ask for clarification about what information you are looking for. I assume the NRC has received or been 

made aware of our comments and concems to this point as they relate to the addition of unit 3 at Lake Anna. Are you just 

inquiring, then, about our comments related to the new transmission line? If so, please provide a map of the proposed 

line route and we would be happy to provide comments and recommendations about the protection of wildlife resources 

related to the construction of that line. If you are in need of broader comments regarding the project as a whole, please 

clarify that for me so that I may put together our comprehensive comments about this project. 

We appreciate any clarification you can provide. We want to make sure that we do not miss any available opportunities 

to provide comments on this project. Thank you. Amy 

AmyM.Ewing 

Environmental Services Biologist 

Virginia Dept. of Game and Inland Fisheries 

4010 West Broad Street 

Richmond, VA 23230 

804-367-2211 

amy.ewing@dgif.virginia.gov 

2 

highlighted. In addition, below is a link to the North Anna combined license home page should you need more 

detailed information. 

We look forward to receiving VDGIF's comments on the scope of the North Anna combined license 

environmental review. 

If you have any additional questions, please feel to contact me. 

Thanx 

Alicia 

hltP:/Iwww.nrc.gOV/reactors/new-licensing/colinorth-anna.html 

scroli down to Applicant Documents, Click part 3 - Environmental Report 

From: Amy.Ewing@dgif.virginia.gov [mailto:Amy.Ewing@dgif.virginia.gov] 

Sent: Tuesday, April 29,20083:31 PM 

To: AlIda Williamson 

Cc: Ray.Femald@dgif.virginja.gov; Brian.Walson@dgif,virginia.gov; John.Kauffman@dgif.virginia.gov 

Subject: North Anna Power Station Combined Ucense Application Review 

Ms. Wlmamson, 

We received a letter from your office dated April 1, 2008 that requests information, comments or concerns from us that 

we consider appropriate under the provisions of the FWCA. It appears you are asking for this information in preparation 

for writing the EIS on the combined license. As you know, our agency has been very involved in all aspects of this 

project, including the IFIM being performed in waters downstream of Lake Anna. We have not, as of yet, received 

any maps of the proposed transmission line and cannot provide comments related to impacts the construction of this 

line may have on wildlife without understanding what the proposed corridor is. 

I am writing to ask for clarification about what information you are looking for. I assume the NRC has received or been 

made aware of our comments and concems to this point as they relate to the addition of unit 3 at Lake Anna. Are you just 

inquiring, then, about our comments related to the new transmission line? If so, please provide a map of the proposed 

line route and we would be happy to provide comments and recommendations about the protection of wildlife resources 

related to the construction of that line. If you are in need of broader comments regarding the project as a whole, please 

clarify that for me so that I may put together our comprehensive comments about this project. 

We appreciate any clarification you can provide. We want to make sure that we do not miss any available opportunities 

to provide comments on this project. Thank you. Amy 

AmyM.Ewing 

Environmental Services Biologist 

Virginia Dept. of Game and Inland Fisheries 

4010 West Broad Street 

Richmond, VA 23230 

804-367-2211 

amy.ewing@dgif.virginia.gov 

2 
Appendix F 

NUREG-1917, SEIS F-10 February 2010 

i;/f!P7 

y8?~#//6;U 

COMMONWEALTH o/VIRGINIA 0 L. Preston Bryan~ Jr. 

Secretary ofN~raJ Resources 

Chief, Rulemaking 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

Street address: 629 East Main Street, Richmond, Virginia 23219 

Mailing address: P.O. Box 1105, Richmond, Virginia 23218 

TDD (804) 698-4021 

www .d~. virginia~gov 

August14,2008 

Directives and Editing Branch 

Division of Administrative Services 

Office of Administration 

Mailstop T -6059 

U.S- Nuclear Regulatory Commission 

Washington, DC 20555-0001 

:JJ 

in 

() 

;Tl 

< rTl 

o 

David K. Paylor 

Director 

(804) 698-4000 

1-800-592-5482 

<Xl 

RE: Request for Comments on the Nuclear Regulatory Commission's Virginia Electric 

and Power Company, D/B/A Dominion Virginia Power, and Old Dominion Electric 

Cooperative North Anna Nuclear Station Unit 3 Combined License Application; 

Correction and 'Supplement to Notice of Intent to Prepare an Environmental 

Impact Statement and Conduct Scoping Process, Federal RegisterVol. 73, No. 

138, pages 41132-41133 

Dear Sirs: 

This is in response to the Nuclear Regulatory Commission (NRC) July 17,2008 Federal 

Register notice, Virginia Electric and Power Company, DJBIA Dominion Virginia Power, 

and Old Dominion Electric Cooperative North Anna Nuclear Station Unit 3 Combined 

License Application; Correction and Supplementto Notice of Intent to Prepare an 

Environmen1al Impact Statement and Conduct Scoping Process (73 FR 138, 41132-33). 

Description of the NRC Notice 

According to the NRC notice, the notice corrects and supplements a previous Notice of 

Intent to Prepare an Environmental Impact Statement (EIS) and Conduct Scoping 

Process (regarding an application for a combined license) published in the Federal 

Register on March 13, 2008 (73 FR 13589). The action is necessary: 

(5uv$Z:: l3e-f"~~£& 

~~" #i)i--<-~O/3 

.,e-~';;::Ds = #b-u -P? 

. ~ "'" /9-V~"""<-~-><-' 

, (i9:€.-«J1 ) 

i;/f!P7 

y8?~#//6;U 

COMMONWEALTH o/VIRGINIA 0 L. Preston Bryan~ Jr. 

Secretary ofN~raJ Resources 

Chief, Rulemaking 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

Street address: 629 East Main Street, Richmond, Virginia 23219 

Mailing address: P.O. Box 1105, Richmond, Virginia 23218 

TDD (804) 698-4021 

www .d~. virginia~gov 

August14,2008 

Directives and Editing Branch 

Division of Administrative Services 

Office of Administration 

Mailstop T -6059 

U.S- Nuclear Regulatory Commission 

Washington, DC 20555-0001 

:JJ 

in 

() 

;Tl 

< rTl 

o 

David K. Paylor 

Director 

(804) 698-4000 

1-800-592-5482 

<Xl 

RE: Request for Comments on the Nuclear Regulatory Commission's Virginia Electric 

and Power Company, D/B/A Dominion Virginia Power, and Old Dominion Electric 

Cooperative North Anna Nuclear Station Unit 3 Combined License Application; 

Correction and 'Supplement to Notice of Intent to Prepare an Environmental 

Impact Statement and Conduct Scoping Process, Federal RegisterVol. 73, No. 

138, pages 41132-41133 

Dear Sirs: 

This is in response to the Nuclear Regulatory Commission (NRC) July 17,2008 Federal 

Register notice, Virginia Electric and Power Company, DJBIA Dominion Virginia Power, 

and Old Dominion Electric Cooperative North Anna Nuclear Station Unit 3 Combined 

License Application; Correction and Supplementto Notice of Intent to Prepare an 

Environmen1al Impact Statement and Conduct Scoping Process (73 FR 138, 41132-33). 

Description of the NRC Notice 

According to the NRC notice, the notice corrects and supplements a previous Notice of 

Intent to Prepare an Environmental Impact Statement (EIS) and Conduct Scoping 

Process (regarding an application for a combined license) published in the Federal 

Register on March 13, 2008 (73 FR 13589). The action is necessary: 

(5uv$Z:: l3e-f"~~£& 

~~" #i)i--<-~O/3 

.,e-~';;::Ds = #b-u -P? 

. ~ "'" /9-V~"""<-~-><-' 

, (i9:€.-«J1 ) 
Appendix F 

February 2010 F-11 NUREG-1917, SEIS 

Chief, Rufemaking 

U.S. Nucfear Regulatory Commission 

1. to correctly identify the document the NRC staff intends to prepare, the 

applicants for the combined license (COL) and the matters that the scoping 

process is intended to accomplish; 

2. to inform the public and other scoping participants that alternative sites will not be 

considered in the review of the staff of the U.S. Nuclear Regulatory Commission 

(NRC or Commission) or in the environmental impact statement (EIS) prepared 

in connection with the COL application; and 

3. to reopen the scoping comment period so as to provide the public with an 

opportunity to participate in the environmental scoping process, as described in 

10 CFR 51.29, in regard to the correctly identified matters that the scoping 

process is intended to accomplish. 

On November 27,2007, the NRC issUed ESP-003 to Dominion Nuclear North Anna, 

lLC, for the North Anna Early Site Permit Site (ESP) (the site of proposed Unit 3). 

Furthermore, an application dated, November 27, 2007, for a COL for North Anna Unit 3 

submitted by Virginia Electric and 'Power Company dlbla Dominion Virginia Power and 

Old Dominion Electric Cooperative (Applicants) references the ESP for the North Anna 

ESP site, ESP-003. According to the NRC notice, for a COL application that references 

an ESP, the NRC staff, pursuant to 10 CFR 51.75(c), prepares a supplement to the 

. ESP EIS (NUREG-1811) in accordance with 10 CFR 51.92(e). Accordingly, the 

purpose of the notice is to inform the public that the NRC staff will be preparing a 

supplement to NUREG-1811, the ESP Final EIS, in support of the reviewofthe COL. 

Pursuant to NRC regulations in 10 CFR 51.92(e), the scoping process for the 

i; . supplemental EIS to the ESP Final EIS will be used to accomplish the following: 

(a) Identification of the economiC, technical, and other benefits and costs of the 

proposed action, 'to the extent thatthe EIS for the ESP did not include an 

assessment of these benefits and costs; . 

(b) Identification of other energy alternatives, to the extent that the EIS for the ESP 

did .not include an assessment of energy alternatives; 

(c) Identification of the issues related to the impacts of construction and operation of 

the facility that were riot resolved in the ESP proceeding; and 

(d) Identificatiori of the issues related to the impacts of construction and operation 

that were resolved in the ESP proceeding but where new and significant 

information exists, including but not limited to, new and significant information 

demonstrating that the design of the facility falls outside the site characteristics 

and design parameters specified in the ESP. 

In light of the above information; the NRC staff has decided to reopen the scoping 

comment period for thirty (30) days to enhance the ability of members of the public to 

participate .in the scoping process. ' 

2 

Chief, Rufemaking 

U.S. Nucfear Regulatory Commission 

1. to correctly identify the document the NRC staff intends to prepare, the 

applicants for the combined license (COL) and the matters that the scoping 

process is intended to accomplish; 

2. to inform the public and other scoping participants that alternative sites will not be 

considered in the review of the staff of the U.S. Nuclear Regulatory Commission 

(NRC or Commission) or in the environmental impact statement (EIS) prepared 

in connection with the COL application; and 

3. to reopen the scoping comment period so as to provide the public with an 

opportunity to participate in the environmental scoping process, as described in 

10 CFR 51.29, in regard to the correctly identified matters that the scoping 

process is intended to accomplish. 

On November 27,2007, the NRC issUed ESP-003 to Dominion Nuclear North Anna, 

lLC, for the North Anna Early Site Permit Site (ESP) (the site of proposed Unit 3). 

Furthermore, an application dated, November 27, 2007, for a COL for North Anna Unit 3 

submitted by Virginia Electric and 'Power Company dlbla Dominion Virginia Power and 

Old Dominion Electric Cooperative (Applicants) references the ESP for the North Anna 

ESP site, ESP-003. According to the NRC notice, for a COL application that references 

an ESP, the NRC staff, pursuant to 10 CFR 51.75(c), prepares a supplement to the 

. ESP EIS (NUREG-1811) in accordance with 10 CFR 51.92(e). Accordingly, the 

purpose of the notice is to inform the public that the NRC staff will be preparing a 

supplement to NUREG-1811, the ESP Final EIS, in support of the reviewofthe COL. 

Pursuant to NRC regulations in 10 CFR 51.92(e), the scoping process for the 

i; . supplemental EIS to the ESP Final EIS will be used to accomplish the following: 

(a) Identification of the economiC, technical, and other benefits and costs of the 

proposed action, 'to the extent thatthe EIS for the ESP did not include an 

assessment of these benefits and costs; . 

(b) Identification of other energy alternatives, to the extent that the EIS for the ESP 

did .not include an assessment of energy alternatives; 

(c) Identification of the issues related to the impacts of construction and operation of 

the facility that were riot resolved in the ESP proceeding; and 

(d) Identificatiori of the issues related to the impacts of construction and operation 

that were resolved in the ESP proceeding but where new and significant 

information exists, including but not limited to, new and significant information 

demonstrating that the design of the facility falls outside the site characteristics 

and design parameters specified in the ESP. 

In light of the above information; the NRC staff has decided to reopen the scoping 

comment period for thirty (30) days to enhance the ability of members of the public to 

participate .in the scoping process. ' 

2 
Appendix F 

NUREG-1917, SEIS F-12 February 2010 

Chief, Rulemaking , 

U.S. Nuclear Regulatory Commission 

SCOPING COMMENTS 

The following discussion pertains to the NRC's decision to:prepare a supplemental EIS . 

in support of the COL instead of an EIS. Inasmuch as a COL is a major federal action, 

a supplemental EIS would not provide the rigorous environmental analysiS necessary to 

guide decision makers on a COL application. The ~RC has repeatedly stated that "to 

construct and operate a nuclear power plant, an ESP holder must obtain a CP and OL, 

or a COL, which are separate major federal actions which require their own 

environmental review in aCC()rdance with 10 CFR Part 51" (references: ESP Final EIS, 

page 1-2, ESP Supplemental EIS, Executive Summary, page xViii, and ESP, DEIS, . 

Executive Summary page xxi). The recent decision (published on July 17, 2008) to 

prepare a supplement to the Final ESP EIS to support the COL instead of another EIS 

for the COL is also inconsistent with the NRC's earlier position as reflected in Mr. 

William D. Be~ner's July 6, 2005 letter responding to Mr. Adrian Reymer at the Nuclear 

Energy Institute. In .that letter, Mr. Beckner stated ·We believe that a portion of the 

underlying basis for industry's view is nOt consistent with the NRC'S regulations and the 

applicable case law interpreting the National Environmental Policy Act of 1969, as 

amended (NEPA). In particular, inasmuch as an ESP and a COL are major federal 

actions, an environmental assessment is not a sufficient environmental inquiry on which 

to base an action on an ESP or COL application. Accordingly, pursuant to 10 CFR . 

51.20, both actions require the preparation of an EIS." 

While we understand that the NRC's current rliles implementing NEPA (10 CFR 51.92) 

allow the NRC to prepare a supplement to the ESP EIS to support the COL, over the . 

past five years (since 2003 until March 13,2008) the NRC has consistently maintained 

that an EIS would be prepared to support the COL. It was with this understanding that 

the Commonwealth reviewed and commented on the,Draft EIS (March 3, 2005) and 

Supplemental EIS (September 8, 2006) for the ESP. During the ESP review process 

several environmental impact considerations were deferred to the COL stage of the 

licensing process. Following the 2006 amendments to the NRC rules, the Final ESP 

EIS which was published in December 2007 continued to assert that the ESP and COL 

are separate major federal actions requiring their own environmental review. Therefore, 

the Commonwealth had no reason to anticipate the NRC's recent change in its position 

on the type of NEPA document which would be prepared for the COL process. 

NEPA AND FEDERAL CONSISTENCY REVIEW AUTHORITIES 

DEO's roles with respect to the review of any environmental documents that may be 

prepared for the proposed action are described below. DEO's Office of Environmental 

Impact Review (OEIR) will coordinate Virginia's review of environmental documents 

prepared pursuant to the National Environmental Policy Act and comment to the NRC 

on behalf of the Commonwealth. A similar review process pertains to federal 

consistency certifications (FCC) submitted pursuant to the Coastal Zone Management 

Act (CZMA) of 1972, as amended. 

3 

Chief, Rulemaking , 

U.S. Nuclear Regulatory Commission 

SCOPING COMMENTS 

The following discussion pertains to the NRC's decision to:prepare a supplemental EIS . 

in support of the COL instead of an EIS. Inasmuch as a COL is a major federal action, 

a supplemental EIS would not provide the rigorous environmental analysiS necessary to 

guide decision makers on a COL application. The ~RC has repeatedly stated that "to 

construct and operate a nuclear power plant, an ESP holder must obtain a CP and OL, 

or a COL, which are separate major federal actions which require their own 

environmental review in aCC()rdance with 10 CFR Part 51" (references: ESP Final EIS, 

page 1-2, ESP Supplemental EIS, Executive Summary, page xViii, and ESP, DEIS, . 

Executive Summary page xxi). The recent decision (published on July 17, 2008) to 

prepare a supplement to the Final ESP EIS to support the COL instead of another EIS 

for the COL is also inconsistent with the NRC's earlier position as reflected in Mr. 

William D. Be~ner's July 6, 2005 letter responding to Mr. Adrian Reymer at the Nuclear 

Energy Institute. In .that letter, Mr. Beckner stated ·We believe that a portion of the 

underlying basis for industry's view is nOt consistent with the NRC'S regulations and the 

applicable case law interpreting the National Environmental Policy Act of 1969, as 

amended (NEPA). In particular, inasmuch as an ESP and a COL are major federal 

actions, an environmental assessment is not a sufficient environmental inquiry on which 

to base an action on an ESP or COL application. Accordingly, pursuant to 10 CFR . 

51.20, both actions require the preparation of an EIS." 

While we understand that the NRC's current rliles implementing NEPA (10 CFR 51.92) 

allow the NRC to prepare a supplement to the ESP EIS to support the COL, over the . 

past five years (since 2003 until March 13,2008) the NRC has consistently maintained 

that an EIS would be prepared to support the COL. It was with this understanding that 

the Commonwealth reviewed and commented on the,Draft EIS (March 3, 2005) and 

Supplemental EIS (September 8, 2006) for the ESP. During the ESP review process 

several environmental impact considerations were deferred to the COL stage of the 

licensing process. Following the 2006 amendments to the NRC rules, the Final ESP 

EIS which was published in December 2007 continued to assert that the ESP and COL 

are separate major federal actions requiring their own environmental review. Therefore, 

the Commonwealth had no reason to anticipate the NRC's recent change in its position 

on the type of NEPA document which would be prepared for the COL process. 

NEPA AND FEDERAL CONSISTENCY REVIEW AUTHORITIES 

DEO's roles with respect to the review of any environmental documents that may be 

prepared for the proposed action are described below. DEO's Office of Environmental 

Impact Review (OEIR) will coordinate Virginia's review of environmental documents 

prepared pursuant to the National Environmental Policy Act and comment to the NRC 

on behalf of the Commonwealth. A similar review process pertains to federal 

consistency certifications (FCC) submitted pursuant to the Coastal Zone Management 

Act (CZMA) of 1972, as amended. 

3 
Appendix F 

February 2010 F-13 NUREG-1917, SEIS 

· . - ~ . :'.' 

\, ·.t~;j~~ i:~'- ;'.t7: t 

Chief. Rulema1o;ing 

U.S. Nuclear Regulatory Commission 

Pursuant to the CZMA, federal licensing or permit activities affecting Virginia's coastal 

resources or coastal uses must be consistent with the enforceable policies of the 

Virginia Coastal Resources Management Program (VCP) (also called the Virginia 

Coastal Zone Management Program) (See Federal Consistency Regulations, 15 CFR 

Part. 930, sub-part D, ConsistenCy for Activities Requiring a License or Permit). DEQ 

must be provided with a federal consistency certification which involves an analysis of 

the activities in light of the enforceable policies of the VCP (first enclosure), and a 

commitment to comply with the enforceable policies'. In addition, we invite your 

attention to the advisory policies of the VCP (second enclosure). 

Sections 930.57 and 930.58 of the Federal Consistency Regulations and Virginia's 

Federal Consistency Information Package available on DEQ's web site at 

http://www.dea.virginia.gov/eirlfederal.html. give content requirements for a consistency 

certification. . 

We recommend that the submission of the federal consistency certification follows the 

completion of the NEPA review process to facilitate the resolution of issues before 

embarking on the consistency review. We believe that this approach will prevent 

unnecessary delays in the consistency review process which could result from changes 

... - made during the NEPA review. . 

Environmental Review 

The following state and local Virginia agencies are likely to be included in the 

coordinated review of submitted environmental documents (npte: starred (*) agencies 

administer one or more of the Enforceable Policies of the Virginia Coastal ResoiJrces 

Management Program. 

Department of Environmental Quality: 

Office of Environmental Impact Review 

Tidewater Regional Office" 

Water Division . 

Air Division· 

Waste Division 

Department of Game and Inland Fisheries* 

Department of Conservation and Recreation: 

Division of Chesapeake Bay. Local Assistance* 

Division of Soil and Water Conservation" 

Division of Planning and Recreation Resources 

Department of Health* 

Marine Resources Commission* 

Department of Historic Resources 

Virginia Institute of Marine Science 

Department of Mines, Minerals, and Energy 

Department of Agriculture and Consumer Services 

Department of Forestry 

4 

· . - ~ . :'.' 

\, ·.t~;j~~ i:~'- ;'.t7: t 

Chief. Rulema1o;ing 

U.S. Nuclear Regulatory Commission 

Pursuant to the CZMA, federal licensing or permit activities affecting Virginia's coastal 

resources or coastal uses must be consistent with the enforceable policies of the 

Virginia Coastal Resources Management Program (VCP) (also called the Virginia 

Coastal Zone Management Program) (See Federal Consistency Regulations, 15 CFR 

Part. 930, sub-part D, ConsistenCy for Activities Requiring a License or Permit). DEQ 

must be provided with a federal consistency certification which involves an analysis of 

the activities in light of the enforceable policies of the VCP (first enclosure), and a 

commitment to comply with the enforceable policies'. In addition, we invite your 

attention to the advisory policies of the VCP (second enclosure). 

Sections 930.57 and 930.58 of the Federal Consistency Regulations and Virginia's 

Federal Consistency Information Package available on DEQ's web site at 

http://www.dea.virginia.gov/eirlfederal.html. give content requirements for a consistency 

certification. . 

We recommend that the submission of the federal consistency certification follows the 

completion of the NEPA review process to facilitate the resolution of issues before 

embarking on the consistency review. We believe that this approach will prevent 

unnecessary delays in the consistency review process which could result from changes 

... - made during the NEPA review. . 

Environmental Review 

The following state and local Virginia agencies are likely to be included in the 

coordinated review of submitted environmental documents (npte: starred (*) agencies 

administer one or more of the Enforceable Policies of the Virginia Coastal ResoiJrces 

Management Program. 

Department of Environmental Quality: 

Office of Environmental Impact Review 

Tidewater Regional Office" 

Water Division . 

Air Division· 

Waste Division 

Department of Game and Inland Fisheries* 

Department of Conservation and Recreation: 

Division of Chesapeake Bay. Local Assistance* 

Division of Soil and Water Conservation" 

Division of Planning and Recreation Resources 

Department of Health* 

Marine Resources Commission* 

Department of Historic Resources 

Virginia Institute of Marine Science 

Department of Mines, Minerals, and Energy 

Department of Agriculture and Consumer Services 

Department of Forestry 

4 
Appendix F 

NUREG-1917, SEIS F-14 February 2010 

Chief, RuJemaking 

U.S. Nuclear Regulatory Commission 

Department of Forestry 

Department of Transportation 

Hampton Roads Planning District Commission .. 

Affected Locality (ies) . . 

In .order to ensure an effective coordinated review of the EIS and the consistency 

certification, we will require about 24 copies of each document (6 hard copies and 18 

CDs) when it is published. The document should include one or more U.S. Geological 

Survey topographic maps as part of its information. We recommend, as well, that 

project details be adequately described and analyzed. While this Office does not 

participate in scoping efforts beyond the advice·given herein, other agencies may 

independently provide scoping comments to you concerning the preparation of the 

NEPA document for the proposed project. 

If you have questions about the NEPA review process or the federal consistency review 

process, feel free to call me at (804) 698-4325 or John Fisher of this Office at (804) 698c 

4339. 

Enclosures 

cc. Richard Weeks, DEQ 

Michael Murphy, DEQ 

Thomas Falla, DEQ-NVRO 

Kotur S. Narasimhan, DEQ-Air 

Paul Kohler, DEQ-Waste 

Joseph Hasse", DEQ-Water 

John Kauffman, DGIF 

Amy Ewing, DGIF 

Bob Munson, OCR 

Robbie Rhur, DCR 

Rene Hypes, OCR 

Les Foldesi, VDH 

Susan Douglas, VDH 

Tony Watkinson, MRC 

Ethel R. Eaton, DHR 

Chris Adkins, VDOT 

Keith Tignor, VDACS 

Matt Heller, DMME 

Todd Groh, VDF 

Sincerely, 

~~~. Ellie L. Irons, Manager 

Office of Environmental Impact Review 

5 

Chief, RuJemaking 

U.S. Nuclear Regulatory Commission 

Department of Forestry 

Department of Transportation 

Hampton Roads Planning District Commission .. 

Affected Locality (ies) . . 

In .order to ensure an effective coordinated review of the EIS and the consistency 

certification, we will require about 24 copies of each document (6 hard copies and 18 

CDs) when it is published. The document should include one or more U.S. Geological 

Survey topographic maps as part of its information. We recommend, as well, that 

project details be adequately described and analyzed. While this Office does not 

participate in scoping efforts beyond the advice·given herein, other agencies may 

independently provide scoping comments to you concerning the preparation of the 

NEPA document for the proposed project. 

If you have questions about the NEPA review process or the federal consistency review 

process, feel free to call me at (804) 698-4325 or John Fisher of this Office at (804) 698c 

4339. 

Enclosures 

cc. Richard Weeks, DEQ 

Michael Murphy, DEQ 

Thomas Falla, DEQ-NVRO 

Kotur S. Narasimhan, DEQ-Air 

Paul Kohler, DEQ-Waste 

Joseph Hasse", DEQ-Water 

John Kauffman, DGIF 

Amy Ewing, DGIF 

Bob Munson, OCR 

Robbie Rhur, DCR 

Rene Hypes, OCR 

Les Foldesi, VDH 

Susan Douglas, VDH 

Tony Watkinson, MRC 

Ethel R. Eaton, DHR 

Chris Adkins, VDOT 

Keith Tignor, VDACS 

Matt Heller, DMME 

Todd Groh, VDF 

Sincerely, 

~~~. Ellie L. Irons, Manager 

Office of Environmental Impact Review 

5 
Appendix F 

February 2010 F-15 NUREG-1917, SEIS 

'. 

. . . . ' . 

. COMMONWEALTH of VIRGINIA " L.,Pri:ston BrYant, 1r. DEPARTMENT OF ENVIRONMENTAL QUAUTY 

Street address: 629 East Main Street. Richmon<!, Virginia 23219 

Mailing address: P. O. Bo" I 0009, Richmond, Vrrginia 23240 

... Fax (804) 698-4500 TOO. (804) 698-4021 

wwW.deq.vjTgini~:gov 

David K. Paylor 

Sec~ ofN~ Resourees: Director 

. (804) 6984000 

1-800-592-5482 

Attachment 1 . 

. Enforceable R~guiatory Programs comprising . Virginia's Coastal Resources 

Management Program (yCP) 

a. . Fisheries M~nagement - The program stresses the conservation and enhancement 

of finfish and. shellfish resources and the promotion of commercial and recreational 

fISheries to maximize food ptoduction and recreational opportunities. This program 

is administered by the Marine Resources Commission (VMRC); Virginia Cod~ 28.2-

200 to. 28.2-713 and the Department of .Game and Inland Fisheries (OGIF); Virginia 

Cod~ 29.1-100 tQ 29.1"570. ... . . . 

. The State T ributyltin (TBT) RegulatOry Prograrn has been added to the Rsheries 

Management program. . The General Assembly amended the Virginia Pesticide 

Use and Application Acias it related to the possession, sale, or' use of marine 

. antifoulant paints containing' TBT. The use· of TBT . in . boat paint constitutes a 

· serious threat to important marine animal species. The TBT program monitors 

boating actiVities and boat painting activities 'to- ensure compliance with TBT 

regulations promulgated pursuant to the amendment The VMRC, DGIF. and 

Virginia Department .. of Agriculture Consumer Services· (VOACS) share 

enforceme.nt responsibilities; Virginia Cod~ 3.1-249.59 tQ 3.1-249.62. . . 

. b. Subaqueous lands Management. - The. management. program for subaqueous 

landS establishes conditions for granting or denying pemlits to use state-owned 

bottomlarids' based on conSiderations of potential effects on marine and fISheries' 

resources, tidal wetlands. adjacent or nearby properties, anticipated public and' 

private benefits, and water quality standards· established by the Department of 

Environmental Quality (DEQ).. The program is administered' by the Marine 

Resources Commission; Virginia Cod~ 28.2-1200 tQ28.2-1213. . . . . 

c. . Wetlands Management - The purpose of the wetlands management piogram is to . 

preserve wetlands, prevent' their despoliation. and acCommodate economic 

development in a manner consistent with wetlands preservation_ 

· (1) The tidal. wetlands program is administered by the Marine ReSources 

Commission; Virginia Cod~ 28.2-1301 through 28.2-1320 .. 

(2) The Virginia Water Protection Pemlit program administe~ by DEQ includes 

· • protection of wet/ands -bOth tidal and nbn-tldal;Virginia COde §62.144.15:5 

and Water QUality Ce.rtificationpursuant to Section 401 of the Clean Water Act .• 

'. 

. . . . '. '. . 

. COMMONWEALTH of VIRGINIA " L.,Pri:ston BrYant, 1r. DEPARTMENT OF ENVIRONMENTAL QUAUTY 

Street address: 629 East Main Street. Richmon<!, Virginia 23219 

Mailing address: P. O. Bo" I 0009, Richmond, Vrrginia 23240 

... Fax (804) 698-4500 TOO. (804) 698-4021 

wwW.deq.vjTgini~:gov 

David K. Paylor 

Sec~ ofN~ Resourees: Director 

. (804) 6984000 

1-800-592-5482 

Attachment 1 . 

. Enforceable R~guiatory Programs comprising . Virginia's Coastal Resources 

Management Program (yCP) 

a. . Fisheries M~nagement - The program stresses the conservation and enhancement 

of finfish and. shellfish resources and the promotion of commercial and recreational 

fISheries to maximize food ptoduction and recreational opportunities. This program 

is administered by the Marine Resources Commission (VMRC); Virginia Cod~ 28.2-

200 to. 28.2-713 and the Department of .Game and Inland Fisheries (OGIF); Virginia 

Cod~ 29.1-100 tQ 29.1"570. ... . . . 

. The State T ributyltin (TBT) RegulatOry Prograrn has been added to the Rsheries 

Management program. . The General Assembly amended the Virginia Pesticide 

Use and Application Acias it related to the possession, sale, or' use of marine 

. antifoulant paints containing' TBT. The use· of TBT . in . boat paint constitutes a 

· serious threat to important marine animal species. The TBT program monitors 

boating actiVities and boat painting activities 'to- ensure compliance with TBT 

regulations promulgated pursuant to the amendment The VMRC, DGIF. and 

Virginia Department .. of Agriculture Consumer Services· (VOACS) share 

enforceme.nt responsibilities; Virginia Cod~ 3.1-249.59 tQ 3.1-249.62. . . 

. b. Subaqueous lands Management. - The. management. program for subaqueous 

landS establishes conditions for granting or denying pemlits to use state-owned 

bottomlarids' based on conSiderations of potential effects on marine and fISheries' 

resources, tidal wetlands. adjacent or nearby properties, anticipated public and' 

private benefits, and water quality standards· established by the Department of 

Environmental Quality (DEQ).. The program is administered' by the Marine 

Resources Commission; Virginia Cod~ 28.2-1200 tQ28.2-1213. . . . . 

c. . Wetlands Management - The purpose of the wetlands management piogram is to . 

preserve wetlands, prevent' their despoliation. and acCommodate economic 

development in a manner consistent with wetlands preservation_ 

· (1) The tidal. wetlands program is administered by the Marine ReSources 

Commission; Virginia Cod~ 28.2-1301 through 28.2-1320 .. 

(2) The Virginia Water Protection Pemlit program administe~ by DEQ includes 

· • protection of wet/ands -bOth tidal and nbn-tldal;Virginia COde §62.144.15:5 

and Water QUality Ce.rtificationpursuant to Section 401 of the Clean Water Act .• 
Appendix F 

NUREG-1917, SEIS F-16 February 2010 

'. 

Attachment 100ritinued 

Page 2 

d. Dunes Management- Dune protection is' carried :but pursuant to The Coastal 

Primary Sand Dune Protection Act and is intended to prevent destruction . or 

aHeration of primary dunes. This program is administered by the Marine Resources 

Commission; Virginia CodE! 28.2~1400 through 28.2-1420; . 

e.' Non-point Source Pollution Control :- (1) Virginia's Erosion and Sediment Control 

Law requires soil-disturbing projects to be designed to reduce soil erosion and to 

decrease inputs of chemical nutrients and sediments to the Chesapeake Bay, its 

tributaries, .and '. other rivers, and waters of the Commonwealth; This program is. 

administered by the Department of Conservation and Recreation; Virginia Code ~ 10; 1-560 et.seg.). . . .. . . . '. '. . 

. (2) Coastal Lands Management isa state-local cooperative program administered 

by the DCR's Division of Chesapeake Bay Local Assistance and 84 localities in 

Tidewater (see i) Virginia; Virginia Code§10.1 c2100 -10.1-2114 and 9 VAC10-20 

etseq. 

f. Point Source Pollution Control - The point source program is administered' by the '. 

State Water Control Board (DEQ) pUrsuant tb Virginia Code. 62.1-44: 15. Point 

'.' source pollution control is accomplished throug~ .the. implementation of: . ,. ." 

(1) the' National. Pollutant Disch~rgeElimination System (NPDES) permit program 

estabiished . pursuant to Section 402 of the federal Clean· Water Act and· 

administered in Virginia as the Virginia Pollutant Discharge EUmination System 

(VPDES) permit program.' .. 

(2) The Virginia Water Protection Permit (VWPP) program administered by DEQ; 

. Virginia Code §62.1-44.15:5 and Water Quality Certification pursuant .10 Sectiori 

401 of the CI.ean Water Act.. . .' 

g. Shoreline Sanitation - The purpose of this program is to reQulatethe installation of 

septic tanks, set standards conceming soil types suitable for septic tanks, and 

specify minimum distances that tanks must ,be placl9d away from streams, rivers, 

and other waters of the Commonwealth. .' This program' is administered by the 

Department of Health (Virginia CodE! 32.1-164 throug/"t 32.1-165). . 

h. Air Pollution Control- The program implements the federal Clean Air Act 10 provide 

a iegaiiy enforceable State Implerhimtalion Plan fOr the attainment and 

maintenance of the National Ambien! Air. Quality Standards. This program is 

aclministeredby the State AirPollution Control Board (Virginia Code. 10-1.1300 

through §10.1-1320) .. · 

.. (i) . Coastal Lands Management is a state-local cooperative program administered by 

the DCR's Division of Chesapeake Bay. Local Assistance and 84 localities in 

Tidewater, Virginia established pursuant to the Chesapeake Bay Preservation Act; 

Virginia Code. §10.1-2100 -10;h2114 ancl Chesapeake Bay Preservation Area 

Designation and Management Regulations; Virginia Administrative Code 9 VAC10-

20 etseq. . 

'. 

Attachment 100ritinued 

Page 2 

d. Dunes Management- Dune protection is' carried :but pursuant to The Coastal 

Primary Sand Dune Protection Act and is intended to prevent destruction . or 

aHeration of primary dunes. This program is administered by the Marine Resources 

Commission; Virginia CodE! 28.2~1400 through 28.2-1420; . 

e.' Non-point Source Pollution Control :- (1) Virginia's Erosion and Sediment Control 

Law requires soil-disturbing projects to be designed to reduce soil erosion and to 

decrease inputs of chemical nutrients and sediments to the Chesapeake Bay, its 

tributaries, .and '. other rivers, and waters of the Commonwealth; This program is. 

administered by the Department of Conservation and Recreation; Virginia Code ~ 10; 1-560 et.seg.). . . .. . . . '. '. . 

. (2) Coastal Lands Management isa state-local cooperative program administered 

by the DCR's Division of Chesapeake Bay Local Assistance and 84 localities in 

Tidewater (see i) Virginia; Virginia Code§10.1c2100 -10.1-2114 and 9 VAC10-20 

etseq. 

f. Point Source Pollution Control - The point source program is administered' by the '. 

State Water Control Board (DEQ) pUrsuant tb Virginia Code. 62.1-44: 15. Point 

'.' source pollution control is accomplished throug~ .the. implementation of: . ,. ." 

(1) the' National. Pollutant Disch~rgeElimination System (NPDES) permit program 

estabiished . pursuant to Section 402 of the federal Clean· Water Act and· 

administered in Virginia as the Virginia Pollutant Discharge EUmination System 

(VPDES) permit program.' .. 

(2) The Virginia Water Protection Permit (VWPP) program administered by DEQ; 

. Virginia Code §62.1-44.15:5 and Water Quality Certification pursuant .10 Sectiori 

401 of the CI.ean Water Act.. . .' 

g. Shoreline Sanitation - The purpose of this program is to reQulatethe installation of 

septic tanks, set standards conceming soil types suitable for septic tanks, and 

specify minimum distances that tanks must ,be placl9d away from streams, rivers, 

and other waters of the Commonwealth. .' This program' is administered by the 

Department of Health (Virginia CodE! 32.1-164 throug/"t 32.1-165). . 

h. Air Pollution Control- The program implements the federal Clean Air Act 10 provide 

a iegaiiy enforceable State Implerhimtalion Plan fOr the attainment and 

maintenance of the National Ambien! Air. Quality Standards. This program is 

aclministeredby the State AirPollution Control Board (Virginia Code. 10-1.1300 

through §10.1-1320) .. · 

.. (i) . Coastal Lands Management is a state-local cooperative program administered by 

the DCR's Division of Chesapeake Bay. Local Assistance and 84 localities in 

Tidewater, Virginia established pursuant to the Chesapeake Bay Preservation Act; 

Virginia Code. §10.1-2100 -10;h2114 ancl Chesapeake Bay Preservation Area 

Designation and Management Regulations; Virginia Administrative Code 9 VAC10-

20 etseq. . 
Appendix F 

February 2010 F-17 NUREG-1917, SEIS 

'. 

Attachment 2 

Advisory Policies for Geograpbic Areas of Particular Concern 

a. Coastal Natural Resource Areas· These areas are vital 10 estuarine and marine ecosystems 

andlor are of great importance to areas immediately inland of the shoreline. Such areas 

receive special attention from the Commonwealth because of their conservation, 

recreational, ecological, and aesthetic values. These areas are worthy of special 

consideration in any planning or resources management process and include the following 

resources: 

a) Wetlands 

b) Aquatic Spawning, Nursery, and Feeding Grounds 

c) Coastal Primary Sand Dunes 

d) Barrier Islands 

. e) Significant Wildlife Habitat Areas 

I) Public Recreation Areas 

g) Sand and Gravel Resources 

h) Underwater Historic Sites. 

b. Coastal Natural Hazard Areas· This policy covers areas \'IJlnerable to continuing and severe 

erosion and areas susceptible to potential damage from wind, tidal, and storm related events 

including flooding. New buildings and other structures should be designe.d and sited to 

minimize the potential for property damage due to storms or shoreline erosion. The areas of 

concern are as follows: 

i) Highly Erodible Areas 

ii) Coastal High Hazard Areas, including flood plains. 

c. Waterfront Development Areas· These areas are vital to the Commonwealth because of the 

limited number of areas suitable for waterfront· activities. The areas of concern are as 

follows: 

i) Commercial Ports 

ii) Commercial Fishing Piers 

iii) Community Waterfronts 

Although the management of such areas is the responsibility of local government and some 

regional authorities, designation of these areas as Waterfront Development Areas of 

Particular Concern (APC) under the VCRMP is encouraged. Designation will allow the use 

of federal CZMA funds to be used to assist planning for such areas and the implementation 

of such plans .. The VCRMP recognizes two broad classes of priority uses for waterfront 

development APC: 

i) water access dependent activities; 

ii) activities significantly enhanced by the waterfront location and complementary to 

other existing and,'or planned activities in a given waterfront area. 

'. 

Attachment 2 

Advisory Policies for Geograpbic Areas of Particular Concern 

a. Coastal Natural Resource Areas· These areas are vital 10 estuarine and marine ecosystems 

andlor are of great importance to areas immediately inland of the shoreline. Such areas 

receive special attention from the Commonwealth because of their conservation, 

recreational, ecological, and aesthetic values. These areas are worthy of special 

consideration in any planning or resources management process and include the following 

resources: 

a) Wetlands 

b) Aquatic Spawning, Nursery, and Feeding Grounds 

c) Coastal Primary Sand Dunes 

d) Barrier Islands 

. e) Significant Wildlife Habitat Areas 

I) Public Recreation Areas 

g) Sand and Gravel Resources 

h) Underwater Historic Sites. 

b. Coastal Natural Hazard Areas· This policy covers areas \'IJlnerable to continuing and severe 

erosion and areas susceptible to potential damage from wind, tidal, and storm related events 

including flooding. New buildings and other structures should be designe.d and sited to 

minimize the potential for property damage due to storms or shoreline erosion. The areas of 

concern are as follows: 

i) Highly Erodible Areas 

ii) Coastal High Hazard Areas, including flood plains. 

c. Waterfront Development Areas· These areas are vital to the Commonwealth because of the 

limited number of areas suitable for waterfront· activities. The areas of concern are as 

follows: 

i) Commercial Ports 

ii) Commercial Fishing Piers 

iii) Community Waterfronts 

Although the management of such areas is the responsibility of local government and some 

regional authorities, designation of these areas as Waterfront Development Areas of 

Particular Concern (APC) under the VCRMP is encouraged. Designation will allow the use 

of federal CZMA funds to be used to assist planning for such areas and the implementation 

of such plans .. The VCRMP recognizes two broad classes of priority uses for waterfront 

development APC: 

i) water access dependent activities; 

ii) activities significantly enhanced by the waterfront location and complementary to 

other existing and,'or planned activities in a given waterfront area. 
Appendix F 

NUREG-1917, SEIS F-18 February 2010 

Ad"ison' Poliries for Sborefront Access Planning and Proll'rlion 

a. Virginia Public Beaches - Approximately 25 miles of public beaches are located in the 

cities, counties, and towns of Virginia exclusive of public beaches on state and federal land. 

These public shoreline areas will be maintained to allow public access to recreational 

resources. 

b. Virginia Outdoors Plan - Planning for coastal access is provided by the Department of 

Conservation and Recreation in cooperation with other state and local government agencies. 

The Virginia Outdoors Plan (Vap), which is published by the Department, identifies 

recreational facilities in the Commonwealth that provide recreational access. The vap also 

serves to identify future needs of the Commonwealth in relation to the provision of 

recreational opportunities and shoreline access. Prior to initiating any project, consideration 

should be given to the proximity of the project site to recreational resources identified in the 

Yap. 

c. Parks, Natural Areas, and Wildlife ManaQement Areas - Parks, Wildlife Management Areas, 

and Natural Areas are provided for the recreational pleasure of the citizens of the 

Commonwealth and the nation by local, state, and federal agencies. The recreational values 

of these areas should be protected and maintained. 

d. Waterfront Recreational Land Acquisition -It is the policy of the Commonwealth to protect 

areas, properties,lands, or any estate or interest therein; of scenic beauty, recreations! utility, 

historical interest, or unusual features which may be acquired, preserved, and maintained for· 

the citizens of the Commonwealth. . . 

e. Waterfront Recreational Facilities - This policy applies to the provision of boat ramps, 

public landings, and bridges which provide water access to the citizens of the 

Commonwealth. These facilities shall be designed, constructed, and maintained to provide 

points of water access when and where practicable. 

f. Waterfront Historic Properties - The Commonwealth has a long history of settlement and 

development, and much of that history has involved both shorelines and near-shore areas. 

The protection· and preservation of historic shorefront properties is primarily the 

responsibility of the Department of Historic Resources. Buildings, structures, and sites of 

historical, architectural, and/or archaeological interest are significant resources for the 

citizens of the Commonwealth. It is the policy of the Commonwealth and the VCRMP to 

enhance. the protection of buildings, structures, and sites of historical, architectural, and 

archaeological significance from damage or destruction when practicable. 

Ad"ison' Poliries for Sborefront Access Planning and Proll'rlion 

a. Virginia Public Beaches - Approximately 25 miles of public beaches are located in the 

cities, counties, and towns of Virginia exclusive of public beaches on state and federal land. 

These public shoreline areas will be maintained to allow public access to recreational 

resources. 

b. Virginia Outdoors Plan - Planning for coastal access is provided by the Department of 

Conservation and Recreation in cooperation with other state and local government agencies. 

The Virginia Outdoors Plan (Vap), which is published by the Department, identifies 

recreational facilities in the Commonwealth that provide recreational access. The vap also 

serves to identify future needs of the Commonwealth in relation to the provision of 

recreational opportunities and shoreline access. Prior to initiating any project, consideration 

should be given to the proximity of the project site to recreational resources identified in the 

Yap. 

c. Parks, Natural Areas, and Wildlife ManaQement Areas - Parks, Wildlife Management Areas, 

and Natural Areas are provided for the recreational pleasure of the citizens of the 

Commonwealth and the nation by local, state, and federal agencies. The recreational values 

of these areas should be protected and maintained. 

d. Waterfront Recreational Land Acquisition -It is the policy of the Commonwealth to protect 

areas, properties,lands, or any estate or interest therein; of scenic beauty, recreations! utility, 

historical interest, or unusual features which may be acquired, preserved, and maintained for· 

the citizens of the Commonwealth. . . 

e. Waterfront Recreational Facilities - This policy applies to the provision of boat ramps, 

public landings, and bridges which provide water access to the citizens of the 

Commonwealth. These facilities shall be designed, constructed, and maintained to provide 

points of water access when and where practicable. 

f. Waterfront Historic Properties - The Commonwealth has a long history of settlement and 

development, and much of that history has involved both shorelines and near-shore areas. 

The protection· and preservation of historic shorefront properties is primarily the 

responsibility of the Department of Historic Resources. Buildings, structures, and sites of 

historical, architectural, and/or archaeological interest are significant resources for the 

citizens of the Commonwealth. It is the policy of the Commonwealth and the VCRMP to 

enhance. the protection of buildings, structures, and sites of historical, architectural, and 

archaeological significance from damage or destruction when practicable. 
Appendix F 

February 2010 F-19 NUREG-1917, SEIS 

Eup>e S. Grecheck 

Vtce President 

Nw:Iear Development 

'Dominion" 

DomiaioD. BnCI'8Y' Inc. • Dominion Generation Innsbrook Technical Center 

5000 Dominion Boulevard. Glen Allen, VA 23060 

Phon., 804-273·2«2, F"" 804-273·3903 

E-mail: Eugcne.Grccheck@dom.com 

Ms. Kathleen Kilpatrick, Director 

Virginia Department of Historic Resources 

2801 Kensington Avenue 

Richmond, Virginia 23221 

November 4. 2008 

Re: DOMINION COMBINED LICENSE PROJECT 

NORTH ANNA POWER STATION 

PROJECT UPDATE and ARCHAEOLOGICAL SURVEY (2008) 

VDHR File No. : 2000-1210 

Dear Ms. Kilpatrick: 

COL-0370 

This letter follows up on Dominion's continued progress with the above-referenced project. As 

you are likely aware, Dominion received an Early Site Permit (ESP) for the North Anna site 

from the U.S. Nuclear Regulatory Commission (NRC) on November 27,2007. Upon NRC's 

issuance of the ESP and finding of site suitability for potential new nuclear generation at North 

Anna, Dominion applied to NRC for a license to construct and operate (COL) l! third nuclear 

unit at the North Anna site. This COL application (COLA) was submitted to the NRC on 

November 27,2007, and has been under review by NRC since that time. 

The NRC has been in consultation with VDHR during their review of Dominion's North Anna 

COLA. Dominion expects NRC's review of the COLA to be completed in mid-2011. Site 

development and construction is planned during the next several years. As stated in an October 

I I, 2007 letter from Mr. Tony Banks of my staff to Dr. Ethel Eaton of VDHR, Dominion will 

continue to communicate and work closely with all appropriate agencies regarding cultural 

resources associated with this project. 

One 2008 project development relevant to both VDHR and NRC review is the identification of 

another archaeological site in an area proposed for construction support purposes. Earlier this 

year, our consultant, The Louis Berger Group, Inc. (Berger), conducted an additional 

archaeological survey, identified one archaeological site, and recommended avoidance and 

preservation in place, if feasible. (A fL'la! report of this archaeological S ... .u-vey will be provided 

to VDHR when it is available.) Dominion commits to preserving this archaeological site, 

through avoidance, should it or any others be determined eligible for inclusion in the National 

Register of Historic Places. Different means of avoidance could include noting locations 

designated for protection on drawings, following directions through appropriate procedures and 

work instructions, and/or physical controls such as fencing or postings. 

Eup>e S. Grecheck 

Vtce President 

Nw:Iear Development 

'Dominion" 

DomiaioD. BnCI'8Y' Inc. • Dominion Generation Innsbrook Technical Center 

5000 Dominion Boulevard. Glen Allen, VA 23060 

Phon., 804-273·2«2, F"" 804-273·3903 

E-mail: Eugcne.Grccheck@dom.com 

Ms. Kathleen Kilpatrick, Director 

Virginia Department of Historic Resources 

2801 Kensington Avenue 

Richmond, Virginia 23221 

November 4. 2008 

Re: DOMINION COMBINED LICENSE PROJECT 

NORTH ANNA POWER STATION 

PROJECT UPDATE and ARCHAEOLOGICAL SURVEY (2008) 

VDHR File No. : 2000-1210 

Dear Ms. Kilpatrick: 

COL-0370 

This letter follows up on Dominion's continued progress with the above-referenced project. As 

you are likely aware, Dominion received an Early Site Permit (ESP) for the North Anna site 

from the U.S. Nuclear Regulatory Commission (NRC) on November 27,2007. Upon NRC's 

issuance of the ESP and finding of site suitability for potential new nuclear generation at North 

Anna, Dominion applied to NRC for a license to construct and operate (COL) l! third nuclear 

unit at the North Anna site. This COL application (COLA) was submitted to the NRC on 

November 27,2007, and has been under review by NRC since that time. 

The NRC has been in consultation with VDHR during their review of Dominion's North Anna 

COLA. Dominion expects NRC's review of the COLA to be completed in mid-2011. Site 

development and construction is planned during the next several years. As stated in an October 

I I, 2007 letter from Mr. Tony Banks of my staff to Dr. Ethel Eaton of VDHR, Dominion will 

continue to communicate and work closely with all appropriate agencies regarding cultural 

resources associated with this project. 

One 2008 project development relevant to both VDHR and NRC review is the identification of 

another archaeological site in an area proposed for construction support purposes. Earlier this 

year, our consultant, The Louis Berger Group, Inc. (Berger), conducted an additional 

archaeological survey, identified one archaeological site, and recommended avoidance and 

preservation in place, if feasible. (A fL'la! report of this archaeological S ... .u-vey will be provided 

to VDHR when it is available.) Dominion commits to preserving this archaeological site, 

through avoidance, should it or any others be determined eligible for inclusion in the National 

Register of Historic Places. Different means of avoidance could include noting locations 

designated for protection on drawings, following directions through appropriate procedures and 

work instructions, and/or physical controls such as fencing or postings. 
Appendix F 

NUREG-1917, SEIS F-20 February 2010 

Ms. Kathleen Kilpatrick 

COL-0370 

Page20f2 

Furthennore, as planning continues and activities begin that may have ground-disturbing 

impacts, Dominion will coordinate with VDHR to ensure the protection of previously evaluated 

and any newly-discovered cultural resources. If, at any point, avoidance of a cultural resources 

site is deemed impractical, consultation with VDHR will be re-initiated to detennine other 

appropriate treatment measures. 

Please be advised that Dominion's cultural resources assessments and consultations with 

VDHR are shared with NRC. It is Dominion's intent to not only meet our regulatory 

obligations, but to be good stewards of the resources located in the communities in which we 

serve. Dominion will continue to work with VDHR and NRC as we move forward on this 

important project. 

Please contact Tony Banks at (804) 273-2170 (tony.banks@dom.com) if you have questions. 

Very truly yours, 

Eugene S. Grecheck 

cc: R. Kirchen, VDHR 

A. Williamson, USNRC 

R. Bronson, USACE 

Ms. Kathleen Kilpatrick 

COL-0370 

Page20f2 

Furthennore, as planning continues and activities begin that may have ground-disturbing 

impacts, Dominion will coordinate with VDHR to ensure the protection of previously evaluated 

and any newly-discovered cultural resources. If, at any point, avoidance of a cultural resources 

site is deemed impractical, consultation with VDHR will be re-initiated to detennine other 

appropriate treatment measures. 

Please be advised that Dominion's cultural resources assessments and consultations with 

VDHR are shared with NRC. It is Dominion's intent to not only meet our regulatory 

obligations, but to be good stewards of the resources located in the communities in which we 

serve. Dominion will continue to work with VDHR and NRC as we move forward on this 

important project. 

Please contact Tony Banks at (804) 273-2170 (tony.banks@dom.com) if you have questions. 

Very truly yours, 

Eugene S. Grecheck 

cc: R. Kirchen, VDHR 

A. Williamson, USNRC 

R. Bronson, USACE 
Appendix F 

February 2010 F-21 NUREG-1917, SEIS 

COMMONWEALTH of VIRGINIA 

L. Preston Bryant, Jr. 

Secretary of Natural Resources Department of Historil; Resources Kathleen S. KiJ patrick 

Director 

2801 Kensington Avenue, Richmond, Virginia 23221-0311 Tel: (804) 367-2323 

Fax: (804) 367-2391 

TOO; (804) 367-2386 

www.dhr.virginia.gov 

February 3. 2009 

Chief, Rulemaking 

Directives iuid Editing Branch 

Mail Stop T6-D59 

U.S.·Nuclear Regulatory Commission 

Washington, D.C. 20555-0001 

1&-/~1//)<6 

7.:2 rl< 7'1/'1(" 

o 

RE: Draft NUREG-1917; Supplemental EIS, North Anna Power Station Unit 3 COL 

DHR File No. 2000-1210; DEQ #09-001F 

We have received from the. Nuclear Regulatory Commission (NRC) the draft Supplemental 

Environin'eniaf Impact Statem~nt (DSEIS) referenced above. 

We find that the .p.s.~!~.accur",t!,ly reflects consultation to date and adequa.tely addresses our concerns. 

We str~ng6' s~P.Port tli~·§.olllirii~ments made by Dominion Virginia Power in Section 4.6 of the DSEIS 

which will provide foi-,the continued consideration and protection of historic properties. If the NRC and 

Dominion are unable or unwilling to abide by these commitments, additional consultation on the impacts 

of the COL on historic properties will be necessary. Provided the commitments are met, we find that a 

determination of no adverse effect to historic properties is appropriate. 

Thank you for the opportunity to comment on this document. If you have any·questions, ple~e do not 

hesitate to contact ine at (804) 367-2323, ext. 153 or c'mail roger.kjrchel1@dhr.vjrgi~~gov, l~ 

W: ~ kjj-ch~n; Ar~liaciol~gisf 

Offide~f Revie,\>~~a tompliihc~ ",' . ~. " " " .,.' . .". .,,'" ';.-'" ~ •. :' _;. ; .:7 .. :. .". 

Mr;: John E: Fi;h~r, DEQ'; OEiR ". 

.,' 

.... : . 

Administrative Services Capital Region Office Tidewater Region Office 

;T] ri ::-) ~ 

'il co 

':;::; 

. ~~."", 

. ~ :"" .... . "', ... . iTl ··;.:)., .. ,0,' , \ .. '~ 

'9. 

'.r.;::- . 

>.o~ .. :<, ~'i!:' ",,' ,": .' 

", ,/=-:x.-F:'?>~= #.?)~ -tJ,3 .1 _', .... ·.1 '.'. ': ":' •• , ..... : •• " 

Roanoke Region Office Northern Region Office 

10 Courthouse Avenue 2801 Kensington Ave. 

Petersburg. VA 23803 ·.lticftmond, VA 2322.1 

Tel: (804) 863,1624 , ,. T.I:i8()4i'}~7-:i323 

14415 Old Courthouse Way, 2"" Floor 

Newport News, VA 23608 

1030 Penmar Ave .• SE 5357 Main Street 

Roanoke, VA 240 13 PO Box 519 

. , .. .rel, (540) 8S7-7~8S. '. Stephens City, VA 226SS 

Fax' (804) 862'6196 , ..... ' .:·FiIx:'(804)367-2391 

6 U A.J,s'-r If~/leur ~;tJuee 1/ ~ ~:o;. /?!JJ:-< -:-/>l? . 

"Tek(757) 886-2807 

Fa" (757) 886-2808 '-:''j!,lhS40j ~57-7588· Tel: (540) 868-7031 

'. Fa,,·(540) 868-7033 ) 

~; /J·MI-IJa.-.rt8(J')--J (8<.t-U1 

COMMONWEALTH of VIRGINIA 

L. Preston Bryant, Jr. 

Secretary of Natural Resources Department of Historil; Resources Kathleen S. KiJ patrick 

Director 

2801 Kensington Avenue, Richmond, Virginia 23221-0311 Tel: (804) 367-2323 

Fax: (804) 367-2391 

TOO; (804) 367-2386 

www.dhr.virginia.gov 

February 3. 2009 

Chief, Rulemaking 

Directives iuid Editing Branch 

Mail Stop T6-D59 

U.S.·Nuclear Regulatory Commission 

Washington, D.C. 20555-0001 

1&-/~1//)<6 

7.:2 rl< 7'1/'1(" 

o 

RE: Draft NUREG-1917; Supplemental EIS, North Anna Power Station Unit 3 COL 

DHR File No. 2000-1210; DEQ #09-001F 

We have received from t~e Nucle~r Regulatory Commission (NRC) the draft Supplemental 

Environin'eniaf Impact Statement (DSEIS) referenced above. 

We find that the .p.s.~!~.accur",t!,ly reflects consultation to date and adequa.tely addresses our concerns. 

We str~ng6' s~P.Port tli~·§.olllirii~ments made by Dominion Virginia Power in Section 4.6 of the DSEIS 

which will provide foi-,the continued consideration and protection of historic properties. If the NRC and 

Dominion are unable or unwilling to abide by these commitments, additional consultation on the impacts 

of the COL on historic properties will be necessary. Provided the commitments are met, we find that a 

determination of no adverse effect to historic properties is appropriate. 

Thank you for the opportunity to comment on this document. If you have any·questions, ple~e do not 

hesitate to contact ine at (804) 367-2323, ext. 153 or c'mail roger.kjrchel1@dhr.vjrgi~~gov, l~ 

W: ~ kjj-ch~n; Ar~liaciol~gisf 

Offide~f Revie~'~~a tompliihc~ ".' . ~. " " " .,.' . .". .,,'" ';.-'" ~ •. :' _;. ; .:7 .. :. ." . 

Cc: Mr;: John E: Fi;h~r, DEQ '; OEiR ". 

. ,' 

.... :. 

Administrative Services Capital Region Office Tidewater Region Office 

;T] ri :) ~ 'il co 

. ~ :"" .... . "', ... . '9 . 

, \ .. '~ '.r.;::- . 

>'O~'.:<, 

~'i!:' ",,' , .. : .. 

'" ,/=-:x.-F:'?>~= #.?)~ -tJ.3 .1 ....... ·.1.... .: .. : ... , ..... : .... 

Roanoke Region Office Northern Region Office 

10 Courthouse Avenue 2801 Kensington Ave. 

Petersburg. VA 23803 ·JU.cftmond, VA 2322.1 

Tel: (804) 863,1624 . .. T.I:i8()4i'}~7-:i323 

14415 Old Courthouse Way, 2nd Floor 

Newport News, VA 23608 

1030 Penmar Ave., SE 5357 Main Street 

Roanoke, VA 240 13 PO Box 519 

. , .. .Tel, (540) 8S7-7~8S. '. Stephens City, VA 226SS 

Fax' (804) 862'6196 ....... .:·FiIx:'(804)367-2391 

6 U A.J,s'-r If~/leur ~;tJuee 1/ ~ ~:o;. /?!JJ:-< -:-/>l? . 

.. Tek(757) 886-2807 

Fa.: (757) 886-2808 '-:''il,lhS40j ~57-7588' Tel: (540) 868-7031 

'. Fax:'(540) 868-7033 ) 

~; /J·M)../Ja.-.rt8(J')--J (8<.t-U1 
Appendix F 

NUREG-1917, SEIS F-22 February 2010 

HUNTING 

FISHING 

PCTTEI'lY 

MUSEUM 

ARTIF"ACTS 

KEVIN BROWN, CHIEF 

TELEPHDNE: SD4-B43-20S7 

PAMUNKEY INDIAN RESERVATION 

PAMUNKEY TRIBAL GOVERNMENT 

331 POCKET RD. 

KING WILLIAM, VIRGINIA 23096 

JJ 

,-, 

t'~J 

·<1 

...,., 

~ 

ffi 

Chief. Rules and Directives Branch 

Division of Administrative Services 

Mail Stop TWB-05-BOIM 

U.S. Nuclear Regulatory Commission 

Washington, D.C. 20555-0001 

/~~/Off 

13 ,FX 7r;tlt 

\1, 

::J 

'T\ 

8 

(J:J ':~~~~ ~ 

Feb. 3.2009 (jJ 

2: 

'9 ill 

C:J V\ 

V\ 

Dear Sirs: 

As Chief of the Pamunkey Indian Tribe of Virginia, I am writing this letter to ask that a pennit 

NOT be given to Dominion Power for construction of a new nuclear reactor at the North Anna 

site; OrJy recently have I received the draft report and have not had ample time to review it with 

the tribal council. In briefly looking over the report. we disagree with the findings that no 

significant historical or archaeological resources will be impacted. We the Pamunkey Indians 

have lived, fished and hunted on the shores of the Pamunkey River for thousands of years. The 

head waters of our river are the North and South Anna. Anything that effects those rivers has a 

direct impact on our lives and our culture. An in-depth TCP mitigation is warranted. and we are 

asking to be a consultsnt party in that mitigation. I am forwarding a copy of this letter to the 

Virginia Department of Historic Resources. Thank you. 

Sincerely, 

~/3-?~ .. ~ .. 

cc: ethel eaton ,,;' 

, ) 

~ 

~ U? 

,E-If.r'l> s ~ ;J;JH. -;lJ:8 ' 

~;: Jl'W-td~..r-h0 &~/LJ.£) 

HUNTING 

FISHING 

PCTTEI'lY 

MUSEUM 

ARTIF"ACTS 

KEVIN BROWN, CHIEF 

TELEPHDNE: SD4-B43-20S7 

PAMUNKEY INDIAN RESERVATION 

PAMUNKEY TRIBAL GOVERNMENT 

331 POCKET RD. 

KING WILLIAM, VIRGINIA 23096 

JJ 

,-, 

t'~J 

·<1 

...,., 

~ 

ffi 

Chief. Rules and Directives Branch 

Division of Administrative Services 

Mail Stop TWB-05-BOIM 

U.S. Nuclear Regulatory Commission 

Washington, D.C. 20555-0001 

/~~/Off 

13 ,FX 7r;tlt 

\1, 

::J 

'T\ 

8 

(J:J ':~~~~ ~ 

Feb. 3.2009 (jJ 

2: 

'9 ill 

C:J V\ 

V\ 

Dear Sirs: 

As Chief of the Pamunkey Indian Tribe of Virginia, I am writing this letter to ask that a pennit 

NOT be given to Dominion Power for construction of a new nuclear reactor at the North Anna 

site; OrJy recently have I received the draft report and have not had ample time to review it with 

the tribal council. In briefly looking over the report. we disagree with the findings that no 

significant historical or archaeological resources will be impacted. We the Pamunkey Indians 

have lived, fished and hunted on the shores of the Pamunkey River for thousands of years. The 

head waters of our river are the North and South Anna. Anything that effects those rivers has a 

direct impact on our lives and our culture. An in-depth TCP mitigation is warranted. and we are 

asking to be a consultsnt party in that mitigation. I am forwarding a copy of this letter to the 

Virginia Department of Historic Resources. Thank you. 

Sincerely, 

~/3-?~ .. ~ .. 

cc: ethel eaton ,,;' 

, ) 

~ 

~ U? 

,E-If.r'l> s ~ ;J;JH. -;lJ:8 ' 

~;: Jl'W-td~..r-h0 &~/LJ.£) 
Appendix F 

February 2010 F-23 NUREG-1917, SEIS 

DEPARTMENT OF THE ARMY 

NORFOLK DISTRICT CORPS OF ENGINEERS 

FORT NORFOLK 803 FRONT STREET 

NORFOLK VIRGINIA 23510-1096 

9 March 2009 

Northern Virginia Regulatory Section 

NAO 2008-02534 (Lake Anna) 

US Nuclear Regulatory Commission 

OWFN 11 F-J 

Attn: Ms. Alicia Williams 

Washington, DC 20555-000 I 

Dear Ms. Williams: 

This is in reference to your request for Corps' comments for the "Supplemental Environmental 

Impact Statement, Combined License (COL) at North Anna Power Station Unit 3" project in Caroline 

County. 

Based on the Supplemental EIS draft submitted by you, any fill proposed in waters of the 

United States regulated under Section 404 of the Clean Water Act (33 U.S.C. 1344) and may 

require Department of the Army authorization. We recommend you submit the following 

information so we my conduct a public interest review: 

I. A USGS topographic map depicting the location and boundaries of the project site for the 

proposed Units 3 and 4. 

2. The complete proposed plan of development with a depiction of all work that is 

subject to regulation under Section 404 of the Clean Water Act (i.e. intake and 

outfalls structures within jurisdictional waters andlor wetlands). 

3. A survey andlor report for the federally listed threatened species; swamp pink 

CHelonias bullata), small whorled pogonia (Isotria medeoloides), and sensitive joint 

vetch (Aeschvnomene virginica. 

4. Evidence that discharges of dredged or fill material into waters of the United 

States are avoided or minimized to the maximum extent practicable at the project 

site. 

5. A compensatory mitigation plan that addresses the loss of wetlands and streams 

impacts by the proposed project. 

In addition, our review of the Virginia Department of Historical Resources Data Sharing 

System (VDHR DSS) indicates that the proposed work may affect cultural resources. These 

resources may eligible for listing on the National Register of Historic Places (enclosed maps) and 

may be subject to compliance with Section 106 of the National Historic Preservation Act of 1966. 

According to 36 CFR 800.2(a) (2): 

..... /fmore than one Federal agency is involved in an undertaking. some or all {oflthe agencies 

may designate a lead Federal agency, which shall identify the appropriate official to serve as the 

agency official who shall act on their behalf, fulfilling their collective responsibilities under 

section 106. Those Federal agenCies that do not designate a lead Federal agency remain 

individually responsible for their compliance with this part . .. 

Pursuant to the above provision, the United States Nuclear Regulatory Commission (USNRC) is 

hereby designated as the lead federal agency to fulfill the collective Federal responsibilities under Section 

DEPARTMENT OF THE ARMY 

NORFOLK DISTRICT CORPS OF ENGINEERS 

FORT NORFOLK 803 FRONT STREET 

NORFOLK VIRGINIA 23510-1096 

9 March 2009 

Northern Virginia Regulatory Section 

NAO 2008-02534 (Lake Anna) 

US Nuclear Regulatory Commission 

OWFN 11 F-J 

Attn: Ms. Alicia Williams 

Washington, DC 20555-000 I 

Dear Ms. Williams: 

This is in reference to your request for Corps' comments for the "Supplemental Environmental 

Impact Statement, Combined License (COL) at North Anna Power Station Unit 3" project in Caroline 

County. 

Based on the Supplemental EIS draft submitted by you, any fill proposed in waters of the 

United States regulated under Section 404 of the Clean Water Act (33 U.S.C. 1344) and may 

require Department of the Army authorization. We recommend you submit the following 

information so we my conduct a public interest review: 

I. A USGS topographic map depicting the location and boundaries of the project site for the 

proposed Units 3 and 4. 

2. The complete proposed plan of development with a depiction of all work that is 

subject to regulation under Section 404 of the Clean Water Act (i.e. intake and 

outfalls structures within jurisdictional waters andlor wetlands). 

3. A survey andlor report for the federally listed threatened species; swamp pink 

CHelonias bullata), small whorled pogonia (Isotria medeoloides), and sensitive joint 

vetch (Aeschvnomene virginica. 

4. Evidence that discharges of dredged or fill material into waters of the United 

States are avoided or minimized to the maximum extent practicable at the project 

site. 

5. A compensatory mitigation plan that addresses the loss of wetlands and streams 

impacts by the proposed project. 

In addition, our review of the Virginia Department of Historical Resources Data Sharing 

System (VDHR DSS) indicates that the proposed work may affect cultural resources. These 

resources may eligible for listing on the National Register of Historic Places (enclosed maps) and 

may be subject to compliance with Section 106 of the National Historic Preservation Act of 1966. 

According to 36 CFR 800.2(a) (2): 

..... /fmore than one Federal agency is involved in an undertaking. some or all {oflthe agencies 

may designate a lead Federal agency, which shall identify the appropriate official to serve as the 

agency official who shall act on their behalf, fulfilling their collective responsibilities under 

section 106. Those Federal agenCies that do not designate a lead Federal agency remain 

individually responsible for their compliance with this part . .. 

Pursuant to the above provision, the United States Nuclear Regulatory Commission (USNRC) is 

hereby designated as the lead federal agency to fulfill the collective Federal responsibilities under Section 
Appendix F 

NUREG-1917, SEIS F-24 February 2010 

106 for the. North Anna Power Station Unit 3, if the USNRC determines an adverse effect on historic 

resources: 

The Corps authorizes the USNRC to conduct Section 106 coordination on its behalf. If a 

Memorandum of Agreement is required by USNRC, under 36 CFR 800.6, the following clause should be 

included in the introductory text: 

"WHEREAS, pursuant to Section 404 of the Clean Water Act, a Department of the Army permit 

will likely be requiredfrom the Corps of Engineers for this project, and the Corps has designated 

USNRC as the leadfederal agency tofolfillfederal responsibilities under Section 106; and 

Any work in these areas may require authorization by state and local agencies. Thank you 

for providing us the opportunity to provide early comment on the project. 

If you have any questions, please call 540-786-0080. For, and on behalf of, Deborah 

Massenburg, Acting Chief, and Northern Virginia Regulatory Section: 

Enclosure 

Sincerely, 

fl, i£ 

Regena Bronson 

Project Manager 

Northern Virginia Regulatory Section 

106 for the. North Anna Power Station Unit 3, if the USNRC determines an adverse effect on historic 

resources: 

The Corps authorizes the USNRC to conduct Section 106 coordination on its behalf. If a 

Memorandum of Agreement is required by USNRC, under 36 CFR 800.6, the following clause should be 

included in the introductory text: 

"WHEREAS, pursuant to Section 404 of the Clean Water Act, a Department of the Army permit 

will likely be requiredfrom the Corps of Engineers for this project, and the Corps has designated 

USNRC as the leadfederal agency tofolfillfederal responsibilities under Section 106; and 

Any work in these areas may require authorization by state and local agencies. Thank you 

for providing us the opportunity to provide early comment on the project. 

If you have any questions, please call 540-786-0080. For, and on behalf of, Deborah 

Massenburg, Acting Chief, and Northern Virginia Regulatory Section: 

Enclosure 

Sincerely, 

fl, i£ 

Regena Bronson 

Project Manager 

Northern Virginia Regulatory Section 
Appendix F 

February 2010 F-25 NUREG-1917, SEIS 

L. Preston Bryant. Jr. 

COMMONWEALTH o/VIRGINIA 

~;~~~}!~~!z;':'s7~~~~?!~~~~~~/i~;{liar;;J\/tO Mailing address: P.O: Box 1105. Richmond. Vi~ginji 23218 David K. Payl'" 

Secretary or Natural Resources TDD (804) 698-4021 Di=,or 

www.deq.virginia.gov 

March 18,2009 

Chief, Rules and Directives Branch 

Division of Administrative Services 

Mail Stop TWB-05-BOl M 

U.S. Nuclear Regulatory Commission 

Washington, D.C. 20555-001 

(804) 698·4020 

1-800·592·5482 

RE: Draft Supplemental Environmental Impact Statement for the Combined License 

(COL) for North Anna Power Station Unit 3, Louisa County, (DEQ 09-001 F). 

Dear Sir/Madam: 

The Commonwealth of Virginia has completed its review of the December 2008 Draft 

Supplemental Environmental Impact Statement (received January 5, 2009) for the 

above referenced project. The Department of Environmental Quality is responsible for 

coordinating Virginia's review of federal environmental documents and responding to 

appropriate federal officials on behalf of the Commonwealth. DEQ is also responsible 

for coordinating Virginia's review of federal consistency documents submitted pursuant 

to the Coastal Zone Management Act (CZMA) and providing the state's response. The 

following agencies participated in the review of this proposal: 

Department of Environmental Quality 

Department of Game and Inland Fisheries 

Department of Conservation and Recreation 

Department of Agriculture and Consumer Services 

Department of Mines, Minerals and Energy 

Department of Health 

Department of Forestry 

Department of Historic Resources 

Department of Transportation 

Thomas Jefferson Planning District Commission 

The Marine Resources Commission, Department of Emergency Management, 

Department of State Police, Virginia Institute of Marine Science, Louisa County, Orange 

County, Spotsylvania County, Hanover County, Town of Mineral, George Washington 

Regional Commission, and Rappahannock-Rapidan Planning District Commission were 

also invited to comment on the proposal. 

S(j/f./5I I!b'n~~~ 

~~'" /lJ H -I) 1'3 

L. Preston Bryant. Jr. 

COMMONWEALTH o/VIRGINIA 

~;~~~}!~~!z;':'s7~~~~?!~~~~~~/i~;{liar;;J\/tO Mailing address: P.O: Box 1105. Richmond. Vi~ginji 23218 David K. Payl'" 

Secretary or Natural Resources TDD (804) 698-4021 Di=,or 

www.deq.virginia.gov 

March 18,2009 

Chief, Rules and Directives Branch 

Division of Administrative Services 

Mail Stop TWB-05-BOl M 

U.S. Nuclear Regulatory Commission 

Washington, D.C. 20555-001 

(804) 698·4020 

1-800·592·5482 

RE: Draft Supplemental Environmental Impact Statement for the Combined License 

(COL) for North Anna Power Station Unit 3, Louisa County, (DEQ 09-001 F). 

Dear Sir/Madam: 

The Commonwealth of Virginia has completed its review of the December 2008 Draft 

Supplemental Environmental Impact Statement (received January 5, 2009) for the 

above referenced project. The Department of Environmental Quality is responsible for 

coordinating Virginia's review of federal environmental documents and responding to 

appropriate federal officials on behalf of the Commonwealth. DEQ is also responsible 

for coordinating Virginia's review of federal consistency documents submitted pursuant 

to the Coastal Zone Management Act (CZMA) and providing the state's response. The 

following agencies participated in the review of this proposal: 

Department of Environmental Quality 

Department of Game and Inland Fisheries 

Department of Conservation and Recreation 

Department of Agriculture and Consumer Services 

Department of Mines, Minerals and Energy 

Department of Health 

Department of Forestry 

Department of Historic Resources 

Department of Transportation 

Thomas Jefferson Planning District Commission 

The Marine Resources Commission, Department of Emergency Management, 

Department of State Police, Virginia Institute of Marine Science, Louisa County, Orange 

County, Spotsylvania County, Hanover County, Town of Mineral, George Washington 

Regional Commission, and Rappahannock-Rapidan Planning District Commission were 

also invited to comment on the proposal. 

S(j/f./5I I!b'n~~~ 

~~'" /lJ H -I) 1'3 
Appendix F 

NUREG-1917, SEIS F-26 February 2010 

Combined License (COL) for North Anna Power Station Unit 3 

PROJECT DESCRIPTION 

On November 27, 2007, the U.S. Nuclear Regulatory Commission (NRC) received an 

application from Dominion Virginia Power and Old Dominion Electric Cooperative, 

collectively known as Dominion, for a combined license (COL) for the North Anna 

Power Station (NAPS) site (Dominion 2007). The NAPS site is located approximately 

40 miles north-northwest of Richmond in louisa County, Virginia. A COL, which 

encompasses both a construction permit and an operating license, is a Commission 

approval to build and operate one or more nuclear power facilities. In its application, 

Dominion specified the Economic Simplified BOiling-Water Reactor (ESBWR) as the 

proposed design for the new reactor, designated Unit 3, to be constructed and operated 

at the NAPS site. 

The COL application references an early site permit (ESP) for the North Anna ESP site, 

which is located on the NAPS. In November 2007, NRC approved Issuance of the ESP 

for two additional nuclear units at the NAPS ESP site. This approval was supported by 

information documented in the ESP final Environmental Impact Statement (ESP EIS) 

(NRC 2006). The ESP permit, ESP-003, was issued to Dominion by the NRC on 

November 27,2007 (NRC 2007a). For a COL application that references an ESP, the 

NRC staff, pursuant to 10 CFR) 51.75(c), prepares a supplement to the ESP EIS in 

accordance with 10 CFR 51.92(e). The NRC relied upon the analysis in ESP E!S as 

the basis in preparation of the supplemental EIS (SEIS). 

Included in the SEIS are (1) the results of the NRC preliminary analyses, which 

consider and weigh the environmental effects of the proposed action and of 

constructing and operating a new nuclear unit at the NAPS site; (2) mitigation measures 

for reducing or avoiding adverse effects; (3) the environmental impacts of alternatives to 

the proposed action; and (4) the NRC's recommendation regarding the proposed action 

based on its environmental review. The COL application references an ESP, so where 

appropriate, the SEIS adopts results of the environmental review conducted in support 

of the ESP application and incorporates those results by reference. 

In the ESP ER (Dominion Nuclear North Anna, llC 2006a), Dominion Nuclear North 

Anna, llC stated that no alterations to the transmission system would be required. In 

its COL ER (Dominion 2007a), Dominion indicated that an additional 500-kV 

transmission line, within the existing ladysmith right-at-way would be required to ensure 

system reliability. The new transmission line is expected to be approximately 15 miles 

long; the existing right-of-way is approximately 275 feet wide, and will not need to be 

expanded to accommodate the new proposed transmission line. 

2 

Combined License (COL) for North Anna Power Station Unit 3 

PROJECT DESCRIPTION 

On November 27, 2007, the U.S. Nuclear Regulatory Commission (NRC) received an 

application from Dominion Virginia Power and Old Dominion Electric Cooperative, 

collectively known as Dominion, for a combined license (COL) for the North Anna 

Power Station (NAPS) site (Dominion 2007). The NAPS site is located approximately 

40 miles north-northwest of Richmond in louisa County, Virginia. A COL, which 

encompasses both a construction permit and an operating license, is a Commission 

approval to build and operate one or more nuclear power facilities. In its application, 

Dominion specified the Economic Simplified BOiling-Water Reactor (ESBWR) as the 

proposed design for the new reactor, designated Unit 3, to be constructed and operated 

at the NAPS site. 

The COL application references an early site permit (ESP) for the North Anna ESP site, 

which is located on the NAPS. In November 2007, NRC approved Issuance of the ESP 

for two additional nuclear units at the NAPS ESP site. This approval was supported by 

information documented in the ESP final Environmental Impact Statement (ESP EIS) 

(NRC 2006). The ESP permit, ESP-003, was issued to Dominion by the NRC on 

November 27,2007 (NRC 2007a). For a COL application that references an ESP, the 

NRC staff, pursuant to 10 CFR) 51.75(c), prepares a supplement to the ESP EIS in 

accordance with 10 CFR 51.92(e). The NRC relied upon the analysis in ESP E!S as 

the basis in preparation of the supplemental EIS (SEIS). 

Included in the SEIS are (1) the results of the NRC preliminary analyses, which 

consider and weigh the environmental effects of the proposed action and of 

constructing and operating a new nuclear unit at the NAPS site; (2) mitigation measures 

for reducing or avoiding adverse effects; (3) the environmental impacts of alternatives to 

the proposed action; and (4) the NRC's recommendation regarding the proposed action 

based on its environmental review. The COL application references an ESP, so where 

appropriate, the SEIS adopts results of the environmental review conducted in support 

of the ESP application and incorporates those results by reference. 

In the ESP ER (Dominion Nuclear North Anna, llC 2006a), Dominion Nuclear North 

Anna, llC stated that no alterations to the transmission system would be required. In 

its COL ER (Dominion 2007a), Dominion indicated that an additional 500-kV 

transmission line, within the existing ladysmith right-at-way would be required to ensure 

system reliability. The new transmission line is expected to be approximately 15 miles 

long; the existing right-of-way is approximately 275 feet wide, and will not need to be 

expanded to accommodate the new proposed transmission line. 

2 
Appendix F 

February 2010 F-27 NUREG-1917, SEIS 

Combined license (COL) for North Anna Power Station Unit 3 

CONCLUSION 

Reviewers indicated that the draft SEIS did not address the Instream Flow Incremental 

Methodology study conduced by Dominion in cooperation with state natural resource 

agencies, including a discussion of the proposed operating rules developed from the 

study, particularly with respect to the effect of the potential three inch rise in normal lake 

storage. Other omissions that should be adequately addressed in the final SEIS 

include a discussion of the small whorled pogonia as it occurs on upland sites, a 

discussion of the expected traffic distribution (for construction-related traffic and for 

operations) and the effects upon the state highways and intersections, and the 

discussion of an updated evacuation plan that addresses the area of impact in the 

event of an emergency. 

ENVIRONMENTAL IMPACTS AND MITIGATION 

1. Water Quality & Wetlands. According to the SEIS (page 4-4, 4.3.1), excavation, fill, 

and grading operations that will occur during construction of the proposed Unit 3 would 

alter two of three ephemeral streams on the NAPS site, and possibly one or more 

Wetlands. Wetland delineations and jurisdictional determinations of the upland 

landscape and submerged lake areas that would be impacted by construction would be 

required in order to submit an application for a Section 404 Permit application to the 

U.S. Army Corps of Engineers (Corps). 

The SEIS (page 5-5, 5.3.3) states that new information available since preparation of 

the ESP EIS includes additional information on the ambient water quality in Lake Anna, 

a description of plant water treatment methods and chemical additives, blowdown 

flowrates, and expected chemical concentrations in the plant discharge. According to 

the document (page 5-5, 5.3.3), the discharge water-quality parameters for the 

proposed Unit 3 is within (equal to or less than) the range of plant parameter envelope 

(PPE) values evaluated for the ESP. The NRC concludes that the impacts of operating 

the proposed Unit 3 on water quality would remain small. Pollutant discharges would 

be regulated under a VIrginia Pollutant Discharge Elimination System permit issued by 

the Commonwealth of Virginia. 

1 (a) Agency Jurisdiction. The State Water Control Board (SWCB) promulgates 

Virginia's water regulations, covering a variety of permits to include Virginia Pollutant 

Discharge Elimination System (VPDES) permit, Virginia Pollution Abatement Permit, 

Surface and Groundwater Withdrawal Permit, and the Virginia Water Protection Permit 

(VWPP). The VWPP is a state permit which governs wetlands, surface water, and 

surface water withdrawalslimpoundments. It also serves as § 401 certification of the 

. federal Clean Water Act § 404 permits for dredge and fill activities in waters of the U.S. 

The VWPP Program is under the Office of Wetlands and Water Protection/Compliance, 

within the DEQ Division of Water Quality Programs. In addition to central office staff 

that review and issue VWP permits for transportation and water withdrawal projects, the 

3 

Combined license (COL) for North Anna Power Station Unit 3 

CONCLUSION 

Reviewers indicated that the draft SEIS did not address the Instream Flow Incremental 

Methodology study conduced by Dominion in cooperation with state natural resource 

agencies, including a discussion of the proposed operating rules developed from the 

study, particularly with respect to the effect of the potential three inch rise in normal lake 

storage. Other omissions that should be adequately addressed in the final SEIS 

include a discussion of the small whorled pogonia as it occurs on upland sites, a 

discussion of the expected traffic distribution (for construction-related traffic and for 

operations) and the effects upon the state highways and intersections, and the 

discussion of an updated evacuation plan that addresses the area of impact in the 

event of an emergency. 

ENVIRONMENTAL IMPACTS AND MITIGATION 

1. Water Quality & Wetlands. According to the SEIS (page 4-4, 4.3.1), excavation, fill, 

and grading operations that will occur during construction of the proposed Unit 3 would 

alter two of three ephemeral streams on the NAPS site, and possibly one or more 

Wetlands. Wetland delineations and jurisdictional determinations of the upland 

landscape and submerged lake areas that would be impacted by construction would be 

required in order to submit an application for a Section 404 Permit application to the 

U.S. Army Corps of Engineers (Corps). 

The SEIS (page 5-5, 5.3.3) states that new information available since preparation of 

the ESP EIS includes additional information on the ambient water quality in Lake Anna, 

a description of plant water treatment methods and chemical additives, blowdown 

flowrates, and expected chemical concentrations in the plant discharge. According to 

the document (page 5-5, 5.3.3), the discharge water-quality parameters for the 

proposed Unit 3 is within (equal to or less than) the range of plant parameter envelope 

(PPE) values evaluated for the ESP. The NRC concludes that the impacts of operating 

the proposed Unit 3 on water quality would remain small. Pollutant discharges would 

be regulated under a VIrginia Pollutant Discharge Elimination System permit issued by 

the Commonwealth of Virginia. 

1 (a) Agency Jurisdiction. The State Water Control Board (SWCB) promulgates 

Virginia's water regulations, covering a variety of permits to include Virginia Pollutant 

Discharge Elimination System (VPDES) permit, Virginia Pollution Abatement Permit, 

Surface and Groundwater Withdrawal Permit, and the Virginia Water Protection Permit 

(VWPP). The VWPP is a state permit which governs wetlands, surface water, and 

surface water withdrawalslimpoundments. It also serves as § 401 certification of the 

. federal Clean Water Act § 404 permits for dredge and fill activities in waters of the U.S. 

The VWPP Program is under the Office of Wetlands and Water Protection/Compliance, 

within the DEQ Division of Water Quality Programs. In addition to central office staff 

that review and issue VWP permits for transportation and water withdrawal projects, the 

3 
Appendix F 

NUREG-1917, SEIS F-28 February 2010 

Combined License (COL) for North Anna Power Station Unit 3 

seven DEQ regional offices perform permit application reviews and issue permits for the 

covered activities. . 

1{b) Agency Comments. 

Virginia Water Protection Permit 

The SEIS recognizes the need for permitting of potential impacts to wetlands resulting 

from the construction and/or operation of Unit 3. According to the DEQ Office of 

Wetlands and Water Protection (OWWP), the report states that Dominion Virginia 

Power has conducted a wetland delineation to determine the location, extent, and type 

of surface waters present, and that approximately 6.68 acres of wetland, 5,500 linear 

feet of stream and 2.49 acres of open water have been identified within the proposed 

construction footprint. The report also states that permanent disturbance may be 

limited to less than 0.5 acre of non-tidal wetland and less than 800 linear feet of stream 

within the site footprint. State- and federal-listed threatened and endangered species 

were identified as potentially occurring on the site. 

Virginia Pollutant Discharge Elimination System 

According to the DEQ Northern Regional Office (NRO), the SEIS discusses many 

issues that will be addressed as part of the modification of Dominion's existing VPDES 

permit. The final VPDES permit determination will be dependent on the Dominion's 

application. 

1{c) Agency Findings. 

Virginia Water Protection Permit 

Based on a review of the location map provided with the SEIS, DEQ is unable to 

determine the exact quantity of wetland and stream impacts. However, because 

impacts are proposed to wetlands and streams, this project will likely require a Virginia 

Water Protection Permit. DEQ-NRO agrees with the technical and regulatory 

discussion in the SEIS and finds no reason to suggest a VWPP could not be obtained. 

The DEQ-NRO VWPP program will make the final permit decision regarding potential 

impacts to state waters. . 

Virginia Pollutant Discharge Elimination System 

DEQ agrees with the technical discussions in the SEIS and has no technical or 

regulatory reasons to suggest that a modification could not proceed. 

4 

Combined License (COL) for North Anna Power Station Unit 3 

seven DEQ regional offices perform permit application reviews and issue permits for the 

covered activities. . 

1{b) Agency Comments. 

Virginia Water Protection Permit 

The SEIS recognizes the need for permitting of potential impacts to wetlands resulting 

from the construction and/or operation of Unit 3. According to the DEQ Office of 

Wetlands and Water Protection (OWWP), the report states that Dominion Virginia 

Power has conducted a wetland delineation to determine the location, extent, and type 

of surface waters present, and that approximately 6.68 acres of wetland, 5,500 linear 

feet of stream and 2.49 acres of open water have been identified within the proposed 

construction footprint. The report also states that permanent disturbance may be 

limited to less than 0.5 acre of non-tidal wetland and less than 800 linear feet of stream 

within the site footprint. State- and federal-listed threatened and endangered species 

were identified as potentially occurring on the site. 

Virginia Pollutant Discharge Elimination System 

According to the DEQ Northern Regional Office (NRO), the SEIS discusses many 

issues that will be addressed as part of the modification of Dominion's existing VPDES 

permit. The final VPDES permit determination will be dependent on the Dominion's 

application. 

1{c) Agency Findings. 

Virginia Water Protection Permit 

Based on a review of the location map provided with the SEIS, DEQ is unable to 

determine the exact quantity of wetland and stream impacts. However, because 

impacts are proposed to wetlands and streams, this project will likely require a Virginia 

Water Protection Permit. DEQ-NRO agrees with the technical and regulatory 

discussion in the SEIS and finds no reason to suggest a VWPP could not be obtained. 

The DEQ-NRO VWPP program will make the final permit decision regarding potential 

impacts to state waters. . 

Virginia Pollutant Discharge Elimination System 

DEQ agrees with the technical discussions in the SEIS and has no technical or 

regulatory reasons to suggest that a modification could not proceed. 

4 
Appendix F 

February 2010 F-29 NUREG-1917, SEIS 

Combined License (COL) for North Anna Power Station Unit 3 

1(d) Requirements. 

Virginia Water Protection Permit 

The wetland delineation should be confirmed by the U.S. Army Corps of Engineers 

(Corps). In addition to contacting the Corps for the wetland confirmation, Dominiori 

must contact the DEQ Virginia Water Protection Permit program to determine the 

necessity of the VWPP(s). Coordination of this project should be conducted with the 

Virginia Marine Resources CommisSion, the Corps and DEQ through the Joint Permit 

Application (JPA) process. The JPA must include documentation of all avoidance and 

minimization efforts and a conceptual plan for appropriate compensatory mitigation. 

Avoidance and minimization of wetland and stream impacts should occur to the 

maximum extent practicable. 

Virginia Pollutant Discharge Elimination System 

Dominion must request a permit modification from DEQ-NRO before it can proceed with 

construction of Unit 3, as acknowledged in the SEIS. 

1 (e) Recommendations. DEQ-OWWP offers the following recommendations with 

respect to antiCipated water quality and wetlands impacts: 

• Coordinate closely with DEQ regarding mitigation options as they are 

considered and developed. 

• Examine onsite mitigation options to compensate for unavoidable permanent 

wetland impacts and conversions or purchase of credits at a mitigation bank 

within the watershed of the proposed impacts. 

• Consider mitigating impacts to forested or converted wetlands by establishing 

new forested wetJandswithin the impacted watershed. 

• Restore temporary impact areas to their original contours and_revegetate with 

the same or similar species. 

• Coordinate with the Virginia Department of Game and Inland Fisheries and/or 

the U.S. Fish and Wildlife Service regarding presence of endangered or 

threatened species andlor habitat, prior to seeking a permit from the Virginia 

Water Protection Permit Program. 

• Coordinate with DEQ-NRO regarding the Virginia Pollutant Discharge 

Elimination System permit that will be required for the proposed discharges to 

Lake Anna. 

In general, DEQ recommends that stream and wetland impacts be avoided to the 

maximum extent practicable. To minimize unavoidable impacts to wetlands and 

waterways, DEQ recommends the following practices: 

5 

Combined License (COL) for North Anna Power Station Unit 3 

1(d) Requirements. 

Virginia Water Protection Permit 

The wetland delineation should be confirmed by the U.S. Army Corps of Engineers 

(Corps). In addition to contacting the Corps for the wetland confirmation, Dominiori 

must contact the DEQ Virginia Water Protection Permit program to determine the 

necessity of the VWPP(s). Coordination of this project should be conducted with the 

Virginia Marine Resources CommisSion, the Corps and DEQ through the Joint Permit 

Application (JPA) process. The JPA must include documentation of all avoidance and 

minimization efforts and a conceptual plan for appropriate compensatory mitigation. 

Avoidance and minimization of wetland and stream impacts should occur to the 

maximum extent practicable. 

Virginia Pollutant Discharge Elimination System 

Dominion must request a permit modification from DEQ-NRO before it can proceed with 

construction of Unit 3, as acknowledged in the SEIS. 

1 (e) Recommendations. DEQ-OWWP offers the following recommendations with 

respect to antiCipated water quality and wetlands impacts: 

• Coordinate closely with DEQ regarding mitigation options as they are 

considered and developed. 

• Examine onsite mitigation options to compensate for unavoidable permanent 

wetland impacts and conversions or purchase of credits at a mitigation bank 

within the watershed of the proposed impacts. 

• Consider mitigating impacts to forested or converted wetlands by establishing 

new forested wetJandswithin the impacted watershed. 

• Restore temporary impact areas to their original contours and_revegetate with 

the same or similar species. 

• Coordinate with the Virginia Department of Game and Inland Fisheries and/or 

the U.S. Fish and Wildlife Service regarding presence of endangered or 

threatened species andlor habitat, prior to seeking a permit from the Virginia 

Water Protection Permit Program. 

• Coordinate with DEQ-NRO regarding the Virginia Pollutant Discharge 

Elimination System permit that will be required for the proposed discharges to 

Lake Anna. 

In general, DEQ recommends that stream and wetland impacts be avoided to the 

maximum extent practicable. To minimize unavoidable impacts to wetlands and 

waterways, DEQ recommends the following practices: 

5 
Appendix F 

NUREG-1917, SEIS F-30 February 2010 

Combined License (COL) for North Anna Power Station linn 3 

• Operate machinery and construction vehicles outside of stream-beds and 

wetlands; use synthetic mats when in-stream work is unavoidable. 

• Preserve the top 12 inches of trench material removed from wetlands for use as 

wetland seed and root-stock in the excavated area. 

• Erosion and sedimentation controls should be designed in accordance with the 

most current edition of the Virginia Erosion and Sediment Control Handbook. 

These controls should be in place prior to clearing and grading, and maintained 

in good working order to minimize impacts to state waters. The controls should 

remain in place until the area is stabilized. 

• Place heavy equipment, located in temporarily impacted wetland areas, on mats, 

geotextile fabric, or use other suitable measures to minimize soil disturbance, to 

the maximum extent practicable. 

• Restore all temporarily disturbed wetland areas to pre-construction conditions 

and plant or seed with appropriate wetlands vegetation in accordance with the 

cover type (emergent, scrub-shrub, or forested). The applicant should take all 

appropriate measures to promote revegetation of these areas. Stabilization and 

restoration efforts should occur immediately after the temporary disturbance of 

each wetland area instead of waiting until the entire project has been completed. 

• place all materials which are temporarily stockpiled in wetlands, deSignated for 

use ·for the immediate stabilization of wetlands, on mats, geotextile fabric in order 

to prevent entry in State waters. These materials should be managed in a 

manner that prevents leachates from entering state waters and must be entirely 

removed within thirty days following completion of that construction activity. The 

disturbed areas should be retumed to their original contours, stabilized within 

thirty days following removal of the stockpile, and restored to the original 

vegetated state. 

• All non-impacted surface waters within the project or right-of-way limits that are 

within 50 feet of any clearing, grading, or filling activities should be clearly 

flagged or marked for the life of the construction activity within that area. The 

project proponent should notify all contractors that these marked areas are 

surface waters where no activities are to occur. 

• Measures should be employed to prevent spills of fuels or lubricants into state 

waters. 

2. Subaqueous Lands. The SEIS does not include a discussion of potential project 

impacts on state subaqueous lands. 

2(a) Agency Jurisdiction. The Virginia Marine Resources Commission (VMRC), 

pursuant to Section 28.2-1200 et seq. of the Code of Virginia, has jurisdiction over any 

encroachments in, on, or over any state-owned rivers, streams, or creeks in the 

Commonwealth. 

6 

Combined License (COL) for North Anna Power Station linn 3 

• Operate machinery and construction vehicles outside of stream-beds and 

wetlands; use synthetic mats when in-stream work is unavoidable. 

• Preserve the top 12 inches of trench material removed from wetlands for use as 

wetland seed and root-stock in the excavated area. 

• Erosion and sedimentation controls should be designed in accordance with the 

most current edition of the Virginia Erosion and Sediment Control Handbook. 

These controls should be in place prior to clearing and grading, and maintained 

in good working order to minimize impacts to state waters. The controls should 

remain in place until the area is stabilized. 

• Place heavy equipment, located in temporarily impacted wetland areas, on mats, 

geotextile fabric, or use other suitable measures to minimize soil disturbance, to 

the maximum extent practicable. 

• Restore all temporarily disturbed wetland areas to pre-construction conditions 

and plant or seed with appropriate wetlands vegetation in accordance with the 

cover type (emergent, scrub-shrub, or forested). The applicant should take all 

appropriate measures to promote revegetation of these areas. Stabilization and 

restoration efforts should occur immediately after the temporary disturbance of 

each wetland area instead of waiting until the entire project has been completed. 

• place all materials which are temporarily stockpiled in wetlands, deSignated for 

use ·for the immediate stabilization of wetlands, on mats, geotextile fabric in order 

to prevent entry in State waters. These materials should be managed in a 

manner that prevents leachates from entering state waters and must be entirely 

removed within thirty days following completion of that construction activity. The 

disturbed areas should be retumed to their original contours, stabilized within 

thirty days following removal of the stockpile, and restored to the original 

vegetated state. 

• All non-impacted surface waters within the project or right-of-way limits that are 

within 50 feet of any clearing, grading, or filling activities should be clearly 

flagged or marked for the life of the construction activity within that area. The 

project proponent should notify all contractors that these marked areas are 

surface waters where no activities are to occur. 

• Measures should be employed to prevent spills of fuels or lubricants into state 

waters. 

2. Subaqueous Lands. The SEIS does not include a discussion of potential project 

impacts on state subaqueous lands. 

2(a) Agency Jurisdiction. The Virginia Marine Resources Commission (VMRC), 

pursuant to Section 28.2-1200 et seq. of the Code of Virginia, has jurisdiction over any 

encroachments in, on, or over any state-owned rivers, streams, or creeks in the 

Commonwealth. 

6 
Appendix F 

February 2010 F-31 NUREG-1917, SEIS 

Combined License (COL) for North Anna Power Station Unit 3 

2(b) Agency Comments. VMRC did not respond to our request for comments on the 

SEIS. However, in previous responses to the ESP EIS (DEQ #06·125F) and federal 

consistency certification (DEQ #05·079F) VMRC asserted that the agency's permit 

jurisdiction would extend to the portions of the project which result In direct impacts and 

encroachment to the historic stream channel of the North Anna River (Ellis/Madden, 

8/31/06). 

Questions on this jurisdiction may be directed to the Commission (Jeff Madden or Ben 

McGinnis, telephone (757) 247-2200). 

3. Water Resources Management. The SEIS (page 2-23,2.7.2.1) notes that 

Dominion has agreed to conduct an Instream Flow Incremental Methodology (IFIM) 

study of the North Anna River below the dam. This study is required by the 

COinmonwealth of Virginia to enable preparation of the Coastal Zone Management Act 

consistency determination that is required prior to the issuance of a COL. Study 

design, analysis, and interpretation were done in cooperation and consultation with the 

Virginia Department of Game and Inland Fisheries (DGIF) and DEQ. According to the 

document, the primary objective of the North Anna IFIM study is to determine whether 

any changes (generally reductions) in dam releases as a result of the proposed Unit 3 

operation could have an impact on aquatic resources below the dam. The NRC will 

review the final results of the completed IFIM and incorporate them into the final SEIS, 

as appropriate. 

3(a) Agency Comments on IFIM Study. 

(i) DGIF. Upon review of the Early Site Permit and associated federal 

consistency certification for the proposed addition of a third reactor at North 

Anna Power Station, DGIF expressed concerns about the operation of the 

third reactor and the reservoir as they relate to maintenance of downstream 

flows in the North Anna and Pam un key rivers. To address agency 

concerns, DGIF and other state resource agencies recommended that 

Dominion perform an Instream Flow Incremental Methodology study in the 

North Anna River below the Lake Anna dam and in downstream waters of 

the Pamunkey River. DGIF worked closely with Dominion and the 

permitting agencies on the design of the study and the analysis of the 

results. As stated in the SEIS, the primary goal of the IFIM is to determine 

whether possible changes in dam releases resulting from the operation of 

the third reactor are likely to adversely impact aquatic resources below the 

dam. 

The IFIM is complete and DGIF is currently working with Dominion, the 

permitting agencies, and other natural resource agencies to finalize the 

results and develop operating rules for the proposed third reactor (including 

reservoir management procedures) that reduce the frequency of dam 

7 

Combined License (COL) for North Anna Power Station Unit 3 

2(b) Agency Comments. VMRC did not respond to our request for comments on the 

SEIS. However, in previous responses to the ESP EIS (DEQ #06·125F) and federal 

consistency certification (DEQ #05·079F) VMRC asserted that the agency's permit 

jurisdiction would extend to the portions of the project which result In direct impacts and 

encroachment to the historic stream channel of the North Anna River (Ellis/Madden, 

8/31/06). 

Questions on this jurisdiction may be directed to the Commission (Jeff Madden or Ben 

McGinnis, telephone (757) 247-2200). 

3. Water Resources Management. The SEIS (page 2-23,2.7.2.1) notes that 

Dominion has agreed to conduct an Instream Flow Incremental Methodology (IFIM) 

study of the North Anna River below the dam. This study is required by the 

COinmonwealth of Virginia to enable preparation of the Coastal Zone Management Act 

consistency determination that is required prior to the issuance of a COL. Study 

design, analysis, and interpretation were done in cooperation and consultation with the 

Virginia Department of Game and Inland Fisheries (DGIF) and DEQ. According to the 

document, the primary objective of the North Anna IFIM study is to determine whether 

any changes (generally reductions) in dam releases as a result of the proposed Unit 3 

operation could have an impact on aquatic resources below the dam. The NRC will 

review the final results of the completed IFIM and incorporate them into the final SEIS, 

as appropriate. 

3(a) Agency Comments on IFIM Study. 

(i) DGIF. Upon review of the Early Site Permit and associated federal 

consistency certification for the proposed addition of a third reactor at North 

Anna Power Station, DGIF expressed concerns about the operation of the 

third reactor and the reservoir as they relate to maintenance of downstream 

flows in the North Anna and Pam un key rivers. To address agency 

concerns, DGIF and other state resource agencies recommended that 

Dominion perform an Instream Flow Incremental Methodology study in the 

North Anna River below the Lake Anna dam and in downstream waters of 

the Pamunkey River. DGIF worked closely with Dominion and the 

permitting agencies on the design of the study and the analysis of the 

results. As stated in the SEIS, the primary goal of the IFIM is to determine 

whether possible changes in dam releases resulting from the operation of 

the third reactor are likely to adversely impact aquatic resources below the 

dam. 

The IFIM is complete and DGIF is currently working with Dominion, the 

permitting agencies, and other natural resource agencies to finalize the 

results and develop operating rules for the proposed third reactor (including 

reservoir management procedures) that reduce the frequency of dam 

7 
Appendix F 

NUREG-1917, SEIS F-32 February 2010 

Combined License (COL) for North Anna .power Station Un~ 3 

releases below 40 cubic feet per second (cfs), thereby protecting 

downstream aquatic resources. 

'(ii) DEQ. According to the DEQ Office of Surface and Ground Water Supply 

Planning (OSGSP), DEQ, DGIF, DCR and Dominion have been working on 

the IFIM study that was required as result of the state's conditional Coastal 

Zone Management Act (CZMA) certification for the Early Site Permit. Based 

on the study, Dominion proposed a set of rules for operating the reservoir ' 

and the cooling system of Unit 3 that would mitigate the impact of the new 

unit on water resources. In summary, the proposal involves: 

• raising the normal level of the lake by three inches; , 

• releasing a minimum flow of 40 cubic feet per second (cfs) whenever the 

lake is above 248 feet; 

• releasing a minimum flow of 20 cfs whenever the. lake is less than 248 

feet; 

.' operating in maximum water conservation mode whenever the lake is 

below 250 feet; and 

• making a targeted recreation release of 177 cfs in June and July if the 

lake is above 250 feet. 

ReCieatloii 

The recreation release would begin on Friday afternoon or evening and last 

for about 18 hours. This pulse of water is designed to be present in the most 

popular recreational boating reach during the daylight hours on Saturday. 

These mitigation measures were designed to protect lake levels, protect 

aquatic life and enhance river recreation if water storage was in good 

condition. An additional benefit of the pulse is that it would temporarily 

improve fish habitat and restore some of the natural variability to river's 

summer hydrologic regime. 

Wetlands 

Dominion also studied the impact of the three-inch rise in normal lake levels 

on docks and on fringe wetlands around the lake. Preliminary indications are 

the three-inch iise wili have smaii impacts on docks and wetlands. 

Fisheries 

The North Anna River is a highly altered system with the minimum release cif 

40 cfs becoming the typical flow for most of the summer and fall. The historic 

minimum flow of 40 cfs and the lack of turbidity in the release produced a 

8 

Combined License (COL) for North Anna .power Station Un~ 3 

releases below 40 cubic feet per second (cfs), thereby protecting 

downstream aquatic resources. 

'(ii) DEQ. According to the DEQ Office of Surface and Ground Water Supply 

Planning (OSGSP), DEQ, DGIF, DCR and Dominion have been working on 

the IFIM study that was required as result of the state's conditional Coastal 

Zone Management Act (CZMA) certification for the Early Site Permit. Based 

on the study, Dominion proposed a set of rules for operating the reservoir ' 

and the cooling system of Unit 3 that would mitigate the impact of the new 

unit on water resources. In summary, the proposal involves: 

• raising the normal level of the lake by three inches; , 

• releasing a minimum flow of 40 cubic feet per second (cfs) whenever the 

lake is above 248 feet; 

• releasing a minimum flow of 20 cfs whenever the. lake is less than 248 

feet; 

.' operating in maximum water conservation mode whenever the lake is 

below 250 feet; and 

• making a targeted recreation release of 177 cfs in June and July if the 

lake is above 250 feet. 

ReCieatloii 

The recreation release would begin on Friday afternoon or evening and last 

for about 18 hours. This pulse of water is designed to be present in the most 

popular recreational boating reach during the daylight hours on Saturday. 

These mitigation measures were designed to protect lake levels, protect 

aquatic life and enhance river recreation if water storage was in good 

condition. An additional benefit of the pulse is that it would temporarily 

improve fish habitat and restore some of the natural variability to river's 

summer hydrologic regime. 

Wetlands 

Dominion also studied the impact of the three-inch rise in normal lake levels 

on docks and on fringe wetlands around the lake. Preliminary indications are 

the three-inch iise wili have smaii impacts on docks and wetlands. 

Fisheries 

The North Anna River is a highly altered system with the minimum release cif 

40 cfs becoming the typical flow for most of the summer and fall. The historic 

minimum flow of 40 cfs and the lack of turbidity in the release produced a 

8 
Appendix F 

February 2010 F-33 NUREG-1917, SEIS 

Combined License (COL) for North Anna Power Station Unit 3 

fairly good sports fishery in the river below the dam. The weighted useable 

area graphs produced by the instream flow study were very important in 

forming preliminary recommendations for operating the project. These 

curves show sharply falling habitat as flow declines below 100 cfs for several 

important species. The state agencies do not support an increased 

frequency or duration of flows below 40 cfs, if avoidable, because of the 

precipitous decline in habitat that occurs as flow falls below these !avals. 

With the three inch rise, and the early activation of dry cooling, the additional 

occurrences of releases of below 40 cfs will be limited. Dominion presented 

information to the agencies on December 15, 2008 that estimated that the 

amount of time that flows would be less than 40 cfs would be 5.5% of the 

time, an increase from 5.2% of the time with the present two units. OSGSP 

believes that this is a small change. 

Dominion's preliminary proposal for minimum releases is nearly identical with 

the proposal analyzed by NRC in the ESP EIS (i.e. 40 or 20 CFS depending 

on whether the lake was above or below 248 feet). The NRC concludes, in 

the SEIS and in the previous EIS for the ESP, that Unit 3 would have small or 

moderate impacts on lake levels and downstream flows. 

3(b) Findings. The draft SEIS does not factor in the effect of a potential three inch iise 

in normal lake storage. This mitigating measure will further reduce the impacts of Unit 3 

on lake levels and downstream flow. . 

3(c) Recommendations. DEQ-OSGSP offers the following recommendations: 

• Dominion should continue to coordinate with DEQ regarding the evaluation of 

potential impact the three-inch rise may have on wetlands. 

• Should the size or scope of the project change, additional review by DEQ 

may be necessary. 

• Dominion should strictly adhere to erosion and sediment controls and 

stormwater management practices, and monitor construction activities to 

ensure that erosion and stormwater management practices are adequately 

preventing sediment and pollutant migration into surface waters, including 

wetlands. . 

The DEQ Northern Regional Office will make the final permit decision regarding 

potential impacts to state waters. 

3(d) Conclusion. DGIF will continue to work with Dominion, the permitting agencies, 

and other natural resource agencies to develop operating rules that avoid adverse 

impacts upon downstream resources, including recreational uses, or to mitigate 

unavoidable impacts. Possible impacts upon protected species and the waters that 

9 

Combined License (COL) for North Anna Power Station Unit 3 

fairly good sports fishery in the river below the dam. The weighted useable 

area graphs produced by the instream flow study were very important in 

forming preliminary recommendations for operating the project. These 

curves show sharply falling habitat as flow declines below 100 cfs for several 

important species. The state agencies do not support an increased 

frequency or duration of flows below 40 cfs, if avoidable, because of the 

precipitous decline in habitat that occurs as flow falls below these !avals. 

With the three inch rise, and the early activation of dry cooling, the additional 

occurrences of releases of below 40 cfs will be limited. Dominion presented 

information to the agencies on December 15, 2008 that estimated that the 

amount of time that flows would be less than 40 cfs would be 5.5% of the 

time, an increase from 5.2% of the time with the present two units. OSGSP 

believes that this is a small change. 

Dominion's preliminary proposal for minimum releases is nearly identical with 

the proposal analyzed by NRC in the ESP EIS (i.e. 40 or 20 CFS depending 

on whether the lake was above or below 248 feet). The NRC concludes, in 

the SEIS and in the previous EIS for the ESP, that Unit 3 would have small or 

moderate impacts on lake levels and downstream flows. 

3(b) Findings. The draft SEIS does not factor in the effect of a potential three inch iise 

in normal lake storage. This mitigating measure will further reduce the impacts of Unit 3 

on lake levels and downstream flow. . 

3(c) Recommendations. DEQ-OSGSP offers the following recommendations: 

• Dominion should continue to coordinate with DEQ regarding the evaluation of 

potential impact the three-inch rise may have on wetlands. 

• Should the size or scope of the project change, additional review by DEQ 

may be necessary. 

• Dominion should strictly adhere to erosion and sediment controls and 

stormwater management practices, and monitor construction activities to 

ensure that erosion and stormwater management practices are adequately 

preventing sediment and pollutant migration into surface waters, including 

wetlands. . 

The DEQ Northern Regional Office will make the final permit decision regarding 

potential impacts to state waters. 

3(d) Conclusion. DGIF will continue to work with Dominion, the permitting agencies, 

and other natural resource agencies to develop operating rules that avoid adverse 

impacts upon downstream resources, including recreational uses, or to mitigate 

unavoidable impacts. Possible impacts upon protected species and the waters that 

9 
Appendix F 

NUREG-1917, SEIS F-34 February 2010 

Combined license (COL) for North Anna Power Station Unit 3 

support them will be considered in DGIF's final comments and recommendations 

resulting from review of the IFIM results. 

4. Wildlife Resources and Protected Species. According to the SEIS (page 4-10, 

section 4.4.3) the information and associated impacts for wildlife resources and 

protected species are provided and resolved in Section 4.4.3 of the ESP EIS (NRC 

2006). Based on the staff's analysis, construction, operation and cumulative impacts to 

threatened or endangered species were considered small. 

3(a) Agency Jurisdiction. The Department of Game and Inland Fisheries (DGlF), as 

the Commonwealth's wildlife and freshwater fish management agency, exercises 

enforcement and regulatory jurisdiction over wildlife and freshwater fish, Including state 

or federally listed endangered or threatened species, but excluding listed insects 

(Virginia Code Title 29.1). The DGIF is a consulting agency under the U.S. Fish and 

Wildlife Coordination Act (16 U.S.C. sections 661 et seq.), and provides environmental 

analysis of projects or permit applications coordinated through DEC and several other 

state and federal agencies. DGIF determines likely impacts upon fish and wildlife 

resources and habitat, and recommends appropriate measures to avoid, reduce, or 

compensate for those impacts. 

4(b) Agency Comments. 

Federsl- snd Stste-listed Species 

According to DGIF data and those from the Department of Conservation and 

Recreation (OCR), downstream waters have been known to support: 

• dwarf wedgemussel (federally-listed endangered); 

• James spinymussel (federally-listed endangered); 

• Atlantic pigtoe (state-listed endangered); and 

• green floater (state-listed threatened). 

Resctor Site 

According to DGIF records, listed wildlife resources under DGIF's jurisdiction are not 

documented from the site proposed for placement of the third reactor. Therefore, 

impacts upon listed wildlife resources are not iikeiy to result from site preparation or 

construction of the third reactor. 

500 kV Transmission Line 

DGIF reviewed the proposed corridor for the additional 500kV line required to carry the 

output of the existing Lake Anna units and the proposed third unit. DGIF does not 

10 

Combined license (COL) for North Anna Power Station Unit 3 

support them will be considered in DGIF's final comments and recommendations 

resulting from review of the IFIM results. 

4. Wildlife Resources and Protected Species. According to the SEIS (page 4-10, 

section 4.4.3) the information and associated impacts for wildlife resources and 

protected species are provided and resolved in Section 4.4.3 of the ESP EIS (NRC 

2006). Based on the staff's analysis, construction, operation and cumulative impacts to 

threatened or endangered species were considered small. 

3(a) Agency Jurisdiction. The Department of Game and Inland Fisheries (DGlF), as 

the Commonwealth's wildlife and freshwater fish management agency, exercises 

enforcement and regulatory jurisdiction over wildlife and freshwater fish, Including state 

or federally listed endangered or threatened species, but excluding listed insects 

(Virginia Code Title 29.1). The DGIF is a consulting agency under the U.S. Fish and 

Wildlife Coordination Act (16 U.S.C. sections 661 et seq.), and provides environmental 

analysis of projects or permit applications coordinated through DEC and several other 

state and federal agencies. DGIF determines likely impacts upon fish and wildlife 

resources and habitat, and recommends appropriate measures to avoid, reduce, or 

compensate for those impacts. 

4(b) Agency Comments. 

Federsl- snd Stste-listed Species 

According to DGIF data and those from the Department of Conservation and 

Recreation (OCR), downstream waters have been known to support: 

• dwarf wedgemussel (federally-listed endangered); 

• James spinymussel (federally-listed endangered); 

• Atlantic pigtoe (state-listed endangered); and 

• green floater (state-listed threatened). 

Resctor Site 

According to DGIF records, listed wildlife resources under DGIF's jurisdiction are not 

documented from the site proposed for placement of the third reactor. Therefore, 

impacts upon listed wildlife resources are not iikeiy to result from site preparation or 

construction of the third reactor. 

500 kV Transmission Line 

DGIF reviewed the proposed corridor for the additional 500kV line required to carry the 

output of the existing Lake Anna units and the proposed third unit. DGIF does not 

10 
Appendix F 

February 2010 F-35 NUREG-1917, SEIS 

Combined License (COL) for North Anna Power, Station Unit 3 

currently document any listed wildlife or resources under its jurisdiction from the project 

area. Therefore, impacts upon such species and resources are not likely to result from 

the construction of this line. In addition, as this new line will be co-located within an 

existing power line corridor, it does not appear that significant wildlife habitat alterations 

will occur. 

4(c) Recommendations. DGIF offers the following recommendations for the 

protection of wildlife resources during project construction: 

• Adhere to erosion and sediment controls for all land-disturbing activities. 

• Conduct any in-stream activities during low or no-flow conditions. 

• Use non-erodible cofferdams to isolate the construction area. 

• Block no more than 50% of the streamflow at any given time. 

• Stockpile excavated material in a manner that prevents reentry into the stream. 

• Restore original streambed and streambank contours. 

• Revegetate barren areas with native vegetation. 

• Construct stream crossings via clear-span bridges when applicable due to future 

maintenance costs associated with culverts and the loss of riparian and aquatic 

habitat. 

5. Natural Heritage Resources. The SEIS does not include a discussion of natural 

heritage resources. However, the document (page 2-17, section 2.7.1.4) states that the 

NRC expects Dominion to work with the Commonwealth, including the Department of 

Conservation and Recreation's Natural Heritage Program, on development and 

implementation of any required monitoring programs. 

5(a) Agency Jurisdiction The mission of the Virginia Department of Conservation and 

Recreation is to conserve Virginia's natural and recreational resources. OCR supports a 

variety of environmental programs organized within seven divisions including the 

Division of Natural Heritage. The Natural Heritage Program's (DCR-DNH) mission is 

conserving Virginia's biodiversity through inventory, protection, and stewardship. The 

Virginia Natural Area Preserves Act, 10.1-209 through 217 of the Code of Virginia, was 

passed in 1989 and codified OCR's powers and duties related to statewide biological 

inventory: maintaining a statewide database for conservation planning and project 

review, land protection for the conservation of biodiversity, and the protection and 

ecological management of natural heritage resources (the habitats of rare, threatened, 

and endangered species, significant natural communities, geologiC sites, and other 

natural features). 

5(b) Agency Comments. DCR-DNH searched its Biotics Data System for occurrences 

of natural heritage resources from the project site. Biotics historically documents the 

presence of natural heritage resources in the project area. However, due to the scope 

11 ' 

Combined License (COL) for North Anna Power, Station Unit 3 

currently document any listed wildlife or resources under its jurisdiction from the project 

area. Therefore, impacts upon such species and resources are not likely to result from 

the construction of this line. In addition, as this new line will be co-located within an 

existing power line corridor, it does not appear that significant wildlife habitat alterations 

will occur. 

4(c) Recommendations. DGIF offers the following recommendations for the 

protection of wildlife resources during project construction: 

• Adhere to erosion and sediment controls for all land-disturbing activities. 

• Conduct any in-stream activities during low or no-flow conditions. 

• Use non-erodible cofferdams to isolate the construction area. 

• Block no more than 50% of the streamflow at any given time. 

• Stockpile excavated material in a manner that prevents reentry into the stream. 

• Restore original streambed and streambank contours. 

• Revegetate barren areas with native vegetation. 

• Construct stream crossings via clear-span bridges when applicable due to future 

maintenance costs associated with culverts and the loss of riparian and aquatic 

habitat. 

5. Natural Heritage Resources. The SEIS does not include a discussion of natural 

heritage resources. However, the document (page 2-17, section 2.7.1.4) states that the 

NRC expects Dominion to work with the Commonwealth, including the Department of 

Conservation and Recreation's Natural Heritage Program, on development and 

implementation of any required monitoring programs. 

5(a) Agency Jurisdiction The mission of the Virginia Department of Conservation and 

Recreation is to conserve Virginia's natural and recreational resources. OCR supports a 

variety of environmental programs organized within seven divisions including the 

Division of Natural Heritage. The Natural Heritage Program's (DCR-DNH) mission is 

conserving Virginia's biodiversity through inventory, protection, and stewardship. The 

Virginia Natural Area Preserves Act, 10.1-209 through 217 of the Code of Virginia, was 

passed in 1989 and codified OCR's powers and duties related to statewide biological 

inventory: maintaining a statewide database for conservation planning and project 

review, land protection for the conservation of biodiversity, and the protection and 

ecological management of natural heritage resources (the habitats of rare, threatened, 

and endangered species, significant natural communities, geologiC sites, and other 

natural features). 

5(b) Agency Comments. DCR-DNH searched its Biotics Data System for occurrences 

of natural heritage resources from the project site. Biotics historically documents the 

presence of natural heritage resources in the project area. However, due to the scope 

11 ' 
Appendix F 

NUREG-1917, SEIS F-36 February 2010 

Combined License (COL) for North Anna Power Station Unit 3 

of the activity and the distance to the resources, DCR-DNH does not anticipate that this 

project will adversely impact these natural heritage resources. 

5(c) State-listed Plant and Insect Species. The Endangered Plant and Insect 

Species Act of 1979, Chapter 39 §3.1-1 020 through 1030 of the Code of Virginia, as 

amended, authorizes the Virginia Department of Agriculture and Consumer Services 

(VDACS) to conserve, protect, and manage endangered and threatened species of 

plants and insects. The VDACS Virginia Endangered Plant and Insect Species 

Program personnel cooperates with the U.S. Fish and Wiidlife Service (USFWS), DCRDNH and other agencies and organizations on the recovery, protection or conservation 

of listed threatened or endangered species and designated plant and insect species 

that are rare throughout their worldwide ranges. In those instances where recovery 

plans, developed by USFWS, are avaiiable, adherence to the order and tasks outlined 

in the plans are followed to the extent possible. 

Small Whorled Pogonia 

VDACS notes that the SEIS lists several federal- and state-listed endangered and 

threatened species within the scope of the project area. The small whorled pogonia is 

not generally found in wetland habitat at described in the SEIS (page 5-13, section 

5.4.3.1). The species occurs on upland sites in mixed deciduous or mixed deciduous 

and coniferous forests that are generally in second- or third-growth successional stages 

5(d) State Natural Area Preserves. OCR files do not indicate the presence of any 

State Natural Area Preserves under the agency's jurisdiction in the project vicinity. 

5(e) Recommendations. DCR-DNH and VDACS offer the following recommendations 

for this proposal: 

• Contact DCR-DNH, Rene Hypes at (804) 371-2708 for an update on natural 

heritage information if a significant amount of time passes before the project is 

initiated since new and updated information is continually added to Biotics. 

• The final SEIS should include a discussion of the small whorled pogonia as it 

occurs on upland sites. 

6. Erosion and Sediment Control and Stormwater Management. According to the 

SEIS (page 4-25. 4.10), measures and controls to limit adverse impacts during 

construction, including erosion and sediment control, were addressed in Section 4.10 of 

the ESP EI$ (NRC 2006). These measures and controls have been incorporated into 

the Environmental Protection Plan (EPP) for the site that is included as Appendix 1 A of 

the COL ER (Dominion 2007a). Simiiarly, storm water management is incorporated in 

the EPP. 

12 

Combined License (COL) for North Anna Power Station Unit 3 

of the activity and the distance to the resources, DCR-DNH does not anticipate that this 

project will adversely impact these natural heritage resources. 

5(c) State-listed Plant and Insect Species. The Endangered Plant and Insect 

Species Act of 1979, Chapter 39 §3.1-1 020 through 1030 of the Code of Virginia, as 

amended, authorizes the Virginia Department of Agriculture and Consumer Services 

(VDACS) to conserve, protect, and manage endangered and threatened species of 

plants and insects. The VDACS Virginia Endangered Plant and Insect Species 

Program personnel cooperates with the U.S. Fish and Wiidlife Service (USFWS), DCRDNH and other agencies and organizations on the recovery, protection or conservation 

of listed threatened or endangered species and designated plant and insect species 

that are rare throughout their worldwide ranges. In those instances where recovery 

plans, developed by USFWS, are avaiiable, adherence to the order and tasks outlined 

in the plans are followed to the extent possible. 

Small Whorled Pogonia 

VDACS notes that the SEIS lists several federal- and state-listed endangered and 

threatened species within the scope of the project area. The small whorled pogonia is 

not generally found in wetland habitat at described in the SEIS (page 5-13, section 

5.4.3.1). The species occurs on upland sites in mixed deciduous or mixed deciduous 

and coniferous forests that are generally in second- or third-growth successional stages 

5(d) State Natural Area Preserves. OCR files do not indicate the presence of any 

State Natural Area Preserves under the agency's jurisdiction in the project vicinity. 

5(e) Recommendations. DCR-DNH and VDACS offer the following recommendations 

for this proposal: 

• Contact DCR-DNH, Rene Hypes at (804) 371-2708 for an update on natural 

heritage information if a significant amount of time passes before the project is 

initiated since new and updated information is continually added to Biotics. 

• The final SEIS should include a discussion of the small whorled pogonia as it 

occurs on upland sites. 

6. Erosion and Sediment Control and Stormwater Management. According to the 

SEIS (page 4-25. 4.10), measures and controls to limit adverse impacts during 

construction, including erosion and sediment control, were addressed in Section 4.10 of 

the ESP EI$ (NRC 2006). These measures and controls have been incorporated into 

the Environmental Protection Plan (EPP) for the site that is included as Appendix 1 A of 

the COL ER (Dominion 2007a). Simiiarly, storm water management is incorporated in 

the EPP. 

12 
Appendix F 

February 2010 F-37 NUREG-1917, SEIS 

Combined License (COL) for North Anna Power Station Unit 3 

6(a) Agency Jurisdiction. OCR's Division of Soil and Water Conservation (DSWC) 

administers the Virginia Erosion and Sediment Control Law and Regulations 

(VESCL&R) and Virginia Stormwater Management Law and Regulations (VSWML&R). 

6(b) Erosion and Sediment Control Plan. Accordh1g to DCR-DSWC,the property 

owner is responsible for submitting a project-specific erosion and sediment control 

(ESC) plan to Louisa County for review Cind approval pursuant to the local ESC 

requirements, if the project involves a land-disturbing activity of equal to or greater than 

10,000 square feet. Depending on local requirements the area 01 land disturbance 

requiring an ESC plan may be less. The ESC plan must be approved by the locality 

prior to any land-disturbing activity at the project site. All regulated land-disturbing 

activities associated with the project, including on and off site access roads, staging 

areas, borrow areas, stockpiles, and soil intentionally transported from the project must 

be covered by the project specific ESC plan. Local ESC program requirements must be 

requested through Louisa County. [Reference: Virginia Erosion and Sediment Control 

Law § 10.1-563; Virginia Erosion and Sediment Control Regulations 4 VAC 50-30-30 

and 4 VAC 50-30-40] 

6(c) Stormwater Management Plan. Dependent on local reqUirements, a Stormwater 

Management (SWM) plan may be required. Local SWM program requirements must be 

requested through Louisa County. [Reference: Virginia Stormwater Management Act 

§ 10.1 .. 603.3; Virginia Sfortnwater Management (VS!vtPJ Perrnit Regulations 4 VAC50-

60-110] 

6(d) Virginia Stormwater Management Program General Permit for Stormwater 

Discharges from Construction Activities. OCR is responsible for the issuance, 

denial, revocation, termination and enforcement of the Virginia Stormwater 

Management Program General Permit for Stormwater Discharges from Construction 

Activities related to municipal separate storm sewer systems (MS4s) and construction 

activities for the control of stormwater discharges from MS4s and land disturbing 

activities under the Virginia Stormwater Management Program. 

The operator or owner of construction activities involving land disturbance of equal to or 

greater than one acre are required to register for coverage under the General Permit for 

Discharges of Storm water from Construction Activities and develop a project-specific 

stormwater pollution preventiolJ plan (SWPPP). Construction activities requiring 

registration also includes land disturbance of less than one acre of total land area that 

is part of a larger common plan of development or sale if the larger common plan of 

development will ultimately disturb equal to or greater than one acre. The SWPPP 

must be prepared prior to submission of the registration statement for coverage under 

the general permit and the SWPPP must address water quality and quantity in 

accordance with the Virginia Stormwater Management Program Permit Regulations. 

13 

Combined License (COL) for North Anna Power Station Unit 3 

6(a) Agency Jurisdiction. OCR's Division of Soil and Water Conservation (DSWC) 

administers the Virginia Erosion and Sediment Control Law and Regulations 

(VESCL&R) and Virginia Stormwater Management Law and Regulations (VSWML&R). 

6(b) Erosion and Sediment Control Plan. Accordh1g to DCR-DSWC,the property 

owner is responsible for submitting a project-specific erosion and sediment control 

(ESC) plan to Louisa County for review Cind approval pursuant to the local ESC 

requirements, if the project involves a land-disturbing activity of equal to or greater than 

10,000 square feet. Depending on local requirements the area 01 land disturbance 

requiring an ESC plan may be less. The ESC plan must be approved by the locality 

prior to any land-disturbing activity at the project site. All regulated land-disturbing 

activities associated with the project, including on and off site access roads, staging 

areas, borrow areas, stockpiles, and soil intentionally transported from the project must 

be covered by the project specific ESC plan. Local ESC program requirements must be 

requested through Louisa County. [Reference: Virginia Erosion and Sediment Control 

Law § 10.1-563; Virginia Erosion and Sediment Control Regulations 4 VAC 50-30-30 

and 4 VAC 50-30-40] 

6(c) Stormwater Management Plan. Dependent on local reqUirements, a Stormwater 

Management (SWM) plan may be required. Local SWM program requirements must be 

requested through Louisa County. [Reference: Virginia Stormwater Management Act 

§ 10.1 .. 603.3; Virginia Sfortnwater Management (VS!vtPJ Perrnit Regulations 4 VAC50-

60-110] 

6(d) Virginia Stormwater Management Program General Permit for Stormwater 

Discharges from Construction Activities. OCR is responsible for the issuance, 

denial, revocation, termination and enforcement of the Virginia Stormwater 

Management Program General Permit for Stormwater Discharges from Construction 

Activities related to municipal separate storm sewer systems (MS4s) and construction 

activities for the control of stormwater discharges from MS4s and land disturbing 

activities under the Virginia Stormwater Management Program. 

The operator or owner of construction activities involving land disturbance of equal to or 

greater than one acre are required to register for coverage under the General Permit for 

Discharges of Storm water from Construction Activities and develop a project-specific 

stormwater pollution preventiolJ plan (SWPPP). Construction activities requiring 

registration also includes land disturbance of less than one acre of total land area that 

is part of a larger common plan of development or sale if the larger common plan of 

development will ultimately disturb equal to or greater than one acre. The SWPPP 

must be prepared prior to submission of the registration statement for coverage under 

the general permit and the SWPPP must address water quality and quantity in 

accordance with the Virginia Stormwater Management Program Permit Regulations. 

13 
Appendix F 

NUREG-1917, SEIS F-38 February 2010 

Combined License (COL) for North Anna Power Station Unij 3 

General information and registration forms for the general permit are available on 

DCR's website at http://www.dcr.virginia.gov/soil & water/vsmp.shtm!. [Reference: 

Virginia Storm water Management Act § 10.1-603.1 et seg.; and VSMP Permit 

Regulations 4 VAC-50 ~. 

7. Air Pollution Control. Measures and controls to limit adverse air impacts during 

construction were addressed in Sectiori 4.10 of the ESP EIS (NRC 2006) and 

incorporated into the Environmental Protection Plan (EPP) for the site that is included. 

as Appendix 1 A of the COL ER (Dominion 2007a) (SEIS page 4-25, section 4.10). The 

document (page 5-2, section 5.2) indicates that the meteorological and air quality 

impacts from operation of the proposed closed cycle, combination wet and dry cooling 

system for Unit 3 would be limited to those resulting from the cooling system and 

periodic pollutant emissions from auxiliary boilers and generators that would support the 

unit. 

7(a) Agency Jurisdiction. DEQ's Air Quality Division, on behalf of the State Air 

Pollution Control Board, is responsible to develop regulations that become Virginia's Air 

Pollution Control Law. DEQ is charged to carry out mandates of the state law and 

related regulations as well as Virginia's federal obligations under the Clean Air Act as 

amended in 1990. The objective is to protect and enhance public health and quality of 

life through control and mitigation of air pollution. The division ensures the safety and 

qualitlj of air in Virginia by monitoih1g and analyzing air quaiiiy data, reguiating sources 

of aj~ pollution, and working with local, state and federal agencies to plan and 

implement strategies to protect Virginia's air quality. The appropriate regional office is 

directly responsible for the issue of necessary permits to construct and operate all 

stationary sources in the region as well as to monitor emiSSions from these sources for 

compliance. As a part of this mandate, the environmental documents of new projects to 

be undertaken in the state are also reviewed. In the case of certain projects, additional 

evaluation and demonstration must be made under the general conformity provisions of 

state and federal law. 

7(b) Agency Comments. 

Ozone Attainment Area 

The project site is located in a designated ozone attainment area. Precursors to ozone 

(03) pollution include volatile organic compounds (VOCs) and oxides of nitrogen (NO.). 

However, due to the proximity of the site to Spotsylvania arid Hanover counties, which 

are deSignated as ozone maintenance areas, Dominion should take all reasonable 

precautions to limit emissions of VOCs and NO., principally by controlling or limiting the 

burning of fossil fuels. 

14 

Combined License (COL) for North Anna Power Station Unij 3 

General information and registration forms for the general permit are available on 

DCR's website at http://www.dcr.virginia.gov/soil & water/vsmp.shtm!. [Reference: 

Virginia Storm water Management Act § 10.1-603.1 et seg.; and VSMP Permit 

Regulations 4 VAC-50 ~. 

7. Air Pollution Control. Measures and controls to limit adverse air impacts during 

construction were addressed in Sectiori 4.10 of the ESP EIS (NRC 2006) and 

incorporated into the Environmental Protection Plan (EPP) for the site that is included. 

as Appendix 1 A of the COL ER (Dominion 2007a) (SEIS page 4-25, section 4.10). The 

document (page 5-2, section 5.2) indicates that the meteorological and air quality 

impacts from operation of the proposed closed cycle, combination wet and dry cooling 

system for Unit 3 would be limited to those resulting from the cooling system and 

periodic pollutant emissions from auxiliary boilers and generators that would support the 

unit. 

7(a) Agency Jurisdiction. DEQ's Air Quality Division, on behalf of the State Air 

Pollution Control Board, is responsible to develop regulations that become Virginia's Air 

Pollution Control Law. DEQ is charged to carry out mandates of the state law and 

related regulations as well as Virginia's federal obligations under the Clean Air Act as 

amended in 1990. The objective is to protect and enhance public health and quality of 

life through control and mitigation of air pollution. The division ensures the safety and 

qualitlj of air in Virginia by monitoih1g and analyzing air quaiiiy data, reguiating sources 

of aj~ pollution, and working with local, state and federal agencies to plan and 

implement strategies to protect Virginia's air quality. The appropriate regional office is 

directly responsible for the issue of necessary permits to construct and operate all 

stationary sources in the region as well as to monitor emiSSions from these sources for 

compliance. As a part of this mandate, the environmental documents of new projects to 

be undertaken in the state are also reviewed. In the case of certain projects, additional 

evaluation and demonstration must be made under the general conformity provisions of 

state and federal law. 

7(b) Agency Comments. 

Ozone Attainment Area 

The project site is located in a designated ozone attainment area. Precursors to ozone 

(03) pollution include volatile organic compounds (VOCs) and oxides of nitrogen (NO.). 

However, due to the proximity of the site to Spotsylvania arid Hanover counties, which 

are deSignated as ozone maintenance areas, Dominion should take all reasonable 

precautions to limit emissions of VOCs and NO., principally by controlling or limiting the 

burning of fossil fuels. 

14 
Appendix F 

February 2010 F-39 NUREG-1917, SEIS 

Combined License (COL) fOr North Anna Power Station Unn 3 

Fugitive Dust 

Fugitive dust must be kept to a minimum by using control methods outlined in 9 VAC 5-

50-60 et seq. of the Regulations for the Control and Abatement of Air Pollution. These 

precautions include, but are not limited to,·the following: 

• Use, where possible, of water orchemicals for dust control; 

• Installation and use of hoods, fans, and fabric filters to enclose and vent the 

handling of dusty materials; 

• Covering of open equipment for conveying materials; and 

• Prompt removal of spilled or tracked dirt or other materials from paved streets 

and removal of dried sediments resulting from soil erosion. 

Open Burning 

If project activities include the burning of construction material, this activity must meet 

the requirements under 9 VAC 5-40-5600 et seq. of the Regulations for open burning, 

C!nd it may require a permit. The Regulations provide for, but do not require, the local 

adoption of a model ordinance concerning open burning. Dominion should contact 

Louisa County officials to determine what local requirements, if any, exist. The model 

ordinance includes, but is not limited to, the following provisions: 

• All reasonable effort shall be made to minimize the amount of material burned, 

with the number and size of the debris piles; 

• The material to be burned shall consist of brush, stumps and similar debris 

waste and clean-burning demolition material; 

• The burning shall be at least 500 feet from any occupied building unless the 

occupants have given prior permission, other than a building located on the 

property on which the burning is conducted; 

• The burning shall be conducted at the greatest distance practicable from 

highways and alr.fields; 

• The burning shall be attended at all times and conducted to ensure the best 

possible combustion with a minimum of smoke being produced; 

• The burning shall not be allowed to smolder beyond the minimum period of time 

necessary for the destruction of the materials; and 

• The burning shall be conducted only when the prevailing winds are away from 

any city, town or built-up area. 

Fuel Burning Equipment 

The installation of any fuel burning equipment (e.g. boilers and generators), may require 

permitting from DEQ prior to beginning construction of the facility (9 VAC 5-80, Article 6, 

Permits for New and Modified Sources). This would include cooling towers as there 

15 

Combined License (COL) fOr North Anna Power Station Unn 3 

Fugitive Dust 

Fugitive dust must be kept to a minimum by using control methods outlined in 9 VAC 5-

50-60 et seq. of the Regulations for the Control and Abatement of Air Pollution. These 

precautions include, but are not limited to,·the following: 

• Use, where possible, of water orchemicals for dust control; 

• Installation and use of hoods, fans, and fabric filters to enclose and vent the 

handling of dusty materials; 

• Covering of open equipment for conveying materials; and 

• Prompt removal of spilled or tracked dirt or other materials from paved streets 

and removal of dried sediments resulting from soil erosion. 

Open Burning 

If project activities include the burning of construction material, this activity must meet 

the requirements under 9 VAC 5-40-5600 et seq. of the Regulations for open burning, 

C!nd it may require a permit. The Regulations provide for, but do not require, the local 

adoption of a model ordinance concerning open burning. Dominion should contact 

Louisa County officials to determine what local requirements, if any, exist. The model 

ordinance includes, but is not limited to, the following provisions: 

• All reasonable effort shall be made to minimize the amount of material burned, 

with the number and size of the debris piles; 

• The material to be burned shall consist of brush, stumps and similar debris 

waste and clean-burning demolition material; 

• The burning shall be at least 500 feet from any occupied building unless the 

occupants have given prior permission, other than a building located on the 

property on which the burning is conducted; 

• The burning shall be conducted at the greatest distance practicable from 

highways and alr.fields; 

• The burning shall be attended at all times and conducted to ensure the best 

possible combustion with a minimum of smoke being produced; 

• The burning shall not be allowed to smolder beyond the minimum period of time 

necessary for the destruction of the materials; and 

• The burning shall be conducted only when the prevailing winds are away from 

any city, town or built-up area. 

Fuel Burning Equipment 

The installation of any fuel burning equipment (e.g. boilers and generators), may require 

permitting from DEQ prior to beginning construction of the facility (9 VAC 5-80, Article 6, 

Permits for New and Modified Sources). This would include cooling towers as there 

15 
Appendix F 

NUREG-1917, SEIS F-40 February 2010 

Combined license (COL) for North Anna Power Station Un~ 3 

may be issues with voe emissions resultant from additives to make-up water, or 

particulate emissions from the cooling towers that may require air permitting. The 

project proponent should contact DEQ-NRO for guidance on whether this provision 

applies. 

7(c) Findings. According to DEQ-NRO, the SEIS does not thoroughly discuss air 

permit requirements. 

7(d) Requirements. Dominion must contact DEQ-NRO prior to construction activities 

and operation to review applicable air permit requirements. 

8. Solid and Hazardous Wastes and Hazardous Materials. According to the SEIS 

(page 3-11, section 3.2.4.3), non-radioactive solid wastes (e.g., construction debris) 

would be handled in compliance with appropriate state and federal regulations. 

8(a) Agency Jurisdiction. Solid and hazardous wastes in Virginia are regulated by the 

Virginia Department of Environmental Quality, the Virginia Waste Management Board 

(VWMB) and the U.S. Environmental Protection Agency. They administer programs 

created by the federal Resource Conservation and Recovery Act, Comprehensive 

Environmental Response Compensation and Liability Act, commonly called Superfund, 

and the Virginia Waste Management Act. DEQ administers regulations established by 

the VWMB and reviews permit applications for completeness and confoimanCe with 

facility standards and financial assurance requirements. All Virginia localities are 

required, under the Solid Waste Management Planning Regulations, to identify the. 

strategies they will follow on the management of their solid wastes to include items such 

as facility siting, long-term (20-year) use, and alternative programs such as materials 

recycling and composting. 

8(b) Agency Comments. DEQ's Waste Division staff determined that both solid and 

hazardous waste issues were addressed in the report. A geographic information 

system (GIS) database search did not reveal any waste Sites within a half mile radius 

that would impact or be impacted by construction activities at the project site. 

The Waste Division performed a cursory review of DEQ data files and determined that 

there are several hazardous waste and solid waste sites located in the same zip code. 

These are as follows. 

Hazardous Waste Site 

• NorthAnna Power Station (VAD065376279), a treatment, storage and disposal 

facility (TSDF) 

16 

Combined license (COL) for North Anna Power Station Un~ 3 

may be issues with voe emissions resultant from additives to make-up water, or 

particulate emissions from the cooling towers that may require air permitting. The 

project proponent should contact DEQ-NRO for guidance on whether this provision 

applies. 

7(c) Findings. According to DEQ-NRO, the SEIS does not thoroughly discuss air 

permit requirements. 

7(d) Requirements. Dominion must contact DEQ-NRO prior to construction activities 

and operation to review applicable air permit requirements. 

8. Solid and Hazardous Wastes and Hazardous Materials. According to the SEIS 

(page 3-11, section 3.2.4.3), non-radioactive solid wastes (e.g., construction debris) 

would be handled in compliance with appropriate state and federal regulations. 

8(a) Agency Jurisdiction. Solid and hazardous wastes in Virginia are regulated by the 

Virginia Department of Environmental Quality, the Virginia Waste Management Board 

(VWMB) and the U.S. Environmental Protection Agency. They administer programs 

created by the federal Resource Conservation and Recovery Act, Comprehensive 

Environmental Response Compensation and Liability Act, commonly called Superfund, 

and the Virginia Waste Management Act. DEQ administers regulations established by 

the VWMB and reviews permit applications for completeness and confoimanCe with 

facility standards and financial assurance requirements. All Virginia localities are 

required, under the Solid Waste Management Planning Regulations, to identify the. 

strategies they will follow on the management of their solid wastes to include items such 

as facility siting, long-term (20-year) use, and alternative programs such as materials 

recycling and composting. 

8(b) Agency Comments. DEQ's Waste Division staff determined that both solid and 

hazardous waste issues were addressed in the report. A geographic information 

system (GIS) database search did not reveal any waste Sites within a half mile radius 

that would impact or be impacted by construction activities at the project site. 

The Waste Division performed a cursory review of DEQ data files and determined that 

there are several hazardous waste and solid waste sites located in the same zip code. 

These are as follows. 

Hazardous Waste Site 

• NorthAnna Power Station (VAD065376279), a treatment, storage and disposal 

facility (TSDF) 

16 
Appendix F 

February 2010 F-41 NUREG-1917, SEIS 

Combined License (COL) for North Anna Power Station Unit 3 

Solid Waste Sites 

• Louisa County Sanitary Landfill, solid waste permit (SWP) 134, a closed sanitary 

landfill 

• Louisa County Sanitary Landfill, SWP 194, a sanitary landfill 

• Louisa County Sanitary Landfill, SWP 567, a sanitary landfill 

8{c) Waste Management. Any soil that is suspected afcontamination or wastes that 

are generated during construction-related activities must be tested and disposed of in 

accordance with applicable federal, state, and local laws and regulations. 

8{d) Asbestos-contalnlng Material and Lead-based Paint. Any structures being 

demolished, renovated, or removed, should be checked for asbestos-containing 

materials (ACM) and lead-based paint (LBP) prior to demolition. If ACM or LBP are 

found, in addition to the federal waste-related regulations mentioned above, state 

regulations 9VAC 20-80-640 for ACM and 9VAC 20-60-261 for LBP must be followed. 

8{e) RecommendatIons. The DEQ Waste Division recommends the following: 

• Access the following website to locate additional information on hazardous waste 

and solid waste sites using their identification numbers: 

o http://www.epa.aov/supertund/siteslcursiteslindex.htm or. 

• Implement pollution prevention principles, including the reduction, reuse, and 

recycling of all solid wastes generated. All generation of hazardous wastes 

should be minimized and handled appropriately. 

8{t) ReqUIrement. If the construction of this project will include the use of portable fuel 

AST(s) with a capacity of greater than 660 gallons, the tank(s) must be registered with 

DEQ using AST Registration Form 7540-AST. 

9. Pesticides and HerbIcIdes. DEQ recommends that the use of herbicides or 

pesticides for construction or landscape maintenance should be in accordance with the 

principles of integrated pest management. The least toxic pesticides that are effective 

in controlling the target species should be used. Contact the Department of Agriculture 

and Consumer Services at (804) 786-3501 for more information. 

10. Forest Resources. According to the SEIS (page 4-6, section 4.4.1), the current 

plant design and layout for Unit 3 indicates that approximately 125 acres of forested 

habitat would be lost (Dominion 2008a). All of this habitat is relatively recent regrowth 

and contains no unique or sensitive plant species or communities. Furthermore, the 

document (page 4-7, section 4.4.1) states that the new transmission line will be 

17 

Combined License (COL) for North Anna Power Station Unit 3 

Solid Waste Sites 

• Louisa County Sanitary Landfill, solid waste permit (SWP) 134, a closed sanitary 

landfill 

• Louisa County Sanitary Landfill, SWP 194, a sanitary landfill 

• Louisa County Sanitary Landfill, SWP 567, a sanitary landfill 

8{c) Waste Management. Any soil that is suspected afcontamination or wastes that 

are generated during construction-related activities must be tested and disposed of in 

accordance with applicable federal, state, and local laws and regulations. 

8{d) Asbestos-contalnlng Material and Lead-based Paint. Any structures being 

demolished, renovated, or removed, should be checked for asbestos-containing 

materials (ACM) and lead-based paint (LBP) prior to demolition. If ACM or LBP are 

found, in addition to the federal waste-related regulations mentioned above, state 

regulations 9VAC 20-80-640 for ACM and 9VAC 20-60-261 for LBP must be followed. 

8{e) RecommendatIons. The DEQ Waste Division recommends the following: 

• Access the following website to locate additional information on hazardous waste 

and solid waste sites using their identification numbers: 

o http://www.epa.aov/supertund/siteslcursiteslindex.htm or. 

• Implement pollution prevention principles, including the reduction, reuse, and 

recycling of all solid wastes generated. All generation of hazardous wastes 

should be minimized and handled appropriately. 

8{t) ReqUIrement. If the construction of this project will include the use of portable fuel 

AST(s) with a capacity of greater than 660 gallons, the tank(s) must be registered with 

DEQ using AST Registration Form 7540-AST. 

9. Pesticides and HerbIcIdes. DEQ recommends that the use of herbicides or 

pesticides for construction or landscape maintenance should be in accordance with the 

principles of integrated pest management. The least toxic pesticides that are effective 

in controlling the target species should be used. Contact the Department of Agriculture 

and Consumer Services at (804) 786-3501 for more information. 

10. Forest Resources. According to the SEIS (page 4-6, section 4.4.1), the current 

plant design and layout for Unit 3 indicates that approximately 125 acres of forested 

habitat would be lost (Dominion 2008a). All of this habitat is relatively recent regrowth 

and contains no unique or sensitive plant species or communities. Furthermore, the 

document (page 4-7, section 4.4.1) states that the new transmission line will be 

17 
Appendix F 

NUREG-1917, SEIS F-42 February 2010 

Combined license (COL) for North Anna Power Station Un~ 3 

constructed in the existing North Anna to Ladysmith right-of-way. No additional clearing 

of forested ilegetation will be required for construction of the transmission line. 

10(a) Agency Jurisdiction. The mission of the Virginia Department of Forestry 

(VDOF) is to protect and develop healthy, sustainable forest resources for Virginians. 

VDOF was established in 1914 to prevent and suppress forest fires and reforest bare 

lands. Since the Department's inception, it has grown and evolved to encompass other 

pioieciion and management duties including: protecting Virginia's forests from wildfire, 

protecting Virginia's waters, managing and conserving Virginia's forests, managing 

state-owned lands and nurseries, and managing regulated incentive programs for forest 

landowners. 

10(b) Agency Findings. The Department of Forestry finds that proposed clearing of 

125 acres of timberland for the Unit 3 footprint, and the 80 acre proposed clearing due 

to construction will have a significant impact on the forest resources of the 

Commonwealth. . 

10(c) Agency Recommendations. VDOF recommends that the proposed clearing due 

to construction be mitigated. Potential opportunities for mitigation include but are not 

limited to: 

• Plant open company lands within Virginia to create forested stands. 

• Work with VDOF to develop a cost share program.to assist private landowners 

statewide, to reforest harvested timberlands or plant open lands with pine or 

hardwood seedlings. This mitigation program would be funded by Dominion. 

• Work with VDOF, or other Virginia conservation agency or group, to create a 

forest land conservation fund to be used for the purchase of conservation 

easements or property acquisitions of forested lands. These purchases could be 

statewide and would ensure that the forested lands are managed and retained 

as working forest lands. . 

• Mitigation should achieve a ratio in excess of 1 to 1, more than one acre of land 

reforested or protected to every one acre cleared, for power-line right-of-way. 

Therefore, Dominion would assist landowners in the conservation, reforestation 

or purchase of at least 200+ acres within the county area or statewide. 

11. Water Supply. The SEIS (page 2-36, section 2.8.2.6) includes a review of major 

public watei supply systems in the region. 

11 (a) Agency Jurisdiction. The Virginia Department of Health (VDH), Office of 

Drinking Water (ODW) reviews projects for the potential to impact public drinking water 

sources (groundwater wells and surface water intakes). 

18 

Combined license (COL) for North Anna Power Station Un~ 3 

constructed in the existing North Anna to Ladysmith right-of-way. No additional clearing 

of forested ilegetation will be required for construction of the transmission line. 

10(a) Agency Jurisdiction. The mission of the Virginia Department of Forestry 

(VDOF) is to protect and develop healthy, sustainable forest resources for Virginians. 

VDOF was established in 1914 to prevent and suppress forest fires and reforest bare 

lands. Since the Department's inception, it has grown and evolved to encompass other 

pioieciion and management duties including: protecting Virginia's forests from wildfire, 

protecting Virginia's waters, managing and conserving Virginia's forests, managing 

state-owned lands and nurseries, and managing regulated incentive programs for forest 

landowners. 

10(b) Agency Findings. The Department of Forestry finds that proposed clearing of 

125 acres of timberland for the Unit 3 footprint, and the 80 acre proposed clearing due 

to construction will have a significant impact on the forest resources of the 

Commonwealth. . 

10(c) Agency Recommendations. VDOF recommends that the proposed clearing due 

to construction be mitigated. Potential opportunities for mitigation include but are not 

limited to: 

• Plant open company lands within Virginia to create forested stands. 

• Work with VDOF to develop a cost share program.to assist private landowners 

statewide, to reforest harvested timberlands or plant open lands with pine or 

hardwood seedlings. This mitigation program would be funded by Dominion. 

• Work with VDOF, or other Virginia conservation agency or group, to create a 

forest land conservation fund to be used for the purchase of conservation 

easements or property acquisitions of forested lands. These purchases could be 

statewide and would ensure that the forested lands are managed and retained 

as working forest lands. . 

• Mitigation should achieve a ratio in excess of 1 to 1, more than one acre of land 

reforested or protected to every one acre cleared, for power-line right-of-way. 

Therefore, Dominion would assist landowners in the conservation, reforestation 

or purchase of at least 200+ acres within the county area or statewide. 

11. Water Supply. The SEIS (page 2-36, section 2.8.2.6) includes a review of major 

public watei supply systems in the region. 

11 (a) Agency Jurisdiction. The Virginia Department of Health (VDH), Office of 

Drinking Water (ODW) reviews projects for the potential to impact public drinking water 

sources (groundwater wells and surface water intakes). 

18 
Appendix F 

February 2010 F-43 NUREG-1917, SEIS 

Combined License (COL) for North Anna Power Station Unit 3 

11 (b) Agency Comments. VDH-ODW states that there are four groundwater wells 

within one mile of the project site. The North Anna Power Plant operates wells 4, 6, 7 

and the Information Center well. Impact to these wells may occur as a result of 

construction. There are no surface water intakes within a five-mile radius of the site. 

11(c) Recommendation. VDH-ODW recommends that the NAPS waterworks system 

operator be notified prior to any ground disturbance or changes in discharge pattems at tho. f~",mh. "I'Q 'U"""IILY, 

Contact Barry Matthews, VDH at (804) 864-7515 for additional information. 

12. Geologic and Minerai Resources. According to the SEIS (page 2-6, section 2.4), 

the proposed Unit 3 site is underlain by rocks of the Ta River Metamorphic Suite, which 

extends thousands of feet below the ground surface. Th'e crystalline metamorphic 

rocks near the ground surface have I,mdergone extensive weathering to create a layer 

of saprOlite about 100 feet thick beneath the site. The geotechnical properties of the 

saprolite are unsuitable for use as a structural fill material for plant construction, and 

excavated material will have to be removed to another location (NRC 2006a). 

12(a) Agency Jurisdiction. The mission of the DMME, Division of Mineral Resources 

(DMR) is to enhance th~ development and conservation of energy and mineral 

resources in a safe and environmentally sound manner to support a more productive 

economy in Virginia. Serving as Virginia's geological survey, DMME-DMR generates, 

collects, compiles, and evaluates geologic data, creates and publishes geologic maps 

and reports, works cooperatively with other state and federal agencies, and is the 

primary-source of information on geology, mineral and energy resources, and geologic 

hazards for both the mineral and energy industries and the general public. DMMEDMR also provides the necessary geologic support for those divisions of DMME that 

regulate the permitting of new mineral and fuel eXtraction sites, miner safety, and land 

reclamation. 

12(b) Agency Comments. DMME finds that the project does not pose a significant 

impact to the availability of mineral resources. 

For additional information, contact Matt Heller, DMME at (434) 

13. Historic Structures and Archaeological Resources. According to the SEIS 

(page 4-17, section 4.6) there are four historic resource sites in the area of the 

proposed Unit 3. Dominion has planned construction activities to avoid all four cultural 

resource locations (Dominion 2008a). 

_ 13(a) Agency Jurisdiction. The Department of Historic Resources (DHR) conducts 

reviews of projects to determine their effect on historic structures or cultural resources 

under its jurisdiction. DHR, as the designated State's Historic Preservation Office, 

19 

Combined License (COL) for North Anna Power Station Unit 3 

11 (b) Agency Comments. VDH-ODW states that there are four groundwater wells 

within one mile of the project site. The North Anna Power Plant operates wells 4, 6, 7 

and the Information Center well. Impact to these wells may occur as a result of 

construction. There are no surface water intakes within a five-mile radius of the site. 

11(c) Recommendation. VDH-ODW recommends that the NAPS waterworks system 

operator be notified prior to any ground disturbance or changes in discharge pattems at tho. f~",mh. "I'Q 'U"""IILY, 

Contact Barry Matthews, VDH at (804) 864-7515 for additional information. 

12. Geologic and Minerai Resources. According to the SEIS (page 2-6, section 2.4), 

the proposed Unit 3 site is underlain by rocks of the Ta River Metamorphic Suite, which 

extends thousands of feet below the ground surface. Th'e crystalline metamorphic 

rocks near the ground surface have I,mdergone extensive weathering to create a layer 

of saprOlite about 100 feet thick beneath the site. The geotechnical properties of the 

saprolite are unsuitable for use as a structural fill material for plant construction, and 

excavated material will have to be removed to another location (NRC 2006a). 

12(a) Agency Jurisdiction. The mission of the DMME, Division of Mineral Resources 

(DMR) is to enhance th~ development and conservation of energy and mineral 

resources in a safe and environmentally sound manner to support a more productive 

economy in Virginia. Serving as Virginia's geological survey, DMME-DMR generates, 

collects, compiles, and evaluates geologic data, creates and publishes geologic maps 

and reports, works cooperatively with other state and federal agencies, and is the 

primary-source of information on geology, mineral and energy resources, and geologic 

hazards for both the mineral and energy industries and the general public. DMMEDMR also provides the necessary geologic support for those divisions of DMME that 

regulate the permitting of new mineral and fuel eXtraction sites, miner safety, and land 

reclamation. 

12(b) Agency Comments. DMME finds that the project does not pose a significant 

impact to the availability of mineral resources. 

For additional information, contact Matt Heller, DMME at (434) 

13. Historic Structures and Archaeological Resources. According to the SEIS 

(page 4-17, section 4.6) there are four historic resource sites in the area of the 

proposed Unit 3. Dominion has planned construction activities to avoid all four cultural 

resource locations (Dominion 2008a). 

_ 13(a) Agency Jurisdiction. The Department of Historic Resources (DHR) conducts 

reviews of projects to determine their effect on historic structures or cultural resources 

under its jurisdiction. DHR, as the designated State's Historic Preservation Office, 

19 
Appendix F 

NUREG-1917, SEIS F-44 February 2010 

Combined License (COL) for North Anna Power Station Unit 3 

ensures that federal actions comply with Section 106 of the National Historic 

Preservation Act of 1962 (NHPA), as amended, and its implementing regulation at 36 

CFR Part 800. The NHPA requires federal agencies to consider the effects of federal 

projects on properties that are listed or eligible for listing on the National Register of 

Historic Places. Section 106 also applies if there are any federal involvements, such as 

licenses, permits, approvals or funding. 

13(b) Agency Comments. DHR finds that the SEIS accurately reflects consultation to 

date and adequately addresses agency concerns. DHR strongly supports Dominion's 

commitments in the SEIS (section 4.6) which will provide for the continued 

consideration and protection of historic properties. 

13(c) Requirement. If the NRC and Dominion are unable or unwilling to abide by the 

commitments, additional consultation on the impacts of the COL on historic properties 

will be necessary pursuant to Section 106. 

13(d) Conclusion. Provided the commitments are met, DHR finds that a determination 

of no adverse effect to historic properties is appropriate. 

For additional information, contact Roger Kirchen, DHR at (804) 367-2323, ext. 153. 

14. Transportation Impacts. The document (page 4-14, section 4.5.4.1) notes that 

the NRC conciuded in the ESP EiS that if the planned upgrades and improvements to 

the road systems in the region are implemented, the temporary impacts of construction 

on transportation in the region would be small to moderate, and further mitigation 

beyond the actions stated above would not be warranted. Furthermore, the document 

(page 5-19, section 5.5.4.1) states that new information since the ESP EIS was 

prepared indicates that although the overall population in the region of the NAPS Site is 

growing more rapidly than estimated in the ESP EIS, the operations workforce for Unit 3 

will be smaller than contemplated in the ESP EIS (500 workers rather than 720). 

14(a) Agency Comments. According to VDOT, while the comments provided below 

are presented by county, the comments should not necessarily be considered countyspecific. 

Hanover County 

Despite .the conclusion in the SEIS (page 5-19, section 5.5.4.1) that the transportation 

impacts may be small, it is not possible to determine the impact of the project on 

Hanover. County until more detailed information on the distribution of traffic is provided. 

This development is in a rural area where the impacts on these low-volume·roads may 

be relatively higher than in an urban area. Note that VDOT does not normally make 

temporary improvements for construction-related traffic as the SEIS (page 5-19, section 

5.5.4.1) appears to suggest. 

20 

Combined License (COL) for North Anna Power Station Unit 3 

ensures that federal actions comply with Section 106 of the National Historic 

Preservation Act of 1962 (NHPA), as amended, and its implementing regulation at 36 

CFR Part 800. The NHPA requires federal agencies to consider the effects of federal 

projects on properties that are listed or eligible for listing on the National Register of 

Historic Places. Section 106 also applies if there are any federal involvements, such as 

licenses, permits, approvals or funding. 

13(b) Agency Comments. DHR finds that the SEIS accurately reflects consultation to 

date and adequately addresses agency concerns. DHR strongly supports Dominion's 

commitments in the SEIS (section 4.6) which will provide for the continued 

consideration and protection of historic properties. 

13(c) Requirement. If the NRC and Dominion are unable or unwilling to abide by the 

commitments, additional consultation on the impacts of the COL on historic properties 

will be necessary pursuant to Section 106. 

13(d) Conclusion. Provided the commitments are met, DHR finds that a determination 

of no adverse effect to historic properties is appropriate. 

For additional information, contact Roger Kirchen, DHR at (804) 367-2323, ext. 153. 

14. Transportation Impacts. The document (page 4-14, section 4.5.4.1) notes that 

the NRC conciuded in the ESP EiS that if the planned upgrades and improvements to 

the road systems in the region are implemented, the temporary impacts of construction 

on transportation in the region would be small to moderate, and further mitigation 

beyond the actions stated above would not be warranted. Furthermore, the document 

(page 5-19, section 5.5.4.1) states that new information since the ESP EIS was 

prepared indicates that although the overall population in the region of the NAPS Site is 

growing more rapidly than estimated in the ESP EIS, the operations workforce for Unit 3 

will be smaller than contemplated in the ESP EIS (500 workers rather than 720). 

14(a) Agency Comments. According to VDOT, while the comments provided below 

are presented by county, the comments should not necessarily be considered countyspecific. 

Hanover County 

Despite .the conclusion in the SEIS (page 5-19, section 5.5.4.1) that the transportation 

impacts may be small, it is not possible to determine the impact of the project on 

Hanover. County until more detailed information on the distribution of traffic is provided. 

This development is in a rural area where the impacts on these low-volume·roads may 

be relatively higher than in an urban area. Note that VDOT does not normally make 

temporary improvements for construction-related traffic as the SEIS (page 5-19, section 

5.5.4.1) appears to suggest. 

20 
Appendix F 

February 2010 F-45 NUREG-1917, SEIS 

Combined License (COL) for North Anna Power Station Unit 3 

SpotsylvanIa County 

Based on the information provided, it was also difficult to determine transportation 

impacts in Spotsylvania County. Availability of the traffic management plan, and 

VDOT's role, referenced in the document would assist in further evaluation. VDOT 

anticipates that the road network should be able to handle the addition of 500 

employees. However, (;lVerweight loads due to construction traffic, may cause 

excessive impacts to the surrounding road system and road improvements or road 

repair may be required. A funding source for this work has not been addressed in the 

SEIS. Note that some of the planned road improvements that would serve this site no 

longer have public funds allocated, delaying the proposed work. 

14(b) Recommendations. VDOT recommends that the final SEIS should include a 

discussion and analysis of the following: 

• The expected traffic distribution (for construction-related traffic and for 

operations) and the effects upon the state highways and intersections .. 

• Where construction workers and additional employees will be housed, routes 

traveled to work, and the number of work shifts. 

• An updated evacuation plan that addresses the area of impact in the event of 

an emergency is desired based on the proposed improvements described in 

the SEIS. 

For additional information regarding these comments, contact Melanie Allen, VDOT at 

(804) 786-0868. 

15. Emergency Planning. According to the SEIS (page 1-4, section 1.1.2), the NRC 

analyzes the safety characteristics of the proposed site and emergency planning 

information in a Safety Evaluation Report (SER). The SER presents the conclusions 

reached by the NRC regarding (1) whether there is reasonable assurance that an 

ESBWR can be constructed and operated at the NAPS site without undue risk to the 

health and safety of the public; and (2) whether the emergency preparedness program 

meets the applicable requirements in 10 CFR Part 50, 10 CFR Part 52, 10 CFR Part 73, 

and 10 CFR Part 100. The SER review is separate from the environmental review 

process. 

15(a) Agency Review. The Virginia Department of State Police (DSP) and Virginia 

Department of Emergency Management (OEM) did not respond to DEQ's request for 

comments on the SEIS. 

21 

Combined License (COL) for North Anna Power Station Unit 3 

SpotsylvanIa County 

Based on the information provided, it was also difficult to determine transportation 

impacts in Spotsylvania County. Availability of the traffic management plan, and 

VDOT's role, referenced in the document would assist in further evaluation. VDOT 

anticipates that the road network should be able to handle the addition of 500 

employees. However, (;lVerweight loads due to construction traffic, may cause 

excessive impacts to the surrounding road system and road improvements or road 

repair may be required. A funding source for this work has not been addressed in the 

SEIS. Note that some of the planned road improvements that would serve this site no 

longer have public funds allocated, delaying the proposed work. 

14(b) Recommendations. VDOT recommends that the final SEIS should include a 

discussion and analysis of the following: 

• The expected traffic distribution (for construction-related traffic and for 

operations) and the effects upon the state highways and intersections .. 

• Where construction workers and additional employees will be housed, routes 

traveled to work, and the number of work shifts. 

• An updated evacuation plan that addresses the area of impact in the event of 

an emergency is desired based on the proposed improvements described in 

the SEIS. 

For additional information regarding these comments, contact Melanie Allen, VDOT at 

(804) 786-0868. 

15. Emergency Planning. According to the SEIS (page 1-4, section 1.1.2), the NRC 

analyzes the safety characteristics of the proposed site and emergency planning 

information in a Safety Evaluation Report (SER). The SER presents the conclusions 

reached by the NRC regarding (1) whether there is reasonable assurance that an 

ESBWR can be constructed and operated at the NAPS site without undue risk to the 

health and safety of the public; and (2) whether the emergency preparedness program 

meets the applicable requirements in 10 CFR Part 50, 10 CFR Part 52, 10 CFR Part 73, 

and 10 CFR Part 100. The SER review is separate from the environmental review 

process. 

15(a) Agency Review. The Virginia Department of State Police (DSP) and Virginia 

Department of Emergency Management (OEM) did not respond to DEQ's request for 

comments on the SEIS. 

21 
Appendix F 

NUREG-1917, SEIS F-46 February 2010 

Combined License (COL) for North Anna Power Station Unit 3 

1S{b) Recommendation. DEQ recommends that NRC coordinate the development of 

the SER with OEM and DSP and provide them the opportunity to review and comment 

on the final document. 

16. Regional Planning District Review. 

16{a) Agency Jurisdiction. In accordance with the Code of Virginia, Section 15.2-

4207, planning district commissions encourage and facilitate local government 

cooperation and state-local cooperation in addresSing, on a regional basiS, problems of 

greater than local significance. The cooperation resulting from this is intended to 

facilitate the recognition and analysis of regional opportunities and take account of 

regional influences in planning and implementing public policies and services. Planning 

district commissions promote the orderly and efficient development of the physical, 

social and economic elements of the districts by planning, and encouraging and 

aSSisting localities to plan, for the future. 

16(b) Agency Comments. The Thomas Jefferson Planning District Commission 

(T JPDC) reviewed the SEIS and has no comments. The George Washington Regional 

Commission and Rappahannock-Rapidan Planning District Commission did not 

respond to DEQ's request for comments on the SEIS. 

Contact Rochelle Garwood, T JPDC at (434) 979-7310. 

17. Local Review. DEQ distributes NEPA documents to the chief administrative officer 

of every locality potentially impacted by the proposal. The purpose of the distripution is 

to enable the locality to evaluate the proposed project for environmental impact, 

conSistency with the locality's comprehensive plan, local ordinances and other 

applicable law and to provide the locality with an opportunity to comment. DEQ solicits 

their comments, and consider their responses in substantially the same manner as 

DEQ solicits and receives comments from state agencies. 

17(a) Agency Response. DEQ solicited comments on the SEIS from the Counties of 

Louisa, Orange, Spotsylvania and Hanover, and the Town of Mineral. However, no 

local comments on the proposal were received by DEQ. 

18. Pollu.tlon Prevention. DEQ advocates that principles of pollution prevention be 

used in all construction projects as well as in facility operations. Effective siting, 

planning, and on-site Best Management Practices (BMPs) will help to ensure that 

environmental impacts are minimized. However, pollution prevention techniques also . 

include decisions related to construction materials, deSign, and operational procedures 

that will facilitate the reduction of wastes at the source. 

18{a) Recommendations. We have several pollution prevention recommendations 

that may be helpful in the construction of this project and in the operation of the faCility: 

22 

Combined License (COL) for North Anna Power Station Unit 3 

1S{b) Recommendation. DEQ recommends that NRC coordinate the development of 

the SER with OEM and DSP and provide them the opportunity to review and comment 

on the final document. 

16. Regional Planning District Review. 

16{a) Agency Jurisdiction. In accordance with the Code of Virginia, Section 15.2-

4207, planning district commissions encourage and facilitate local government 

cooperation and state-local cooperation in addresSing, on a regional basiS, problems of 

greater than local significance. The cooperation resulting from this is intended to 

facilitate the recognition and analysis of regional opportunities and take account of 

regional influences in planning and implementing public policies and services. Planning 

district commissions promote the orderly and efficient development of the physical, 

social and economic elements of the districts by planning, and encouraging and 

aSSisting localities to plan, for the future. 

16(b) Agency Comments. The Thomas Jefferson Planning District Commission 

(T JPDC) reviewed the SEIS and has no comments. The George Washington Regional 

Commission and Rappahannock-Rapidan Planning District Commission did not 

respond to DEQ's request for comments on the SEIS. 

Contact Rochelle Garwood, T JPDC at (434) 979-7310. 

17. Local Review. DEQ distributes NEPA documents to the chief administrative officer 

of every locality potentially impacted by the proposal. The purpose of the distripution is 

to enable the locality to evaluate the proposed project for environmental impact, 

conSistency with the locality's comprehensive plan, local ordinances and other 

applicable law and to provide the locality with an opportunity to comment. DEQ solicits 

their comments, and consider their responses in substantially the same manner as 

DEQ solicits and receives comments from state agencies. 

17(a) Agency Response. DEQ solicited comments on the SEIS from the Counties of 

Louisa, Orange, Spotsylvania and Hanover, and the Town of Mineral. However, no 

local comments on the proposal were received by DEQ. 

18. Pollu.tlon Prevention. DEQ advocates that principles of pollution prevention be 

used in all construction projects as well as in facility operations. Effective siting, 

planning, and on-site Best Management Practices (BMPs) will help to ensure that 

environmental impacts are minimized. However, pollution prevention techniques also . 

include decisions related to construction materials, deSign, and operational procedures 

that will facilitate the reduction of wastes at the source. 

18{a) Recommendations. We have several pollution prevention recommendations 

that may be helpful in the construction of this project and in the operation of the faCility: 

22 
Appendix F 

February 2010 F-47 NUREG-1917, SEIS 

Combined License (COL) for North Anna Power Station Unit 3 .. 

• Consider development of an effective Environmental Management System 

(EMS). An effective EMS will ensure that the Dominion is committed to 

minimizing its environmental impacts, setting environmental goals, and achieving 

improvements in its environmental performance. DEQ offers EMS development 

. assistance and it recognizes facilities with effective Environmental Management 

Systems through its Virginia Environmental Excellence Program. 

• Consider environmental attributes·when purchasing materials. For example, the 

extent of recycled material content, toxicity level, and amount of packaging 

should be considered and can be specified in purchasing contracts. 

• Consider contractors' commitment to the environment (such as an EMS) when 

choosing contractors. Specifications regarding raw materials and construction 

practices can be incl.uded in contract documents and requests for proposals. 

• Choose sustainable materials and practices for infrastructure construction and 

design. These could include asphalt and concrete containing recycled materials, 

and integrated pest management in landscaping, among other things. 

• Integrate pollution prevention techniques into the airport maintenance and 

operation, to include the following: inventory control (record-keeping and 

centralized storage for hazardous materials), product substitution (use of nontoxic cleaners), and source reduction (fixing leaks, energy-efficient HVAC and 

equipment). Maintenance facilities should be designed with sufficient and 

suitable space to allow for effective inventory control and preventative 

maintenance. 

DEQ's Office of Pollution Prevention provides information and technical assistance 

relating to pollution prevention techniques and EMS. For more information, contact 

DEQ's Office of Pollution Prevention, Sharon Baxter at (804) 698-4344. 

FEDERAL CONSISTENCY UNDER THE COASTAL ZONE MANAGEMENT ACT 

Pursuant to the Coastal Zone Management Act of 1972, as amended, Dominion is 

required to determine the conSistency of its activities affecting Virginia's coastal 

resources or coastal uses with the Virginia Coastal Resources Management Program 

(VCP) (see section 307{c){1) of the Act and 15 CFR Part 930, sub-part D, section 

930.50 et seq.). This involves an analysis of the activities in light of the Enforceable 

Polices of the VCP (Attachment 1)), and submission of a consistency certification 

reflecting that analysis and committing Dominion to comply with the Enforceable 

Policies. This certification may be provided as part of the documentation concluding 

theNEPA SEIS review process, or independently, depending on Dominion's 

preference. We also invite Dominion to consider the VCP Advisory Policies 

(Attachment 2). . 

23 

Combined License (COL) for North Anna Power Station Unit 3 .. 

• Consider development of an effective Environmental Management System 

(EMS). An effective EMS will ensure that the Dominion is committed to 

minimizing its environmental impacts, setting environmental goals, and achieving 

improvements in its environmental performance. DEQ offers EMS development 

. assistance and it recognizes facilities with effective Environmental Management 

Systems through its Virginia Environmental Excellence Program. 

• Consider environmental attributes·when purchasing materials. For example, the 

extent of recycled material content, toxicity level, and amount of packaging 

should be considered and can be specified in purchasing contracts. 

• Consider contractors' commitment to the environment (such as an EMS) when 

choosing contractors. Specifications regarding raw materials and construction 

practices can be incl.uded in contract documents and requests for proposals. 

• Choose sustainable materials and practices for infrastructure construction and 

design. These could include asphalt and concrete containing recycled materials, 

and integrated pest management in landscaping, among other things. 

• Integrate pollution prevention techniques into the airport maintenance and 

operation, to include the following: inventory control (record-keeping and 

centralized storage for hazardous materials), product substitution (use of nontoxic cleaners), and source reduction (fixing leaks, energy-efficient HVAC and 

equipment). Maintenance facilities should be designed with sufficient and 

suitable space to allow for effective inventory control and preventative 

maintenance. 

DEQ's Office of Pollution Prevention provides information and technical assistance 

relating to pollution prevention techniques and EMS. For more information, contact 

DEQ's Office of Pollution Prevention, Sharon Baxter at (804) 698-4344. 

FEDERAL CONSISTENCY UNDER THE COASTAL ZONE MANAGEMENT ACT 

Pursuant to the Coastal Zone Management Act of 1972, as amended, Dominion is 

required to determine the conSistency of its activities affecting Virginia's coastal 

resources or coastal uses with the Virginia Coastal Resources Management Program 

(VCP) (see section 307{c){1) of the Act and 15 CFR Part 930, sub-part D, section 

930.50 et seq.). This involves an analysis of the activities in light of the Enforceable 

Polices of the VCP (Attachment 1)), and submission of a consistency certification 

reflecting that analysis and committing Dominion to comply with the Enforceable 

Policies. This certification may be provided as part of the documentation concluding 

theNEPA SEIS review process, or independently, depending on Dominion's 

preference. We also invite Dominion to consider the VCP Advisory Policies 

(Attachment 2). . 

23 
Appendix F 

NUREG-1917, SEIS F-48 February 2010 

Combined license (COL) for North Anna Power Station Unit 3 

However, in accordance with 15 CFR Part 930, §930.66, federally permitted activities 

previously determined to be consistent with the VCP, but which have not yet begun, 

require further coordination by the applicant if the proposed activity will affect any 

coastal use or resource in a substantially different way than originally described. 

Substantially different coastal effects are reasonably foreseeable if the applicant makes 

substantial changes in the proposed activity that are relevant to VCP Enforceable 

Policies, or if there are Significant new circumstances or information relevant to the 

proposed activity and the effects of that activity on any coastal use or resource. In the 

event that the referenced project affects any coastal use or resource in a substantially 

different way than originally described, Dominion must notify DEQ through a 

supplemental consistency certification. 

If you need clarification of these comments, please contact Ellie Irons at (804) 698-

4325 or John Fisher at (804) 698-4339. 

REGULATORY AND COORDINATION NEEDS 

1. Water Quality and Wetland Impacts. 

Virginia Water Protection Permit 

Water quality and wetland impacts associated with this proposal will require a Virginia 

Water Protection Permit issued by the DEQ Northem Regional Office pursuant to 

Virginia Code §62.1-44.15:5. Dominion's wetland delineation should be confirmed by 

the Corps. A Joint Permit Application may be obtained from and submitted to the 

Virginia Marine Resources Commission which serves as a clearinghouse for the jOint 

permitting process involving the. VMRC, DEQ, Corps, and local wetlands boards. For 

additional information and coordination, contact Trisha Beasley, DEQ-NRO at (703) 

583-3940. . 

Virginia Pollutant Discharge Elimination System 

The modification of Dominion's existing VPDES permit under Virginia Code 9 VAC 25-

31 should be coordinated with DEQ-NRO. For additional information and coordination, 

contact Bryant Thomas, DEQ-NRO at (703) 583-3843. 

2. Water Resources Management. Dominion shouid continue to work with DEa, 

OGIF, OCR and other appropriate natural resource agencies on finalizing operating 

rules to avoid and mitigate adverse impacts upon downstream resources. For more 

information, contact Scott Kudlas, DEQ at (804) 698-4456; John Kaufman, DGIF at 

(434) 296-4731; and Robert Munson; OCR at (804) 786-6140. 

24 

Combined license (COL) for North Anna Power Station Unit 3 

However, in accordance with 15 CFR Part 930, §930.66, federally permitted activities 

previously determined to be consistent with the VCP, but which have not yet begun, 

require further coordination by the applicant if the proposed activity will affect any 

coastal use or resource in a substantially different way than originally described. 

Substantially different coastal effects are reasonably foreseeable if the applicant makes 

substantial changes in the proposed activity that are relevant to VCP Enforceable 

Policies, or if there are Significant new circumstances or information relevant to the 

proposed activity and the effects of that activity on any coastal use or resource. In the 

event that the referenced project affects any coastal use or resource in a substantially 

different way than originally described, Dominion must notify DEQ through a 

supplemental consistency certification. 

If you need clarification of these comments, please contact Ellie Irons at (804) 698-

4325 or John Fisher at (804) 698-4339. 

REGULATORY AND COORDINATION NEEDS 

1. Water Quality and Wetland Impacts. 

Virginia Water Protection Permit 

Water quality and wetland impacts associated with this proposal will require a Virginia 

Water Protection Permit issued by the DEQ Northem Regional Office pursuant to 

Virginia Code §62.1-44.15:5. Dominion's wetland delineation should be confirmed by 

the Corps. A Joint Permit Application may be obtained from and submitted to the 

Virginia Marine Resources Commission which serves as a clearinghouse for the jOint 

permitting process involving the. VMRC, DEQ, Corps, and local wetlands boards. For 

additional information and coordination, contact Trisha Beasley, DEQ-NRO at (703) 

583-3940. . 

Virginia Pollutant Discharge Elimination System 

The modification of Dominion's existing VPDES permit under Virginia Code 9 VAC 25-

31 should be coordinated with DEQ-NRO. For additional information and coordination, 

contact Bryant Thomas, DEQ-NRO at (703) 583-3843. 

2. Water Resources Management. Dominion shouid continue to work with DEa, 

OGIF, OCR and other appropriate natural resource agencies on finalizing operating 

rules to avoid and mitigate adverse impacts upon downstream resources. For more 

information, contact Scott Kudlas, DEQ at (804) 698-4456; John Kaufman, DGIF at 

(434) 296-4731; and Robert Munson; OCR at (804) 786-6140. 

24 
Appendix F 

February 2010 F-49 NUREG-1917, SEIS 

Combined license (COL) for North Anna Power Station Unit 3 

3. Protected Plant Species. Dominion should contact Keith Tignor, VDACS at (804) 

786-3515 regarding the inclusion of information and analysis on the small whorled 

pogonia in the final SEIS. 

4. Erosion and,Sedlment Control and Stormwater Management. 

4(a) Erosion and Sediment Control, and Stormwa!er Management. Constiuction 

must comply with Virginia's Erosion and Sediment Control Law (Virginia Code 10.1-567) 

and regulations (4 VAC 50-30-30 ~ and Stormwater Management Law (Virginia 

Code 10.1-603.5) and regulations (4 VAC 3-20-210 et seq.) as locally administered. 

Local erosion and sediment control, and stormwater management requirements should 

be coordinated with the Louisa County Department of Community Development 

Planning and Zoning Division at (540) 967-3430. 

4(b) Virginia Stormwater Management Program General Permit for Stormwater 

Discharges from Construction Activities. For projects involving land-disturbing 

activities equal to or greater than one acre, Dominion is required to apply for registration 

coverage under the Virginia Stormwater Management Program General Permit for 

Discharges of Stormwater from Construction Activities. Specific questions regarding 

the Stormwater Management Program requirements should be directed to Holly Sepety 

with DCA at (804) 225-2613. 

5. AIr Quality Regulations. This project is subject to air regulations administered by 

the Department of Environmental Quality. The following sections of the Code of 

Virginia' and Virginia Administrative Code are applicable: . 

• 9 VAC 5-50-60 et seg. governing fugitive dust emissions; and 

• 9 VAC 5-40-5600 et seg., for open burning. 

The installation of fuel burning equipment (e.g. boilers and generators), may require a 

permit (9 VAC 5-80, Article 6 Permits for New and Modified Sources) prior to beginning 

construction of a facility. 

For more information and coordination contact Terry Darton; DEQ-NRO at (703) 583-

3845. Also, contact local Louisa County officials for information on any local 

requirements pertaining to open burning 

6. Solid and Hazardous Wastes. All solid waste, hazardous waste, and hazardous 

materials must be managed in accordance with all applicable federal, state, and local 

environmental regulations. Some of the applicable state laws and regulations are: 

• Virginia Waste Management Act (Code of Virginia Section 10.1-1400 et seq.); 

• Virginia Hazardous Waste Management Regulations (VHWMR) (9VAC 20-60); 

25 

Combined license (COL) for North Anna Power Station Unit 3 

3. Protected Plant Species. Dominion should contact Keith Tignor, VDACS at (804) 

786-3515 regarding the inclusion of information and analysis on the small whorled 

pogonia in the final SEIS. 

4. Erosion and,Sedlment Control and Stormwater Management. 

4(a) Erosion and Sediment Control, and Stormwa!er Management. Constiuction 

must comply with Virginia's Erosion and Sediment Control Law (Virginia Code 10.1-567) 

and regulations (4 VAC 50-30-30 ~ and Stormwater Management Law (Virginia 

Code 10.1-603.5) and regulations (4 VAC 3-20-210 et seq.) as locally administered. 

Local erosion and sediment control, and stormwater management requirements should 

be coordinated with the Louisa County Department of Community Development 

Planning and Zoning Division at (540) 967-3430. 

4(b) Virginia Stormwater Management Program General Permit for Stormwater 

Discharges from Construction Activities. For projects involving land-disturbing 

activities equal to or greater than one acre, Dominion is required to apply for registration 

coverage under the Virginia Stormwater Management Program General Permit for 

Discharges of Stormwater from Construction Activities. Specific questions regarding 

the Stormwater Management Program requirements should be directed to Holly Sepety 

with DCA at (804) 225-2613. 

5. AIr Quality Regulations. This project is subject to air regulations administered by 

the Department of Environmental Quality. The following sections of the Code of 

Virginia' and Virginia Administrative Code are applicable: . 

• 9 VAC 5-50-60 et seg. governing fugitive dust emissions; and 

• 9 VAC 5-40-5600 et seg., for open burning. 

The installation of fuel burning equipment (e.g. boilers and generators), may require a 

permit (9 VAC 5-80, Article 6 Permits for New and Modified Sources) prior to beginning 

construction of a facility. 

For more information and coordination contact Terry Darton; DEQ-NRO at (703) 583-

3845. Also, contact local Louisa County officials for information on any local 

requirements pertaining to open burning 

6. Solid and Hazardous Wastes. All solid waste, hazardous waste, and hazardous 

materials must be managed in accordance with all applicable federal, state, and local 

environmental regulations. Some of the applicable state laws and regulations are: 

• Virginia Waste Management Act (Code of Virginia Section 10.1-1400 et seq.); 

• Virginia Hazardous Waste Management Regulations (VHWMR) (9VAC 20-60); 

25 
Appendix F 

NUREG-1917, SEIS F-50 February 2010 

Combined License (COL) for North Anna Power Station Unit 3, 

• Virginia Solid Waste Management Regulations (VSWMR) (9VAC 20-80); and 

• Virginia Regulations for the Transportation of Hazardous Materials (9VAC 20-

·110). 

Some of the applicable Federal laws and regulations are: 

• Resource Conservation and Recovery Act (RCRA) (42 U.S.C. Section 6901 et 

seq.); 

• Title 40 of the Code of Federal Regulations; and 

• U.S. Department of Transportation Rules for Transportation of Hazardous 

materials (49 CFR Part 107). 

6(a) Asbestos-ContaInIng Material. II' is the responsibility of the owner or operator of 

a renovation or demolition activity, prior to the commencement of the renovation or 

demolition, to thoroughly inspect the affected part of the facility where the operation will 

occur for the presence of asbestos, including Category I and Category" nonfriable 

asbestos containing material (ACM). Upon classification as friable or non-friable, all 

waste ACM shall be disposed of in accordance with the Virginia Solid Waste 

Management Regulations (9 VAC 20-80-640), and transported in accordance with the 

Virginia regulations governing Transportation of Hazardous Materials (9 VAC 20-110-10 

et seq.). Contact the DEQ Waste Management Program for additional information, 

(804) 698-4021, and the Department of Labor and industry, Ronald L. Graham at (804) 

371-0444. 

6(b) Lead-Based Paint. If applicable, the proposed project must comply with the U.S. 

Department of Labor, Occupational Safety and Health Administration (OSHA) 

regulations, and with the Virginia Lead-Based Paint Activities Rules and Regulations. 

For additional information regarding these requirements contact the Department of 

Professional and Occupational Regulation, David Dick at (804) 367-8588. 

7. Storage Tank Registration. Dominion must register portable ASTs (>660 gallons) 

associated with this proposed action with DEQ. Registration forms are available on 

DEQ's web site at http://www.deg.virginia.gov/tankslfnf.html#forms. The registration 

should be mailed to the DEQ address listed on the form along with the listed 

registration fee. For additional information contact Cynthia Sale, DEQ Northern 

Regional Office at (703) 583-3830. 

8. Forest Resources. Dominion may contact Todd Groh, VDOF at (434) 977-6555, 

ext. 3344, regarding potential opportunities for mitigation of the loss of trees from forest 

clearing due to construction. 

26 

Combined License (COL) for North Anna Power Station Unit 3, 

• Virginia Solid Waste Management Regulations (VSWMR) (9VAC 20-80); and 

• Virginia Regulations for the Transportation of Hazardous Materials (9VAC 20-

·110). 

Some of the applicable Federal laws and regulations are: 

• Resource Conservation and Recovery Act (RCRA) (42 U.S.C. Section 6901 et 

seq.); 

• Title 40 of the Code of Federal Regulations; and 

• U.S. Department of Transportation Rules for Transportation of Hazardous 

materials (49 CFR Part 107). 

6(a) Asbestos-ContaInIng Material. II' is the responsibility of the owner or operator of 

a renovation or demolition activity, prior to the commencement of the renovation or 

demolition, to thoroughly inspect the affected part of the facility where the operation will 

occur for the presence of asbestos, including Category I and Category" nonfriable 

asbestos containing material (ACM). Upon classification as friable or non-friable, all 

waste ACM shall be disposed of in accordance with the Virginia Solid Waste 

Management Regulations (9 VAC 20-80-640), and transported in accordance with the 

Virginia regulations governing Transportation of Hazardous Materials (9 VAC 20-110-10 

et seq.). Contact the DEQ Waste Management Program for additional information, 

(804) 698-4021, and the Department of Labor and industry, Ronald L. Graham at (804) 

371-0444. 

6(b) Lead-Based Paint. If applicable, the proposed project must comply with the U.S. 

Department of Labor, Occupational Safety and Health Administration (OSHA) 

regulations, and with the Virginia Lead-Based Paint Activities Rules and Regulations. 

For additional information regarding these requirements contact the Department of 

Professional and Occupational Regulation, David Dick at (804) 367-8588. 

7. Storage Tank Registration. Dominion must register portable ASTs (>660 gallons) 

associated with this proposed action with DEQ. Registration forms are available on 

DEQ's web site at http://www.deg.virginia.gov/tankslfnf.html#forms. The registration 

should be mailed to the DEQ address listed on the form along with the listed 

registration fee. For additional information contact Cynthia Sale, DEQ Northern 

Regional Office at (703) 583-3830. 

8. Forest Resources. Dominion may contact Todd Groh, VDOF at (434) 977-6555, 

ext. 3344, regarding potential opportunities for mitigation of the loss of trees from forest 

clearing due to construction. 

26 
Appendix F 

February 2010 F-51 NUREG-1917, SEIS 

Combined License (COL) for North Anna Power Station Unit 3 

9. Transportation Impacts. Dominion should contact Melanie Allen, VDOT at (804) 

786-0868, regarding additional information and analysis on potential traffic impacts of 

the proposal for the final SEIS. 

Thank you for the opportunity to review the Draft Supplemental Environmental Impact 

. Statement for the Combined License (COL) for North Anna Power Station Unit 3 in 

Louisa County. Detailed comments of reviewing agencies are attached for your review. 

Please contact me at (804) 698-4325 or John Fisher at (804) 698-4339 for clarification 

of these comments. . . 

Sincerely, 

Ellie Irons, Manager 

Office of Environmenta'·'mp~ct Review 

Enclosures 

cc: David Davis, DEQ-OWWP 

David Hartshorn, DEQ-NRO 

Paul Kohler, DEQ-ORP 

Tony Watkinson, VMRC 

Amy Ewing, DGIF 

Keith Tignor, VDACS 

Todd Groh, VDF 

Matt Heller, DMME 

Pam Mason, VIMS 

Ethel Eaton, DHR 

Barry Matthews, VDH 

Melanie Allen, VDOT 

Mike Cline, DEM 

Ronnie Rice, DSP 

Eugene Stockton, DSP 

Lee Lintecum, Louisa County 

Bill Rolfe, Orange County 

James Wheeler, Spotsylvania County 

Rhu Harris, Hanover County 

Willie Harper; Town of Mineral 

Billie Campbell, Thomas Jefferson PDC 

Robert Wilson, George Washington Regional Commission 

Jeffrey Walker, Rappahannock-Rapidan PDC 

27 

Combined License (COL) for North Anna Power Station Unit 3 

9. Transportation Impacts. Dominion should contact Melanie Allen, VDOT at (804) 

786-0868, regarding additional information and analysis on potential traffic impacts of 

the proposal for the final SEIS. 

Thank you for the opportunity to review the Draft Supplemental Environmental Impact 

. Statement for the Combined License (COL) for North Anna Power Station Unit 3 in 

Louisa County. Detailed comments of reviewing agencies are attached for your review. 

Please contact me at (804) 698-4325 or John Fisher at (804) 698-4339 for clarification 

of these comments. . . 

Sincerely, 

Ellie Irons, Manager 

Office of Environmenta'·'mp~ct Review 

Enclosures 

cc: David Davis, DEQ-OWWP 

David Hartshorn, DEQ-NRO 

Paul Kohler, DEQ-ORP 

Tony Watkinson, VMRC 

Amy Ewing, DGIF 

Keith Tignor, VDACS 

Todd Groh, VDF 

Matt Heller, DMME 

Pam Mason, VIMS 

Ethel Eaton, DHR 

Barry Matthews, VDH 

Melanie Allen, VDOT 

Mike Cline, DEM 

Ronnie Rice, DSP 

Eugene Stockton, DSP 

Lee Lintecum, Louisa County 

Bill Rolfe, Orange County 

James Wheeler, Spotsylvania County 

Rhu Harris, Hanover County 

Willie Harper; Town of Mineral 

Billie Campbell, Thomas Jefferson PDC 

Robert Wilson, George Washington Regional Commission 

Jeffrey Walker, Rappahannock-Rapidan PDC 

27 
Appendix F 

NUREG-1917, SEIS F-52 February 2010 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION.III 

1650 ATch Street 

Philadelphia, Pennsylvania 19103-2029 

, March 20,2009 

'Ms. Alicia WiIliamson 

T~D32 

U.S, Nuclear Regulatory Commission 

'Washington, DC 20555-0001 

/&/021/~?, 

1:3,P1<... 77;tl~' 

, (!!) w 

~. 

U'1 

.J:: 

RE: Draft Supplemental Environmental Impact Statement for the Coinbined License for North ' 

Anna Power Station Unit 3 ESP Site-NUREG- i917. 

Dear Ms. Williamson: 

In acco;Uance with Section 102(2) (C) of the National Environmental Policy Act (NEPA), 

, 42 U.S.C. § 4332(2) (C), Section 309 of the Clean Air Act, 42 U.S.C. § 7609, and the Council on 

Environmental Quality (CEQ) regiJlations,40 CFR Parts.1500-1508, the United States 

Environmental Protection Agency (EPA), has reviewed the Draft Supplemental Environmental 

Impact Statement (SEIS) for the above referenced project. The Draft SEIS was prepared to assess 

the potential envirorimental impacts that would result from. the constructlop and operation of an 

additional ilUclear power unit (Unit 3) at the North Anna Power Station (NAPS). 

On November 27, 2007 Dominion Nuclear North Anna LLC cProject sponsor) w~ 

issued an Early Site Pennit(ESP) by the NR(,:for the NAPS. The ESP gives approval of the, 

suitability for tJieconstruction and operation, at the NAPS for ,one or more new 'nuclear units. 

The environmental'review oftJiis action was documented in the'En,,~oronental Impact Statement 

, for the Early Site Permit at fueNorth Alina Site (ESP-EIS, publish~d December 2006). The 

Draft SElS provides for a subsequent environmental review related to the proposal by Dominion 

Nuclear North Aruia UC toconstriii:t~d'o~ekt~ ah Economic, SiwpHfied1;lQiling,Water', 

Reactor ~ Unit 3: WIth a total combined therina(power rating of 4500: megawatts at its NAPS in 

Louisa CoUnty, Virginia. The proposed umt would use a closed-cycle, combination dry, and wet 

cooling tower sYstem, with makeup water supplied by Lake Anna. The proposed project would 

also include the construction of it new 15 mile 500-kV transmissiQn ,li,ne,()I)..e~isting right of way 

to support the proposed Unit 3. The Drill SE~S rf,lference~ the.ESpcJ,l.~S,and provides for. the 

environmental reviewofnew'anc:\ sisnificaritiiUc;>nlj~ti~ri.· ", , ' 

, EPA has reviewed the Draft SEIS: Whiie EPA cortiniendstl!e applicant for its efforts to 

redUCe the volume of dIscharge from Uni( 3: EPA continues to have concerns regarding the 

thermal discharge froin tlie proposect Unit 3 cQnsistentwitb those e~pressed in our August 28, 

2006 comments op thti"Supplemental Envirorimentai Impact Statement for the Early Site Permit. 

As you know, the existing Units 1 and 2 have a thennal variance under Virginia's Pollution 

Discharge Elimination System (VPDES) permit.. While the .VPDES pennit fs protective of water 

quality, thermal discharges may decrease the le~el of dissolved oxygen in the water adding stress ' 

to the aquatic community. EPA has ecological concems with the cumulative unpacts to the lake 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION.III 

1650 ATch Street 

Philadelphia, Pennsylvania 19103-2029 

, March 20,2009 

'Ms. Alicia WiIliamson 

T~D32 

U.S, Nuclear Regulatory Commission 

'Washington, DC 20555-0001 

/&/021/~?, 

1:3,P1<... 77;tl~' 

, (!!) w 

~. 

U'1 

.J:: 

RE: Draft Supplemental Environmental Impact Statement for the Coinbined License for North ' 

Anna Power Station Unit 3 ESP Site-NUREG- i917. 

Dear Ms. Williamson: 

In acco;Uance with Section 102(2) (C) of the National Environmental Policy Act (NEPA), 

, 42 U.S.C. § 4332(2) (C), Section 309 of the Clean Air Act, 42 U.S.C. § 7609, and the Council on 

Environmental Quality (CEQ) regiJlations,40 CFR Parts.1500-1508, the United States 

Environmental Protection Agency (EPA), has reviewed the Draft Supplemental Environmental 

Impact Statement (SEIS) for the above referenced project. The Draft SEIS was prepared to assess 

the potential envirorimental impacts that would result from. the constructlop and operation of an 

additional ilUclear power unit (Unit 3) at the North Anna Power Station (NAPS). 

On November 27, 2007 Dominion Nuclear North Anna LLC cProject sponsor) w~ 

issued an Early Site Pennit(ESP) by the NR(,:for the NAPS. The ESP gives approval of the, 

suitability for tJieconstruction and operation, at the NAPS for ,one or more new 'nuclear units. 

The environmental'review oftJiis action was documented in the'En,,~oronental Impact Statement 

, for the Early Site Permit at fueNorth Alina Site (ESP-EIS, publish~d December 2006). The 

Draft SElS provides for a subsequent environmental review related to the proposal by Dominion 

Nuclear North Aruia UC toconstriii:t~d'o~ekt~ ah Economic, SiwpHfied1;lQiling,Water', 

Reactor ~ Unit 3: WIth a total combined therina(power rating of 4500: megawatts at its NAPS in 

Louisa CoUnty, Virginia. The proposed umt would use a closed-cycle, combination dry, and wet 

cooling tower sYstem, with makeup water supplied by Lake Anna. The proposed project would 

also include the construction of it new 15 mile 500-kV transmissiQn ,li,ne,()I)..e~isting right of way 

to support the proposed Unit 3. The Drill SE~S rf,lference~ the.ESpcJ,l.~S,and provides for. the 

environmental reviewofnew'anc:\ sisnificaritiiUc;>nlj~ti~ri.· ", , ' 

, EPA has reviewed the Draft SEIS: Whiie EPA cortiniendstl!e applicant for its efforts to 

redUCe the volume of dIscharge from Uni( 3: EPA continues to have concerns regarding the 

thermal discharge froin tlie proposect Unit 3 cQnsistentwitb those e~pressed in our August 28, 

2006 comments op thti"Supplemental Envirorimentai Impact Statement for the Early Site Permit. 

As you know, the existing Units 1 and 2 have a thennal variance under Virginia's Pollution 

Discharge Elimination System (VPDES) permit.. While the .VPDES pennit fs protective of water 

quality, thermal discharges may decrease the le~el of dissolved oxygen in the water adding stress ' 

to the aquatic community. EPA has ecological concems with the cumulative unpacts to the lake 
Appendix F 

February 2010 F-53 NUREG-1917, SEIS 

due to thennal discharge from the existing units, the proposed Unit 3 and the low dissolved 

oxygen levels from several lake tributaries. As a result, EPA believes that Dominion Nuclear 

. North Anna LLC should consider additional mitigative measures to offset the potential thermal 

discharge impacts: 

Primarily because of this concern, EPA has rated the Dratl SEIS as "Enviromnental 

Concerns" (EC - 1) for its enviromnental impact. An EC rating means the review has identified 

enviromnenml impa~ts that should be avoided in order to fully protect the enviromnel1t. ~ 

Corrective measures may require changes to the preferred alternative or application <if mitiga,.tion 

. measures that can reduce the environmental impact. The nUll)eric rating assesses the adequacy of 

the Enviromnental IrnpactStatement. The' numeric 1 rating indicates that the Draft SEIS 

adequately sets forth the enviromnental impact(s) of the preferred alternative. A'copy of our 

rating system is attached.. • . . .... . 

EPA appreciates the opportunity to submit «omments on ·the Draft SEISfor the North 

AnnaProjectand would be pleased tei discuss our coricern regarding the project. Please feel free 

to contact me o'r Kevin Mag~rr at (215) 814-5724, if you wish to discuss our concerns further. 

Attachment: EPA Rating SystemCIjteria 

Sincerely, 

d(.--~C;I'- lJ ... - . Je1!1; Lapp, Associat~DirecC9 Office of Environmental Programs 

. 0 Printed Dill 00% recycledlrecyclable paper with 100% post-consumer fiber lind process chlorine free. 

Customer Service Hotline: 1-800-438-2474 

due to thennal discharge from the existing units, the proposed Unit 3 and the low dissolved 

oxygen levels from several lake tributaries. As a result, EPA believes that Dominion Nuclear 

. North Anna LLC should consider additional mitigative measures to offset the potential thermal 

discharge impacts: 

Primarily because of this concern, EPA has rated the Dratl SEIS as "Enviromnental 

Concerns" (EC - 1) for its enviromnental impact. An EC rating means the review has identified 

enviromnenml impa~ts that should be avoided in order to fully protect the enviromnel1t. ~ 

Corrective measures may require changes to the preferred alternative or application <if mitiga,.tion 

. measures that can reduce the environmental impact. The nUll)eric rating assesses the adequacy of 

the Enviromnental IrnpactStatement. The' numeric 1 rating indicates that the Draft SEIS 

adequately sets forth the enviromnental impact(s) of the preferred alternative. A'copy of our 

rating system is attached.. • . . .... . 

EPA appreciates the opportunity to submit «omments on ·the Draft SEISfor the North 

AnnaProjectand would be pleased tei discuss our coricern regarding the project. Please feel free 

to contact me o'r Kevin Mag~rr at (215) 814-5724, if you wish to discuss our concerns further. 

Attachment: EPA Rating SystemCIjteria 

Sincerely, 

d(.--~C;I'- lJ ... - . Je1!1; Lapp, Associat~DirecC9 Office of Environmental Programs 

. 0 Printed Dill 00% recycledlrecyclable paper with 100% post-consumer fiber lind process chlorine free. 

Customer Service Hotline: 1-800-438-2474 

Appendix G 

Environmental Impacts of Transportation 

February 2010 G-1 NUREG-1917, SEIS 

Appendix G 

Environmental Impacts of Transportation 

Appendix G of the North Anna early site permit environmental impact statement (ESP EIS) 

provides information on unirradiated fuel shipment; spent fuel shipment, and radioactive waste 

shipment from the North Anna Power Station. For each shipment areas, the environmental 

impacts are estimated along with information regarding transportation accidents. Any new 

information discovered since the preparation of the ESP EIS is provided in Section 6.2 of this 

supplemental EIS. Sections 4.8.3 and 5.8.6 provide information regarding the impact of 

transporting both construction and operational workers to the site, respectively. 

Appendix H 

Supporting Documentation on Radiological 

Dose Assessment 

February 2010 H-1 NUREG-1917, SEIS 

Appendix H 

Supporting Documentation on Radiological 

Dose Assessment 

Appendix H of the North Anna early site permit environmental impact statement (ESP EIS) 

provides information regarding the methodology and input data for dose estimates to the public 

from liquid effluents; from gaseous effluents, from airborne tritium releases from the proposed 

Unit 3 wet cooling towers; cumulative dose estimates; and dose estimates to biota from liquid 

and gaseous effluents. Revised dose estimates based on source terms for the proposed Unit 3 

reactor design are provided in Sections 4.9, 5.9, and 7.8 of this supplemental EIS. 

Appendix I 

Early Site Permit Site Characteristics and 

Plant Parameter Envelope 

February 2010 I-1 NUREG-1917, SEIS 

Appendix I 

Early Site Permit Site Characteristics and Plant 

Parameter Envelope 

Appendix I of the North Anna early site permit environmental impact statement (ESP EIS) 

provides the site specific plant parameter envelope values for the North Anna ESP site. For the 

ESP, the impacts of constructing two units, Units 3 and 4, were evaluated. The information 

listed in Appendix I is for a single unit value, which in most cases is identical for the proposed 

second unit. Under the ESP issued by the U.S. Nuclear Regulatory Commission, the value of 

the plant parameters listed in Appendix I of the ESP EIS are limiting values for receiving a 

combined license for up to two additional units at the North Anna ESP site. Based on the 

chosen reactor design, actual values or statement that the will not be exceeded for the various 

items are provided in appropriate sections of this supplemental EIS. 

Appendix J 

Early Site Permit Site Permit Conditions, 

Commitments, Assumptions, and 

Unresolved Issues 

February 2010 J-1 NUREG-1917, SEIS 

Appendix J 

Early Site Permit Site Permit Conditions, 

Commitments, Assumptions, and 

Unresolved Issues 

Appendix J of the North Anna early site permit environmental impact statement (ESP EIS) 

provides information on the ESP permit conditions, identifies assumptions, and lists the 

unresolved issues. Assumptions were listed according to various technical disciplines as well 

as by site conditions, mitigation of impacts, plant parameter envelope values, and identification 

of information that could affect the technical basis or conclusions for the determination of the 

impact levels identified in the ESP EIS. Permit conditions were incorporated in the ESP 

(ESP-003) that was issued by the U.S. Nuclear Regulatory Commission to Dominion Virginia 

Power and Old Dominion Electric Cooperative in November 2007. 

All unresolved issues have been addressed in the appropriate sections of this supplemental 

EIS. These unresolved issues fell into two categories: (1) those dependent on a specific 

reactor design that was identified in the combined license (COL) application, or (2) those that 

could be deferred until the submittal of the COL (e.g., need for power, energy alternatives, and 

alternatives to mitigate severe accidents). 

Appendix K 

Staff’s Independent Review of Water Budget Impacts 

February 2010 K-1 NUREG-1917, SEIS 

Appendix K 

Staff’s Independent Review of Water Budget Impacts 

Appendix K of the early site permit environmental impact statement (ESP EIS) provides 

(1) information regarding the methods used by the U.S. Nuclear Regulatory Commission staff 

in their independent assessment of the impacts of the proposed Unit 3’s closed-cycle, 

combination dry and wet cooling system and (2) the staff’s findings. The proposed reactor 

design and cooling system in the combined license application is similar to that evaluated in the 

staff’s independent review for North Anna Power Station ESP site, and the staff’s findings do not 

change from those documented in the ESP EIS. More specific information regarding the cooling 

system for the proposed Unit 3 is provided in Section 3.2.2 of this supplemental EIS. 

Appendix L 

Authorizations and Consultations 

February 2010 L-1 NUREG-1917, SEIS 

Appendix L 

Authorizations and Consultations 

Table L-1 contains a list of the environmental-related authorizations, permits, certifications, 

and consultations, potentially required by Federal, State, regional, local, and affected Native 

American tribal agencies for activities related to site preparation, construction, and operation of 

a potential new nuclear unit at the North Anna Power Station Unit 3 site. Specific information 

regarding each authorization has been added, in italicized format, in the Status column in 

Table L-1. 
NUREG-1917, SEIS L-2 February 2010

Appendix L Table L-1. Federal, State, and Local Authorizations and Consultations Agency Authority Requirement Activity Covered Status

Lake Anna Special Area Plan Committee 

N/A Conditional Land Use 

Approval 

Local land use approval – Lake Anna Overlay District, as need basis 

Consultation with Lake Anna Advisory Committee expected to be conducted following issuance of COL 

NRC 10 CFR Part 30 Byproduct Materials 

License 

NRC license to possess special nuclear materials 

To be issued with COL 

NRC 10 CFR Part 70 Special Nuclear 

Materials License 

NRC license to possess nuclear fuel To be issued with COL 

Virginia State Corporation Commission 

Code of Virginia, Section 56-265.2 and 56-46.1 

Certificate of Public Convenience and Necessity 

Approval for construction of new generating facility 

Necessary for construction 

VDEQ 9 VAC 5-20-160 Registration Annual re-certification of air emission 

sources from NAPS site 

Expected to be submitted with the (Air) Operating Permit application in 2011 

VDEQ Clean Air Act, 

9 VAC 5-80-800 

Operating Permit Operation of air emission sources Expected to be submitted 

in 2011 

VDEQ 9 VAC 5-80-800 Minor Source - General 

Permit 

Construction and operation of minor air emission sources 

Expected to be submitted in 2011, if applicable 

VDEQ CWA, Section 402; 

9 VAC 25-10 / 9 VAC-25-820 / 9 VAC- 25-790 

Virginia Pollutant Discharge Elimination System Permit (VPDES) / Nutrient General permit/ Sewage treatment Certificates 

Regulate limits of pollutants in liquid discharge to surface water 

Expected to be submitted for construction sewage discharge permit in 2010; for operational discharge permit 2011; for certificates to construct & operate sewage treatment plants To be determined (TBD) 

VDEQ 9 VAC 50-5-60 

et seq. 

Control and Abatement of Air Pollution 

Fugitive dust control Expected to be submitted 

with (Air) Operating Permit application in 2011 
Appendix L

February 2010 L-3 NUREG-1917, SEIS Table L-1. (contd) Agency Authority Requirement

Activity Covered Status

VDEQ 9 VAC 5-80, Article 6 Permits for New and 

Modified Stationary Sources 

Permit to install fuel burning equipment (e.g., boilers and generators) 

Expected to be submitted with (Air) Operating Permit application in 2011 

VDCR 9 VAC 25-180 General Permit Notice 

of Termination (NOT) for storm water discharges from construction activities (VDCR 199-147) 

Termination of coverage under the general permit for storm water discharge from construction site activities 

Expected to be conducted under general permit for phased constructionrelated activities beginning in 2010 

Virginia Department of Historic Resources (VDHR) 

National Historic Preservation Act, Section 106; 36 CFR Part 800 

Cultural Resources Survey/Consultation 

Determine location of historic/cultural resources at the North Anna Unit 3 site and any associated work areas. If resources are present, avoidance is recommended per the VDHR. 

Received last concurrence letter in 2009 

Virginia Department of Transportation (VDOT) 

24 VAC 30 et seq. Consultation Equipment transport routes employee 

and/or public access routes, level-ofservice review, transportation management plan 

Expected to be conducted in 2011 

Louisa County 4 VAC 50-30 Erosion and Sediment 

Control Plan 

Erosion and sediment control. Received ESCP 30-80 in 

2009 to support land disturbance beginning in 2010; Expected to be updated for additional phased constructionrelated activities beginning in 2011 

Appendix M 

Severe Accident Mitigation Alternatives 

February 2010 M-1 NUREG-1917, SEIS 

Appendix M 

Severe Accident Mitigation Alternatives 

M.1 Introduction 

Dominion Virginia Power and Old Dominion Electric Cooperative, collectively known as 

Dominion, have submitted an application to construct an Economic Simplified Boiling-Water 

Reactor (ESBWR) at the North Anna Power Station (NAPS). Current policy developed after the 

Limerick decision (Limerick 1989) requires that the U.S. Nuclear Regulatory Commission (NRC) 

staff consider alternatives to mitigate the consequences of severe accidents in a site-specific 

environmental impact statement (EIS). The severe accident mitigation alternative (SAMA) 

review presented here considers both severe accident mitigation design alternatives (SAMDAs) 

and procedural alternatives. 

In 10 CFR 52.79(a)(38), the NRC requires that applicants for combined licenses (COLs) include 

“... a description and analysis of design features for the prevention and mitigation of severe 

accidents.” The Environmental Report and the Final Safety Analysis Report in the Dominion

COL application (Dominion 2008) address these requirements. In 10 CFR 52.47(a)(23), the 

NRC requires that applications for a reactor design certification include “... a description and 

analysis of design features for the prevention and mitigation of severe accidents....” In addition, 

10 CFR 52.47(a)(27) requires a description of a “...plant-specific probabilistic risk assessment 

(PRA) and its results.” That information and related supplemental information in response to 

requests for additional information have been submitted by the applicant for design certification. 

In addition, the applicant for design certification has provided technical documents covering the 

ESBWR PRA (GE 2006; GEH 2008a; GEH 2009b) and ESBWR SAMDAs (GEH 2007). 

While the NRC has not completed its generic SAMDA review of the ESBWR for design 

certification, it has conducted a SAMDA review specific to operation of an ESBWR at the NAPS 

site. The analysis is based on: 

1. the most recent PRA and SAMDA submissions for the ESBWR design certification review 

2. results of the analysis of probability-weighted risks of an earlier ESBWR design at the 

NAPS early site permit (ESP) site is included in the ESP environmental impact statement 

(EIS) (NRC 2006) 

3. comparison of reactor core inventories, of severe accident release rates, and of core 

damage frequencies (CDFs) for the current design with those of the earlier design. 
Appendix M 

NUREG-1917, SEIS M-2 February 2010 

An analysis for an ESBWR at a generic site is presented first, and then the analysis is extended 

to include consideration of NAPS site-specific information. 

M.2 ESBWR SAMDA Review – Generic Site 

Chapter 10 of the ESBWR Probabilistic Risk Assessment (PRA) (GEH 2009b) provides an 

estimate of the offsite risk to the population within 80 km (50 mi) of a location with conservative 

siting characteristics. The baseline results of the PRA for internal events during full-power 

operation are presented and compared to the Commission’s individual and societal safety goals 

in Table M-1. These results indicate that the risk from severe accidents would be at least four 

orders of magnitude lower than the Commission’s Safety Goals (51 FR 30028). 

Table M-1. Comparison of ESBWR PRA Results for a Generic Site with the Commissions’ 

Safety Goals 

Goal Risk Goal 

ESBWR 

24 Hours After 

Onset of 

Core Damage 

(ground 

release)(a)

ESBWR 

72 Hours After 

Onset of 

Core Damage 

(elevated 

release)(b) 

Safety Goal 

Achieved 

72 Hours After 

the Onset of 

Core Damage 

Individual Risk 

(0 – 1 Mile) <3.9 × 10−7 1.6 × 10−10 1.6 × 10−10 Yes 

Societal Risk 

(0 – 10 Mile) <1.7 × 10−6 2.0 × 10−11 2.6 × 10−11 Yes 

Radiation Dose 

Probability at 

0.25 Sv 

(0 – 0.5 Mile) 

<10−6 2 × 10−9

 1.9 × 10−9 Yes 

(a) GEH 2009b, Table 10.4-1a 

(b) GEH 2009b, Table 10.4-1b 

Section 17.1 of the revised PRA lists the external event and shutdown CDF results. The values 

listed are of the same magnitude as those for the at-power internal events case. It is apparent 

that for the two safety goal measures, the total risk from all accidents (internal and external 

events) would not increase by more than an order of magnitude above the risk for only internal 

events. 
Appendix M 

February 2010 M-3 NUREG-1917, SEIS 

GE-Hitachi Nuclear Energy (GEH) affirmed that the individual risk and societal risk goals are 

maintained with a sufficient margin of safety. The risk results, together with supporting 

sensitivity studies, lead to the risk insight that public health and safety is well achieved in the 

ESBWR design, as shown by the PRA analysis. 

M.2.1 Potential Design Improvements 

In its ESBWR SAMDA assessment (GEH 2007), the design certification applicant identified 

177 candidate alternatives based on a review of alternatives for other plant designs, including 

those considered in license renewal environmental reports and the General Electric Advanced 

Boiling-Water Reactor (ABWR) SAMDA study (GE 1995). Certain design improvements were 

eliminated from further consideration because they were already incorporated into the ESBWR 

design. The following are examples of design enhancement features currently included in the 

ESBWR design: 

• improved isolation condenser system design 

• depressurization valves 

• A.C.-independent fire water pumps for makeup and injection 

• passive containment cooling system 

• basemat internal melt arrest and coolability device and gravity driven cooling system deluge 

function 

• D.C. power reliability 

• actuation logic reliability 

• motor-driven, feed-water pumps 

• water pool elevation above drywell head elevation 

• containment ultimate strength and maximum design pressure 

• incorporation of flood mitigation into design 

• reactor water cleanup system heat exchanger sized for decay heat removal 

• 72-hour coping period for station blackout (SBO) 

• upgraded low-pressure piping for the reactor coolant pressure boundary 

• digital instrumentation and control systems. 
Appendix M 

NUREG-1917, SEIS M-4 February 2010 

In the screening process, 42 candidate alternatives were eliminated as being inapplicable for 

the ESBWR design, 65 candidate alternatives were considered to be similar to those already 

included in the ESBWR design, 29 candidate alternatives were procedural or administrative 

rather than design alternatives (whose benefits were considered to be unlikely to exceed those 

alternatives evaluated relative to their potentially high costs), and 26 candidate alternatives 

were eliminated on the basis of their high cost relative to potential benefits. The remaining 

15 candidate alternatives were considered to have very low benefit because they would not 

significantly reduce risk. 

M.2.2 Risk Reduction Potential of Design Improvements 

The design certification applicant assumed that each design alternative would work perfectly 

to completely eliminate all severe accident risk from the internal events that were evaluated. 

This assumption is conservative as it maximizes the benefit of each design alternative. The 

applicant estimated the public exposure benefits for the design alternative on the basis of the 

reduction of risk expressed in terms of whole body person-rem per year received by the total 

population within an 80-km (50-mi) radius of the generic ESBWR site. 

The design certification applicant used the cost-benefit methodology found in Regulatory 

Analysis Technical Evaluation Handbook (NUREG/BR-0184) (NRC 1997) to calculate the 

maximum attainable benefit associated with completely eliminating all risk for the ESBWR. This 

methodology considers averted onsite and replacement power costs. The applicant estimated 

the present worth of eliminating all severe accident risk at about $4630. Increasing the offsite 

population doses and property damage costs by a factor of 10 and using maximum estimates 

for cleanup, decontamination, replacement power costs, the present worth increases to about 

$41,380. 

The design certification applicant’s risk reduction estimates are based on point-estimate (mean) 

values, without consideration of uncertainties in CDF or offsite consequences. Even though this 

approach is consistent with that used in previous design alternative evaluations, further 

consideration of these factors could lead to significantly higher risk reduction values, given the 

extremely small CDF and risk estimates in the baseline PRA. 

M.2.3 Cost Impacts of Candidate Design Improvements 

NEDO-33306, Revision 1, Licensing Topical Report, ESBWR Severe Accident Mitigation Design 

Alternatives (GEH 2007) did not assess the capital cost associated with the various design 

alternatives evaluated by the design certification applicant. The applicant maintained that the 

economic impacts of severe accidents, when combined with their associated frequencies, would 

result in an overall risk that is significantly lower than current operating reactors; therefore, any 

additional design modifications would be costly compared to any potential benefits. The 

applicant further indicated that any design modifications, including even a change of a 
Appendix M 

February 2010 M-5 NUREG-1917, SEIS 

manufacturer to reduce CDF, would incur approximately $2 million associated with the 

implementation of the supplier quality assurance program. 

M.2.4 Cost-Benefit Comparison 

The methodology used by GEH was based primarily on the NRC’s guidance for performing 

cost-benefit analysis outlined in NUREG/BR-0184 (NRC 2004). The guidance involves 

determining the net value for each SAMDA according to the following formula: 

Net Value = (APE + AOC + AOE + AOSC) – COE 

where APE = present value of averted public exposure ($) 

 AOC = present value of averted offsite property damage costs ($) 

 AOE = present value of averted occupational exposure costs ($) 

 AOSC = present value of averted onsite costs ($); this includes cleanup, 

 decontamination, and long-term replacement power costs 

 COE = cost of enhancement ($). 

If the net value of a SAMDA is negative, the cost of implementing the SAMDA is larger than 

the benefit associated with the SAMDA, and it is not considered to be cost beneficial. 

Table M-2 summarizes Dominion’s estimates of each of the associated cost elements. The 

provided results are based on the approach, parameters, and data listed in NUREG/BR-0184. 

The estimates in Table M-2 are based on the PRA Revision 1 CDF of 7.54 × 10−8

/yr (GEH 

2006). The total CDF in the updated PRA is 1.2 × 10−7

/yr (GEH 2009b). This value would 

increase the benefits listed in the table by a factor of about 1.5. 

The design certification applicant provided estimates using a 7-percent discount rate. The 

NRC recently issued Revision 4 of NUREG/BR-0058, “Regulatory Analysis Guidelines of the 

U.S. Nuclear Regulatory Commission,” (NRC 2004), which reflects the agency’s policy on 

discount rates. NUREG/BR-0058, Revision 4, states that two sets of estimates should be 

developed: one at 3 percent and one at 7 percent. Use of a 3-percent discount rate would 

result in an almost doubling of the estimated benefits. 

The monetary present value estimate for each risk attribute does not represent the expected 

reduction in risk resulting from a single accident; rather, it is the present value of a stream of 

potential losses extending over the projected lifetime of the facility (in this case projected to be 

60 years). Therefore, the estimate reflects the expected annual loss resulting from a single 

accident, the possibility that such an accident could occur at any time over the licensed life, and 

the effect of discounting these potential future losses to present value. 
Appendix M 

NUREG-1917, SEIS M-6 February 2010 

Table M-2. Summary of Estimated Averted Costs for a Generic Site 

Quantitative Attributes 

Present Value Estimate ($) 

Best(a) Maximum(b)

Health Public 366 3660c

Occupational 38 76 

Property Offsite 157 1570(c)

Onsite NA(d) NA(d)

Cleanup and 

decontamination 

Onsite 1167 1591 

Replacement power 2900 34,486 

Total 4628 41,383 

(a) “Best Estimate” is based on mean release frequency and “best estimate parameter values” 

(GEH 2006). 

(b) Maximum estimate is based on mean release frequency and high estimate parameter values. 

(c) Estimate is based on a factor of 10 increase in estimated dose or public property values. 

(d) Not analyzed. 

As indicated above, the design certification applicant estimated the total present dollar value 

equivalent associated with complete elimination of severe accidents at a single ESBWR unit site 

to range between $4628 and $41,383. The estimated cost of replacement power has the 

largest effect on the averted cost. For any SAMDA to be cost beneficial, the enhancement cost 

must be less than $41,383. Based on this cost estimate, the design certification applicant 

concluded that none of the SAMDA candidates are cost beneficial. 

M.2.5 Staff Evaluation 

In 10 CFR 52.47(a)(27), the NRC requires that an applicant for design certification describe and 

provide results of a design-specific PRA. The aim of this PRA is to seek improvements in the 

reliability of core and containment heat-removal systems that are significant and practical and 

do not impact excessively on the plant. The set of potential design improvements considered 

for the ESBWR includes those from generic boiling-water reactor SAMA reports and from the 

ABWR design. The ESBWR design already incorporates many design enhancements related to 

severe accident mitigation. Such design improvements have resulted in a CDF that is about an 

order of magnitude less than that of the ABWR design. For example, the ESBWR design can 

cope with an SBO for 72 hours (i.e., no reliance on A.C. power for the first 72 hours), thus 

eliminating core damage sequences that contributed more than 40 percent of CDF in the ABWR 

design. 

The design certification applicant’s estimates of risk do not account for uncertainties either in 

CDF or in offsite radiation exposures resulting from a core damage event. The uncertainties in 
Appendix M 

February 2010 M-7 NUREG-1917, SEIS 

both of these key elements are fairly large because key safety features of the ESBWR design 

are unique, and their reliability has been evaluated through analysis and testing programs rather 

than through operating experience. In addition, the estimates of CDF and offsite exposures do 

not account for the added risk from earthquakes. 

M.3 North Anna Site-Specific SAMDA Review 

The discussion above evaluates SAMDAs for the ESBWR at a generic site. The following 

discussion updates that evaluation to include consideration of NAPS site-specific factors, 

including meteorological conditions, population distribution, and land use. It also updates the 

evaluation to include the results of the most recent PRA for the generic design. The last part of 

this discussion deals with procedural SAMAs. 

M.3.1 Risk Estimates 

The NRC staff evaluated the potential risks associated with severe accidents for an 

ESBWR using NAPS site-specific data in the North Anna ESP EIS (NRC 2006). Table 5-20, 

in the ESP EIS reports a CDF of 2.9 × 10−8

 yr−1, and population dose and cost risks of 

3.3 × 10−3

 person-rem yr−1 and $4.85 yr−1, respectively. These risks are based on internally 

initiated events that occur while the reactor is at power. CDF estimates in NEDO-33306, 

Revision 1 (GEH 2007) indicate that the total CDF for all events including externally initiated 

events and events while the reactor is shutdown is about a factor of 2.5 higher than listed in the 

ESP EIS. 

The Dominion COL application (Dominion 2008) references an ESBWR design that is more 

recent than the design reviewed by the staff in the ESP EIS. Dominion reviewed the evaluation 

in the ESP EIS and concluded that there was no new and significant information. The ESBWR 

vendor has submitted a more recent design than referenced by Dominion and updated the 

ESBWR PRA (GEH 2009a, 2009b). The NRC staff considers the changes in the ESBWR 

design and PRA to be significant because the changes have the potential to impact the staff’s 

evaluation with respect to potential impacts of severe accidents. Consequently, the staff has 

evaluated the effects of the change in design on reactor-specific input to the consequence 

assessment. The staff compared the reactor core inventory, release fractions, and CDFs for 

the ESBWR design referenced in the COL application with the reactor core inventory, release 

fractions, and CDFs for the design reviewed in the ESP EIS. 

There were changes in release characteristics that would result in increases in consequences. 

The staff adjusted the population dose and cost consequences for each ESBWR release 

category in the ESBWR severe accident analysis in the ESP EIS to account for changes in 

CDFs. Although the total CDF for the current ESBWR is higher than that of the ESBWR design 

evaluated in the ESP EIS, there were several release categories for which the CDFs decreased. 

The net result of the changes in release category CDFs are (1) an increase in the population 
Appendix M 

NUREG-1917, SEIS M-8 February 2010 

risk from 3.3 × 10−3 person-rem yr−1 to about 7.2 × 10−3 person-rem yr−1 and (2) an increase in 

cost risks from $4.85 yr−1 to $16.00 yr−1. When external initiating events and events when the 

reactor is shutdown are considered, the risks are increased by about a factor of 6.9. 

The staff also considered changes in noble gas, cesium, and iodide release fractions for each of 

the release categories. There were only minor changes in the noble gas release fractions. The 

cesium and iodide release fractions decreased in 8 of the 10 release categories, including all of 

the release categories that contribute significantly to risk. The decreases ranged from about a 

factor of 2 to almost a factor 60. The risk estimates reported in the ESP EIS (NRC 2006) have 

not been adjusted to account for changes in release fractions because the total risk estimates 

are low, and the contribution to risk of individual isotopes is not readily available. 

Based on the comparisons of core inventories, CDFs and release fractions, and independent 

confirmatory calculations, the staff believes that the severe accident risks of the current ESBWR 

design are not significantly different than those of the design evaluated in the ESP EIS (NRC 

2006). The staff concludes that those risks are of SMALL significance. Finally, the staff 

believes that ESBWR severe accident risks discussed in the ESP EIS adjusted for differences 

in release category CDFs, externally initiated events, and events while the reactor is shut down 

are appropriate for use in the NAPS site-specific evaluation of ESBWR SAMAs. 

M.3.2 Cost-Benefit Comparison 

In assessing the risk reduction potential of design improvements for the ESBWR, the NRC staff 

has based its evaluation on the applicant’s risk reduction estimates for the various design 

alternatives, in conjunction with an assessment of the potential impact of uncertainties on the 

results. Using the methodology described above, the NRC staff revised the averted cost 

estimates in Table M-2 to reflect the updated ESBWR PRA (GEH 2009b) and NAPS sitespecific parameters. The results are presented in the columns for the NAPS site in Table M-3. 

The analysis presented in Tables M-2 and M-3 present the value of reducing the severe 

accident risk to zero. These values are used in screening potential SAMDAs. Using the results 

in Table M-2, the applicant for design certification concluded that no candidate alternative from 

an initial list of 177 alternatives would be cost beneficial. The NAPS site-specific values are 

lower than those estimated for a generic site and are far below the minimum estimated cost for 

a design change. 
Appendix M 

February 2010 M-9 NUREG-1917, SEIS 

Table M-3. Summary of Estimated Averted Costs for the NAPS Site 

Quantitative Attributes 

Present Value Estimate ($) 

GEH(a) NAPS Site(b)

Best(c) Maximum(d) 7% Discount 3% Discount 

Health Public 366 3660(e) 295(f) 584(f)

Occupational 38 76 58 258 

Property Offsite 157 1570(e)

 282(f) 557(f)

Onsite NA(g) NA(g)

 NA(g) NA(g)

Cleanup and 

Decontamination 

Onsite 1167 1591 1795 3550 

Replacement 

Power 

 2900 34,486 462 5488 

Total 4628 41,383 2892 10,371 

(a) GEH estimates are based on a CDF of 7.54 × 10−8 yr−1 from PRA Revision 1 (GEH 2006). 

(b) NRC staff estimates are based on PRA Revision 4 CDF estimates and NAPS site-specific parameters. 

(c) “Best estimate” is based on mean release frequency (from PRA Revision 1) and “best estimate” 

parameter values. 

(d) Maximum estimate is based on mean release frequency (PRA Revision 1) and high estimate parameter 

values. 

(e) Estimate is based on a factor of 10 increase in estimated dose or public property. 

(f) North Anna specific value based on risk from ESP EIS adjusted for changes in release category CDFs. 

(g) Not analyzed. 

The original list of 177 ESBWR SAMDAs included 29 candidate alternatives that were 

procedural or administrative in nature. These items were eliminated from consideration 

because they did not involve design changes. However, these candidate alternatives fall within 

the scope of the SAMA review that the NRC staff conducts as part of its environmental review of 

applications. The staff reviewed the candidate alternatives that were previously removed from 

consideration because they did not involve design changes. Following are examples of items 

removed from consideration for this reason: 

• enhance procedural guidance for use of cross-tied component cooling or service water 

pumps 

• implement procedures for alignment of a spare diesel to shutdown board after loss of offsite 

power and failure of diesel normally supplying it 

• emphasize steps in recovery of offsite power after an SBO 

• develop a severe weather conditions procedure 

• develop procedures for replenishing diesel fuel 
Appendix M 

NUREG-1917, SEIS M-10 February 2010 

• increase frequency for valve leak-testing 

• improve inspection of rubber expansion joints on the main condenser. 

Such SAMAs generally involve procedures that would not have been developed for a reactor 

and are typically not developed until construction has been completed and the plant is 

approaching operation. Based on the staff evaluation, none of these SAMAs could reduce the 

CDF or risk to zero for an ESBWR at the NAPS site. Therefore, they likely would not be cost 

effective if the procedures that are referenced actually existed. 

Dominion stated in its Environmental Report (Dominion 2009) that it will consider the procedural 

and administrative SAMAs when it is developing its procedures, as long as they do not exceed 

the maximum averted cost. It is the staff expectation that risk mitigation will be considered in 

development and implementation of procedures and training programs. Further, the staff notes 

that the cost of implementing risk mitigation measures during procedure development is 

significantly less expensive than modifying existing procedures to include comparable mitigation 

measures. Dominion has also stated, and regulations require, that programs and procedures 

be in place prior to loading fuel into the reactor. 

M.3.3 Conclusions 

Based on its evaluation of the ESBWR PRA (GEH 2009b), the ESBWR SAMDA analysis 

(GEH 2007), and its independent review and update of the severe accident consequence 

assessment performed as part of the North Anna ESP review, the NRC staff concludes that 

there are no ESBWR SAMDAs that would be cost beneficial at the NAPS site. The staff further 

concludes that detailed consideration of procedural SAMAs should be deferred until procedures 

and training programs are being developed. The staff has a reasonable expectation that risk 

mitigation measures will be considered when procedures and training programs are developed, 

and that procedure development will be completed prior to loading fuel into the reactor. 

M.4 References 

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

Certifications, and Approvals for Nuclear Power Plants.” 

51 FR 30028. August 21, 1986. “Safety Goals for the Operation of Nuclear Power Plants; 

Policy Statement; Correction and Republication.” Federal Register. U.S. Nuclear Regulatory 

Commission. 

Dominion Virginia Power (Dominion). 2008. North Anna 3 Combined License Application. 

Revision 1, December 2008. Accession No. ML090570781.
Appendix M 

February 2010 M-11 NUREG-1917, SEIS 

Dominion Virginia Power (Dominion). 2009. North Anna 3 Combined License Application, 

Part 3: Applicants’ Environmental Report – Combined License Stage. Revision 2, July 2009. 

Accession No. ML092160490. 

General Electric Nuclear Energy (GE). 1995. Technical Support Document for the ABWR. 

25A5680, Revision 1. 

General Electric Nuclear Energy (GE). 2006. ESBWR Design Certification Probabilistic Risk 

Assessment. NEDO-33201, Revision 1. Accession No. ML063390519. 

GE-Hitachi Nuclear Energy (GEH). 2007. ESBWR Severe Accident Mitigation Design 

Alternatives. NEDO-33306, Revision 1. Accession No. ML072390051. 

GE-Hitachi Nuclear Energy (GEH). 2008a. ESBWR Design Control Probabilistic Risk 

Assessment. NEDO-33201, Revision 3. Accession No. ML081920299. 

GE-Hitachi Nuclear Energy (GEH). 2009a. ESBWR Standard Plant Design Certification 

Application Design Control Document, Revision 6, Tier 1 and Tier 2. August 31, 2009. 

Accession No. ML092680651. 

GE-Hitachi Nuclear Energy (GEH). 2009b. ESBWR Design Certification Probabilistic Risk 

Assessment. NEDO-33201, Revision 4. Accession No. ML092030199. 

Limerick Ecology Action vs. NRC, 869 F.2d 719 [3rd Cir. 1989]. 

U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation 

Handbook, Final Report. NUREG/BR-0184, NRC, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the 

U.S. Nuclear Regulatory Commission. NUREG/BR-0058, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2006. Environmental Impact Statement for 

an Early Site Permit (ESP) at the North Anna ESP Site. NUREG-1811, Washington, D.C. 

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(9-2004)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

 (Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-1917

3. DATE REPORT PUBLISHED

MONTH

February

YEAR

2010

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

Supplemental Environmental Impact Statement for the Combined License (COL) for North Anna

Power Station Unit 3 

Final Report

5. AUTHOR(S)

See Appendix A of this report.

6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

Division of Site and Environmental Review

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

Same as 8 above

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

Docket No. 52-017

11. ABSTRACT (200 words or less)

This supplemental environmental impact statement (SEIS) includes the U.S. Nuclear Regulatory Commission (NRC) staff's

analysis that considers and weighs the environmental impacts of constructing and operating a new nuclear unit (Unit 3) at the

North Anna Power Station (NAPS) site near Mineral, Virginia, and the mitigation measures available for reducing or avoiding

adverse impacts. 

The NRC staff's recommendation related to the environmental aspects of the proposed action is that the combined license

(COL) should be issued. This recommendation is based on (1) Dominion's COL environmental report (ER); (2) the staff's review

conducted for the ESP application and documented in the ESP environmental impact statement (ESP EIS); (3) consultation with

Federal, State, Tribal, and local agencies; (4) the staff's own independent review of potential new and significant information

available since preparation and publication of the ESP EIS; (5) the staff's consideration of comments related to the

environmental review that were received during the review process; and (6) the assessments summarized in the SEIS, including

the potential mitigation measures identified in the ER and in the SEIS.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

North Anna Power Station Unit 3

National Environmental Policy Act

NEPA

Supplemental Environmental Impact Statement

FInal SEIS

Early Site Permit

ESP

COL

Combined License 

New Reactors

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER

Office of New Reactors

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001
l). 

~ 

UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

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